Policies are one of the unavoidable assets that you will need during your infosec journey.
We sometimes see policies as long tedious documents that use far too many words to say don't be a dick. When done properly, our policies can be relatable, audienced, and therefore effective. This post is going to tell you about my experiences.
At first, you'll probably think you need 39 amazing policies, all with the same lovely first seven pages of corporate crap (title page, table of contents, copyright statement, audience, version control, definitions etc). You don't. I made this mistake, and it was style over substance.
For a start, no one will read them all and fully understand them. Not even your in-house lawyer (if you have one of those).
Secondly, not all policies need apply to everyone, and they shouldn't.
Thirdly, you'll think, at first you need everything in the policy, because the auditor's asked for these in advance, and they will give a first impression. My experience is that a good auditor much prefers a shorter practical one.
Too short?
Let's take a look at an example that is both tongue-in-cheek, and to the point.
This one's from Ryan McGeehan. It's apparently been in my pinboard since August 2022.
What you'll see is great — if you're an engineer. I think it's too long for most people.
There's also a few things that I would expect will be taken care of by Corporate IT (or however you call it — things like device setup)
That's it, though, something that probably fits on 4 pages of reasonable sized type-face. All in all.
If you're a startup, or starting — go ahead, be inspired by it.
Epistemology of policies
or, what's the thinking about policies.
I'm a convert to a tiered system of policies and associated documents.
The policy. Your highest level commitment to doing something (e.g. a password policy shall exist, follow best practice, be reviewed by the board each year)
The framework. Not everything will need a framework, but some specialized areas typically do. An example is a Risk Management Framework that sets out the methodology, matrices, risk universe, risk taxonomies, thresholds for escalation etc. You might also have a Vendor Management Framework, or a AI Framework.
Standards These can be deeply technical (e.g. your encryption standard) or more general — e.g. a password standard might set out the rules such as:
people involved in procuring new systems must ensure support SCIM.
where possible, five random words generated by your password manager
the maximum length permitted by third-parties.
reflects best practices, e.g.
unlearn about password rotation (you must change your passsword every N days).
One of my favourite updates to v4 of PCI-DSS was abolition of forced password changes)
unlearn about three of upper, lower, number, special
learn that '3' is easy for the computer to understand is an 'e'
4. Guidelines These are more likely to be documents (including wiki pages) that are updated more frequently and which must be followed. You'll probably want a good password guideline that:
mandates the use of a named (e.g. 1Password) as the authorized password manager.
says to use SSO where-ever possible
and passkeys over passwords
Reviewers
Where possible, it's very sensible to have someone with appropriate competence to review any policy changes. This is especially useful where the policy is highly technical, specialized, or concerning risk or legal aspects.
Get that feedback, incorporate it (if it makes sense), and then, when it comes to submitting for approval, use that to say it's been peer-reviewed.
I'm in two minds about if this should be documented more than your committee papers — I think it depends on your stylistic approach and the tool you use — it could be:
a single line (Reviewed by: XXX, Job Title, YYYY-MM-DD)
a series of preserved comments
a 'final' comment, or
maybe as comments in a pull-request
a string of emails
a 'tracked changes' document
The workflow that works best for you will probably be more helpful — but try not to make it too technical so others can help you.
Approvals
Concerning approvals, this model has worked for me:
It gives agility, allowing for temporary changes to be made subject to proper oversight and also recognizes that some areas can be delegated (without abdicating responsibility). Delegation is perfectly acceptable and shows proportionality and functional governance throughout the organization.
🧢 If you want to be overly cautious you can use the risk assessment process to document this has been considered, and presumably, accepted as a risk that doesn't need treatment, just monitoring.
Modern ways of working
Most of the standards require the policy to be written and communicable. I'm very much an advocate of trying to make these documents as lively as possible, and that includes
cutting the crap
using images
using gifs/videos
hyperlinking (although you might want to use archive.org to ensure the content stays valid).
🧢 My tool of choice is a wiki.
I've used Confluence, MediaWiki, and GitHub wikis for this task (and quickly looked at Notion).
🧢 Given a choice, I would use GitHub, and publish it as a site (with a CNAME). However, you will probably want to use what you've got already. If you're less nerdy, then go with something easier.
I wouldn't wish Atlassian on anyone else, although it does have an advantage that serveral of The Tools[^1] support import from it (although they look really ugly because they come without any CSS and it's not true markdown)
Most wiki platforms have:
permissions systems to restrict unintended/unauthorized editing
built-in version history and github style diffs (additions in green, removals in red)
a way to show approval (although you may need to use Semantic Versioning, depending on which wiki software you use)
support for a simple hostname like policies.example.xyz, so people can find it without trawling slack/email.
export to your trust center / auditors as PDF/Word/Markdown
hosted versions, so you don't need to maintain the tool.
Which policies should I have?
There's a lot of answers to this, and the short answer is, it all depends on why you're doing security.
If it's for business transformation / pro-ing the fuck up (as I like to call it), you'll want ones that help you do what you want to, more securely.
If it's for certification, you'll probably find blogs telling you what's needed -- these may be out of date, opinions masquerading as fact, correct, or some mixture of all of these. I go to the source.
If you've decided to use a helpful tool, the warning I give is that they may not be accurate or only focussed on a tech aspect of compliance. They are not a magic bullet.
ChatGPT can be quite reliable to answer a question like:
"Which policies do I need to have to comply with modern industry best practices, the latest UK NCSC Cyber Assessment Framework, ISO 27001:2022, PCI DSS 4.0.1, NIST CSF 2.0, NIST SP 800 series, the EU's DORA, the FCA's Handbook"
Grouping together (as you see from ChatGPT) can be helpful, it sometimes isn't.
I generally lump similar things together, but prefer to keep things separate; it makes linking to things easier, has been my feeling.
Keeping separate also makes it easier if you're dealing with multiple assurance/audit regimes: you don't need to explain "this part doesn't apply to you".
Less is more, in the game of audit.
In the table below, I've taken the grouped list, and added a column of the things I would move out (as strikethrough isn’t supported on datawrapper, and substack doesn’t deign to support tables)
Split
These are the policies I'd split to their own (each line being a new policy) — if applicable to you (not everyone is going to be from regulated industries after all).
For most of these, the policies should be fairly straightforward:
there is a policy
there's not a policy because this doesn't apply or is out of scope
The policy may wish to assign responsibility to an officer or committee to own the policy and maintain it (usually at least annually) and to derive metrics to measure if the policy is effective.
If you need help writing the policy, a lot of universities seem to have their policies on their websites, but these can be long, verbose, seventeen levels of governance. I tend to use ChatGPT to help suggest the headings, and then tailor the text to the company, rather than editing something suggested (although there are a few areas where you might want an example policy in full.
🔧 Engineer your prompt so you don't get [Company] to search and replace
If it's not written down, it doesn't exist.
If it's not measured, you can't say it's working.
That's my intro to the policies -- as I expected, it's longer than the length I suggest most policies should be… but hopefully its helpful, and this helps you get started.
FN1: In this instance The Tools mean thinks like Drata, Vanta etc that are sold to help you make your compliance journey easier.
I see the pros and cons of these; they're useful for helping on the technical controls and supposedly continual monitoring, but less so on other controls, and usually are restricted to a handful of tools for their observability not multiple concurrent in the same suite, so give false sense of confidence.
In my experience, some of the integrations can break, and support can be quite rubbish and in different timezones.
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