Building an ISP That Works

In today’s business environment, data is a core driver of revenue, valuation, and competitive advantage, which is why protecting information has become as essential as protecting physical property or cash reserves. An Information Security Program (ISP) is the framework through which organizations safeguard their most valuable digital and physical information assets. Without documented policies, roles, and controls, companies risk confusion, liability, and operational breakdown when incidents occur.

The ‘Information Security’ Landscape

At its core, ‘information security’ is about protecting information in all three states of processing, storage, and transmission, notes Alex Sharpe of Sharpe Management Consulting LLC. Within ‘information security,’ terms like cybersecurity, information security (INFOSEC), and information assurance (IA) are often used interchangeably, but they have meaningful differences.

• Cybersecurity focuses specifically on information in digital environments.
• INFOSEC encompasses the protection of information in any form, i.e., paper documents, whiteboards, digital files, or databases.
• Information assurance is about ensuring that the right people receive the right information at the right time, without interruption or compromise.

All three align around the ‘CIA Triad,’ which represents Confidentiality, Integrity, and Availability. These concepts form the backbone of modern security frameworks and are echoed throughout regulations such as NIST CSF, the California Consumer Privacy Act (CCPA), and the New York SHIELD Act.

Why Regulation Matters and Why It’s Getting More Complex

From state privacy laws to federal reporting obligations, businesses face a rapidly expanding web of compliance requirements; the cost of misalignment between legal obligations and technical controls can be catastrophic.

In the United States alone, companies must navigate:

• State privacy statutes such as the aforementioned CCPA and NY SHIELD Act.
• Various Federal rules including HIPAA, which regulates health information, and the Gramm-Leach Bliley Act (GLBA), which safeguards consumer financial data.
• SEC rules requiring disclosure of cybersecurity incidents and board-level oversight.
• Reporting mandates under the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA).

Third-Party and Supply Chain Risk

According to Sharpe, third-party and supply chain vulnerabilities have become one of the most significant sources of cybersecurity incidents. This trend is driven by a simple reality: modern businesses rely heavily on external vendors, cloud services, managed service providers, payment platforms, logistics partners, and a growing ecosystem of subcontractors. Each connection in that chain represents another potential entry point for attackers. Failures here often result in higher breach-related losses due to the complexity of coordinating responses across multiple organizations. For many companies, vendor risk represents the largest blind spot and the greatest potential source of legal, financial, and reputational exposure.

Unlike traditional perimeter-based security risks, third-party breaches are dangerous because organizations often have limited visibility into the security practices of the vendors they depend upon. Even companies with strong internal controls can be exposed through a single weak link in their supply chain. This is why regulators, insurers, and boards increasingly expect robust vendor risk management programs.

A strong vendor-risk program includes:

• Categorizing vendors by strategic importance, data access, and potential operational impact.
• Using GRC or vendor risk-management tools to automate assessments, risk scoring, and continuous monitoring.
• Requiring and reviewing SOC 2 Type 2 reports for technology and cloud service providers
• Embedding security expectations into contracts, including cooperation requirements during investigations, breach notification obligations, rights to audit, and logging or evidence preservation requirements.
• Performing ongoing, not annual, monitoring to ensure vendor risks are continuously evaluated as services, threats, and business conditions evolve.

Employee Training

Employees are often described as the ‘weakest link’ in cybersecurity; however, with proper training, communication, and engagement, employees can become one of the strongest layers of defense within an organization.

In today’s environment, employees interact with technology constantly: email, collaboration tools, mobile apps, cloud services, and increasingly, AI platforms. Each interaction creates an opportunity for attackers to exploit. Phishing remains the most common entry point for ransomware attacks; attackers know that exploiting human psychology is often easier than breaking through technical defenses.

Effective training programs include:

• Routine phishing simulations designed to teach, not shame, employees.
• Clear guidance on how to report suspicious activity quickly.
• Training tailored to different roles, especially those with elevated privileges or access to sensitive data.
• Education on safe use of AI tools, personal devices, and cloud-based collaboration platforms.
• Regular refreshers rather than one-time annual sessions, ensuring security stays front-of-mind.

Beyond formal training, organizations should cultivate a culture where employees feel empowered to ask questions, report mistakes early, and collaborate with security teams. Manipulating employees succeeds most easily in cultures where employees fear getting in trouble or assume security is ‘someone else’s job.’

By positioning employees as partners rather than liabilities, organizations strengthen both their security posture and their internal communication channels, which are both critical elements when rapid response is required.

Key Steps in Creating an Effective Information Security Program

1. Conduct a Risk Assessment: Everything begins with understanding risk. A comprehensive risk assessment includes identifying sensitive data, evaluating threats, and determining business impacts. Important to note is that prohibiting tools, technologies, or processes outright can stifle innovation and does not totally avoid the risk posed.
2. Develop Written Policies and Procedures: An ISP should include policies on access control, incident response, acceptable use, remote work, encryption, and more. These policies should define expectations and accountability, guiding both daily operations and crisis response.
3. Governance Integration: Organizations increasingly adopt a ‘Three Lines of Defense model,’ with some extending it to four lines:

• First Line: Operational staff and managers
• Second Line: Risk management, compliance, and security leadership
• Third Line: Internal audit
• Fourth Line: External auditors and regulators

“If you build the house and decide where the wiring goes afterward, you’ll have to break walls,” observes J. Eduardo Campos of Embedded-Knowledge, Inc. In other words, security must be embedded as the organization grows and not added retroactively.

4. Data Classification and Access Controls: Access decisions must be tied to the criticality of information. Overly complex classification systems can create confusion and noncompliance. A simpler structure such as ‘public,’ ‘internal,’ ‘confidential,’ and ‘high-risk’ is recommended. Without strong authentication, auditing, and privilege controls, even the best-designed ISP will fail.

Security as a Business Enabler

As organizations become more digitized, interconnected, and data-driven, the line between business strategy and security strategy disappears. Modern companies cannot compete, innovate, or scale without a solid foundation of security practices guiding their decisions. The most resilient organizations are those that treat security as an enabler of innovation and not a barrier to it. When governance frameworks, vendor-risk processes, training programs, and AI policies work together, the result is not restriction but empowerment. Teams can operate faster and more confidently because guardrails are clear, risks are known, and responsibilities are shared.

Ultimately, an effective Information Security Program is not defined by the length of its policy documents or the number of tools it deploys. It is defined by how well it aligns security practices with business objectives, how clearly it communicates expectations, and how consistently it adapts to emerging risks. When done right, a mature ISP strengthens resilience, protects revenue, supports innovation, and reinforces organizational culture.

To learn more about this topic, view How to Build and Implement your Company’s Information Security Program. The quoted remarks referenced in this article were made either during this webinar or shortly thereafter during post-webinar interviews with the panelists. Readers may also be interested to read other articles about cybersecurity.

This article was originally published on December 15, 2025.

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