The Internet Security Alliance (ISA) Submits comments to DHS on ISAO initiative

Goal of the Best Practice Process Should be Increased Actionable Information and Improved Overall Cyber security -- The ultimate goal of the standards organization in identifying the best practices for ISAOs should not simply be to increase the amount of information shared. The goal needs be an increase in actionable information that increases cyber security.

Need to Get Increased Involvement from SMB Community – In today’s threat landscape, small businesses and third party vendors are increasingly becoming the launching point for malicious attackers attempting to gain access to sensitive data. The ISAO best practices process will need to find smaller organizations appropriate market incentives to participate in the system.

Standards Organization Should be a Not for Profit Organization and Should Have Experience in a Multi-Stakeholder Process -- the organization that sets rules for the ISAOs needs to be free of cultural bias, and the appearance of a vested corporate interest.

Process being undertaken by Standards Organization Needs to be Industry-Led -- To prevent even the appearance of inappropriate government influence in the information sharing or standards development process, the Standards Organization should be an organization that is not a governmental organization or an organization that depends upon a Federal Department or Agency for its operation.

Standards Organization Should Build upon Existing Framework -- It is essential that the Standards Organization understands and builds upon the existing information sharing organizations, models, and operations. There is a wealth of experience in how to share information effectively.

Selected Standards Organization Needs to Appreciate the International Nature of Cyber Threat and be Respected Internationally -- Since the cyber threat environment is global and information sharing takes place in a global context, the selected standards organization should be one that is recognized and respected internationally.