Is it time for your business to have an external security audit?
Posted by : Mary E. Shacklett
Computer and network security is a pervasive
concern for everyone--even those who are not in tightly regulated
industries that demand lockdowns of communications and information. At
the same time, most IT staffs already have more day to day projects than
they can handle. They lack internal expertise that can be applied to
security evaluations and on some IT staffs, there is even active
resistance.
The easiest thing to do is throw the security audit
"over the fence" and into the hands of an outside auditor who can tell
you where you have controls missing and technology exposed. But if you
are a small to medium-sized company, the issue is often affordability.
What can you do to address IT security with the internal resources that
you have available--and at what point do you look for an outside
security audit?
We'll review both options, presenting the elements
you need to be successful in your own security approach--and when to
make that step to retain an outside security auditor.
The top
security audit issues
IT security audit pressures vary between
industry sectors. If you are running an IT network in government,
finance or healthcare, you are already tightly regulated for security
breaches and information sharing. Your company probably receives a visit
from an IT regulator or examiner every twelve to eighteen months. There
is pressure to comply because if you are found out of compliance, it can
have career repercussions.
High technology businesses also have
security pressures, but these are more self-imposed. For these
businesses, the leak of critical intellectual property from a computer
network can bring down an entire organization. On the other hand, mom
and pop businesses, manufacturing and fabrication facilities, hardware
stores and auto parts dealerships have less security regulation and
fewer fears of intellectual property theft. Security demands can be low.
"We find overall that the amount of industry regulation plays a
major role in companies' network security efforts," says Stuart
Chontos-Gilchrist, president of E3 Technology , an IT
security auditing and design firm. "For companies not operating in
highly regulated industries, it's often a matter of whether you choose
or don't choose to create industry best practices in security. Financial
and healthcare companies are highly regulated, and must focus on IT
security. Publicly traded companies that are subject to Sarbanes-Oxley
reporting requirements also need to focus on the security aspects of
their operations. However, there are still many smaller companies that
manage to "fly under the radar" of industry security
focuses."
Chontos-Gilchrist says that important focal issues for
any professionally conducted IT security audit begin with the area of
vendor management, and the policies and procedures that form the basis
of a company's entire IT security program. Related to this are the
company's disaster recovery and business continuation plans, and the
security-related solutions and technologies that are deployed in the
company, such as security software on all desktop computers, intrusion
prevention, and effective patch and change management procedures for
the software that the company runs. If all of these areas are tightly
controlled and up to date, the company's security measures are quite
likely to be effective.
However, IT security is a process and not
a one-time project. Someone has to continually monitor security trends,
and then take steps to ensure that the company's networks remain
bullet-proof. Companies can begin with an internal person who assumes
the IT audit responsibility, or they can opt to outsource the function
for periodic third party reviews.
Handling security audits
internally
Companies that address IT security audits
internally look to either their accounting or their IT areas for an
individual who can shoulder the security audit responsibility.
"Usually, a company will have someone who already is an internal auditor
conduct the security audits for IT," says Chontos-Gilchrist. "The
company wants to do the best job of auditing that it can with its
available internal resources, and often these resources come from
Finance. This can be a disadvantage to IT, because a financial person
may not have the specialized background in IT security. On the other
hand, there are segregation of function issues if you have an IT person
perform IT security audits, and that same person is responsible for
administering IT security on a day to day basis."
In both cases,
unless the company is very large, there are battles between audits and
other workload priorities--and audits are not addressed in a timely
manner. There is also the danger of too much familiarity if the same
auditor examines IT security year after year. It is hard to stay fresh
to perceive all of the possible issues. To prevent this excess
"familiarity" from occurring, many organizations cycle their internal
auditors through a variety of company audits, and these corporate
auditors frequently work in conjunction with different external auditors
on the various corporate audit areas.
"Companies turn to an
outside party to perform their security audits after they reach a
certain size that allows for a security budget," says Chontos-Gilchrist.
"While there are exceptions, in the financial market we typically see
banks, credit unions and others look for outside IT security audits when
they reach an asset level of 100 million dollars or more. For private
companies, this threshold is usually around 70 million dollars in annual
sales."
If you choose to utilize an internal auditor for your IT
security, look for someone with an IT security skillset. Minimally, the
person should have three or four years of IT technical experience--and
his function should be segregated from the roles of in-house security
technicians and administrators.
Some companies adopt the approach
of training a financial auditor "on the job" in IT security audits.
This is risky, because an individual with a financial background may not
know all of the areas he needs to be concerned with when it comes to
checking systems and networks for security. For this reason, larger
companies that have internal audit teams have a separate audit team for
finance/operations and a separate team that addresses IT.
Formal
IT security certifications like the CISSP and CISP are also important as
training and qualification criteria--but an non-credentialed individual
who knows the ins and outs of the system and of IT security can be just
as effective.
"In the end, companies are driven by regulations
and financial incentives," says Chontos-Gilchrist. "If there's not a
regulatory or financial incentive, companies will often do the minimum
for their IT security. We've seen this in the large retail market, when
the minimum is done until the regulator steps in. From a security
standpoint, this is where regulations like Sarbanes-Oxley make a
difference."
When to conduct an outside IT security
audit
Even large companies that have internal audit functions
opt to perform IT audits using external experts. This is because a third
party sees the networks with a fresh eye. The third party is up to speed
on the latest security trends and regulations. It can suggest remedies
for network and system weaknesses--and it can offer an objective
perspective that is impossible to obtain from within the company.
"When we find a company that has issues in its IT security, it is
often an IT staff training issue," says Chontos-Gilchrist. "On the
average, we only find about 20 percent of the companies that we audit
are adequately prepared for the IT security responsibilities they are
charged with."
Minimizing the expense
Outside IT
security audits cost money, and are frequently at risk when it comes to
budget cuts. An IT security audit also does not offer a magical formula
when it comes to measurable return on investment (ROI). Instead, IT
audits are defensive measures. Audits are about prevention and
detection, and sites should assess what is the worst thing that could
happen if there is a security breach, and then present this to
management as part of their risk mitigation strategies.
There are
also other cost conservation strategies that can be applied to external
audits.
Ask the external auditors bidding on your IT security
audit to provide you with several options for the audit. Sometimes, it
is possible to divide the work into phases, such as intrusion detection
testing, or a separate policy and procedure review. This allows you to
calibrate your security work to your budget and to pay as you
go.
Finally, organize as much documentation as possible before the
auditor arrives, and do what you can to have the documentation in
electronic form. "The most efficient and cost-effective audits are those
where the client has organized all of his security information and
documentation into a single binder, or in a consolidated electronic
format," says Chontos-Gilchrist. "An electronic format for documentation
is the best, because it allows your external auditor to perform quick
searches on topics....In the end, an audit is about proving that a
company is already doing what it is supposed to do. Well developed and
well organized security documentation goes a long way in this process."
When do you look to the
outside for an IT security audit? Here is a list of 10 telltale
signs:
* When there are new industry regulations your
company will be subject to. New regulations to comply with mean
tight deadlines for compliance. An outside regulator has already met
with the compliance agency and has read through all of the
documentation. If there is a massive regulatory mandate in your
industry, you can pre-empt the possibility of a poor regulatory audit
by having a third party auditor in beforehand to assess your networks,
and to make recommendations on how you can bring networks and systems up
to speed for the latest regulatory environment.
* When you
need an outside assessment because there's the possibility of internal
compromise. Not only is security compromise bad--it is even worse
when the company is aware of the possibility of internal fraud or
compromise and does not seek outside help. Outside help is important
because you need someone who is absolutely impartial to the entire audit
fact finding process. You also could be held liable if you allow an
internal person perform the audit who might have had a role in the
system or network breach.
* When you want to check your
internal security measures. Most ITers don't enter the profession
with the idea of becoming an internal IT security auditor. Instead, some
grow into that position over time. Along the way, they have held (or
still hold) other IT duties. Most pick up the security function along
the way, and are not trained experts in security-- although they might
be the company's "resident experts." When first establishing your IT
security function, it is smart to retain an outside auditor to review
your system and to make recommendations. Even if you never engage
another outside auditor, the expert review and recommendations will go a
long way in setting the stage for your own security
priorities.
* When you are large enough and have available
budget. This is what most companies wait for--the budget for a
third party security review. For financial institutions, this means an
asset size of $100 million or better. For private sector companies,
company size is generally around $70 million in sales or more. There are
also many smaller organizations who opt for outside IT audits because of
the information sensitivities of their businesses, or tight industry
regulations that they must comply with.
* When you want strong
security practices. Most companies don't start out with IT security
expertise on board. Obtaining an outside audit by a third party is an
excellent way to get started. It will furnish you with a roadmap of what
you need to do to optimally secure your systems and networks.
*
When you bring on a new technology with high or unknown risk potential.
Implementing a wireless network is a good example. Using an outside
auditor to help you establish a security risk mitigation strategy prior
to implementation is an excellent practice.
* When you have
intellectual property or customer information protection requirements.
If you are in these categories, you might also be tightly
regulated. It is a good idea to conduct an external audit.
*
When you don't have internal resources. You can outsource your IT
security audits, and still meet your security needs.
* When
your business risk assessment dictates that you do something about
security. If you do not have the resources to address the security
shortcomings internally, you can hire an outside security firm or
auditor to assist you.
* When you want to design for security.
An external audit resource can assist you in developing security
policies and procedures, and can provide security training to your IT
staff.
Mary E. Shacklett is president of Transworld Data, a marketing
and technology practice for technology companies and
organizations.
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