Safety, Integrity and Availability, are clear priority risk considerations associated with the Power generation sector.
As such, the safety of people, the environment and Power generation operational assets is typically ensured by a combination of mechanical and computerised (i.e., operational technology/industrial control systems) based controls. Combined they are expected to provide process control, safeguarding, dependable real-time data integrity and near-continuous availability to support business operations. With the continued prevalence of digitalisation, convergence and connectivity with popular mainstream technologies, these priority risk considerations are being exposed to a wider range of cyber threats.
In the context of an organisation with no or limited OT cyber security risk management, CNB Tel recommends a holistic approach when defining an effective OT cyber security risk management strategy/programme.
The first step in this journey is to understand risk and consequences to the organisation. At a basic level, this means identifying the most critical OT functions essential to fulfilling the organisation’s business operations, and the potential consequences of a cyber attack against them. The knowledge of an organisation’s system custodians and engineers should be leveraged to identify methods an adversary could use to compromise critical OT functions. This valuable knowledge includes technical system architecture details, procedural and ways of working insights, like logical user access, third-party service provider scope, supply chain considerations, physical security etc. Real-world cyber scenarios seen across industries should be considered, of course, not all will be applicable, but to ensure completeness and due diligence they should be considered.
The ultimate aim of this initial analysis is to identify and prioritise risks that result in high-consequence events for the organisation. It also provides a high-level snapshot of current risk exposure and whether this exposure is within or out of organisational risk appetite/tolerance. Any subsequent OT cyber security strategy/programme and risk mitigations should be aligned accordingly with this analysis to ensure tangible risk reduction that is outcome focused. This approach helps organisations justify OT cyber security improvements and the associated costs by being armed with better information and understanding of “What, Why and How?”
The second stage in the journey sees the definition and establishment of an overarching OT Cyber Security Framework (OT-CSF) that delivers formalised policies, procedures, datasets, work instructions and best practice guidance designed for OT cyber security risk management. The OT-CSF should be aligned accordingly with guidance provided within industry frameworks such as:
The scope and depth of the OT-CSF must be realistic and defined based on factors such as plausible operational business risk and regulatory compliance requirements. An overburdensome OT-CSF may deliver perfect cyber security on paper, but in reality, will likely be ignored or worked around rendering it ineffective. At a minimum, an OT-CSF should include:
Formal governance model (assignment of accountable, responsible, supporting, consulted roles/parties) Formal end-to-end operating model (visualisation of operations through to OT asset/system support) Regulatory compliance requirements (locale/country dependant, e.g. UK/EU NIS, CISA etc) Asset inventorisation/management (listing of OT assets that require run and maintain support) Network architecture documentation (logical and physical diagrams representing as-is architecture and includes all north-south and east-west connectivity) Incident response plan (based on real-world industry scenarios that pose the most risk) Workforce development (minimum training curriculum and awareness for all OT users) Applicable supporting OT cyber security procedural controls (e.g., access control, management of change, portable media management, backup and recovery etc) Basic performance monitoring and reporting (e.g., management reviews and continuous improvement processes)