Red Clay Renovations is an internationally recognized, awarding winning firm that specializes in the renovation and rehabilitation of residential buildings and dwellings. The company specializes in updating homes using “smart home” and “Internet of Things” technologies while maintaining period correct architectural characteristics. Please refer to the company profile posted in the online classroom for additional background information and information about the company’s operating environment.
Policy Issue & Plan of Action
The Manager’s Deskbook contains issue specific policies and implementation procedures which are required to mitigate risks to the company and to otherwise ensure good governance of the company’s operations. The Chief Information Security Officer (CISO) and key CISO staff members held a kick-off meeting last week to identify issue specific policies which should be added to the company’s policy system in the IT Governance category. The policies will be disseminated throughout the company by incorporating them into the Manager’s Deskbook. The required issue specific policies are:
- Data Breach Response Policy
- Preventing / Controlling Shadow IT Policy
- Management and Use of Corporate Social Media Accounts Policy
For the purposes of this assignment, you will create a policy recommendations briefing package (containing an Executive Summary and draft policies) and submit that to your instructor for grading.
Note: In a “real world” environment, the policy recommendations briefing package would be submitted to the IT Governance board for discussion and vetting. After revisions and voting, a package containing the accepted policies would be sent to all department heads and executives for comment and additional vetting. These comments would be combined and integrated into the policies and sent out for review again. It usually takes several rounds of review and comments before the policies can be sent to the Chief of Staff’s office for forwarding to the Corporate Governance Board. During the review & comments period, the policies will also be subjected to a thorough legal review by the company’s attorneys. Upon final approval by the Corporate Governance Board, the policies will be adopted and placed into the Manager’s Deskbook. This entire process can take 9 to 12 months, if not longer.
Your Task Assignment
As a staff member supporting the CISO, you have been asked to research and then draft an issue specific policy for each of the identified issues (three separate policies). These policies are to be written for MANAGERS and must identify the issue, explain what actions must be taken to address the issue (the company’s “policy”), state the required actions to implement the policy, and name the responsible / coordinating parties (by level, e.g. department heads, or by title on the organization chart).
After completing your research and reviewing sample policies from other organizations, you will then prepare an “approval draft” for each issue specific policy.
- The purpose of each issue specific policy is to address a specific IT governance issue that requires cooperation and collaboration between multiple departments within an organization.
- Each issue specific policy should be no more than two typed pages in length (single space paragraphs with a blank line between).
- You will need to be concise in your writing and only include the most important elements for each policy.
- You may refer to an associated “procedure” if necessary, e.g. a Procedure for Requesting Issuance of a Third Level Domain Name (under the company’s Second Level Domain name) or a Procedure for Requesting Authorization to Establish a Social Media Account.
Your “approval drafts” will be combined with a one page Executive Summary (explaining why these issue specific policies are being brought before the IT Governance Board).
Research:
- Review the table of contents and relevant chapters in the Certified Information Privacy Professional textbook to find information about legal and regulatory drivers.
- Review NIST’s definition of an “Issue Specific Policy” and contents thereof in NIST SP 800-12 Section 5.3. This document provides information about the content of an issue specific policy (as compared to comprehensive system and enterprise security policies).
- Review the weekly readings and resource documents posted in the classroom. Pay special attention to the resources which contain “issues” and “best practices” information for:
- Data Breach Response
- Preventing / Controlling Shadow IT
- Social Media
- Review NIST guidance for required / recommended security controls (see NIST SP 800-12, NIST SP 800-53, and NIST SP 800-100). Some suggested control families are:
- Access Control (AC) control family (for Social Media policy)
- Incident Response (IR) control family (for Data Breach policy)
- System and Services Acquisition (SA) control family (Domain Name, Shadow IT, Website Governance)
- Find and review additional authoritative / credible sources on your own which provide information about IT security issues (related to data breaches / responses, shadow IT, and/or social media use) which require policy solutions.
Write:
- Prepare briefing package with approval drafts of the three IT related policies for the Manager’s Deskbook. Your briefing package must contain the following:
- Executive Summary
- “Approval Drafts” for
o Data Breach Response Policy
o Preventing / Controlling Shadow IT Policy
o Management and Use of Corporate Social Media Accounts Policy
As you write your policies, make sure that you address IT and cybersecurity concepts using standard terminology.
- Use a professional format for your policy documents and briefing package. Your policy documents should be consistently formatted and easy to read.
- You must include a cover page with the assignment title, your name, and the due date. Your reference list must be on a separate page at the end of your file. These pages do not count towards the assignment’s page count.
- Common phrases do not require citations. If there is doubt as to whether or not information requires attribution, provide a footnote with publication information or use APA format citations and references.
- You are expected to write grammatically correct English in every assignment that you submit for grading. Do not turn in any work without (a) using spell check, (b) using grammar check, (c) verifying that your punctuation is correct and (d) reviewing your work for correct word usage and correctly structured sentences and paragraphs.
Full Answer Section
The Data Breach Response Policy outlines the necessary steps and responsibilities for effectively identifying, containing, eradicating, and recovering from a data breach incident. This policy is crucial for minimizing potential financial, reputational, and legal damages, aligning with legal and regulatory requirements highlighted in the CIPP textbook and drawing upon best practices from NIST SP 800-12 and the Incident Response (IR) control family of NIST SP 800-53.
The Preventing / Controlling Shadow IT Policy addresses the risks associated with the unauthorized use of hardware, software, and cloud services within the organization. This policy aims to establish a framework for managing the adoption of new technologies in a secure and compliant manner, referencing NIST SP 800-12 and aligning with the System and Services Acquisition (SA) control family of NIST SP 800-53.
The Management and Use of Corporate Social Media Accounts Policy provides guidelines for the responsible and secure use of social media platforms for Red Clay Renovations’ business purposes. This policy aims to protect the company’s brand, ensure compliance with relevant regulations, and mitigate potential security risks, drawing upon best practices for social media governance and aligning with the Access Control (AC) control family of NIST SP 800-53.
These policies are designed to be concise and actionable for managers across all departments, facilitating a coordinated approach to IT governance and risk mitigation at Red Clay Renovations.
Approval Draft: Data Breach Response Policy
1. Issue: Data breaches pose a significant threat to Red Clay Renovations, potentially leading to the compromise of sensitive customer data, intellectual property, and proprietary information. Failure to effectively respond to a data breach can result in substantial financial losses, reputational damage, legal liabilities, and regulatory penalties, as outlined in relevant privacy regulations (e.g., GDPR as discussed in CIPP).
2. Policy: Red Clay Renovations is committed to a swift, effective, and legally compliant response to any data breach incident. All managers are responsible for understanding and adhering to this policy to minimize the impact of such incidents.
3. Required Actions for Implementation:
- Detection and Reporting: Any suspected or confirmed data breach must be immediately reported to the Information Security Department. Managers who become aware of a potential incident are responsible for escalating this information without delay through established communication channels.
- Containment: Upon notification, the Information Security Department, in coordination with relevant department heads (e.g., IT, Legal, Public Relations), will take immediate steps to contain the breach to prevent further data loss and system compromise. This may involve isolating affected systems, revoking access credentials, and implementing temporary security measures.
- Eradication: The Information Security Department will lead the process of identifying and removing the root cause of the data breach. This may involve forensic analysis, system patching, and the implementation of enhanced security controls.
- Recovery: Following eradication, the Information Security Department, in collaboration with IT and relevant department heads, will oversee the restoration of affected systems and data. This process will prioritize business continuity and data integrity.
- Notification: The Legal Department, in consultation with executive management and the Information Security Department, will determine the necessity and scope of notifications to affected individuals, regulatory bodies (as mandated by laws like GDPR), and other stakeholders, ensuring compliance with all legal and contractual obligations.
- Post-Incident Review: Following the resolution of a data breach, a comprehensive post-incident review will be conducted by the Information Security Department, involving relevant department heads, to identify lessons learned, improve security controls, and update the Data Breach Response Policy and associated procedures.
4. Responsible / Coordinating Parties:
- Information Security Department (CISO and Staff): Responsible for leading the investigation, containment, eradication, and recovery efforts; maintaining the Data Breach Response Policy and procedures; and coordinating technical aspects of the response.
- Department Heads (All Departments): Responsible for ensuring their staff are aware of this policy and reporting any suspected incidents immediately; providing necessary personnel and resources to support the response efforts within their areas.
- IT Department: Responsible for providing technical support for containment, eradication, and recovery efforts, as directed by the Information Security Department.
- Legal Department: Responsible for advising on legal and regulatory obligations related to data breaches, overseeing notification processes, and managing potential litigation.
- Public Relations Department: Responsible for managing external communications related to data breaches, in coordination with executive management and the Legal Department.
- Executive Management: Responsible for overall oversight of the data breach response and ensuring adequate resources are allocated.
Approval Draft: Preventing / Controlling Shadow IT Policy
1. Issue: The unauthorized acquisition and use of hardware, software, and cloud services (collectively known as “Shadow IT”) by employees can introduce significant security vulnerabilities, compliance risks, data loss, and operational inefficiencies within Red Clay Renovations. These unsanctioned technologies often lack proper security controls, may not integrate with existing IT infrastructure, and can violate licensing agreements.
2. Policy: Red Clay Renovations prohibits the acquisition, installation, or use of any hardware, software, or cloud services for business purposes that have not been explicitly approved and managed by the IT Department. All managers are responsible for ensuring their teams adhere to this policy and understand the associated risks.
3. Required Actions for Implementation:
- Awareness and Education: Department heads are responsible for educating their teams about the risks associated with Shadow IT and the importance of adhering to this policy. This includes highlighting potential security vulnerabilities, data privacy concerns, and the lack of IT support for unsanctioned technologies.
- Centralized Procurement Process: All requests for new hardware, software, and cloud services must be submitted through the established IT procurement process. Managers must ensure their teams follow this process and do not independently acquire or implement IT solutions.
- IT Review and Approval: The IT Department will review all requests for new technologies to ensure they meet security standards, comply with licensing agreements, integrate with existing infrastructure, and align with the company’s overall IT strategy. Approval will be granted based on a comprehensive risk assessment and business need.
- Monitoring and Detection: The IT Department will implement monitoring tools and processes to detect the use of unauthorized hardware, software, and cloud services on the company network and devices.
- Remediation: Upon detection of Shadow IT, the IT Department will work with the relevant department head to understand the usage and assess the associated risks. Unauthorized technologies may be required to be removed or replaced with approved alternatives. In cases of non-compliance, appropriate disciplinary actions may be taken in accordance with company HR policies.
- Regular Review and Updates: The IT Department will regularly review the company’s approved technology catalog and procurement process to ensure it meets the evolving needs of the business and provides secure and efficient solutions. Managers are encouraged to provide feedback on technology needs through established channels.
Sample Answer
Policy Recommendations Briefing Package: Enhancing IT Governance at Red Clay Renovations
Cover Page:
Assignment Title: IT Governance Policy Recommendations for Red Clay Renovations Your Name: [Your Name] Due Date: April 15, 2025
Executive Summary
This briefing package presents three issue-specific policies for inclusion in the Red Clay Renovations Manager’s Deskbook, under the IT Governance category. These policies address critical areas of IT risk management and operational efficiency, requiring collaboration across multiple departments to ensure effective implementation and adherence. The increasing reliance on data, the proliferation of unsanctioned technology, and the expanding use of social media necessitate clear guidelines to protect the company’s assets, reputation, and legal standing