Month: April 2024

What’s Better – Complete Coverage With Multiple Tools Or Partial Coverage With One Tool?

The debate between complete coverage with multiple tools versus imperfect coverage with one tool regularly pops up in discussions between security professionals. What we are really talking about is attempting to choose between maximum functionality and simplicity. Having pursued both extremes over the course of my security career I offer this post to share my perspective on how CISOs can think about navigating this classic tradeoff.

In Support Of All The Things

Let’s start with why you may want to pursue complete coverage by using multiple technologies and tools.

Heavily Regulated And High Risk Industries

First, heavily regulated and high risk businesses may be required to demonstrate complete coverage of security requirements. These are industries like the financial sector or government and defense. (I would normally say healthcare here, but despite regulations like HIPAA the entire industry has lobbied against stronger security regulations and this has proven disastrous via major incidents like the Change Healthcare Ransomware Attack). The intent behind any regulation is to establish a minimum set of required security controls businesses need to meet in order to operate in that sector. It may not be possible to meet all of these regulatory requirements with a single technology and therefore, CISOs may need to evaluate and select multiple technologies to meet the requirements.

Defense In Depth

Another reason for selecting multiple tools is to provide defense in depth. The thought process is: multiple tools will provide overlap and small variances in how they meet various security controls. These minor differences can offer defenders an advantage because if one piece of technology is vulnerable to an exploit, another piece of technology may not be vulnerable. By layering these technologies throughout your organization you reduce the chances an attacker will be successful.

An example of this would be if your business is protected from the internet by a firewall made by Palo Alto. Behind this PA firewall is a DMZ and the DMZ is separated from your internal network by a firewall from Cisco. This layered defense will make it more difficult for attackers to get through the external firewall, DMZ, internal firewall and into the LAN. (See image below for a very simplistic visual)

Downside Of All The Things

All the things may sound great, but unless you are required to meet that level of security there can be a lot of downsides.

First, multiple technologies introduce complexity into an environment. This can make it more difficult to troubleshoot or detect issues (including security events). It can also make it more difficult to operationally support these technologies because they may have different interfaces, APIs, protocols, configurations, etc. It may not be possible to centrally manage these technologies, or it may require the introduction of an additional technology to manage everything.

Second, all of these technologies can increase the number of people required to support them. People time can really add up as a hidden cost and shouldn’t be thrown away lightly. People time starts the second you begin discussing the requirements for a new technology and can include the following:

  • Proof of Concepts (PoCs)
  • Tradeoff & Gap Analysis
  • Requests for Information (RFI)
  • Requests for Proposal (RFP)
  • Requests for Quotes (RFQ)
  • Contract Negotiation
  • Installation
  • Integration
  • Operation & Support

Finally, multiple technologies can cause performance impacts, increased costs and waste. Performance impacts can happen due to differences in technologies, complexity, configuration errors or over consumption of resources (such as agent sprawl). Waste can happen due to overlap and duplicated functionality because not all of the functionality may not get used despite the fact you are paying for it.

Advantages and Disadvantages Of A Single Tool

A single tool that covers the majority, but not all, of your requirements offers one advantage – simplicity. This may not sound like much, but after years of chasing perfection, technology simplicity can have benefits that may not be immediately obvious.

First, seeking out a single tool that meets the majority of requirements will force your security team to optimize their approach for the one that best manages risk while supporting the objectives of the business. Second, a single tool is easier to install, integrate, operate and support. There is also less demand on the rest of the business in terms of procurement, contract negotiation and vendor management. Lastly, a single tool requires less people to manage it and therefore you can run a smaller and more efficient organization.

The biggest disadvantage of a single tool is it doesn’t provide defense in depth. One other disadvantage is it won’t meet all of your security requirements and so the requirements that aren’t met should fall within the risk tolerance of the business or somehow get satisfied with other compensating controls.

A single tool that covers the majority, but not all, of your requirements offers one advantage – simplicity.

Wrapping Up

There are a lot of advantages to meeting all of your requirements with multiple tools, but these advantages come with a tradeoff in terms of complexity, operational overhead, duplicated functionality and increased personnel requirements. If you operate a security program in a highly regulated or highly secure environment you may not have a choice so it is important to be aware of these hidden costs. A single tool reduces complexity, operational overhead and personnel demands, but can leave additional risk unmet and fails to provide defense in depth. Generally, I favor simplicity where possible, but you should always balance the security controls against the risk tolerance and needs of the business.

If Data Is Our Most Valuable Asset, Why Aren’t We Treating It That Way?

There have been several high profile data breaches and ransomware attacks in the news lately and the common theme between all of them has been the disclosure (or threat of disclosure) of customer data. The after effects of a data breach or ransomware attack are far reaching and typically include loss of customer trust, refunds or credits to customer accounts, class action lawsuits, increased cyber insurance premiums, loss of cyber insurance coverage, increased regulatory oversight and fines. The total cost of these after effects far outweigh the cost of implementing proactive security controls like proper business continuity planning, disaster recovery (BCP/DR) and data governance, which begs the question – if data is our most valuable asset, why aren’t we treating it that way?

The Landscape Has Shifted

Over two decades ago, the rise of free consumer cloud services, like the ones provided by Google and Microsoft, ushered in the era of mass data collection in exchange for free services. Fast forward to today, the volume of data growth and the value of that data has skyrocketed as companies have shifted to become digital first or mine that data for advertising purposes and other business insights. The proliferation of AI has also ushered in a new data gold rush as companies strive to train their LLMs on bigger and bigger data sets. While the value of data has increased for companies, it has also become a lucrative attack vector for threat actors in the form of data breaches or ransomware attacks.

The biggest problem with business models that monetize data is: security controls and data governance haven’t kept pace with the value of the data. If your company has been around for more than a few years chances are you have a lot of data, but data governance and data security has been an afterthought. The biggest problem with bolting on security controls and data governance after the fact is it is hard to reign in pandoras box. This is also compounded by the fact that it is hard to put a quantitative value on data, and re-architecting data flows is seen as a sunk cost to the business. The rest of the business may find it difficult to understand the need to rearchitect their entire business IT operations since there isn’t an immediate and tangible business benefit.

Finally, increased global regulation is changing how data can be collected and governed. Data collection is shifting from requiring consumers to opt-out to requiring them to explicitly opt-in. This means consumers and users (an their associated data) will no longer be the presumptive product of these free services without their explicit consent. Typically, increased regulation also comes with specific requirements for data security, data governance and even data sovereignty. Companies that don’t have robust data security and data governance are already behind the curve.

False Sense Of Security

In addition to increased regulation and a shifting business landscape, the technology for protecting data really hasn’t changed in the past three decades. However, few companies implement effective security controls on their data (as we continue to see in data breach notifications and ransomware attacks). A common technology used to protect data is encryption at rest and encryption in transit (TLS), but these technologies are insufficient to protect data from anything except physical theft and network snooping (MITM). Both provide a false sense of security related to data protection.

Furthermore, common regulatory compliance audits don’t sufficiently specify protection of data throughout the data lifecycle beyond encryption at rest, encryption in transit and access controls. Passing these compliance audits can give a company a false sense of security that they are sufficiently protecting their data, when the opposite is true.

Just because you passed your compliance audit, doesn’t mean you are good to go from a data security and governance perspective.

Embrace Best Practices

Businesses can get ahead of this problem to make data breaches and ransomware attacks a non-event by implementing effective data security controls and data governance, including BCP/DR. Here are some of my recommendations for protecting your most valuable asset:

Stop Storing and Working On Plain Text Data

Sounds simple, but this will require significant changes to business processes and technology. The premise is the second data hits your control it should be encrypted and never, ever, unencrypted. This means data will be protected even if an attacker accesses the data store, but it also will mean the business will need to figure out how to modify their operations to work on encrypted data. Recent technologies such as homomorphic encryption have been introduced to solve these challenges, but even simpler activities like tokenizing the data can be an effective solution. Businesses can go one step further and create a unique cryptographic key for every “unique” customer. This would allow for simpler data governance, such as deletion of data.

Be Ruthless With Data Governance

Storage is cheap and it is easy to collect data. As a result companies are becoming digital data hoarders. However, to truly protect your business you need to ruthlessly govern your data. Data governance policies need to be established and technically implemented before any production data touches the business. These policies need to be reviewed regularly and data should be purged the second it is no longer needed. A comprehensive data inventory should be a fundamental part of your security and privacy program so you know where the data is, who owns it and where the data is in the data lifecycle.

The biggest problem with business models that monetize data is: security controls and data governance haven’t kept pace with the value of the data.

Ruthlessly governing data can have a number of benefits to the business. First, it will help control data storage costs. Second, it will minimize the impact of a data breach or ransomware attack to the explicit time period you have kept data. Lastly, it can protect the business from liability and lawsuits by demonstrating the data is properly protected, governed and/or deleted. (You can’t disclose what doesn’t exist).

Implement An Effective BCP/DR and BIA Program

Conducting a proper Business Impact Analysis (BIA) of your data should be table stakes for every business. Your BIA should include what data you have, where it is and most importantly, what would happen if this data wasn’t available? Building on top of the BIA should be a comprehensive BCP/DR plan that appropriately tiers and backs up data to support your uptime objectives. However, it seems like companies are still relying on untested BCP/DR plans or worse solely relying on single cloud regions for data availability.

Every BCP/DR plan should include a write once, read many (WORM) backup of critical data that is encrypted at the object or data layer. Create WORM backups to support your RTO and RPO and manage the backups according to your data governance plan. Having a WORM backup will prevent ransomware attacks from being able to encrypt the data and if there is a data breach it will be meaningless because the data is encrypted. BCP / DR plans should be regularly tested (up to full business failover) and security teams need to be involved in the creation of BCP/DR plans to make sure the data will have the confidentiality, integrity and availability when needed.

Don’t Rely On Regulatory Compliance Activities As Your Sole Benchmark

My last recommendation for any business is – just because you passed your compliance audit, doesn’t mean you are good to go from a data security and governance perspective. Compliance audits exist as standards for specific industries to establish a minimum bar for security. Compliance standards can be watered down due to industry feedback, lobbying or legal challenges and a well designed security program should be more comprehensive than any compliance audit. Furthermore, compliance audits are typically tailored to specific products and services, have specific scopes and limited time frames. If you design your security program to properly manage the risks to the business, including data security and data governance, you should have no issues passing a compliance audit that assesses these aspects.

Wrapping Up

Every business needs to have proper data security and data governance as part of a comprehensive security program. Data should never be stored in plain text and it should be ruthlessly governed so it is deleted the second it is no longer needed. BCP/DR plans should be regularly tested to simulate data loss, ransomware attacks or other impacts to data and, while compliance audits are necessary, they should not be the sole benchmark for how you measure the effectiveness of your security program. Proper data protection and governance will make ransomware and data breaches a thing of the past, but this will only happen if businesses stop treating data as a commodity and start treating it as their most valuable asset.

Security Considerations For M&A and Divestitures

I’ve been speaking to security startups over the last few weeks and some of the discussions made me think about the non-technical aspects of security that CISOs need to worry about. Specifically, things like mergers, acquisitions and divestitures and the different risks you will run into when executing these activities. There are a number of security issues that can materialize when combining businesses or separating businesses and in this post I’ll share some of the things you need to think about from a security perspective that may not be obvious at first glance.

What’s Going On Here?

There are a number of reasons for mergers & acquisitions (M&A) or divestitures. For the past two decades, the tech industry has used M&A to acquire smaller startup companies as a way to collect intellectual property, acquire specific talent or gain a competitive advantage. Divestitures may be the result of changing business priorities, separating business functions for regulatory reasons, eliminating redundancies or a way to sell a part of the business to cover costs. Mergers, acquisitions and divestitures are similar because you will want to review the same things from a security perspective, but it is probably easiest to think of divestitures as the reverse of an M&A – you are separating a business instead of combining a business. Divestitures are definitely less common than M&A in the tech space, but they aren’t unheard of. There are also differences in terms of the security risks you need to think about depending on if you are acquiring a business or separating a business. My best advice is to work with the legal and finance teams performing the due diligence and have a set process (that you have contributed to) so you don’t forget anything. With that, let’s dive into a few different areas.

Physical Security

Physical security is something you will need to think about for both M&A and divestitures. For M&A you will want to perform a physical security assessment on the facilities you are acquiring to make sure they meet or exceed your standards. Reviewing physical security controls like badging systems, fencing, bollards, cameras, fire suppression, emergency lighting, tempest controls (if required), safes and door locks will all help make sure your new facilities are up to standard. If you aren’t sure how to perform this, hire a company that specializes in physical security assessments or physical red teaming.

While physical security for M&A may seems straight forward, there are a few gotchas when performing divestitures. The biggest gotcha is understanding and reviewing the existing access of the people that are part of the divestiture because you will now need to consider them outsiders. All of your standard off-boarding processes will apply here such as terminating accesses to make sure someone doesn’t retain access to a system they are no longer authorized to access (like HR, Finance, etc.).

Things can get complicated if parts of the business are divesting, but not fully. Some examples of this are when the business divests a smaller part, but allows the smaller part to co-locate in their existing facilities. This may complicate physical security requirements such as how to schedule or access common areas, how to schedule conference rooms, how to separate wifi and network access, etc. In the above example, the larger company may act like a service provider to the divested part of the business, but there still needs to be effective security controls in place between the two parts.

Personnel Security

I touched on this a bit already, but personnel security is something to consider when performing M&A or divestitures. With M&A the biggest issue will be how to smash the two IAM systems and HR systems together without punching huge holes in your network. Typically what happens is the two parts operate separately for a while and then consolidate to a single system and the employees of the acquired business get new accounts and access.

For divestitures, particularly if they don’t result in a clean split, you will need to focus heavily on access control and insider threats. Think about how you will separate access to things like source code, financial systems, HR systems, etc. If the smaller company has physical access to your space then you need to build in proper physical and logical controls to limit what each business can do, particularly for confidentiality and competitive reasons.

What’s an example of where this can go wrong? Let’s say business A is going to divest a small part of its business (business B). The complete divestiture is going to take a while to finalize so company A agrees to allow company B to continue to access their existing office space, including conference rooms. However, the legal team didn’t realize the conference rooms are tied to company A’s SSO and calendaring system so company B has no way to schedule the conference rooms without retaining access to company A’s IAM system creating a major security risk. Whoops!

The biggest gotcha is understanding and reviewing the existing access of the people that are part of the divestiture because you will now need to consider them outsiders.

Contracts

Contracts may not seem like a typical security issue, but they should be part of your review, particularly when performing M&A. Why? You are acquiring a business that is worth something and that business will have existing contracts with customers. The contractual terms with those customers may not match the contractual terms of the acquiring company, which can cause a risk if there is a significant difference in contract terms. Smaller companies are more agile, but they also usually have less negotiating power compared to large companies and as a result are more likely to agree to non-standard contract terms. What are some terms you need to think about?

  • Vulnerability Remediation Times – How quickly did the new company promise to fix vulnerabilities for their customers?
  • Incident & Breach Disclosure Time Frames – How quickly did the new company promise to notify customers of a breach or incident? I have seen very small time frames suggested in contracts, which are impossible to meet, so I definitely recommend reviewing these.
  • Disclosure of Security Postures – Does the new company have contractual terms promising to provide SBOMs or other security posture assessments to their customers on a regular basis?
  • Compliance Requirements – Has the new company agreed to be contractually obligated to maintain compliance certifications such as PCI-DSS, SOC 2, ISO27001, etc.
  • Penetration Testing & Audits – Has the new company contractually agreed to have their products or services penetration tested or have their security program audited? Have they agreed to provide these reports to their customers on a regular basis?
  • Privacy & Data Governance Terms – Is the new company required to comply with privacy regulations such as allowing customers have their data deleted, or mandating certain data governance requirements like DLP, encryption, data deletion, etc?
  • BCP/DR and SLAs – Are there contractual uptime SLAs or response times and does the existing BCP/DR plan support these SLAs?

My advice is to set a timeline post acquisition to review and standardize all of your contracts to a single set of standard clauses covering the above topics. This is usually part of a security addendum that the legal team can help you create. The biggest challenge with contracts will be to “re-paper” all of your customers to hopefully get them on the same standardized contract terms so your security program doesn’t have a bunch of different requirements they have to try to meet.

Accuracy Of M&A’s

One of the biggest risk of performing M&A’s is trying to get an accurate picture of the existing security posture of the company being acquired. Why is this so difficult? The company being acquired is trying to look as good as possible so they get top dollar. They can’t hide things, but they aren’t going to tell you where all the skeletons are buried either. The acquiring company usually doesn’t get a full picture of the existing security posture until after the deal is done and you start trying to integrate the two parts of the business. If you have a chance to interview the existing security team before the M&A closes definitely ask to see their latest audit reports, compliance certifications, penetration testing reports, etc. Consider working with legal to set conditions for how old these reports can be (e.g. no older than 6 months) to hopefully give you a more accurate picture or require the acquired company to update them before the deal closes. Interview key members of the staff to ask how processes work, what are their biggest pain points, etc. Consider hiring an outside company to perform an assessment, or you can even consider talking to one of their largest customers to get their external view point (if possible).

Wrapping Up

M&A and divestitures can be exiting and stressful at the same time. It is important for the security team to be integrated into both processes and to have documented steps to make sure risks are being assessed and addressed. I’ve listed a few key focus areas above, but most importantly standardizing your M&A security review can help avoid “buyers remorse” or creating unnecessary risk to the acquiring business. Finally, having a documented divestiture process and reviewing the divestiture with legal can help avoid security risks after the fact.

Should There Be A Professional CISO Certification and Organization?

I’ve been thinking a lot about the CISO role and how it is rapidly maturing from a technology and compliance role to a more generalized business executive role that specializes in security and risk. The primary catalyst for this evolution is the recent release of the SEC rules requiring companies to report material incidents on their 8K forms. It also requires companies to disclose their process for governing security issues (via committees or other processes) and their process for determining materiality (via their annual 10k filing). All of this is having a similar effect on the CISO role that Sarbanes-Oxley had on the CEO and CFO role after it was passed in 2002. The end result is public companies are now being expected to demonstrate investment and expertise in governing security issues, which is elevating the CISO role to become a true executive officer and is ushering the role into the board room.

Why Did The SEC Establish The New Requirements?

Security reporting and disclosures by public companies has been lacking. There has been zero incentive or accountability for companies to report these events other than via lawsuits, stock price corrections or brand and reputation impact These disclosures often happen as a result of a news report published months or years after the actual incident. The company then issues a generic statement downplaying the event and emphasizing how serious they take security. The SEC has determined this pattern of behavior is insufficient for investors to accurately make decisions about the health of the company.

Why Do Professional Certifications Exist?

Professional certifications exist for a number of reasons. Doctors, accountants. professional engineers and lawyers all must demonstrate a minimum level of knowledge to get licensed in their chosen profession. They must also agree to conduct themselves according to a specific code of conduct. This allows the practitioners to wield specific credentials demonstrating proficiency and credibility in that field. Displaying professional credentials attests these professionals bear the responsibility to protect life, prevent fraud or protect assets.

Additionally, professional credentials afford the practitioners a number of benefits such as knowledge sharing, continual career development, job placement and act as a back stop if someone’s conduct is called into question. Certifying organizations can testify on someone’s behalf if they believe they have upheld the requirements of the profession, or they can self regulate and strip someone of their credentials for fraud or gross negligence.

A short list of fields with professional certifications are as follows:

  • Lawyers – Bar
  • Doctors – Medical license, National Board of Medical Examiners (NBME), State level licenses, American Board of Medical Specialities (ABMS)
  • Accountants – Financial Accounting Standards Board (FASB), Government Accounting Standards Board (GASB), Generally Accepted Accounting Principles (GAAP), Certified Public Accountant (CPA)
  • Engineers – Certified Professional Engineer (CPE)
  • Privacy Professionals – International Association of Privacy Professionals (IAPP)

Existing Security Certifications And Organization Are Lacking

There are already a number of certifications security professionals can choose from on their path to becoming a CISO. A short list of common certifications listed on CISO job postings or LinkedIn profiles is as follows:

  • C|CISO
  • CISSP
  • CISM
  • CISA
  • CRISC

Of these certifications, only the C|CISO certification comes close to offering a specific certification for CISOs. The rest serve either as generalized security certifications or specific offshoots of the security profession. These certifications are often bundled together by professionals to demonstrate breadth of knowledge in the security field.

While existing certifications are good, they are all lacking in what is needed for someone to serve as a CISO at a publicly traded company. They are more generalized about how to serve as a CISO at any company (small to large), but publicly traded companies have specific requirements and demands. Specifically, most of the certifications above are extremely heavy on a breadth of technical aspects and popular industry frameworks. Some of them do cover how to create and manage a security program. Some even cover basic board level conversations (although these are usually technical discussions, which are unrealistic). Where I find these certifications lacking is as follows:

  • Realistic board level conversations about risk and tradeoffs including building effective presentations
  • Board and legal conversations about materiality for security incidents
  • Common board committees and what to expect as a CISO serving on a board level committee for your company
  • Testifying or providing legal evidence post incident
  • Legal conversations about how to best notify customers of breaches including drafting communications
  • Legal conversations with security researchers and navigating vulnerability disclosures
  • How to establish and manage a bug bounty program
  • Navigating conversations with law enforcement or national security issues
  • How to effectively change or strengthen security culture
  • How to have conversations with other C-Suite executives about security
  • Navigating customer and industry requests for disclosure of security program information
  • Managing the budget / P&L for a security function including tooling, licenses, services, travel, expenses, equipment, certifications, etc.
  • Common security team structures and how to design a security org that add maximum value for the business
  • Personnel management, skillsets expected for different roles, matching training and certifications to job function, etc.
  • Negotiating with vendors and cyber insurance companies
  • Contract review and negotiation with customers (including common security and privacy clauses)
  • Creating RFPs, RFIs and RFQs
  • Talking to customers about security at your company or hot button security issues
  • Establishing requirements, conducting trade-off analyses and performing build vs buy analysis
  • How to effectively network with peers
  • Industry resources such as ISACs, Infraguard, etc.
  • Top recruiting agencies for placing CISOs at publicly traded companies
  • Career development post operational CISO (boards, consulting, etc.)
  • Properly documenting your security program
  • How to navigate achieving common compliance certifications such as SOC1, SOC2, FedRAMP, ISO27001, HIPAA, PCI-DSS. Typical costs, consulting companies that can help with these processes and what to expect during the process.
  • When to outsource your security program to an MSP
  • When to bring in an outside consulting or incident response firm
  • Successfully passing an external audit
  • Negotiating for a job including severance, D&O liability, assessing the role, etc.
  • Differences in the CISO role depending on who it reports to (General Counsel, CTO, CIO, CEO, CFO)
  • How to navigate common security related political and moral hazards at public companies

As you can see, there is a big difference between what certifications offer and the real demands of a public company CISO. Additionally, there are a number of professional security organizations such as the Information Systems Security Certification Consortium (ISC2), Information Systems Audit and Control Association (ISACA) and The Council of E-Commerce Consultants (EC-Council). Each has their own certification track, terminology and code of conduct. Each is good in their own right, but there is still a lack of a single certifying body for public company CISOs similar to a CPA. Arguably, ISACA comes closest to being an international organization that can back CISOs, but they lack a CISO specific certification covering the majority of the topics above.

While existing certifications are good, they are all lacking in what is needed to prepare someone to serve as a CISO at a publicly traded company.

Why There Should Be A Professional CISO Certification

The SEC requirements are forcing public companies to govern security to the same standard forced by Sarbanes-Oxley 20 years ago. The SEC considers security to be a material concern to investors and public companies need to treat the issue accordingly. As a result CISOs are getting elevated to the board room and CISOs need to be prepared to navigate the issues they will encounter while serving at a public company.

The advantages of a professional CISO certification and accompanying organization are as follows:

  • Standard of ethics and conduct – CISOs face a difficult job and often walk into roles that aren’t properly supported or properly funded. Yet, CISOs are asked to bear the responsibility and accountability for the security health of the organization. A standard of ethics and conduct, similar to a CPA, will backstop the authority of the CISO and serve as guidelines for how to navigate common issues at publicly traded companies.
  • Standard credential for publicly traded companies – Large companies face a difficult job sorting through the credentials and titles of job applicants. Most public companies hire executive recruiting firms to help navigate the sea of candidates to find ones that are truly qualified for the role. However, a single professional CISO certification would distinguish individuals who have met the standard to be a CISO at a publicly traded company and distinguish these credential holders from other individuals with discretionary CISO titles.
  • Shelter the role from (some) liability – One advantage of a professional certification like the ones for doctors, engineers, lawyers and public accountants is it provides a standard of conduct. These professionals can fall back on this standard of conduct if their professionalism is called into question and they can even have the certifying organization offer testimony on their behalf. As CISO take on more liability, a professional CISO organization can be useful to help support CISOs, testify on their behalf, offer recommendations for liability insurance policies or even provide low cost liability insurance through the organization. They can even help review employment contract terms to evaluate liability policies, severance, legal coverage, etc.
  • Board Level Expertise – One of the primary roles of public company CISOs is to present to the board and help the company navigate regulatory and compliance requirements such as SEC filings, breach notifications, etc. A professional CISO certification offer individuals this experience and it can give them the confidence to speak to the board on how to navigate topics of risk. By certifying individuals are qualified to operate in the board room the board will gain another voice to balance the other C-Suite executives who aren’t grounded in technology and security issues.
  • Consulting and auditing – One final advantage of a professional CISO certification is for the “big 4” consulting firms or other agencies who are contracted by investment companies to audit and certify the filings and reports of public companies. In this case, a certified CISO can represent shareholders and investors for the accuracy of security filings around governance processes, representation in board committees, recommendations for appropriate investment in security governance and generally offering advice on industry best practices for security governance at publicly traded companies.

Wrapping Up

I’m bullish on the CISO role long term because I think it is the ultimate C-Suite executive. Public company CISOs touch all aspects of the business, they need to have strong technical chops, need to understand business topics and need to have the political chops to build alliances and navigate big company politics. Existing security certifications are good, but none of them offer a comprehensive breadth of topics to prepare individuals to become a CISO at a publicly traded company. As CISOs establish their role and credibility in the board room, it will become critical for these individuals to have credentials that back their experience, offer support and can elevate the CISO role on par with other C-Level execs, similar to what Sarbanes-Oxley did for CFOs after 2002.

Are We Peak CISO?

Let’s be honest…the CISO role is weird right now. It is going through a transformative phase and the industry is at an inflection point similar to what other C-Level roles (like the CFO) have gone through in the past. What makes the role weird? The CISO community and any company that has a CISO is facing unprecedented regulatory pressure, the economy and interest rates have people on edge, layoffs in the tech sector have shaken employee confidence (to the applause of investors) and technology innovation via AI is causing additional disruption and risk across all sectors.

In additional to these external pressures the past few years have seen the proliferation of CISO title sprawl and confusion from companies about how to best employ and utilize a CISO (hint, we aren’t your scapegoats). Despite all of this turmoil, change is also a time for opportunity and there are a few things I think will help clarify and mature the CISO role.

CISO Title Sprawl

I’ve been tracking job titles and job postings on LinkedIn for the past year or so and I’ve noticed a phenomenon I’ll call title sprawl. A quick search for titles shows there are vCISOs, Advisory CISOs, Fractional CISOs, CISOs In Residence and Field CISOs. On top of this, add in Chief Security Officers, Chief Trust Officers and Heads of Security. Do we need all of these titles? Maybe, but I think this title sprawl is more indicative of three things 1) People with CISO titles are in high demand and people want to retain the title once they get it and 2) Companies are still uncertain about how to title and employ someone to lead their security function. 3) Title sprawl is a result of the political power struggle occurring between the CISO role and other C-Level roles (more on that below).

From the titles above there are really only four functions for a current or former CISO – board member (in some capacity), executive management (officer of the company), consultant and sales. There is similar title sprawl and variance with CTO titles, but not to the extent of the CISO title (yet). Time will tell if other C-Level roles start to follow suit, but for now, let’s break down the functional CISO role buckets.

Board Member – These are current or former CISOs who sit on a board either as a technical advisor, business advisor or some combination thereof.

Executive Management – Individuals employed by a company to lead the information security program. May also manage other parts of IT such as identity, privacy, data, etc. Titles may be CISO, CSO, CISO in Residence (for Venture Capital), Chief Trust Officer and Head of Security.

Consultant – These are individuals who are providing their expertise as a current or former CISO to other companies to help them establish, transition or manage a security program. Often the companies employing these individuals claim they can’t afford a full time CISO, but they seem to be able to afford other full time C-Suite titles (hmm…)? Titles may include Virtual CISO (vCISO), Fractional CISO, CISO in Residence and Consulting CISO. (CISO in Residence again because they can “consult” to their VC holding companies about the state of their security programs).

Sales – These are people who are experts in the field of security, may hold one or more certifications and may be past CISOs. Their job is to help the company they work for drive sales. Typically the title they use is Field CISO or Advisory CISO.

Standardize The Reporting Structure

Moving on from title sprawl, companies are also confused about where the CISO title should sit. Some companies advertise it as a Director level role reporting into the VP of some function. Other’s title it as a VP level role reporting into a Senior VP or some other executive. Still other companies have the CISO reporting to the CEO, CIO, CTO or General Counsel. It is even possible this person is an individual contributor. Companies are clearly confused about whether the CISO is a technologist, regulatory compliance specialist or true C-Suite executive. While reporting structure may be a direct reflection on company culture, it is also a public example of the battle for equivalency that is playing out between the CISO and other C-Level roles. Often, CISOs are hired by other C-Levels (not the CEO) and until it becomes more common for CISOs to report to the CEO as an accepted peer to other C-Levels, this confusion and variance will persist. That being said, if you are considering a CISO title and the company isn’t willing to add you to the D&O liability policy then you may be better off taking a lower level title to eliminate personal risk.

Bolster Security Management Certifications

Security certifications from popular organizations talk a lot about regulations, risk and different security concepts (technical or not), but few, if any, offer a comprehensive certification on what it truly takes to be a CISO. Any CISO level certification should include potential career paths that lead to the CISO role, career paths post CISO role, difference in the CISO role based on company size, exposure to business topics in addition to security topics, SEC reporting, interfacing with law enforcement and lastly discussion of how to maximize success based on where the role sits – e.g. reporting to the CEO, CTO or CIO and how that may change your lens as a CISO. This begs the question if there should be a true professional level CISO certification similar to a professional engineer, accountant or lawyer, but let’s save that discussion for a future blog post.

Embrace Increased Regulation

Given the recent increase in regulation, particularly from the SEC, bolstering CISO certifications to include more business acumen may soon be table stakes instead of a nice to have. Recent regulations forcing companies to disclose material cybersecurity events in their 8k filings are starting to accelerate the maturity of the CISO role at publicly traded companies. Companies can no longer fail to invest in security or report breaches (unless they want steep penalties). In particular, this is forcing the CISO role into the board room or at least on par with other C-Level roles because they have to help these companies navigate the decision to report material events in their filings. Existing and future CISOs can embrace this increase in regulation to backstop their authority at companies who are struggling to fully embrace the CISO role as a C-Level executive. While it may not elevate the current role with a promotion, it should at least open the door to the board room and provide a seat at the table for discussion.

While CISO reporting structure may be a direct reflection on company culture, it is also a public example of the battle for equivalency that is playing out between the CISO and other C-Level roles.

The last point I’ll make about regulation is – while the SEC watered down the requirements for cybersecurity expertise on boards, I predict this expertise will still be required and in demand as companies start to navigate the new SEC reporting requirements. In particular, companies may be penalized and eventually required to demonstrate cybersecurity board expertise (via experience or certifications) if they are found to have a material security breach and can’t demonstrate appropriate security governance at the board level.

What’s The End Result?

It is clear the security industry and the CISO role are in a state of confusion as a result of the tight job market, uncertain economy, increased regulation and pace of technology innovation. The net effect of title sprawl and the struggle for equivalency is – it confuses customers, investors, partners, recruiters and job candidates. Title sprawl artificially increases competition for jobs and causes a wide variance in how the CISO role is employed. However, I think this state of confusion is a good thing because it is forcing conversations and causing people to stop and think. The CISO role is the newest member of the C-Suite and it is growing up and trading in the hoodie for a collared shirt. We are starting to claim our seat at the board level and are able to hold our own or make other C-Level roles redundant. As the CISO role evolves from a “nice to have” to a “must have” in the C-Suite, we will see this confusion fade away and the CISO role will truly reach its peak.