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[Editor's Note: Cybersecurity Law & Strategy received two separate and unique pitches on the same idea — that CISOs reporting to CIOs creates inherent conflict and can actually harm the security of the organization. This article, by Board of Editors member Kenya Parrish-Dixon, echoes the sentiments presented in Jake Frazier's article in the April issue, yet provides a different perspective on the topic, doing a deeper dive into why the roles should be separate.]
Where the chief information security officer sits within an organizational structure has been debated for years. The issue was presumably resolved when the "chief" was added to the title. This clearly moves an information security officer or security officer into the C-suite among other executives that report directly to the president and CEO of an organization and its board members. Moreover, once the Sarbanes-Oxley Act was passed mandating CISO independence for the financial sector under its "separation of duty" requirement, all third-party service providers to the financial sector should have followed suit. However, the intensity of information security briefings often leads to organizations tucking the CISO under the CIO instead. After all, all technology is related, right? This is a huge mistake, and it is wreaking havoc on American data security.
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