Even though many compliance mandates such as HIPAA require risk assessments only be performed annually, that's not nearly often enough for most organizations, says Gary Alterson, director of risk and advisory services for Neohapsis.
[How do you know if you've been breached? See Top 15 Indicators of Compromise.]
"Given the rapidly changing threat environment and how fast IT moves, I recommend that risk assessments be refreshed and reviewed at least quarterly, if not monthly," Alterson says.
But the reality is that most organizations today have a hard enough time keeping up with their annual risk assessments, says Jim Mapes, chief security officer at BestIT, which is why he says that organizations have to rethink the way they approach the process.
"A better approach is to make risk assessments more of a life cycle and process within the organization," he says. "Perform assessments continuously throughout the year, collecting data on new vulnerabilities, remediation of older vulnerabilities, and identification of problem areas where vulnerability could not be remediated and recording the business decision to mitigate the risk and impact to some other acceptable level."
Crucial to that evolution to a life cycle mentality is building time and resources into the IT life cycle for internal auditors, says Alterson's colleague, Nathaniel Couper-Noles, principle security consultant for NeoHapsis. According to Couper-Noles, one of the most common refrains he has heard from auditees is they're too busy for an internal audit.
"Paradoxically, a lack of reserve capacity actually justifies audit attention as this is often the case when schedules are too aggressive, when projects are in the lurch, controls may be relaxed, and uncorrected small issues lead to bigger ones," he says. "Audit early and audit often, and condition IT teams to design processes and systems so that they can be audited comprehensively, painlessly and effectively."
Part of that design should include day-to-day tracking of operational risk factors that affect the business' security posture. This is especially key for keeping track of changes in the IT environment or the threat environment that happen between assessments. While it may seem a tall task, organizations can at least get started on a more continuous assessment process by prioritizing.
"Don't try to conquer the world all at once! Focus on what matters most by identifying the proprietary, financial, and customer data that we tend to be most risk-adverse about when it comes to its protection," says Luke Klink, security consultant for Rook Consulting.
Finally, most critical is that organizations shouldn't just be assessing risks but also working on mitigating them throughout the life cycle. Leaving the same critical risks to be identified in assessment after assessment is the security equivalent to wheel-spinning and something that Eric Cabetas, managing partner of Include Security, says says organizations do all of the time.
"I've seen a company have an AppSec SDLC assessment conducted yearly, and they pay $200,000 for it just to ignore the recommendations of the consulting company year after year," he says. "The consulting company happily takes their pay and leaves until next year, not providing any value at all to the assessed company. They should have instead done an analysis of why originally identified risks are not being addressed within the client company."
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