Friday, December 05, 2008

Risk metrics should drive security, without dictating it

How precise do risk measures need to be in order to be of value to an organization? Is it necessary to calculate an annual loss expectancy (ALE) for each type of information security risk in order to justify security decisions? For better or worse, most organizations have settled on a security budget that is a fraction of the overall IT budget, which in mature companies remains a steady proportion of annual revenue.

Given the challenge of putting together credible loss numbers across the range of identified threats against the organization, it doesn’t make much sense to try to optimize budgets purely against a risk forecast. Instead, security is best treated as a constraint in decisions to optimize revenue, operating costs, profit or other key measures. Protection for critical assets needs to cross an “adequacy” threshold. Conversely, when changes stress or stretch protection capabilities to the point of exposing critical assets to threats, the information security function begins raising the case for change.

So if risk management is more about being on the right side of a threshold, as is literally specified in the EU Privacy Directive / US Safe Harbor guidance, then precision is not nearly as important as confidence. Polling organizations such as Gallup provide a margin of error of 2% because the difference between winning and losing a contest is often very close. But in contrast, safety and security based decisions i.e. “we need to act, now” can become clear with margins of 10-15% or more. As an example, if the brakes on the family minivan squeak and start slipping, its time to get them replaced.

With the help of a few reasonable, simplifying assumptions, it is possible to make trustworthy risk-based decisions based on just two critical metrics: security control coverage, and information asset exposure.

These assumptions are as follows:
1. The impact of security incidents are best characterized in financial terms, i.e. information security incidents have the potential to affect current and/or future costs, and current and/or future sales. (Health and safety critical environments are an exception that should be treated differently.)
2. The value that IT security provides to an organization comes from decreasing the frequency and severity of security incidents by:
a. Preventing incidents from occurring whenever possible
b. Detecting relevant events where and when they occur, and mobilizing an effective response to minimize the damage and restore normal operation as quickly as possible.
3. Security control coverage is a leading indicator of risk to information systems, business processes and data.

Based on these assumptions, two key metrics for decision makers can persuasively frame the security “threshold” decision without requiring an unreasonable level of precision:
1. Information asset exposure: a measure of the relative contribution of that asset to the current and future revenue of the organization.
2. Security control coverage: a measure of the number and type of industry best practice recommendations implemented independently as layers of protection on each asset and process owned or used by the organization to serve its customers and stakeholders.

As an example, consider a company with $120 million in annual sales, $150 million in assets, 500 employees, tens of thousands of current and former customers, Market capitalization of $110 million, and an operating margin of about 18%. Based on these estimates, here’s a quick back-of-the-envelope estimate of the scale involved in information protection decisions:

$120 million in annual sales works out to about $330,000 per day or between $10,000 and $25,000 per hour. So to this company, the loss of several hours of downtime from a key system or systems, plus incident handling costs and lost worker time, etc. can run between $150,000 to $200,000.

According to a 2006 report from the Association of Certified Fraud Examiners, the median fraud loss for asset misappropriation (skimming, payroll fraud or fraudulent invoicing) is $150,000.

Forrester estimates that a privacy breach cost between $90 and $305 per record to address; the Ponemon Institute provides a similar number. Based on those estimates, losing personal information on 5,000 customers would result in costs of between $500,000 and $1,000,000.

Asset exposure, described as a fraction of revenue, is a linear function: the longer the downtime, or more records exposed, the higher the cost. But as described in an earlier post, security is not linear. In a population of systems connected by trust relationships, a failure in server A will lead to a compromise of server B, C, D and on down the line.

Earlier this year, Verizon published a Data Breach Investigation Report based on follow-up on over 500 cases in a four year period. While there’s much to take away from the results, two measures stand out in terms of shaping risk decisions: 85% of identified breaches were the result of opportunistic attacks, and 87% were considered avoidable through reasonable controls. That is; security control coverage provides a strong leading indicator as to the likelihood of experiencing a security breach.

So, given an operating margin of 18% (roughly average for the S&P 500) it could take $5 to $6 of additional revenue to make up for each dollar lost due to a security incident.

Against these measures, determining levels of acceptable risk becomes a much more straightforward exercise without the need for precise risk forecasting. Instead, it becomes a question of risk tolerance: will the extensions to the customer-facing systems generate enough new revenue to justify exposure to some of the scenarios listed above?

Metrics can frame the issues, but ultimately the business has to drive it.