Chapter 5: How to generate policies

Policies are the backbone of an effective cybersecurity strategy. They establish the rules, guidelines, and expectations for behavior within an organization, ensuring that security practices are consistent, compliant, and aligned with business objectives. 

As a vCISO, one of your key responsibilities is to help organizations generate new policies or revise existing ones to adapt to evolving threats and regulatory requirements. This chapter will guide you through the process of creating and updating cybersecurity policies that support your clients’ security posture and business goals.

The role of policies in cybersecurity

Policies serve as a formalized framework that defines how an organization protects its assets, manages risks, and complies with regulatory requirements. They provide direction and clarity, ensuring that employees understand their roles and responsibilities in maintaining security. Effective policies help to:

• Define acceptable and unacceptable behaviors.
• Establish procedures for responding to security incidents.
• Outline compliance requirements and how they will be met.
• Protect sensitive data and resources.
• Align security practices with business objectives.

Policies should be clear, concise, and enforceable, providing a solid foundation for security operations and decision-making.

To create policies and/or revise existing policies, follow these steps:

Step 1: Identify the need for policy creation or revision

The first step in generating or revising policies is to identify the need for change. This can be driven by various factors, including:

• Regulatory requirements
• Industry standards
• Security incidents
• Business changes
• Risk assessments

New laws or changes to existing regulations (e.g., GDPR, HIPAA) may necessitate updates to policies.

Adoption of industry standards (e.g., NIST, ISO 27001) might require policy adjustments.

Recent security breaches or incidents may reveal gaps in existing policies, highlighting the need for revision.

Changes in business operations, such as the introduction of new technologies, services, or partnerships, can impact the security landscape and require policy updates.

Findings from risk assessments and audits may uncover vulnerabilities that need to be addressed through policy changes.

Step 2: Conduct a policy gap analysis

Perform a gap analysis to compare current policies with the requirements and best practices identified in the previous step. This analysis will help you identify areas where existing policies are lacking, outdated, or no longer applicable. The gap analysis should focus on:

• Comparing current policies against regulatory and compliance requirements.
• Assessing the effectiveness of policies in mitigating identified risks.
• Identifying inconsistencies or ambiguities in current policies.
• Evaluating the enforceability of existing policies.

Step 3: Engage stakeholders

Policy creation and revision should be a collaborative process that involves input from key stakeholders. These include:

• Executive leadership: Ensures that policies align with the organization’s strategic goals and receive the necessary support for enforcement.
• IT and security teams: Provide technical insights and ensures that policies are practical and enforceable from a technical standpoint.
• Legal and compliance teams: Ensure that policies meet legal and regulatory requirements.
• Human resources: Provides insights into how policies will impact employees and how they can be effectively communicated and enforced.
• Department heads: Offer perspective on how policies will affect specific business units and their operations.

Step 4: Draft or revise policies

Based on the findings from the gap analysis and input from stakeholders, draft new policies or revise existing ones. When drafting policies, consider the following guidelines:

• Clarity and simplicity
• Specificity
• Relevance
• Compliance
• Enforceability

Policies should be written in clear, simple language that is easily understood by all employees, regardless of their technical expertise.

Clearly define what is expected, including roles, responsibilities, and procedures. Avoid vague language that can lead to misunderstandings.

Tailor policies to the specific needs and context of the organization. Generic policies may not address unique risks and requirements.

Ensure that policies meet all applicable regulatory and legal requirements.

Policies should be practical and enforceable. Include consequences for non-compliance to emphasize their importance.

Step 5: Review and approve policies

Once the draft policies are prepared, they should be reviewed by key stakeholders to ensure accuracy, relevance, and alignment with organizational goals. After review, policies should be approved by senior leadership to demonstrate commitment and authority. The approval process may involve:

• Formal review meetings with stakeholders.
• Legal review to ensure compliance with laws and regulations.
• Final approval from the executive team, board of directors or delegated senior member of staff.

Step 6: Communicate policies to employees

Effective communication is crucial for the successful implementation of policies. Employees must be aware of and understand the policies that affect them. To communicate policies effectively:

• Training sessions: Conduct training sessions to educate employees about new or revised policies, their responsibilities, and the importance of compliance.
• Documentation: Make policies easily accessible through the organization’s intranet or a centralized document repository.
• Regular reminders: Send periodic reminders about key policies, especially those related to critical areas such as data protection and incident response.
• Feedback mechanisms: Provide channels for employees to ask questions or provide feedback on policies, helping to improve understanding and address concerns.

Step 7: Monitor and enforce policies

Once policies are implemented, ongoing monitoring and enforcement are essential to ensure compliance. This can involve:

• Regular audits: Conduct regular audits to verify that policies are being followed and are effective in mitigating risks.
• Incident reporting: Establish procedures for reporting and responding to policy violations or security incidents.
• Disciplinary measures: Implement disciplinary measures for non-compliance, demonstrating the seriousness of policy adherence.
• Continuous improvement: Use feedback from audits, incidents, and employee input to continually improve policies and address new challenges.