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One of our ISO 27001 clients in the legal vertical recently asked Pivot Point Security to perform a gap assessment of their Incident Response Plan. They were a little surprised when we asked for their most recent risk assessment and Business Continuity Plan.
I often say, “Information Security controls are often hierarchical and interdependent in nature.” Here are two examples that illustrate this:
- When looking at an Incident Response Plan (IRP), it is important to consider the Risk Assessment, because you can’t gauge the IRP’s effectiveness without understanding the scope and boundaries of the Information Security Management System (ISMS) and the requirements for legal compliance and evidence of due diligence.
- Similarly, when evaluating an IRP it’s also important to consider the Business Continuity Plan, as the IRP’s effectiveness relates to the Business Continuity Management System requirements. It is critical to understand this relationship, as it is often during the Incident Response process (e.g., the analysis phase) that the Business Continuity Plan (BCP) gets “triggered.”
It actually got a little more interesting in this case, as their BCP wasn’t “really” a BCP per se. We view a well-executed BCP as having two parts: 1) An IT Continuity component, often referred to as an IT Continuity Plan or a Disaster Recovery Plan (DRP), and 2) A Business Continuity component. The first defines the requirement for and drives the recovery of the computing infrastructure, while the latter defines the requirements for and drives the recovery of the personnel and processes that operate the business. With both in place, the business can recover.
In this case the BCP was really more a DRP, and our review of the IRP ended up identifying this “out of scope gap.” Which – although not technically part of their IRP – would have made it far less effective.
Another ISO 27001 client’s “Hurricane Sandy” experience also illustrates this interdependence well. When investigating their data center’s switchover to emergency power, they learned that flooding had crippled the building’s power and connectivity. Their Incident Response Plan then triggered their Disaster Recovery Plan and they “failed” their critical IT infrastructure over to their DR vendor. When they realized that the building/offices would be “closed” for some period of time the IRP/DRP triggered their Business Continuity Plan. Critical services were shifted to other offices, their emergency DR site, and home based operations. The process was painful and it didn’t work perfectly – but they did recover and did not sustain significant business impact. The Continuous Improvement elements of ISO 27001 require that organizations learn from incidents – so most of the rough edges of their Incident Response, Disaster Recovery, and Business Continuity have now been smoothed out.
So if you’re looking at your BCP or DRP or IRP (ain’t acronyms wonderful (AAW)?) – make sure you look at them in a holistic fashion.