Security Management Strategies for the CIO
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McKesson's SOX program leverages the ISO 27001 standard for information security management and the COBIT framework for IT management and metrics. Sapp says his organization has deployed Brabeion IT GRC suite to manage policies and map multiple regulations, such as PCI and HIPAA, to control frameworks. But he believes a collaboration of tools will ultimately meet McKesson's needs to get to integrated GRC and he is evaluating several other tools such as asset management and configuration management databases (CMDB). SOX, PCI and HIPAA are McKesson's three largest compliance issues, and the company's SAP environment, which it uses for its financials, is the primary area of concern. "We found many parallels where one piece of ISO will satisfy parts of each one of those regulations," Sapp says. Access controls, for example, are codicils of each of those regulations. "ISO allows us to map across that and ensure by meeting that one ISO objective, I can test once, and certify many [times]. If I'm using the same access control process across each one, then I can reduce the amount of testing I do. That's what I've been able to do with our SOX program. I can drastically reduce the amount of time we spend in audits because we have improved our process so much. We're getting through audits in what I would call record time and within our budget." Sapp's |
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| current evaluation of GRC tools, he hopes, will further put out to pasture the tedious, laborious manual processes in place for collecting data from business units, testing and mapping controls to particular regulations. With 200-plus controls applicable to the SOX program, Sapp says that was his first target for automation with the Brabeion tool.
"We looked to an automated tool to help us be able to test the controls, attach the evidence and keep the user from going to the next step," he says. "I had one user tell me we've improved the quality of life here. We actually used SharePoint prior to automation, but the workload isn't there that you get in these tools." Sapp says the GRC tools he's seen do a fine job of defining the assets and entities of an organization. He says they are solid for analyzing workflow and creating dependencies; this kind of intelligence can be applied outside of GRC as well. He adds that the tools are sound for collecting asset information (e.g., identifying unsupported or expiring versions of software), which helps in a risk assessment. Finally, he says the dashboard facilities are a strong means of providing a risk picture to the C-level. In contrast, he says some tools try to do too much, and don't do very much very well. Products billed as turnkey, full-enterprise GRC programs sometimes suffer from poor workflow because of misguided focus. "Vendors sell hard on the tool rather than getting you to step back and look at process and strategy," Sapp says. "They don't think process and strategy first; they throw this toolset at you and say this will solve all your problems." Forrester's Othersen says the tools at their core address compliance well, mapping sources, automating manual tests and providing solid reporting. Where they fail is in not linking IT risk to business risk. "They don't have a business perspective in their risk engines," Othersen says. "All of them are IT focused, yet most risk happens in the line of business. If you lose credit card numbers, the line of business pays, not IT. Translating IT control failures into business risks is one of the biggest failings of those packages." He adds that they don't address governance, either. "It's up to you as a CIO or security manager to use the tool to collect and analyze data on your own."
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This was first published in September 2008
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