Information Security function had to be aligned to Risk Management function to provide independence by separating Infosec Governance and Infosec operations responsibilities. Enhancement in the policy was focused on the wider and strategic modifications, faster adoption of emerging technologies and empowering all stakeholders.
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- While defining policy, objective was also to remove subjectivity
- Enable empowerment to businesses to define and own ‘risk’ enabling productivity and efficiency in decision making.
- Define “Risk Control Self Assessment” wherever possible with templates and checklist, supported by appropriate guidelines.
- Provide focus on employee empowerment with increased responsibility and at the same time ensure technology tools are on constant vigilance to prevent unintentional or intentional incidents.
- Keep balance between empowerment and security.
- Along with empowerment define measurement metrics - “Key Risk Indicators”, “Key Performance Indicators” which would help us to measure security levels of all Business Units uniformly and integrate risk score with business risk.
- Define modular SOA (Statement of Applicability) for each business unit to ensure their respective regulator’s requirements are met and business units are flexible to add/modify/delete any controls to meet their obligations to security requirements.
- Define separate security governance and security operations to build objectivity in the system where custodians of data are no longer controllers of data, yet enablers of data sharing.
- Define revised policy to be technology agnostic, business addressing along with technology, regulatory requirements and adheres to key industry standards
- Define Integrated information security policy as a part of business process along with increased involvement of business user through RCSA (Risk Control Self Assessment) and build transparency and self awareness about risk level.
- Define accountability for each individual’s own actions and performance metric.
- Define strong monitoring system for end user activity as well as network access perspective.
- Consider BYOD and Cloud as a market trend towards mobility and flexibility while defining Policy
- Establish strong security management framework for managing new technology developments.
Establish GRC (Governance, Risk and Compliance) framework to build visibility and better governance.
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