It is probably safe to say that we security professionals hear the phrase in the title of this post rather frequently. For one, I heard it again earlier today from a experienced professional presenting on a webinar… I believe it is a cliche.
I actually think the phrase conveys the view that we do some things for security sake and do certain other things for compliance sake (but not necessarily for “improving the security risk posture” sake). Therein lies the problem in my view. Why should we do certain things for compliance if they don’t necessarily improve the security risk posture? BTW.. I think we shouldn’t do security for security sake either… more on it below.
I don’t think there is any security regulation that requires you to implement a specific control no matter what the risk associated with not implementing the control is. I think we all agree PCI DSS is perhaps the most prescriptive security regulation there is and even it provides an option for us not to implement a specific control just for compliance sake if we could justify the reason by way of compensating controls . See below.
Note: Only companies that have undertaken a risk analysis and have legitimate technological or documented business constraints can consider the use of compensating controls to achieve compliance. (Source: Requirements and Security Assessment Procedures – PCI DSS version 3.0 (pdf))
I think all this can change if we insist on using the word “Risk” (and meaning it) in all of our security or privacy related conversations. It can be hard to make the change because understanding and articulating risk is not easy… we know it is certainly much harder than rattling out a security control from a security framework (NIST 800-53, HITRUST CSF, ISO 27002 et al.) or some regulation (PCI DSS, HIPAA Security Rule et al.). It requires one to do a risk analysis and a good risk analysis requires work that can be hard to come by and we need to watch for the pitfalls .
We may be better served to think of non-compliance as an option and non-compliance needs to be treated as just another risk like all other risks that are possibly more serious in nature (risk of loss of patient privacy, intellectual property or identity theft etc.). If we did that, we would be in a position to articulate (or at least be forced to) why implementing a particular compliance requirement doesn’t make sense because the risk associated with not implementing it is low enough given certain business/technical factors or compensating controls we may have.
Before I forget …Just like it doesn’t make sense to do compliance for compliance sake, it doesn’t make sense to do security for security sake either. We often see this problem withSecurity Privacy Risk organizations looking to get themselves a “security certification” of some sort such as HITRUST CSF, ISO et al. In the quest to attain a passing certification score, you could find yourself implementing security controls for “security certification” sake. There are certainly valid reasons why one would want to pursue certification, but one needs to be watchful so we aren’t forced to do security for security sake.
So, let us make a change in how we approach security and compliance by identifying and articulating “the risk” always and everytime …. Perhaps, we can make a start in the direction by not using the cliche in the title of the post. Instead, we might perhaps say something like “From a security or privacy risk standpoint…”.