September 07, 2010, 12:57 PM — Let's say your organization doesn't have a formal enterprise risk management program. If you're at a big company, ERM might seem daunting because of silos, inertia and so on.
If you're at a small company, you might think you lack the resources to pull it off.
I propose that ERM is worth doing and doesn't have to be so complex if you simply "begin with the end in mind," as Stephen Covey says in The 7 Habits of Highly Successful Security Leaders. Or would have said if he'd written such a book.
The basis of my thoughts is COSO's ERM framework (link goes to a PDF of the Executive Summary). Here is the end to keep in mind as you begin your ERM efforts, taken from COSO's work:
You want to create
* a process
* that can be applied to strategy-setting
* in order to achieve business objectives.
COSO says the goal of ERM is "to provide reasonable assurance regarding the achievement of entity objectives." Translation: The goal is to enable the business. That should be your security department's goal, and (critically) your CEO must know that it's your goal. That's why I like COSO's formulation of ERM. It communicates to the business that you are working to help them achieve their objectives.
Also see 'Enterprise risk management: All systems go'
So here's an exercise that can help you begin to devise and refine a process that can be applied in strategy-setting. It doesn't require any org-chart-jitsu. It's just a beginning, but it can be a beginning that yields immediate payoff. And that will help gather support for more formal efforts down the road.
The exercise--the process--consists of six steps. Let's choose internal investigations as the first business activity to which we'll apply these steps. The six steps are based on COSO's seven components of ERM, modified for this beginner's exercise.
Step 1. Create a working group that includes a representative from every department that plays any role in internal investigations. This might include HR, corporate security, information security, facilities, finance and legal.
Step 2. Brainstorm (i.e., red team) events and scenarios that could create risk for the company in an internal investigation. Such events might include information leaks in various departments or a potentially violent suspect.
Rank the risks by likelihood and impact. Absolute precision is not necessary here, although this step may provide the impetus to gather new metrics, both within your business and from the outside world for benchmarking purposes.
Step 4. Now for controls and solutions: List existing controls. Look for redundancy across departments. Brainstorm new ones to address these risks. Rank new controls based on cost, difficulty, and effectiveness--especially noting controls that can reduce likelihood and impact across multiple types of event. With good luck, you might be able to pay for a new control by reducing the redundancy of existing controls.
Step 5. Select the appropriate point person responsible for implementing (or championing) each high-priority control.
Step 6. Establish a way to measure the effect of each new control and a way to communicate that measurement within and outside of your working group. Don't get too hung up on making Step 6 overly formal. Keep the end in mind: Enable business objectives. Keep it simple. Show progress. Make internal investigations more effective and less risky.
Now repeat this six-step process with a new team for each of these additional areas:
* business continuity and disaster recovery
* intellectual property protection
* and brand protection.
Obviously each of these areas may require a different slightly set of team members.
