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Controls: So Many to Choose From

04/04/2019


There’s a growing tendency in the world of cyber security to simplify inherently complex problems into one-dimensional concepts. Nowhere is this more apparent than in the world of controls.

There are several controls frameworks and hundreds of unique controls an organization could implement in their organization if they wanted to. But this is neither efficient nor practical – there needs to be a better way to select the right tool for a very specific role.

The tangibility-abstraction matrix offers one such solution.

​Framework
​Number of Controls 
​NIST 800-53
​854
PCI DSS
​331
ISO 27001
​114
Critical Security Controls 
​149

Tangibility

The tangibility of a control describes how close or distant it is from the information it protects.

Technical controls – such as firewalls, anti-malware and encryption – are the closest.

Paperwork controls – like policies and procedures to support the function of technical controls in the organization – are less tangible because they’re further away from the information.

Abstraction

Data Governance

The degree of abstraction describes what level of direct oversight a control has over the information it protects.

Asset-level controls – such as firewalls, antimalware or encryption – are the closest to the information and directly affect it, the computer it’s stored in or the network it’s transmitted over.

Variance controls help detect when asset level controls are not functioning properly. These inform businesses when they’re more exposed than normal (e.g. anti-malware application has gone offline).

Decision-making controls are the key human element in this system. Organizational decision-makers consider inputs from all other controls (technical, paperwork, people, asset and variance) and determine what to do next. This could involve change control, business continuity or incident response.


Implementing Controls

Data Governance

Consider an organization regularly handles credit card payments and needs to become Payment Card Industry Data Security Standard (PCI-DSS) compliant. As they begin implementing (largely pre-determined) controls, a clear pattern develops.

In this case, it’s unbalanced: The compliance focus skews heavily toward the bottom left quadrant of the Abstraction-Tangibility matrix.

Recognizing this, the business would want to shift their attention back to risk and maturity focuses to determine which controls would offer a more balanced and well-rounded cyber security program.

Minding the Spread

Data Governance

It’s unrealistic to expect a perfectly even spread. The skew will always be slightly greater to the bottom left – focusing more on the information and technical controls. But the goal should be to spread up and right to cover as many types of controls as possible and create a well-rounded program.