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CHAPTER 1: PROJECT MANDATE
It may be something of a clichĂŠ, but for information security management system (ISMS) projects, it is certainly true to say that well begun is half-way done. The person charged with leading an ISO/IEC 27001:2013 ISMS project has to reduce something that looks potentially complex, difficult, and expensive in terms of time and resources, to something that everyone believes can be achieved in the timeframe allocated and with the resources allowed. And then you have to make sure it is actually delivered!
What this actually means is the ISMS project leader has to set up the project in such a way that it is adequately resourced, there is enough time (including for everything that may go wrong), and everyone understands the risks in the project and accepts the controls that are being deployed to minimize them.
Almost everyone dislikes change; very few people relish dealing with the unknown. Most people will see an ISMS project as something that brings both change and the unknown into their working life, and not everyone will welcome it. Thatâs normalâtheyâll get on board in the end.
The project leader, in the first phase of the project, is the person to whom everyone else in the organization turns for insight, comfort, and support. You have to be the person who provides enthusiasm, certainty, and an understanding of what is involved.
This means learning on the job in a transparent fashion is not advisable. I donât mean you need to know all the answers at the outsetâthat is not realistic. As long as you have a clear understanding of the strategic issues and practical knowledge of where to turn for advice and guidance, you can be effectiveâeven if youâre only a day or two ahead of everyone else in the detailed knowledge required for the project.
Youâd be surprised at the number of times someone has kicked off an ISMS project without adequate preparation, has failed to answer a series of questions or challenges about specific issues adequately, and has then been surprised that the project has lost credibility rather quickly.
Your CEOâs support for the project is even more important than your own understanding of what youâre trying to achieve. Information security is both a management and a governance issue. Successful implementation of an ISMS depends absolutely on the project having real support from the top of the organization. With it, you have a real shot at success; without it, none at all. Securing real top management supportânot mere lip serviceâis key to ISO 27001 success. In this context, Iâm not necessarily talking about the CEO of a large, multi-subsidiary organization; Iâm talking about the person who is accountable for the business success or failure of the trading entity considering adopting ISO 27001. This could be a trading division, a subsidiary company, a standalone unit, or a virtual organization.
It is important to be clear about the meaning of âaccountableâ in this context. I am talking about the person whose job and career ultimately depend on the success of the business entity that is considering ISO 27001; this person does not always occupy the role that is formally âwhere the buck stops.â All organizations know exactly where the buck really stops, and this is the person I refer to as the CEO in this chapter.
Strategic alignment
The first reason the CEO must fully support you and the ISMS project is it is a business project, not an IT project. It must be fully aligned with the business model, business strategy, and goals, and has to be a priority for the business and be allocated an appropriate level of resources. While the CEO is unlikely to be the ISMS project leader, the only person who can effectively prioritize cybersecurity is the CEO. No single project leader is in a position to be clear about the organizationâs strategic needs and goals, but as this is a strategic project that affects everyone, you need to be âin the loopâ so you can tailor your own plans to deliver the organizationâs business priorities.
You also need to know what the strategic risks faced by the organization are, and how these are reflected and prioritized in information security risks. There are many possible questions, the answers to which will be critical to your approach and detailed plan. For instance, is the risk of intellectual property theft more significantâwith a greater potential impactâthan the risk of, for example, a three-day business closure? Is regulatory compliance more, or less, important than reducing the cost of sales? Is information security and regulatory compliance going to be important in outsourcing solutions (or, when faced with a choice between a lower cost but less secure, and a more secure but more expensive outsourcing option, which one will the organization choose)? How should conflict between the regulatory requirements of two different jurisdictions in which the organization trades be resolved? What is the trade-off between the operational flexibility allowed to subsidiary organizations, and implementation of a minimum, consistent level of information security and IT service reliability? What are the long-term plans for specific support services (if theyâre to be outsourced, then youâre going to approach ISMS implementation differently than if theyâre staying in-house)? There are many such questions, the answers to which you need to know before you even start planning. And there are many others that will come up in the course of the project.
Prioritization and endorsement
The second reason you require this level of support is that, without it, the project simply will not happen. It is not enough for the CEO and executive management simply to acknowledge the project is important. It is not enough that they merely talk about it. It is not enough that you know the organizationâs strategic priorities and are able to align the project with the business plan.
If it really is to happen, senior management must be committed, well and truly determined to achieve it. Top management commitment means the project gets the financial and human resources it needs. It gets the oversight, âface timeâ and internal communication headlines it needs. Unless you have this sort of commitment, there will be lots of things people throughout the organization will see as higher priorities than your project. Of course, there are going to be some higher priorities; what you need is clear prioritization that is understood across the business and is continuously supported by the CEO.
The relative prioritization of your project must be clearly understood. Within that context, it needs to have the firm and uncompromising endorsement of the CEO. By âendorsementâ I mean that, when those occasionally unnecessary internal barriers appear, the words: âThis is a project endorsed/mandated by the CEOâ should go a long way to overcoming them.
Change management
The third reason you need the CEOâs support is an ISMS project is likely to be a change management project. The implementation of an ISMS is not a low-impact activity. It may require changes to how computer users do a number of things and it also affects aspects of managersâ everyday activities. A successful ISMS project is, in other words, a low-key but nevertheless wide-ranging change management project, and the way you approach it has to learn from the experience of successful change management programs.
There have been many books written about change management. Many of these projects fail to deliver the benefits used to justify the expense of commencing and seeing them through. Successful implementation of an ISMS does not require a detailed, strategic change management program, particularly not one devised and driven by external consultants. What it does require is complete clarity among senior management, those charged with driving the project forward, and those whose work practices will be affected as to why the change is necessary, what the end result must look like, and why this result is essential. For this reason you want your CEO to be leading by example, doing all the things youâre going to want everyone else to be doing.
The fact is the Standard itself demands this level of support. It will not allow any certification body to certify an ISMS without firm evidence senior management is committed. The reason for this is simple: if commitment is lacking, the ISMS will not be adequate; the risks to the organization will not have been properly recognized or fully addressed; and the strategic business goals and consequent future information security requirements are unlikely to have been considered.
The CEOâs role
Ideally, the CEO should be the driving force behind the program, and achievement of ISO 27001 certification should be a clearly stated goal in the current business plan. The CEO needs to understand fully the strategic issues around IT governance and information security, and the value to the company of successful certification. The CEO must be able to articulate this to the directors and top management, and to deal with objections and issues arising. Above all, he or she must be sufficiently in command of this part of the business plan to be able to keep it on track against its strategic goals.
The chairperson and top management should give as much attention to monitoring progress against the ISO 27001 implementation plan as they do to monitoring all other key business goals. Clause 5.1 of the Standard specifically requires evidence of this commitment from the top: âTop management shall demonstrate leadership and commitment with respect to the information security management system.â If the CEO, chairperson, and board of directors are not behind this project, there is little point in proceeding; certification will not happen without clear evidence of such commitment. This principle of leadership from the top is, of course, also essential to all major change projects.
If you are already the CEO of the organization, then youâre doing exactly the right thing by reading this book and preparing to drive the information security project yourself. If youâre not the CEO, then you have to secure the sort of commitment and support I described above.
The ideal leader of an ISMS project is a business leaderâa chief operations officer (COO) or a line of business leader. Adopting an ISMS is a business project and business leadership is therefore fundamental to its success. ISMS projects often fail because they have been set up apparently as a technology initiative and are therefore seen and treated as narrow and undeserving of full business commitment. âJust another IT projectâ is the wrong message for driving an ISMS into the culture of the organization.
There are, of course, organizations in which the chief information officer (CIO) is a member of the senior management team, responsible for an integrated function that includes information security, and already has the full trust and support of the CEO and top management. In such an organization the CIO could be the driver of the project, but it will still need the CEOâs commitment and support, not least so everyone in the organization understands that securing recognition is a business priority. The CIO will also urgently need to build a cross-business project team. I will return to this later.
The project mandate
The project mandate is where you capture initial evidence of this commitment in a usable format. A project mandate (laid out in a project initiation documentâPID) is a document that is widely used to capture the key elements of any complex project. It ensures there is a single, original point of reference that sets out the three keys to project success: deliverables, timeline, and budget.
Complex projects fail because one or more of these three project variables are poorly identified and/or managed. âScope creepâ is one of the most common roots of project failure. Project mandates, therefore, seek to clearly identify project scope and to pin down the three variables in order to support an effective project governance process.
Your project mandate should address these four points:
- Deliverables: Identify the objective as the achievement of ISO 27001 certification for either a specific part or the whole of the organization and, if possible, identify why information security is important for your organization.
- Timeline: Create an outline project plan and identify a target completion date on the basis of the nine steps to success.
- Budget: Identify the resources, both internal and external, as well as the training, software, and tools you will need for the project.
- Authorization to proceed: The mandate should contain management endorsement of the project and authorization to proceed, in order to achieve the identified objectives using the budgeted resources.
Deliverables and the project objective
While the project deliverable is relatively easy to define (for example, achieve ISO 27001 certification within four months), you still need to be clear about the reasons for pursuing that objective as well as clarifying the difference between project objective and information security objectives.
The purpose of an ISMS is, of course, to reduce and control risks to your information. The actual objective (or objectives) of your ISMS project may be different to the purposes of the ISMS itself, and you should be clear about these differences if you are to appropriately focus both the project and the ISMS. The project objective may be, for instance, to secure ISO 27001 certification within a given timeframe in order to meet a contractual or regulatory requirement, to improve business competitiveness, or to reduce the cost and complexity of sales and marketing responses to tender invitations. Project objectives, in other words, link specifically to business benefits that are to be derived from their achievement. Project objectives will usually be high level and performance against them should be easy to track.
Information security objectives may be, but are not necessarily, related to the project objectives. Information security objectives will definitely be linked to the preservation of confidentiality, integrity, and availability of information within the context of the organization and in relation to its risk appetite. Progress toward achieving information security objectives must be measurable, which means the objectives themselves need to be specific, measurable, achievable, realistic, and time-bound. Typical objectives might, for instance, be to reduce the number of disruptive information security incidents from 14 per year to 2 per year, or to increase network availability from 97% and 20Ă7Ă360 to 99.99999% and 24Ă7Ă365. Such objectives will be broken down into lower level objectives, with accountability for their achievement allocated to appropriate departments and levels within the organization.
Gap analysis
Most organizations are already taking steps to manage their information security. While there may be significant vulnerabilities, it is not as though nothing is currently being done! The starting point for your project is usually, therefore, to understand how far your current practices are from the requirements set out in ISO 27001, and the best way to do this is with what we call a âgap analysis.â This is a quick, reasonably high-level audit of your current information security management practices against the requirements set out in ISO 27001, which identifies where there is a shortfall and also identifies what resources and capabilities you have in place for closing the gap...
