Independent thinking. Informed defence.

CISO Times

Intelligence for the people behind the defence.

The CISO Decision Brief

How do we…

How do we separate what belongs in a policy, a standard and a procedure?

6 decision pointsThe pack behind this answer: Security Policy Management

Add to board memo

The short answer

Recommendation
Give every document exactly one tier, and test each sentence before it goes in. Keep commitments in the policy, and move settings to a standard, steps to a procedure, advice to a guideline and background to training.
Reasoning
The tiers exist because they are approved and reviewed at different levels. A policy that carries settings, steps and advice grows long, goes out of date quickly and needs top-level approval for every small change. With each kind of content in its own tier, the policy stays short and stable, and standards and procedures change with the technology, approved at the level that can judge them. A lower tier may add detail but never contradict the tier above: where they disagree, the higher tier applies until the lower one is corrected.
Considerations
  • The approvers, review intervals and page limit are the CISO Times policy pack's defaults: the Head of Information Security approves standards and procedures, reviews run every 12 or 24 months by tier, and a policy body is at most 4 pages. Your own framework may set different ones.
  • The top policy goes to the board or its equivalent: the board or a board risk committee it delegates to, the management board in a two-tier structure, or executive management where there is no board. In a NIS2 or DORA entity, the management body approves it itself.
  • A deadline that is central to what the policy promises can stay in the policy, such as a leaver's access being disabled by the end of their last working day. A technical setting, such as a password length or a time-out, cannot.
  • If you cannot tell whether a sentence is mandatory, or whether it would change within the year, take the cautious answer: treat it as mandatory, or as standard material, and let the owner decide when the draft is checked.

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. 17 steps.
  1. Start

    You have requirements and need to place them

    Policies that carry settings, steps and advice become long, go out of date quickly and need top-level approval for every small change. The fix is to put each kind of content in the tier made for it. The tiers exist because they are approved and reviewed at different levels.

    In the pack

  2. Step

    Give each document one tier, stated on its first page

    Each document is a policy, standard, procedure or guideline, never a mix, and its title ends with that word. The top policy is approved by the board or its equivalent: the board, or a board risk committee it has delegated this to; in a two-tier structure, the management board; where there is no board, executive management. Other policies go to executive management. In the pack's defaults, standards and procedures go to the Head of Information Security, and policies and standards are reviewed every 12 months, procedures and guidelines every 24.

    In the pack

  3. Step

    Test one sentence at a time

    Work sentence by sentence, because one draft can mix content from several tiers. The pack gives a quick test for each sentence. The questions below apply it in one order that works; move each sentence to the first tier that fits.

    In the pack

  4. Decision

    Does it explain background, threats or history?

    Explanations of why a threat matters, how an incident happened or what a regulation says are useful, but nobody can comply with them. They make a policy longer without adding a single requirement.

    In the pack

  5. Outcome

    Move it to training or a guideline

    Keep at most one sentence of it in the policy's Purpose section. If the Purpose runs past five lines, it is doing the work of a guideline. Threat statistics and history belong in awareness material.

    In the pack

  6. Decision

    Must anyone follow it?

    A policy, standard or procedure must be followed. A guideline is recommended practice, and nobody is non-compliant for ignoring it. If you are unsure whether something is mandatory, treat it as mandatory and let the owner decide when the draft is checked.

    In the pack

  7. Outcome

    Guideline: recommend it, with no 'must'

    For example: "When working in a public place, sit where your screen cannot be overlooked." A guideline may not contain a 'must' statement. If something has to be done, it belongs in a standard or a procedure.

    In the pack

  8. Decision

    Does it say how a task is done, or who does which step?

    Steps, forms, tools and who presses which button are procedure material. The pack's test: if it says who clicks what, it belongs in a procedure.

    In the pack

  9. Outcome

    Procedure: write the steps by named role

    For example: "To grant access: 1. The line manager raises a request. 2. The system owner approves." In the policy, keep only a pointer: "following the X Procedure". The people who run a procedure are trained on it; staff do not acknowledge it one by one.

    In the pack

  10. Decision

    Would it change when a product, setting or number changes?

    A setting, a number or a product that could change within the year is standard material. Password length, time-outs and patch deadlines are examples. Nobody outside IT can judge them, and they would force top-level approval of every adjustment. If you cannot tell, treat the answer as yes.

    In the pack

  11. Decision

    Is the figure central to what the policy promises?

    Some deadlines are commitments management should approve. "A leaver's access is disabled by the end of their last working day" can stay in a policy. A technical value, such as a password length or a time-out, cannot.

    In the pack

  12. Outcome

    Standard: set the measurable requirement

    For example: "Passwords are at least 14 characters" or "Critical patches are applied within 14 calendar days." In the policy, keep the commitment and point to the standard: "to the standard set in the X Standard".

    In the pack

  13. Outcome

    Policy: state it as a commitment

    A commitment the organisation must keep, whoever is in post, such as "Every administrator account must use multi-factor authentication." Keep the policy short: the pack's default is at most 4 pages of body. If a draft runs over, move settings, then steps, then explanations, then examples down a tier.

    In the pack

  14. Decision

    Does a lower tier contradict the tier above it?

    A lower tier may add detail. It may never contradict the tier above. Check for it whenever a standard or procedure is drafted or revised.

    In the pack

  15. Outcome

    Follow the higher tier; correct the lower document

    Where a standard and its policy disagree, the policy applies until the standard is corrected. Correct it through review. If the correction changes a 'must' statement or a value people work to, it is a material change.

    In the pack

  16. Outcome

    Each tier holds only its own kind of content

    The policy stays short and stable, so fewer changes need top-level approval. Standards and procedures change with the technology, approved at the level that can judge them. Record each document with its tier on your register.

    In the pack

Practical checklist

  1. State each document's tier on its first page, and end its title with the tier's name.
  2. Test the draft one sentence at a time.
  3. Move background, threats and history to training or a guideline, keeping at most one sentence of it in the policy's Purpose.
  4. Move recommended practice that nobody must follow to a guideline, with no 'must' statement in it.
  5. Move steps, forms, tools and who does which step to a procedure written by named role, and leave a pointer in the policy.
  6. Move settings and numbers that could change within the year to a standard, unless the figure is central to what the policy promises.
  7. Name each lower-tier document's parent on its first page, and check that none contradicts the tier above.
  8. Where one does, follow the higher tier and correct the lower document through review. List each document with its tier on your register.

Evidence to have ready

  • Your register, listing every document with its owner, tier, status, version, approval date and next review date.
  • The dated approval of each document at its tier's level: a minute, a signed approval page or the approval record in your document management system.
  • The first page of each document, showing its tier and, below the Policy tier, its parent document.
  • The revision history of each changed document, showing whether the change was classed as material.

Assumptions

  • You use, or are moving to, a four-tier document set: policy, standard, procedure and guideline.
  • The approvers and review intervals shown are the defaults in the CISO Times policy pack. Your own framework may set different ones. The tests for each sentence matter more than the numbers.

Not covered here