Introduction to Cybersecurity Frameworks: Why They Matter
Cybersecurity frameworks are critical for many organizations. But what exactly is a cybersecurity framework, and why does it matter? A cybersecurity framework systematically manages privacy and security risks by establishing effective processes and standards. These frameworks help identify vulnerabilities, assess threats, and implement safeguards that align with an organization’s objectives and mission. Whether it is used to meet compliance requirements, secure sensitive data, or align with business objectives, a cybersecurity framework helps organizations approach security holistically.
Adopting a cybersecurity framework is more than just an operational consideration for organizations. It is a strategic imperative. It extends beyond risk management and is not limited to IT departments. It impacts entire organizations, from the executive suite to frontline staff. A well-implemented framework bridges the gap between safeguards and business objectives, ensuring that an organization’s cybersecurity initiatives become integral to enterprise-wide decision-making and build stakeholder trust. In healthcare organizations, this includes patients, providers, business partners, and regulators. By embedding cybersecurity practices into an organization’s culture, risk management evolves into a proactive, continuous, and adaptive process rather than a reactive, one-time effort. Frameworks also help organizations navigate legal and regulatory landscapes, making them critical for compliance with laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH).
This Article begins by discussing how to choose the most appropriate cybersecurity framework for an organization. It then assumes the adoption of the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) and explains what it entails. It discusses considerations for implementing the framework to strengthen an organization’s cybersecurity posture, increase resilience, and maintain its reputation. It concludes by examining NIST CSF Version 2.0, focusing on its key updates and implications.
Choosing the Right Cybersecurity Framework: Conducting a Business Impact Analysis
NIST CSF is adaptable for organizations of all sizes and industries, but you might wonder if it is right for you. Selecting an appropriate cybersecurity framework is critical, but how can you determine if this framework or an alternative is more suitable for your needs? Before choosing a framework to adopt, consider conducting a business impact analysis (BIA). A BIA will provide insight into critical business functions and help map them to the organization’s missions and objectives. By undertaking a BIA, you can:
Identify critical systems (i.e., assets) and determine which systems support the most critical functions and require the highest level of protection;
Understand the organization’s risk tolerance to prioritize security efforts;
Identify the organization’s regulatory and compliance requirements, such as HIPAA, HITECH, and other laws and regulations;
Identify existing threats and vulnerabilities that cyber threats could exploit; and
Form documented plans to address gaps and weaknesses to mitigate identified risks and strengthen the organization’s security posture.
Understanding these aspects of your organization will better prepare you to choose the cybersecurity framework that best aligns with top priorities and effectively addresses specific challenges. As mentioned above, for this Article, we assume your organization has chosen the NIST Cybersecurity Framework after conducting a BIA as described above. Let’s dive in.
What is the NIST Cybersecurity Framework (CSF)?
Before delving into this article's main focus, the updated NIST CSF Version 2.0, we first discuss what NIST CSF is and how it fits into the broader context of organizational risk management. For over a decade, NIST CSF has been the gold standard for developing and managing cybersecurity programs. Since its initial publication, users have downloaded it more than 2 million times in more than 185 countries and translated it into at least nine languages.
NIST CSF aligns with the cybersecurity program management lifecycle. It is a free resource that supports organizations in establishing and improving their security programs. It is not mandatory, so organizations do not have to obtain a certification or incur additional expenses by adopting it. Instead, it offers voluntary guidance based on established industry standards and guidelines. According to NIST, the framework helps organizations address threats while supporting business objectives. It may be prudent to use it as a living resource to adjust and adapt as your organization evolves and your security program matures.
The framework is designed to help organizations identify risks and vulnerabilities, understand their potential impact, inform responses, recover from incidents, evaluate the root causes of weaknesses and vulnerabilities, and improve controls to reduce risks. For healthcare organizations, where patient safety often depends on securing sensitive data, this framework can mean the difference between operational continuity and devastating disruption.
NIST CSF was created from Executive Order 13636 and has undergone several updates, with the Cybersecurity Enhancement Act of 2014 ratifying the voluntary standards into NIST responsibilities as Version 1.0 was released. It stems from collaboration between private sector professionals and government agencies. In February 2022, NIST requested information to enhance the framework's effectiveness and provide further guidance on managing supply chain risk. After reviewing responses and analyzing the Request for Information (RFI) results, NIST released a core draft of Version 2.0 in April 2023 while inviting additional public comments to refine the framework’s structure. The final version was published in February 2024. Here is the complete timeline:
To better understand NIST CSF Version 2.0, let’s start with a high-level overview of Version 1.0. It’s comprised of 5 core functions. These 5 functions include 23 related categories (control families) and 108 subcategories (controls). The subcategories are not exhaustive and describe detailed outcomes that support each category.
Organizations can implement these core functions, categories, and subcategories in phases, starting with partial implementation and progressing to higher program maturity levels, such as risk-informed, repeatable, and adaptive stages. The functions, categories, and subcategories apply to all Information and Communication Technology an organization uses, including information technology, the Internet of Things, and operational technology. They apply to all technology environments, including cloud, mobile, and artificial intelligence systems.
On both sides of NIST CSF, organizations should focus on governance and communication, key supporting elements for framework implementation and program management. Both are fundamental components of effective and mature cyber risk management programs. Without proper governance, you’re only implementing controls. While these controls may meet minimum regulatory compliance standards, building a program that effectively protects an organization’s sensitive data requires more.
Implementing NIST CSF
Once you've selected the cybersecurity framework that best fits your organization, it's time to establish or improve your cybersecurity program. Begin by prioritizing and defining the scope of your efforts. This means identifying your business and mission objectives, determining the systems that support your critical business units and processes, and understanding your risk tolerances. Next, orient yourself by cataloging related systems and assets, recognizing regulatory requirements, and identifying current threats, vulnerabilities, and issues highlighted in previous risk assessments.
Create a current profile by evaluating which categories and subcategories of the framework your organization currently meets, establishing a baseline for your cybersecurity posture. If you haven’t done so recently, conduct a thorough risk assessment to analyze your operational environment to determine the likelihood and potential impact of cybersecurity events. With this information, develop a target profile that outlines your desired state, using the framework's categories and subcategories while considering unique organizational risks and external stakeholders. Develop an approach that identifies the status of individual cybersecurity controls by isolating and evaluating control building blocks and their level of adoption, including definition, implementation, evolution, and validation. Then, assign maturity ratings for framework-aligned controls as shown in the following:
Identify and prioritize gaps by comparing your current profile to your target profile, considering mission drivers, costs and benefits, and associated risks. Then, formulate a prioritized action plan and implement it by assigning responsibilities and diligently tracking progress. Remember, cybersecurity is not a one-time effort but a continuous process. This means regularly repeating these steps to ensure ongoing improvement and resilience against emerging threats.
The problem? Traditional cybersecurity risk analysis focuses on technology solutions and detailed configurations. Many organizations lack sufficient funding, resources, or staff for effective remediation when new risks are identified, even if they are critical or high severity. There is often a significant delay between discovering risk and acquiring all the tools a team needs to resolve it, sometimes extending for a year or longer until the next budget cycle. In the interim, repeated vulnerability assessments uncover new risks, causing the list to grow longer and creating a snowball effect that overwhelms teams, preventing them from working through their remediation tasks. Most need help prioritizing which tasks to address first with limited resources.
This is why governance is a crucial component of a framework-aligned program. It facilitates buy-in with executives and key stakeholders, enabling effective communication that aligns program goals with the organization’s mission and objectives. When engaging executives with governance at the forefront, you can better demonstrate your current profile, target profile, and future vision for the program. Additionally, you can use your action plan to identify gaps and weaknesses, as well as the resources and financial support needed to close these gaps. As you’ll see, NIST acknowledged this problem and addressed it in its updated CSF Version 2.0.
The NIST Cybersecurity Framework (CSF) is not static and continues to evolve with the current and future threat landscape. As illustrated in the timeline above, in 2018, for example, it was expanded to include self-assessments, supply chain risk management, identity and access management, and the vulnerability disclosure lifecycle. Most recently, NIST CSF Version 2.0 was released. Let’s explore this in more detail.
NIST CSF Version 2.0: Leveling Up
After a thorough year-long review, NIST CSF Version 2.0 was released in February 2024. The new version expands its focus, particularly on governance, resilience, and integration, having significant implications for healthcare organizations. It offers an excellent opportunity for organizations to reassess and enhance their cybersecurity strategies and posture. The framework’s new resources are free, ensuring accessibility for organizations of all sizes.
Organizations can leverage NIST’s reference architecture to implement secure technology solutions. By aligning with NIST CSF Version 2.0, healthcare organizations can develop new target profiles to ensure their security posture is robust and resilient. What might the updated framework look like for your organization?
Transitioning to NIST CSF Version 2.0 requires a solid understanding of the framework's updates and their impact on organizational cybersecurity strategies. To effectively transition, organizations should first identify their adversaries by analyzing threat events, sources, characteristics, and intent. They should also conduct an updated assessment of their cybersecurity programs to highlight strengths and expose gaps. Determining organizational risks involves factoring in vulnerabilities, the likelihood of attack initiation, potential impacts, and mitigation strategies. This structured approach ensures alignment with Version 2.0’s goals, creating a more resilient and adaptive cybersecurity program.
As mentioned above, before NIST CSF Version 2.0, there were 5 core functions. The Govern function is a new addition, emphasizing the growing importance of governance in managing cybersecurity risks. Here is an updated depiction of the updated version’s 6 core functions:
Let's first discuss the interconnectedness of these 6 core functions, which should be addressed concurrently. Actions supporting Govern, Identify, Protect, and Detect should all happen continuously, and actions supporting Respond and Recover should always be ready for when cybersecurity incidents occur. All functions have important roles related to cybersecurity incidents. The Govern, Identify, and Protect outcomes help prevent and prepare for incidents, while the Govern, Detect, Respond, and Recover outcomes help discover and manage incidents.
New Features of NIST CSF Version 2.0
The new Govern function represents a critical evolution of the framework and is the first new core function since its creation. This function emphasizes embedding governance and risk management at the foundation of an organization’s cybersecurity program, aligning business objectives with cybersecurity strategies, and ensuring executive-level accountability. Key elements of the Govern function include defining the organizational context, establishing a risk management strategy, and clarifying roles and responsibilities across leadership and operational teams. Governance also extends to policies and procedures, ensuring compliance among internal staff and alignment with third-party vendors and supply chains. In healthcare, where compliance with HIPAA and safeguarding patient data are paramount, this function is crucial for establishing executive-level accountability and ensuring strategic alignment between cybersecurity and business goals. By integrating governance and risk management processes into an organization’s overall cybersecurity strategy, organizations can strengthen oversight and support informed decision-making regarding mitigating, accepting, or transferring risks.
The Identify function is the foundation for understanding and managing cybersecurity risks. This core function involves cataloging critical organizational assets, systems, and data and assessing risks associated with these resources. Core components include asset management, supply chain risk management, and comprehensive risk assessments. By clearly understanding these elements, organizations can prioritize their cybersecurity efforts and ensure alignment with their overall risk management strategies. Continuous evaluation and improvement are essential to adapting to emerging threats.
The Protect function focuses on implementing safeguards to mitigate identified risks. This includes identity management, access controls, security awareness training, and data protection measures. The updated framework introduces Platform Security and Technology Infrastructure Resilience as new categories within this function. Platform Security ensures that technology safeguards align with an organization’s risk strategy, while Technology Infrastructure Resilience focuses on maintaining operational continuity by protecting systems against potential disruptions.
The Detect function enhances an organization’s ability to identify and analyze potential cybersecurity events in real-time. This function emphasizes the integration of cyber threat intelligence and continuous monitoring across internal systems and external vendors. Key components include analyzing adverse events to prioritize responses and maintain visibility throughout the supply chain. Organizations can address potential threats by staying proactive before they escalate into significant incidents.
The Respond function outlines actionable steps for mitigating cybersecurity incidents once detected. While this function has seen minimal changes from NIST CSF Version 1.1, it remains essential for effectively addressing threats. This includes incident management, reporting, communication, and mitigation strategies. A robust incident response plan ensures that organizations can contain the damage from an attack and minimize disruptions to operations.
The Recover function highlights the importance of restoring systems and ensuring data integrity after an incident. Recovery efforts focus on executing incident recovery plans, restoring normal operations, and verifying the integrity of affected data and systems. These steps are crucial for maintaining patient trust and ensuring business continuity, particularly with the increase of ransomware attacks, especially in the healthcare sector.
Introducing the Govern function in NIST CSF Version 2.0 marks a transformative step, acknowledging that effective governance is the cornerstone of a successful cybersecurity program. Together, these 6 core functions provide organizations with a robust framework for improving their cybersecurity posture, aligning with business objectives, and building resilience against ever-evolving cyber threats.
Takeaways from the "Safeguarding Health Information" Event
Attending the "Safeguarding Health Information: Building Assurance through HIPAA Security 2024" event gave me a firsthand glimpse into the transformative updates of the NIST CSF Version 2.0. The two-day conference focused on advancements in healthcare privacy and security and presented valuable insights into how the updated framework shapes the future of cybersecurity in healthcare. As a participant in this event, I gained a deeper appreciation for the framework’s relevance and its ability to address the unique challenges faced by the healthcare sector.
NIST CSF Version 2.0 introduces an expanded scope and enhanced implementation guidance, marking a significant shift in its approach to organizational cybersecurity. One notable update is the framework’s broadened applicability, which applies to all organizations, regardless of type or size, unlike its predecessor. This universality is reflected in the framework’s name change from “Framework for Improving Critical Infrastructure Cybersecurity” to “The Cybersecurity Framework.” This shift underscores NIST’s intent to make the framework a cornerstone of comprehensive cybersecurity risk management across diverse sectors. By adopting a more inclusive focus, NIST demonstrates its commitment to making the framework accessible and relevant to organizations of all types and sizes, including smaller healthcare providers that may lack significant resources for cybersecurity. This update represents a transition from the framework’s original focus on critical infrastructure, such as hospitals, to universal applicability, ensuring all entities can implement robust cybersecurity practices tailored to their unique needs.
To enhance this broader emphasis, NIST CSF Version 2.0 delivers refined guidance for developing customized profiles, enabling organizations to tailor the framework to their specific sectors, technologies, or distinct challenges. Practical implementation examples for each function's subcategories are especially useful for smaller organizations, providing actionable insights that facilitate their adoption of the framework. These updates increase the framework's accessibility, connecting overarching cybersecurity principles with practical, everyday applications.
NIST introduced the CSF 2.0 Reference Tool, an online resource designed to streamline implementation by enabling organizations to browse, search, and export the framework’s core data in human and machine-readable formats. This dynamic, user-friendly platform offers practical guidance and examples, making the framework more accessible and actionable. The tool also facilitates integration with other standards and guidelines, supporting healthcare organizations in adopting comprehensive and cohesive cybersecurity strategies. It exemplifies NIST’s commitment to providing a comprehensive suite of resources beyond a single document to help organizations manage cybersecurity risks more effectively and collaboratively.
Another key update is the integration of supply chain security throughout the framework. Healthcare organizations increasingly rely on a network of third-party vendors and partners to support operations, making supply chain risks a pressing concern. The updated framework embeds supply chain considerations at every level, encouraging organizations to address vulnerabilities across their extended networks. This focus is especially critical in healthcare, where interconnected systems and shared data often create potential vulnerabilities. An organization is only as secure as its weakest link.
The framework’s commitment to continuous improvement was also a significant focus. Presenters discussed how NIST CSF Version 2.0 recognizes cybersecurity as an evolving area, requiring organizations to adapt their strategies to keep pace with emerging threats and technologies. It is intended to apply to future changes in technologies and environments. This forward-looking approach encourages healthcare organizations to regularly assess and refine their cybersecurity programs, ensuring they remain resilient in the face of new challenges.
NIST CSF Version 2.0 Community Profiles were also introduced as a collaborative tool for tailoring the framework to specific contexts, such as industries, technologies, or unique challenges. These profiles enable organizations to define interests, goals, and outcomes and find consensus on priorities for their community. This means creating profiles aligning cybersecurity practices with sector-specific regulatory requirements, operational realities, and risk environments for healthcare. Structured templates were showcased during the event, offering organizations a clear roadmap to map priorities and outcomes to the framework’s taxonomy.
Looking Ahead: NIST CSF 2.0 and the Future of Cybersecurity
The release of NIST CSF Version 2.0 marks a pivotal moment for organizational cybersecurity. It reflects forward-looking principles, incorporating emerging technologies and fostering collaboration within the healthcare sector. Despite its expanded scope, it remains a cornerstone for protecting critical infrastructure, including healthcare. Organizations can bolster their defenses by adopting these updated guidelines, improving governance, and ensuring alignment with industry best practices. These updates address evolving threats and offer a proactive strategy for future challenges. They enhance resilience and adaptability amid rising cyber risks. Cybersecurity risk management is an ongoing process, and the updated NIST CSF Version 2.0 guides organizations to success.
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