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Managing Risk in Information Technology
As information technology increasingly falls within the scope of corporate governance, so management must increasingly focus on the management of risk to the achievement of its business objectives.
There are two fundamental components of effective management of risk in information and information technology: the first relates to an organization's strategic deployment of information technology in order to achieve its corporate goals, the second relates to risks to those assets themselves. IT systems usually represent significant investments of financial and executive resources. The way in which they are planned, managed and measured should therefore be a key management accountability, as should the way in which risks associated with information assets themselves are managed.
Clearly, well managed information technology is a business enabler. Every deployment of information technology brings with it immediate risks to the organization and, therefore, every director or executive who deploys, or manager who makes any use of, information technology needs to understand these risks and the steps that should be taken to counter them.
ITIL, the Information Technology Infrastructure Library, has long provided an extensive collection of best practice IT management processes and guidance. In spite of an extensive range of practitioner-orientated certified qualifications, it is not possible for any organization to prove - to its management, let alone an external third party - that it has taken the risk-reduction step of implementing best practice.
More than that, ITIL is particularly weak where information security management is concerned - the ITIL book on information security really does no more than refer to a now very out-of-date version of ISO 17799, the information security code of practice.
The emergence of the international IT Service Management (ISO 27001) and Information Security Management (ISO20000) standards changes all this. They make it possible for organizations that have successfully implemented an ITIL environment to be externally certificated as having information security and IT service management processes that meet an international standard; organizations that demonstrate - to customers and potential customers - the quality and security of their IT services and information security processes achieve significant competitive advantages.
Information Security Risk
The value of an independent information security standard may be more immediately obvious to the ITIL practitioner than an IT service management one. The proliferation of increasingly complex, sophisticated and global threats to information security, in combination with the compliance requirements of a flood of computer- and privacy-related regulation around the world, is driving organizations to take a more strategic view of information security. It has become clear that hardware-, software- or vendor-driven solutions to individual information security challenges are, on their own, dangerously inadequate. ISO/IEC 27001 (what was BS7799) helps organizations make the step to sytematically managing and controlling risk to their information assets.
IT Process Risk
IT must be managed systematically to support the organization in achieving its business objectives, or it will disrupt business processes and undermine business activity. IT management, of course, has its own processes - and many of these processes are common across organizations of all sizes and in many sectors. Processes deployed to manage the IT organization itself need both to be effective and to ensure that the IT organization delivers against business needs. IT service management is a concept that embraces the notion that the IT organization (known, in ISO/IEC 20000 as in ITIL, as the "service provider") exists to deliver services to business users, in line with business needs, and to ensure the most cost-effective use of IT assets within that overall context. ITIL, the IT Infrastructure Library, emerged as a collection of best practices that could be used in various organizations. ISO/IEC 20000, the IT service management standard, provides a best-practice specification that sits on top of the ITIL.
Regulatory and Compliance Risk
All organizations are subject to a range of information-related national and international legislation and regulatory requirements. These range from broad corporate governance guidelines to the detailed requirements of specific regulations. UK organizations are subject to some, or all, of:
Combined Code and Turnbull Guidance (UK)
EU data protection, privacy regimes
Sectoral regulation: FSA (1) , MiFID (2) , AML (3)
Human Rights Act, Regulatation of Investigatory Powers Act
Computer misuse regulation
Those organizations with US operations may also be subject to US regulations such as Sarbanes Oxley and SEC regulations, as well as sectoral regulation such as GLBA (4), HIPAA (5) and USA PATRIOT Act. Most organizations are possibly also subject to US state laws that appear to have wider applicability, including SB 1386 (California Information Practice Act) and OPPA (6) . Compliance depends as much on information security as on IT processes and services.
Many of these regulations have emerged only recently and most have not yet been adequately tested in the courts. There has been no co-ordinated national or international effort to ensure that many of these regulations - particularly those around personal privacy and data protection - are effectively co-ordinated. As a result, there are overlaps and conflicts between many of these regulations and, while this is of little importance to organizations trading exclusively within one jurisdiction, the reality is that many enterprises today are trading on an international basis, particularly if they have a website or are connected to the Internet.
A management system is a formal, organized approach used by an organization to manage one or more components of their business, including quality, the environment and occupational health and safety, information security and IT service management. Most organizations - particularly younger, less mature ones, have some form of management system in place, even if they're not aware of it. More developed organizations use formal management systems which they have certified by a third party for conformance to a management system standard. Organizations that use formal management systems today include corporations, medium- and small-sized businesses, government agencies, and non-governmental organizations (NGOs).
Standards and Certifications
Formal standards provide a specification against which aspects of an organization's management sytsem can be independently audited by an accredited certification body and, if the management system is found to conform to the specification, the organization can be issued with a formal certificate confirming this. Organizations that are certificated to ISO 9000 will already be familiar with the certification process.
Integrated Management Systems
Organizations can choose to certify their management systems to more than one standard. This enables them to integrate the processes that are common - management review, corrective and preventative action, control of documents and records, and internal quality audits - to each of the standards in which they are interested. There is already an alignment of clauses in ISO 9000, ISO 14001 (the environmental management system standard) and OHSAS 18001 (the health and safety management standard) that supports this integration, and which enables organizations to benefit from lower cost initial audits, fewer surveillance visits and which, most importantly, allows organizations to 'join up' their management systems.
The emergence of these international standards now enables organizations to develop an integrated IT management system that is capable of multiple certification and of external, third party audit, while drawing simultaneously on the deeper best-practice contained in ITIL. This is a huge step forward for the ITIL world.
(1)Financial Services Authority
(2)Markets in Financial Instruments Directive
(3)Anti-money laundering regulations
(5)Health Insurance Portability and Accountability Act
(6)Online Personal Privacy Act
About the Author: Alan Calder is an international authority on IT Governance and information security management. He led the world’s first successful implementation of BS 7799, the information security management standard upon which ISO 27001 is based, and wrote the definitive compliance guide for this standard, ‘IT Governance: A Manager’s Guide to Data Security and BS7799/ISO17799’. The 3rd edition of this book is the basis for the UK Open University’s postgraduate course on Information Security. He has just written, for BSI, a management guide on integrating ISO 27001 and ISO 20000 Management Systems, drawing heavily on ITIL best practice. He is a consultant to companies around the world, including Cisco.