Security risk management process
Introduction
This document explains some of the key concepts in information security risk management, as well as explaining how to carry out the actions required by Sourcegraph’s Information Security Risk Management Policy. Knowledge of the policy, including details of the required actions and definitions of key terms, is assumed within this document. In other words, please read the policy if you haven’t already!
Risk register
Sourcegraph’s security team maintains an information security risk register. This risk register tracks high-level issues which could affect the confidentiality, integrity, or availability of the data Sourcegraph manages. As it is high-level, the risk register does not contain specific technical vulnerabilities. Instead, it tracks security concerns which require medium- to long-term effort to rectify.
The risk register is the source of truth for Sourcegraph’s information security risks. To edit the Risk Register, you must be a member of the Security team; if you do not have access and believe you might require it, email security@sourcegraph.com.
Information Security Risk Committee
The Information Security Risk Committee exists to discuss the management of information security risks across the organization. It is responsible for the regular review of Sourcegraph’s information security risk profile as required by the Information Security Risk Policy.
Sourcegraph’s Information Security Risk Committee is currently comprised of:
- Quinn Slack, Head of Product & Engineering
- Dan Adler, VP Operations
- Diego Comas, Security Lead
- Tammy Zhu, Diector of Legal
Risk identification
Information security risks can be raised in either of the following two ways:
- ad-hoc, by emailing the security team
- by a member of the Information Security Risk Committee during the scheduled risk review meeting
Ad-hoc risk identification
Sourcegraph’s employees can raise potential information security risks at any time by sending an email with details of the risk in question to security@sourcegraph.com.
It is the responsibility of the Security team member currently on the support rota to ensure that:
- The email is acknowledged
- Any unclear details about the risk in question are clarified with the person reporting the risk
- Estimates of inherent and residual risk are created according to the process described in the Information Security Risk Management Policy. Only Security team members are able to add new risks and set information security risk estimates.
- A risk owner is assigned. An appropriate risk owner should have good knowledge of the risk area in question, and should be able to own and drive any required risk treatments.
- If required, a treatment plan with a due date is defined
Security team members are also free to raise and triage risks in this manner as required.
Risk identification through scheduled review
New risks might also be identified during the scheduled risk review process; for more information on this process, see ‘Reporting and review’ below.
Risk treatment, acceptance, and exceptions
Once a risk has been triaged and entered into the risk register, it will either require treatment or acceptance. By default, any risk with a Low residual risk estimate is considered to be accepted, and requires no further action until the next scheduled risk review.
Any risk with a Medium or a High residual risk estimate will require further controls to reduce the information security risk to Sourcegraph. It is the responsibility of the Security team member handling the risk entry to work with the risk owner to identify treatments that would achieve this goal, and a realistic timeline in which this can happen.
Once this is done, the risk entry in the register should be updated with links to specific issues in relevant trackers (Github, Jira, etc.) where the treatment actions will occur, as well as the due date. The Security team member must notify the risk owner of this change and receive written confirmation that they are satisfied with the status of the risk register entry.
In some cases, it might be possible that there is no reasonable treatment possible for a risk that exceeds the threshold for risk treatment. In this case, an exception should be sought. Exceptions can only be signed off by the CTO. In order to raise an exception:
- Discuss the risk first with the Engineering Manager of the Security team to confirm that an exception should be sought in this case.
- Compose an email to the CTO, including the Engineering Manager of the Security team and the risk owner, explaining the nature of the risk and the reason why a suitable treatment cannot be found. If the CTO confirms in writing that they are happy to grant this exception, update the risk register accordingly.
- If the CTO is not satisfied that an exception is merited, work with the involved parties to investigate other possible treatments or approaches to the problem.
Reporting and review
In order to ensure that the risk register is up-to-date and irrelevant risks are removed, a Google Calendar entry will prompt the Security team to send out a risk report once every six months. The team member on the Security support rota must then send out a high-level risk report to all current risk owners and the Information Security Risk Committee. This report should contain:
- A link to the current risk register
- A summary of new risks added to the register since the previous report
- A summary of risks requiring treatment that are about to or have already exceeded their due date
As part of this reporting process, risk owners should also be requested to review their risks and confirm in writing that they are satisfied with their status in the risk register. Any changes that they wish to make should then be discussed on an individual basis, and the risk register should be updated when a conclusion is reached. All decisions made should be written down in the risk register for later reference, as well as to confirm that the risk register item has been punctually reviewed.
When the review process is completed, the updated risk register should be sent to the Security Engineering Manager for approval using the Approval workflow in Google Sheets.
I’m part of the risk committee – what are my responsibilities?
Members of the risk committee have two main responsibilities:
- Working with the Security team to identify any risks related to their area of the business as part of the scheduled risk review process.
- Assisting the Security team in developing and iterating on the risk management programme to ensure it is meeting the goals of the risk management policy.
The Security team will let you know whenever your input is required on matters relating to security risk management - if you haven’t heard from us, there’s nothing required from you at the moment!
I’m a risk owner – what do I do now?
Risk owners are responsible for:
- Working with the Security team to identify treatment plans for risks relating to their business areas
- Ensuring that treatment plans agreed upon are put into action and delivered by the agreed upon due date
The Security team will ensure that you are involved in all parts of the treatment process from when a risk is raised against your area. This includes involving you in:
- Verifying that an identified risk has been identified correctly, and that all available controls to mitigate against the risk have been noted
- Verifying that the risk estimate for the risk (as defined in the risk management policy) is accurate
- Developing a reasonable treatment plan for the risk, and identifying a realistic due date for the delivery of the plan
- Closing off the risk when the treatment plan is complete