A policy, to have any utility at all, needs to exist in a larger context.
“We need a policy on that.” This is a phrase that seems to act as a universal panacea to too many managers. When a problem is identified, and the blame game has been exhausted, the way to sort things out, they believe, is to create a policy. If you’ve got a policy, then everything will be fine, because everything will be clear, and everyone will obey the policy, and nothing can go wrong.
The problem is that policy, on its own, is worthless.
A policy, to have any utility at all, needs to exist in a larger context, or, to think of it in a different way, to sit in a chain of artefacts. It is its place in this chain that actually gives it meaning. Let me explain.
When that manager said that they wanted a policy, what did that actually mean? That rather depends on how wise the manager is. Hopefully, the reason that the manager identified the need for a policy was because:
- they noticed that something had gone wrong that shouldn’t have done and;
- they wanted to have a way to make sure it didn’t happen again.
The problem with policy on its own is that it doesn’t actually help with either of those points. What use does it have, then?
Let’s look at those pieces separately. When we say that “something had gone wrong that shouldn’t have done“, what we’re saying is that there is some sort of model for what the world should look like, giving us often general advice on our preferred state. Sometimes this is a legal framework, sometimes it’s a regulatory framework, and sometimes it’s a looser governance model. The sort of thing I’d expect to see at this level would be statements like:
- patient data must be secured against theft;
- details of unannounced mergers must not be made available to employees who are not directors of the company;
- only authorised persons may access the military base.
These are high level requirements, and are statements of intent. They don’t tell you what to do in order to make these things happen (or not happen), they just tell you that you have to do them (or not do them). I’m going to call collections of these types of requirements “governance models”.
At the other end of the spectrum, you’ve got the actual processes (in the broader sense of the term) required to make the general intent happen. For the examples above, these might include:
- AES-256 encryption using OpenSSL version 1.1.1 FIPS, with key patient-sym-current for all data on database patients-20162019;
- documents Indigo-1, Indigo-3, Indigo-4 to be collected after meeting and locked in cabinet Socrates by CEO or CFO;
- guards on duty at post Alpha must report any expired passes to the base commander and refuse entry to all those producing them.
These are concrete processes that must be followed, which will hopefully allow the statements of intent that we noted above to be carried out.
Policies and audit
The problem with both the governance statements and the processes identified is that they’re both insufficient. The governance statements don’t tell you how to do what needs to be done, and the processes are context-less, which means that you can’t tell what they relate to, or how they’re helping. It’s also difficult to know what to do if they fail: what happens, for example, if the base commander turns up with an expired pass?
Policies are what sit in the middle. They provide guidance as to how to implement the governance model, and provide context for the processes. They should give you enough detail to cover all eventualities, even if that’s to say “consult the Legal Department when unsure”. What’s more, they should be auditable. If you can’t audit your security measures, then how can you be sure that your governance model is being followed? But governance models, as we’ve already discovered, are at the level of intent – not the sort of thing that can be audited.
Policies, then, should provide enough detail that they can be auditable, but they should also preferably be separated enough from implementation that rules can be written that are applicable in different circumstances. Here are a few policies that we might create to follow the first governance model examples above:
- patient data must be secured against theft;
- Policy 1: all data at rest must be encrypted by a symmetric key of at least 256 bits or equivalent;
- Policy 2: all storage keys must be rotated at least once a month;
- Policy 3: in the event of a suspected key compromise, all keys at the same level in that department must be rotated.
You can argue that these policies are too detailed, or you can argue that they’re not detailed enough: both arguments are fair, and level of detail (or granularity) should depend on the context and the use to which they are being put. However, though I’m sure that all of the example policies I’ve given could be improved, I hope that they are all:
- able to be implemented by one or more well-defined processes;
- understandable by both those who concerned with the governance level and those involved at the process implementation and operations level.
The value of auditing
I’ve written about auditing before (Confessions of an auditor). I think it’s really important. Done well, it should allow you to discover whether:
- your processes are covering all of the eventualities of your policies;
- whether your policies are actually being implemented correctly.
Auditing may also address whether your policies fully meet your governance model. Auditing well is a skill, but in order to help your auditor – whether they are good at it or bad at it – having a clearly defined set of policies is a must. But, as I pointed out at the beginning of this article, policies for policies’ sake are worthless: put them together with governance and processes, however, and they provide technical and business value.
1 – this is sarcasm.
2 – yes, I know. But let’s not be rude if we can avoid it. We want to help managers, because the more clue we deliver to them, the easier our lives will be.
3 – and you never know: one day, even you might be a manager.
4 – which is probably not a US military base, given the spelling of “authorised”.
5 – example only…
6 – this, in my experience, is the correct answer to many questions.