I know it’s a provocative title, but I think it’s true. Despite having used Eramba for somewhere between 6–8 years (first the community edition then the enterprise) I realized recently I have been using it wrong.
I actually went back and watched a few more episodes of the learning courses offered on eramba.org and realized my mistakes.
Here is a quote where we do things differently than Eramba advises.
Episode 1
Introduction to the Internal Control Module
In eramba, Internal Controls are activities that your organisation performs to deal with a problem (in eramba, that is Risks, Compliance Requirements and Data Privacy).
Eramba says:
Every time someone moves a finger in your organisation, they are doing something, therefore an Internal Control is likely to exist.
Internal Controls are solutions to Problems.
We went at it a different way, and it kinda works for us, so the reason for this post is to get some feedback if we are missing something major because of this “mistake”.
We basically went at it like this:
Analyse context ⇒ determine assets to protect ⇒ check for risks ⇒ identify measures to mitigate ⇒ summarize treatment (aka those measures) in a policy ⇒ use one or more “internal controls” in Eramba to periodically check the execution/implementation of some details mentioned in the policy
Let me give you an example:
When the ISO 27001 Annex A ask what we do about “8.13 Information backup” our reply is “here is our Backup Policy” which details how we handle that.
The policy contains a high-level outlook but also the specific details of what/when/how is to be backed up as well as a matrix listing all systems with backup targets and RTO/RPO.
As a policy is basically just a piece of paper as I used to say before Eramba it’s useless without monitoring.
So we chose random parts of all our policies which are suitable to be monitored and/or measured and use the “internal controls” to verify.
i.e. we have internal controls where we regularly approach the person responsible to provide proof that he:
- setup backups in the intervals specified in the policy
- has done 2 successful restore tests every 6 months
- is using encryption as directed in the policy
This has worked pretty well, the only issue I noticed was when assigning controls in eramba, the policies get automatically added.
That’s when I realized that I have many controls mapped to one policy while Eramba seems to say that one control should be mapped to multiple policies.
So for us, controls are a means to check the implementation and effectiveness of policies.
Sorry for the long post, just wanted to get some feedback on what you guys reading this forum think about this issue.