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CISO Times

Intelligence for the people behind the defence.

The CISO Decision Brief

When do we…

When do we share a report, certificate or policy with a customer, and on what terms?

9 decision pointsThe pack behind this answer: Security Questionnaire & Due Diligence Response

Add to board memo

The short answer

Recommendation
Share a document only when it is in your evidence index, in date, and released by the person its sharing tier names. Public items can go to any customer or live prospect. Under NDA items go only when an agreement covers the recipient and the document that day, and a Summary only item goes as its approved summary.
Reasoning
Evidence supports answers you are held to, and some of it must never leave the organisation. The index gives each item an owner, a scope, dates and one sharing tier, so the decision is made once and not for each request. A document shows only its own scope and period, so it is described by its title, scope, issuer and dates and no further. A supplier's document belongs to the supplier, whose terms decide whether it may be shared.
Considerations
  • Check expiry on the day you send. An expired or withdrawn item is not sent, and one sent by mistake is a wrong answer that goes through the correction route.
  • An agreement with a customer's lawyers does not by itself cover its security team. Ask Legal to confirm cover for the recipient and the document.
  • A recipient with no agreement in force is offered the Public items and a summary whose own tier is Public. The request for an agreement goes to Legal.
  • Say the organisation is certified or compliant only when a current indexed document says so for that scope and Legal has confirmed the wording.

The decision, step by step

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

  • Start
  • Step
  • Decision
  • Outcome
  • Loop back

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. 22 steps.
  1. Start

    A customer asks for a report, certificate or policy

    Treat every such request as a request for evidence, whoever receives it. Evidence supports answers the organisation is held to, and some of it must never leave. The rule is the same for a short email, a call or a line in a questionnaire: nothing goes out until the evidence index and the release rules have been applied.

    In the pack

  2. Decision

    Is the sender a customer, or a prospect in a live sale?

    Only customers and prospects in a live sales opportunity are answered. Anyone else is declined and the reason recorded. Sales may still send the Public overview and Public evidence to them. If it is not clear who the sender is, treat the answer as no until the account owner confirms.

    In the pack

  3. Outcome

    Decline, send only Public items, record why

    Reply politely and send nothing beyond the Public overview and Public evidence. Record the decline and the reason in your request log. Sales may send the Public overview and Public evidence, and nothing else goes.

    In the pack

  4. Decision

    Is the item in the evidence index?

    The index lists what the organisation may send, with each item's scope, issuer, owner, dates and sharing tier. A document found on a shared drive but missing from the index has no tier and no owner, so nobody has decided who may see it. If you are unsure, answer no.

    In the pack

  5. Outcome

    Do not send; ask the response lead to place it first

    Judgement call: the pack gives every item a tier and an owner but does not say how to treat a document that is not indexed. This flow takes the cautious route. The response lead and the Head of Information Security decide whether it joins the index and in which tier. Meanwhile tell the customer what is available now, from the Public items.

    In the pack

  6. Decision

    Has it expired or been withdrawn, or is that unknown?

    Check the expiry date on the day you send, not on the day the item was indexed. An item past its expiry date, or withdrawn, is not sent. The answers that cite it are held until its owner renews it or changes them.

    In the pack

  7. Outcome

    Do not send; the owner renews it or replaces it

    Tell the customer only what the owner has confirmed about renewal, and give no date the owner has not confirmed. Sending an expired certificate or report is a wrong answer, and the correction route applies if it has already gone. Do not hide it.

    In the pack

  8. Decision

    Is it a supplier's document, not the organisation's own?

    A hosting provider's certificate or report belongs to the provider, which holds the control and the attestation. Its scope of claim is the supplier's service, not ours. It is shared only as the supplier's terms allow, and never shown as the organisation's own.

    In the pack

  9. Decision

    Do the supplier's terms allow you to share it?

    Read the terms the index records for that supplier. If they are not recorded or not clear, answer no and ask the owner to check with the supplier.

    In the pack

  10. Outcome

    Do not send; point the customer to the supplier

    Tell the customer whose document it is and that the supplier controls its release. Offer what the organisation can say on its own account instead, within its own scope. Do not describe the supplier's controls as the organisation's.

    In the pack

  11. Step

    Label it as the supplier's, with its scope

    State the supplier's name and the scope on the document, for example the hosting service and not the organisation's systems. The customer must not be able to read it as the organisation's own certificate.

    In the pack

  12. Decision

    Which sharing tier is the item in?

    Every indexed item has exactly one tier. The tier decides who releases it and whether it may go at all. Public needs no further agreement. Under NDA needs an agreement in force. Summary only is never sent as it stands. Never shared is not sent.

    In the pack

  13. Outcome

    Do not send; offer the overview and Public items

    Internal workpapers such as internal control test results never leave the organisation. Only the Head of Information Security and Legal together can change a tier. A customer who insists is told what is available instead, and the request is logged.

    In the pack

  14. Step

    Send the approved summary named in the index instead

    An item such as a full penetration test report holds detail an attacker could use, so the item stays inside. Its approved summary goes in its place, released by the Head of Information Security. The summary has its own sharing tier, so this flow checks the summary again from the start: a recipient with no agreement in force gets it only where the summary's own tier is Public (EV-13).

    In the pack

  15. Decision

    Does an NDA cover the recipient and this document today?

    The agreement must be in force on the day of sending and cover the recipient and the document. An agreement with a customer's lawyers does not by itself cover its security team: ask Legal. If cover is unclear or has lapsed, answer no.

    In the pack

  16. Outcome

    Offer Public items and summaries; Legal requests an NDA

    Send the Public items, and a summary only where the summary's own tier is Public, and ask Legal to put an agreement in place. Send the Under NDA item once Legal confirms it covers the recipient. Tell the customer what is waiting on the agreement.

    In the pack

  17. Decision

    Will you say the organisation is certified or compliant?

    Describe the item by its title, scope, issuer and dates, as the document states them, and no further. A statement that the organisation is certified, compliant or aligned is a legal claim about a scope. It is made only when a current document in the index says it for that scope and Legal has confirmed the wording. If unsure, answer yes.

    In the pack

  18. Outcome

    Hold the wording; Legal confirms it first

    Remove the claim or have it confirmed. Name the document and say whose it is, but leave out any statement that the organisation holds a certificate or is compliant unless the index and Legal support it. The distributor in the pack's example holds no certificate of its own and says so.

    In the pack

  19. Decision

    Does it expire within 60 days?

    The pack's default warning window is 60 days. Say in the response when an item expires within it, and state the date. Say that it is being renewed only if the item's owner has confirmed that.

    In the pack

  20. Step

    Put the expiry date in the response

    Write the date plainly. Do not word it as a promise, such as 'we will renew by', which turns a description into a commitment the customer can hold you to. Mention renewal only if the item's owner has confirmed it.

    In the pack

  21. Step

    Add the covering statement and send through the customer's channel

    The covering statement says the response describes the organisation as at a date, for the stated scope, and that any commitment is made only in the agreement. The account owner sends only what the response lead released, by the customer's channel or an encrypted route. Releasing needs the person the tier names.

    In the pack

  22. Outcome

    Record the item, recipient and date, then close

    Record the item, the recipient and the day in your request log, and keep an exact copy of what was sent with the item versions. If the item or its date later proves wrong, the log shows who received it.

    In the pack

Practical checklist

  1. Confirm the sender is a customer or a prospect in a live sale, or decline and record why.
  2. Find the item in the evidence index, and send nothing that is not indexed.
  3. Check its expiry date on the day of sending, and hold it if it has expired or been withdrawn.
  4. For a supplier's document, check the supplier's terms allow sharing, and label it as theirs with its scope.
  5. Apply the sharing tier: send Public items, send the approved summary of a Summary only item, and never send a Never shared item.
  6. Send an Under NDA item only once Legal confirms an agreement covers the recipient and the document that day.
  7. Describe each item by title, scope, issuer and dates, state any expiry within 60 days, and mention renewal only if its owner has confirmed it.
  8. Add the covering statement, send through the customer's channel or an encrypted route, and record the item, the recipient and the day.

Evidence to have ready

  • The evidence index entry for each item sent: type, scope, issuer, owner, dates, sharing tier and any supplier's terms.
  • The release record in your request log: the item, the recipient, the day and who released it.
  • The non-disclosure agreement in force on the day, and Legal's confirmation that it covers the recipient and the document.
  • The exact copy of the response as sent, with the item versions and the covering statement.
  • Legal's written confirmation of any certification or compliance wording.

Assumptions

  • The organisation keeps an evidence index with a sharing tier, owner and expiry date for each item. Without one, build it before the next request.
  • A named response lead handles requests, and the Head of Information Security (or whoever holds that role) releases Under NDA items. The tiers and the 60-day warning are the pack's defaults, which your own standard may change.
  • Legal can confirm whether a non-disclosure agreement covers a given recipient and document.

Not covered here