Question:What organizational structure would be most effective for
information-security governance?
Our advice:
Information-security experts are a long way from establishing best practices in
organizing security: Chief security officers variously advocate security
reporting to facilities, operations, legal, IT, and even human resources.
Ultimately (and legally) the board of directors is responsible for protecting
the company's assets, but someone has to keep the board informed about the
risks the company is facing from security threats. This should be the job of a
chief security officer. Unfortunately, they are rare and almost always too low
on the organizational chart to effectively interact with the board, and
reporting structures often blunt and filter (even suppress) those messages
before they reach the board.
So right away the organizational-structure issue comes down to which C-level
executive your top security person reports to. There seems to be no dominant
rule for companies placing the head of security (physical and/or information)
above the chief information officer, reporting to the CIO, or several levels
below the CIO. Corporate culture appears to be the biggest factor, but also
industry type. Consider the following structures and their consequences:
Information security reports to the CIO.
CIOs want to be seen as value-adders, focused on productivity and profits, and
cannot afford to be branded as "inhibitors." This mind-set can cause CIOs to
delay reporting potential security problems upward.
Information security reports to the chief operating officer.
Chief operating officers are concerned about delivering products and services,
resolving customer issues, and increasing sales. Instead of protecting the
company's larger goals, the focus is too often on finding solutions for
customer complaints, continuously monitoring satisfaction, and fighting for
market share.
Information security reports to the CFO.
CFOs all too frequently act as if the best way to grow profits is to cut costs.
When they oversee a security organization, they evaluate security budgetary
issues by scrutinizing every capital expenditure or head-count increase.
Industry and organizational size have an influence. Retail and pharmaceutical
industries are most content with security chiefs under the direction of the
CIO, while some other industries are migrating to a corporate (i.e., outside of
IT) security-management structure. In midsize to large organizations where the
emphasis is on technical measures mitigating technical threats, the CIO is
usually the security boss.
An effective security organization hinges on collaboration among the CFO,
auditors, legal staff, business-unit managers, corporate and physical security
teams, IT senior managers, midlevel administrators, and the entire range of
corporate stakeholders, whose awareness of and participation in a security
program is essential. For information security, this means a structure where
the security head's reporting relationship is an enabler, not a deterrent, to
integrating the activities of primarily the IT, operations, and corporate
auditing groups. It's the opposite of the fragmented security management norm
at many companies today. Until top management recognizes security as a critical
function with strategic impact, security of all sorts will continue to get
shuffled around and fail to obtain adequate resources.
Security is rapidly evolving into a critical shared service within many
organizations, with the head of corporate security increasingly taking on
responsibilities for information security. Within five years most organizations
will have a risk-management function that (1) is not within IT and (2) will
include a number of things currently on CIOs' plates, such as business
continuity, and a security program-management office, as well as non-IT risk
functions such as fraud and physical security. The path to this governance
structure is being blazed by companies that are taking a coordinated approach
to physical security, information security, and risk management because they
believe bottom-line improvements come most easily when security is treated as a
business process.
-- David Foote
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