This column was produced by (ISC)² U.S. Government Advisory Council Executive Writers Bureau. Patrick D. Howard at Kratos Technology & Training Solutions was lead author of this peer-reviewed article.
One of the long-standing complaints continually heard from IT managers pertains to the adversarial relationship they experience with their agency Office of the Inspector General. Notwithstanding the normal separation of duties established by design, the tension they experience with the IG staff is exacerbated specifically because of the annual information security evaluation mandated by the Federal Information Security Management Act.
Although adversarial relations predate FISMA, chief information security officers blame the annual FISMA audit for the increased level of friction they experience with the agency IG.
For well over a decade, the OIG’s annual information security program evaluation conducted in compliance with FISMA has been the primary means of measuring the health of an agency’s information security program. Right or wrong—evaluation results have become a highly visible means of scoring, not only the performance of the agency itself, but also that of individual staff members, specifically the chief information officer and the CISO.
Consequently, many of these officials take FISMA evaluation findings personally and complain about the following:
- IT audit personnel merely check the box, focusing only on compliance and lose sight of what they are doing to counter “real” security risks; also, IT auditors do not appear to want to accept their explanations for why compliance cannot be achieved (i.e., operational necessity).
- IT auditors enjoy playing “gotcha” by seeking to find evidence of noncompliance and show no desire to understand or accept explanations for mission essential deviations.
- The annual FISMA audit disrupts IT operations, and the time necessary to support the annual FISMA audit is excessive; consequently, it is burdensome for IT staff personnel to respond to IG requests for documentation and interviews that are identical to those of the previous year.
Unquestionably, there is another side to this coin. IT auditors complain about the difficulty in getting agency personnel to provide sufficient evidence of compliance, and the inability to get direct answers to what they consider to be straight-forward questions. Nor do they look forward to contentious meetings where their IT expertise is called into question.
For these reasons, neither the agency IT staff nor the IG IT auditors may look forward to the annual FISMA evaluation, and in response, agency IT managers may downplay evaluation findings. This is evidenced by the lack of corrective action and the excessive number of repeat findings each year. Obviously, conflicts resulting from the annual FISMA evaluation can also sour the long-term relationship between the agency IG and CIO/CISO as well.
A good working relationship between the agency IT staff and the OIG is critical to the success of an enterprise IT security program, and conflicts in this relationship will result in a perception of inefficiency and ineffectiveness both inside and outside the organization. Agencies that experience ongoing adversity between these internal offices should consider taking steps in the following three areas:
1. Evaluate Organizational Objectives, Roles and Responsibilities
The CISO and the IG audit lead must ensure they each understand the mission of their counterpart and the respective roles. By doing this, they can identify common ground for improving the posture of the agency’s information security program and coordinate joint goals and objectives.
Each should acknowledge the part the other has to play in protecting the agency’s sensitive information. An open discussion can lead to acknowledgement of shared goals, appreciation of their particular capabilities and strengths, and recognition of terms, definitions, principles and procedures that govern their respective operations.
2. Increase Communications
Agencies must seek to increase opportunities for the IG audit staff and IT operations and security staff to communicate with each other their plans and operations in order to build common understanding and provide a means for providing input.
CISOs should meet with the IG’s IT audit lead at least quarterly and should discuss upcoming audits well in advance. Pre-audit coordination should begin well in advance of any audit, including the annual FISMA evaluation, and discussions should be detailed enough to allow elaboration of expectations on both sides.
3. Focus on Risk Management
While there is no doubt agencies must comply with government security mandates and practices, in the final analysis, the agency IT security program must be based on risk management principles rather than compliance.
Because of today’s resource constraints, there is no practical way for agencies to be fully compliant in every respect at all times. Consequently, the agency must focus its attention on minimizing risks and developing processes that allow that to happen.
Since the annual FISMA evaluation does not appear to be going away anytime soon, agencies must find a way to improve the critical relationship between their IT and IG functions. Adversity and tension can be reduced by ensuring that their IT and IG audit staffs understand and appreciate their respective missions and roles, fostering better communications between the staffs, and ensuring both IT and IG personnel are guided by agency risk management imperatives. Only then can agencies begin to realize true progress in improving the posture of their information security programs.