Migrating Controls & Risks To A New Persona Model (Phase 3)

by Alex Johnson 60 views

This article dives deep into Phase 3 of the CoSAI-RM Persona Model uplift, focusing on migrating all existing controls and risks to the newly designed persona model. This crucial step ensures that our risk management framework accurately reflects shared responsibilities and organizational realities. Let's explore the objectives, scope, tasks, and considerations involved in this significant undertaking.

Understanding the Project Scope

This Phase 3 migration of all controls and risks to new persona model is a key component of the larger Epic: Uplift CoSAI-RM Persona Model. This project relies on the successful completion of several preceding phases, including:

  • Phase 1a - Persona Schema Updates (#110)
  • Phase 1b - Framework Applicability Schema (#111)
  • Phase 2 - Content Population (#112)
  • Workstream 3 Persona to Control & Risk Mapping Exercise - (tbd)

Project Objective

The central objective of this phase is to update all controls and risks within the controls.yaml and risks.yaml files. This update ensures that these elements reference the new persona model, accurately depicting shared responsibility where applicable. The specific mappings of personas to controls and risks are To Be Determined (TBD) and will be defined through a dedicated mapping exercise conducted by workstream 3. This exercise is essential for identifying the most suitable assignments.

Scope of the Migration

To fully grasp the scope, let's consider the current and target states of our control and risk landscape:

Current State:

  • 29 persona references in controls.yaml
  • 26 persona references in risks.yaml
  • All current references utilize legacy personas: personaModelCreator, personaModelConsumer

Target State:

  • All controls mapped to appropriate new personas within the model.
  • All risks mapped to relevant new personas in the model.
  • Multi-persona assignments implemented where shared responsibility is identified.
  • Successful schema validation to ensure data integrity.
  • Successful cross-reference validation to maintain consistency across the framework.

Important Note: While we migrate to the new persona model, the legacy persona references will remain within the codebase during this phase. A future phase will specifically address the cleanup strategy for these deprecated persona usages.

Key Tasks in Phase 3

This migration involves several critical tasks, each contributing to the successful adoption of the new persona model.

1. Workstream 3 Mapping Exercise: Laying the Foundation

Before any migration can commence, the workstream 3 mapping exercise is paramount. This exercise will determine the appropriate persona assignments for each control and risk. This crucial step involves:

  • Analyzing the purpose and scope of each control.
  • Identifying the personas responsible for implementing each control.
  • Documenting the rationale behind multi-persona assignments, clearly outlining shared responsibilities.
  • Considering organizational boundaries and real-world control ownership dynamics.
  • Mapping risks to the personas who need to be aware of and actively mitigate them.

Deliverable: The primary deliverable is a comprehensive mapping document. This document will explicitly specify the new persona assignments for all 29 controls and 26 risks, providing a clear roadmap for the migration process.

2. Updating controls.yaml: A Step-by-Step Guide

The process of updating the controls.yaml file, located at risk-map/yaml/controls.yaml, is methodical and ensures accuracy. The steps include:

  1. Reviewing the mapping document meticulously, derived from workstream 3's efforts.
  2. Updating each control's personas field with the newly determined assignments.
  3. Retaining the legacy persona mappings (personaModelCreator, personaModelConsumer) for the time being.
  4. Validating schema compliance after each update to maintain data integrity.

Example Transformation:

Let's illustrate the transformation pattern with a concrete example:

Before:

- id: controlExample
  title: Example Control
  personas:
    - personaModelCreator  # Legacy persona

After:

- id: controlExample
  title: Example Control
  personas:
    - [New persona(s) from workstream 3 mapping]
    - personaModelCreator # legacy persona

This example showcases how the new persona assignments are integrated while preserving the legacy references for now.

3. Updating risks.yaml: A Mirror Process

The procedure for updating the risks.yaml file, found at risk-map/yaml/risks.yaml, mirrors the process for controls.yaml. It involves:

  1. Reviewing the mapping document generated by workstream 3.
  2. Updating each risk's personas field with the appropriate new assignments.
  3. Preserving legacy persona mappings (personaModelCreator, personaModelConsumer).
  4. Validating schema compliance after each update to ensure data accuracy.

Example Transformation:

Here's an example of how a risk entry is transformed:

Before:

- id: riskExample
  title: Example Risk
  personas:
    - personaModelConsumer  # Legacy persona

After:

- id: riskExample
  title: Example Risk
  personas:
    - [New persona(s) from workstream 3 mapping]
    - personaModelConsumer # legacy persona

This demonstrates the consistent approach to updating both controls and risks.

4. Rigorous Validation & Testing: Ensuring Accuracy and Consistency

Validation and testing are paramount to ensure the migration's success. We employ several methods to achieve this:

Schema Validation:

We use the check-jsonschema tool to validate the structure and content of our YAML files against predefined schemas:

check-jsonschema --schemafile risk-map/schemas/controls.schema.json risk-map/yaml/controls.yaml
check-jsonschema --schemafile risk-map/schemas/risks.schema.json risk-map/yaml/risks.yaml

Cross-reference Validation:

To maintain consistency across the framework, we use Python scripts to validate cross-references:

python3 scripts/hooks/validate_control_risk_references.py --force
python3 scripts/hooks/validate_riskmap.py --force

Legacy Persona Check:

We also perform a check to ensure that legacy persona references are retained as intended:

# Should return 0 results
grep -n "personaModelCreator\|personaModelConsumer" risk-map/yaml/controls.yaml
grep -n "personaModelCreator\|personaModelConsumer" risk-map/yaml/risks.yaml

A successful check should return zero results, indicating that legacy personas are correctly preserved.

5. Documentation Updates: Reflecting the Changes

Documentation is a living entity, and it's crucial to update it to reflect the new persona model. This involves updating control and risk examples in guide-controls.md and guide-risks.md respectively.

Updating guide-controls.md:

We add an example to illustrate shared responsibility:

#### Shared Responsibility Example

Controls may be assigned to multiple personas when responsibility is shared:

```yaml
- id: controlExample
  personas:
    - personaOne
    - personaTwo


#### Updating `guide-risks.md`:

Similarly, we update the risk examples:

```markdown
#### Multi-Persona Risk Example

Risks may apply to multiple personas who need to be aware of and mitigate them:

```yaml
- id: riskExample
  title: Example Risk
  personas:
    - personaOne
    - personaTwo


These updates ensure that the documentation accurately reflects the new multi-persona assignments.

## Quality Assurance Checklist: A Comprehensive Review

Our Quality Assurance (QA) checklist ensures that all aspects of the migration are thoroughly reviewed and validated.

### Prerequisites:

*   [ ] Workstream 3 mapping exercise completed.
*   [ ] Mapping document approved and finalized.

### Migration Execution:

*   [ ] All 29 control persona references updated per the mapping document.
*   [ ] All 26 risk persona references updated per the mapping document.
*   [ ] Shared responsibility correctly represented where specified in the mapping.
*   [ ] Schema validation passes.
*   [ ] Cross-reference validation passes.
*   [ ] Documentation examples updated.

## The Review Process: Ensuring Community Alignment

Our review process is structured into three phases to ensure thoroughness and community alignment.

### Phase A: Workstream 3 Mapping Exercise

*   Workstream 3 analyzes all controls and risks meticulously.
*   Proposed persona assignments are documented comprehensively.
*   Rationale for each mapping decision is provided clearly.
*   Shared responsibility scenarios are identified and documented.
*   **Deliverable:** A mapping document ready for review.

### Phase B: Mapping Document Review

*   The CoSAI community reviews the proposed mappings.
*   Subject matter experts validate the assignments.
*   Feedback is addressed, and the mapping document is finalized.
*   The mapping document is formally approved for implementation.

### Phase C: Implementation and Validation

*   Approved mappings are applied to `controls.yaml` and `risks.yaml`.
*   Validation scripts are executed to ensure data integrity.
*   A Pull Request (PR) is created with all changes for review.
*   A final technical review is conducted before merging the changes.

## Success Criteria: Defining a Successful Migration

We have defined clear success criteria for both the mapping and implementation phases.

### Mapping Phase:

*   [ ] Workstream 3 mapping exercise completed successfully.
*   [ ] Mapping document covers all 29 controls and 26 risks comprehensively.
*   [ ] Rationale documented for all assignments, providing a clear audit trail.
*   [ ] Mapping document approved by the CoSAI community, ensuring alignment.

### Implementation Phase:

*   [ ] All mappings match the approved mapping document precisely.
*   [ ] All validation scripts pass, confirming data integrity.
*   [ ] Mermaid graphs render correctly, ensuring visual consistency.
*   [ ] Documentation reflects the new persona model accurately.

## Rollback Plan: Preparing for Contingencies

Despite our best efforts, unforeseen issues may arise. Our rollback plan outlines the steps to take if the migration introduces problems:

1.  **Revert YAML files** to their pre-migration state, preserving the previous working configuration.
2.  **Keep schema changes**, as they are backward compatible and do not introduce breaking changes.
3.  **Defer Phase 3** until the issues are fully resolved, preventing further complications.
4.  **Maintain legacy personas** indefinitely if needed, ensuring continued functionality.

## Branch Strategy: A Structured Approach to Integration

Our branch strategy ensures a smooth and controlled integration process:

*   **Target branch:** `develop` (content changes require offline community review).
*   **Blocked by:**
    *   Phase 2 - Content Population
    *   Workstream 3 mapping exercise completion
    *   Mapping document approval

**_Important:_** This phase cannot begin until workstream 3 completes the mapping exercise and the CoSAI community approves the mapping document. Implementation requires offline community review before merging.

## Estimated Effort: Resource Planning and Timelines

We have estimated the effort required for both the mapping and implementation phases.

### Mapping Phase (Workstream 3):

*   Analysis of all controls and risks: 12-16 hours.
*   Documentation of mapping rationale: 4-6 hours.
*   Mapping document review period: 1-2 weeks.
*   **Mapping Phase Total:** 16-22 hours + 1-2 weeks review.

### Implementation Phase:

*   Apply mappings to YAML files: 4-6 hours.
*   Validation and testing: 3-4 hours.
*   Documentation updates: 2-3 hours.
*   Community review period: 1 week.
*   **Implementation Phase Total:** 9-13 hours + 1 week review.

### Overall Total:

25-35 hours + 2-3 weeks review.

## Key Considerations and Notes

*   **Critical Dependency:** This phase is blocked on workstream 3 completing the mapping exercise, highlighting its importance.
*   The mapping exercise is essential for determining the correct persona assignments, which is fundamental to the framework's accuracy.
*   Incorrect persona assignments will reduce the value and usability of the risk framework, underscoring the need for precision.
*   Community input and review are critical for validating mapping decisions, ensuring alignment and buy-in.
*   Consider incremental implementation if the mapping document is delivered in phases, allowing for more agile execution.
*   All mapping decisions must be documented with a clear rationale for future reference, creating an auditable and transparent process.

In conclusion, Phase 3 represents a significant step forward in the evolution of our risk management framework. By carefully migrating controls and risks to the new persona model, we enhance the framework's accuracy, relevance, and usability. This structured approach, combined with community collaboration and rigorous validation, ensures a successful transition. For more information on risk management frameworks, you can visit the **[National Institute of Standards and Technology (NIST)](https://www.nist.gov/)** website.