IT Governance and Change Management Proposal Education Department Western Australia (Case Analysis)
1. Executive Summary
From recent information
technology (IT) audit cycles during 2017 and 2019, multi-agencies of Western
Australian (WA) State have resulted similar undesirable conclusions reported by
WA Audit General. The audit findings were strongly concerned with weaknesses of
IT security and business continuity across the agencies. To rectify these year-after-year
issues, WA Department of Education (DoE) takes the initiative to design and
implement a new governance framework as the first pilot to improve the IT
governance system in responding to the weaknesses addressed in the audit
reports. Control Objectives for Information and Related Technologies (COBIT)
2019 is used for the design of governance system, and Queensland Change
Management Plan Workbook and Template is used for managing the implementation to ensure the
effectiveness and its sustainability.
This proposal
will provide an overview of the WA Audit General’s reports and DoE background.
It will also analyse COBIT19 core models to produce an effective design of IT governance
system and develop a sustainable change management for its implementation.
2. Understanding the Background
WA Audit General performed comprehensive IT audits between
2016 and 2018 across 14 agencies. The reports of 3 audits revealed that control
weaknesses have been found existing repeatedly around IT system security,
security of sensitive information and business continuity, arising in
application control and general computer controls (Auditor General Western Australia 2017, 2018, 2019).
In July 2017, DoE was reformed by merging the
Department of Education and Department of Education Services. The Department’s role
has been influencing the whole education system in Western Australia (Department of Education 2018a). Since 2018, the department’s strategic plan is to provide
up-to-date curriculum, high quality teaching, effective leadership, good
governance, safe learning environment and strong collaboration (Department of Education 2018b). All schools are using Standing Operating Environment (SOE)
for delivering online learning and content (MLA 2012). More than 100,000 of
student, parents and teacher are using online communication (Connect) platform
across 75 schools compared to approximately 70,000 users during last year (Department of Education 2018a).
As coupled the IT security weaknesses in WA agencies, and
the growth of users on the online services in DoE, the department could face severe
consequences ranking from disruption of online learning delivery due to system
failures to personal information exposure in the events of data breach.
3. The Design of Governance Framework
3.1. Overview of COBIT19
COBIT19 is a
framework for management and governance of IT. It guides enterprises how to develop
an IT governance system, based on enterprise’s goals, with a dynamic and
holistic approach that provides stakeholder value. It also focuses on
end-to-end and tailored system where governance and management activities are
clearly distinct (ISACA 2018b, 2018c).
3.2. Identifying and Analysing COBIT Core Models
To identify the governance
and management objectives and practices, it is necessary to understand and
associate the DoE environment with COBIT design factors. Below are the significant
factors that drive decision making in achieving the governance system in DoE.
i.
Strategy:
DoE is a government agency and is currently focusing delivering
high quality of education while facing financial constraint (Department of Education 2018a). As a result, the primary focus of the department is to
provide stable service and the secondary focus is to minimise cost.
ii. Goals:
DoE’s goal also pays high attention on information
security and business continuity improvement.
Based on COBIT mapping table and an analysis of
significant prioritisation (See Appendix 1), there is 1 governance
objective and 3 management objectives that need to be adhered by to strengthen
IT governance system. The governance objective is to optimise risk (EDM03),
while management objectives are to manage security services (DSS05), continuity
(DSS04) and security (APO13).
3.3. Defining Key Practices and Challenges
3.3.1. EDM03 – Risk Optimisation
This governance objective is to ensure that IT-related
risks in DoE are optimised and it is below department’s risk appetite and
tolerance. Also, the impact of the risks is identified and managed. Governance
bodies of the department must be the key involvement in implementing relevant
practices including evaluating, directing and monitoring the risk management.
To ensure that the processes are effectively employed,
Minister of Education and Training should take the accountability while Director
and Deputy Director General Department of Education as well as Chief
Information Officer and Director ICT Governance and Planning should take
responsibility of practices performance.
By properly evaluating IT risks, IT security and
business continuity risks in DoE are assessed and properly defined, and thus
the establishment of related practices to manage the risks are being acknowledged
and enforced more effectively. But there might be some cultural challenges
involved since the ownership acceptance and commitment from Minister of
Education and Training who is accountable for this object is required.
3.3.2. APO13 – Security Management
This management objective is to limit the occurrence and
severity of information incidents in DoE – to below risk appetite level. To
achieve the objective, firstly, information security management system (ISMS) including
standards, policy and approaches to secure technology and business processes
need to be established and maintained in alignment with business needs. Then, a
treatment plan is to be defined according to business cases with a
comprehensive recommendation of how the risks are managed. Also, regular communication of the plan and
updates must be in place to provide ongoing assessment of the ISMS and its
improvement.
Managing security requires Chief Information Security
Officer’s (CISO) accountability in achieving it. However, since DoE does not
have CISO (Department of Education 2018a, p. 186), this role should be temporary taken by CIO while other
underline levels need to be delegated other responsibilities (See Appendix 2).
The proper implementation of security practices enables
DoE to identify information security risks that the department is prone to and
to develop a reasonable approach to address them in a cost-effective manner.
For instance, the department might focus on the risks related could-based solution
since student learning platform is an online solution. The main limitation that
DoE is facing while adopting these practices is competency shortage. The
department may need to employ a CISO who have enough skill and experience in
information security strategy to lead the adaptation and to influence the aware
of its necessity.
3.3.3. DSS04 – Continuity
Management
This COBIT core model is to make business and IT
organisation properly respond to events causing business disruption. The
important practices that DoE necessarily performs include defining continuity
plan objectives and scope, developing and documenting business continuity plan
(BCP) and disaster recovery plan (DRP). Training must also be provided to all
relevant internal and external people, and the BCP and DRP test and assessment
should be conducted regularly.
Deputy Director General Education Business Services
should take the accountability of this core model and assign various
responsibilities to other executives and directors underneath (See Appendix 2).
The benefit of this objective is to provide DoE a set
of controls safeguarding the continuous availability of business operation. In
the fact that the department using online solution to manage student information
and learning, solid plans such deploying secondary cloud solution and having
regular data replication can be defined as parts of the scope to ensure the
online service continuity. Nevertheless, there are some challenges related to
staff training because there are over thousands of stuff across the department
and schools (Department of Education 2018a), and might not be cost-effective to acquire additional
services.
3.3.4. DSS05 – Managed Security
Services
To answer the DoE’s
primary focus – information security, this objective allows the department to create
more concrete elements to protect information form identified information
security risks and to minimise the impact of any incidents. To succeed that, various
practices may also be required such as managing network and infrastructure
security, user identity management, logical and physical accesses, and
protecting the systems from malicious software.
It is also a key
difficulty that all the practices need a competent CISO to be accountable for those
beneath managements who are have responsibility to make it happen (See Appendix 2). In addition, it is a cost incurrence as comprehensive tools need to be
employed – for example, security information and event management (SIEM), and
it also involves culture adaptation to a more restrictive environment of user
devices when identity and access management systems are implemented.
4. Change Management Strategy
4.1. Change Vision
This change management is made for IT governance system
improvement. It will affect some changes in policies and processes in DoE. It aims
to enhance IT system security, information security and business continuity.
Without the improvement of IT governance, the risks associated to IT security and
business continuity are less likely to be minimised while the scale of
information is increasing. Failing to protect the information will result great
reputation loss and make WA citizen’s personal information exposed to malicious
activists.
4.2. Change Detail
Structure Change
1. CIO’s role needs to be
temporarily modified by including accountable and responsible for information
security risk management until the department may place a CISO.
2. CISO will have an
independent office to oversee and operate all the information security matters
and implementation.
People and Skills
Pre-requisite skills such as security service tools should be
provided to IT team under CIO and CISO offices.
4.3. Approach
Stakeholders
Participating Level
|
Stakeholders
|
Driver
|
1.
Minister of Education and Training
2.
Director General Department of Education
3.
Deputy Director General Education Business Services
|
Advocating
|
1.
Chief Information Officer
2.
Director ICT Operations and Customer Services
3.
Director ICT Governance and Planning
4.
Director Integration, Build and Deployment
|
Active Participants
|
Relevant department
officers who are working under the 4 Advocative.
|
Willingness
|
1.
WA Audit General
2.
Executive Director Finance and Commercial Services
|
Understanding
|
Director Business and
Customer Services
|
Resistance Management:
Survey is to be conducted
before the implementation start targeting CIO, Director ICT Operations and
Customer Services, Director ICT Governance and Planning, and Director
Integration, Build and Deployment offices to ensure all key players clearly
understand the vision and to foresee future barriers.
Role
|
Member
|
Project Steering Committee
|
1. Minister of Education and
Training
2.
Director General Department of Education
3.
Deputy Director General Education Business Services
|
Project Manager
|
Chief
Information Officer
|
Communication Manager
|
Director
ICT Governance and Planning
|
Governance
Integration Manager
|
Director ICT Operations and Customer Services
|
Process
Integration Manager
|
Director Integration, Build and Deployment
|
4.4.
Strategy
Action
Plan
1. Communication the change
2. Pre-implementation survey
3. Pre-requisite skill training
4. Governance objective
implementation
5. Management objective
implementation
6. Awareness training
7. Feedback survey
8. Close of project
Communication
Plan:
1. Vision
2. Key management involvement
3. Project timeline
4. Pre-requisite skill training
5. Implementation specification
6. Awareness training
7. Close of the project
Training
Plan
1. Overview of COBIT19 (For
Executive and Director levels)
2. Security awareness (For
everyone)
3. Business continuity (For
everyone)
4. Disaster recovery (For IT
team responsible for recovering system)
5. Security incident response
(For IT team responsible for IT Security monitoring)
Resistance
Plan
From
the survey completed from the previous stage, it can identify who are likely to
resist to the change in the department. The Project Communication Manager then
can conduct a consultation meeting to assure that the resistance is caused by
misunderstanding of the key message delivery or other factors and to find
further remedial actions (See Appendix 6 for common change
resistance and overcome factors).
4.5.
On-going Monitoring
and Review
Upon the
completion of the implementation, DoE should consolidate all the strengths and challenges,
and properly document them as key lessons learn. This document can be used for evaluating
the post implementation performance and effectiveness. In additional, regular
on-going internal audit function should be performed to monitor the consistency
of the performance. Where any business process changes are required, the IT
governance should be re-evaluated, and new directions should be provided to
align those changes.
5.
Conclusion
In conclusion,
this report is written as a solution to strengthen IT governance coping with IT
system security, information security and business continuity weaknesses
addressed by Western Australian Audit General in the context of piloting in
Department of Education. four COBIT core models are to be adopted into the
department, including risk optimisation, security management, security service
management and continuity management. To some extent, there are some challenges
foreseen in the new governance system including culture change, competency need
and cost incurrence. However, with the use of adequate change management
(Queensland Change Management Plan Workbook) which responsibilities are communicated,
strategies and approaches are followed, it will ensure that the transition of
the new governance system will not impact daily operations and will be
sustainable in the Department of Education.
6. Appendices
Appendix 1: Mapping Process
From mapping the enterprise
goals (ISACA 2018a, pp. 139-140), it provides the following objectives:
Education Department’s
Goals
|
Remark
|
(EG02) Managed business
risk
(EG06) Business continuity
|
Based on 2 the goal of
ensuring IT security and business continuity.
|
Alignment Goals
|
Remark
|
(AG07) Security of information,
processing, infrastructure and application and privacy
|
AG03 is excluded because
most of its objectives are the same as AG07 and it is less significant.
|
Governance and Management
Objectives
|
Remark
|
(EDM03) Ensure risk
optimisation
(APO13) Managed security
(DSS04) Managed continuity
(DSS05) Managed security
Services
|
APO12 and BAI10 are
excluded because they are less significant and due to DoE budget constraint.
|
Appendix 2: RACI Charts
Security Management
Continuity
Management
Management Practices
|
Deputy Director General Education Business
Services
|
Chief Information Officer
|
Director Business and Customer Services
|
Director ICT Operations and Customer
Service
|
Director ICT Governance and Planning
|
Director Integration, Build and Deployment
|
Information Security Manager
|
1.
Identifying plan object and scope
|
A
|
R
|
R
|
C
|
I
|
R
|
I
|
2.
Developing and documenting business continuity plan (BCP)
and disaster recovery plan (DRP).
|
A
|
R
|
R
|
C
|
I
|
R
|
I
|
3.
Reviewing and test the plan
|
A
|
R
|
R
|
R
|
C
|
R
|
I
|
4.
Conduct training
|
A
|
I
|
R
|
C
|
C
|
I
|
I
|
Security
Services Management
Management Practices
|
Chief Information Officer
|
Director Business and Customer Services
|
Director ICT Operations and Customer
Service
|
Director ICT Governance and Planning
|
Director Integration, Build and Deployment
|
Information Security Manager
|
1.
Network and infrastructure security
|
A
|
I
|
R
|
I
|
R
|
C
|
2.
User identity and logical access
|
A
|
C
|
R
|
I
|
R
|
C
|
3.
Physical access
|
A
|
C
|
R
|
I
|
R
|
C
|
4.
Protecting against malicious software
|
A
|
I
|
R
|
I
|
R
|
C
|
Appendix 3: Action
Plan
Activities
|
Responsible Person
|
Timeframe
|
Communication the change
|
Communication Manager
|
01-Jan to 15-Jan-2020
|
Pre-implementation survey
|
Communication Manager
|
15-Jan to 15-Feb-2020
|
Pre-requisite skill
training
|
Process Integration
Manager
|
15-Feb to 30-Mar-2020
|
Governance objective
implementation
|
Governance Integration
Manager
|
1-Apr to 15-May-2020
|
Management objective
implementation
|
Process Integration
Manager
|
1-Apr to 15-Aug-2020
|
Awareness training
|
Governance Integration
Manager and Process Integration Manager
|
15-Aug to 7-Sep-2020
|
Feedback survey
|
Communication Manager
|
8-Sep to 30-Sep 2020
|
Close of project
|
Chief Information Officer
|
1-Oct-2020
|
Appendix 4: Communication
Plan
What
|
Who
|
How
|
When
|
1.
Vision
|
From: Director General
Department of Education
To: Chief Information Officer, Director ICT Operations and Customer
Services, Director ICT Governance and Planning, Director Integration, Build
and Deployment
|
Meetings
|
After the Proposal Approved
|
2.
Key management involvement
|
From: Project Manager
To: Other Executive and
Director Under Deputy Director General Education Business Services
|
Meetings
|
Early Jan-2020
|
3.
Project timeline
|
From: Project Manager
To: Other Executive and
Director Under Deputy Director General Education Business Services
|
Email and Meeting
|
Early Jan-2020
|
4.
Pre-requisite skill training
|
From: Process Integration
Manager
To: Underneath Team
|
Workshop and Meeting
|
Mid Feb-2020
|
5.
Implementation specification
|
From: Process Integration
Manager
To: Underneath Team
|
Email and Meeting
|
Early Mar-2020
|
6.
Awareness training
|
From: Communication Manager
To: Director ICT Operations and Customer Services, Director
ICT Governance and Planning
Director Integration, Build and Deployment Offices
|
Email
|
Early Aug-2020
|
7.
Close of the project
|
From: Project Manager
To: All offices under Deputy Director General Education
Business Services
|
Email, Department Announcement
|
Early Oct-2020
|
Appendix 5: Training Plan
Module
|
Outcome
|
Delivery Mode
|
Overview of COBIT19
|
-
DoE will understand the benefit of good IT governance.
-
Promoting effectiveness of IT governance in the department
|
Online learning
|
Security awareness
|
-
DoE will understand the significance of IT security.
-
Promoting individual awareness
|
Online learning
|
Business continuity
|
-
DoE will be able to act accordingly in the event of any
business disruption.
|
Workshop
|
Disaster recovery
|
-
DoE will be able to act accordingly in the event of IT
system failures.
|
Workshop
|
Security incident response
|
-
DoE IT team will be able to act accordingly in the event of
IT security breach.
|
Workshop
|
Appendix 6: Change
Resistance Root Causes and Overcome Factors
ISACA (2018d, p. 39) identifies some common root causes and overcome factors of
resistance to change as the table below.
Root causes
|
Overcome Factors
|
-
Misunderstanding the usefulness of the requirements
-
Afraid of increase in workload and cost
-
Unwilling to admit fault
-
Threat to role and power
|
-
Provide awareness based on educating rather than
instructing
-
Employ change agents who have both IT and business
experience
-
Create a sense of success after each implementation
milestone.
-
Boost the sense of recognition in every small win
-
Focus on enabling or empowering people by training,
coaching, mentoring, transferring skills.
|
Reference List
Auditor General Western Australia 2017, Information Systems Audit Report 2017, ISSN: 2200-1921 Western
Australian Auditor General’s Report 7th Floor Albert Facey House 469 Wellington
Street, Perth.
Auditor
General Western Australia 2018, Information
Systems Audit Report 2018, ISSN: 2200-1921, Western Australian Auditor
General’s Report 7th Floor Albert Facey House 469 Wellington Street, Perth.
Auditor
General Western Australia 2019, Information
Systems Audit Report 2019, ISSN: 2200-1921, Western Australian Auditor
General’s Report 7th Floor Albert Facey House 469 Wellington Street, Perth.
Department
of Education 2018a, Department of
Education Annual Report 2017–18 ISSN: 1843–2396 Department of Education - Government of
Western Australia.
Department
of Education 2018b, Strategic Outline,
ISBN 978-0-7307-4617-1, Department of Education Western Australia, 151 Royal
Street East Perth WA 6004.
ISACA
2018a, COBIT® 2019 Design Guide:
Designing an Information and Technology Governance Solution, ISBN
978-1-60420-765-1 ISACA, 1700 E. Golf Road, Suite 400 Schaumburg, IL 60173, USA
.
ISACA
2018b, COBIT® 2019 Framework: Governance
and Management Objectives, ISBN 978-1-60420-764-4, ISACA, 1700 E. Golf
Road, Suite 400 Schaumburg, IL 60173, USA .
ISACA
2018c, COBIT® 2019 Framework:
Introduction and Methodology ISBN 978-1-60420-763-7, ISACA, 1700 E. Golf
Road, Suite 400 Schaumburg, IL 60173, USA .
ISACA
2018d, COBIT® 2019 Implementation Guide:
Implementing and Optimizing an Information and Technology Governance Solution,
ISBN 978-1-60420-766-8, ISACA, 1700 E. Golf Road, Suite 400 Schaumburg, IL
60173, USA .
MLA,
JW 2012, The role of ICT in Western
Australian Education: Living and Working in a Digital World, ISBN:
978-1-921865-59-6, Parliament of Western Australia, Perth, < www.parliament.wa.gov.au/ehsc>.
Queensland
Government Chief Information Officer Change
Management Plan Workbook and Template <http://www.nrm.wa.gov.au/media/10528/change_management_plan_workbook_and_template.pdf>.
Comments
Post a Comment
What do you think?