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[Editor's Note: Cybersecurity Law & Strategy received two separate and unique pitches on the same idea — that CISOs reporting to CIOs creates inherent conflict and can actually harm the security of the organization. This article, by Board of Editors member Kenya Parrish-Dixon, echoes the sentiments presented in Jake Frazier's article in the April issue, yet provides a different perspective on the topic, doing a deeper dive into why the roles should be separate.]
Where the chief information security officer sits within an organizational structure has been debated for years. The issue was presumably resolved when the "chief" was added to the title. This clearly moves an information security officer or security officer into the C-suite among other executives that report directly to the president and CEO of an organization and its board members. Moreover, once the Sarbanes-Oxley Act was passed mandating CISO independence for the financial sector under its "separation of duty" requirement, all third-party service providers to the financial sector should have followed suit. However, the intensity of information security briefings often leads to organizations tucking the CISO under the CIO instead. After all, all technology is related, right? This is a huge mistake, and it is wreaking havoc on American data security.
Law firms and vendors are breached so frequently that corporations have tried forcing them to have better security — especially since hacking into a law firm is an easier target and success results in a larger treasure trove than just breaching a single company — by requiring firms to complete security protocol spreadsheets covering anywhere from 100 to 1,200 controls/questions. However, spreadsheets of controls are hard to manage, even if an organization has an ISO 27001 or SOC 2 certification. Additionally, these certifications are only snapshots of security protocols and do not give insight into day-to-day risk management by the organization's CISO. Corporations still cannot see the daily security posture of a law firm that houses their data. And breaches of law firms continue.
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