Independent thinking. Informed defence.

CISO Times

Intelligence for the people behind the defence.

The CISO Decision Brief

How do we…

How do we turn maturity gaps into an improvement plan the budget can carry?

5 decision pointsThe pack behind this answer: Security Maturity & Internal Assessment

Add to board memo

The short answer

Recommendation
Give every practice below target one action per level, order them with the pressing ones first, and take the approver a plan with options: one within the current budget, the one you recommend, and a faster one only if it is worth asking, each saying what it leaves below target.
Reasoning
A practice moves up one level per action, so planning two levels as one step hides the risk that the first does not take hold (rule MA-12). Practices on which a risk outside appetite, or an obligation recorded as not met, rests come first; then the lower levels and the larger gaps (rule MA-11). Staff effort and outside spend are shown apart, because staff time is effort, not cost. Options let the approver choose knowingly what stays below target.
Considerations
  • The five priority actions, the six months at Defined before Managed and the effort bands are the pack's defaults. Your own method may set others.
  • Never change a target to make the plan look better. Without targets approved before scoring, there is no gap to plan against.
  • Work another plan already funds, such as a risk treatment action, is named as what an action waits for and not costed twice.
  • The approver depends on governance: the board or a board risk committee it has delegated to, the management board in a two-tier structure, or executive management where there is no board.

The decision, step by step

Select any step for the reasoning behind it and where the pack covers it.

  • Start
  • Step
  • Decision
  • Outcome

Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.

Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.

Read as text

The same flow written out: each step, its reasoning and where the pack covers it. 18 steps.
  1. Start

    The assessment shows gaps against the approved targets

    A gap is a domain's target minus its level, counted in levels: never a score, a percentage or an average. Start from the decided results, after validation, and from the targets exactly as the sponsor approved them. Never change a target to make the plan look better. The plan is an improvement plan; it is not an audit or a compliance plan.

    In the pack

  2. Decision

    Were the targets approved before any evidence was scored?

    Each domain needs a target and a reason: an obligation that rests on it, a risk outside appetite, or a business need. Defined is the default target; Managed needs one of those reasons. Targets set after seeing the results tend to be set to fit them. If you cannot show a dated approval from before scoring, take the cautious branch.

    In the pack

  3. Outcome

    Agree the targets and their reasons before you plan

    Without an approved target there is no gap to plan against. The pack has fieldwork wait until the sponsor approves the targets, and treats a target changed after scoring has started as a target for the next assessment. Where targets were never approved, the way forward is your judgement: one route is to have the sponsor approve them with their reasons now, and say plainly in the report that they were set after the results were known.

    In the pack

  4. Step

    Give every practice below target one action

    Every practice below its domain's target is a finding and gets an action. Each action names an owner, a due date and the evidence that will show it is done, taken from what the next level needs. A domain at or above its target needs no action, and the sponsor may lower the effort spent on it.

    In the pack

  5. Decision

    Is any practice more than one level below its target?

    A practice moves up one level per action. A practice at Not in place with a target of Defined is two levels short, and a Managed target adds a step after Defined. Planning two levels as one action hides the risk that the first step does not take hold.

    In the pack

  6. Step

    Plan one step per level, each after the one before

    The second step starts where the first ends and falls due on or after it. Managed is planned no sooner than six months after the practice reaches Defined, with records, in the pack's default. A roadmap never plans a jump of two levels in one step.

    In the pack

  7. Step

    Order the actions: pressing first, then lower levels, larger gaps

    A practice is pressing when a risk recorded as outside appetite in the risk register, or an obligation recorded as not met by the body that owns it, rests on it. A practice the assessor merely thinks important is not pressing. After the pressing ones come the practices at the lower level, then the domains with the larger gap, then domain and practice order.

    In the pack

  8. Step

    Give up to five priority, with the earliest dates owners can meet

    Up to five actions take priority in one cycle in the pack's default: the first five in the order above. Give them the earliest dates their owners can meet. The Head of Information Security proposes them and the approver approves them, and an overdue priority action is named to the sponsor in the quarterly report. The rest stay in the plan with later dates.

    In the pack

  9. Step

    Name what each action waits for, inside or outside the plan

    An action falls due on or after the one it waits for. Some wait for work outside the plan, such as a risk treatment action funded through the risk treatment plan. Name it, and do not cost it twice. A recovery test, for example, may wait for the rebuild a treatment action pays for.

    In the pack

  10. Step

    Estimate staff effort and outside spend separately

    Put each action in an effort band, in person-days: the pack's defaults are Small up to 5, Medium 6 to 20 and Large 21 to 60. Enter money spent outside, such as licences, services and contractors, as a one-off cost. Staff time is effort, not cost. Adding up the bands' upper bounds gives a ceiling, not an estimate.

    In the pack

  11. Decision

    Does any action need money spent outside?

    If no action needs outside spend, the current budget carries the whole plan, and the approver's decision is about the plan, its dates and the staff effort it takes. If any action needs spend, the approver needs to see what the plan buys with and without it.

    In the pack

  12. Step

    Build options: current budget, recommended, and faster

    The first option keeps to the current budget: only items with no outside cost, and nothing that waits for an item it drops. The second is the plan you recommend. Add a faster or fuller one only if it is worth asking. Give each its one-off and yearly cost and say what it leaves below target.

    In the pack

  13. Decision

    Can the owners carry the effort in the quarters planned?

    In a small organisation one person may own most items. The pack's answer is to spread the due dates so each quarter's work is possible. Checking each owner's load before the plan goes for approval is your own step. If you have not checked it, take the cautious branch.

    In the pack

  14. Step

    Spread the due dates so each quarter's work is possible

    Keep the priority actions early and move the rest. Fewer, larger steps are fine in a small organisation, but keep one level per step and a named owner for each. Moving a date never moves a target.

    In the pack

  15. Step

    Take the report, plan and options to the approver

    The sponsor takes them to the approver your governance sets: the board, or a board risk committee it has delegated to; the management board in a two-tier structure; executive management where there is no board. Ask for three decisions: the targets, the plan and the investment. Present levels in words, and say the result is not an audit or a statement of compliance.

    In the pack

  16. Decision

    Does the option chosen leave any practice below target?

    An option within the current budget can leave some practices below target, and a risk outside appetite without the work that would reduce it. The pack asks each option to say what it leaves below target, and the risk that stays, so the approver chooses knowingly. If you cannot tell what the chosen option leaves, take the cautious branch.

    In the pack

  17. Outcome

    Minute what the option leaves below target, and weigh its risk

    Record the option approved, and what it leaves below target, with the approver's minute and the roadmap. The pack passes the results to the risk register after approval. Whether a gap left unfunded needs its own risk entry, or a word with the owner of a risk outside appetite that rests on it, is your judgement through your own risk process. The practices left below target come back as findings at the next assessment.

    In the pack

  18. Outcome

    Track the actions monthly; re-plan items that slip each quarter

    Expected levels are a plan. A level moves only when someone other than the action's owner re-assesses the practice. Each quarter, compare re-assessed levels with the expected ones and report progress to the sponsor.

    In the pack

Practical checklist

  1. Start from the decided results and the targets as the sponsor approved them.
  2. Give every practice below target an action with an owner, a due date and the evidence that will show it done.
  3. Plan one step per level, each due on or after the one before.
  4. Order the actions, and give up to five priority the earliest dates their owners can meet.
  5. Name what each action waits for, inside or outside the plan.
  6. Put each action in an effort band, and enter outside spend separately as a one-off cost.
  7. Build the options, and spread due dates so each owner's quarter is possible.
  8. Take the report, plan and options to the approver, and record what the chosen option leaves below target.

Evidence to have ready

  • The roadmap, with each step's practice, level from and to, owner, due date, effort band and outside cost.
  • The options, each with its one-off and yearly cost and what it leaves below target.
  • The approver's minute recording the option approved.
  • Each quarter's comparison of re-assessed levels with the expected ones.

Assumptions

  • You have a maturity assessment whose results are decided, after the practice owners saw the draft, and a target for each domain approved before any evidence was scored.
  • The approver is the one your governance sets: the board, or a board risk committee it has delegated to; the management board in a two-tier structure; or executive management where there is no board.
  • The five priority actions, the six months at Defined before Managed and the effort bands are the pack's defaults. Your own method may set others before the first assessment; a change after it is a break in series.

Not covered here