In a webinar, Steven Chabinsky, Cyber Columnist for Security and General Counsel and Chief Risk Officer for CrowdStrike, discussed NIST’s cybersecurity framework and its future.
NIST’s Framework-work is now law, he said, so it’s here to stay. The Cybersecurity Enhancement Act of 2014, passed into law on December 18, 2014, authorizes NIST to facilitate and support the development of voluntary, industry-led cyber standards and best practices for critical infrastructure – codifying elements of the successful process through which the NIST Cybersecurity Framework was developed.
The Framework is being adopted by some major players and forced onto others, Chabinsky said. For example:
- Intel uses the Framework, and will require its vendors to use the Framework by contract.
- Bank of America uses the Framework and also will require its vendors to use it.
- Apple incorporates the Framework as part of the broader security protocols across its corporate networks.
- Walgreens incorporates the Framework as one of its tools for identifying and measuring risk.
- QVC uses the Framework.
- U.S. Bank; Pacific Gas & Electric; Kaiser Permanente have committed to use the Framework.
- AIG is starting to incorporate the NIST Framework into how it underwrites cyber insurance for large, medium-sized, and small businesses.
The Framework may be “voluntary,” Chabinsky said, but regulators (and litigators) also love it because:
- FTC: NIST framework “is fully consistent with the FTC’s enforcement framework”
- SEC: Some of our questions when conducting examinations of registered entities track the Framework.
- FCC: The NIST Framework proactive risk management approach “is the only workable strategy for securing commercial networks”
How can cyber risk management & NIST help an enterprise? According to Chabinsky:
• The use of Enterprise Risk Management principles to mitigate significant harms to information and information systems relating to:
– Losses of Confidentiality (perhaps PII or Trade Secrets)
– Losses of Integrity (including data accuracy and product/systems reliability)
– Losses of Availability (consider service downtime or data loss)
• Typical ERM cyber strategies include
– Prioritizing what is required, or most important using cost/benefit analysis
– Implementing technical, administrative, and physical controls
– Reducing Threats, Vulnerabilities, and/or Consequences
– Accepting residual risk
– Being prepared to manage an incident
Chabinsky also offered “real lessons” learned about the Framework, which he said include:
- Raises awareness and communication within an organization, including executive leadership
- Improves communications across organizations, allowing cybersecurity expectations to be shared with business partners, suppliers, and among sectors
- Useful as a strategic planning tool to assess risks and current practices
- Core mappings can be used to demonstrate alignment with standards, guidelines, best practices, and, in some cases, regulatory requirements
- Some organizations use the Framework to benchmark performance; others explicitly avoid applying the Framework in this way.
One of the most important and valuable benefits of the Framework pilot project was the internal discussions it helped foster for Intel, Chabinsky explained. Conversations about defining the organization’s Profile to determine the various levels of risk the organization is willing to accept are extremely valuable in aligning and prioritizing an organization’s cybersecurity risk management activities.”
The target score versus assessed score discussions were especially instructive, as they enabled participants to discuss and compare risks across domains in a common language and on common ground. They also helped facilitate agreement between stakeholders and leadership on risk tolerance and other strategic risk management issues, understandings, which in turn, can guide the organization in security project prioritization and funding.
Chabinsky concluded by offering the next steps for NIST. They include:
- NIST will develop material on aligning the Framework with business processes, including integrating cybersecurity risk management with broader enterprise risk management.
- NIST is developing a risk management approach for privacy within the federal government to facilitate better identification of privacy risk in information systems.
You can view this on demand at http://www.securitymagazine.com/events/1089-happy-birthday-nist-cybersecurity-framework