Who decides…
Who should assess our security practices when the team is too small to be independent?
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The short answer
- Recommendation
- Keep the rule that no one rates a practice they own or run, and change where you look for the assessor: a colleague from another function, a swap, a reciprocal peer, then a contracted assessor. Only where none is possible does the owner rate it, marked self-assessed and capped at Defined.
- Reasoning
- The rule is the internal audit rule applied to an assessment: no one assesses their own work (rule MA-14). A small team does not make it optional. A colleague from finance controls, risk or internal audit is usually the best choice: they know how the organisation works, can ask for a record and wait for it, and have no stake in the answer. A self-assessed result is still useful, but it cannot be Managed, because Managed needs a check by someone other than the person who does the work.
- Considerations
- A practice is your own work if you own it, do it, manage the people who do it day to day, or wrote its procedure.
- If more than a third of the results would be self-assessed, or one person runs every practice, the sponsor decides whether to commission an independent assessment.
- In a reciprocal or contracted arrangement, agree the scope, the model and confidentiality in writing first. By the pack's default, a contracted assessor has not designed, run or advised on what they rate in the last 12 months.
- If a regulator, certifier or customer will rely on the result, the independence it needs may be set by them.
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. 12 steps.
Start
Every practice needs an assessor who does not run it
The rule is the internal audit rule applied to an assessment: no one assesses their own work. A small team does not make it optional. It changes where you look for the assessor.
In the pack
- P19-A03 Internal Security Assessment ProcedureThe rule (rule MA-14)
- P08-A08 ISMS Internal Audit Programme & ProcedureIndependence (rule IS-07)
Step
List who owns and who runs each practice
A practice is your own work if you own it, do it, manage the people who do it day to day, or wrote the procedure it follows. Where you can, also avoid someone rating a practice run by the person they report to. The Head of Information Security owns the programme and rates no practice they own or run.
In the pack
- P19-A03 Internal Security Assessment ProcedureThe rule (rule MA-14)
- P19-A03 Internal Security Assessment ProcedurePH-1 Plan
- P19-A03 Internal Security Assessment ProcedureRoles
Step
Name a lead who runs none of the practices
The assessment lead assigns assessors and decides each result, so the lead must be independent of every practice. Authority matters more than security knowledge: the standing to ask a manager for records by a date and to decide a level the manager disputes. An internal audit manager, a finance controls manager or a risk manager usually has it.
In the pack
- P19-A03 Internal Security Assessment ProcedureRoles
Decision
Is there a colleague outside security who runs none of them?
Someone from finance controls, risk or internal audit is usually the best choice. They know how the organisation works, can ask for a record and wait for it, and have no stake in the answer. What they lack is security detail, which a briefing on what each level needs supplies. The Head of Information Security or the owner may explain what a record is and where it is kept; they do not suggest a level.
- Yes: Assign that assessor and record it in the plan
- No, or not known: Do different people or teams run different practices?
In the pack
- P19-A03 Internal Security Assessment ProcedureWays to stay independent, in the order to try them (rule IO-1)
- P19-A03 Internal Security Assessment ProcedureBriefing an assessor who is not a security specialist
Decision
Do different people or teams run different practices?
With two or more people in security, or a security team beside an IT team, people can rate each other's practices and never their own. Check the split against the list of who runs what: a swap only works where the practices are really divided.
- Yes: Assign that assessor and record it in the plan
- No, or not known: Is there a trusted peer in another organisation?
In the pack
- P19-A03 Internal Security Assessment ProcedureWays to stay independent, in the order to try them (rule IO-2)
Decision
Is there a trusted peer in another organisation?
A single-person security function can arrange for a peer in the same sector to rate its practices while it rates theirs. Agree the scope, the model and the confidentiality terms in writing first. Using the same model on both sides keeps results comparable over time.
- Yes: Assign that assessor and record it in the plan
- No, or not known: Can you contract an external assessor?
In the pack
- P19-A03 Internal Security Assessment ProcedureWays to stay independent, in the order to try them (rule IO-3)
- P19-A03 Internal Security Assessment ProcedureA contracted or reciprocal assessor
Decision
Can you contract an external assessor?
An external assessor can rate just the practices no one inside can rate independently, or the whole programme. It fits where one person runs every practice or where a regulator or customer will rely on the result. Agree in writing that they have not designed, run or advised on what they rate in the last 12 months (the pack's default), and that they use your model.
In the pack
- P19-A03 Internal Security Assessment ProcedureWays to stay independent, in the order to try them (rule IO-4)
- P19-A03 Internal Security Assessment ProcedureA contracted or reciprocal assessor
Outcome
Assign that assessor and record it in the plan
Use the first option that gives an assessor who neither owns nor runs the practice, and name them against it in the assessment plan. The levels they give count in full, up to Managed where the evidence supports it.
In the pack
- P19-A03 Internal Security Assessment ProcedureWays to stay independent, in the order to try them (rule IO-1 to IO-4)
- P19-A03 Internal Security Assessment ProcedureAssessment plan
Step
Self-assess, mark it, and cap it at Defined
Where none of the options works for a practice, its owner rates it. The result is marked self-assessed so the reader knows how far to rely on it, and it cannot be above Defined, because Managed needs a check by someone other than the person who does the work. The lead tells the sponsor. A later independent check of the evidence lifts the cap.
In the pack
- P19-A03 Internal Security Assessment ProcedureThe rule (rules IO-5, MA-14)
- P19-A03 Internal Security Assessment ProcedureEscalation
- P19-A02 Security Maturity Model & Scoring MethodIndependence (rule MA-14)
Decision
Over a third self-assessed, or one person runs every practice?
Count the self-assessed results against all results. The pack's target for this measure is none, and never more than a third. Above a third, or where one person runs every practice, the sponsor decides whether to commission an independent assessment, and records the decision (IT-3). If you have not finished assigning assessors, answer yes until you have.
- Yes, or not known: Propose an independent assessment to the sponsor
- No: Proceed, and count self-assessed results in the report
In the pack
- P19-A03 Internal Security Assessment ProcedureWhen to commission an independent assessment (rule IT-3)
- P19-A06 Maturity Findings & Improvement TrackerMeasures (rule MAM-03)
Outcome
Propose an independent assessment to the sponsor
The lead takes a proposal to the sponsor, who decides whether to commission an independent assessment instead of the internal one or as well as it. The plan records the decision and the reason, including a decision not to commission one.
In the pack
- P19-A03 Internal Security Assessment ProcedureEscalation (rule IT-3)
- P19-A03 Internal Security Assessment ProcedureWhen to commission an independent assessment
Outcome
Proceed, and count self-assessed results in the report
The report's limits section states how many results are self-assessed, which practices they are, and why no one independent was available. Each stays capped at Defined until someone independent checks its evidence. The count of self-assessed results is also reported to the sponsor each quarter.
In the pack
- P19-A07 Maturity Assessment Report Template7. Limits of this assessment (rule MA-14)
- P19-A06 Maturity Findings & Improvement TrackerMeasures (rule MAM-03)
Practical checklist
- List who owns and who runs each practice.
- Name an assessment lead who runs none of the practices and can ask managers for records.
- For each practice, try a colleague from another function, then a swap, then a reciprocal peer, then a contracted assessor.
- Brief any assessor who is not a security specialist on what each level needs.
- Where no option works, let the owner rate it, mark it self-assessed and cap it at Defined.
- Count the self-assessed results, and take a proposal to the sponsor if they exceed a third.
- State the self-assessed results and why in the report's limits section.
Evidence to have ready
- The assessment plan naming the assessor for each practice and the option used.
- The written terms with any reciprocal or contracted assessor.
- The count of self-assessed results, which practices they are and why no one independent was available.
- The sponsor's recorded decision on an independent assessment where the trigger applied.
Assumptions
- You rate practices on four maturity levels in words, as the CISO Times maturity pack does, where Managed needs a check by someone other than the person who does the work.
- A member of management sponsors the assessment and can ask colleagues outside security to give time to it.
- This is a maturity assessment for your own use. If a regulator, certifier or customer will rely on it, the independence it needs may be set by them.
Not covered here
- Whether to commission a fully independent assessment instead. That is “When should we commission an independent assessment instead of self-assessing?”.
- Who may carry out the ISO/IEC 27001 internal audit in a small organisation. That is “How do we run an internal audit when we are small?”.
- How assessors who are not security specialists rate consistently. That is “How do we score maturity consistently when different people assess?”.
Related questions
- How do we run an internal audit when we are small?
- When should we commission an independent assessment instead of self-assessing?
- How do we score maturity consistently when different people assess?
- How do we tell whether evidence actually proves the level someone claims?
- How do we tell whether our security programme is mature, and which gaps matter?