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The Coalfire Blog

Where should CISO report?

July 06, 2011, John Rostern, VP, Technology Advisory and Assessment Services

John Rostern

A key question faced by many organizations in defining the role and responsibilities of the security organization, is where to align the most senior information security executive, (typically referred to as the Chief Information Security Officer or CISO).  To answer this question it is important to clearly define the responsibilities of this position and place them in appropriate context.

There are two broad categories of security functions in any organization, security operations and oversight. Security operations includes functions such as account provisioning, access control, and the management, configuration and deployment of security infrastructure (firewalls, IDS, etc.) and related network components. Security oversight is a governance activity that validates that security operations are being performed according to documented policies, standards and procedures and that those operations are effective in meeting the legal and regulatory requirements of the organization.  A key part of the governance aspect of this position is the role is setting appropriate policies that are aligned with the business stakeholders.

Security operations can be, and typically are, positioned within the IT organization of the company.  Since many of the day to day functions are integrated into IT operations such as the Help Desk, this is a sensible and common organizational construct. However, the oversight role of the CISO must be treated differently.  The role of the CISO can be compared in many ways to that of Internal Audit. While many functions of Internal Audit are financial in nature, that group does not report within the operational structure of the Chief Financial Officer (CFO) or Controller. The reason for this is independence, the need for a third party within the company to provide objective, independent oversight – in this case over accounting and financial reporting.  Similarly the role of the CISO requires similar independence in providing objective, independent oversight with respect to information risk management and security.

To achieve the organizational objectives of the CISO, this function should be positioned outside of the IT organization. The mission of the CISO is based on the effective assessment, mitigation and management of technology related risk to the business. Possible reporting alignments for the CISO include;

  • Chief Risk Officer (CRO)
  • Chief Compliance Officer (CCO)
  • Chairman of the Audit Committee of the Board of Directors
  • Chief Audit Executive (CAE)
  • Chief Legal Officer / Corporate General Counsel

The proper positioning of the CISO in the organization will lay the foundation for their success and increase their effectiveness in managing technology related risks.

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