Using Exceptions As A Discovery Tool

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Security exceptions should be used sparingly and should be truly exceptional circumstances that are granted after the business accepts a risk. In mature security programs the security exceptions process is well defined and has clear criteria for what will and will not meet the exception criteria. In mature programs exceptions should be the exception, not the norm. However, in newer security programs exceptions can be a useful tool that provides discovery as well as risk acceptance.

Maturing A Security Program

One of the first things a new CISO will need to do is understand the business and how it functions. As part of this process the CISO will need to take an inventory of the current state of things so he or she can begin to form a strategy on how to best manage risk. As a new CISO your security program may not have well defined security policies and standards. As you begin to define your program and roll out these policies, the exception process can be a valuable tool that gives the perception of a choice, while allowing the security team to uncover areas of the business that need security improvement. Over time, as the business and security program mature, the CISO can gradually deny any requests to renew or extend these exceptions.

Rolling Out A New Security Process

Another area that is useful to have an exceptions process is when rolling out a new security process. For example, if you are rolling out a new process that will require teams to perform SAST and DAST scanning of their code and fix vulnerabilities before going into production, then allowing security exceptions during the initial rollout of the process can be useful to allow teams more time to adapt their development processes to incorporate the new security process. Allowing exceptions can foster good will with the development team and allow the security function visibility into the behavior and culture of the rest of the business. This can allow the security function and development team the opportunity to collaborate together with the ultimate goal of removing any exceptions and following the process to reduce risk to the business.

Tackling Security Tech Debt or Shadow IT

A common maturity evolution for companies is the elimination of shadow IT. The security function can assist with the elimination of shadow IT by creating an exception process and allowing an amnesty period where the business is allowed to continue to operate their shadow IT as long as it is declared. In reality you are giving the business the perception that they will be granted an exception when they are really giving the security function visibility into things they wouldn’t otherwise know about. This can be a useful tool to discover and eliminate policy exceptions as long as it is used sparingly and with good intent (not punitively).

Documentation Is Key

No matter how you choose to use exceptions within your security program there are a few best practices to follow.

1. Exceptions should be truly exceptional. If you do grant one for discovery purposes make sure there is a plan to close the exception. Exceptions shouldn’t be the rule and they shouldn’t be expected. Sometimes the rest of the business just needs someone to tell them no.

2. Time box the exception. Don’t just grant an exception without some sort of end date. The business needs to know an exception is temporary and there should be a well defined plan to make improvements and close the exception. The security team should grant a reasonable amount of time to execute that plan, but it shouldn’t be a never ending story.

3. Review often. Security exceptions should be reviewed often. Part of your security program should review the open exceptions, which ones are ending, if there are patterns where there are lots of similar exceptions and if there are teams who request a high volume of exceptions. Reviewing exceptions gives you insight into how well security processes and controls are working. It also gives you insight into which parts of the business need help.

4. Require the business owner to sign off. The reality of a well run security program is the business ultimately owns the decision if they want to accept a risk or not. The CISO makes a recommendation, but they don’t own the business systems or processes. As a result, the security exception process should require the business owner to sign off on any exception. This will ensure there is documentation that they were made aware of the risk, but this can also act as a visibility tool for the business owner into their own teams. I’ve often found a business leader is not always aware of what their teams are doing at the tactical level and the exceptions process can provide them the opportunity to check their team and correct behavior before it gets to the CISO.

Wrapping Up

The exception process can be a valuable tool for discovery of hidden risk throughout the business. By offering an amnesty period and giving the perception of flexibility, the security team can foster good will with the business while gaining valuable visibility into areas that may be hidden. The exception process also is a valuable tool for the security program to document risk acceptance by the applicable business owner, but can also provide business owners visibility into how well their team is meeting security requirements. Lastly, as the security program matures, the security team can gradually require the business to close down the exceptions by improving their security posture.