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What follows is a template to help guide you in developing your own cybersecurity plan. This template has at its core a modified version of the template structure suggested in the late 2018 ''Cybersecurity Strategy Development Guide'' created for the National Association of Regulatory Utility Commissioners (NARUC).<ref name="NARUCCyber18" /> While their document focuses on cybersecurity for utility cooperatives and commissions, much of what NARUC suggests can still be more broadly applied to all but the tiniest of businesses. Additional resources such as AHIMA's ''AHIMA Guidelines: The Cybersecurity Plan''<ref name="DowningAHIMA17" />; National Rural Electric Cooperative Association (NRECA), Cooperative Research Network's ''Guide to Developing a Cyber Security and Risk Mitigation Plan''<ref name="LebanidzeGuide11" />; and various cybersecurity experts' articles<ref name="LagoHowTo19" /><ref name="NortonSimilar18" /><ref name="EwingFourWays17" /><ref name="KrasnowCyber17" /><ref name="CopelandHowToDev18" /><ref name="TalamantesDoesYour17" /> have been reviewed to further supplement the template. This template covers 10 main cybersecurity planning steps, each with multiple sub-steps. Additional commentary, guidance, and citation is included with those sub-steps. | What follows is a template to help guide you in developing your own cybersecurity plan. This template has at its core a modified version of the template structure suggested in the late 2018 ''Cybersecurity Strategy Development Guide'' created for the National Association of Regulatory Utility Commissioners (NARUC).<ref name="NARUCCyber18" /> While their document focuses on cybersecurity for utility cooperatives and commissions, much of what NARUC suggests can still be more broadly applied to all but the tiniest of businesses. Additional resources such as AHIMA's ''AHIMA Guidelines: The Cybersecurity Plan''<ref name="DowningAHIMA17" />; National Rural Electric Cooperative Association (NRECA), Cooperative Research Network's ''Guide to Developing a Cyber Security and Risk Mitigation Plan''<ref name="LebanidzeGuide11" />; and various cybersecurity experts' articles<ref name="LagoHowTo19" /><ref name="NortonSimilar18" /><ref name="EwingFourWays17" /><ref name="KrasnowCyber17" /><ref name="CopelandHowToDev18" /><ref name="TalamantesDoesYour17" /> have been reviewed to further supplement the template. This template covers 10 main cybersecurity planning steps, each with multiple sub-steps. Additional commentary, guidance, and citation is included with those sub-steps. | ||
Note that before development begins, you'll want to consider the resources available and key stakeholders involved. Do you have the expertise available in-house to address all 10 planning steps, or will you need to acquire help from one or more third parties? Who are the key individuals providing critical support to the business and its operations? Having the critical expertise and stakeholders involved with the plan's development process early on can enhance the overall plan and provide for more effective strategic outcomes.<ref name="NARUCCyber18" /> | Note that before development begins, you'll want to consider the knowledge resources available and key stakeholders involved. Do you have the expertise available in-house to address all 10 planning steps, or will you need to acquire help from one or more third parties? Who are the key individuals providing critical support to the business and its operations? Having the critical expertise and stakeholders involved with the plan's development process early on can enhance the overall plan and provide for more effective strategic outcomes.<ref name="NARUCCyber18" /> | ||
===5.1. Develop strategic cybersecurity goals and define success=== | ===5.1. Develop strategic cybersecurity goals and define success=== | ||
====5.1.1 Broadly articulate business goals and how information technology relates==== | ====5.1.1 Broadly articulate business goals and how information technology relates==== | ||
Something should drive you to want to implement a cybersecurity plan. Sometimes the impetus may be external, such as a major breach at another company that affects millions of people. But more often than not, well-formulated business goals and the resources, regulations, and motivations tied to them will propel development of the plan. Business goals have, hopefully, already been developed by the time you consider a cybersecurity plan. Now is the time to identify the technology and data that are tied to those goals. A clinical testing laboratory, for example, may have as a business goal "to provide prompt, accurate analysis of specimens submitted to the laboratory." Does the lab utilize information management systems as a means to better meet that goal? How secure are the systems? What are the consequences of having mission-critical data compromised in said systems? | |||
====5.1.2 Articulate why cybersecurity is vital to achieving those goals==== | ====5.1.2 Articulate why cybersecurity is vital to achieving those goals==== | ||
Looking to your business goals for the technology, data, and other resources used to achieve those goals gives you an opportunity to turn the magnifying glass towards why they need to be secure. The clinical testing lab will likely be dealing with protected health information (PHI), and an electric cooperative must reliably provide service practically 100 percent of the time. Both the data and the service must be protected from physical and cyber intrusion, at risk of significant and costly consequence. | |||
====5.1.3 Based on the above, state the cybersecurity mission and define how to achieve it==== | ====5.1.3 Based on the above, state the cybersecurity mission and define how to achieve it==== | ||
====5.1.4 Gain and promote active and visible support from executive management in achieving the cybersecurity mission==== | ====5.1.4 Gain and promote active and visible support from executive management in achieving the cybersecurity mission==== | ||
Revision as of 19:52, 29 November 2019
1. What is a cybersecurity plan and why do you need it?
Developing a cybersecurity plan is not a simple process; it requires expertise, resources, and diligence. Even a simple plan may involve several months of development, more depending on the complexity involved. The time it takes to develop the plan may also be impacted by how much executive support is provided, the size of the development team (bigger is not always better), and how available required resources are.[1]
2. What are the major standard and regulations dictating cybersecurity action?
3. The NIST Cybersecurity Framework and its control families
4. Fitting a framework or specification into a cybersecurity plan
5. Develop and create the cybersecurity plan
What follows is a template to help guide you in developing your own cybersecurity plan. This template has at its core a modified version of the template structure suggested in the late 2018 Cybersecurity Strategy Development Guide created for the National Association of Regulatory Utility Commissioners (NARUC).[1] While their document focuses on cybersecurity for utility cooperatives and commissions, much of what NARUC suggests can still be more broadly applied to all but the tiniest of businesses. Additional resources such as AHIMA's AHIMA Guidelines: The Cybersecurity Plan[4]; National Rural Electric Cooperative Association (NRECA), Cooperative Research Network's Guide to Developing a Cyber Security and Risk Mitigation Plan[2]; and various cybersecurity experts' articles[3][5][6][7][8][9] have been reviewed to further supplement the template. This template covers 10 main cybersecurity planning steps, each with multiple sub-steps. Additional commentary, guidance, and citation is included with those sub-steps.
Note that before development begins, you'll want to consider the knowledge resources available and key stakeholders involved. Do you have the expertise available in-house to address all 10 planning steps, or will you need to acquire help from one or more third parties? Who are the key individuals providing critical support to the business and its operations? Having the critical expertise and stakeholders involved with the plan's development process early on can enhance the overall plan and provide for more effective strategic outcomes.[1]
5.1. Develop strategic cybersecurity goals and define success
5.1.1 Broadly articulate business goals and how information technology relates
Something should drive you to want to implement a cybersecurity plan. Sometimes the impetus may be external, such as a major breach at another company that affects millions of people. But more often than not, well-formulated business goals and the resources, regulations, and motivations tied to them will propel development of the plan. Business goals have, hopefully, already been developed by the time you consider a cybersecurity plan. Now is the time to identify the technology and data that are tied to those goals. A clinical testing laboratory, for example, may have as a business goal "to provide prompt, accurate analysis of specimens submitted to the laboratory." Does the lab utilize information management systems as a means to better meet that goal? How secure are the systems? What are the consequences of having mission-critical data compromised in said systems?
5.1.2 Articulate why cybersecurity is vital to achieving those goals
Looking to your business goals for the technology, data, and other resources used to achieve those goals gives you an opportunity to turn the magnifying glass towards why they need to be secure. The clinical testing lab will likely be dealing with protected health information (PHI), and an electric cooperative must reliably provide service practically 100 percent of the time. Both the data and the service must be protected from physical and cyber intrusion, at risk of significant and costly consequence.
5.1.3 Based on the above, state the cybersecurity mission and define how to achieve it
5.1.4 Gain and promote active and visible support from executive management in achieving the cybersecurity mission
[4] As NARUC notes, "with leadership buy-in, it will be easier to institutionalize the idea that cybersecurity is a priority and can result in more readily available resources."[1]
5.2 Define scope and responsibilities
5.2.1 Define the scope and applicability through key requirements and boundaries
5.2.2 Define the roles, responsibilities, and chain of command of those enacting and updating the cybersecurity plan
5.2.3 Ensure responsibility for security risk management and other key aspects (the “who” of it) is clear
5.3 Identify cybersecurity requirements and objectives
5.3.1 Detail the existing system and classify its critical cyber assets
5.3.2 Define the contained data and classify its criticality (data maps may help)
5.3.3 Identify current and previous cybersecurity policy and tools; determine what has worked and what hasn’t
5.3.4 Identify the regulations and standards affecting your assets and data (e.g., what are the data retention requirements)
5.3.6 Identify and analyze physical entry points
5.3.7 Perform a gap analysis (comparing safeguards in place vs. how well they work)
5.3.8 Perform a risk assessment and prioritize risk based on threat, vulnerability, likelihood, and impact (e.g., examine personnel, third parties, hardware, etc.)
5.3.9 Declare and describe objectives based on the outcomes of the above assessments
5.3.10 Develop new policies for passwords, physical security, etc. where gaps have been identified from the above assessments and objectives
5.3.11 Select and refine security controls for identification, protection, detection, response, and recovery based on the assessments, objectives, and policies above (NIST security controls are used for this example plan)
5.4 Establish performance indicators and associated time frames
5.4.1 Determine baselines and indicators based on the assessments and objectives from the previous step
5.4.2 Determine how to measure progress and assess performance (quantitative vs. qualitative) and what tools are needed for such measurement and assessment (e.g., monitoring anomalous activity, system and asset activity logging)
5.5 Identify key stakeholders
5.5.1 Determine what external (federal, state, local, and private) entities the business currently interacts with
5.5.2 Determine what internal entities or people may act as cybersecurity stakeholders
5.5.3 Define how those stakeholders shape the cybersecurity plan and its strategic goals
5.6 Determine resource needs
5.6.1 Determine whether sufficient in-house subject-matter expertise exists, and if not, how it will be acquired
5.6.2 Estimate time commitments and resource allocation towards training exercises, professional assistance, infrastructure, asset management, and recovery and continuity
5.6.3 Review the budget
5.7 Develop a communications plan
5.7.1 Address the need for transparency in improving the cybersecurity culture
5.7.2 Determine guidelines for everyday communication (e.g., informing third parties of organization privacy policies) and mandatory reporting to meet cybersecurity goals
5.7.3 Determine guidelines for handling or discussing sensitive information
5.7.4 Address incident reporting and response (consider the use of playbooks, report templates, and training drills) as well as corrective action
5.7.5 Address cybersecurity training methodology, requirements, and status tracking
5.8 Develop a recovery and continuity plan
5.8.1 Consider linking a cybersecurity incident recovery plan and communication tools with a business continuity plan and its communication tools
5.8.2 Include a listing of organizational resources and their criticality, a set of formal recovery processes, security and dependency maps, a list of responsible personnel, a (previously mentioned) communication plan, and information sharing criteria
5.9 Establish how the overall cybersecurity plan will be implemented
5.9.1 Detail the specific steps regarding how all the above will be implemented
5.9.2 State the major implementation milestones
5.9.3 Determine how best to communicate progress on the plan’s implementation
5.10 Review progress
5.10.1 Monitor and assess the effectiveness of security controls
5.10.2 Review how to capture and incorporate corrective action procedures and results
5.10.3 Determine how often to review and update the cybersecurity plan
5.10.4 Determine external sources for “lessons learned” and how to incorporate them for improving cybersecurity strategy
6. Closing remarks
Appendix 1. A revised NIST Cybersecurity Framework, tied to LIMSpec
6.1 Access control
6.2 Awareness and training
6.3 Audit and accountability
6.4 Security assessment and authorization
6.5 Configuration management
6.6 Contingency planning
6.7 Identification and authentication
6.8 Incident response
6.9 Maintenance
6.10 Media protection
6.11 Physical and environmental protection
6.12 Planning
6.13 Personnel security
6.14 Risk assessment
6.15 System and services acquisition
6.16 System and communication protection
6.17 System and information integrity
References
- ↑ 1.0 1.1 1.2 1.3 1.4 Cadmus Group, LLC (30 October 2018). "Cybersecurity Strategy Development Guide" (PDF). National Association of Regulatory Utility Commissioners. https://pubs.naruc.org/pub/8C1D5CDD-A2C8-DA11-6DF8-FCC89B5A3204. Retrieved 29 November 2019.
- ↑ 2.0 2.1 Lebanidze, E. (2011). "Guide to Developing a Cyber Security and Risk Mitigation Plan" (PDF). National Rural Electric Cooperative Association, Cooperative Research Network. https://www.cooperative.com/programs-services/bts/documents/guide-cybersecurity-mitigation-plan.pdf. Retrieved 29 November 2019.
- ↑ 3.0 3.1 Lago, C. (10 July 2019). "How to implement a successful cybersecurity plan". CIO. IDG Communications, Inc. https://www.cio.com/article/3295578/how-to-implement-a-successful-security-plan.html. Retrieved 29 November 2019.
- ↑ 4.00 4.01 4.02 4.03 4.04 4.05 4.06 4.07 4.08 4.09 4.10 4.11 4.12 4.13 4.14 Downing, K. (December 2017). "AHIMA Guidelines: The Cybersecurity Plan" (PDF). American Health Information Management Association. https://journal.ahima.org/wp-content/uploads/2017/12/AHIMA-Guidelines-Cybersecurity-Plan.pdf. Retrieved 29 November 2019.
- ↑ 5.0 5.1 Norton, K. (21 June 2018). "Similar but Different: Gap Assessment vs Risk Analysis". HIPAA One. https://www.hipaaone.com/2018/06/21/gap-assessment-vs-risk-analysis/. Retrieved 29 November 2019.
- ↑ 6.0 6.1 Ewing, S. (12 July 2017). "4 Ways to Integrate Your Cyber Security Incident Response and Business Continuity Plans". Delta Risk. https://deltarisk.com/blog/4-ways-to-integrate-your-cyber-security-incident-response-and-business-continuity-plans/. Retrieved 29 November 2019.
- ↑ 7.0 7.1 Krasnow, M.J. (February 2017). "Cyber-Security Event Recovery Plans". International Risk Management Institute, Inc. https://www.irmi.com/articles/expert-commentary/cyber-security-event-recovery-plans. Retrieved 29 November 2019.
- ↑ 8.0 8.1 "How to Develop A Cybersecurity Plan For Your Company (checklist included)". Copeland Technology Solutions. 17 July 2018. https://www.copelanddata.com/blog/how-to-develop-a-cybersecurity-plan/. Retrieved 29 November 2019.
- ↑ 9.0 9.1 Talamantes, J. (6 September 2017). "Does Your Cybersecurity Plan Need an Update?". RedTeam Knowledge Base. RedTeam Security Corporation. https://www.redteamsecure.com/blog/does-your-cybersecurity-plan-need-an-update/. Retrieved 29 November 2019.
