Chapter 2. Policy Elements and Style

Chapter Objectives

After reading this chapter and completing the exercises, you will be able to do the following:

Image Distinguish between a policy, a standard, a procedure, a guideline, and a plan.

Image Identify policy elements.

Image Include the proper information in each element of a policy.

Image Know how to use “plain language.”

In Chapter 1, “Understanding Policy,” you learned that policies have played a significant role in helping us form and sustain our social, governmental, and corporate organizations. In this chapter, we begin by examining the hierarchy and purpose of guiding principles, policy, standards, procedures, and guidelines as well as adjunct plans and programs. Returning to our focus on policies, we examine the standard components and composition of a policy document. You will learn that even a well-constructed policy is useless if it doesn’t deliver the intended message. The end result of complex, ambiguous, or bloated policy is, at best, noncompliance. At worst, it leads to disastrous consequences. In this chapter, you will be introduced to “plain language,” which means using the simplest, most straightforward way to express an idea. Plain-language documents are easy to read, understand, and act on. By the end of the chapter, you will have the skills to construct policy and companion documents.

Policy Hierarchy

As you learned in Chapter 1, a policy is a mandatory governance statement that presents management’s position. A well-written policy clearly defines guiding principles, provides guidance to those who must make present and future decisions, and serves as an implementation roadmap. Policies are important, but alone they are limited in what they can accomplish. Policies need supporting documents to give them context and meaningful application. Standards, baselines, guidelines, and procedures each play a significant role in ensuring implementation of the governance objective. The relationship between the documents is known as the policy hierarchy. In a hierarchy, with the exception of the topmost object, all objects are subordinate to the one above it. In a policy hierarchy, the topmost object is the guiding principles, as illustrated in Figure 2.1.

Image

FIGURE 2.1 Policy hierarchy.

Polices reflect the guiding principles and organizational objectives. Standards enable the policies by defining action. Guidelines, procedures, and baselines support the standards. Let’s take a closer look at each of these concepts.

Standards

Standards serve as specifications for the implementation of policy and dictate mandatory requirements. For example, our password policy might simply state the following:

1. All users must have a unique user ID and password that conforms to the company password standard.

2. Users must not share their password with anyone regardless of title or position.

3. If a password is suspected to be compromised, it must be reported immediately to the help desk and a new password must be requested.

The password standard would then dictate the required password characteristics, such as the following:

Image Minimum of eight upper- and lowercase alphanumeric characters

Image Must include at least one special character (such as *, &, $, #, !, or @)

Image Must not include the user’s name, the company name, or office location

Image Must not include repeating characters (for example, 111)

As you can see, the policy represents expectations that are not necessarily subject to changes in technology, processes, or management. The standard, however, is very specific to the infrastructure. Standards are determined by management, and unlike policies, they are not subject to Board of Directors authorization. Standards can be changed by management as long as they conform to the intent of the policy.

Baselines

Baselines are an aggregate of implementation standards and security controls for a specific category or grouping, such as platform (for example, Windows OS), device type (for example, iPad), ownership (for example, employee owned), and location (for example, mobile users). The primary objective of a baseline is uniformity and consistency. An example of a baseline related to our password policy and standard example is the mandate that a specific Active Directory Group Policy configuration be used on all Windows devices to technically enforce security requirements, as illustrated in Figure 2.2.

Image

Figure 2.2 Windows Group Policy settings.

In this example, by applying the same Active Directory Group Policy to all Windows workstations and servers, the standard was implemented throughout the organization. In this case, there is also assurance that new devices will be configured accordingly.

Guidelines

Guidelines are best thought of as teaching tools. The objective of a guideline is to help people conform to a standard. In addition to using softer language than standards, guidelines are customized for the intended audience and are not mandatory. Guidelines are akin to suggestions or advice. A guideline related to the password standard in the previous example might read like this:

“A good way to create a strong password is to think of a phrase, song title, or other group of words that is easy to remember and then convert it, like this:

Image “The phrase ‘Up and at ’em at 7!’ can be converted into a strong password such as up&atm@7!.

Image “You can create many passwords from this one phrase by changing the number, moving the symbols, or changing the punctuation mark.”

This guideline is intended to help readers create easy-to-remember, yet strong passwords.

Procedures

Procedures are instructions for how a policy, standard, baseline, and guidelines are carried out in a given situation. Procedures focus on actions or steps, with a specific starting and ending point. There are four commonly used procedure formats:

Image Simple Step—Lists sequential actions. There is no decision making.

Image Hierarchical—Includes both generalized instructions for experienced users and detailed instructions for novices.

Image Graphic—This format uses either pictures or symbols to illustrate the step.

Image Flowchart—Used when a decision-making process associated is with the task.

In keeping with our previous password example, let’s take a look at a Simple Step procedure for changing a user’s Windows password:

1. Press and hold the Ctrl+Alt+Delete keys.

2. Click the Change Password option.

3. Type your current password in the top box.

4. Type your new password in both the second and third boxes. (If the passwords don’t match, you will be prompted to reenter your new password.)

5. Click OK and then log in with your new password.


NOTE

As with guidelines, it is important to know both your audience and the complexity of the task when designing procedures. In Chapter 8, “Communications and Operations Security,” we discuss in detail the use of standard operating procedures (SOPs).


Plans and Programs

The function of a plan is to provide strategic and tactical instructions and guidance on how to execute an initiative or how to respond to a situation, within a certain timeframe, usually with defined stages and with designated resources. Plans are sometimes referred to as programs. For our purposes, the terms are interchangeable. Here are some examples of information security–related plans we discuss in this book:

Image Vendor Management Plan

Image Incident Response Plan

Image Business Continuity Plan

Image Disaster Recovery Plan

Policies and plans are closely related. For example, an Incident Response Policy will generally include the requirement to publish, maintain, and test an Incident Response Plan. Conversely, the Incident Response Plan gets its authority from the policy. Quite often, the policy will be included in the plan document.

Policy Format

Writing policy documents can be challenging. Polices are complex documents that must be written to withstand legal and regulatory scrutiny while at the same time be easily read and understood by the reader. The starting point for choosing a format is identifying the policy audience.

Policy Audience

Who the policy is intended for is referred to as the policy audience. It is imperative, during the planning portion of the security policy project, to clearly define the audience. Policies may be intended for a particular group of employees based on job function or role. An application development policy is targeted to developers. Other policies may be intended for a particular group or individual based on organizational role, such as a policy defining the responsibility of the Information Security Officer. The policy, or portions of it, can sometimes apply to people outside of the company, such as business partners, service providers, contractors, or consultants. The policy audience is a potential resource during the entire policy lifecycle. Indeed, who better to help create and maintain an effective policy than the very people whose job it is to use those policies in the context of their everyday work?

Policy Format Types

Organize, before you begin writing! It is important to decide how many sections and subsections you will require before you put pen to paper. Designing a template that allows the flexibility of editing will save considerable time and reduce aggravation.

There are two schools of thought in regard to policy format. The first is to write each policy as a discrete document; this document type is referred to as a singular policy. The second is to group like policies together; this document type is referred to as a consolidated policy. Consolidated policies are often organized by section and subsection. Table 2.1 illustrates policy document format options.

Image

TABLE 2.1 Policy Document Format Options

The advantage to individual policies is that each policy document can be short, clean and crisp, and targeted to its intended audience. The disadvantage is the need to manage multiple policy documents and the chance that they will become fragmented and lose consistency. The advantage to consolidation is that it presents a composite management statement in a single voice. The disadvantage is the potential size of the document and the reader challenge of locating applicable sections.

In the first edition of this book, we limited our study to singular documents. Since then, both the use of technology and the regulatory landscape have increased exponentially—only outpaced by escalating threats. In response to this ever-changing environment, the need for and number of policies has grown. For many organizations, managing singular policies has become unwieldy. The current trend is toward consolidation. Throughout this edition, we are going to be consolidating policies by security domain. You will be introduced to each security domain in Part II, “Information Security Policy Domains.”

Regardless of which format you choose, do not include standards, baselines, guidelines, or procedures in your policy document. If you do so, you will end up with one big unruly document. You will undoubtedly encounter one or more of the following problems:

Image Management challenge—Who is responsible for managing and maintaining a document that has multiple contributors?

Image Difficulty of updating—Because standards, guidelines, and procedures change far more often than policies, updating this whale of a document will be far more difficult than if these elements were properly treated separately. Version control will become a nightmare.

Image Cumbersome approval process—Various regulations as well as the Corporate Operating Agreement require that the Board of Directors approve new policies as well as changes. Mashing it all together means that every change to a procedure, guideline, or standard will potentially require the Board to review and approve. This will become very costly and cumbersome for everyone involved.

Policy Components

Policy documents have multiple sections or components (see Table 2.2). How the components are used and in what order will depend on which format—singular or consolidated—you choose. In this section, we examine the composition of each component. Consolidated policy examples are provided in the “In Practice” sidebars.

Image

TABLE 2.2 Policy Document Components

Version Control

Best practices dictate that policies are reviewed annually to ensure they are still applicable and accurate. Of course, policies can (and should) be updated whenever there is a relevant change driver. Version control, as it relates to policies, is the management of changes to the document. Versions are usually identified by a number or letter code. Major revisions generally advance to the next letter or digit (for example, from 2.0 to 3.0). Minor revisions generally advance as a subsection (for example, from 2.0 to 2.1). Version control documentation should include the change date, name of the person or persons making the change, a brief synopsis of the change, the name of the person, committee, or board that authorized the change, and the effective date of the change.

Image For singular policy documents, this information is split between the policy heading and the administrative notation sections.

Image For consolidated policy documents, a version control table is included either at the beginning of the document or at the beginning of a section.

Introduction

Think of the introduction as the opening act. This is where we first meet the reader and have the opportunity to engage them. Here are the objectives of the introduction:

Image To provide context and meaning

Image To convey the importance of understanding and adhering to the policy

Image To acquaint the reader with the document and its contents

Image To explain the exemption process as well as the consequence of noncompliance

Image To thank the reader and to reinforce the authority of the policy

The first part of the introduction should make the case for why policies are necessary. It is a reflection of the guiding principles, defining for the reader the core values the company believes in and is committed to. This is also the place to set forth the regulatory and contractual obligations that the company has—often by listing which regulations, such as GLBA, HIPAA, or MA CMR 17 201, pertain to the organization as well as the scope of the policy.

The second part of the introduction should leave no doubt that compliance is mandatory. A strong statement of expectation from a senior authority such as the Chairman of the Board, CEO, or President is appropriate. Readers should understand that they are unequivocally and directly responsible for the safeguarding of information and systems in the course of their normal employment or relationship with the company. It should also make clear that questions are welcome and a resource is available who can clarify the policy and/or assist with compliance.

The third part of the introduction should describe the policy document, including the structure, categories, and storage location (for example, the company intranet). It should also reference companion documents such as standards, guidelines, programs, and plans.

The fourth part of the introduction should explain how to handle situations where compliance may not be feasible. It should explain the exemption process. The section should also address the consequences of willful noncompliance.

The introduction should end with a “thank you” and with words of encouragement. The introduction should be signed by a person who has the authority to enforce the policy. This final statement reinforces the organizational commitment.

Image For singular policy documents, the introduction should be a separate document.

Image For consolidated policy documents, the introduction serves as the preface and follows the version control table.

Policy Heading

A policy heading identifies the policy by name and provides the reader with an overview of the policy topic or category. The format and contents of the heading significantly depend on the format (singular or consolidated) you are using.

Image Singular policies must be able to stand on their own, which means it is necessary to include significant logistical detail in each heading. The information contained in a singular policy heading may include the organization or division name, category (section), subsection, policy number, name of the author, version number, approval authority, effective date of the policy, regulatory cross-reference, and a list of supporting resources and source material. The topic is generally self-explanatory and does not require an overview or explanation.

Image In a consolidated policy document, the heading serves as a section introduction and includes an overview. Because the version number, approval authority, and effective date of the policy have been documented in the version control table, it is unnecessary to include them in section headings. Regulatory cross-reference (if applicable), lead author, and supporting documentation are found in the Administrative Notation section of the policy.

Policy Goals and Objectives

Policy goals and objectives act as a gateway to the content to come and the security principle they address. This component should concisely convey the intent of the policy. Note that even a singular policy can have multiple objectives. We live in a world where business matters are complex and interconnected, which means that a policy with a single objective might risk not covering all aspects of a particular situation. It is therefore important, during the planning phase, to pay appropriate attention to the different objectives the security policy should seek to achieve.

Image Singular policies list the goals and objectives either in the policy heading or in the body of the document.

Image In a consolidated policy document, the goals and objectives are grouped and follow the policy heading.

Policy Statement

Up to this point in the document, we have discussed everything but the actual policy statement. The policy statement is best thought of as a high-level directive or strategic roadmap. This is the section where we lay out the rules that need to be followed and, in some cases, reference the implementation instructions (standards) or corresponding plans. Policy statements are intended to provide action items as well as the framework for situational responses. Policies are mandatory. Deviations or exceptions must be subject to a rigorous examination process.

Policy Exceptions and the Exemption Process

Realistically, there will be situations where it is not possible or practical, or perhaps may even be harmful, to obey a policy directive. This does not invalidate the purpose or quality of the policy. It just means that some special situations will call for exceptions to the rule. Policy exceptions are agreed waivers that are documented within the policy. For example, in order to protect its intellectual property, Company A has a policy that bans digital cameras from all company premises. However, a case could be made that the HR department should be equipped with a digital camera to take pictures of new employees to paste them on their ID badges. Or maybe the Security Officer should have a digital camera to document the proceedings of evidence gathering after a security breach has been detected. Both examples are valid reasons why a digital camera might be needed. In these cases, an exception to the policy could be added to the document. If no exceptions are ever to be allowed, this should be clearly stated in the Policy Statement section as well.

An exemption or waiver process is required for exceptions identified after the policy has been authorized. The exemption process should be explained in the introduction. The criteria or conditions for exemptions should not be detailed in the policy, only the method or process for requesting an exemption. If we try to list all the conditions to which exemptions apply, we risk creating a loophole in the exemption itself. It is also important that the process follow specific criteria under which exemptions are granted or rejected. Whether an exemption is granted or rejected, the requesting party should be given a written report with clear reasons either way.

Finally, it is recommended to keep the number of approved exceptions and exemptions low, for several reasons:

Image Too many built-in exceptions may lead employees to perceive the policy as unimportant.

Image Granting too many exemptions may create the impression of favoritism.

Image Exceptions and exemptions can become difficult to keep track of and successfully audit.

If there are too many built-in exceptions and/or exemption requests, it may mean that the policy is not appropriate in the first place. At that point, the policy should be subject to review.

Policy Enforcement Clause

The best way to deliver the message that policies are mandatory is to include the penalty for violating the rules. The policy enforcement clause is where the sanctions for non-adherence to the policy are unequivocally stated in order to reinforce the seriousness of compliance. Obviously, you must be careful with the nature of the penalty. It should be proportional to the rule that was broken, whether it was accidental or intentional and the level of risk the company incurred.

An effective method of motivating compliance is proactive training. All employees should be trained in the acceptable practices presented in the security policy. Without training, it is hard to fault employees for not knowing they were supposed to act in a certain fashion. Imposing disciplinary actions in such situations can adversely affect morale. We will take a look at various training, education, and awareness tools and techniques in later chapters.

Administrative Notations

The purpose of administrative notations is to refer the reader to additional information and/or provide a reference to an internal resource. Notations include regulatory cross-references, the name of corresponding documents such as standards, guidelines, and programs, supporting documentation such as annual reports or job descriptions, and the policy author’s name and contact information. You should only include notations that are applicable to your organization. However, you should be consistent across all policies.

Image Singular policies incorporate administrative notations either in the heading, at the end of the document, or split between the two locations. How this is handled depends on the policy template used by the company.

Image In a consolidated policy document, the administrative notations are located at the end of each section.

Policy Definitions

The Policy Definition section is a glossary of terms, abbreviations, and acronyms used in the document that the reader may be unfamiliar with. Adding definitions to the overall document will aid the target audience in understanding the policy, and will therefore make the policy a much more effective document.

The rule of thumb is to include definitions for any instance of industry-specific, technical, legal, or regulatory language. When deciding what terms to include, it makes sense to err on the side of caution. The purpose of the security policy as a document is communication and education. The target audience for this document usually encompasses all employees of the company, and sometimes outside personnel. Even if some technical topics are well known to all in-house employees, some of those outside individuals who come in contact with the company—and therefore are governed by the security policy—may not be as well versed in the policy’s technical aspects.

Simply put, before you begin writing down definitions, it is recommended to first define the target audience for whom the document is crafted, and cater to the lowest common denominator to ensure optimum communication efficiency.

Another reason why definitions should not be ignored is for the legal ramification they represent. An employee cannot pretend to have thought that a certain term used in the policy meant one thing when it is clearly defined in the policy itself. When you’re choosing which words will be defined, therefore, it is important not only to look at those that could clearly be unknown, but also those that should be defined to remove any and all ambiguity. A security policy could be an instrumental part of legal proceedings and should therefore be viewed as a legal document and crafted as such.

Writing Style and Technique

Style is critical. The first impression of a document is based on its style and organization. If the reader is immediately intimated, the contents become irrelevant. Keep in mind that the role of policy is to guide behavior. That can only happen if the roadmap is clear and easy to use. How the document flows and the words you use will make all the difference as to how the policy is interpreted. Know your intended reader and write in a way that is understandable. Use terminology that is relevant. Most importantly, keep it simple. Polices that are overly complex tend to be misinterpreted. Policies should be written using plain language.

Using Plain Language

The term plain language means using the simplest, most straightforward way to express an idea.

No one technique defines plain language. Rather, plain language is defined by results—it is easy to read, understand, and use. Studies have proven that documents created using plain-language techniques are effective in a number of ways:1

Image Readers understand documents better.

Image Readers prefer plain language.

Image Readers locate information faster.

Image Documents are easier to update.

Image It is easier to train people.

Image Plain language saves time and money.

Even confident readers appreciate plain language. It enables them to read more quickly and with increased comprehension. The use of plain language is spreading in many areas of American culture, including governments at all levels, especially the federal government, healthcare, the sciences, and the legal system.


FYI: Warren Buffet on Using Plan Language

The following is excerpted from the preface to the Securities and Exchange Commission’s A Plain English Handbook:

“For more than forty years, I’ve studied the documents that public companies file. Too often, I’ve been unable to decipher just what is being said or, worse yet, had to conclude that nothing was being said.

“Perhaps the most common problem, however, is that a well-intentioned and informed writer simply fails to get the message across to an intelligent, interested reader. In that case, stilted jargon and complex constructions are usually the villains.

“One unoriginal but useful tip: Write with a specific person in mind. When writing Berkshire Hathaway’s annual report, I pretend that I’m talking to my sisters. I have no trouble picturing them: Though highly intelligent, they are not experts in accounting or finance. They will understand plain English, but jargon may puzzle them. My goal is simply to give them the information I would wish them to supply me if our positions were reversed. To succeed, I don’t need to be Shakespeare; I must, though, have a sincere desire to inform.

“No siblings to write to? Borrow mine: Just begin with ‘Dear Doris and Bertie.’”

Source: Securities and Exchange Commission, “A Plain English Handbook: How to create clear SEC disclosure documents,” www.sec.gov/news/extra/handbook.htm.


The Plain Language Movement

It seems obvious that everyone would want to use plain language, but as it turns out, that is not the case. There is an enduring myth that in order to appear official or important, documents should be verbose. The result has been a plethora of complex and confusing regulations, contracts, and, yes, policies. In response to public frustration, the Plain Language Movement began in earnest in the early 1970s.

In 1971, the National Council of Teachers of English in the U.S. formed the Public Doublespeak Committee. In 1972, U.S. President Richard Nixon created plain language momentum when he decreed that the “Federal Register be written in ‘layman’s terms.’” The next major event in the U.S. history of plain language occurred in 1978, when U.S. President Jimmy Carter issued Executive Orders 12,044 and 12,174. The intent was to make government regulations cost-effective and easy to understand. In 1981, U.S. President Ronald Reagan rescinded Carter’s executive orders. Nevertheless, many continued their efforts to simplify documents; by 1991, eight states had passed statutes related to plain language.

In 1998, then-President Clinton issued a Presidential Memorandum requiring government agencies to use plain language in communications with the public. All subsequent administrations have supported this memorandum. In 2010, plain language advocates achieved a major victory when the Plain Writing Act was passed. This law requires federal government agencies to write publications and forms in a “clear, concise, well-organized” manner using plain language guidelines.

We can take a cue from the government and apply these same techniques when writing policies, standards, guidelines, and plans. The easier a policy is to understand, the better the chance of compliance.


FYI: Plain Language Results

Here’s an example of using plain language that involves the Pacific Offshore Cetacean Take Reduction Plan: Section 229.31. Not only did the National Marine Fisheries Service (NMFS) improve the language of this regulation, they turned the critical points into a user-friendly quick reference card, made it bright yellow so it’s easy to find, and laminated it to stand up to wet conditions.

Before

After notification of NMFS, this final rule requires all CA/OR DGN vessel operators to have attended one Skipper Education Workshop after all workshops have been convened by NMFS in September 1997. CA/OR DGN vessel operators are required to attend Skipper Education Workshops at annual intervals thereafter, unless that requirement is waived by NMFS. NMFS will provide sufficient advance notice to vessel operators by mail prior to convening workshops.

After

After notification from NMFS, vessel operators must attend a skipper education workshop before commencing fishing each fishing season.

Source: www.plainlanguage.gov/examples/before_after/regfisheries.cfm


Plain Language Techniques for Policy Writing

The Plain Language Action and Information Network (PLAIN) describes itself on its website (http://plainlanguage.gov) as a group of federal employees from many different agencies and specialties, who support the use of clear communication in government writing. In March of 2011, PLAIN published the Federal Plain Language Guidelines. Some of the guidelines are specific to government publications. Many are applicable to both government and industry. The ten guidelines, listed here, are pertinent to writing policies and companion documents:

1. Write for your audience. Use language your audience knows and is familiar with.

2. Write short sentences. Express only one idea in each sentence.

3. Limit a paragraph to one subject. Aim for no more than seven lines.

4. Be concise. Leave out unnecessary words. Instead of, “for the purpose of,” use “to.” Instead of, “due to the fact,” use “because.”

5. Don’t use jargon or technical terms when everyday words have the same meaning.

6. Use active voice. A sentence written in the active voice shows the subject acting in standard English sentence order: subject-verb-object. Active voice makes it clear who is supposed to do what. It eliminates ambiguity about responsibilities. Not “It must be done” but “You must do it.”

7. Use “must” not “shall” to indicate requirements. “Shall” is imprecise. It can indicate either an obligation or a prediction. The word “must” is the clearest way to convey to your audience that they have to do something.

8. Use words and terms consistently throughout your documents. If you use the term “senior citizens” to refer to a group, continue to use this term throughout your document. Don’t substitute another term, such as “the elderly” or “the aged.” Using a different term may cause the reader to wonder if you are referring to the same group.

9. Omit redundant pairs or modifiers. For example, instead of “cease and desist,” use either “cease” or “desist.” Even better, use a simpler word such as “stop.” Instead of saying “the end result was the honest truth,” say “the result was the truth.”

10. Avoid double negatives and exceptions to exceptions. Many ordinary words have a negative meaning, such as unless, fail to, notwithstanding, except, other than, unlawful (“un-” words), disallowed (“dis-” words), terminate, void, insufficient, and so on. Watch out for them when they appear after “not.” Find a positive word to express your meaning.

Want to learn more about using plain language? The official website of PLAIN has a wealth of resources, including the Federal Plain Language Guidelines, training materials and presentations, videos, posters, and references.

Summary

You now know that policies need supporting documents to give them context and meaningful application. Standards, guidelines, and procedures provide a means to communicate specific ways to implement our policies. We create our organizational standards, which specify the requirements for each policy. We offer guidelines to help people comply with standards. We create sets of instructions known as procedures so tasks are consistently performed. The format of our procedure—Simple Step, Hierarchical, Graphic, or Flowchart—depends on the complexity of the task and the audience. In addition to our policies, we create plans or programs to provide strategic and tactical instructions and guidance on how to execute an initiative or how to respond to a situation, within a certain timeframe, usually with defined stages and with designated resources.

Writing policy documents is a multistep process. First, we need to define the audience for which the document is intended. Then, we choose the format. Options are to write each policy as a discrete document (singular policy) or to group like policies together (consolidated policy). Lastly, we need to decide upon the structure, including the components to include and in what order.

The first and arguably most important section is the introduction. This is our opportunity to connect with the reader and to convey the meaning and important of our policies. The introduction should be written by the “person in charge,” such as the CEO or President. This person should use the introduction to reinforce company-guiding principles and correlate them with the rules introduced in the security policy.

Specific to each policy are the heading, goals and objectives, the policy statement, and (if applicable) exceptions. The heading identifies the policy by name and provides the reader with an overview of the policy topic or category. The goals and objectives convey what the policy is intended to accomplish. The policy statement is where we lay out the rules that need to be followed and, in some cases, reference the implementation instructions (standards) or corresponding programs. Policy exceptions are agreed waivers that are documented within the policy.

An exemption or waiver process is required for exceptions identified after a policy has been authorized. The policy enforcement clause is where the sanctions for willful non-adherence to the policy are unequivocally stated in order to reinforce the seriousness of compliance. Administrative notations refer the reader to additional information and/or provide a reference to an internal resource. The policy definition section is a glossary of terms, abbreviations, and acronyms used in the document that the reader may be unfamiliar with.

Recognizing that the first impression of a document is based on its style and organization, we studied the work of the Plain Language Movement. Our objective for using plain language is to produce documents that are easy to read, understand, and use. We looked at ten techniques from the Federal Plain Language Guideline that we can (and should) use for writing effective policies. In the next section of the book, we put these newfound skills to use.

Test Your Skills

Multiple Choice Questions

1. The policy hierarchy is the relationships between which of the following?

A. Guiding principles, regulations, laws, and procedures

B. Guiding principles, standards, guidelines, and procedures

C. Guiding principles, instructions, guidelines, and programs

D. None of the above

2. Which of the following statements best describes the purpose of a standard?

A. To state the beliefs of an organization

B. To reflect the guiding principles

C. To dictate mandatory requirements

D. To make suggestions

3. Which of the following statements best describes the purpose of a guideline?

A. To state the beliefs of an organization

B. To reflect the guiding principles

C. To dictate mandatory requirements

D. To make suggestions

4. Which of the following statements best describes the purpose of a baseline?

A. To measure compliance

B. To ensure uniformity across a similar set of devices

C. To ensure uniformity across different devices

D. To make suggestions

5. Simple Step, Hierarchical, Graphic, and Flowchart are examples of which of the following formats?

A. Policy

B. Program

C. Procedure

D. Standard

6. Which of the following terms best describes instructions and guidance on how to execute an initiative or how to respond to a situation, within a certain timeframe, usually with defined stages and with designated resources?

A. Plan

B. Policy

C. Procedure

D. Package

7. Which of the following statements best describes a disadvantage to using the singular policy format?

A. The policy can be short.

B. The policy can be targeted.

C. You may end up with too many policies to maintain.

D. The policy can easily be updated.

8. Which of the following statements best describes a disadvantage to using the consolidated policy format?

A. Consistent language is used throughout the document.

B. Only one policy document must be maintained.

C. The format must include a composite management statement.

D. The potential size of the document.

9. Policies, standards, guidelines, and procedures should all be in the same document.

A. True

B. False

C. Only if the company is multinational

D. Only if the documents have the same author

10. Version control is the management of changes to a document and should include which of the following elements?

A. Version or revision number

B. Date of authorization

C. Change description

D. All of the above

11. Which of the following is not a policy introduction objective?

A. To convey the importance of understanding and adhering to the policy

B. To provide explicit instructions on how to comply with the policy

C. To explain the exemption process as well as the consequence of non-compliance

D. To thank the reader and to reinforce the authority of the policy

12. The name of the policy, policy number, and overview belong in which of the following sections?

A. Introduction

B. Policy Heading

C. Policy Goals and Objectives

D. Policy Statement

13. The aim or intent of a policy is stated in the ________.

A. introduction

B. policy heading

C. policy goals and objectives

D. policy statement

14. Which of the following statements is true?

A. A security policy should only include one objective.

B. A security policy should not include any exceptions.

C. A security policy should not include a glossary.

D. A security policy should not list all step-by-step measures that need to be taken.

15. The _________ contains the rules that must be followed.

A. policy heading

B. policy statement

C. policy enforcement clause

D. policy goals and objectives

16. A policy should be considered _____.

A. mandatory

B. discretionary

C. situational

D. optional

17. Which of the following best describes policy definitions?

A. A glossary of terms used

B. A detailed list of the possible penalties associated with breaking rules set forth in the policy

C. A list of all the members of the security policy creation team

D. None of the above

18. The _________ contains the penalties that would apply if a portion of the security policy were to be ignored by an employee.

A. policy heading

B. policy statement

C. policy enforcement clause

D. policy statement of authority

19. What component of a security policy does the following phrase belong to? “Wireless networks are allowed only if they are separate and distinct from the corporate network.”

A. Introduction

B. Administrative notation

C. The policy heading

D. The policy statement

20. There may be situations where it is not possible to comply with a policy directive. Where should the exemption or waiver process be explained?

A. Introduction

B. The policy statement

C. The policy enforcement clause

D. The policy exceptions

21. The name of the person/group (for example, executive committee) that authorized the policy should be included in ___________________.

A. the version control table or the policy statement

B. the heading or the policy statement

C. the policy statement or the policy exceptions

D. the version control table or the policy heading

22. When you’re drafting a list of exceptions for a security policy, the language should _________________.

A. be as specific as possible

B. be as vague as possible

C. reference another, dedicated document

D. None of the above

23. If supporting documentation would be of use to the reader, it should be __________________.

A. included in full in the policy document

B. ignored because supporting documentation does not belong in a policy document

C. listed in either the Policy Heading or Administrative Notation section

D. included in a policy appendix

24. When writing a policy, standard, guideline, or procedure, you should use language that is ___________.

A. technical

B. clear and concise

C. legalese

D. complex

25. Readers prefer “plain language” because it __________________.

A. helps them locate pertinent information

B. helps them understand the information

C. saves time

D. All of the above

26. Which of the following is not a characteristic of plain language?

A. Short sentences

B. Using active voice

C. Technical jargon

D. Seven or fewer lines per paragraph

27. Which of the following terms is best to use when indicating a mandatory requirement?

A. must

B. shall

C. should not

D. may not

28. A company that uses the term “employees” to refer to workers who are on the company payroll should refer to them throughout their policies as _________.

A. workforce members

B. employees

C. hired hands

D. workers

29. “The ball was thrown by Sam to Sally” is a passive sentence. Which of the following sentences represents an active version of this sentence?

A. The ball was thrown to Sally by Sam.

B. Sally caught the ball.

C. Sam threw the ball to Sally.

D. The ball was thrown by Sam to Sally, who caught it.

30. Even the best-written policy will fail if which of the following is true?

A. The policy is too long.

B. The policy is mandated by the government.

C. The policy doesn’t have the support of management.

D. All of the above.

Exercises

Exercise 2.1: Creating Standards, Guidelines, and Procedures

The University System has a policy that states “All students must comply with their campus attendance standard.”

1. You are tasked with developing a standard that documents the mandatory requirements (for example, how many classes can be missed without penalty). Include at least four requirements.

2. Create a guideline to help students adhere to the standard you created.

3. Create a procedure for requesting exemptions to the policy.

Exercise 2.2: Writing Policy Statements

1. Who would be the target audience for a policy related to campus elections?

2. Keeping in mind the target audience, compose a policy statement related to campus elections.

3. Compose an enforcement clause.

Exercise 2.3: Writing a Policy Introduction

1. Write an introduction to the policy you created in Exercise 2.2.

2. Generally an introduction is signed by an authority. Who would be the appropriate party to sign the introduction?

3. Write an exception clause.

Exercise 2.4: Writing Policy Definitions

1. The purpose of policy definitions is to clarify ambiguous terms. If you were writing a policy for an on-campus student audience, what criteria would you use to determine which terms should have definitions?

2. What are some examples of terms you would define?

Exercise 2.5: Using Clear Language

1. Identify the passive verb in each of the following lines. Hint: Test by inserting a subject (for example, he or we) before the verb.

Image

2. Shorten the following phrases (for example, “Consideration should be given to” can be shortened to “consider”).

Image

3. Delete the redundant modifiers (for example, for “actual facts,” you would delete the word “actual”):

a) Honest truth

b) End result

c) Separate out

d) Start over again

e) Symmetrical in form

f) Narrow down

Projects

Project 2.1: Categorizing a Real Security Policy

1. Search online for “Tufts University Information Technology Resources Security Policy.”

2. Read the document. Identify the policy components that were covered in this chapter.

3. What is the last modified date of the policy? Does the date influence your opinion of the policy?

4. Choose a couple terms in the policy that are not defined in the Policy Definitions section and write a definition for each.

Project 2.2: Analyzing the Enterprise Security Policy for the State of New York

1. Search online for the “State of New York Cyber Security Policy P03-002” document.

2. Read the policy. What is your overall opinion of the policy?

3. What is the purpose of the italic format? In your opinion, is it useful or distracting?

4. The reference to the “Definitions and Acronyms” document in the policy is incorrect. The correct reference is www.dhses.ny.gov/ocs/resources/documents/Definitions-Acronyms.pdf. What are the pros and cons of having a single glossary?

5. The policy references standards and procedures. Identify at least one instance of each. Can you find any examples of where a standard, guideline, or procedure is embedded in the policy document?

Project 2.3: Testing the Clarity of a Policy Document

1. Locate your school’s information security policy. (It may have a different name.)

2. Select a section of the policy and use the U.S. Army’s Clarity Index to evaluate the ease of reading (reference the “In Practice: U.S. Army Clarity Index” sidebar for instructions).

3. Explain how you would make the policy more readable.

References

1. Baldwin, C. Plain language and the document revolution. Washington, D.C.: Lamplighter, 1999.

Regulations and Directives Cited

Carter, J. “Executive Order—Improving Government Regulations,” accessed 05/2013, www.presidency.ucsb.edu/ws/?pid=30539.

Clinton, W. “President Clinton’s Memorandum on Plain Language in Government Writing,” accessed 05/2013, www.plainlanguage.gov/whatisPL/govmandates/memo.cfm.

Obama, B. “Executive Order 13563—Improving Regulation and Regulatory Review,” accessed 05/2013, www.whitehouse.gov/the-press-office/2011/01/18/improving-regulation-and-regulatory-review-executive-order.

“Plain Writing Act of 2010” PUBLIC LAW 111–274, Oct. 13, 2010, accessed 05/2013, www.gpo.gov/fdsys/pkg/PLAW-111publ274/.../PLAW-111publ274.pdf.

Other References

Krause, Micki, CISSP, and Harold F. Tipton, CISSP. Information Security Management Handbook, Fifth Edition. Boca Raton, FL: CRC Press, Auerbach Publications, 2004.

“Tufts University Information Technology Resource Security Policy.” Tufts University, accessed 05/2013, www.tufts.edu/tccs/p-resourcesec1.shtml.

Smith, T. “State of New York, Cyber-Security Policy P03-002,” Office of CyberSecurity, accessed 05/2013, www.dhses.ny.gov/.../documents/Cyber-Security-Policy-P03-002-V3.4.pdf.

Smith, T. “State of New York, Cyber Security Policies, Standards and Guidelines Definitions & Acronyms,” accessed 05/20/2013, www.dhses.ny.gov/ocs/resources/documents/Definitions-Acronyms.pdf.

Official website of PLAIN, accessed 05/2013, www.plainlanguage.gov.

“Pacific Offshore Cetacean Take Reduction Plan: Section 229.31,” PLAIN, accessed 05/20/2013, www.plainlanguage.gov/examples/before_after/regfisheries.cfm.

“Federal Plan Language Guidelines,” PLAIN, accessed 05/2013, www.plainlanguage.gov/howto/guidelines/FederalPLGuidelines/index.cfm.

“Action Officer Development Course, Staff Writing Module,” United States Army Training and Doctrine Command, accessed 05/2013, www.plainlanguage.gov/resources/take_training/index.cfm.

Mazur, B. “Revisiting Plan Language,” accessed 05/2013, www.plainlanguage.gov/whatisPL/history/mazur.cfm. Originally published in the May 2000 (Vol. 47, No. 2) issue of Technical Communication, The Journal of the Society for Technical Communication.

Kimble, J. “The Elements of Plain Language,” accessed 05/2013, www.plainlanguage.gov/whatisPL/definitions/Kimble.cfm.

“Various Plain English Statutes,” accessed 05/2013, www.languageandlaw.org/TEXTS/STATS/PLAINENG.HTM.

“Before and After,” Plain English Campaign, accessed 05/2013, www.plainenglish.co.uk.

“The Writing Clarity Rating,” accessed 05/2013, www.infogineering.net/writing-clarity-rating.htm.

“A Plain English Handbook: How to Create Clear SEC Disclosure Documents,” Securities and Exchange Commission, accessed 05/2013, www.sec.gov/news/extra/handbook.htm.

“Resources for Trainers—Class Exercises and Answers,” accessed 05/2013, www.plainlanguage.gov/resources/for_trainers/PLAIN.cfm.

Buffet, W. Preface to the Securities and Exchange Commission’s “A Plain English Handbook: How to Create Clear SEC Disclosure Documents,” accessed 05/2013, www.sec.gov/news/extra/handbook.htm.

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