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CISO Times

Intelligence for the people behind the defence.

The CISO Decision Brief

Who decides…

Who should assess our security practices when the team is too small to be independent?

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

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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.
  1. 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

  2. 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.

  3. 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.

  4. 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.

    In the pack

  5. 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.

    In the pack

  6. 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.

    In the pack

  7. 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

  8. 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

  9. 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

  10. 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.

    In the pack

  11. 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

  12. 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

Practical checklist

  1. List who owns and who runs each practice.
  2. Name an assessment lead who runs none of the practices and can ask managers for records.
  3. For each practice, try a colleague from another function, then a swap, then a reciprocal peer, then a contracted assessor.
  4. Brief any assessor who is not a security specialist on what each level needs.
  5. Where no option works, let the owner rate it, mark it self-assessed and cap it at Defined.
  6. Count the self-assessed results, and take a proposal to the sponsor if they exceed a third.
  7. 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