I figured I'd wait until after my paternity leave was over before I started thinking seriously about words like "control" and "compliance," but I felt the need to say something after reading Bejtlich's post "Controls are Not the Solution to Our Problem."
He illustrates through citing an example of a control, and identifying ways that it fails to achieve total effectiveness. The control may not work and could be superfluous. His alternate approach is a system of assessments, tests and monitoring coupled with a rigorous set of metrics.
If someone describes an asset as "secure," "safe" or "reliable," my job as an auditor is to ask the question "How do you know?" The answer is a control. Bejtlich's "field-assessed" approach is another set of controls, mostly detective rather than preventative. What happens when his approach is codified into a government procedure or a vendor contract? A security practitioner with a preventative approach could grouse about how these pen tests and honeynets don't address the security needs in his shop (due to scale of operations or type and level of risk).
Tossing out controls is also just not an option. Effective or not, compliance keeps you out of jail. I don't always feel that on some roads a 55 mph limit is a necessary control to prevent accidents, but that will mean I am not breaking the law when I speed.
I'm not as big a proponent of metrics as a control solution, but I'll leave that to another post.
Tuesday, November 27, 2007
Confusion In My Eyes That Says It All
Posted by Dutcher Stiles at 1:56 PM
Labels: compliance, controls, internal auditing, risk assessment, risk management
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