EXPERT RESPONSE
Absolutely.
Security regulatory compliance is actually the natural by-product of a well-executed risk management strategy. It's the floor and not the ceiling when it comes to protecting the most important assets of an enterprise. Yet it has become abused and over-used as the measure of the security and fidelity of the information assets in many enterprises today.
As I mentioned in my recent posting regarding PCI-DSS, security regulatory compliance does not equal security. Further, security does not always equal effective risk management, especially in the absence of a structured assessment methodology that takes business impact into consideration.
Instead of managing risk and assessing business impact within this context, compliance has become the regulated solution for force-feeding transparency and plugging the gap between the two approaches. This has happened for many reasons -- some good, some bad.
The reality is that most enterprises see security regulatory compliance as a necessary evil, as well as a way of securing budget in hard times, but that doesn't necessarily mean that compliance contributes to the things that matter most. It simply means that the low-hanging fruit of due care and due diligence have been attended to.
In today's threat and vulnerability-centric security landscape, security regulatory compliance has unfortunately become the metric against which the efficacy and effectiveness of information security programs are measured. This is because managing risk is hard work. Compliance, if you believe the vendor hype, is only a point-and-click or a single product deployment away.
By setting the bar at compliance, enterprises can be lulled into a false sense of "security." As I mentioned in my PCI-DSS post, Hannaford Brothers was compliant with PCI-DSS, and yet they suffered a horrific breach. Time will tell whether the gaps associated with their security regulatory compliance efforts, versus managing the things that matter most, were contributors to their failings.
There's little excuse for not being compliant and there's even less excuse for not managing risk.
The availability of mature risk assessment frameworks (such as OCTAVE and FAIR) combined with the maturity of IT and governance frameworks (such as COBIT and ITIL) provide an excellent foundation upon which to manage risk and measure and maintain compliance without sacrificing at the altar of possibility.
By now, given the rampant escalation in dramatic data breaches, security integrators and the customers they serve recognize that hope – and the compliance that sometimes shores it up – is not a strategy.
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