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Assess Mitigation Practices


Assess Mitigation Practices

The next step is to assess the mitigation strategies that are currently in place and determine what additional mitigation strategies need to be used in order to effectively manage the risks. Controls may include those that form a part of the hierarchy of controls, or they may be the result of transfer of the risk.

Typically, different vulnerabilities and threats will exist within different areas, all contributing to the risks under review. Where appropriate, the assessment of current mitigation may be undertaken by different business areas. For example, mitigating risks associated with access controls is in fact a shared responsibility between IT, business managers and human resources. The risk cannot be isolated and mitigated simply by introducing new software. A process, agreed to by all parties, must be developed and adhered to in order to ensure accesses are terminated , for example, when an individual leaves the company.



Identify Mitigation Categories

Identify the processes that are currently being used to mitigate the vulnerability or threat. Mitigation categories refer to types of controls. The most common controls are:

  • Policy

  • Process

  • Management Practice

  • Guideline

  • Standard Operating Procedures (SOPs)

Other types include:

  • Technical Standard

  • Contract

  • Organization/Council

  • Training

  • Regulation

  • Software Tools

The assessment of current controls should review four key areas:

  • Are there controls in place for this vulnerability or threat? (i.e., Do they exist? )

  • Are these controls properly implemented? (i.e., Are they implemented everywhere they are required? Are they implemented consistently?)

  • Are the controls effective in managing the vulnerability or threat? Have the controls been effective in the past at addressing similar potential risks? Have the potential risks been realized (i.e., have the risks previously matured) in the past?

  • Are there safeguards or compensating controls in place to mitigate this vulnerability or threat? Have these been effective in the past?

Based on the effectiveness of existing controls and in light of the detailed review of vulnerabilities and threats, make recommendations on what else can be done to mitigate vulnerabilities and threats. Additional controls, new processes and/or new technology may be necessary. Obviously the final recommendations incorporated into the risk mitigation plan should present the options felt to offer the optimal value-added return on investment for the resources required and hence deliver the greatest impact to the business.

Once recommendations have been made for all risks, validate that they:

  • are consistent and will address the risks

  • will be acceptable to those, across all business areas, who will work with them on a day-to-day basis

  • do not contradict existing controls or cause negative effects outside the scope

  • are justified in terms of the anticipated costs, potential risk and the anticipated reward



Measure Compliance

Develop Compliance Processes, Methods and Tools

Measuring compliance is critical to the overall success of the entire risk management process. Determine if the risk management methods are actually having a positive impact and be able to measure the extent to which the mitigation controls are in fact being used. Clearly, compliance measurement is somewhat onerous; however, successful implementations depend on how easy the process is and the perception that the process is useful, and will not have a negative impact. Typically, auditors are brought in at this point in the process. The key here is to ensure that the auditors are on-board with the process and their findings will not be used against the organizations being audited . Compliance monitoring should not be viewed as the penalty phase of risk management. This is why it is so important to have a separate risk management function that is a partner with the company s audit team. Consider the following when planning compliance measurement tools:

  • Scope of compliance measurement, that is, who will be measured, where and when measurements are to be taken and possibly by whom.

  • How to perform data capture, for example, self-assessment questionnaires, Web-based tools, interviews, audit results, and metrics returned from execution of routine processes. (Do not underestimate time required to capture data.)

  • How to solicit responses, for example, how to ensure responses are made to questionnaires, how to ensure data are returned as requested .

  • Methods to collate and store the responses.

  • Methods to measure responses, that is, determine how to use the data to measure compliance.

  • Follow-up actions that may be required.

  • Other information may need to be gathered in this initial planning task, including:

  • inventory of what is currently under control, and

  • the conflict resolution process and escalation process.

Summary

Risk management is an important corporate business process and sound management practice. Using IT risk management practices is critical to business success in the e-business age. Using a risk management framework to assess IT risks enables companies to make logical decisions about risk and helps to determine where to use resources to mitigate risks. Finally, and most importantly, using a process like the one described in this chapter does work. The key is to use the process consistently and make it part of the corporate culture.