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Category Archives: architecture
What is reference architecture?

https://hjortberg.substack.com/p/reference-architecture-explained
Great quote from post above by @
great reference architecture doesn’t limit possibilities, it expands them by providing a strong foundation for innovation.
A reference architecture is a recommendation, not a law. It is a flexible, high-level framework that provides guidance and best practices for designing systems in a specific domain. It is not mandatory, not a specific implementation, and not a one-size-fits-all solution. Instead, it serves as a reference point that you can adapt to your unique needs and context.
Business Contextual Architecture – Keelson Management, a wholly owned subsidiary of CMA CMG

This is a follow up post to another one that focuses on Port and Terminal Cybersecurity in general. This post focuses on the business contextual architecture of a company responsible for maritime terminal cybersecurity, Keelson Management. This is another use case for The Agile Security System by @Andrew Townley.
Please refer to others postings on The Agile Security System: 1) Overview of The Agile Security System; 2) Overall approach for producing the output for business contextual architectures and initial observations; 3) the efficiency gains via re-use, iterations, and time boxing of this approach; 4) value of this approach – why and help prioritize tactics; and 5) Developing a cybersecurity objectives or business attributes for a cybersecurity strategy based on mitigations to risks to business objectives.
Let me know what you think!
~R&R,
Everyone Needs Some!
Initial Observations
- In the realm of Maritime Transport Systems (MTS), it’s imperative for organizations to designate a Cybersecurity Officer (CySO). The CySO’s key responsibility revolves around developing, revising, and disseminating a “Cyber Annex” to Facility Security Officers. This annex serves as a guarantee that the cybersecurity measures and risk mitigation efforts pertaining to the facility’s physical security and safety are pertinent and adequate. Essentially, it serves as a strategic roadmap to tackle the cybersecurity challenges inherent in MTS. You can find more details about the Cyber Annex at this link: Cyber Annex Guide. It’s worth noting that while the Cyber Annex is a robust strategy, it may not encompass all potential cybersecurity vulnerabilities or remedies. Some might wonder about the necessity of introducing the “CySO” role (vs “CISO” by the US Coast Guard). Nevertheless, for MTS organizations like Keelson, ensuring a cybersecurity strategy aligns with the security objectives of being “Assured” and “Compliant” are paramount.
- Like organizations in other industries, effective management of cyber risk is critical to the success of an MTS organization. A successful cyber-attack can lead to several risks for US ports and terminals. Refer to the CISA diagram, the Port Facility Cybersecurity risk, for a list of cybersecurity risk. “Risk-Managed’ and “Integrity-Assured” are critical security objectives of any cybersecurity strategy.
- Maritime ports are a rich environment for cyber-attacks. For example, a recent study from Rutgers shows various scenarios of physical and cyber-attacks against MTS organization. MTS organizations need to recognize that cyber-attacks translate to real business risk and need to manage it. MTS organizations need to understand that threat actors are “burrowing” into their environments in preparation for future conflicts (refer to minute 30 [ish] of the US House Select Committee on the CCP, “The CCP Cyber Threat to the American Homeland and National Security,” dated 01/31/2024) “Risk-Managed,” and “Educated” (about cyber-attacks on their operating environment) are key objectives.
- The MTS is an industry that has a very visible intersection between the physical and cybersecurity worlds. The compromise of operational technology (OT) ships or systems ashore can result in considerable harm to personal safety and security of ships, ports and marine facilities. Facility Security Assessments (i.e., physical security risk assessments) , as required by the US Coast Guard as part of their Navigation and Vessel Inspection Circular No. 01-20 (NVIC 01-20), includes a review of computing systems and networks; the goal is to understand if cybersecurity vulnerabilities can be exploited to compromise physical controls. As such, US Coast Guard provides recommendations that MTS organizations create a traceability matrix between cybersecurity vulnerabilities and their associated physical security vulnerabilities. US Coast Guard also recommends a traceability matrix between cybersecurity protections and the cybersecurity vulnerabilities they remediate. “Safe” and “Compliant” are important security objectives that need to be part of cybersecurity strategy.
- Practice. Practice. Practice. Incident Response, Business Continuity plans and alert triage playbooks all need to practiced on a regular basis. IR plans must include contacting the FBI, US Coast Guard (i.e., Captain of the Port), and CISA. “Usable,” “Documented”, “Maintained” and “Governed” are critical objectives for any cybersecurity program.
- MTS organizations should use the NIST Cybersecurity Framework to measure effectiveness via a maturity assessment and benchmarking with peers. I recommend hiring a 3rd party to complete an initial maturity assessment and require them to provide a benchmark of the MTS sector. It is critical that any target maturity needs to be calibrated with the risk management and governance of the organization (i.e., NIST CsF Profile). The US Coast Guard recommends using the NIST Cybersecurity Framework (CSF) as the preferred framework for aligning cybersecurity protections, which includes a baseline with various maturity levels. To simplify implementation, I suggest mapping the NIST CSF to CIS Critical Security Controls, incorporating the CIS Controls ICS Implementation Guide for more practical guidance on control implementation. It’s crucial to extend this mapping to the MITRE ATT&CK framework and ensure that assessments encompass the scope of technology deployment, procedures, and staffing levels/skills. Technology is at best ineffective at worst useless without process, correct staffing levels and skill sets. I also recommend reviewing NIST’s website for latest information on NIST CsF 2.0, including the new “Govern” function and Informative References. Today, there is no Community Profile specific to MTS, although there is one for the PNT. MTS organizations heavily use PNT. As such, “Compliant” “Usable” “Governed” and “Effective” are key attributes or security objectives.
- Threat intelligence and collaboration is critical between organizations and entities in the MTS; this also applies between CMA CMG corporation and their subsidiaries. MTS organization should participate in and contribute to the Maritime Transportation System Information Sharing and Analysis Center and the annual Maritime Cybersecurity Summit . The MTS-ISAC publishes an annual report outlining trends that MTS should be aware of. For example, the 2023 report provides the following reasons for increased risk for MTS organizations: a) geopolitical tension; b) inability for MTS organizations (or governments) to counter or pushing nation states or criminals for cyber-attacks. c) economy is driving underemployed or unemployed to cybercrime; d) MTS organizations lag behind in technology and require modernization; and e) an increase in 3rd party integrations. CMA appears to have a threat intelligence capabilities based on their advisories regarding conflicts in world. “Threat-Managed” is an important security objective of Keelson Management cybersecurity strategy.
- Due to the heavy use of OT, OT Cybersecurity needs to be prioritized in terms skill set and process. Need specialization and support for Operational Technology. NIST has published a guide on OT Security (NIST SP 800-32r, According to attacks on OT systems in the maritime industry has increased by 900% since 2017 (in 2021; see https://sustainableworldports.org/wp-content/uploads/IAPH-Cybersecurity-Guidelines-version-1_0.pdf).
- It is imperative for MTS organizations to ensure the defensibility of their cybersecurity programs. I recently engaged in a conversation with a former Chief Information Security Officer (CISO) from a chip manufacturing company. Despite having a budget that surpassed many other organizations, he acknowledged that his organization still faced successful cybersecurity incidents. Every MTS organization must acknowledge the inevitability of compromises. These organizations cannot solely rely on outspending or outskilling threat actors, particularly those backed by nation states. For instance, according to Chris Way, the Director of the FBI, the People’s Republic of China (PRC) boasts the largest hacking program globally, surpassing the combined efforts of all major countries and outnumbering U.S. government hackers 50 to 1 (refer to minute 20 of the Select Committee on the CCP, “The CCP Cyber Threat to the American Homeland and National Security,” dated 01/31/2024). Furthermore, a 2023 MTS-ISAC report highlighted a concerning trend where countries tend to police MTS victims of cyber-attacks and attribute blame to them, rather than holding accountable the threat actor groups responsible. A critical cybersecurity objective of any cybersecurity program is “Auditable.”
- Network segmentation is critical for MTS organizations. The US Coast Guard published a simple network architecture that highlights an approach to this segmentation.

Initial Questions
- Is the business contextual architecture correct? What is missing?
- Where do requirements for Keelson come from? Below is a listing of sources for potential requirements for a company, like Keelson, operating seaport container terminals in the US. It is imperative for a company to assign a role to consistently review these sources along with others to draft company specific policies and standards and training material. Cybersecurity staff would have to collaborate with legal and compliance teams. Here is a quick list of potential sources: a) International Association of Ports and Harbors (IAPH); b) US Coast Guard (USCG). US Coast Guard has published several guidance documents: i) Navigation and Vessel Inspection Circular (NVIC 01-20) ; ii) Maritime Cybersecurity Assessment and Annex Guide (MCAAG); c) Cybersecurity and Infrastructure Security Agency (CISA); d) Baltic and International Maritime Council (BIMCO); e) International Maritime Organization (IMO).; f) Jones Walker Survey ; g) ISO/IEC 27001; h) Executive Order on Amending Regulations Relating to the Safeguarding of Vessels, Harbors, Ports, and Waterfront Facilities of the United States; h) NIST Cybersecurity Framework (version 2.0); i) Corporate CMA CMG Policies and Standards.
- Are the roles and responsibilities been clearly defined by CMA and Keelson? Why was Keelson originally setup as a wholly owned subsidiary of CMA?
Business Contextual Architecture – SC Johnson & Son, A Manufacturer and the Value of Re-Usable Architecture

Greetings, fellow architect or cybersecurity strategist! Imagine if you had a looming deadline and a meeting scheduled with a stakeholder in just two hours, especially as a newcomer to the company or potentially a new customer, preparation is key.
In tackling this challenge, consider leveraging the Agile Security System (TASS) for a streamlined approach.
Note: for a deeper understanding of the methodology, refer to the insights provided in the Rogers post.
This article, however, won’t introduce new techniques; instead, it underscores the efficacy of TASS, particularly in swiftly delivering a business contextual architecture. The swiftness of TASS is attributed to key factors: simplicity over complicated models in software, a focus on iterations over perfectionism, and a commitment to re-usability.
In terms of re-usability (#3), it’s noteworthy that the domain impact worksheet incorporates elements from another manufacturing company, ON. This re-usability extends beyond the worksheet itself to encompass requirements, risks, mitigations, and even initial observations and questions specific to a particular domain. The versatility of TASS lies in its ability to adapt and apply proven elements across various aspects, facilitating a more efficient and effective approach to cybersecurity strategy. A word of caution though: do not the let beauty of this approach turn you into a “lazy” (not in smart way) and “autopilot architect.”
I prefer to “practice what I preach,” hence I’ve established a two-hour time limit to complete this post. This includes conducting research, developing the domain impact worksheet, formulating observations and questions, and finally, posting the content on the blog. And yes, I leverage ChatGPT to help improve how some of the content is written. Hopefully, ChatGPT doesn’t completely eliminate my personality from the writing!
Let me know what you think!
~R&R,
Everyone Needs Some!
Initial Observations
| Observation | Re-useable | Detailed Information |
| SC Johnson must protect their intellectual property (IP | Yes | See ON Semiconductor posting |
| SC Johnson must have advanced capabilities in intrusion detection, web security, threat intelligence, and training | Yes | See ON Semiconductor posting |
| SC Johnson security, encompassing both facility and infrastructure, including cybersecurity, is crucial for ensuring safety, operational effectiveness and profitability. | Yes | See ON Semiconductor posting |
| SC Johnson must gather and keep up with laws and regulations and translating them into physical, administrative, and technical controls | Yes | See ON Semiconductor posting Note – one unique source of requirements is the US Environmental Protection Agenda List of Lists – Consolidated List of Chemicals |
| SC Johnson must establish an Enterprise Architecture (EA) capability | Yes | See ON Semiconductor posting Note – EA function is even more important in light of SC Johnson strategy to make the world a better place through various initiatives (like Base of the Pyramid Team, Blue Paradox) |
| SC Johnson cybersecurity capabilities must encompass attack surface management and threat intelligence | Yes | See ON Semiconductor posting |
| SC Johnson must have a strategy for cloud governance, process, people and technology. | Yes | See Rogers Posting |
Initial Questions
Re-useable questions for another manufacturer organization
- Is the accuracy of the business architecture confirmed, and is there any essential component missing?
- Does a reference architecture exist for a specific plant that includes cybersecurity requirements? How is the integration handled in the event of a merger with a new company?
- What role does IT and Cybersecurity play in the expansion or installation of a new manufacturing facility?
- In what ways can Cybersecurity support and safeguard Research and Development (R&D) efforts?
- Is there a defined policy or stance regarding Generative AI, and does SC Johnson have an Emerging Technology Committee in place?
Unique Questions
- What critical applications are needed for the key processes identified?
- How integrated are SC Johnson’s partners in terms of their networks or data sharing?
- Has the executive leadership team written a “risk factors” report (like the risk factor section of a SEC filing)?
Business Contextual Architecture – Another Manufacturer Use Case (ON Semiconductor)

Delve into another instance of harnessing the Agile Security System. This time the focus is on ON Semiconductor. For insights into the methodology, kindly consult the Rogers post. This article will spotlight a couple of ways in which this approach can prove beneficial for individuals in these specific functions:
- Security Operations Center (including cloud)
- Incident Response
- Security Technology Management (i.e. firewall, email, EDR, cloud-native tools etc.)
- Identity Access & Management
- Identity Operations
- Threat hunting & Intelligence
- End point management.
- Forensics
- Detection Engineering
- Data Protection Engineering
- Vulnerability Management
Value of Agile Security System “Artifacts” for Non-Architecture Functions
- It addresses the fundamental “why” behind your role, serving as a source of inspiration. If you haven’t already, consider watching Simon Sinek’s older, but insightful video on this topic (https://youtu.be/Jeg3lIK8lro?si=K9xJGldk1AfQ-zMT) or read his book, “Start with Why.” Utilizing the business contextual architecture enables you to connect your role with the organization’s value. This approach reminds you that your role is an integral part of a larger system or context. Despite the allure and “coolness” of your role (e.g., Penetration Tester, Digital Forensic Examiner, Cloud Security Architect, or Threat Intelligence Analyst), cybersecurity doesn’t operate in isolation; it exists to deliver value. In your role, you contribute to the organization’s success by providing value that aligns with its goals. To put it another way, your role exists to the help the company “win” by helping them managing risk, so they “score points,” “win the game,” “win the championship or season” and be “winners” over decades of time (e.g. IBM, AT&T, GE etc.) What happens to players that don’t help their teams’ win? Yep, they get traded (here is video by Reed Hasting that talks about this analogy).
Side note – I also like Sinek’s view on high performing teams too (https://www.youtube.com/watch?v=zP9jpxitfb4 and https://www.youtube.com/watch?v=PTo9e3ILmms)
At ON, you create value by assisting customers in solving complex problems, contributing to the development of cutting-edge products, supporting the achievement of net-zero emissions by 2040, and facilitating profitable revenue growth. You must help ON do this better and before their competitors. That is it .
This linkage between your cybersecurity function and value becomes clearer when using the Agile Security System’s Baseline Enterprise Perspective ( Figure 2) and the company specific business architecture. The Baseline Enterprise Perspective shows the relationships between the different domains. For example, the “Other” (Figure 1) in the People domain help <<deliver>> services that <<create>> financial, social and business value. Another example is how the “Other” (Figure 1) in the People domain <<manage>> and <<build>> Information Technology, which, in turn, <<supports>> Process and <<represents” Information, which in turn, <<has>> financial value.

It aids in prioritizing operational activities of your cybersecurity functioning by providing answers to key questions such as:
- Where should I begin vulnerability scanning or requiring continuous scanning?
- What area needs to be “hunted” (and cleared of) for threat actors?
- What alerts and incidents should the SOC and/or IR team prioritize?
- Where should data protection engineering begin focusing their efforts?
- What changes should be assigned a higher risk within the change management process?
- What roles should undergo IAM access reviews?
- What detection alerts should be created by the Detection Engineering team?
- What use cases should the forensics team plan for?
The answer to questions like those above can be uncovered using the architecture depicted in Figure 1 as well as creating an Agile Security System Baseline Service perspective for each service listed in the Services domain (see Figure 3 for the Baseline Service perspective). While the architecture may lack specific technical details like hostnames and IP addresses, obtaining this information and ensuring its accurate linkage to the appropriate parent domain is easily achievable. The primary takeaway is that you now possess an understanding of the crucial services, products, and information contributing to value creation. Our mission is to safeguard and enable this value.
In the case of ON, it’s imperative to conduct vulnerability scans and complete IAM access reviews for applications, platforms, and networks supporting identified in the processes. With the recent acquisitions of “EFK” and “GT Advanced,” can a Zero Trust Network Access solution be deployed to expedite integration while minimizing risks? Does the threat hunting team thoroughly assess the networks associated with EFK and GT Advanced? Do they replicate this exercise when a manufacturing facility expands operations or a new one is built? Did the threat intel team and 3rd party risk team participate in the due diligence process for acquiring EFK and GT Advanced as well as the joint venture with Leshan?
Furthermore, have the detection engineering, data protection engineer, and SOC teams prioritized alerts, DLP rules, and responses for unlikely or unauthorized scenarios? For instance, if an employee in the Sales, Marketing, or IT teams transfers IP information from the US to a Chinese location, how are these situations managed? When the engineering team overseeing firewalls upgrades a firewall responsible for routing/monitoring traffic from a manufacturing process, should this change be considered high-risk even with a high-availability setup? Considering scenarios where an IR or forensic team might need to take a system offline, how do they assess the potential impact of such a decision? IR and forensics teams can refer to the business contextual architecture for insights!
Do you have the responsibility of devising tabletop exercise scenarios? It’s no surprise that you can utilize the business contextual architecture to aid in this task. For example, Understanding that Sales & Marketing services and associated processes play a crucial role in ON’s success, you could focus a tabletop exercise focused on the systems supporting Sales and Marketing processes and what happens if there are unavailable due to a ransomware attack.

Initial Observations
- ON must protect their intellectual property (IP). In the same aforementioned article by Anne Meixner, it is highlighted that individuals with access to critical systems and data within a company can become a security risk, either through intentional malicious actions or unintentional compromise due to human error. An illustrative instance of human error is provided, where engineers inadvertently leaked Samsung trade secrets using ChatGPT. To mitigate such risks, implementing administrative controls such as non-disclosure agreements, confidentiality agreements, trademarks, and educational initiatives becomes crucial. This underscores the need for a well-established insider risk management program to address and mitigate potential threats originating from within the organization. Effectively safeguarding ON’s IP necessitates the integration of security objectives that prioritize Confidentiality, Classification, Threat-Managed, Access-Control, Education, Authorization, Identification Legal, Duty-Segregation, Governance, Risk-Management and Monitoring.
- It is imperative for ON to possess advanced capabilities in intrusion detection, web security, threat intelligence, and training. According to the 2023 Verizon data breach report, surprisingly, only 1% of reported breaches in the Manufacturing sector involved partners, while a significant 90% were attributed to external threat actors. The predominant attack patterns observed were system intrusions, social engineering, and basic web attacks. In the context of motivation, threat actors primarily targeted organizations in the Manufacturing sector for financial gain, espionage, and convenience. Given this landscape, robust threat intelligence capabilities play a pivotal role in comprehending, identifying, and containing attacks driven by espionage motives.The above requires the cybersecurity strategy to incorporate the security objectives that prioritize Confidentiality, , Threat-Managed, Access-Control, Education, Risk-Management and Monitoring.
- A comprehensive vulnerability management program is crucial for ON’s security. Once again, in the article “Securing Chip Manufacturing Against Growing Cyber Threats,” Meixner references Joon Ahn, a vice president in the IT division at Amkor Technology, a company specializing in wafer level and packing assembly. According to Ahn, a notable gap in the semiconductor industry lies in connectivity vulnerabilities. Smart manufacturing technologies heavily rely on connectivity, introducing vulnerabilities as hackers target unsecured network connections to gain access to sensitive systems. The vulnerability management program should be leveraging CVSS 4.0 and have adequate resources assigned to monitor potential vulnerabilities affecting ON’s environment. To address integrity-related security objectives, ON must prioritize Vulnerability-Managed, Change-Managed, Configuration-Managed, Auditable, and Maintenance as essential components of its security strategy.
- As an “outsider” of the semiconductor industry, a semiconductor company like ON has to invest A LOT of capital and operational funds to setup a manufacturer facility. One University of Berkeley study has an estimated range of 3-4 billion US dollars. Every dollar spent on cybersecurity is a dollar taken away from running a manufacturer facility or profit creating service or process. To state the obvious, any security strategy needs to incorporate the security objectives of Cost-Effective and Efficient.
- It seems that ON acknowledges the necessity of incorporating education and awareness into their cybersecurity strategy for both customers and suppliers (see https://www.onsemi.com/company/events/webinars/don-t-let-cybersecurity-become-the-weakest-link-in-the-automotive-system for an example).
- Security, encompassing both facility and infrastructure, including cybersecurity, is crucial for ensuring safety, operational effectiveness and profitability. As articulated in ON’s 10K filing, any inability to use manufacturing facilities, testing facilities, and external manufacturers at anticipated or minimum purchase obligation levels, or a scenario where production capacity expands without a proportional increase in revenue, may lead to fixed costs and operating expenses associated with these facilities and arrangements not being fully absorbed. This could result in elevated average unit costs and diminished gross profits, potentially causing a significant adverse impact on ON’s operational outcomes. Additionally, as Joon Ahn, vice present at Amkor Technology summarized in an article on semiengineering.com, physical security becomes increasingly important as manufacturing facilities become more automated. Unauthorized access to the factory floor can result in equipment damage or theft. Any security strategy needs to incorporate the security objectives of Risk-Managed, Threat-Managed, Access-Controlled, and Interoperable.
- Application security is fundamental. This becomes even more clear and scarier when you read the opinion post by Lumpkin and Levin (2022) in the article “The mother of all ‘zero-days’ – immortal flaws in semiconductor chips.” They state the following:
Every chip starts life as a software program before it is fabricated, mostly in Asia, and mostly in Taiwan, into a chip. The process that transforms design code into “sand in the hand” silicon is just as vulnerable today as consumer applications were in the early 2010s, and for all the same reasons. The impact is deeper and more penetrating because once a chip is compromised, it is nearly impossible to patch. It might be in space or under an ocean. Our enemies know this too.
This means that software flaws needed to be detected and remediated continuously throughout the development lifecycle and iterations. Application security cannot be bolted on, but designed and built in. Any ON cybersecurity strategy must be structured to address the security objectives of Risk-Managed, Awareness, Threat-Managed, Integrity-Assured and Compliant. - Like all organizations, ON must gather and keep up with laws and regulations and translating them into physical, administrative and technical controls. As a manufacturer, ON has several of same sources for requirements as those posted for Rogers. Cybersecurity strategy must be organized to address the security objectives of Auditable, Legal and Compliant. Here are some potential sources for cybersecurity requirements: a) United States Patent and Trademark Office; b) United States Uniform Trade Secrets Act; c) United States Sarbanes-Oxley Act of 2002; d) European Union’s General Data Protection Regulation; e) United States Patent and Trademark Office; f) Canadian Bill C-27; g) SEMI E187 and SEMI E188 Standards; h) Creating Helpful Incentives to Produce Semiconductors and Science Act; i) United States Inflation Reduction Act; j)the International Traffic in Arms Regulation promulgated under the Arms Export Control Act (“ITAR”; k) United States Foreign Corrupt Practices Act (“FCPA”); l) anti-boycott provisions of the U.S. Export Administration Act; m) United States Responsible Business Alliance (“RBA”) Code of Conduct United States; n) FCPA (anti-corruption laws); o) NIST 800-171.
If you’re curious about how the Agile Security System manages requirements engineering, please consult the Figures 5, 6, and 7 provided below (prior to the questions section). It’s important to note that these figures are not complete and would require further iterations. The figure also only show the first page of the domain analysis worksheet too. This aspect is notably robust within the Agile Security System, allowing you to follow a set of requirements, objectives, or goals within a specific domain, along with their associated risks and mitigations. Notably, these aspects directly correspond to cybersecurity strategy. This process can be defined as the threat modeling of the business context. As per the threat modeling manifesto, the process involves addressing four key questions: a) What are we building (requirements, goals, objectives)?; b) What could go wrong (risks)? c) How do we plan to address it (mitigations)? d) Have we done an adequate job? The final question involves a “gut check” to evaluate the documentation. Ideally, all questions are collaboratively answered by the team, avoiding dependence on a singular “hero threat modeler.” - Establishing an Enterprise Architecture (EA) capability is imperative to provide a systematic approach to processes and architecture. This is essential for supporting the design and implementation of a new manufacturing facility and the integration of new companies. The EA capability should also encompass cybersecurity architecture.
As noted in ON’s 10K filing from 2022, if ON is
unable to successfully integrate new strategic acquisitions, which could materially adversely affect our business, results of operations and financial condition. Per Successful acquisitions and alliances in our industry require, among other things, efficient integration and aligning of product offerings and manufacturing operations and coordination of sales and marketing and research and development efforts, often in markets or regions in which we have less experience. Risks related to successful integration of an acquisition include, but are not limited to: (1) the ability to integrate information technology and other systems; (2) issues not discovered in our due diligence
ON’s cybersecurity strategy must incorporate the security objectives of Risk-Managed, Threat-Managed, Integrity-Assured, Governed, Efficient , Cost-Effective, Monitored, Usable and Adaptable. - For a global company, effective cybersecurity capabilities must encompass attack surface management and threat intelligence. ON seems to operate with 19 Internet Service Providers (ISPs) and 102 visible endpoints on the internet (including 4 DNS servers and 4 email servers via Proofpoint). It is crucial to vigilantly monitor the contraction and expansion of this attack surface to identify potential weaknesses, such as configuration errors or systems without system owners
- Like Rogers Corporation and the City of Mesa, ON has a cloud presence (in AWS). It appears that may be migrating their website, www.onsemi.com to AWS (beta-www.onsemi.com). I have the same observations for ON as those for Rogers Corporation.
- ON must retain highly skilled personnel, and its cybersecurity program should not be overly burdensome to the extent that employees choose to leave the company. It is crucial that the cybersecurity program at ON is competitive, efficient, effective, and user-friendly to avoid making it overly burdensome and cumbersome.
- ON provides products to companies in the industrial sector, contributing to the development of more intelligent cities, factories, and buildings. The demand for cybersecurity in product delivery is expected to rise as ON’s “smart” technologies continue to expand, and the company adopts its own technology in its manufacturing facilities. Another term used to describe a more intelligent factory is Industry 4.0 (or the 4th Industrial Revolution), as per ChatGPT 3.5, involving the integration of digital technologies, the Internet of Things, artificial intelligence, and data analytics into the industrial process. Clearly, as manufacturing processes become more digitized and interconnected for ON and its customers and suppliers, solving cybersecurity challenges becomes crucial.
- Managing Third-Party/Supply Chain Risks is crucial. This involves overseeing aspects such as monitoring, access control, incident response, and governance. However, it’s crucial to strike a balance; third-party risk management practices and processes must not become so burdensome that companies are disinclined to engage in business collaborations. The reliance of manufacturing and operations on third-party facilities, suppliers of raw materials, and software is significant. Identifying alternative manufacturers and suppliers can be a time-consuming and expensive endeavor, often complicated by a limited pool of qualified providers. Collaboration and a well-practiced incident response plan are vital when dealing with connections to third parties. It’s essential to limit exposure and prioritize containment. This means restricting third-party access to a specific set of resources, thereby minimizing the potential impact. Regular validation of access, following a zero-trust approach, adds an extra layer of security and assurance.
The article, “Securing Chip Manufacturing Against Growing Cyber Threats” by Anne Meixner states that 60% to 90%, of impactful security issues stem from suppliers. This is, in part, due to a growing level of interdependency among companies in this industry, and ON is likely no exception. As the Meixner’s article summarizes the current situation of 3rd party interdependency.
Where methodologies and standards do exist for security, they often are confusing, cumbersome, and incomplete. There are plenty of gaps, particularly among some of the smaller suppliers of IP, equipment, and materials, where security remains primitive at best. This is partly due to the fact that in the past, much of the focus was on vulnerabilities in chips and chipmakers. But there is an increasingly high level of interdependency between companies in the semiconductor industry. The number of interactions is growing as complexity increases, and as chip designs become increasingly heterogeneous.
Figure 4 provides a conceptual view of the interdependency the semiconductor industry Change Managed, Monitored, Risk-Managed, Access-Controlled, Threat-Monitored, Threat Management, Governed, and Vetted are key attributes that need to be part of any cybersecurity strategy.




Initial Questions
- Is the accuracy of the business architecture confirmed, and are there any essential elements missing?
- Does a reference architecture exist for a specific manufacturing facilities that includes cybersecurity requirements? That is, business knows the cost associated with the cybersecurity infrastructure and tools for a facility. Has IT provided a BOM for the different facility types? Does cybersecurity have a process to on-board a facility into their processes?
- How are risk management and policy governance handled? Is ON the culture open an approach similar to one discussed for the City of Mesa?
- How is the integration handled in the event of a merger with a new company?
- What is the logistics process for transporting products between facilities? For instance, how are silicon wafers manufactured in the Czech Republic transported to a facility in another company? How are these protected?
- What role does IT and Cybersecurity play in the expansion or installation of a new manufacturing facility?
- In what ways can Cybersecurity support and safeguard Research and Development (R&D) efforts?
- The prevalence of VPN connections is notable. With 23 internet-accessible VPN endpoints (23 out of 103, or 22%), what is the reason for this high number?
- Is there an ongoing project to transition http://www.onsemi.com to AWS (beta-www.onsemi.com, 23.22.192.64)? Has AWS been design with their cloud adoption framework? Does the SOC use cloud native tools or 3rd party tools for security cloud operations?
- Is there representation from ON at Semicon West, and is Semicon West considered a reputable conference?
- Is there a defined policy or stance regarding Generative AI, and does ON have an Emerging Technology Committee in place?
- Is ON following the guidance from the NSA? Is it applicable?
Business Contextual Architecture – Public Sector Case Study
Presented here is another segment in the series focusing on constructing a business contextual architecture, utilizing the Agile Security System devised by Andrew Townley. This particular case study centers on the public sector, specifically examining the context of the City of Mesa, Arizona. The figure below is the Domain Impact Worksheet from the Agile Security System.

Methodology
Please note that I use the phrases of “security objectives” or “business objectives” throughout the observations below. This is an architectural or strategy technique that I learned from SABSA and Andrew Townley. SABSA refers to them as “business attributes.” Business attributes are abstractions of risk mitigation strategies or enablement strategies that must be met for an organization to deliver or achieve a desired outcome, goal or objective. The specific security objectives, like Available, Risk-Managed, and associated definitions are from “Getting Started with the Agile Security System” (Townley, 2023, Appendices E and F). A cybersecurity strategy and operations need to incorporate and deliver on these cybersecurity objectives.
Observations
- The official website, www.mesaaz.gov, stands as the primary brand for the City. Residents depend on the site’s continuous availability, anticipating unfettered access at all times. Moreover, residents expect that any information gathered from them is handled with the utmost protection. The security objectives, encompassing Availability, Governed, Duty-Segregated, Reputable, and Safe, are paramount in this context. Additionally, Customer-focused, Usable, and Resourced are other important business objectives.
- Data.mesaaz.gov and openbudget.mesaaz.gov assume a pivotal role in promoting the City’s strategic priority of cultivating “Strong Community Connections.” The essence of their importance is rooted in harnessing data analytics, minimizing disruptions to stakeholders, and aligning with the objective of ensuring transparency with citizens, thereby helping the implementation of a smarter Mesa. These two websites share the same security objectives as www.mesaaz.gov, including Availability, Governed, Duty-Segregated, Reputable, and Safe. Additionally, an overarching objective for Data.mesaaz.gov and openbudget.mesaaz.gov is to be Interoperable.
- Complexity and diversity of City Services are unapparelled. The City of Mesa operates utilities, medical service, police, transportation, library, parks, social services and public Wi-Fi. These services are delivered by people operating in 28 diverse departments within the City of Mesa. The services are structured by unique and overlapping processes and expose different types of information to customers and employees. The intricate complexity and diversity of services provided by the City of Mesa give rise to distinct business requirements, legislative demands, and a varied landscape of attack surfaces that require targeted risk mitigation strategies. A notable example is the existence of 52 internet-accessible web applications supporting diverse city processes. Consequently, it is imperative to incorporate critical security objectives into the cybersecurity strategy to effectively address these challenges. The essential security objectives include Risk-managed, Compliant, Documented, Recoverable, Access Controlled, Compliant, Integrity-Assured.
- Given the complexity and diversity of the City of Mesa’s services, the maturing of an Enterprise Architecture (EA) capability becomes imperative. The City has recognized the importance of maturing such capability by incorporating it into their IT Strategic Plan and Roadmap document. EA capability needs to incorporate and be integrated with Cybersecurity Architecture and Solution Architecture These architecture domains play a crucial role in ensuring that solutions are not only technologically sound but also aligned with key cybersecurity objectives and requirements. Customer-Focused and Governed are key business objectives. Enterprise Architecture can help break down silos, down silos, explore new technologies / capabilities, ensure IT alignment with the 50 year plan (see https://plan.konveio.com/tomorrows-mesa-2050-general-plan), and IT governance.
- Effective risk management and policy governance are indispensable for municipalities like the City of Mesa, particularly in the context of limited funding for cybersecurity compared to federal governments or private corporations. Prioritizing IT security and privacy funding via risk management is paramount. A key facet of risk management involves identifying the appropriate owner / role, whether it be a City Manager, Mayor, or Department Head, to accept, mitigate, or transfer risks. The integration of risk management with a comprehensive City-wide framework, beyond cybersecurity and privacy, is essential. The adoption of a “Domain Framework” based on SABSA becomes instrumental, where each domain is owned by an accountable individual responsible for setting policies and risk appetite, while adhering to the parent risk parameters and policies. For example, the City of Mesa via the Mayor and City Council would set a city wide risk appetite level and general cybersecurity risk policy (i.e., Enterprise Domain). All child domains (e.g. Process, Information, Information Technology) would have to adhere to the risk appetite and policies of the parent (i.e., Enterprise Domain). This approach enables the appropriate role to make and own risk decisions similar to the ones they are already making in finance, legal, and HR. Cybersecurity would need to be consulted on cybersecurity policy and risk decisions. This approach also removes IT Security as the perceived owner of all cybersecurity risk and a blocker to projects/initiatives. Cybersecurity could also work with domain owners to draft policies. Domain owners would be accountable for writing policies for their domain and demonstrating compliance to them.
- Cybersecurity in local governments is a public safety risk that needs to be Risk-managed and Safe.
- There are a lot of processes needed to structure the diverse City services. Process information in the Domain Impact worksheet are from the Process Classification Framework® (PCF), The City Government PCF. There is a potential opportunity to leverage the City Government PCF to benchmark services, resulting in improvements in processes and services. Per APQC, the PCF Experience serves as a high-level, industry-neutral enterprise process model that allows organizations to see their business processes from a cross-industry viewpoint.
- The City exhibits a seemingly greater transparency in sharing information about its IT assets compared to the private sector, evident in instances such as Palo Alto Networks customer success story featuring their technology used by the City. However, this abundance of information poses potential risks as threat actors could leverage it for reconnaissance purposes (see MITRE ATT&CK framework T1589, T1590, T1591). Therefore, a well-rounded cybersecurity strategy needs to incorporate the cybersecurity objectives of Educated, Classified, and Risk-Managed. Striking a balance between transparency and security is crucial to maintain the City’s resilience against potential cyber threats.
- The City of Mesa must allocate sufficient resources, if not already, to effectively identify and manage regulatory requirements for its complex environment. This necessitates collaboration, potentially through a committee comprising representatives from IT Security & Risk, the City Attorney’s office, and designated “Domain Owners” (see #5 above) for specific services. Any cybersecurity strategy needs to incorporate the objective of “Compliant.” Below are examples of potential regulatory and standards that may impose requirements for cybersecurity and privacy based on the information utilized and services offered by the City of Mesa. These sources should be carefully considered and integrated into the security strategy to maintain compliance: a) PHI – Health Insurance Portability and Accountability Act; b) PII – Children’s Online Privacy Protection Act, The Electronic Communications Privacy Act, Arizona’s Data-Breach Notification Law; c) Payment Information – The Payment Card Industry Data Security Standard; d) Water Utility – US Environmental Protection Agency Cybersecurity Checklist; e) Arizona Freedom of Information Act; f) US Transportation Security Administration cybersecurity requirements for airports and aircraft operators; g) US Executive Branch Strategies and Orders – National Cybersecurity Strategy, Executive Order 14028, Executive Order 13800. Policy Directive PPD-21; h) US Federal Aviation Agency’s regulations for Unmanned Aircraft System; i)NIST Cybersecurity Framework; j) Criminal Justice Information – FBI’s CJIS Security Policy; k) Cybersecurity Incident – SEC Rules on “Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure by Public Companies.” Obviously, the City of Mesa is not a publicly traded company and these rules don’t apply to the City. However, it might be worthwhile to adopt the SEC framework for handling disclosures in the spirit of transparency if it doesn’t conflict with other laws or regulations.
- Ransomware is a critical concern. Per the Verizon Data Breach report from 2023, ransomware remains the favored approach for disrupting government operations. Several security objectives need to be addressed in response to ransomware: Risk-Managed, Recoverable, Access Controlled, Integrity-Assured, and Educated. Dallas (May 2023 – June 2023) and City of Oakland (February – April 2023) are two examples cities impacted by ransomware attacks. At minimum, the City should, if not already: a) utilize the domain impact worksheet (or similar business architecture modeling or business impact analysis) to initiate the identification of critical services necessitating protection, resilience, and expedited recovery in the event of a ransomware attack; b) evaluate the City’s alignment with CISA’s Stop Ransomware Guide, potentially converting the guidance into a spreadsheet or web application to assess and monitor progress. This evaluation should encompass technology, personnel, and processes; c) encourage cybersecurity technology partners to conduct complimentary ransomware health checks and remediation assessments of their technologies deployed within the City of Mesa’s environment; d) ensure the existence of an up-to-date and tested Incident Response plan, involving key stakeholders such as the City Manager, City Attorney, Mayor, and Councilors. Additionally, safeguard and regularly test the backup and restore infrastructure to ensure its effectiveness in mitigating the impact of a potential ransomware incident. Ensure there is reputable incident response company, like Verizon, Mandiant etc, on retainer to assist with incident response along with appropriate federal and state agencies.
- The City of Mesa should be cognizant of several trends identified in the 2023 Verizon Data Breach Report that are relevant to its security posture. While the report does not provide a breakdown for government levels, the patterns observed, such as system intrusion, basic web attacks, DDoS, social engineering, and miscellaneous errors, are pertinent to municipal entities. Espionage-motivated actors pose a notable threat in this sector, and the persistent issue of collusion between disgruntled internal actors and external entities requires attention. Financially motivated actors and nation states targeting public sectors for information remain a concern, with personal information being the most frequently stolen data type. In response to these threat actors, critical security objectives, including Risk-Managed, Integrity-Assured, and Risk-Aware, must be addressed. The City of Mesa should explore the feasibility of implementing geo-blocking for all web applications, except www.mesaaz.gov, to ensure it continues to support efforts to market and attract individuals and organizations to the city. Additionally, it is advisable for the city to assess its control maturity and capabilities against recognized frameworks such as the CIS Critical Controls and MITRE ATT&CK to ensure a robust and adaptive security posture, especially for applications listed in the “Critical Apps” subdomain. Side note – I like that VERIS has mapped their incident classification patterns to MITRE ATT&CK framework techniques and the CIS Critical Controls
- Similar to other cities, the City of Mesa has placed a strategic emphasis on evolving into a “Smarter City.” As the city progresses towards becoming smarter, several of the previously mentioned Security Objectives remain applicable. The criticality and frequency of cybersecurity incidents are expected to rise, especially as services increasingly rely on interconnected Operational Technology (OT) systems, Information Technology (IT) systems, and Smart City infrastructure. Recognizing the growing complexity and interconnectivity, CISA has offered cybersecurity best practices tailored for and attributes of a trusted for Smart Cities. Consulting and potentially adhering to these best practices is crucial for the City of Mesa to enhance the security posture of its Smart City initiatives.
- Like Rogers Corporation, the City of Mesa has a cloud presence. I would have the same observations for the City of Mesa as those for Rogers Corporation.
Initial questions
- Is the accuracy of the Domain Impact worksheet accurate, or are there crucial elements missing?
- What are critical services and initiatives requiring guidance from cybersecurity?
- What is the risk management process for identity, assessing, addressing etc. risk?
- Who is responsible for collecting regulations etc. and converting them into policies and requirements?
- Is there a dedicated cybersecurity and IT plan for managing attacks involving ransomware?
- Why is business continuity with Cybersecurity?
- How are cybersecurity items on the IT Strategy and Roadmap identified and prioritized?
- How does cybersecurity architecture, enterprise and solution architecture integrate?
- What components of the CIS Critical Security Controls are in place for the Information Technology parent domain in terms of people, process and technology?
- How is the cloud governed? Are there any initiatives involving cloud?
- How is the network segmented?
- How mature is City of Mesa’s Security Operations Capability?
Architecture vs engineering – Good quote
You need both architecture and engineering to ultimately deliver and maintain value for the customer. This is an obvious statement but these two practices are often confused or used interchangeably. I found this definition / statement from Andrew Townley helpful in terms of keeping the “lines” less blurry
If you’re implementing someone else’s design or creating the design of something mentioned in someone else’s design…you’re an engineer..if you’re the one doing the design…or, in most of the cases we find ourselves trying to surface, document and communicate the structure and interconnections of the way our organizations work, identifying critical functions in the context of delivering some kind of thing that ultimately will be recognized by someone as being of “value”..you’re an architect~ Andrew Townley (2023).
SABSA business attributes – Good reference
I came across this good reference on attributes and suggested ways to measure them. Of course, the Blue Book (https://www.amazon.com/Enterprise-Security-Architecture-Business-Driven-Approach/dp/157820318X) has them as well.
If you don’t know about SABSA or attributes, you are seriously missing out on an incredible tool for solving problems and delivering measurably effective and stakeholder aligned architectures.
https://onlinelibrary.wiley.com/doi/pdf/10.1002/9780470476017.app1
Business Contextual Architecture – The Why, The Approach and A Case Study
The Why
So, you are a newly hired X at an organization. You can substitute X with CISO, architect, engineer, senior manager, consultant, sales manager etc. Maybe, you are a cybersecurity architect or enterprise architect at an existing organization and you have been tasked to develop a cybersecurity architecture strategy.
You probably have many, many questions (or you should), like…
- How do I determine what is most important to the organization?
- How do I gather and organize the various requirements from policies, standards and stakeholders?
- How do I get the “lay of the land” quickly, so I can ask people good questions and share some initial observations?
- How do you create credibility and trust?
- How do I get my organization to “shift left?”
The Approach
Over the past two years, I’ve been immersed in a transformative approach aimed at tackling these types of questions. This method, known as the “Agile Security System,” has been developed, maintained and taught by Andrew Townley (visit https://agilesecuritysystem.com for more details) and is based on SABSA. I have been a big supporter and fan of SABSA since 2018. My journey with Andrew’s methodology began during my participation in a “Building Effective Security Architectures” cohort. Subsequently, I had the opportunity to put it into practice within a healthcare organization valued at over $9 billion. To reinforce my understanding, I delved into Andrew’s book, “Getting Started with The Agile Security System,” as a refresher this year. For ongoing insights and master classes on this methodology, Andrew’s “Club” is an invaluable resource, complemented by his monthly “Security Sanity” newsletter.
Note: it’s important to clarify that my acknowledgment of Andrew Townley’s work, is not driven by any financial incentives or benefits from him. I credit him for this approach because it genuinely deserves recognition (and owns the copyrights and trade mark too).
A critical and must deliverable of the business contextual architecture of the “Agile Security System” is the “Domain Impact Worksheet.” Other deliverables include:
- Listing of requirements and objectives per domain in the “Domain Impact Worksheet.”
- Listing of risks to the objectives and requirements
- Listing of strategies to mitigate the identified risks
- Mapped relationships and approved interactions between domains
This posting focuses on the “Domain Impact Worksheet” deliverable. In Figure 1 below, the “Domain Impact Worksheet,” the interplay of blue and gold boxes unfolds. Each of these colored boxes represents a unique “domain,” a concept rooted in the idea that a domain is “any collection of elements that share a common set of characteristics that can be deployed to deliver a common purpose” (Townley, 2023). This foundational concept, courtesy of SABSA, is a noteworthy contribution to breaking down and organizing elements of an organizational. Gold domains have elements with corresponding items in the real and physical world, while blue domains organize logical elements.
The Domain Impact worksheet serves as a consistent, visual framework and communication tool for organizing elements of an organization for analysis and structuring requirements (see question #2 above). Each domain adheres to a consistent set of criteria, aiding in the determination of whether an element belongs within its confines. Moreover, each domain can have distinct requirements that must be addressed or risks mitigated via security objectives (i.e. Cybersecurity Strategy). The beauty of this system lies in its ability to nest domains within each other, forming a hierarchy of super-domains and subdomains. Subdomains domains inherit requirements from their super-domain but may also have unique requirements from their peer domains.
In essence, the “Domain Impact Worksheet” becomes a canvas illustrating (see question #3 above) the connectivity between the organization’s vital value streams and the underlying components of people, products, processes, services, facilities, information, and technology (see question #1 above). It not only visually organizes these elements but also provides foundation for showing how they interact with another within the organizational landscape. It helps you “shift left” (see question #5 above) because you start with “the business” context and creates credibility (see question #4 above) by demonstrating that you understand what cybersecurity needs to protect and enable.
One key principle embedded in “The Agile Security System” is the commitment to thorough preparation (i.e., do your homework). I complete “my homework” by utilizing various tools, including:
- SEC 10-K Document review: One valuable resource is the SEC 10-K Filings, particularly the “Risk Factors” section. This document, initially introduced to me when I was enrolled in the MBA program at Grand Canyon University, offers a business-centric perspective on cybersecurity risks alongside other organizational challenges. Instead of drowning in a sea of technical jargon, it provides a holistic view, steering clear of mere lists of CVEs or the latest cyber threats.
- SSL Labs Report Review: Provides a “grade” on the SSL hygiene of a website and type of web platform (e.g. IIS, Apache) utilized by the website.
- Shodan IO Report Review: The Shodan IO report on the main website takes the investigation further, presenting web platforms, operating systems, and even country locations.
- Searching and reviewing job descriptions. Job descriptions can be surprisingly revealing. A glance at them can provide valuable information on the technical applications and platforms actively used within the organization, offering a glimpse into its technological ecosystem.
- OSINT Framework. This is not a tool per se, but a way to query free search engines, resources, and tools publicly available on the Internet. Various tools provide information on IP addresses.
- Review the latest Verizon Data Breach report. This report furnishes incident data within a particular industry, aiding in the identification of potential risks for the organization under scrutiny.
- Prompting ChatGPT 3.5. Leveraging the power of generative AI through ChatGPT 3.5 can bring another layer of understanding. This platform not only answers questions but also provides contextual information about the organization, generating risks, and information in areas that you are not well-versed in.
- Leverage Microsoft PowerPoint, Word, Google Slides or Docs. Don’t overlook the simplicity and adaptability of familiar tools. The Microsoft PowerPoint slide, as exemplified in Figure 1, the “Domain Impact Worksheet” is based on a template from “Building Effective Security Architectures” cohort. It serves as a template for creating reusable business contextual architectures, offering a straightforward yet effective means of documentation. I also use Microsoft Word to collect and organize my notes and output from the various tools mentioned above. My notes are organized around the various domains and risk factors.
A Case Study – Rogers Corporation (Engineering and Manufacturing, ROG – NYSE)
Rogers Corporation designs, develops, manufactures and sells high-performance and high-reliability engineered materials and components to meet our customers’ demanding challenges. Rogers operates two strategic operating segments: Advanced Electronics Solutions (AES) and Elastomeric Material lSolutions (EMS).
Note – Elastomeric materials are polymers with elastic properties, capable of returning to their original shape after deformation
The “Domain Impact Worksheet” in Figure 1 summarizes part of the business contextual architecture of Rogers Corporation.

Figure 1 – Domain Impact Worksheet for Rogers Corporation
Let’s go back to question # 3 above except let’s slightly re-word it.
What are some questions and initial observations about Rogers Corporation?
Initial Observations
- Ensuring the safeguarding and facilitation of critical functions such as manufacturing, engineering, sales, financial systems, shipping, and engineering services is of paramount importance. The uninterrupted operation of factories and the timely issuance of invoices are directly tied to the financial health of the company. This principle extends to our Supply Chain partners as well. Any cybersecurity incident or unforeseen disruption stemming from poorly executed upgrades or changes has the potential to significantly impede these essential services. A comprehensive cybersecurity strategy must integrate security goals that encompass availability, change management, configuration management, monitoring, recoverability, risk management, vulnerability management, threat monitoring, threat management, and usability.(see Townley, 2023 Appendix E for definitions of these objectives or attributes).
- Securing Rogers’ proprietary information, including trade secrets such as manufacturing processes, patents, licenses, and confidential customer data, demands a strategic focus within any robust cybersecurity framework. Effectively safeguarding these critical assets necessitates the integration of security objectives that prioritize confidentiality, classification, access control, duty segregation, awareness, governance, and ongoing monitoring (see Townley, 2023 Appendix E for definitions of these objectives or attributes).
- The business requirements for writing cybersecurity policies and ensuring Rogers complies with various regulations come from several sources. These requirements must be harmonized and ideally aligned with a centralized control framework, such as the Unified Compliance Framework. To achieve this, an evaluation of the following regulations for relevance is essential: a) EU General Data Protection Regulation; b) Cybersecurity Law of the People’s Republic of China (2017); c) National Security Law (2015, China); d) Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Privacy Act, Hungary); e) Personal Information Protection Act (PIPA, South Korea); f) California Consumer Privacy Act; g) Sarbanes-Oxley Act (US); h) Securities and Exchange Commission (SEC) Guidance, including the new incident disclosure; i) State Data Breach Notification Laws. Consequently, the cybersecurity strategy must be structured to address the security objectives of auditability, legality, and compliance (see Townley, 2023 Appendix E for definitions of these objectives or attributes).
- Rogers appears to have a presence in Azure. Any identified security objectives and cybersecurity strategy needs be extended to this environment. In fact, Rogers’ IT Cloud strategy should have a cybersecurity section that addresses these objectives along with cover other areas: a) multi-disciplinary risk framework to manage risks in the cloud; b) a control framework that is cloud service provider agnostic, but mapped to Azure services; c) approach on how zero trust will be implemented; d) the identity and access management approach; e) the use of a cloud-native application protection platform (see https://www.gartner.com/reviews/market/cloud-native-application-protection-platforms for definition); f) cybersecurity operations center capabilities (see https://www.mitre.org/sites/default/files/2022-04/11-strategies-of-a-world-class-cybersecurity-operations-center.pdf for a great resource on SOCs).
Initial Questions
- Is the accuracy of the Domain Impact worksheet assured, or are there crucial elements missing?
- How do members of the engineering and sales force teams obtain access to the essential data required to support customers effectively?
- What components of the CIS Critical Security Controls are in place for the Information Technology parent domain in terms of people, process and technology?
- Who is accountable and responsible for collecting and maintaining cybersecurity and privacy requirements from the various countries that Rogers operates in?
- How does the organization navigate the complex situation of operating a factory in China while acknowledging documented evidence indicating that China or affiliated actors engage in active intellectual property theft, as highlighted in instances such as those presented in the document at https://foreignaffairs.house.gov/wp-content/uploads/2020/02/Egregious-Cases-of-Chinese-Theft-of-American-Intellectual-Property.pdf?
- In what manner is the network segmented to heighten detection capabilities and restrict the potential impact area in the event of a compromise?
- What categories of Operational Technology (OT) are currently in operation within the environment, and does OT pose a significant risk for Rogers? For a comprehensive definition of OT, refer to https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-82r3.pdf. The latest Verizon Data Breach report indicates that incidents involving OT remain relatively small, particularly in the manufacturing industry, it remains prudent to stay vigilant given the potential impact, as recommended by Verizon.
- What is the cloud governance for the Azure environment? Does it follow the recommended Microsoft governance model, including the team structure? Has the environment been architected to align with the Microsoft Cloud Adoption Framework, especially the use of landing zones?
That is it. Let me know your thoughts. Happy Holidays..
~R&R
Dashing through the snow
In a one-horse open sleigh
O’er the fields we go
Laughing all the way
Bells on bobtails ring
Making spirits bright
What fun it is to create & share
architectures tonight.
#COSAC2023 – Ideas and Themes
Here is a picture of an entry in my journal. It captures ideas and themes that I captured or remembered from #COSAC2023,

