As regulatory compliance demands have risen from HIPAA, Sarbanes-Oxley, PCI DSS, and various state data breach disclosure laws - and more compliance mandates expected to rise - I've often wondered if there's any long term damage to the IT security program by using regulatory compliance mantra as a crux for winning budget. And does doing so move the organizational goal from obtaining a secure IT infrastructure to merely being compliant?
I posed this question in an e-mail to the analysts at IT security research firm, Securosis, including its president Mike Rothman, CTO, Adrian Lane, and firm founder Rich Mogull.
Rich Mogull generally agreed with the premise of the question, and sees the risk of using compliance as budget justifier as a risk for setting compliance as the organization's top goal, not security itself:
I think this one is a self-fulfilling prophecy. Security managers that have to use compliance as the primary justification are either bad at their job (the skill of communicating with the rest of the organization), or work someplace where using the compliance hammer is their only option. In both cases, the odds become high that the result is compliance as the security ceiling.
Security managers don't need to use the compliance hammer as often if they communicate well and have a receptive audience. With most of the IT managers I've talked with, they over-use compliance and create that ceiling out of necessity- the ceiling was underground to start with.
Mike Rothman, makes the argument that security professionals need to speak well with all of the constituencies in their organization, and learn how to align their interests with the interests of other managers in the business, And, perhaps, relying too heavily on compliance to snag budget may mean communication skills need to be shined a bit:
Security professionals need to be able to tell multiple stories to multiple constituencies within their own organization. So for their technical peers, they have to appeal to saving money on operations costs or the downside risk of cleaning up a security mess. For senior management, it's all about how to make more money or spend less money. Or to comply with some regulation that has the bigwigs worried. The most important thing for security folks is to get the resources they need, if that means they need to leverage compliance. It's all good.
Adrian Lane added that it's good to use compliance as a tool for budgetary wins, but make it clear while doing so, that compliance isn't the end game, rather an outcome of a good security program:
Security people know it is better to ask for forgiveness than permission when it comes to budget. The important thing for security folks is to get the resources they need, and if that means getting security capabilities through compliance, it's all good! The investment in a security product that solves compliance requirements can also clean up a security mess with a single investment. The problem you describe is really more an issue of managing expectations: it's critical to position compliance as a benefit of doing security correctly.
That being said, it's critical to position compliance as a benefit of doing security correctly. It's really more about managing expectations, in that there is no 100% security and being compliant does not mean an organization is secure. Not by a long shot.
If welding the regulatory compliance fear-stick is the only way to obtain budget, than use the only tool you have and know. But in the meantime, try to do a better job aligning your interests in securing the business with the interests of management. And make it clear, along the way, that compliance is a product of good security - not the path to security itself.