#ciso – 370 Security Blog

Start Preparing For Your Next Role During Your Current Role

If there is one piece of advice I can pass on to anyone – it is don’t wait to start preparing for your next role. No matter where you are in your career, your job will constantly expose you to new things and those new things will change your perspective, give you experience and make you grow in ways you can’t anticipate. Embrace the growth, but also have the foresight to set yourself up for success no matter where your career takes you. This post offers several lessons learned about how to constantly position yourself for success and most importantly – don’t wait to prepare for your next role.

Start With The Interview

Preparing for your next role begins the second you start interviewing for your current role. The interview process is a time for both the company and the candidate to ask questions. The process will reveal areas of growth on both sides and candidates should embrace the areas they are less confident in or need to work on. This will set them on a path for mastering those skills and to be able to use their current role as a stepping stone to the next role. Candidates can also use the interview to ask how the company views the role evolving and what is the path for promotion (either title or job level)?

During the interview process or after landing the job, candidates should evaluate and learn the skills exhibited by their immediate manager or the senior member of their team. Have conversations with these individuals and make a list of skills you need to master if you were promoted to their role. The time to work on new skills is now, not when a role or promotion is offered. By that time it is too late! Whether you are aiming for a promotion, looking for a new job or if you get laid off and need to find a new position, don’t wait to prepare until you need a job because you will be behind the curve.

Get Certifications

If you are targeting a new role or promotion, look at the qualifications and certifications of individuals in those roles. LinkedIn is a great place to do research on what is needed for career progression. Evaluate the certifications, degrees and experience of people who have the job title you want. Also review job postings to see what companies are looking for. Certifications take time, money and effort so plan accordingly. If your company offers to pay for these certifications take full advantage and build it into your performance goals. Make a plan to obtain the necessary certifications and qualifications so you can position yourself and effectively compete for the role you want.

Demonstrate Expertise

In addition to certifications you also need to demonstrate expertise. When doing your research about your next job, don’t just look at the job title. Look at the skills they require, the company size and the industry. Learn the skills, learn about the company and learn about the industry they operate in. Demonstrate expertise in these areas by writing blog posts, submitting conference talks, participating in local chapter events or participating in a podcast. You can even use popular social media platforms to generate your own content. The point is to build up a body of work that demonstrates your knowledge and most importantly to create an independent profile, separate from your job that represents who you are and what you can do. Think of it as a living resume.

Network

Networking continues to be one of the most powerful ways to advance your career. Attending conferences, chapter meetups, get togethers, and other social events puts a face to a name and builds rapport. This can be invaluable when looking for your next job, but just like everything else it takes time and effort to network.

Outside of the meetups, there are a few other recommendations I have for networking. First, don’t target the people that have the job you want, target the people that hire for the job you want. For example, if you want to be the CISO at a publicly traded company, do research on who the current CISO reports to and then figure out a way to connect with that person so you are on their radar. Second, make a list of companies that you would like to work for and research people at those companies. Start connecting and networking with those people either virtually or physically. Ask for a quick intro call to introduce yourself and learn about their role. Lastly, connect with recruiters that hire for the position you are targeting. Set up an intro call to get their perspective on the market and how you can position yourself better. This will put you on their radar as a candidate when new positions come their way. This all takes time and effort, but if you set a small goal to meet one new person a month, this can quickly lead to a lot of new people in your network by the time you are ready to make a move.

Don’t target the people that have the job you want, target the people that hire for the job you want.

Challenge Yourself

My last piece of advice is to constantly challenge yourself. First, expand your experience by learning about different aspects of the business that will help you to be successful in your next role. Learning about other aspects of the business such as finance, HR, product, sales, engineering, etc. will make you more effective in your current role and give you valuable experience for your next role. It will also generate empathy on both sides, which can pay dividends towards making your next security project a success.

Second, don’t focus on team size. Instead, focus on scope and impact of your role. You may think it is better to have an extremely large team, and while this can be good experience, it doesn’t really tell people anything about what you accomplished. Instead, focus on developing and articulating the scope and impact of your role. For a CISO and the security organization, this means becoming a trusted advisor for the rest of the business and translating your successes into career highlights.

This brings us to the last piece of advice I have, which is to keep a running “brag sheet” of your accomplishments. As you progress in your current role, write down your accomplishments and the things you learn that can be useful in future roles. Continually update your resume and social media profiles to capture these achievements so you don’t have to try and remember them when a new opportunity presents itself. Keeping your resume continually updated means it will be fresh and ready to go when a recruiter reaches out or your dream role opens up.

Wrapping Up

The biggest thing you should take away from this post is to continually improve yourself by gaining experience and credentials that will be useful in your next position. Have the foresight to think about your current position and the moves it will take to get you to your dream role. Start planning for that role today because it takes time to build up the right skills, credentials and expertise for your next job.

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.

Security Theater Is The Worst

We have all been there…we’ve had moments in our life where we have had to “comply” or “just do it” to meet a security requirement that doesn’t make sense. We see this throughout our lives when we travel, in our communities and in our every day jobs. While some people may think security theater has merit because it “checks a box” or provides a deterrent, in my opinion security theater does more harm than good and should be eradicated from security programs.

What Is Security Theater?

Security theater was first coined by Bruce Schneier and refers to the practice of implementing security measures in the form of people, processes or technologies that give the illusion of improved security. In practical terms, this means there is something happening, but what that something is and how it actually provides any protection is questionable at best.

Examples Of Security Theater

Real life examples of security theater can be seen all over the place, particularly when we travel. The biggest travel security theater is related to liquids. TSA has a requirement that you can’t bring liquids through security unless they are 3 ounces or smaller. However, you can bring a bottle of water through if it is fully frozen…what? Why does being frozen matter? What happens if I bring 100, 3 ounce shampoo bottles through security? I still end up with the same volume of liquid and security has done nothing to prevent me from bringing the liquid through. As for water, the only thing that makes sense for why they haven’t relaxed this requirements is to prop up the businesses in the terminal that want to sell overpriced bottles of water to passengers. Complete theater.

“Security theater is the practice of implementing security measures that give the illusion of improved security.”

Corporate security programs also have examples of security theater. This can come up if you have an auditor that is evaluating your security program against an audit requirement and they don’t understand the purpose of the requirement. For example, and auditor may insist you install antivirus on your systems to prevent viruses and malware, when your business model is to provide Software as a Service (SaaS). With SaaS your users are consuming software in a way that nothing is installed on their end user workstations and so there is little to no risk of malware spreading from your SaaS product to their workstations. Complete theater.

Another example of security theater is asking for attestation a team is meeting a security requirement instead of designing a process or security control that actually achieves the desired outcome. In this example, the attestation is nothing more than a facade designed to pass accountability from the security team, that should be designing and implementing effective controls, to the business team. It is masking ineffective process and technologies. Complete theater.

Lastly, a classic example of security theater is security by obscurity. Otherwise known as hiding in plain sight. If your security program is relying on the hope that attackers won’t find something in your environment then prepare to be disappointed. Reconnaissance tools are highly effective and with enough time threat actors will find anything you are trying to hide. Hope is not a strategy. Complete theater.

What Is The Impact Of Security Theater?

Tangible And Intangible Costs

Everything we do in life has a cost and this is certainly true with security theater. In the examples above there is a real cost in terms of time and money. People who travel are advised to get to the airport at least two hours early. This cost results in lost productivity, lost time with family and decreased self care.

In addition to tangible costs like those above, there are also intangible costs. If people don’t understand the “why” for your security control, they won’t be philosophically aligned to support it. The end result is security theater will erode confidence and trust in your organization, which will undermine your authority. This is never a place you want to be as a CISO.

Some people may argue that security theater is a deterrent because the show of doing “security things” will deter bad people from doing bad things. This sounds more like a hope than reality. People are smart. They understand when things make sense and if you are implementing controls that don’t make sense they will find ways around them or worse, ignore you when something important comes up.

With any effective security program the cost of a security control should never outweigh the cost of the risk, but security theater does exactly that.

Real Risks

The biggest problem with security theater is it can give a false sense of security to the organization that implements it. The mere act of doing “all the things” can make the security team think they are mitigating a risk when in reality they are creating the perfect scenario for a false negative.

How To Avoid Security Theater?

The easiest way to avoid security theater is to have security controls that are grounded in sound requirements and establish metrics to evaluate their effectiveness. Part of your evaluation should evaluate the cost of the control versus the cost of the risk. If your control costs more than the risk then it doesn’t make sense and you shouldn’t do it.

The other way to avoid security theater is to exercise integrity. Don’t just “check the box” and don’t ask the business you support to check the box either. Take the time to understand requirements from laws, regulations and auditors to determine what the real risk is. Figure out what an effective control will be to manage that risk and document your reasoning and decision.

The biggest way to avoid security theater is to explain the “why” behind a particular security control. If you can’t link it back to a risk or business objective and explain it in a way people will understand then it is security theater.

Can we stop with all the theater?

What’s The Relationship Between Security Governance and Organizational Maturity?

Organizational and security governance is touted as a key component of any successful security program. However, I’ve been thinking about governance lately and how it relates to the overall maturity of an organization. This has prompted some questions such as: what happens if you have too much governance? and What’s the relationship between security governance and organizational maturity?

What Is Governance?

First, let’s talk about what governance is.

Governance is the process by which an organization defines, implements and controls the business.

Let’s unpack what this means for a security organization. The process of defining security for the business is done through policies, standards and guidelines. Security policies are requirements the business must meet based on laws, regulations or best practices adopted by the business. These policies align to business objectives. Implementation is done through security controls that are put in place to meet a specific policy or to manage a risk. Lastly, controlling the business is done via audits and compliance checks. The security org follows up on how well the business is following policies, implementing controls and managing risk. Control can also include enforcement, which can involve gating processes, such as requiring approval for business critical and high risk activities, or recommending additional security requirements for the business to manage a risk.

Why Do We Need Governance At All?

In an ideal world we wouldn’t. Imagine a business that is created entirely of clones of yourself. There would be implicit and explicit trust between you and your other selves to do what is best for the business. Communication would be simple and you would already be aligned. In this case you don’t need a lot (or any) governance because you can trust yourself to do the things. However, unless you are Michael Keaton in Multiplicity, this just isn’t a reality.

Governance achieves a few things for a business. First, it communicates what is required of its employees and aligns those employees to common objectives. Second, it helps employees prioritize activities. None of this would be needed if human’s weren’t so complex with diverse backgrounds, experiences, perspectives, education, etc. In an ideal world we wouldn’t need any governance at all. The reality is, we do need governance, but it needs to be balanced so it doesn’t unnecessarily impede the business.

How Does This Relate To Organizational Maturity?

Organizational maturity refers to how your employees are able to execute their tasks to achieve the objectives of the business. This relates to things like the quality of code, how quickly teams resolve operational issues or how efficiently they perform a series of tasks. It can be loosely thought of as efficiency, but I actually think it combines efficiency with professionalism and integrity. Maturity is knowing what good is and being able to execute efficiently to get there. There is a fantastic book about this topic called Accelerate: The Science of Lean Software and DevOps: Building High Performing Technology Organizations by Nicole Forsgren PhD.

Which brings us to the relationship of governance and maturity…

There is an inverse relationship between organizational maturity and organizational governance. In simple terms:

The less mature an organization, the more governance is needed.

For example, if your organization struggles to apply patches in a timely manner, continually introduces new code vulnerabilities into production or repeatedly demonstrates behavior that places the business at risk, then your organizational maturity is low. When organizational maturity is low, the business needs to put processes and controls in place to align employees and direct behavior to achieve the desired outcomes. In the examples above, increased governance is an attempt to manage risk because your employees are behaving in a way that lacks maturity and is placing the business at risk.

What causes low organizational maturity?

Organizational maturity is a reflection of employee behavior, skillset, knowledge, education and alignment. In other words, organizational maturity is a reflection of your organizational culture. In practical terms your employees may simply not know how to do something. They may not have experience with working for your type of business or in the industry you operate in. Perhaps they had a really bad boss at a past job and learned bad behavior. Whatever the reason, low organizational maturity is linked to lots of sub-optimal outcomes in business.

How To Improve Organizational Maturity?

If governance and maturity are inversely linked, the question becomes how can we increase organizational maturity so we need less governance? There are a lot of ways to increase organizational maturity. One that is fairly obvious is to start with a mature organization and maintain it over time. However, this is easier said than done and is why some organizations are fanatical about culture. This relates to everything from hiring to talent management and requires strong leadership at all levels of the company.

“The less mature an organization,
the more governance is needed.”

Other ways to improve organizational maturity are through training and education. This is why security awareness and training programs are so critical to a successful security program. Security awareness and training programs are literally attempting to improve organizational maturity through education.

One last way to improve maturity is via process. The security organization can establish a new process that all teams must follow. As teams go through this process you can educate them and reward teams that exhibit the ideal behavior by relaxing the process for them. You can also help teams educate themselves by publishing the requirements and making the process transparent. The challenge with imposing a new process is having the discipline to modify or remove the process when needed, which comes back to governance.

What’s the right level of governance?

The optimal level of governance is going to be based on your organizational maturity and desired business outcomes. In order to determine if you have too much or too little governance you need to measure organizational maturity and the effectiveness of existing organizational governance. There are industry standard processes for measuring organizational maturity, like the Capability Maturity Model Integration (CMMI) and Six Sigma, or you can create your own metrics. Some ways to measure governance effectiveness are:

Ask For Feedback On Security Processes – Are the processes effective? Do teams view them as an impediment or are they viewed favorably? Are the processes easy to navigate and objective or are they opaque and subjective?
Measure Effectiveness Of Security Controls – Are your security controls effective? If you ask a team to do work to implement a security control you should have clear metrics that determine if that control is effective. If you implement a control, but that control hasn’t changed the outcome, then the control is ineffective. This can indicate your governance is ineffective or your organizational maturity needs to improve.
Assess and Update Policy – Security policies should be living documents. They shouldn’t be set in stone. Security policies need to map back to laws and regulations they support and the business requirements needed to be successful. Laws, regulations and business requirements all change over time and so should your security policies. By having up to date and relevant security policies you can ensure your organizational governance matches the maturity of the business.

What Are Typical Scenarios For Governance And Maturity?

There are four scenarios related to governance and maturity:

A mature organization with too much governance – your organization is mature, but you are overly controlling with process and requirements. The net effect will be to slow down and impede the business unnecessarily. You are effectively lowering the organizational maturity due to too much governance.

An immature organization with too little governance – this is a recipe for disaster. If your organization is immature and you fail to govern the organization you will open the business up to unnecessary risk. You will get out maneuvered by your competitors, you will miss opportunities, you will fail to comply with laws and regulations and generally will have a lot of activity without any result. Your employees will lack coordination and as a result your business will suffer.

A mature organization with too little governance – This isn’t a bad scenario to be in. A mature organization implies they are doing the right things and don’t need a lot of guidance. A laissez faire attitude may be the right thing to allow employees flexibility and freedom, but it does come with inherent risk of not being compliant with laws and regulations. It may also mean there is duplication of effort or multiple ways of doing things, which could be optimized.

Governance and maturity are balanced – obviously this is the ideal scenario where your organizational governance is balanced to the level of maturity of the organization. Easy to think about in practice, difficult to achieve in reality.

Wrapping Up

Organizational governance and maturity are inversely related and need to be balanced in order for the business to operate effectively. There are ways to measure organizational maturity and governance effectiveness and by having a continual feedback loop you can optimally align both for success.

Using Exceptions As A Discovery Tool

Security exceptions should be used sparingly and should be truly exceptional circumstances that are granted after the business accepts a risk. In mature security programs the security exceptions process is well defined and has clear criteria for what will and will not meet the exception criteria. In mature programs exceptions should be the exception, not the norm. However, in newer security programs exceptions can be a useful tool that provides discovery as well as risk acceptance.

Maturing A Security Program

One of the first things a new CISO will need to do is understand the business and how it functions. As part of this process the CISO will need to take an inventory of the current state of things so he or she can begin to form a strategy on how to best manage risk. As a new CISO your security program may not have well defined security policies and standards. As you begin to define your program and roll out these policies, the exception process can be a valuable tool that gives the perception of a choice, while allowing the security team to uncover areas of the business that need security improvement. Over time, as the business and security program mature, the CISO can gradually deny any requests to renew or extend these exceptions.

Rolling Out A New Security Process

Another area that is useful to have an exceptions process is when rolling out a new security process. For example, if you are rolling out a new process that will require teams to perform SAST and DAST scanning of their code and fix vulnerabilities before going into production, then allowing security exceptions during the initial rollout of the process can be useful to allow teams more time to adapt their development processes to incorporate the new security process. Allowing exceptions can foster good will with the development team and allow the security function visibility into the behavior and culture of the rest of the business. This can allow the security function and development team the opportunity to collaborate together with the ultimate goal of removing any exceptions and following the process to reduce risk to the business.

Tackling Security Tech Debt or Shadow IT

A common maturity evolution for companies is the elimination of shadow IT. The security function can assist with the elimination of shadow IT by creating an exception process and allowing an amnesty period where the business is allowed to continue to operate their shadow IT as long as it is declared. In reality you are giving the business the perception that they will be granted an exception when they are really giving the security function visibility into things they wouldn’t otherwise know about. This can be a useful tool to discover and eliminate policy exceptions as long as it is used sparingly and with good intent (not punitively).

Documentation Is Key

No matter how you choose to use exceptions within your security program there are a few best practices to follow.

Exceptions should be truly exceptional. If you do grant one for discovery purposes make sure there is a plan to close the exception. Exceptions shouldn’t be the rule and they shouldn’t be expected. Sometimes the rest of the business just needs someone to tell them no.
Time box the exception. Don’t just grant an exception without some sort of end date. The business needs to know an exception is temporary and there should be a well defined plan to make improvements and close the exception. The security team should grant a reasonable amount of time to execute that plan, but it shouldn’t be a never ending story.
Review often. Security exceptions should be reviewed often. Part of your security program should review the open exceptions, which ones are ending, if there are patterns where there are lots of similar exceptions and if there are teams who request a high volume of exceptions. Reviewing exceptions gives you insight into how well security processes and controls are working. It also gives you insight into which parts of the business need help.
Require the business owner to sign off. The reality of a well run security program is the business ultimately owns the decision if they want to accept a risk or not. The CISO makes a recommendation, but they don’t own the business systems or processes. As a result, the security exception process should require the business owner to sign off on any exception. This will ensure there is documentation that they were made aware of the risk, but this can also act as a visibility tool for the business owner into their own teams. I’ve often found a business leader is not always aware of what their teams are doing at the tactical level and the exceptions process can provide them the opportunity to check their team and correct behavior before it gets to the CISO.

Wrapping Up

The exception process can be a valuable tool for discovery of hidden risk throughout the business. By offering an amnesty period and giving the perception of flexibility, the security team can foster good will with the business while gaining valuable visibility into areas that may be hidden. The exception process also is a valuable tool for the security program to document risk acceptance by the applicable business owner, but can also provide business owners visibility into how well their team is meeting security requirements. Lastly, as the security program matures, the security team can gradually require the business to close down the exceptions by improving their security posture.

Defining Your Security Front Door

A key skill for any security program is to partner with and enable the business to be successful. CISOs need to ensure their security teams are approachable, reasonable and most importantly balancing the needs of the business against potential security risks. While security teams exist to help protect the business, they don’t own the business systems or processes and as a result need to adopt an advisory or consultative role with the rest of the business to ensure success.

With that in mind, the way the rest of the business finds and engages with the security team can create a good first impression or can set the tone for a difficult interaction. Think of a house that has great curb appeal – it feels inviting and gives the impression that the owners take good care of their property. The same concept exists for the security program, which I call the Security Front Door.

The Front Door Concept

The security front door defines how the rest of the business engages with and interacts with the security team. The front door can be a confluence page, slack channel with pinned information, or some place that is easily discoverable and accessible. Your security front door should clearly lay out information and resources so the rest of the business can either self serve or easily request and receive help when needed.

What Should Be In Your Front Door?

The front door for your security program should include ways to perform the most commonly requested actions from the security team. For example, you probably want really clear ways to request the following:

Report an incident
Request vulnerability remediation help
Request an exception
Request an architectural review
Dashboards
Discover documentation for policies and processes
Other – a general way to request help for anything else

The front door is not just a way to make a good first impression and enable the business, but when set up correctly it can actually offload the security team and help the business move faster.

Wrapping Up

The front door is a great way to engage with the business to help them move faster, find information and request assistance from the security team. When done correctly it can allow the rest of the business to self serve and can actually offload the security team by reducing the volume of requests that come in. Setting up the security front door may require a lot of up front work, but by understanding the rest of the business, their key pain points and most commonly requested security asks, you can design a front door that will be a win-win for everyone.

Annual Planning For CISOs

The beginning of the year is a popular time for making personal resolutions, which can focus on health, finance or love. While the beginning of the year is a popular time to set resolutions, really what we are talking about is setting goals to improve ourselves. I’m a huge proponent of setting personal goals for the year because it gives focus and purpose to your actions. The beginning of the year is also a great time to review the annual goals of your security program to set your focus and establish priorities. Annual planning has several objectives that CISOs need to consider and include in their process and I’ll cover them in the rest of this post.

Strategic Planning (Strat Planning)

Strategic, or “strat” planning as it is sometimes called, looks at where the business and your organization want to be over a long term time period. Something like 18 months to 5 years is typical in strat planning. The planning session should include discussion of the one or more of the following macro level business topics:

Market forces and opportunities
Industry trends
Regulatory and legal landscape
Competition
Customer sentiment, goals, etc.
Economic and financial environment
Geo-political climate
Technology trends and latest research

This discussion could be part of a SWOT analysis (Strengths, Weaknesses, Opportunities, Threats), but the goal is to understand where your business is and where you want it to go in the long term.

Align The Security Program

Once the business has a strategic plan, the CISO should conduct a similar planning exercise for where they want the security program to be. These are sometimes called “North Stars”, but they are essentially high level objectives over the long term that merge technology trends, regulatory requirements and security goals into long term objective. These won’t be very specific, but instead should act as guidance for where your team should focus and hopefully end up over the next few years.

Examples

An example of a strategic trend and security objective are as follows:

Trend: As companies shift from the datacenter to the cloud and bring your own device (BYOD), the concept of a traditional perimeter no longer makes sense.

Strategic Security Objective: Shift to a zero trust strategy where identity becomes the perimeter.

The goal is to choose big ticket objectives that will take multiple years to achieve, but will provide guidance to your org and the rest of the business about the direction your team is taking. Your strategic plan will inform the next section, which is your operational plan.

Operational Planning (Op Planning)

Operational planning is more tactical in nature and covers a shorter time period than strategic planning. Op planning usually follows either a fiscal or calendar year that way it aligns to performance reviews and budgeting cycles. In op planning the CISO will select the high level goals they want the security organization to complete that year. Usually op planning will include discussion and planning of the following:

Budget creation, forecasting and changes
Headcount planning
Technology investments (if any)
Top risks to focus on
Any audits or compliance certifications needed that year
Development of timing and roadmap for completing specific projects and tasks
Discussion of security controls and services
Skill gaps and training requirements

The point is to create a tactical plan for the year that will inform your team’s specific goals and objectives. These goals should be clear and measurable. I typically use an iterative approach to break my goals down to my directs and then they break their goals down to their teams and so on. This ensures alignment throughout the business.

Measuring and Adjusting

One important aspect of any plan is to continually measure progress and adjust if needed. Goals and objectives aren’t useful if the business has shifted and they are no longer relevant or have become un-obtainable.

Wrapping Up

Strategic and operational planning are important activities for every CISO. These plans define the long term vision for the security organization and break down that vision into tactical objectives that are accomplished throughout the year. This post discussed a high level overview of what goes into strategic and operational planning, but aligning security plans to business risk, mapping security controls, obtaining funding and reporting progress are all complex activities that every CISO needs to master.

Career Options Post CISO

Last year was a busy year for CISOs. Increased regulation from the SEC and other entities are raising the stakes for companies and CISOs. 2023 demonstrated that regulators and law enforcement are not only going to hold companies accountable for incidents and breaches, but they will also pursue accountability against individual CISOs. The CISO role is at an inflection point created by new technologies, increases in regulation and unprecedented personal risk. Given the high stakes of the role I think we are going to see an exodus in the number of people who are willing to shoulder the burden and personal liability of this role. Which begs the question: what are the options for someone after serving in a CISO role?

Serving On A Board

Serving on a board seems like a popular choice lately and now that the SEC has mandated cybersecurity experience on the board I think companies will look to increase their board membership with former CSOs and CISOs. The challenge with serving on a board is finding one that can compensate you sufficiently. I’ve served on several boards over the past 15 years and the compensation will depend on the company size and maturity. Start ups are typically able to offer compensation in the form of equity in the company, but this may turn out to be worthless if the company doesn’t make it. Big company board positions are few and far between, but will pay the best. My advice for CISOs looking to transition into a paying board position is to serve on a board or several boards in your spare time and then transition to become a full time, paid, board member if and when the company can support it.

Advisory CISO / CISO In Residence

One way to “float” between a CISO role and a board member role is to get connected with a Private Equity (PE) or venture Capital (VC) company as an Advisory CISO or CISO In Residence. These roles help the PE and VC companies evaluate potential investments and then help guide the companies to success. If you are an Advisory CISO you can evaluate the companies and if you see one you think has real potential you can choose to be their CISO or serve on their board. Advisory CISOs are not only compensated by the PE / VC company, but they “consult” to the investment companies on a periodic basis and sometimes they are offered the opportunity to invest in the companies they are advising. Not a bad gig.

Consultant

One of the most common post C-Level career paths is to become a consultant. If you are well connected, are in a critical industry or are just great with people, this can be a viable career option. The experience you have built up over your career still has value and companies will pay you handsomely for your time to help advise them. If you work for a company that is unwilling to protect you if you are sued then this may be a way to continue in a CISO capacity, but without the personal risk. I’ve known people who have quit their current role out of frustration and when the company realizes the expertise they are about to lose they hire the person back as a consultant.

Field CISO

Field CISOs are fancy titles for people that are in sales or pre-sales. They typically have a specific region they are assigned and they use the Field CISO title to establish executive relationships with other CISOs and C-Suite members to help sell products and services. Field CISOs typically have extensive industry experience in a particular vertical and then they use that expertise to help tailor solutions to their customers.

Title Change (But Still Security)

Another option post CISO role is to get a title change, but still work in a security related role. This could be something like a Chief Trust Officer or Chief Risk Officer. These roles can offer more flexibility to have a positive impact on the business because they aren’t constrained by the same expectations as a CISO role. At the end of they day you are still a C-Level security executive and can continue to advance your career towards your goals.

Role Change (Not Security)

CISOs are one of the few roles that touch every aspect of the business. As a result, CISOs are well versed in a lot of different business disciplines and it would be easy for a CISO to transition to a CTO, CIO, engineering executive or product executive. For example, a CISO who is looking to exit the role may look to join a security focused startup as their CTO. Their deep industry experience and past credentials will provide credibility and allow them to continue working in the security space in a different capacity. Eventually, they can even hire a CISO to report to them and have oversight over the security function.

Start A Company

CISOs are also well positioned to see gaps in the industry where a solution hasn’t been developed. Lots of well known companies have been formed by former security executives who have left their role to start a company to develop a security related product or service. Starting a company doesn’t mean you have to develop a new technology. You could also start a consulting company, a training company or a staffing company. If you are sitting on a great idea then this is a viable option for you.

Double Down

Lastly, if you enjoy the CISO role, but don’t feel supported or protected by your current company, then find a new CISO role that gives you the support and protection you seek. Part of the interview process for your new role should include questions about who the role reports to, what is the expected budget and headcount, will the role be included in the D&O Policy, what happens if you are personally sued, what is the severance package and how will success be measured? These should all be table stakes for any company looking to hire or retain a CISO and satisfying these requirements will go a long way to making your CISO feel comfortable that you have their back and won’t treat them as a scapegoat.

Chief Incident Scapegoat Officer (CISO)?

Last week the SEC filed a complaint in the Southern District of New York charging SolarWinds and specifically its CISO, Timothy Brown, with fraud. According to the compliant, the SEC alleges the company and Brown made false statements about its security posture to investors. Along with the Uber CISO, Joseph Sullivan, this is the second CISO in the past year to be specifically charged for failing to do their job. In my opinion, these court cases are going to negatively impact the CISO role and make security less transparent to investors. Let’s dive in.

What About The Other C-Levels?

Both cases are unique, however the first thing that stands out to me is only the CISOs are being named and charged. I find this odd because in an ideal organization the CISO still has to partner closely with the other C-Level execs to achieve security objectives. Things like external messaging to customers, SEC filings, etc. all require the coordination and knowledge of other C-Level execs like the CFO, Legal, Marketing and even the CEO. Why aren’t these individuals being named and charged for also contributing to the fraud?

In the worst case scenario, a CISO is poorly supported and struggles to get any of their security objectives funded or implemented. Is the CISO to blame in this scenario? What about the CEO and CFO who withheld funding? How about the Engineering leader who failed to prioritize the security recommendations of the CISO? The point is, I have never found a situation where a CISO is able to operate in a vacuum and so the other C-Level execs also have a responsibility to make sure the company is making true statements and not perpetrating fraud. They should all be held equally accountable.

Responsibility Without Authority

The CISO role has had a lot of press and a surge in visibility over the past few years, but the role still has a long way to go to be on par with other C-Level roles. It is common for the CISO role to report to the CTO, CIO or Chief Legal Counsel. It is uncommon for the CISO role to have a direct reporting line to the CEO. We can discuss who the CISO should report to, but in my opinion, the CISO role still needs to mature compared to the other legacy C-Level roles. The position is currently not on the same level as a CTO or CIO role and this impacts the scope and authority of the role.

Additionally, most CISOs don’t actually own the things they are trying to improve the security posture of. There is always a business or engineering owner that is actually responsible for building and operating the systems that make the company money. As a result, the CISO role typically ends of with all of the responsibility for security, but none of the authority. If the CISO makes a recommendation to fix something and the engineering leader rejects it, who is held accountable for that decision?

Chilling Effect On Open Discussion

My biggest concern with the SEC complaint is the reference to emails that are pointing out the known security issues with the Orion system. Matt Levine wrote a great article in Bloomberg questioning the SEC’s logic and I agree with his assessments. I have never read an SEC filing or investment statement expecting the company to highlight their massive security investments. In fact, I would question if a company should disclose that in a filing at all (unless it is material) because you may inadvertently provide information to attackers that could be used to hack the company.

Additionally, most security teams openly discuss security issues via chat or email. I find these discussions are almost always expressing frustration with current situations with the goal of gaining support for investment to remedy the issue. However, discussions via chat and email also happen to be legally discoverable forms of communication. This means every single email about how much your security sucks will be taken out of context by lawyers and used against you. The obvious solution is to never put your current security failings in writing, which means you can never create a presentation to convince the company to invest in improving security. Or alternatively, if you do place things in writing you frame them in a way that they are asking for legal advice so they can be protected by legal privilege.

Predictions For the CISO Role

I wrote a blog post after the Uber verdict, but both the Uber and SolarWinds cases have caused significant anxiety within the CISO community, which I think will impact the CISO in the following ways going forward:

New CISOs hiring into a role will require companies to list them on their Directors and Officers (D&O) Liability Policy. Also, based on this Bloomberg Law Article about FTX, I recommend making sure the D&O policy specifies how much you will get if all the executives are trying to use the policy at the same time for legal fees.
It will become standard for companies to cover the costs for legal counsel specified by the CISO, should they be individually named in a lawsuit.
As these cases become more common, CISOs will demand higher compensation and protect themselves contractually to minimize their personal risk.
Companies will (hopefully) prioritize security investments to minimize the risk of lawsuits, regulatory actions or security incidents.
Costs for companies to employ and retain a CISO will go up over time.
In extreme cases, the CISO role may shift from a salaried employee to a consultant (I-9) to offload the accountability for security to the company and protect themselves.

Final Thoughts

I can’t recall the last time I saw a CTO or CIO charged with investor fraud for making false statements about their products or enterprise environment. Yet, the CISO role has been getting a lot of scrutiny from regulators recently. I’m all for holding people accountable, but the CISO role doesn’t seem to carry the same weight as the CTO or CIO. The role still struggles with gaining support and funding to place security first. If a company culture is weak or the other executives minimize security, then the CISO will fail to make any meaningful progress. In my opinion, if the CISO of the company is named, then all the officers should be named to drive home the message that they are all accountable for the security of the company.