Is the Cloud Migration Mindset Snafu Reoccurring with Untethered AI Adoption?
Organizations once rushed to the cloud in search of transformation, innovation, reduced cost of ownership, and a competitive advantage. In that haste, they overlooked a hard truth: threat actors thrive in environments filled with misconfigurations and weak security practices. Many enterprises quickly embraced cloud capabilities, but they failed to bring cybersecurity along with them. Most organizations never thoroughly answered the foundational question of cloud-era security: Where does our critical data reside? Even now, many enterprises lack a complete inventory of sensitive data locations or data flows. That visibility gap did not disappear; it simply shifted. And now, with the rise of GenAI, that same unknown data is being fed into tools outside organizational control. The result was years of avoidable breaches, exposed buckets, overly permissive identities, and reactive security strategies that continue to ripple across the industry today. We are witnessing the same pattern with Generative AI and LLMs. The rapid introduction of GenAI and large language models has created unprecedented opportunities, rapid innovation, resource optimization, improved productivity, and enhanced decision quality. Yet one issue persists: Where are the guardrails? For most organizations, they are either immature or nonexistent. AI Governance should have been implemented from day one, with oversight committees established early to set boundaries, evaluate risks, and shape responsible adoption. To bridge this gap, organizations should define clear roles, responsibilities, and processes for these committees to ensure continuous oversight and accountability. This proactive approach helps organizations embed governance into their AI strategies from the outset, reducing risks and aligning with best practices. This is not speculation. Recent research shows that employees are adopting Generative AI at extraordinary rates, often without informing IT or leadership. A supporting perspective can be found in this post by Ian Paul of CheckPoint, ‘How CIOs Can Turn AI Visibility into Strategy.’ The implications are significant. Hidden or “shadow” AI usage creates an environment in which innovation occurs organically, but without governance, oversight, or security. Yet that same usage data, when finally observed, can become an invaluable blueprint for formulating an informed AI strategy. Organizations can learn exactly which tools employees find valuable and which workflows are ripe for meaningful AI-driven efficiency gains. But visibility is the prerequisite for strategy. Security leaders need to understand which AI services are being accessed, what types of prompts are being submitted, how much sensitive content is being shared, and where risky behavior is occurring. Implementing monitoring tools such as AI activity dashboards, data flow analysis, and real-time alerting can provide the necessary visibility. These methods enable organizations to identify unauthorized AI usage, assess data exposure, and ensure compliance with security policies, thereby supporting a more informed and secure AI environment. The gap between organizational intent and real-world usage shows why AI Governance must be a core function, giving leaders confidence in responsible AI management. The lesson is clear. Building visibility, governance, and accountability into AI adoption helps organizations feel prepared and secure against repeating past mistakes. Organizations do not need to slow down innovation. They need to ensure that innovation does not outpace cybersecurity’s ability to support it safely.
NIST AI RMF vs ISO/IEC 42001
Bridging AI Governance and Risk Management As artificial intelligence becomes increasingly integral to business operations, regulators and standards bodies are establishing frameworks to promote trustworthy, transparent, and responsible AI. Three of the most influential are the NIST AI Risk Management Framework 100-1 (AI RMF 1.0), with companion resource 600-1 for Generative AI, and the ISO/IEC 42001:2023 Artificial Intelligence Management System Standard. While both aim to foster responsible AI, they differ in scope, structure, and implementation approach. Understanding these similarities and differences helps organizations integrate both frameworks into a unified, defensible AI governance strategy. Purpose and Intent NIST AI RMF (AI 100-1), released by the U.S. National Institute of Standards and Technology in January 2023, provides a voluntary framework to help organizations identify, manage, and mitigate AI risks throughout the AI lifecycle. It focuses on promoting trustworthiness, ensuring AI systems are valid, reliable, safe, secure, fair, and accountable. ISO/IEC 42001:2023, by contrast, is a certifiable management system standard, similar in structure to ISO/IEC 27001 for information security. It defines requirements for establishing, implementing, maintaining, and continually improving an AI Management System (AIMS), embedding AI governance directly into organizational structures and operations. In short: Structural Approach Framework Core Structure Purpose NIST AI RMF 4 Functions: Govern, Map, Measure, Manage Guides organizations through the lifecycle of identifying and mitigating AI risks ISO/IEC 42001 Plan–Do–Check–Act (PDCA) management cycle Establishes an operational, auditable AI governance system aligned with other ISO standards Both utilize risk-based thinking; however, NIST’s approach is functional and descriptive, whereas ISO’s is prescriptive and certifiable. Common Themes and Overlaps Despite structural differences, both frameworks share strong conceptual alignment and reinforce each other in practice. 1. Risk-Based Approach Both emphasize risk assessment, treatment, and monitoring. 2. Lifecycle Integration Both integrate risk management across the AI lifecycle, from data design and model training to deployment and ongoing monitoring.NIST defines AI actors and their roles, while ISO formalizes these within organizational leadership, planning, and accountability structures. 3. Trustworthiness and Ethical Principles Both promote trustworthy AI, emphasizing accountability, transparency, fairness, safety, and privacy.NIST defines seven core characteristics of trustworthy AI. ISO requires policies and controls that embed these values in corporate governance. 4. Continuous Improvement NIST encourages regular reviews and updates to adapt to the evolution of AI.ISO mandates continual improvement of the AI management system as a formal clause requirement. Key Differences Dimension NIST AI RMF ISO/IEC 42001 Nature Voluntary guidance Certifiable management system Focus AI risk identification and mitigation Organizational governance and control over AI Intended Users AI developers, deployers, policymakers Organizations seeking formal certification Outcome Improved AI trustworthiness and transparency Compliance evidence, accountability, and certification readiness Structure 4 Functions (Govern, Map, Measure, Manage) 10 Clauses (Context, Leadership, Planning, Operation, etc.) Documentation Requirement Recommended Mandatory (policies, risk register, impact assessments, controls) External Alignment OECD, ISO 31000, ISO/IEC 22989 ISO 27001, 9001, 27701, 23894 Auditability Informal self-assessment Third-party certification possible Consideration for Generative AI (NIST AI 600-1) In August 2024, NIST introduced NIST AI 600-1, “Secure Development Practices for Generative AI.” This companion document expands on the AI RMF principles to address the unique risks associated with generative AI systems. While NIST AI RMF 100-1 establishes a broad foundation for risk management across all types of AI, NIST AI 600-1 focuses specifically on model development, data security, and content integrity for generative models, such as large language models (LLMs), image generators, and other foundational models. Key aspects of NIST AI 600-1 include: For organizations already aligned with ISO/IEC 42001, incorporating NIST AI 600-1 controls can strengthen compliance by demonstrating due diligence over the secure development and responsible deployment of generative AI, especially in sectors facing increased regulatory scrutiny, such as finance, healthcare, and education. Practical Integration Strategy For organizations already certified under ISO/IEC management systems (such as 27001 or 9001), ISO/IEC 42001 provides a natural extension for AI governance. For organizations earlier in their AI maturity journey, NIST AI RMF serves as an accessible entry point to build foundational risk management processes before scaling toward certification. A combined approach is often most effective: Example of Complementary Alignment NIST AI RMF Function ISO/IEC 42001 Equivalent Common Outcome Govern Clauses 4–5 (Context, Leadership, Policy) Establishes AI governance culture and accountability Map Clauses 6–7 (Planning, Support) Identifies AI risks, opportunities, and required controls Measure Clause 9 (Performance Evaluation) Audits and monitors AI performance and risk metrics Manage Clauses 8 & 10 (Operation, Improvement) Implements and continuously enhances AI management practices AI Governance Through Policy Creation, Dissemination and Enforcement AI governance, achieved through policy creation, dissemination, and enforcement, is essential for ensuring that artificial intelligence is developed, deployed, and managed responsibly. Policies establish clear boundaries and expectations around how AI systems should operate, addressing critical aspects such as data privacy, bias mitigation, model transparency, and accountability. Without formalized governance policies, organizations risk deploying AI in ways that amplify bias, expose sensitive data, or create ethical and regulatory liabilities. By codifying principles of fairness, explainability, and human oversight into enforceable frameworks, enterprises can ensure that their AI systems align with their organizational values, legal requirements, and risk tolerance levels. Enforcement of these policies is equally critical, as governance without implementation is merely aspirational. Active monitoring, auditing, and continuous evaluation of AI systems are necessary to ensure compliance with established policies and to detect deviations early. Enforcement mechanisms, such as automated controls, periodic reviews, and internal AI ethics committees, translate policy intent into operational reality. This not only reduces risks but also builds trust among stakeholders, customers, and regulators. Effective AI governance through strong policy enforcement ultimately strengthens organizational resilience, enabling innovation with confidence while maintaining ethical integrity and regulatory compliance. Conclusion The evolution of AI governance now encompasses three complementary standards: NIST AI RMF (100-1), ISO/IEC 42001:2023, and NIST AI 600-1, each addressing a distinct yet interconnected layer of responsibility. Together, these frameworks form a comprehensive AI governance ecosystem, one that balances innovation with accountability and automation with human oversight. By integrating all three, organizations can demonstrate not only compliance and control, but also confidence and credibility in how
Incident Response Planning Can’t Wait – Your Best Defense is Preparedness
In the modern cyber threat landscape, incidents are not hypothetical; they are inevitable. The question is not if your organization will experience a security incident, but when and how prepared you will be to respond. The IBM Cost of a Data Breach Report 2025 reinforces this reality. While the global average cost of a breach declined for the first time in five years to USD $4.44 million, the U.S. average reached a record USD $10.22 million, driven by higher regulatory penalties and rising detection costs. IBM’s analysis shows that organizations able to identify and contain breaches more quickly, often through tested incident response processes, AI-driven security tools, and automation, experience significantly lower overall breach costs. The value of a formal incident response capability is also reinforced by NIST Special Publication 800-61 Revision 3, which positions incident response as a core element of enterprise risk management and an integral function within the NIST Cybersecurity Framework 2.0. The guidance emphasizes that an effective IR program is not limited to technical containment; it must include governance, clearly defined roles, communications planning, and post-incident learning. According to NIST, a well-implemented IR process minimizes data loss, reduces service downtime, ensures regulatory obligations are met, and strengthens resilience against future attacks. Revision 3 also stresses continuous improvement through testing, exercises, and integration of lessons learned, turning incident response from a reactive function into a proactive capability that measurably reduces both operational and financial impact. Despite this clear evidence, many organizations delay developing an Incident Response Plan (IRP) until they believe their cybersecurity program is “mature enough.” This delay is a costly gamble. Cyber incidents occur at every level of maturity, often exploiting gaps in early-stage programs, and without an IRP, even a minor incident can escalate into a major crisis. Why Waiting Is a Risk Postponing IR planning creates two significant risks: For small and medium-sized businesses (SMBs), the stakes are even higher. Studies show that 60% of small businesses shut down within six months of a cyberattack, and nearly 40% suffer critical data loss. Recovery is often slow, with many requiring 24 hours or more just to restore basic operations, and that delay can significantly magnify both financial damage and reputational harm. The impact doesn’t end with the initial disruption: 2025 data from ElectroIQ found that 29% of SMBs lose customers permanently after a breach, proving that even incidents that appear manageable at first can quickly escalate into business-ending events. The Role of an Incident Response Plan An IRP is far more than a technical checklist; it is an operational playbook for coordinated crisis management. A strong plan enables the organization to respond decisively under pressure, limit damage, and return to normal operations as quickly as possible. An effective Incident Response Plan (IRP): The IRP serves as a catalyst for maturity. Even if your organization lacks sophisticated detection tools, the plan ensures that when an incident occurs, your response is structured, business-focused, and uniform. Key Elements Backed by Industry Research Drawing on insights from IBM, Verizon DBIR, and SANS, the most effective IRPs incorporate the following elements: 1. Preparation Preparation is the foundation of incident response. It involves building the team, defining processes, and ensuring everyone knows their role before an incident happens. 2. Detection and Analysis The ability to detect an incident early and assess its severity determines how quickly you can contain it. 3. Containment, Eradication, and Recovery Once an incident is confirmed, the focus shifts to limiting damage, removing the threat, and restoring operations. 4. Post-Incident Improvement The post-incident phase is often overlooked, yet it is where significant improvements can be made. This is the time when lessons can be learned and applied to prevent future incidents. Why You Can Start Now, Regardless of Maturity You don’t need a mature SOC, advanced tools, or a large budget to benefit from an Incident Response Program. Even a simple plan, clear roles, communication procedures, and prioritized containment steps, reduces chaos and speeds decisions during a crisis. Starting now allows you to improve over time, building maturity through practice and lessons learned, rather than waiting for a “perfect” state that may never come. A Practical Path Forward For organizations without an IRP, the most effective way to begin is with a phased approach: Conclusion Cybersecurity incidents are inevitable, but chaos is optional. A well-developed, regularly tested Incident Response Plan transforms uncertainty into coordinated action, minimizing operational disruption and financial loss. How AccessIT Group Can HelpAccessIT Group partners with organizations at every stage of cybersecurity maturity to design, implement, and refine effective Incident Response Programs. Our team of experienced security professionals combines proven frameworks with practical, business-focused strategies to build response plans that are actionable, scalable, and tailored to your unique risk profile. We provide hands-on guidance for defining roles, establishing communication protocols, and developing incident-specific playbooks, as well as facilitating tabletop exercises to validate readiness. Whether you’re building your first plan or enhancing an existing program, AccessIT Group ensures you have the processes, training, and expertise to respond swiftly, contain threats, and minimize both operational and financial impact.
What to Expect from vCISO Services – Get What You Pay For
Would you invest in a company whose CEO has no financial background, experience making sound business decisions, or a thorough understanding of business risk? Organizations seeking strategic cybersecurity leadership should understand that not all vCISO services are equal. A true vCISO understands business risk, brings executive- level experience, demonstrates proven leadership, and has a track record of building and maturing cybersecurity programs. In contrast, services provided by someone with only technically focused certifications and minimal experience often lack the depth and breadth required for high-impact, governance-driven, risk-based decision-making. As with most professional services, you get what you pay for, and knowing what to expect from a reputable vCISO services provider can help you make the right investment. NOW is the time to begin developing your cybersecurity program from the top down! 1. Strategic Leadership, Not Just Tactical Support A true vCISO does more than help with policies and procedures. They act as a strategic cybersecurity advisor, aligning security initiatives with your business goals. Expect them to: Warning Sign: If a vCISO service only delivers generic templates or “check-the-box” assessments without a long-term strategy, you’re not getting executive-level value. 2. Risk-Based Approach, Not One-Size-Fits-All Cybersecurity isn’t about buying every tool on the market; it’s about understanding your specific risks and applying the proper controls to mitigate them. A seasoned vCISO should: Warning Sign: If the vCISO’s primary output is a long list of tools to purchase, with little focus on governance or process, you may be paying for a “tool broker,” not a trusted advisor. 3. Expertise and Experience That Match Your Needs Not all vCISOs have the same background. Some specialize in cloud security, while others focus on compliance-heavy industries such as healthcare or finance. When evaluating a service, look for: Warning Sign: Beware of low-cost providers that assign junior consultants or general IT personnel under the “vCISO” title. Actual CISO-level experience comes with years of hands-on leadership in cybersecurity strategy. 4. Measurable Impact and Accountability You should expect your vCISO to provide tangible results, not just recommendations. Deliverables may include: Warning Sign: If progress is hard to measure or if you rarely see actionable reports, the value of the service is questionable. 5. The Price vs. Value Equation Like most services, vCISO offerings range from basic policy templates for a few hundred dollars per month to dedicated executive-level leadership at several thousand dollars per month. The difference often comes down to: While a low-cost provider may seem appealing, underinvestment can leave critical gaps that expose your organization to regulatory fines, costly breaches, reputational damage, or customer departure. A skilled vCISO should help you spend smarter on cybersecurity, often saving money in the long run by avoiding costly incidents or unnecessary tool purchases. Final Thoughts A vCISO isn’t just a “cybersecurity consultant”; they are an extension of your leadership team, driving strategic decision-making and measurable improvements in your security posture. When evaluating providers, remember that you truly get what you pay for. A low-cost option may cover the basics, but a seasoned, reputable vCISO brings the experience, strategy, and risk management expertise that can make the difference between a secure, compliant organization and one that’s vulnerable to a subsequent significant breach. AccessIT Group AccessIT Group fulfills this need by delivering true executive-level vCISO services backed by decades of real-world cybersecurity leadership experience, supported by a team of industry experts. Our vCISOs go beyond policy creation and compliance checklists, providing strategic guidance, measurable risk reduction, and executive/board-level expertise tailored to your organization’s unique needs. With proven success in building and maturing security programs across multiple industries and regulatory environments, AccessIT Group ensures you receive the depth and breadth, with risk and governance focus, and business alignment necessary to protect your organization effectively, because when it comes to cybersecurity leadership, you truly get what you pay for. By: Brett Price – vCISO – C|CISO, CISSP, CISM, CISALead Cybersecurity Consultant
Building a Governance-Driven, Holistic Cybersecurity Program
How a CISO or Virtual CISO Can Align Strategy, Frameworks, and Risk Management The latest SANS & Expel survey underscores a critical point: organizations are adopting tools and frameworks, but many still lack the governance, accountability, and risk-based strategy necessary to mature security operations. This is where a Chief Information Security Officer (CISO) or virtual CISO (vCISO) steps in, offering a solution to these gaps by implementing a governance-driven approach grounded in U.S. or internationally recognized frameworks and risk assessment methodologies. 1 | Governance Begins with Leadership Survey respondents cited executive oversight and governance structures as central to SOC maturity. Yet 24% operate without a formal governance program, relying on ad hoc alignment. A CISO or vCISO plays a crucial role in establishing a structured governance model. This model defines roles, aligns cybersecurity to business objectives, and embeds oversight into the organization’s leadership fabric, providing a sense of security and organization. 2 | Integrating Frameworks for Governance and Maturity Framework Adoption & Role Strategic Value NIST CSF 2.0 74% adoption among respondents Risk-based model for continuous improvement CIS Controls v8.1 Widely implemented in practice Prioritized, actionable safeguards for maturing operational defense ISO/IEC 27001:2022 ~30% of respondents using Governance and risk management integration with certifiable compliance A CISO or vCISO utilizes these frameworks in conjunction to establish a comprehensive and measurable governance program, integrating strategy (NIST CSF), implementation (CIS or NIST SP 800-53), and assurance (ISO 27001) into a unified security architecture. 3 | Advancing Risk Assessments with Modern Methodologies The foundation of any governance-driven program is a robust risk assessment process. While 73% of organizations conduct some form of risk assessment, many lack consistency or alignment to a formal methodology. To mature this practice, a CISO or vCISO should guide evaluations using: These approaches enable a unified, cross-domain view of digital and AI risk, providing leadership with a forward-looking view of threats, vulnerabilities, and business impacts. 4 | Operationalizing the SOC with Unified Oversight 48% of organizations now operate hybrid Security Operations Centers (SOCs), and 47% have increased their reliance on managed services. A CISO or vCISO ensures that these disparate SOC elements, internal staff, MSSPs, and tools are aligned under a single governance model. This includes standardized escalation procedures, playbooks, control testing, and reporting structures tied to business objectives. 5 | Translating Metrics into Governance Outcomes While organizations frequently track: The CISO or vCISO elevates this into board-level reporting by introducing: 6 | Closing the Training and Readiness Gap 43% of organizations lack formal training for their IT and security staff, a major barrier to achieving maturity. A CISO or vCISO drives a training strategy aligned with: Additionally, only 61% of organizations conduct regular cyber-readiness exercises, often limited to compliance checklists. These exercises should evolve into executive-led scenarios that test governance, coordination, and risk tolerance thresholds. These scenarios could involve simulated cyberattacks or data breaches, allowing the executive team to test their response plans and assess the organization’s overall readiness. 12-Month Governance Roadmap: Quarterly Tasks Q1: Launch Security Governance Board Q2: Conduct Risk Assessment Q3: Integrate Frameworks Q4: Build Reporting & Response Final Thoughts A governance-driven cybersecurity program, designed and led by a CISO or vCISO, ensures that risk, compliance, operations, and executive decision-making are connected through a common language. As AI and digital transformation accelerate, security programs must evolve to encompass new threat models, regulatory expectations, and business risks. By utilizing or aligning NIST CSF, CIS Controls, ISO 27001, and AI-specific standards, such as NIST AI RMF and ISO 42001, under a single governance structure, the CISO or vCISO delivers not just security but also accountability, resilience, and strategic value. AccessIT Group helps organizations build, align, and optimize governance-driven, holistic cybersecurity programs by leveraging the expertise of our seasoned vCISOs, Lead Consultants, and technical teams. We go beyond technical controls to embed cybersecurity into the organization’s leadership fabric, defining governance structures, aligning strategic frameworks such as NIST CSF 2.0, ISO 27001, and CIS Controls, and implementing risk assessment methodologies, including NIST SP 800-30 and ISO/IEC 27005. Our approach ensures measurable outcomes: from launching formal governance boards and integrating hybrid SOC oversight to developing AI-specific risk programs using NIST AI RMF and ISO 42001. Whether improving metrics, enhancing executive reporting, or driving role-based training, we help organizations evolve cybersecurity from a compliance function into a strategic enabler of trust, resilience, and accountability. By: Brett Price – Lead Cybersecurity Consultant and vCISO – C|CISO, CISSP, CISM, CISA
The CISO’s Dilemma: Too Much to Do, Too Little Time
Do you wish you could clone yourself? The CISO’s job is extremely dynamic and at times overwhelming. Between board meetings, steering committees, executive briefings, and change control boards (CAB), the CISO’s calendar is often consumed by high-stakes discussions. Yet, those meetings represent just a fraction of the responsibilities under the CISO’s purview. Behind the scenes of strategy development lies a demanding list of operational, tactical, and compliance-driven tasks that must be addressed with urgency and precision. Today’s Chief Information Security Officer is more than a technologist. They are a strategist, a crisis manager, a policy architect, a business enabler, and a steward of trust. The modern CISO’s dilemma is not about capability, it’s about capacity. With limited time and expanding responsibilities, CISOs must constantly prioritizing between what’s critical and what’s consequential. 1. Governance Program Development or Restructuring A security program without governance is like a ship without a rudder. Whether creating a new governance framework or restructuring a legacy one, CISOs must define policies, establish accountability, and ensure alignment with enterprise goals. But this foundational work is often overshadowed by more urgent fire drills, despite being essential for long-term success. 2. Compliance and Audit Preparation From NIST and ISO frameworks to HIPAA, PCI DSS, and state privacy laws, internal and mandated compliance is non-negotiable. CISOs must prepare for internal audits, manage third-party assessments, and respond to regulatory inquiries—all while maintaining daily operational integrity. Compliance is a moving target, and keeping up with it demands continuous attention. 3. KPI and KRI Development To communicate value and risk effectively, CISOs need solid Key Performance Indicators (KPI)s and Key Risk Indicators (KRI)s. Developing meaningful metrics requires more than just dashboards—it demands collaboration with business units, clarity in definitions, and consistency in data sources. These indicators translate cyber risk into business language but are often deprioritized due to competing demands. 4. Policy Creation, Review, and Maintenance Cybersecurity policies guide behavior, set expectations, and support enforcement. Yet with constant regulatory updates and evolving business models, these documents require frequent reviews. From acceptable use to AI governance, the policy lifecycle is a continuous responsibility that rarely gets the time it needs. 5. Tactical and Strategic Road mapping A CISO must look both five weeks and five years ahead. Road mapping involves aligning cybersecurity priorities with business objectives, budget planning, and board-level reporting. Tactical roadmaps keep operations efficient; strategic ones future-proof the organization. Balancing both is a delicate and time-intensive task. 6. Incident Response Program Development & Tabletop Exercises Designing and operationalizing an incident response program requires cross-functional coordination and continuous refinement. Tabletop exercises test muscle memory and reveal gaps, but planning and executing these simulations take time and participation from key stakeholders, many of whom are also time-constrained. 7. Risk and Cybersecurity Gap Assessments NIST SP 800-30 or ISO 27005-based risk assessments and cybersecurity gap analyses are essential to understanding exposure and driving prioritization. These assessments require interviews, control reviews, and documentation deep-dives, none of which happen quickly or easily. 8. Data Identification, Classification, and Flow Mapping Data governance is a cornerstone of security and privacy. CISOs are responsible for identifying where sensitive data resides, classifying it appropriately, and mapping its movement across systems and third parties. This effort is foundational to protecting confidentiality and ensuring compliance, but requires ongoing collaboration with business units and IT. Considering a Data Security Posture Management Solution (DSPM) is paramount to the success of this initiative. 9. Business Continuity and Disaster Recovery Planning Disaster recovery and business continuity are not just IT exercises, they’re strategic necessities. The CISO must help architect, test, and refine plans that ensure the business can operate during crises. This includes scenario planning, recovery time objectives (RTOs), and recovery point objectives (RPOs), all of which take time and precision. 10. Third-Party Risk Management As supply chain threats rise, managing vendor risk has become mission critical. CISOs must assess, onboard, monitor, and reassess third parties, ensuring they meet security expectations. This includes contract reviews, questionnaires, and incident response planning, all while under growing scrutiny from regulators and boards. 11. M&A Cybersecurity Due Diligence Mergers and acquisitions introduce significant risk. CISOs play a central role in evaluating the security posture of acquired entities, identifying inherited risks, and advising on integration strategies. These engagements are high-pressure, time-sensitive, and often confidential. 12. Awareness Training & Simulation Testing Programs Human error remains one of the top causes of security breaches. CISOs must ensure awareness training is not only compliant but engaging and measurable. Simulated phishing campaigns, targeted micro-trainings, and behavioral analytics all fall under this umbrella, but require time, tools, and creativity. 13. Privacy Act Readiness Privacy regulations are no longer theoretical. From California’s CPRA to Virginia, Colorado, and a growing list of U.S. states, data privacy laws are becoming a reality for every organization. The lack of a federal mandate only adds complexity. CISOs must prepare systems and policies for consent management, data subject access rights, breach notification, and data minimization, before enforcement becomes a reality. Conclusion: A Call for Support, Not Just Strategy The modern CISO operates at the intersection of risk, regulation, and resilience. But the breadth of responsibility often exceeds the capacity of even the most experienced leader. The solution is not simply to work harder, but to build stronger teams, secure executive sponsorship, and leverage expert partners where needed. That’s where AccessIT Group’s seasoned and certified virtual CISOs (vCISOs) provide immediate value. Our vCISOs bring deep experience, cross-industry insight, and trusted advisory capabilities to support your organization’s cybersecurity leadership, whether you need strategic governance, compliance oversight, incident readiness, or support for critical initiatives like M&A due diligence, risk assessments, or privacy program development. CISOs need more than just strategy, they need support. With AccessIT Group’s CISO Assist services, organizations can scale their cybersecurity leadership, reduce risk, and move from reactive firefighting to proactive resilience, securing not just today’s operations, but tomorrow’s growth. By: Brett Price – Lead Cybersecurity Consultant and vCISO – C|CISO, CISSP, CISM, CISA
Why KPIs Should Matter to a CISO: Measuring and Improving Cybersecurity
As a Chief Information Security Officer (CISO), your role is not just about implementing, maintaining, monitoring, and continuously improving your cybersecurity program. It’s also about proving its effectiveness and justifying investments. With cyberthreats evolving daily, security leaders must establish measurable, data-driven approaches. Key Performance Indicators (KPIs) play a crucial role in this, as they provide a clear roadmap for your cybersecurity program and empower you to make informed decisions and confidently justify your investments. Why KPIs Matter for a CISO By providing a clear roadmap for your cybersecurity program, KPIs empower you, as a CISO, to make informed decisions and confidently justify your investments. Effective KPIs allow you to: Quantify Security Performance: Show stakeholders how security initiatives reduce risk, minimize the potential financial impact on the organization and increase productivity in a secure and cost-effective manner. Justify Budget Requests: Provide data-backed justifications for security solutions and personnel investments. Enhance Decision-Making: KPIs are not just numbers on a page. They are tools that can be used to identify and reduce risk, assess incident response times, manage compliance, and refine cybersecurity strategies. By providing a clear roadmap for your cybersecurity program, KPIs empower you to make informed decisions and confidently justify your investments. Align with Business Goals: KPIs are not just about measuring cybersecurity performance. They also play a crucial role in ensuring that security initiatives support organizational objectives by streamlining processes and improving functionality. This alignment with business goals is key to demonstrating the value of your cybersecurity program to the wider organization. Essential KPIs for a CISO To drive meaningful cybersecurity investments and continuous improvements, CISOs should track the following KPIs: 1. Mean Time to Detect (MTTD) & Mean Time to Resolve (MTTR) Why it matters: The speed at which your team detects and responds to incidents directly influences the damage caused by cyber threats. Reducing the “blast radius” is key to ensuring minimal impact on the organization. How to measure: Track the time from the first indication of an incident to detection (MTTD) and from detection to resolution (MTTR). Incident response should include the following: identification and analysis, containment, eradication, recovery (resolution), and lessons learned. 2. Phishing Susceptibility Rate Why it matters: Phishing remains a primary attack vector, and understanding how often employees fall for phishing attempts highlights the effectiveness of training. How to measure: Monitor the percentage of employees who click on simulated phishing emails, open links, or enter credentials (phish-prone) versus those who report them. 3. Patch Management Compliance Why it matters: Unpatched vulnerabilities are a leading cause of breaches. Ensuring timely patching reduces exposure. It is critical to prioritize based on vulnerabilities that are critical, high, exploitable, have exploits available, and are currently being exploited in the wild, then work from there. How to measure: Track the percentage of critical, high, and medium patches applied within the required timeframe. Showing a percentage decrease for each severity level per month/quarter shows progress in the right direction. 4. Number of Security Incidents Why it matters: A high number of security incidents may indicate gaps in defense mechanisms. Example: A link that was clicked enabling an adversary to drop information-stealing malware or a keylogger onto an endpoint. How to measure: Categorize incidents by severity and track trends over time. Add a distinction between contained and eradicated incidents and incidents that led to a breach of confidentiality, integrity, and availability. 5. Security Awareness Training Completion Rates Why it matters: Human error is a major security risk. Ensuring employees complete training programs helps mitigate threats. How to measure: Track participation rates and post-training assessments. 6. Third-Party Risk Assessment Scores Why it matters: Vendor security weaknesses can lead to data breaches. Measuring third-party cybersecurity risk helps mitigate supply chain threats. How to measure: Use standardized security questionnaires and risk assessments for vendors. Review penetration testing results, SOC 2 or ISO 27001/27005 reports. 7. Compliance Audit Pass Rate Why it matters: Regulatory fines and reputational damage can result from non-compliance. How to measure: Track the percentage of passed security audits versus failed ones. Making KPIs Actionable Remember, KPIs are not just numbers on a page. They are tools for driving continuous improvement in your cybersecurity program. As a CISO, you can make the most of them by: Align KPIs with Business Risk: Focus on metrics directly impacting business operations. Organizational leadership is concerned with resiliency and profitability, so tailor the KPIs to what matters most to the report’s recipients. Automate Data Collection – Use security tools and SIEM systems to automate reporting. If you don’t have a tool that provides output, including all metrics, consider creating a spreadsheet with a dynamic dashboard. Regularly Review and Adapt – Cyber threats evolve, and your KPIs should, too. KPIs are not static. I update my dashboard monthly in preparation for the quarterly board of directors presentation. Report to Leadership in Business Terms – Translate security metrics into financial and operational impacts. It is critical to present the KPIs adapted to the audience who will be receiving them. You don’t want to talk about CVEs with a CEO or board member. Craft the message in a way that reflects profit and loss. Final Thoughts In today’s rapidly evolving threat landscape, the effectiveness of CISOs is judged not only by their ability to prevent attacks, maintain compliance, or reduce organizational risk but also by how well they measure, communicate, and improve security performance. KPIs, by their proactive nature, provide the foundation for this, ensuring that cybersecurity isn’t just a reactive function but a strategic pillar of business resilience. By leveraging the right KPIs, CISOs cannot only build stronger defenses but also secure executive buy-in and drive long-term security success. AccessIT Group employs vCISOs and other thought leaders with decades of experience leading strategic cybersecurity initiatives in all industry verticals. If you struggle with producing effective KPIs or delivering the proper message to stakeholders, reach out for a free one-hour consultation or engage with our team for a longer-term partnership to ensure your success in identifying, documenting, and
Quantum Computing, Artificial Intelligence, and the Cybersecurity Threat Landscape
Quantum Computing might seem like it’s from another galaxy. Still, quantum physicists, data scientists, computer scientists, and engineers are busy figuring out how to keep it cool (literally) and battling the woes of qubit decoherence. Think about how quickly AI crept up on us! We went from vendors boasting “AI,” which was really just machine learning and neural networks, to witnessing near-miraculous feats of intelligence as we see today. The convergence of quantum computing and artificial intelligence (AI) is set to transform not only the way we compute and process data but also cybersecurity. As quantum computing accelerates AI development, it brings with it tremendous opportunities and intricate challenges in protecting our digital infrastructure. In this post, I delve into how quantum computing will drive AI growth and the exciting cybersecurity implications of this dynamic duo. Understanding the Foundations What Is Quantum Computing? Quantum computing harnesses the quirky principles of quantum mechanics—superposition, entanglement, and quantum tunneling to solve problems at speeds that classical computers can only dream of. Instead of bits (0s and 1s), quantum computers use qubits that can exist simultaneously in multiple states. This allows them to perform complex computations, such as those used in AI, at astonishing speeds. And yes, I just said “astonishing speeds” with a shoulder shrug. It’s incredibly fast at crunching complex mathematics. Consider cryptography: where it might take classical computers 100 years to crack a key, quantum systems could do it in about 10 minutes. That’s why NIST is busy standardizing post-quantum cryptographic algorithms. IBM explains quantum computing in a little more detail in its article, ‘What is quantum computing?’ The State of Artificial Intelligence AI has evolved at a breakneck pace, with astonishing progress in natural language processing, image recognition, and complex decision-making systems. The speed of this evolution is truly remarkable, especially when handling massive datasets and intricate problems. Quantum computing promises to shatter these limitations by supercharging computational speed and efficiency. I can’t help but chuckle when I think of aliens traveling from faraway galaxies to Earth on Qubits. A Brief Overview of Cybersecurity Cybersecurity protects systems, networks, and data from digital attacks and unauthorized access. As cyber threats grow more sophisticated, traditional defenses are constantly under siege. AI has already begun to reshape cybersecurity through improved threat detection, quicker response times, and enhanced risk management. As quantum computing and AI advance together, their combined impact will redefine the cybersecurity landscape. Remember that notorious 2020 deepfake scam? When an AI-generated CEO’s voice tricked an employee into wiring funds, a Japanese company lost 37 million yen (about $340,000 U.S.). Imagine the possibilities when video deepfakes on Zoom or Teams—or even hologram deepfakes become the norm! Yes, hologram deepfakes might be a bit futuristic, but they’re on the horizon. Accelerating AI Growth with Quantum Computing Enhanced Computational Speed and Efficiency Quantum computing could drastically reduce the time required to train AI models. In cybersecurity, this means that threat detection algorithms can be optimized on larger, more complex datasets in record time, paving the way for near-real-time analysis and response. This potential is truly exciting and should inspire optimism about the future of cybersecurity. Faster Training and Optimization: Quantum algorithms, such as Grover’s search algorithm or the quantum approximate optimization algorithm (QAOA), can speed up neural network training, enabling quicker deployment of robust security systems. Efficient Data Processing: Thanks to the inherent parallelism in quantum systems, massive volumes of data can be processed rapidly, a critical factor in identifying and neutralizing cyber threats on the fly. Advancements in Quantum Machine Learning Quantum machine learning (QML) combines quantum computing with AI to create algorithms that can outperform classical ones in specific tasks. In cybersecurity, QML could detect subtle anomalies and patterns that hint at potential threats. Quantum-Enhanced Threat Detection: With quantum computing power, AI systems can analyze complex data sets to uncover sophisticated cyber threats that might otherwise go unnoticed. Hybrid Security Models: In the near term, hybrid models that blend classical and quantum computing could bolster cybersecurity defenses, leveraging the strengths of both worlds for more robust and adaptive solutions. Cybersecurity in the Quantum Age As quantum computing and AI reshape industries, they also introduce new cybersecurity challenges and opportunities: The Double-Edged Sword of Quantum Computing Quantum Threats: One of the biggest concerns is that quantum computers could break current cryptographic protocols like RSA and ECC, which hinge on mathematical problems that quantum systems might solve easily. For more information, check out the PDF on ResearchGate.net. Quantum-Resistant Cryptography: Researchers are also developing post-quantum cryptographic algorithms designed to withstand quantum attacks. These algorithms will ensure that our data remains secure even as quantum computing evolves. Beyond breaking encryption and creating eerily realistic deepfakes, imagine other scenarios for nation-states and financially backed threat actors: AI-Driven Malware: Picture malware that learns, adapts, and alters its behavior in real-time to bypass conventional defenses—rendering traditional signature-based detection methods nearly obsolete. Self-Optimizing Attacks: By leveraging quantum computing’s rapid optimization capabilities, attackers could design malware that constantly refines its tactics to exploit newly discovered vulnerabilities or slip past evolving security measures. Quantum-Enhanced Botnets: If quantum computing becomes accessible to cybercriminals, botnets might be controlled using quantum algorithms, which would increase their efficiency and make them even harder to trace and dismantle. Are you feeling a bit unsettled yet? We must up our cybersecurity game and stay ahead of these evolving threats rather than perpetually playing whack-a-mole. Optimism aside, action is imperative. CrowdStrike has more on AI-powered cyberattacks. AI-Driven Cyber Defense Here’s where I get excited about the future. The fusion of quantum-enhanced AI and cybersecurity can lead to far more sophisticated and adaptive defense systems: Real-Time Threat Analysis: Quantum-enhanced AI can monitor network traffic and system logs in real-time, detecting breaches and anomalies faster than ever before. Predictive Security: AI analyzes vast amounts of data to forecast vulnerabilities and cyber-attack patterns, allowing organizations to shore up defenses proactively. Automated Response Systems: Enhanced computational capabilities mean AI-driven systems can react to threats instantly, reducing the window of vulnerability and mitigating
How did we weather the cyber storm in 2024?
How did we weather the cyber storm in 2024? If you ask National Public Data (NPD), Stoli Group’s U.S. Operations, Gotham Restaurant chain, and potentially others, they may tell you it was the worst year for the business since their inception. This is because they all filed Chapter 11 bankruptcy following a data breach. If you read about these companies, you’ll find they were all suffering financial difficulties prior to the breach, but the breach certainly exacerbated the decision to file. Financial struggles due to the cost of doing business, forensics investigators, fines, lawsuits, and penalties would cause most businesses to struggle to return to business as usual, if not close shop permanently. After researching data breaches, trends, and root causes, I decided to write a post about how we can better secure our organization in 2025, inspired by some of the most prominent data breaches of 2024. Let’s start with the U.S. Treasury. I’m not referring to the downstream breach resulting from the SolarWinds catastrophe in 2020. I’m referring to the breach first detected on December 8th and disclosed in late December of 2024. What can we learn from these breaches? U.S. Department of the Treasury, Reported December 30, 2024 Again, the Treasury fell victim due to its relationship with a third party. As we see more and more third-party breaches leading to downstream compromise, more stringent cybersecurity assessments, closer monitoring, and due diligence language in contracts should be seriously considered. The threat actors gained access by using a stolen API key, which allowed them access to their remote support SaaS platform. Least privilege, API key encryption, and key rotation may have prevented this breach. Unfortunately, the attack was allegedly linked to a well-funded, very sophisticated group referred to as Salt Typhoon, a nation-state threat actor group sponsored by the Chinese government, “allegedly”—I have to say that. Yes, this is the same group linked to recent major telecom company data breaches (Verizon, AT&T, T-Mobile) and seven others. National Public Data (NPD), Reported August 16, 2024 Have you had a background check performed on you? If so, your data may have been stolen during this massive breach and data exfiltration attack affecting Canada, the United States, and the United Kingdom. A suspected 2.9 billion records containing highly sensitive personal data were compromised. This April 2024 attack was executed by the hacker group USDoD, which openly confirmed its identity. Don’t worry—the head honcho was arrested in Brazil as part of Brazil’s Federal Police initiative, “Operation Data Breach.” While the technical details have yet to be released, based on the actors’ normal TTPs, it is suspected that the breach was a result of unpatched vulnerabilities, phishing/smishing, or weak access controls. Regardless, prioritizing patch management is critical. Currently, exploitable vulnerabilities and actively exploited vulnerabilities should be a priority for patch management. Snowflake Inc., June 2024 This cloud-based data warehousing company suffered a breach, which began in April 2024, affecting over 100 customers and leading to unauthorized access and exfiltration of huge amounts of sensitive data. Scattered Spider appears to have targeted Snowflake, obtaining login credentials through infostealer malware. Scattered Spider is well known for being English-speaking and very competent at the art of social engineering via phishing and vishing and is credited with the breaches of Western Digital, MGM Resorts, and Caesars Entertainment, to name a few. Unfortunately, with this attack, the threat actors were able to steal credentials and gain access. Well-trained employees and help desk personnel, along with frequent password rotation or password less solutions, encryption, and strong multi-factor authentication practices, may have dissuaded the attacker from spinning its web and forced it to move elsewhere. Ticketmaster/Live Nation, April – May 2024, Publicly Disclosed May 15, 2024 Huh, I’m beginning to see a pattern here. Guess who the third party was involved with this downstream breach? You got it—Snowflake. You may be thinking that since Scattered Spider was responsible for the breach of Snowflake, they were also responsible for the Ticketmaster breach. Wrong. Shinyhunters stole Ticketmaster data from Snowflake. 1.3GB of data was offered in a one-time sale for $500,000, according to a Dark Web post. Oh, the complex web we weave! Shinyhunters obtained credentials by way of information-stealing malware and a remote access trojan against a fourth party, EPAM Systems. They accessed unencrypted credentials used by an employee to access EPAM Systems’ customers, which were then used to infiltrate the Snowflake account owned by Ticketmaster. Here again, even if I give you my username and password, you won’t be able to log in without my MFA token—preferably not an SMS message. SIM swapping is a common tactic used by Scattered Spider, LAPSUS$ Group, and REvil, to name a few. AT&T, March, April, and July of 2024 Wow, talk about having a target on your back. AT&T suffered multiple breaches in 2024, most likely the work of Scattered Spider and Salt Typhoon. I won’t discuss all the incidents because that’s not the intent of this post. I’m beginning to sound like a broken record. Yet again, it’s all about training and MFA. Yes, this was a downstream attack fueled by the Snowflake breach. Change Healthcare, February 21, 2024 Ransomware attack… I shudder just thinking about one of the companies I vCISO for getting attacked by ALPHV/BlackCat, which is exactly what happened to Change Healthcare in February of this year (or last year, if you’re reading this tomorrow). It turns out this was the largest known data breach of protected health information in history. Over 100 million personal health records were stolen in the double extortion attack, where the attackers exfiltrated the data prior to encrypting it and then demanded a ransom. A $22 million ransom was demanded, and some was paid, according to word on the street. The HIPAA Journal reports that in the nine months ending on September 30, 2024, Change’s parent firm, United Health Group, had incurred $1.521 billion in direct breach response costs and $2.457 billion in total cyberattack impacts (KrebsOnSecurity). This was another case of the
Understanding the Cyber Risk Equation: A Guide for CISOs
Understanding the cyber risk equation, where Risk = (Threat x Vulnerabilities) x Impact, is crucial. This equation encapsulates the culmination of threats, vulnerabilities, likelihood, and impact. It’s a powerful process that can help you grasp how threat sources exploit vulnerabilities to gain access to an organization, whether for financial gain or to inflict harm. Mastering this understanding puts you in control, enabling you to implement proactive measures that mitigate negative impacts on the organization. There are many other forms of risk, such as environmental risks like fire, hurricanes, avalanches, floods, and tornados. There are also forms of business risk, such as credit, reputational, financial, and market risks, or the risk of losing customers due to any of these.You may be thinking at this point, yeah, yeah, I’ve read about all of that studying for my multitude of exams. Well, in simplest terms, the question is, what is the probability that something or someone will exploit a vulnerability through exploit code, a weakness in infrastructure, site location, application code, policy, or business action, and cause harm to the organization? Although, in today’s environment, the CISO must consider all of these things, we’ll focus on cybersecurity risk. Threat Sources 1. Individuals This could be an outsider like a script kiddy, or an insider like someone who just got let go and wants to inflict harm on the organization by stealing intellectual property and releasing it to the public. 2. Groups Organized crime syndicates are more frequently getting into the cybercrime game, ad-hoc groups meeting on Telegram or Discord. 3. Organizations This could be a competitor looking to steal your secret sauce. A supplier with weak cybersecurity practices leading to a 3rd party breach, or a partner that gets breached and a down stream attack occurs. 4. Nation States State funded organizations focused on espionage, Politically motivated or intellectual property theft. ChinaAPT41 (Winnti Group), APT10 (Stone Panda). RussiaAPT28 (Fancy Bear), APT29 (Cozy Bear), Sandworm team. North KoreaLazarus Group, APT37 (Reaper), Kimsuky. IranAPT33 (Elfin), APT34 (OilRig), or Muddy Water. 5. Accidental A user permanently deleting important data or database records, a processing error returns incorrect values, or a backup gets corrupted. 6. Environmental Temperature, humidity, or power supply failure can all destroy critical systems. 7. Natural or Man-Made Disasters Fire, Flood, Tornado, Hurricane, Land Slide, Volcano. Vulnerabilities With the multitude of potential vulnerabilities that can exist in the average organization, the need for prioritization becomes paramount. No software, hardware, mobile device, or operating system is immune. While Microsoft, Adobe, Oracle, Cisco, and Apache were the primary vendors that suffered the most exposure due to vulnerabilities, we now have to include all versions of Linux and Apple in our vulnerability management program. The challenge lies in prioritizing these vulnerabilities, requiring focus and efficiency. When prioritizing vulnerabilities, it’s crucial to consider environmental conditions. You may have a critical vulnerability with an exploit on a box isolated from the rest of the network with no critical data. Should that be a priority? No. This strategic and forward-thinking approach to vulnerability management can help you allocate resources effectively. Key Considerations for Prioritization: If you’re a new CISO or vCISO, consider mapping your attack surface early on and remediating it based on criticality, considering the vulnerability categories above. One consideration wasn’t discussed above, and many times, it’s not included in the equation regarding risk. Still, it is very prevalent when it comes to exposure and should be added to your risk register for mitigation, acceptance, transference, or ignore. Predisposing Conditions: Likelihood When we calculate risk, we must consider and calculate the likelihood of an attack. This may be a daunting task for most, but the key is to watch your adversary’s activity through threat intelligence feeds and cybersecurity news articles. I like to read the Verizon Data Breach Investigation Report (DBIR) to understand the threat landscape. It provides insights into patterns of target industries and the threat actor behaviors or Tactics, Techniques, and Procedures (TTP) used to infiltrate the target. Another great resource is the IBM-sponsored Ponemon Institute’s Cost of a Data Breach, which provides quantitative insights into the financial consequences resulting from breaches that occurred the prior year. Impact The impact on an organization following a breach can vary and be far-reaching, often lasting for years. Let’s identify a few, beginning with fines related to non-compliance. If you’re bound by GDPR, the fines that can be imposed are up to 4% of your annual revenue. PCI-DSS can impose monthly fines between $5,000 and $10,000 per month. The Department of Health and Human Services may impose fines between $25,000 and a maximum of $100,000 per year if the determination was made for willful neglect. There may be other fines incurred by the SEC or other governing bodies. The organization may be subject to legal fees or civil suits because of leaking personally identifiable information (PII). Calling in a forensics team to investigate, identify, eradicate the threat, and help recover from the breach can be quite costly. For small businesses, the costs can range from $8,000 to $30,000, while larger organizations might incur costs between $10,000 and $100,000 or more. Most organizations that are impacted by a data breach resulting in the exfiltration of PII are encouraged to provide credit monitoring services for a period of time, usually one year. Basic credit monitoring services typically range from $10 to $30 per month per individual, so if you consider a breach affecting 24,000 individuals, the cost of providing credit monitoring services could amount to $240,000. Some of the long-term effects may be loss of market share or customers transitioning to a competitor and becoming loyal customers. Losing intellectual property or trade secrets to a competitor or a foreign country will also negatively impact the bottom line. Conclusion In the 2024 Cost of a Data Breach report, the average data breach cost was $4.88 million, up 10% from 2023. No matter how you calculate risk, your job as a CISO is to ensure that the business remains operational and productive, but