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Prior to assessing technical vulnerabilities or levels of security awareness, an information security manager needs to gain an understanding of the current business strategy and direction. A business impact analysis should be performed prior to developing a business continuity plan, but this would not be an appropriate first step in developing an information security strategy because it focuses on availability.

Protection of identifiable personal data is the major focus of recent privacy regulations such as the Health Insurance Portability and Accountability Act (HIPAA). Data mining is an accepted tool for ad hoc reporting; it could pose a threat to privacy only if it violates regulator)' provisions. Identity theft is a potential consequence of privacy violations but not the main focus of many regulations. Human rights addresses privacy issues but is not the main focus of regulations.

Investments in security technologies should be based on a value analysis and a sound business case. Demonstrated value takes precedence over the current business climate because it is ever changing. Basing decisions on audit recommendations would be reactive in nature and might not address the key business needs comprehensively. Vulnerability assessments are useful, but they do not determine whether the cost is justified.

Retention of business records is generally driven by legal and regulatory requirements. Business strategy and direction would not normally apply nor would they override legal and regulatory requirements. Storage capacity and longevity are important but secondary issues. Business case and value analysis would be secondary to complying with legal and regulatory requirements.

Updated security policies are required to align management objectives with security procedures; management objectives translate into policy; policy translates into procedures. Security procedures will necessitate specialized teams such as the computer incident response and management group as well as specialized tools such as the security mechanisms that comprise the security architecture. Security awareness will promote the policies, procedures and appropriate use of the security mechanisms.

Privacy policies must contain notifications and opt-out provisions: they are a high-level management statement of direction. They do not necessarily address warranties, liabilities or geographic coverage, which are more specific.

The cost of implementing security controls should not exceed the worth of the asset. Annualized loss expectancy represents the losses drat are expected to happen during a single calendar year. A security mechanism may cost more than this amount (or the cost of a single incident) and still be considered cost effective. Opportunity costs relate to revenue lost by forgoing the acquisition of an item or the making of a business decision.

Conflicts of this type should be based on a risk analysis of the costs and benefits of allowing or disallowing an exception to the standard. It is highly improbable that a business objective could be changed to accommodate a security standard, while risk acceptance* is a process that derives from the risk analysis.

Information security exists to help the organization meet its objectives. The information security manager should identify information security needs based on organizational needs. Organizational or business risk should always take precedence. Involving each organizational unit in information security and establishing metrics to measure success will be viewed favorably by senior management after the overall organizational risk is identified.

Since management is ultimately responsible for information security, it should approve information security policy statements; the information security manager should not have final approval. Evaluation of third parties requesting access, assessment of disaster recovery plans and monitoring of compliance with physical security controls are acceptable practices and do not present any conflicts of interest.