Risk Assessment Frameworks Rodney Petersen Government Relations Officer Security Task Force Coordinator EDUCAUSE
Overview Definition(s) of Risk Management & Risk Impact(s) of Risk Enterprise Risk Management ERM Frameworks DHS Risk Management Framework NIST Risk Assessment Framework STF Risk Assessment Framework
Definition of Risk Management Risk management is a scientific approach to dealing with pure risks by anticipating possible accidental losses and designing and implementing procedures that minimize the occurrence of loss or the financial impact of the losses that do occur. (Fundamentals of Risk and Insurance, Vaughan and Vaughan) Meaning: Risk as uncertainty concerning the occurrence of a loss.
Risk Equation Risk = Vulnerability x Threat x Impact *Probability Vulnerability = An error or a weakness in the design, implementation, or operation of a system. Threat = An adversary that is motivated to exploit a system vulnerability and is capable of doing so Impact = the likelihood that a vulnerability will be exploited or that a threat may become harmful. *Probability = likelihood already factored into impact.
Types of Risk Strategic – Goals of the Organization Operational – Processes that Achieve Goals Financial – Safeguarding Assets Compliance – Laws and Regulations Reputational – Public Image
Responses to Risk Severity Frequency High Transfer Avoid Low Accept Accept/Transfer
Enterprise Risk Management (ERM) A process, effected by an entity’s board of directors, management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risks to be within its risk appetite, to provide reasonable assurance regarding the achievement of entity objectives. (COSO) A rigorous approach to assessing and addressing the risks from all sources that threatent he achievement of an organization’s strategic objectives. In addition, ERM identifies those risks that represent corresponding opportunities to exploit for competitive advantage. (Tillinghast-Towers Perrin consultancy group) Any issue that impact an organization’s ability to meet its objectives. (Developing A Strategy to Manage Enterprisewide Risk in Higher Education, NACUBO)
ERM Frameworks COSO’s ERM – Integrated Framework Australia/New Zealand Standard – Risk Management ISO Risk Management - Draft Standard The Combined Code and Turnbull Guidance A Risk Management Standard by the Federation of European Risk Management Associations (FERMA)
COSO Integrated Control Framework Committee of Sponsoring Organizations of the Treadway Commission (COSO)
COSO’s ERM – Integrated Framework Entity objectives can be viewed in the context of four categories: Strategic Operations Reporting Compliance ERM considers activities at all levels of the organization: Enterprise-level Division or subsidiary Business unit processes Committee of Sponsoring Organizations of the Treadway Commission (COSO)
Australia/New Zealand Standard (ASS/NZS 4360:2004) – Risk Management
ISO Risk Management - Draft Standard
The Combined Code and Turnbull Guidance Risk assessment Does the company have clear objectives and have they been communicated so as to provide effective direction to employees on risk assessment and control issues? For example, do objectives and related plans include measurable performance targets and indicators? Are the significant internal and external operational, financial, compliance and other risks identified and assessed on an ongoing basis? These are likely to include the principal risks identified in the Operating and Financial Review. Is there a clear understanding by management and others within the company of what risks are acceptable to the board?
A Risk Management Standard by the Federation of European Risk Management Associations (FERMA)
Risk Management Framework for Critical Infrastructure Protection National Infrastructure Protection Plan, 2006
NIST Risk Management Framework Define criticality /sensitivity of information system according to potential impact of loss FIPS 199 / SP 800-60 CATEGORIZE Information System Starting Point SP 800-37 / SP 800-53A FIPS 200 / SP 800-53 SELECT Security Controls Select baseline (minimum) security controls to protect the information system; apply tailoring guidance as appropriate MONITOR Security Controls Continuously track changes to the information system that may affect security controls and reassess control effectiveness SP 800-37 AUTHORIZE Information System Determine risk to agency operations, agency assets, or individuals and, if acceptable, authorize information system operation SP 800-53 / SP 800-30 SUPPLEMENT Security Controls Use risk assessment results to supplement the tailored security control baseline as needed to ensure adequate security and due diligence Determine security control effectiveness (i.e., controls implemented correctly, operating as intended, meeting security requirements) SP 800-53A ASSESS Security Controls Document in the security plan, the security requirements for the information system and the security controls planned or in place SP 800-18 DOCUMENT Security Controls Implement security controls; apply security configuration settings IMPLEMENT Security Controls SP 800-70
Risk Assessment Framework – Security Task Force Purpose of Framework: to provide a high-level overview on the subject of conducting a risk assessment of information systems within higher education. Points to Consider: Risk Assessment (RA) is an ongoing process RA requires strong commitment from senior administration and collaboration between cross-functional units RA is part of strategic and continuity planning RA requires planning and strategy that systematically increases the scope RA needs to become a part of the culture of the university community Effective Risk Management (RM) practices require a "risk aware" culture Effective RM can provide the basis for prioritizing and resolving possible funding conflicts policy supporting ongoing risk assessment should be developed
Phases of Risk Assessment Phase 0: Establish Risk Assessment Criteria for the Identification and Prioritization of Critical Assets (a one-time process) Phase 1: Develop Initial Security Strategies Phase 2: Technological View - Identify Infrastructure Vulnerabilities Phase 3: Risk Analysis - Develop Security Strategy and Plans
Phase 0: Establish Risk Assessment Criteria Goal: to quickly establish the overall criteria for the identification of critical data assets and their appropriate priority level and to obtain senior management's perspective on issues of strategic importance. Process 1: Establish Risk Assessment Criteria Process 2: Apply the Critical Asset Criteria to Classify Data Collections and Related Resources
Phase 1: Develop Initial Security Strategies Goal: Once the information assets have been classified, strategic planning for the rest of the risk management process can begin. Vulnerabilities can be identified, and the process of mitigating the threats that can exploit those vulnerabilities can begin. An institution can decide to specifically focus on the very highest risks, or it may decide to focus first on mitigating risks broadly (or both). The mere process of bringing management together to discuss the organization's strategy about risk mitigation can be extremely fruitful. Process 1: Strategic Perspective - Senior Management Process 2: Operational Perspective - Departmental Management Process 3: Practice Perspective – Staff Process 4: Consolidated View of Security Requirements
Phase 2: Identify Infrastructure Vulnerabilities Goal: To identify areas of potential exposure associated with the systems architecture. Process 1: Evaluation of Key Technology Components Process 2: Evaluation of Selected Technology Components
Phase 3: Develop Security Strategy and Plans Goal: After identifying key information systems resources and evaluating the degree of vulnerability with the systems, quantitatively determine the level of risk associated with each system and system component. This information may then be used to prioritize the allocation of resources to ensure appropriate mitigation of the highest risks and to make appropriate management decisions about the degree of risk that the organization will be willing to accept. Process 1: Risk Assessment Steps 1. Assess the potential impact of threats (and vulnerabilities) to critical assets (qualitative and/or quantitative) 2. Evaluate the likelihood of occurrence of the threats (high, medium, low) 3. Create a consolidated analysis of risks, based on the impact value to critical assets and the likelihood of occurrence Process 2: Protection Strategy and Mitigation Plans
Conclusion It is important to note that this is a process that has no finish line. While a risk assessment - the process of identifying and quantifying risks - might take place on an infrequent basis (e.g., annually), the risk management process - the ongoing process of mitigating the risks to the organization - should be ingrained into the institution's culture to be most effective.