User:Shawndouglas/sandbox/sublevel24

1. What is a cybersecurity plan and why do you need it?

Incidents Reported by Federal Agencies in Fiscal Years 2006-2012 (15400517077).jpg

From law firms^[1] to automotive manufacturers^[2], the need to address cybersecurity is increasingly apparent. In 2018, the Center for Strategic & International Studies estimated that cybercrime causes close to $600 billion in damages to the global economy every year^[3], though due to underreporting of crimes, that number may be much higher. That number also likely doesn't take into account lost business, fines, litigation, and intangible losses^[4] In the end, businesses of all sizes average to about $200,000 in losses due to a cybersecurity incident^[5], and nearly 60 percent of small and midsized businesses go bankrupt within six months because of it.^[6]

It's not just large corporations at risk; small businesses of all types are also subject to cyber crimes, and they aren't doing enough to protect themselves. Juniper Research reports that despite small businesses making up over 99 percent of all companies, approximately 13 percent of overall cybersecurity spending came from those small businesses in 2018, amounting to about $500 per business.^[7]

Even the tiniest of businesses face cybersecurity risks today. The independent contractor with a WordPress-based website advertising their knowledge and skills must still ensure all website plugins and themes are updated and install security plugins to close potential vulnerabilities in the software. Without these precautions, hackers could spread malware, steal user data, add the website to a bot network, or hack it just for fun and learning.^[8]^[9]^[10]

As for larger companies, a late 2018 audit of Fortune 500 companies found a mix of good and bad news: they're doing better at reducing the number of entry points for hackers to enter their systems, yet susceptibility to fraudulent email remains a major concern.^[11]Additionally, Fortune 500 companies are still lagging behind in public transparency of showing a commitment to cybersecurity and protecting customer data.^[12] More broadly, roughly 60 to 70 percent of all companies are still ill-prepared for cyber threats, either not having an up-to-date cybersecurity strategy or having no plan at all.^[6]^[10] By all appearances, businesses still aren't doing enough to protect themselves and their customer's data despite the fact that cybercrime appears to only be getting worse for everyone.

The most solid first steps any organization or individual can take to limit the potential effects of cybercrime is to learn more about the threat and to develop a cybersecurity strategy. For most organizations, this means developing a cybersecurity plan.

A cybersecurity plan is a developed, distributed, reviewed, updated, and protected collection of assessments, analyses, requirements, controls, goals, policies, performance indicators, and metrics that shapes how an organization protects against and responds to cybersecurity threats. 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.^[13]

This guide attempts to assist organizations and individuals with overcoming the involved complexities of cybersecurity plan development and preventing becoming another cybersecurity statistic. It addresses the major standards and regulations affecting cybersecurity, in particular the National Institute of Standards and Technology's (NIST) Cybersecurity Framework and related controls. Also addressed is how to best incorporate a cybersecurity framework and controls into your plan development. At it's heart, this guide includes a comprehensive 10-step plan of attack for developing a cybersecurity plan, followed by closing comments. At the end of this guide, we include an appendix containing a slightly more simplified wording of NIST's most popular cybersecurity controls, as well as mappings to this wiki's own LIMSpec, an evolving set of specifications for laboratory informatics solutions and their development.

Note that this guide has been written with the intent to broadly cover multiple industries. However, it does have a slight lean towards laboratories, particularly those implementing information systems. Despite that, there should be sufficient information contained herein to be helpful to most people attempting to navigate the challenges of consistently applying cybersecurity goals and policies to their organization.

2. What are the major standards and regulations dictating cybersecurity action?

To be fair, the question of which standards and regulations affect how an organization implements cybersecurity is a most difficult one to answer. Not only do related standards and regulations vary by industry, they also vary by geography, complexity, and ease of implementation. Let's turn to the relatively dramatic example of data retention. Consider this statement:

The system shall have a mechanism to securely retain data in the system for a specific time period and enable protections that ensure the accurate and ready retrieval of that data throughout the records retention period.

Through recent updates to LIMSpec, we've found the following national and international regulations, standards, and guidance (Table 1) that tie into data retention and the protection of that retained data (and that list will certainly continue to grow):

Table 1. Regulations, standards, and guidance affecting data retention and the security of retained data
7 CFR Part 331.17 (c) 9 CFR Part 121.17 (c) 21 CFR Part 11.10 (c) 21 CFR Part 58.195 21 CFR Part 211.180 21 CFR Part 212.110 (c) 21 CFR Part 225.42 (b-8) 21 CFR Part 225.58 (c–d) 21 CFR Part 225.102 21 CFR Part 225.110 21 CFR Part 225.158 21 CFR Part 225.202 21 CFR Part 226.42 (a) 21 CFR Part 226.58 (f) 21 CFR Part 226.102 21 CFR Part 226.115 21 CFR Part 312.57 21 CFR Part 312.62 21 CFR Part 606.160 (d) 21 CFR Part 812.140 (d) 21 CFR Part 820.180 (b) 29 CFR Part 1910.1030 (h-2) 40 CFR Part 141.33 40 CFR Part 141.722 40 CFR Part 704 Subpart A 40 CFR Part 717.15 (d) 42 CFR Part 73.17 (c) 42 CFR Part 493.1105 42 CFR Part 493.1283 45 CFR Part 164.105 45 CFR Part 164.316 45 CFR Part 164.530	AAFCO QA/QC Guidelines for Feed Laboratories Sec. 2.4.4 or 3.1 AAVLD Requirements for an AVMDL Sec. 4.10.1.2 AAVLD Requirements for an AVMDL Sec. 4.10.2.1 AAVLD Requirements for an AVMDL Sec. 5.4.3.2 ABFT Accreditation Manual Sec. E-33 AIHA-LAP Policies 2018 2A.7.5.1 ASCLD/LAB Supp. Reqs. for the Accreditation of Forensic Science Testing Laboratories 4.14.1.2 and 4.15.1.2 ASCLD/LAB Supp. Reqs. for the Accreditation of Forensic Science Testing Laboratories 5.9.3.6 and 5.9.7 ASTM E1578-18 E-17-4 CJIS Security Policy 5.3.4 CJIS Security Policy 5.4.6–7 CJIS Security Policy 5.5.2.1 E.U. Annex 11-7.1 E.U. Commission Directive 2003/94/EC Article 9.1 E.U. Commission Directive 2003/94/EC Article 11.4 EPA 815-R-05-004 Chap. III, Sec. 15 EPA 815-R-05-004 Chap. IV, Sec. 8 EPA ERLN Laboratory Requirements 4.9.18 EPA ERLN Laboratory Requirements 4.11.17 EPA QA/G-5 2.1.9 ISO 15189:2012 4.3 ISO/IEC 17025:2017 8.4.2 NIST 800-53, Rev. 4, AT-4 NIST 800-53, Rev. 4, AU-11 and AU-11(1) NIST 800-53, Rev. 4, SI-12 OECD GLP Principles 10 USDA Administrative Procedures for the PDP 5.4 USDA Sampling Procedures for PDP 6.5 WHO Technical Report Series, #986, Annex 2, 15.8–9

This example illustrates the complexity of making a complete and accurate list of regulations, standards, guidance, and other bodies of work demanding data protection from organizations. And this represents only one security control among many. As such, it's difficult to answer this question in full.

Regardless, we can confidently say a few things about the regulations and standards behind cybersecurity. First, the risks and consequences of poor security drive regulation and, more preferably^[14]^[15], standardization, which in turn moves the "goalposts" of cybersecurity among organizations. In the case of regulations, organization that get caught not following them tend to suffer negative consequences, providing some incentive to improve organizational processes to conform to the regulations. But regulations can at times be "imprecise" or "disconnected"^[15] from what actually occurs within the organization and its information systems. When adopted, cybersecurity standards may provide a clearer path of opportunity for organizations to improve their cybersecurity culture and outcomes, particularly since, at least in theory, the standards are developed with a broader consensus of interested individuals with expertise in the field.^[14] In turn, the more organizations that adopt well-designed standards likely have a better chance of conforming to the regulations they must, and they'll likely have more interest in maintaining and improving the goalposts of cybersecurity.

That's not to say that compliance with regulations and standards alone can stop critical risks in their tracks^[16]:

Rules and compliance can mitigate some critical risks but not all of them. Active and cost-effective risk management requires managers to think systematically about the multiple categories of risks they face so that they can institute appropriate processes for each. These processes will neutralize their managerial bias of seeing the world as they would like it to be rather than as it actually is or could possibly become.

Second, modern cybersecurity frameworks and controls are typically harmonized with other standards and updated as business processes, technologies, cyber threats, and even regulations evolve. For example, the industry-specific Water Sector Cybersecurity Risk Management Guidance v3.0, which contains a set of cybersecurity controls as they relate to water and wastewater sectors, is harmonized with the NIST Cybersecurity Framework.^[17] And NIST's Special Publication 800-171, Revision 1: Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations has controls mapped to ISO/IEC 27001:2013 controls.^[18]