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Risk Management is being aware of and taking actions to prepare for probable unfavorable outcomes.
Risk Management Framework is a process the implement risk management in an organization.
There are (6) steps to the RMF:
1. Categorize
2. Select
3. Implement
4. Assess
5. Authorize
6. Continuous Monitoring
More on the Risk Management Framework Steps here:
http://diarmfs.com/risk-management-framework-steps/
The Federal Communication Commission (FCC) Communications Security, Reliability and Interoperability Council (CSRIC) developed a Cybersecurity Risk Management and Best Practice Final Report dated March 2015.
The 400 page document discusses voluntary mechanisms that give the Federal Communications Commission (FCC) and the public assurance that communication providers are taking the necessary measures to manage cybersecurity risks across the 5 major parts of communications: broadcasting, satellite, cable, wireless and wireline.
The document also details implementation guidance to help communication providers adapt to NIST Cybersecurity Framework. The NIST Cybersecurity Framework was created to satisfy the President’s Executive Order 13636 – Improving Critical Infrastructure Cybersecurity.
Each of the 5 major components of FCC communications ( broadcasting, satellite, cable, wireless and wireline) have been be treated as critical infrastructure and evaluated by the NIST Cybersecurity Framework.
The segment and feeder subgroup findings and resulting NIST Cybersecurity Framework implementation guidance are contained in the appendices to this report. – more info here
Other documents with risk management principles include NIST SP 800-39, and NIST SP 800-30.
The principle of risk management center around looking at corporate risk. What is the risk to the bottom-line of the organization? Whether the bottom-line is money, reputation, a mission, or process. How will the organization address risk from the top down? Risk is addressed at every level of the organization from the very top to the bottom. NIST 800-39 breaks this all down in tiers.
To address the actual risk and organization must be able to predict the likelihood of a harmful event (threat) adversely affecting an asset vulnerability.
Risk = ((Vulnerability * Threat) / Countermeasure) * Asset Value at Risk IT Risk
An organization uses a quantitative approach to analyzing and managing the risk to its resources. To do this, they must identify the threat, the asset, the vulnerability and countermeasures (security controls) of the asset. They must determine the level of impact that the organization would suffer if the harmful event occurs. To determine all this they must do risk assessments.
You should deal with business risk BEFORE disaster strikes.
Business risk deal with negative impacts to an organizations bottom line. If harm should strike exposed weaknesses, the business needs to know how they will deal with it and how do they adjust to the situation.
A Business Impact Analysis (BIA) is sometimes done to identify the threats, vulnerabilities, assess, the likelihood of threats acting on identified weakness and the impact if they do. DIARMF pulls for NIST and the NIST is robust enough to address address BIA / business risks. The main documents dealing with business risks are 800-39, 800-30, and 800-34.
NIST SP 800-39, Manage Information Security Risk deals with the process of business risks by way of explaining the risk management necessary for an organization.
NIST SP 800-30, Guide for Conducted Risk Assessment describe the tasks and steps of business impact assessments:
A Business Impact Analysis (BIA) identifies high-value assets and adverse impacts with respect to the loss of integrity or availability. DHS Federal Continuity Directive 2 provides guidance on BIAs at the organization and mission/business process levels of the risk management hierarchy, respectively.
NIST Special Publication 800-34 provides guidance on BIAs at the information system level of the risk management hierarchy.
One of the biggest business risks capture while doing business impact assessments is interruptions of service. After all, if the business is not DOING business then mission, work and revenue stop. So the business/organization and or department must have a contingency plan. NIST Special Publication 800-34, Contingency Planning Guide for Federal Information Systems covers what to do in case of interruptions.
A contingency plan covers what to do in the event of service disruptions including procedures, and technical measures that can get systems back quickly for a while until the disruption passes. NIST 800-34 covers information system contingency plans (ISCPs) who documents them and how. This is also a major part of the security controls addressed in 800-53/DIARMF.
NIST SP 800-39 deals entirely with fixing the challenge of security risk in an organization. Chapter 2 of 800-39 discusses the basics of security risk management & chapter 3 goes into the process of applying security risk management across and organization.
The Fundamentals of Security Risk Management (Chapter 2, 800-39)
The philosophy security risks and how to manage information security at multiple levels of an organization are discussed in Chpt 2 of NIST SP 800-39. The three layers of security risk are:
Tier 1: Organization Level security risk management
Tier 1 addresses security risk from the organizations perspective. This include the implementation of the first component of security risk management which is called risk framing.
In tier 1 or security risk management, the management of the organization establishes governance structure that are in compliance with laws, regulations and policies. Tier 1 activities include establishment of the Risk Executive Function, establishment of the risk management strategy and determination of the risk tolerance.
Security Risk framing provides context for all the security risk activities within an organization, which affects the risk tasks of tier 1 & 2. The result of risk framing is Security Risk Management Strategy.
Security Risk Management Tier 2: Mission/Business Process
Tier 2 Security risk management tasks include: 1) defining the mission processes. 2) Prioritize the mission process with respect to the long term goals of the organization. 3) Define the type of information needed to successfully execute the mission/business processes, critical/sensitivity of the information and the information flows both internal and external of the information.
Tier 3: Information System Security Risk management
From the information system perspective, tier 3 addresses the following tasks:
Chapter 3 focuses on the step to have a comprehensive security risk management program. The tasks discussed include:
Risk Assessment
NIST 800-30 goes into Risk Assessment process. 800-39 covers from a high level. Risk assessment is threat & vulnerability identification and risk determination. Organizational risk framing is a prerequisite to risk assessments, because methods of risk assessment must be established by the contexts of the organizations risk.
Risk Response
Risk response identifies, evaluates, decides on, and implements appropriate courses of action to accept, avoid, mitigate, share, or transfer risk to organizational operations and assets, individuals, other organizations, and the Nation, resulting from the operation and use of information systems.
Risk identification is key to risk response. Risk types include:
Risk accept- is the appropriate risk response when the identified risk is within the organizational risk tolerance. Organizations can accept risk deemed to be low, moderate, or high depending on particular situations or conditions.
Risk avoidance– Organizations may conduct certain types of activities or employ certain types of information technologies that result in risk that is unacceptable. In such situations, risk avoidance involves taking specific actions to eliminate the activities or technologies that are the basis for the risk or to revise or reposition these activities or technologies in the organizational mission/business processes to avoid the potential for unacceptable risk.
Risk mitigation-adding management, technical, administrative safeguards to minimize identified risks to the system.
Risk share & transfer- Risk sharing or risk transfer is the appropriate risk response when organizations desire and have the means to shift risk liability and responsibility to other organizations. Risk transfer shifts the entire risk responsibility or liability from one organization to another organization (e.g., using insurance to transfer risk from particular organizations to insurance
companies).
Risk Monitoring Risk changes with each modification of the system. It’s important to monitor the changes of the risk of a system. Changes to threats can also change risk. This is where Continuous monitoring comes in.
Risk mitigation can only be done by first identifying the risk. And risk identification can only be done by characterization of the assets, discovery of vulnerabilities of those assets and determination of threats and/or possible harm to that system.
So risk mitigation is based on the results of risk assessments.
Risk assessment is a 9 step process.
1) System characterization – a system is an organization asset. So the first step is to discover all the features of that system and understand why it is important.
2) Threat Identification – risk is determined by the likelihood of a threat affecting the weakness of an asset. To limit the risk (risk mitigation), a security practitioner must determine the possible threat, find the weakness and then come up with a way to protect that system.
3) Vulnerability Identification – The security practitioner (information system security officer, information system security analyst, system security engineer etc) must find the weakness of a system.
4) Security Control Analysis – The security control protecting the vulnerability is the actual risk mitigation. Analysis is determining what is needed, when and how much it will cost.
5) Likelihood determination – The importance of risk mitigation is directly proportionate to the likelihood of the threat impacting the organization and its assets vulnerabiltiy.
6) Impact Analysis – The bottom line of risk is the impact that will occur if harm should come to an asset. If the asset ceases to function, what happens to the organization? That question should drive how and why risk is mitigated.
7) Risk Determination / Risk Identification – Based on all the data gathered you can make a pretty good risk determination. You should have defined the systems components and what data is important, made a pretty good conclusion on threat sources and likelihood of the vulnerability exploits and know exactly what kind of impact there will be if the system goes down.
8) Control Recommendation – This is where the actual RISK MITIGATION comes in. All data is gathered from the risk assessment and risk has been identified and evaluated. Risk is mitigated by applying to correct security controls.
9) Results Documentation – The mitigation of risk must be documented for future reference. Sometimes it can only be mitigated later and documented in a Plan of Action and Milestone.
Who does Mitigates the Risk:
First of all, risk cannot always be mitigated. In this cases it is documented in something called a Plan of Action and Milestone (POA&M). And sometimes risk is simple accepted because there is just nothing that can be done. The mitigation of risk is the responsibility of the system owner. The system owner will sometime have a right hand adviser on matters of security, a Chief Security Officer who is not afraid to say NO and will always give the system owner (CIO) the facts no matter how gruesome. The CSO (or equivalent) delegates risk mitigation (implementation of security controls) to security practitioners (DoD 8140 compliant professionals) who hopefully know what they are doing.