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Prior to assessing technical vulnerabilities or levels of security awareness, an information security manager needs to gain an understanding of the current business strategy and direction. A business impact analysis should be performed prior to developing a business continuity plan, but this would not be an appropriate first step in developing an information security strategy because it focuses on availability.

The existence of a steering committee that approves all security projects would be an indication of the existence of a good governance program. Compliance with laws and regulations is part of the responsibility of the steering committee but it is not a full answer. Awareness training is important at all levels in any medium, and also an indicator of good governance. However, it must be guided and approved as a security project by the steering committee.

Governance is directly tied to the strategy and direction of the business. Technology constraints, regulatory requirements and litigation potential are all important factors, but they are necessarily in line with the business strategy.

Protection of identifiable personal data is the major focus of recent privacy regulations such as the Health Insurance Portability and Accountability Act (HIPAA). Data mining is an accepted tool for ad hoc reporting; it could pose a threat to privacy only if it violates regulator)' provisions. Identity theft is a potential consequence of privacy violations but not the main focus of many regulations. Human rights addresses privacy issues but is not the main focus of regulations.

Investments in security technologies should be based on a value analysis and a sound business case. Demonstrated value takes precedence over the current business climate because it is ever changing. Basing decisions on audit recommendations would be reactive in nature and might not address the key business needs comprehensively. Vulnerability assessments are useful, but they do not determine whether the cost is justified.

Retention of business records is generally driven by legal and regulatory requirements. Business strategy and direction would not normally apply nor would they override legal and regulatory requirements. Storage capacity and longevity are important but secondary issues. Business case and value analysis would be secondary to complying with legal and regulatory requirements.

The chief operating officer (COO) is highly-placed within an organization and has the most knowledge of business operations and objectives. The chief internal auditor and chief legal counsel are appropriate members of such a steering group. However, sponsoring the creation of the steering committee should be initiated by someone versed in the strategy and direction of the business. Since a security manager is looking to this group for direction, they are not in the best position to oversee formation of this group.

Minimum standards for securing the technical infrastructure should be defined in a security architecture document. This document defines how components are secured and the security services that should be in place. A strategy is a broad, high-level document. A guideline is advisory in nature, while a security model shows the relationships between components.

A set of security objectives, processes, methods, tools and techniques together constitute a security strategy. Although IT and business governance are intertwined, business controls may not be included in a security strategy. Budgets will generally not be included in an information security strategy. Additionally, until information security strategy is formulated and implemented, specific tools will not be identified and specific cost estimates will not be available. Firewall rule sets, network defaults and intrusion detection system (IDS) settings are technical details subject to periodic change, and are not appropriate content for a strategy document.

A steering committee should be in place to approve all security projects. The fact that the data center manager has final signoff for all security projects indicates that a steering committee is not being used and that information security is relegated to a subordinate place in the organization. This would indicate a failure of information security governance. It is not inappropriate for an oversight or steering committee to meet quarterly. Similarly, it may be desirable to have the chief information officer (CIO) approve the security policy due to the size of the organization and frequency of updates. Difficulty in filling vacancies is not uncommon due to the shortage of good, qualified information security professionals.