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– ITAM Policies Keynote
Keynote – ITAM Policies Foundations for success ITAM Policies, approved at the highest levels and enforced across your entire organisation are a critical foundation for any IT Asset Management function or programme. Kylie Fowler, Principle Consultant at ITAM Intelligence, will present a case study demonstrating how working with the Information Security team of a large federated multi-national allowed her to define and implement ITAM policies, approved at Board Level and communicated across the business. About Kylie Kylie has supported organisations including Balfour Beatty Plc and Interserve Plc to leverage the benefits of IT asset management and achieve their business objectives. Kylie is passionate about bringing her expertise to support businesses of all sizes to reduce risk and achieve a return on their IT investment. Kylie is Convenor of the UK SAM Networking Group, a regular invited speaker at industry events and has published a number of thought leading articles. 1 ITAM Policies Foundations for Success Agenda Background What we did Outcomes Conclusions Questions & comments 3 ITAM Policies – Foundations for Success Background The Scenario The company - >15,000 seats Multi-national Several verticals, including secure public sector (eg Dept of Defence contracts) Federated business structure • - Significant systemic risks • actions of one business unit may adversely impact others Low margin business • Low incentive to spend money to manage low probability - high impact risks 5 What is a federated organisation? How do you manage systemic risk? Group Plc Profits Governance & Management Work!! Division Division Profits Profits Business Unit Business Unit Profits Profits Contract Contract Contract Contract Business Unit Business Unit Profits Profits Contract Contract Contract C O N T R O L Contract 6 Governance through assurance Group IT defines a minimum set of outcomes - These outcomes are described in the Group Policies and Standards - Focus on managing areas of activity with significant systemic risk Divisions & business units define their own policies - Must meet these minimum requirements - Some business units may define stricter policies eg 27K accredited business units Business units and contracts define processes and procedures - Must produce the outcomes required by the policies to the required standard Group assures the policies, process, and procedures - Will they produce the required outcomes? 7 Assurance governance model How do you manage systemic risk? Group Plc Policies Division Division Policies Policies Business Unit Business Unit Processes Processes Business Unit Business Unit Processes Processes Contract Contract Contract Contract Contract Contract Contract Contract Outcomes Outcomes Outcomes Outcomes Outcomes Outcomes Outcomes Outcomes A S S U R A N C E 8 ITAM Policies – Foundations for Success What we did Current state ITAM Current State and Maturity Assessment - Identified lack of global policies and standards as a concern - No global policies defined or approved at Exec Board Level Some local policies in place, but no assurance that they are adequate or are at the standard required of a large multinational corporation Information Security also addressing the lack of policies and standards - ‘Dotted line’ from CISO to Company Secretary and Corporate Risk Board - Joined the Information Security Forum - - Policies, standards and recommended assurance processes being socialised across the federated divisions Socialisation at Exec Board level in progress - - Utilising the ‘Standard of Good Practice and Information Security 2014’ to define comprehensive set of policies and standards for implementation across the company Information Security Policy to be approved at Board level Subsidiary policies and standards to be approved by a lower level approval body consisting of divisional representation Info Sec recognise ITAM as a pre-requisite for effective Information Security 10 The challenges Policy ‘fatigue’ - Concern that senior stakeholders would not support a second policy development and approval process Lack of Exec Sponsorship for ITAM as such - ITAM has a high profile but mainly because of past security breaches - Perceived as an Info Sec issue 11 The recommendation Implement ITAM Policies through the vehicle of the Info Sec Policies - Complete a gap analysis between Information Security Policies and Standards and ITAM equivalents Work with Information Security to modify policies to minimise gaps Report outstanding gaps back to Head of IT Governance to determine next steps CIO Sponsorship obtained for this approach - Consultant (ie me!!) engaged to implement recommendations 12 The process Review ITAM ‘policy library’ - Identify policies appropriate to this organisation Identify standards that meet Group minimum requirements - Focus on systemic risks Avoid being prescriptive about details best left to the business to determine Review draft Info Sec policies - Record which clause covered which ITAM policy / standard Identify gaps / areas where amendments would need to be made Agree changes to be made to the drafts 13 Structure of the Policy Documents Information Security Policy Information Security Standard Human Resource Management Policy Asset Management Policy Systems Management Policy Access Management Policy Human Resource Management Standards Asset Management Standards Systems Management Standards Access Management Standards Acceptable Use Policy Other Info Sec Policies Other Info Sec Standards 14 The process continued Amend Info Sec policies and standards - The majority of amendments were made to the standards - There was a bit of ‘back and forth’ to explain the relevance of some amendments and why they should be included Document the ITAM policy requirements and their location - List of all relevant ITAM policies and which section of the Information Policies cover them 15 The process continued Report outstanding gaps to IT Governance - Disposal of Waste Electrical and Electronic Equipment - - The nature of the business means this issue is bigger than IT and needs to be addressed by Sustainability policies IT systems design to consider software licensing compliance - Need to consider systemic or indirect licensing implications of system design Will refer to Technology Strategy Director for action 16 Changes we made Acceptable Use Policy - All end user oriented policies were added to this document eg - Do not download or install non-approved software Do not give or loan IT Assets to other individuals Assets can be audited and under-utilised assets will be reused IT Asset Management Standard - The policy and standards already specified a requirement to maintain an asset register - - Both hardware and software Provided additional detail regarding how asset register accuracy should be maintained Specify that asset register is checked for software licensing prior to granting system access Implementation of arrangements to support asset tracking and their relationships to each other Implementation of arrangements to enable auditing of software licensing compliance 17 Changes we did NOT need to make Of relevance, but minimal changes required to: - Human resource management standard Third party access standard Access management standard System management standard Mobile computing standard External supplier policy System development management standard Systems development lifecycle standard 18 ITAM Policies – Foundations for Success Outcomes What we achieved A set of comprehensive set of ITAM policies - Single set of integrated policies Approved at Board level and enforceable globally Info Sec and ITAM leveraging and reinforcing good practice Next Steps - Develop ITAM governance and assurance model Aligned but separate to Information Security governance and assurance - Different people, processes and practices, but a single set of policies 20 What I learned Changes to my ‘Policy Library’ - Became less prescriptive - instead of ‘thou shalt not’ it now reads ‘determine the standard regarding...’ eg can IT Assets be used for reasonable personal use? (but note; must define ‘reasonable personal use’) - Added sections regarding Systems Design and the need to take into account ITAM requirements Changes in attitude and thinking - Differentiate between Group level and business unit level policies eg - - Group level: IT Assets to be purchased through prescribed authorisation processes Bus unit level: No reimbursement for software or hardware purchased on a credit card Focus on reputational and systemic risks rather than financial or business unit focused risks - If a business unit or contract wants to waste money or resources through poor ITAM that is their decision to make 21 Conclusions Info Sec and ITAM speak different languages - Info Sec are focused on risks to Information Assets - Regulatory and contractual risks are only relevant where it may impact Information Assets - - Confidentiality Integrity Availability Luckily for ITAM practitioners, the potential for software copyright owners to restrict availability to software means software licence compliance is a consideration for Information Security practitioners! However - ITAM is undoubtedly a pre-requisite for good Info Sec - Many good Info Sec practices are good ITAM, even in areas that are NOT obviously related eg procurement practices There may still be a need for detailed ITAM policy documentation - Particularly for centralised businesses and at the IT Organisation level - But this exercise would certainly give you a head start! 22 Thank you!