Process Flow for Institutions
. . . and why Dan loves the Cybersecurity Assessment Tool!
Another one of those Dan’s New Leaf Posts, meant to inspire thought about IT Governance . . . .
Real quick: What should you do to get started on understanding the new Cybersecurity Assessment Tool (and its impact on future exams)?
It’s very clear, it’s actually on the front page of their website, and it’s what they are calling “Process Flow for Institutions!”
Process Flow for Institutions:
The FFIEC website is clear about a five step approach to conducting your own Cybersecurity Assessment.
- Read Overview for Chief Executive Officers and Boards of Directors to gain insights on the benefits to institutions of using the Assessment, the roles of the CEO and Board of Directors, a high-level explanation of the Assessment, and how to support implementation of the Assessment.
- Read the User’s Guide to understand all of the different aspects of the Assessment, how the inherent risk profile and cybersecurity maturity relate, and the process for conducting the Assessment.
- Complete Part 1: Inherent Risk Profile of the Cybersecurity Assessment Tool to understand how each activity, service, and product contribute to the institution’s inherent risk and determine the institution’s overall inherent risk profile and whether a specific category poses additional risk.
- Complete Part 2: Cybersecurity Maturity of the Cybersecurity Assessment Tool to determine the institution’s cybersecurity maturity levels across each of the five domains.
- Interpret and Analyze Assessment Results to understand whether the institution’s inherent risk profile is appropriate in relation to its cybersecurity maturity and whether specific areas are not aligned. If management determines that the institution’s maturity levels are not appropriate in relation to the inherent risk profile, management should consider reducing inherent risk or developing a strategy to improve the maturity levels.
But that ain’t real quick, is it?
By the end of the week, if you can.
(Have I given you enough links?)
The existence of the above five-step approach is why I am falling in love with the Cybersecurity Assessment Tool. (okay, that’s my last link to it.)
I realize banks have such a difficult compliance burden to achieve, so it would be hard to imagine that we can be positive about a new guidance! But this needs to be done. It’s addressing gaps that have always existed in the FFIEC Guidelines.
And at least this time the FFIEC is mapping a flexible route to cybersecurity. Because of the gaps, there are important achievements that need to be addressed as soon as possible. Getting there will be a path not a to-do, so the integration of the Capability Maturity Model approach to “achievement” makes so much sense in the realm of cyber. Check it out . . . . your examination will be based on maturity, not “yes/no.”
And finally, this guidance leaves me relieved to know I was right about two things: 1) it’s based on the NIST Cybersecurity Framework and 2) it was released in June.
Why? Those who have been attending my free webinars on Incident Response know that I have been predicting a new guidance with the above two stipulations. Well, this is that guidance. I’m still not sure if it truly is a guidance, but if you don’t get started soon, you are (in my opinion) dropping the ball.
This is the one guidance that you don’t want to wait for your examiners to get started.
At least visit their page!
Original article by Dan Hadaway CRISC CISA CISM. Founder and Managing Partner, infotex
Dans New Leaf is a fun blog to inspire thought in the area of IT Governance.