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Implementing the NIST

Cybersecurity Framework
Using COBIT 5
A Step-by-Step Guide for Your Enterprise

Abstract
In a time of growing threats and evolving circumstances, adopting and maintaining a
robust cyber security profile in your enterprise is vital. Valuable information and assets
must be protected, but the mission goes beyond that. An enterprises cyber stance
should fit into a larger comprehensive structure of the governance and management
of enterprise IT. In such a structure with proper governance, risk and control
(GRC) programs, and supported by a thorough audit and assurance function, decisions
are made and actions are taken to maximize value to the enterprise, accounting for
the needs of all stakeholders, balancing risk and reward. Given this importance to
enterprise strategy and results, cyber security as part of an entire GRC structure is
no longer just a tech issue. It is the foundation upon which enterprise innovation
and transformation takes place.
To help organizations address cyber concerns, the National Institute of Standards
and Technology (NIST) has developed a set of voluntary best practices. Still, every
enterprise is different, creating unique challenges for implementation, especially as
part of a comprehensive GRC program. In such a situation, the COBIT 5 governance
framework has proved extremely valuable. This white paper outlines the steps for
bringing your NIST cyber program under a COBIT 5 structure, thereby preparing your
enterprise for value creation and laying the foundation for future innovation and
business transformation.
IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

Introduction
The governance and management of enterprise IT has taken on
a new meaning with the rapid growth of cyber security and the
multitude of best practices in the market. Given the complexity, it
is no wonder why some enterprises continue to struggle with their
efforts or take incomplete actions. Although there are some great
approaches for a cyber security program, a critical success factor is
ensuring that some key principles exist: meeting stakeholder needs,
using a holistic approach, covering the complete enterprise and
leveraging a single integrated framework. All of these principles lead
toward the enterprise goal of providing value, proving that cyber
security is not only an IT issue.

From a cyber security/risk perspective, adopting the COBIT 5


framework and the National Institute of Standards and Technology
(NIST) Framework for Improving Critical Infrastructure Cybersecurity
also known as the Cybersecurity Frameworkcan be a huge factor in
the enterprise creation of value. These frameworks complement each
other well; COBIT 5 practices synchronize with NIST categories.
The adoption methodologies for each framework have a striking
resemblance, which makes the coupling of these frameworks into a
coherent governance approach a good decision. These frameworks
are flexible models that can be modified to meet the needs of the
enterprise and enable any organization to have a tested and
repeatable central framework.

2016 ISACA. All Rights Reserved. 2


IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 55:IN
A STEP-BY-STEP
YOUR ENTERPRISE
GUIDE FOR YOUR ENTERPRISE

Providing value to
approach taken by most enterprisesis not enough.
To be effective, security measures must be fully integrated
into the enterprise architectures and GRC programs.

the enterprise Although cyber security has been traditionally thought of


as a technological problem, cyber security risk cannot be
addressed by only technical solutions. Many breaches can
Even with new technologies, more efficient processes
be attributed not to technology, but to lapses in policies,
and better-trained staff, some things just seem to be
management supervision, failure to assign responsibility for
getting harder to deliver, and one noteworthy area is value.
cyber security tasks or oversight, and an insufficient system of
Enterprises consist of multiple service providers who serve
controls for access to the enterprise systems and data. Cyber
the business through people, processes and technology, and
security, therefore, requires several levels of effort involving:
typically provide this value in the form of services. What does
this mean to the business? Value consists of achieving Application of technology
business benefits while optimizing risk and resources. Management oversight
Without value in those services provided by service providers,
Legal and regulatory awareness
enterprises can most likely expect a massive decline in
stakeholder value and, more importantly, business survival. Employee training
Adoption and implementation of policies and procedures
The elements in this definition of value can be
governing the information technology environment
explained further:
Benefits realization means that the enterprise is This required effort means that overall enterprise governance
attaining the new benefits that it set out to attain, based measures and attitudes toward risk must drive the enterprise
on stakeholder needs, and eliminating initiatives or assets cyber security program. These drivers are most effective
that are underperforming. when they are integrated into the culture of organizational
behaviors and actions.
Risk optimization is the result of making informed
enterprise decisions when the risk exposure is within the This shift in perspective raises security from a technical
enterprises risk appetite. concern to an enterprise issue. Because security concerns
Resource optimization requires applying enterprise influence stakeholders definition of value, the organization
resources at the right time, place and effort, and not must identify, protect, detect, respond and recover from
wasting them frivolously. cyber security threats, and focus many core resources and
competencies so that security risk is managed and aligned
Generally, the key to successful innovation and business with the strategic goals, operational criteria, risk thresholds,
transformation requires investing in a foundational set compliance requirements and technical system architecture.
of enablers, as part of an overall governance, risk and
control (GRC) posture that maximizes these elements of Cyber security is about managing risk. Risk governance
value. If an enterprise exhibits strong competencies in and management is about informed decision making.
the GRC functions, it will be well positioned to drive the Therefore, the cyber security equation has two
kind of transformation needed components: business enablement and asset
to stay competitive and thrive in todays economy. Failure protection. First, cyber security efforts must be aligned to
to consider the importance of these functions to achieving fit the enterprise GRC framework by delivering on business
transformational goals can lead to huge disappointment while strategy. Cyber risk is a critical business risk and thus an
the enterprise spins its wheels in a reactive mode. important element. Second, information is a key enterprise
asset and must be protected based on criticality, integrity and
To add to the challenge of providing value, enter cyber availability needs. Cyber security must be considered in the
security. Stakeholders are influenced by many things, larger picture of enterprise GRC scope, because of the need
and in todays environment, cyber security is most likely to move information in todays economy is vital to success.
somewhere toward the top of the influencers list. Simply
implementing a variety of security mechanismsthe

2017 ISACA. All Rights Reserved. 3


IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

Real-Life Business Transformation:


The need for a
Start with a Simple Approach. simple approach
XYZ is an IT managed service provider in North
America. With over 100 client enterprises, the need Recognizing that cyber security is no longer only an IT
for a single, integrated governance framework was issue, leadership should ensure that the enterprise develops
evident. Each tenant enterprise had specific needs a cyber security/risk framework. There are many to choose
and requirements from a compliance and security from. In fact, there are so many that often enterprises
perspective. The client enterprises had a host of admittedly suffer from framework overload. There is a best
industry frameworks and standards that they used practice for everything: governance, compliance, risk,
for their operations. The complexity of trying to service management, development lifecycles, and of course,
manage this multitude of requirements from several cyber security. The list of these best practices includes
different areas was daunting and created multiple frameworks, bodies of knowledge, standards, methodologies
vulnerabilities, duplication of efforts and wasted and so on. These are found in both public and proprietary
resources. Recognizing this issue, XYZ embarked domains. The secret to enterprise success: Do not fall victim
on a simplification effort with the goal of finding a few to the idea that a single framework can handle all of the
key frameworks that could be leveraged to provide a enterprise needs, i.e., one-size-fits-all; rather, combine these
core governance and management program. This best practices into a single governing framework that governs
was done with the COBIT 5 framework. COBIT 5 the use of all of these various frameworks.
not only referenced commonly known frameworks From a cyber security perspective, the list of best practices
and standards in the industry, it also synchronized is growing quickly, and they all have significant value
well with two of the most common security-related propositions for the enterprise if they are leveraged correctly.
frameworks: ISO/IEC27001 and the NIST Cybersecurity A viable enterprise solution for cyber security is to
Framework. Using these frameworks as the basis adopt a framework to manage frameworks. This is
for improvements, assurance and compliance, accomplished with the intersection of the NIST
stakeholder needs were addressed effectively in all Cybersecurity Framework and COBIT 5 as an
activities. By using COBIT 5 as their central control overarching framework.
tool, this ensured a proper balance of conformance
and performance by ensuring that stakeholder

The NIST CSF


needs, risk and compliance requirements were
addressed based on their importance to the goal
of creating value for stakeholders.

structure
Cyber security attacks are growing more intense and
harmful, and based on the increasing number of incidents
over the last few years, they are likely to continue. These
scenarios, coupled with an increasing threat to a nations
critical infrastructure, puts cyber security protection very
high on any enterprise priority list.

Recognizing the need for broad safeguards against attacks


that could disrupt our nations critical systems, Executive
Order (EO) 13636, Improving Critical Infrastructure

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IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

Cybersecurity,1 directed collaboration with industry to


develop a voluntary risk-based cyber security framework.
In response, the NIST collaborated with ISACA and industry
partners to create a risk-based cyber security framework.
Real-Life Business Transformation:
The NIST Cybersecurity Framework (CSF) provides this Build a Foundation for Innovation
risk-based iterative approach to the adoption of a more
vigilant cyber security posture in the public and private After the XYZ IT managed service provider made
domains. Figure 1 describes the components of the the business decision to leverage COBIT 5 as its
NIST CSF. central governing framework and the NIST
Cybersecurity Framework, the real work began. Due
One of the strongest features of the NIST CSF is the Framework to the size and complexity of the enterprise and its
Core, as illustrated in figure 2. This core is a set of cyber customers, XYZ decided to adopt these frameworks
security activities, desired outcomes and references from iteratively, taking small improvements at a time
industry standards, guidelines and practices. which would yield an ongoing effort. Fortunately, the
COBIT 5 and NIST implementation methodologies
The Framework Core has five functions and 22 categories. are aligned to enable this. During the first two
Each of these categories is further broken down into iterations of this adoption, XYZ recognized that
subcategories and informative references. Informative there was something unique to this transformation:
references provide the specific standard, guideline or It was being driven by stakeholder needs and goals,
which was a new, innovative way of looking at things
for this enterprise. Instead of letting technology drive
value, the needs of the business drove value. The
FIGURE 1 typical knee-jerk reactions to checklists were now
Structure of the NIST Cybersecurity Framework thoughtful analyses of risk, which pointed efforts
toward responding in more appropriate ways.
Component Description Whereas in the past, there was a tendency to
over-control every need, which wasted resources,
now XYZ had methods to determine, based on
The Framework Core consists of five functions
(Identify, Protect, Detect, Respond and Recov- risk, the areas that could be accepted, transferred,
Framework Core
er) and includes activities, desired outcomes avoided or mitigated. Having this link to the business
and applicable references. facilitated a combined effort of all applicable
stakeholders in the cyber security project, rather
Implementation Tiers provides context and than only being driven by technology.
Implementation identifies the degree to which practices
Tiers exhibit the characteristics defined in the
framework. Tiers range, from Tier 1 Partial to
Tier 4 Adaptive.

Profiles are outcomes based on business


needs. This is the analysis of current and
Profiles target profiles that help determine the prioriti-
zation of efforts based on risk.

Implementation Implementation Guidance uses a seven-step


Guidance process that is iterative and flexible.

SOURCE: Framework for Improving Critical Infrastructure Cybersecurity, Version


1.0, National Institute of Standards and Technology. February 12, 2014

1 Framework for Improving Critical Infrastructure Cybersecurity, Version 1.0, National Institute of Standards and Technology. February 12, 2014

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IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

FIGURE 2
Functions of the NIST CSF Framework Core

Identifiy Protect Detect Respond Recover

Appropriate activities to
Develop the organizational Develop and implement the Develop and implement the maintain plans for resistance
Develop and implement the
understanding to manage appropriate safeguards to appropriate activities to and to restore any
appropriate activities to take
cyberspace risk to systems, ensure delivery of critical identify the occurrence of a capabilities or services
action regarding
assets, data and capabilities infrastructure services cybersecurity event that were impaired due to
a cybersecurity event

ASSET MANAGEMENT ACCESS CONTROL ANOMALIES AND EVENTS RESPONSIVE PLANNING RECOVERY PLANNING

SECURITY CONTINUOUS
BUSINESS ENVIRONMENT AWARENESS AND TRAINING COMMUNICATIONS IMPROVEMENTS
MONITORING

GOVERNANCE DATA SECURITY DETECTION PROCESSES ANALYSIS COMMUNICATIONS

INFORMATION PROTECTION
RISK ASSESSMENT MITIGATION
PROCESSES AND PROCEDURES

RISK MANAGEMENT STRATEGY MAINTENANCE IMPROVEMENTS

PROTECTIVE TECHNOLOGY

SOURCE: Framework for Improving Critical Infrastructure Cybersecurity, Version 1.0, National Institute of Standards and Technology. February 12, 2014

practice to use to achieve the associated outcome. These option 1, the gradual approach. The NIST implementation
include specific COBIT 5, CIS Critical Security Controls, ISO/ approach is a nice fit with the COBIT 5 framework, because
IEC 27001, NIST SP 800-53, and ISA 62443 references. COBIT 5:
Employs a principles-based structure

Adopting NIST
Provides a holistic approach
Has a phased, iterative implementation methodology
Is used as an informative reference in the NIST CSF

using COBIT Includes an assessment program based on


industry standards

Regardless of the type of framework, adoption can be Therefore, it is no surprise that COBIT 5 is a natural fit
typically accomplished in one of two ways: for adopting not only solid GRC practices, but also cyber
1. Adopting the framework gradually by starting small to security practices that are based on the NIST CSF.
create quick wins and building on initial successes to Figure 3 shows the alignment between the NIST CSF and
iterate deployments regularly the COBIT 5 implementation steps and principles.

2. Using a big bang approach across the entire enterprise Using a deployment methodology that is proven in the
industry is paramount. Because the NIST CSF and COBIT 5
Although the big bang approach can be a viable solution, align nicely, it is a logical approach. Following are the steps
depending on the situation, it is generally best to adopt of a typical enterprise implementation.

2017 ISACA. All Rights Reserved. 6


IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

FIGURE 3
NIST CSF and COBIT 5 Implementation Alignment

NIST CSF Implementation Steps COBIT Implementation Steps COBIT Principles

1 Prioritize and scope 1 What are the drivers? 1 Meeting stakeholder needs

2 Orient 2 Where are we now? 2 Covering the enterprise end to end

3 Create a current profile


3 Applying a single integrated framework

4 Conduct a risk assessment 3 Where do we want to be?

5 Create a target profile

6 Detemine, analyze and prioritize gaps 4 What needs to be done?

7 Implement action plan 5 How do we get there? 4 Enabling a holistic approach

8 CSF action plan review 6 Did we get there?

9 CSF lifecycle managment 7 How do we keep the momentum going?

5 Separating governance from management

SOURCE: Implementing the NIST Cybersecurity Framework, ISACA

NIST CSF STEP 1: Prioritize and scope with the COBIT 5 implementation Step 2, Where are we
now? and COBIT 5 principles Covering the enterprise end
The purpose of this step is to obtain an understanding of
to end and Applying a single integrated framework.
the current approach to governance and cyber security in
the enterprise and identify key stakeholders, organizational This is where the framework implementation tiers enter the
mission, roles and responsibilities. This aligns with the equation. These are levels of implementation that can assist
COBIT 5 implementation phase What are the drivers? and in assessment and planning of cyber security activities. Tiers
principle Meeting stakeholder needs. describe attributes to consider when completing the current
profile and creating a target profile later on, and describe the
Step 1 is also the right moment to conduct a Goals Cascade
implementation progression. These tiers are also aligned well
exercise (another feature in COBIT 5), which is a really helpful
with the COBIT 5 process capability levels. Figure 5 shows
and effective tool. The Goals Cascade is a series of
the four tiers.
mappings that allow an enterprise to link stakeholder needs
with enterprise goals, IT-related goals and enabler goals. This step conducts a current-state assessment using the
Figure 4 is a high-level description of the Goals Cascade. ISO 15504 approach to process capability. The COBIT 5
assessment methodology is used to complete the current
NIST CSF STEPS 2 AND 3: Orient and Create a profile, iterating through each subcategory and recording
current profile current status, ranging from not achieved to fully achieved.
Now that the goals cascading is complete, it is time to
Therefore, a current profile can also be referred to as the
identify threats to, and vulnerabilities of, those systems and
current state. This is the key output to Step 3. The NIST CSF
assets. The purpose of these two steps is to gain an
provides a template for this, as illustrated in figure 6.
understanding of the enterprise systems and assets that
enable the mission described in Step 1. These steps align

2017 ISACA. All Rights Reserved. 7


IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

FIGURE 4
Stakeholder Drivers
COBIT 5 Goals Cascade

Stakeholder Needs

Enterprise Goals

IT-Related Goals

Enabler Goals

PRINCIPLES, POLICIES CULTURE ETHICS AND


PROCESSES ORGANIZATIONAL STRUCTURES
AND FRAMEWORKS BEHAVIOR

SERVICES, INFASTRUCTURE, PEOPLE, SKILLS AND


INFORMATION
AND APPLICATIONS COMPETENCIES

SOURCE: COBIT 5, A Business Framework for the Governance and Management of Enterprise IT, ISACA

FIGURE 5
NIST CSF Implementation Tiers

Integrated Risk Comparison to COBIT 5


Risk Managment Process External Participation
Management Program Process Capability Levels

Limited institutional awareness.


Tier 1: Informed risk practices. Lacks process to coordinate Level 0 (Incomplete)
Risk management in place
Partial Reactive, ad hoc risk approach. and collaborate. Level 1 (Performed)
but irregular.

Approved risk management


Tier 2: Organization has cyber security Organization has not formalized
practices but not organization-wide. Level 2 (Managed)
Risk risk awareness but not an capabilities to interact and share
Priorities informed by stakeholder
Informed institutionalized approach. information.
goals and corporate risk decisions.

Organization-wide approach to Organization understands


Risk management practices managing cyber security risk. dependencies and partners.
Tier 3:
formally approved, expressed as Risk-informed policies, processes Receives information that Level 3 (Established)
Repeatable
policy, regularly updated. and procedures are defined enables collaboration and
and reviewed. risk-based response decisions.

Implementation Guidance uses Organizational risk approach with Active sharing with partners to
Tier 4: Level 4 (Predictable)
a seven-step process that is situational awareness integrated proactively learn and benefit the
Adaptive Level 5 (Optimizing)
iterative and flexible. into culture. community.

SOURCE: Framework for Improving Critical Infrastructure Cybersecurity, Version 1.0, National Institute of Standards and Technology. February 12, 2014

2017 ISACA. All Rights Reserved. 8


IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

FIGURE 6
NIST CSF Current Profile Template

Function Category Subcategory Relevant COBIT Practices

ID.AM-1: Physical devices and systems within the organization are inventoried BAI09.01, BAI09.02

ID.AM-2: Software platforms and applications within the organization


BAI09.01, BAI09.02, BAI09.05
are inventoried
Asset Management (ID.AM): The
data, personnel, devices, systems,
and facilities that enable the ID.AM-3: Organizational communication and data flows are mapped DSS05.02
organization to achieve business
purposes are identified and managed ID.AM-4: External information systems are catalogued APO02.02
consistent with their relative
importance to business objectives
ID.AM-5: Resources (e.g., hardware, devices, data, and software) are APO03.03, APO03.04,
and the organizations risk strategy.
prioritized based on their classification, criticality, and business value BAI09.02

ID.AM-6: Cybersecurity roles and responsibilities for the entire workforce and
APO01.02, DSS06.03
third-party stakeholders (e.g., suppliers, customers, partners) are established

APO08.04, APO08.05,
ID.BE-1: The organizations role in the supply chain is identified
APO10.03, APO10.04,
and communicated
APO10.05

Business Environment (ID.BE): ID.BE-2: The organizations place in critical infrastructure and its industry
The organizations mission, APO02.06, APO03.01
Identify sector is identified and communicated
(ID) objectives, stakeholders, and
activities are understood and
ID.BE-3: Priorities for organizational mission, objectives, and activities are APO02.01, APO02.06,
prioritized; this information is
established and communicated APO03.01
used to inform cybersecurity
roles, responsibilities, and risk
management decisions. ID.BE-4: Dependencies and critical functions for delivery of critical services
are established

ID.BE-5: Resilience requirements to support delivery of critical services


DSS04.02
are established

APO01.03, EDM01.01,
ID.GV-1: Organizational information security policy is established
EDM01.02
Governance (ID.GV): The
policies, procedures, and processes ID.GV-2: Information security roles & responsibilities are coordinated and
to manage and monitor the APO13.12
aligned with internal roles and external partners
organizations regulatory, legal, risk,
environmental, and operational
requirements are understood ID.GV-3: Legal and regulatory requirements regarding cybersecurity, including
MEA03.01, MEA03.04
and inform the management of privacy and civil liberties obligations, are understood and managed
cybersecurity risk.
ID.GV-4: Governance and risk management processes address
DSS04.02
cybersecurity risks

SOURCE: Implementing the NIST Cybersecurity Framework Toolkit, ISACA

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IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

In this sample template, each of the subcategories are linked NIST CSF STEP 6: Determine, analyze
to specific COBIT 5 practices. These subcategories can also and prioritize gaps
be linked to the other industry references. Information about In this step, the enterprise seeks to understand and
these specific COBIT 5 practices can be found in the COBIT document the actions required to close the gaps between
5: Enabling Processes guide. current and target state environments. This step is aligned
with the COBIT 5 Implementation step What needs to be
NIST CSF STEPS 4 AND 5: Conduct a risk done? and COBIT 5 principles Covering the enterprise end
assessment and Create a target profile to end and Applying a single integrated framework.
The purpose of these two steps is to identify the overarching
The enterprise records the differences between the current
threats to, and vulnerabilities of, those systems and assets
and desired states and uses COBIT 5: Enabling Processes
identified earlier, and determine the likelihood and impact of
to determine the practices and activities that need to be
a cyber security event. Completion of these steps results in a
improved to close the gaps. In addition to the gaps, one
catalog of potential security risk and business impact
must understand the resources and capabilities that are
assessment, a target capability level and target profile.
required to accomplish these efforts. This action plan of
These two steps align with the COBIT 5 implementation activities includes milestones, responsibilities and desired
step, Where do we want to be?, and COBIT 5 principles outcomes according to the set priorities. An action plan
Covering the enterprise end to end and Applying a single should include the following:
integrated framework. Identification

To accomplish this, it is beneficial to use COBIT 5 for Risk, Priority


Process Assessment Model (PAM): Using COBIT 5, and Assumptions and constraints
COBIT 5 Assessors Guide to determine appropriate levels
Rationale
of achievement, and reference the COBIT 5 process APO12,
Manage Risk. Specific actions
Resources
The key outputs of these steps include the enterprise risk
assessment and target profile. The target profile is similar Schedule/milestones
to the current profile template and should include the Status
following information:
Pre-requisites/dependencies
Applicable function
Action assignee
Applicable category
Stakeholder roles
Applicable subcategory
COBIT 5 reference to identify practices required to meet NIST CSF STEP 7: Implement action plan
the goals of the subcategory
After the gaps are known and the plans have been
Achievement rating (e.g., not achieved, partially determined to close those gaps, the enterprise can execute
achieved, largely achieved, fully achieved) based on the plan that addresses the priorities to improve security and
existing procedures meet stakeholder goals. This step is aligned with the COBIT 5
Practices, policies and procedures identified in the risk Implementation step How do we get there? and COBIT 5
assessment principle Enabling a holistic approach.

Description of how the achievement rating was determined The enterprise should consider the challenges, root causes
Actions required to achieve the target state goals and success factors from the COBIT 5 Implementation
Guide, which include:
Resources required

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IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

Test the approach by making small improvements initially further governance or management requirements, and
and to provide some quick wins support continual improvement. This step is aligned with
Involve all stakeholders the COBIT 5 Implementation step How do we keep the
momentum going?
Improve processes before attempting to apply automation
Set clear, measurable goals and produce scorecards
showing how performance is being measured
Communicate in business impact terms Auditing and
Using sound program and project management principles
in this step is key. If this step is successful, the outcomes
include operating procedures for implemented action items,
assurance
performance reports and metrics. Having this single, integrated framework for the governance
and management of enterprise IT and cyber security efforts
NIST CSF STEP 8: CSF action plan review clearly creates value for the enterprise; however, providing
The enterprise reviews the application of the improved assurance for these efforts is just as critical. From a cyber
governance and management practices, and confirms that security perspective, an audit provides management with
the action plan delivered the expected benefits. This step is an evaluation of the effectiveness of cyber security-related
aligned with the COBIT 5 Implementation step Did we get policies, implementation of controls, and achievement of
there? The enterprise assesses the activities from the process purposes. These can identify internal and external
implementation step to ensure that improvements achieve deficiencies that could potentially impact the enterprises
the anticipated goals and risk management objectives. The ability to meet its goals. Considering the three lines of
enterprise documents the lessons learned and identifies any defense model in figure 7, simply adopting the COBIT 5
specific ongoing monitoring needs. and NIST frameworks can be linked to the first two lines of
defense. Therefore, having the third line of defense, the
audit department, can provide an objective view of how
NIST CSF STEP 9: CSF lifecycle management
the frameworks practices and activities are reliable,
The purpose of this step is to provide ongoing review/ accurate, and secure.
assessment of the overall success of the initiative, identify

FIGURE 7
Three Lines of Defense Model Based on COBIT 5 for Risk

Board/Enterprise Risk Committee

Operations

1st Line of Defense 2st Line of Defense 3rd Line of Defense

Operations Risk Function Audit Department

Enterprise Risk Group Compliance

SOURCE: COBIT 5 for Risk, ISACA.

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IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

There are numerous programs available today that provide CSF functions, categories, subcategories, and informative
solid assurance models. Considering the topic of this paper, references. Adopting the three lines of defense model,
it makes sense to adopt an auditing program that focuses incorporated with solid processes and practices, truly
on the COBIT 5 and NIST frameworks. ISACAs IS Audit/ provides a holistic approach that meets stakeholder needs.
Assurance Program for Cyber security: Based on the NIST It is also an important part of the GRC foundation
Cybersecurity Framework Audit Program provides control necessary for successfully undertaking enterprise innovation
objectives, controls and testing steps based on the NIST and transformation.

Ten tips to adoption


Even though the approach outlined in this white paper is 6. Demonstrate quick wins. Many governance adoptions
relatively simple, there are numerous additional considerations tend to fizzle out due to simple exhaustion. Governance
to ensuring that the enterprise efforts are successful. Following is a way of doing business and not a project, so ensure
are some of the most important tips to keep in mind. that the plan can demonstrate quick wins to keep the
1. Know the stakeholders. An enterprise has internal and momentum going. Hint: Plan these as a part of your
external stakeholders. Seek to understand their needs and overall business case.
their expectations and influences. Hint: Collaborate with 7. Use a continuous cycle. There are many approaches to
your Risk Group or PMO, its likely theyve already done a use to keep the momentum going, but the bottom line is
detailed analysis of business stakeholders. that one must think of governance as a commitment that
2. Understand why. What are the drivers? It goes without requires continuous initiatives that focus on improvement.
saying that a business case makes sense, but why does Hint: Demings PDCA, ITILs CSI Model, and COBITs
an enterprise really need governance? Is it for regulatory/ Implementation Model.
compliance, cost savings, because programs and projects 8. Embed new approaches. Let things sink in. The
are amok? Hint: Start with the enterprise stakeholder cultural aspects of change require adoption and
needs and cascade them to IT goals by using the COBIT 5 acceptance. Hint: Read Kotters Leading Change
Goals Cascade. about organizational change.
3. Leverage industry available frameworks. Be careful 9. Formal documentation. Policies, procedures, and key
not to fall into using just one framework because it can do documents must be formalized and organized in a manner
everythingthose do not exist. Use a mix of frameworks that allows stakeholders to get the information they need.
and adjust them to fit the enterprise needs. Hint: COBIT, Hint: Look to your knowledge repository to manage
ISO, NIST. up-to-date documentation.
4. Get top management involved. It is hard to get the 10. Train. Your actions should support your words, so allow
attention of enterprise leadership when they are already time and money to deliver the appropriate training. It will
busy. Look for trigger events that can get the plan in not only demonstrate your commitment, but will increase
front of them and have that plan ready with a powerful the knowledge of the stakeholders. Hint: At a minimum,
message. Hint: Pain points and trigger events tend to COBIT Foundation training should be considered as a part
get the attention of management and can be found in of any adoption efforts.
COBIT 5 Implementation.

5. Instill accountability. This typically starts at the top, but


make sure that key roles are identified with explicit details
regarding their accountabilities. Hint: RACI Charts that can
be found in COBIT 5: Enabling Processes.

2017 ISACA. All Rights Reserved. 12


IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

ISACA
ISACA (isaca.org) helps professionals Disclaimer
around the globe realize the positive ISACA has designed and created
potential of technology in an evolving Integrating COBIT 5 and the NIST
digital world. By offering industry-leading 3701 Algonquin Road, Suite 1010
Cybersecurity Frameworks (the Work)
knowledge, standards, credentialing and Rolling Meadows, IL 60008 USA
primarily as an educational resource for
education, ISACA enables professionals professionals. ISACA makes no claim that Phone: +1.847.253.1545
to apply technology in ways that instill use of any of the Work will assure a
Fax: +1.847.253.1443
confidence, address threats, drive successful outcome. The Work should
innovation and create positive not be considered inclusive of all proper Email: info@isaca.org
momentum for their organizations. information, procedures and tests or www.isaca.org
Established in 1969, ISACA is a global exclusive of other information, procedures
association serving more than 500,000 and tests that are reasonably directed to
engaged professionals in 188 countries. obtaining the same results. In determining Provide feedback:
ISACA is the creator of the COBIT the propriety of any specific information, www.isaca.org/NIST-COBIT5
framework, which helps organizations procedure or test, professionals should Participate in the ISACA
effectively govern and manage their apply their own professional judgment to Knowledge Center:
information and technology. Through its the specific circumstances presented by www.isaca.org/knowledge-center
Cybersecurity Nexus (CSX), ISACA the particular systems or information
helps organizations develop skilled technology environment. Follow ISACA on Twitter:
cyber workforces and enables www.twitter.com/ISACANews
individuals to grow and advance their
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2017 ISACA. All Rights Reserved. 13


IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 5: A STEP-BY-STEP GUIDE FOR YOUR ENTERPRISE

ACKNOWLEDGMENTS
ISACA would like to recognize:

Lead Developer ISACA Board of Directors


Mark Thomas Christos K. Dimitriadis
Ph.D., CISA, CISM, CRISC,
INTRALOT S.A., Greece, Chair
Expert Reviewer
Theresa Grafenstine
Peter Tessin
CISA, CGEIT, CRISC, CIA, CGAP, CGMA,
CPA, US House of Representatives, USA, Vice-chair

Robert Clyde
CISM, Clyde Consulting LLC, USA, Director

Leonard Ong
CISA, CISM, CGEIT, CRISC, CPP, CFE, PMP, CIPM,
CIPT, CISSP ISSMP-ISSAP, CSSLP, CITBCM, GCIA,
GCIH, GSNA, GCFA, Merck, Singapore, Director

Andre Pitkowski
CGEIT, CRISC, OCTAVE, CRMA, ISO27kLA, ISO31kLA,
APIT Consultoria de Informatica Ltd., Brazil, Director

Eddie Schwartz
CISA, CISM, CISSP-ISSEP, PMP, WhiteOps,
USA, Director

Jo Stewart-Rattray
CISA, CISM, CGEIT, CRISC, FACS CP,
BRM Holdich, Australia, Director

Tichaona Zororo
CISA, CISM, CGEIT, CRISC, CIA, CRMA, EGIT |
Enterprise Governance (Pty) Ltd.,
South Africa, Director

Zubin Chagpar
CISA, CISM, PMP, Amazon Web Services,
UK, Director

Rajaramiyer Venketaramani Raghu


CISA, CRISC, Versatilist Consulting India Pvt. Ltd.,
India, Director

Jeff Spivey
CRISC, CPP, Security Risk Management Inc.,
USA, Director

Robert E. Stroud
CGEIT, CRISC, Forrester Research,
USA, Past Chair

Tony Hayes
CGEIT, AFCHSE, CHE, FACS, FCPA, FIIA,
Queensland Government, Australia, Past Chair

Greg Grocholski
CISA, SABIC, Saudi Arabia, Past Chair

Matt Loeb
CGEIT, FASAE, CAE, ISACA, USA, Director

2017 ISACA. All Rights Reserved. 14

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