An Unfunded Mandate Is Not a Mandate
An unfunded mandate is not a mandate. I believe that saying has its roots in federal government bureaucracy, but when it comes to information security, it certainly applies to businesses as well. There’s often a lot of talk about security initiatives, yet they go unfunded and, therefore, are left undone.
An Unfunded Mandate Leads to Problems
Take, for example, a security assessment that finds unsecured network shares and the personally identifiable information (PII) that’s at risk. Security staff can show that the PII is being accessed by people without a business need or, worse, staff members have no idea who is accessing the information, including untrusted outsiders. It’s a high-priority finding that must be corrected before the next audit cycle.
Management says fix it, but the IT and security personnel don’t have the proper tools to adequately implement the policy/fix enterprisewide, perhaps because there’s not enough money for a full-fledged data loss prevention system. So the risk remains. Business goes on.
Another example could be a known advanced malware infection. Intellectual property is seen being transferred out of the network and overseas. It’s acknowledged as a problem that needs to be fixed, but it’s not. Instead, it’s back-burnered to next year when the budget hopefully becomes available. The same goes for security information and event management (SIEM) systems, proper security testing, ongoing user training and the like. We have to do it, but it’ll never get done.
This very scenario plays out in the corporate world month after month, year after year. We’ve been told that we have to fix this or implement that to mitigate the risk, but we keep running into roadblocks. For instance:
- Management’s not fully on board with providing the financial and political backing to roll this out because of a large acquisition that’s coming up.
- There’s only one full-time person to handle these tasks. He or she is already overwhelmed, and we can’t justify hiring anyone else or paying to outsource the function altogether.
- We have to wait until we upgrade our core network switches, move our application environment to the cloud, etc., and that project is on hold until the next budget cycle.
- Our vendors are pushing back, saying that what we’re requesting is not supported, and we can’t afford to change vendors.
The size of the business and the industry in which it operates does not matter — there’s always an excuse. It almost always goes back to budget.
I call it lack of priorities. And we wonder why we keep getting hit.
Put Your Money Where Your Mouth Is
Simply put, an unfunded security mandate is not a true security mandate. I think that in a lot of situations, people would be better off holding themselves to a lower standard of information security. Why require something or agree to fixing something if you know it won’t happen? You end up setting yourself up for failure.
In cases where funds are suddenly cut short on what were assumed to be funded mandates, what are you going to do? You need to have a fallback strategy — sort of an incident response plan to deal with being caught between a rock (a security risk/requirement) and a hard place (no resources to do it).
Can you use what you’ve got by leveraging tools already at your disposal? Can you better manage your time to take on a new task? Are there external resources that you could bring onboard to help at little to no cost, such as interns or co-op students? You need to address these concerns because this issue is going to come up.
Ask any given executive if information security is important and odds are good that everyone will say yes. It’s the actions done — or not done — behind the scenes that speak louder than their words.