ISO 31000 Risk Assessment: Managed File Storage (SharePoint) for PII Data

Canonical - PSP Portal Information Staging
ISO 31000:2018 Compliant

1. Context Establishment (ISO 31000 Clause 6.3)

Assessment Scope: Evaluation of risks associated with using Microsoft SharePoint Online as a managed file storage solution for staging Personally Identifiable Information (PII) data from the PSP (Partner Support Portal) at Canonical.

Risk Criteria: Risk will be evaluated based on potential impact to confidentiality, integrity, and availability of PII data, regulatory compliance (GDPR, CCPA), and Canonical's reputation.

Stakeholders: Security Risk Management Team, Data Protection Officer, IT Operations, Legal & Compliance, Product Teams.

2. Risk Identification (ISO 31000 Clause 6.4.2)

Identified risks associated with SharePoint for PII data staging:

RISK-01: Unauthorized Access to PII Data

Description: External threat actors or malicious insiders gain access to SharePoint repositories containing PII data.

Potential Impact: Data breach, regulatory fines, reputational damage.

RISK-02: Data Exfiltration via Sharing Links

Description: Misconfigured sharing permissions or overly permissive sharing links allow unauthorized access to PII data.

Potential Impact: Unauthorized data disclosure, GDPR violations.

RISK-03: Insider Threat - Privilege Misuse

Description: Authorized employees with access to PII data misuse their privileges for unauthorized purposes.

Potential Impact: Internal data breach, compliance violations.

RISK-04: Data Loss or Corruption

Description: Accidental deletion, ransomware encryption, or corruption of PII data stored in SharePoint.

Potential Impact: Loss of critical business data, operational disruption.

RISK-05: Integration & Transfer Risks

Description: Vulnerabilities in the data transfer process between PSP portal and SharePoint, or insecure API integrations.

Potential Impact: Data interception, integrity compromise during transfer.

3. Risk Analysis with FAIR Model & Sensitivity Analysis

Applying Factor Analysis of Information Risk (FAIR) to quantify risk in financial terms:

How often threat agents contact the SharePoint environment
Probability that contact results in a loss event
Direct costs (response, recovery, replacement)
Indirect costs (fines, reputational damage, legal)

FAIR Analysis Results

Loss Event Frequency (LEF): 1.8 events/year
Total Loss Magnitude (LM): $200,000
Annualized Loss Expectancy (ALE): $360,000
Risk Level (Based on ALE): MEDIUM

4. Risk Evaluation (ISO 31000 Clause 6.4.4)

Evaluating risks against Canonical's risk appetite and tolerance levels:

Impact →
Likelihood ↓
Insignificant
Minor
Moderate
Major
Severe
Rare
Low
Low
Low-Medium
Medium
Medium-High
Unlikely
Low
Low-Medium
Medium
Medium-High
High
Possible
Low-Medium
Medium
Medium-High
High
High
Likely
Medium
Medium-High
High
High
High
Almost Certain
Medium-High
High
High
High
High

Risk Prioritization

Based on FAIR analysis and ISO 31000 evaluation:

  1. RISK-01 (Unauthorized Access): HIGH priority - High potential financial impact
  2. RISK-02 (Data Exfiltration): HIGH priority - Significant regulatory exposure
  3. RISK-05 (Integration Risks): MEDIUM-HIGH priority - Critical data transfer vulnerability
  4. RISK-03 (Insider Threat): MEDIUM priority - Requires monitoring and controls
  5. RISK-04 (Data Loss): MEDIUM priority - Managed through backup strategies

5. Risk Treatment (ISO 31000 Clause 6.5)

Recommended risk treatment options based on FAIR ROI analysis:

Treatment 1: Enhanced Access Controls

Action: Implement conditional access policies, multi-factor authentication, and just-in-time privileged access for SharePoint.

Expected Risk Reduction: 40% reduction in Threat Event Frequency

Cost: $15,000 initial + $5,000/year

ROI (Based on FAIR): 3.2:1

Treatment 2: Data Loss Prevention (DLP)

Action: Deploy Microsoft Purview DLP policies to detect and prevent unauthorized sharing of PII data.

Expected Risk Reduction: 60% reduction in Vulnerability

Cost: $25,000 initial + $10,000/year

ROI (Based on FAIR): 2.8:1

Treatment 3: Encryption & Rights Management

Action: Implement Azure Information Protection for encrypting PII data at rest and in transit with usage restrictions.

Expected Risk Reduction: 50% reduction in Secondary Loss Magnitude

Cost: $20,000 initial + $8,000/year

ROI (Based on FAIR): 1.9:1

Residual Risk Assessment

After implementing recommended treatments, estimated residual risk:

Residual Annualized Loss Expectancy: $95,000
Residual Risk Level: LOW

Residual risk falls within Canonical's risk tolerance level for PII data management.

6. Monitoring & Review (ISO 31000 Clause 6.6)

Key Risk Indicators (KRIs) for ongoing monitoring:

  • Number of unauthorized access attempts to SharePoint PII repositories
  • Frequency of DLP policy violations for PII data
  • Percentage of PII files with appropriate sensitivity labels
  • Time to detect and respond to SharePoint security incidents

Review Frequency: Quarterly risk reviews with monthly KRI reporting to Security Risk Management Team.