Implementation Strategy Development for Security and Privacy Controls
Implementation Strategy Development is a critical phase in the Governance, Risk, and Compliance (GRC) lifecycle that focuses on creating a structured, repeatable, and effective plan for deploying security and privacy controls across an organization. This guide covers everything you need to know for exam success.
Why Is Implementation Strategy Development Important?
Organizations cannot simply select controls and deploy them haphazardly. Without a deliberate strategy, implementations may be:
• Incomplete: Key controls may be missed or only partially implemented, leaving gaps in the security posture.
• Inconsistent: Different teams may implement the same control in different ways, leading to confusion and audit findings.
• Inefficient: Resources (time, money, personnel) may be wasted on low-priority controls while critical risks remain unaddressed.
• Non-compliant: Regulatory and contractual obligations may not be met if implementation is not aligned with applicable frameworks (e.g., NIST SP 800-53, ISO 27001, GDPR).
A well-developed implementation strategy ensures that controls are deployed in a prioritized, consistent, resource-efficient, and measurable manner that supports the organization's mission and risk management objectives.
What Is Implementation Strategy Development?
Implementation Strategy Development is the process of planning how selected security and privacy controls will be put into operation. It bridges the gap between control selection (deciding what controls are needed) and control assessment (verifying that controls work as intended).
Key components of an implementation strategy include:
1. Prioritization of Controls
Not all controls can be implemented simultaneously. The strategy must establish an order of implementation based on:
- Risk severity and likelihood
- Regulatory or compliance deadlines
- Dependencies between controls (some controls must be in place before others can function)
- Organizational readiness
2. Resource Allocation
The strategy identifies and assigns the necessary resources, including:
- Budget and funding sources
- Personnel and skill sets required
- Technology and tools needed
- Time estimates and scheduling
3. Roles and Responsibilities
Clearly defining who is responsible for implementing each control, including:
- System owners
- Information system security officers (ISSOs)
- Control implementers (IT staff, developers, administrators)
- Oversight and governance bodies
4. Implementation Approach
Determining the method of implementation, such as:
- Phased approach: Rolling out controls in stages across different systems or business units
- Parallel approach: Implementing multiple controls simultaneously where resources allow
- Pilot approach: Testing controls in a limited environment before full deployment
- Big bang approach: Deploying all controls at once (less common and higher risk)
5. Common Control Identification
Identifying controls that can be implemented once and inherited by multiple systems (common controls), versus those that must be implemented on a system-specific or hybrid basis. This reduces duplication and increases efficiency.
6. Documentation Requirements
Establishing what documentation is required, such as:
- System Security Plans (SSPs)
- Implementation plans and schedules
- Configuration standards and baselines
- Standard operating procedures (SOPs)
7. Integration with Enterprise Architecture
Ensuring the implementation strategy aligns with the organization's enterprise architecture, including existing technology stacks, network design, and business processes.
8. Risk Acceptance and Tailoring
Determining where compensating controls, risk acceptance decisions, or tailored implementations are appropriate when standard control implementation is not feasible.
How Does Implementation Strategy Development Work?
The process typically follows these steps:
Step 1: Review Control Selection Outputs
Start with the list of controls selected during the risk assessment and control selection phases. Understand the control baselines, overlays, and any tailoring that has been performed.
Step 2: Conduct a Gap Analysis
Compare the current state of the organization's controls against the desired state. Identify which controls are already in place, which are partially implemented, and which are entirely missing.
Step 3: Prioritize Based on Risk
Use risk assessment results to prioritize implementation. Controls that mitigate the highest risks or are required by imminent compliance deadlines should be addressed first. Consider using a risk register or heat map to visualize priorities.
Step 4: Identify Common, Hybrid, and System-Specific Controls
Categorize each control to determine the most efficient implementation path:
- Common controls: Managed centrally and inherited by multiple systems (e.g., physical security, organizational policies)
- System-specific controls: Unique to a single system (e.g., application-level access controls)
- Hybrid controls: Partially common and partially system-specific
Step 5: Develop the Implementation Plan
Create a detailed project plan that includes:
- Milestones and timelines
- Resource assignments
- Dependencies and sequencing
- Success criteria and metrics
- Communication plans for stakeholders
Step 6: Coordinate Across Stakeholders
Engage all relevant parties, including system owners, authorizing officials, privacy officers, IT operations, and business unit leaders. Ensure buy-in and alignment.
Step 7: Execute and Monitor
Begin implementation according to the plan, continuously monitoring progress against milestones. Adjust the strategy as needed based on emerging risks, resource constraints, or organizational changes.
Step 8: Document Implementation Details
Record how each control was implemented, including configuration settings, responsible parties, and any deviations from the original plan. This documentation feeds directly into the System Security Plan (SSP) and supports future assessment activities.
Key Frameworks and Standards
Understanding how implementation strategy development fits within major frameworks is essential:
• NIST Risk Management Framework (RMF): Implementation occurs in Step 3 (Implement). The strategy ensures controls selected in Step 2 (Select) are properly deployed before assessment in Step 4 (Assess).
• NIST SP 800-53: Provides the catalog of controls that the implementation strategy must address.
• NIST SP 800-53A: Guides how implemented controls will be assessed, so the strategy should anticipate assessment requirements.
• ISO 27001: Requires a Statement of Applicability (SoA) and risk treatment plan that functions similarly to an implementation strategy.
• COBIT: Emphasizes governance and management objectives that guide implementation priorities.
Common Challenges in Implementation Strategy Development
• Insufficient resources or competing priorities
• Lack of executive sponsorship or organizational buy-in
• Poor communication between security teams and system owners
• Overly complex or unrealistic timelines
• Failure to account for system interdependencies
• Inadequate documentation leading to difficulties during assessment
• Resistance to change from operational teams
Exam Tips: Answering Questions on Implementation Strategy Development
1. Know the Sequence: Implementation strategy development comes AFTER control selection and BEFORE control assessment. If a question asks about the order of RMF steps, remember: Categorize → Select → Implement → Assess → Authorize → Monitor.
2. Understand Common vs. System-Specific vs. Hybrid Controls: Exam questions frequently test your ability to distinguish between these three types. Common controls are inherited, system-specific are unique to one system, and hybrid controls are a combination. Know that identifying common controls is a key efficiency strategy.
3. Prioritization is Risk-Based: If a question asks how to prioritize control implementation, the answer almost always involves risk. Controls that address the highest risks should be implemented first. Compliance deadlines may also drive prioritization.
4. Look for Keywords: Questions may use terms like implementation plan, deployment strategy, phased approach, resource allocation, gap analysis, or risk treatment plan. These all relate to implementation strategy development.
5. Documentation Matters: Many exam questions test whether you understand that implementation must be documented. The System Security Plan (SSP) should reflect how controls are actually implemented, not just what was planned.
6. Roles and Responsibilities: Know who is responsible for what. The system owner is typically responsible for ensuring controls are implemented. The authorizing official accepts risk. The ISSO supports the system owner. Control implementation is often performed by IT staff, developers, or system administrators.
7. Compensating Controls: If a question describes a scenario where a required control cannot be implemented as prescribed, look for answers involving compensating controls or risk acceptance with appropriate documentation and approval.
8. Beware of Absolute Language: Answers that use words like always, never, all, or none are often incorrect. Implementation strategies must be flexible and tailored to organizational context.
9. Integration Questions: Be prepared for questions about how implementation strategy relates to enterprise architecture, system development life cycle (SDLC), and configuration management. Controls should be integrated into existing processes, not treated as standalone activities.
10. Scenario-Based Questions: For scenario questions, focus on identifying the most appropriate next step. If controls have been selected but not yet deployed, the answer is likely related to developing or executing an implementation strategy. If controls are deployed but not verified, the answer moves to assessment.
11. Cost-Effectiveness: The best implementation strategies maximize security improvement per dollar spent. If a question asks about optimizing implementation, think about leveraging common controls, automating where possible, and addressing highest-risk items first.
12. Remember the Goal: The ultimate purpose of implementation strategy development is to ensure that selected controls are effectively and efficiently put into operation so that organizational risk is reduced to an acceptable level. Keep this goal in mind when evaluating answer choices.
