Best Practices Considerations for Managing a CISO Transition

Disclaimer:

The views and opinions expressed in this article are solely my own and do not represent the views, opinions, or positions of my current or any former employer. This article is based on my personal experiences and observations as a Chief Information Security Officer and is intended for informational purposes only.

Overview

With years of experience as a Chief Information Security Officer (CISO), I've dedicated my career to building security programs that allow organizations to properly defend and respond to cyber threats, ensure compliance, and navigate the ever-changing landscape of information security.

Recently, as I realized I would soon be leaving the role of CISO at my current company and looking for my next CISO challenge, I realized that there was one policy or process I had never appropriately considered—transitioning a CISO out of a company.

Looking for published guidelines or best practices for the CISO transition revealed a startling lack. Unlike other executive transitions, which can follow established playbooks, the unique sensitivities of the CISO role—such as privileged access to critical systems, intimate knowledge of an organization's vulnerabilities, and managing customer trust—require a more nuanced approach that many organizations have yet to formalize.

This gap in guidance can leave companies vulnerable to operational disruptions, insider threats, and reputational harm, underscoring the critical need for effective CISO transitions.

With this in mind, I wrote this article to offer some best practices for managing a CISO's transition. I hope this piece will stimulate discussion and create a formal set of best practices.

Scenario 1 - Ideal: Amicable Separation with Sufficient Notice

Overview:

In the ideal scenario, the CISO provides 3–6 months' notice, allowing for a planned and cooperative transition. This situation reflects the professionalism and forethought many strive to uphold in this role.

Best Practices

1. Develop a Transition Plan:?Develop a clear plan with milestones for knowledge transfer, access revocation, and onboarding of the successor to the CISO. Engage key stakeholders to address potential disruptions proactively. The CISO role typically extends across the business, the executive team, and the board.
2. Facilitate Knowledge Transfer: Document ongoing projects, incident history, and vendor relationships to ensure continuity. Conduct debriefing meetings to capture critical institutional knowledge.
3. Keep an eye on Compliance and Regulations: The CISO role is typically the pinnacle of privileged access. When the CISO departs, you can be sure that auditors and regulators will scrutinize the steps taken to manage this transition. Document every decision and step the company takes as part of this transition. Public companies should pay particular attention to the recently enacted SEC 17 CFR regulations. For example, while the transition is not technically a cybersecurity threat, it is inarguably a material risk and may materially affect business strategy, results of operations, or financial condition.
4. Onboarding the Successor:?Ideally, the incoming CISO should overlap with the transitioning CISO as much as possible to ensure seamless leadership continuity. The outgoing CISO should introduce the successor to regulators, vendors, and key stakeholders. If this is not possible, the company leadership should introduce the successor. It is not a good idea to let the stakeholders discover the change independently.
5. Involve the Exiting CISO in Messaging (Where Possible): Work collaboratively to craft internal and external communications that reassure employees, stakeholders, and partners about continuity and stability.

Recommended Severance Package

• Compensation: Equivalent to 3–6 months' salary.
• Benefits Continuation: Healthcare and retirement contributions for the severance period.
• Bonuses: Payment of earned or deferred bonuses.
• Legal Protections: Indemnification and extended D&O or E&O insurance coverage.

Severance Package Rationale

• This package reflects the value of the CISO's contributions while fostering goodwill.
• It encourages full cooperation during the transition and post-departure availability for consultation.
• Generous terms reduce the likelihood of disputes and strengthen confidentiality and non-disparagement agreements.

Scenario 2 - Less than Ideal: Amicable Separation with Short but Reasonable Notice (2–4 Weeks)

Overview:

This scenario involves a compressed timeline, where the CISO or the organization gives the other party 2–4 weeks' notice. While this situation is still amicable, it challenges both parties to manage a smooth transition under time constraints.

Best Practices

1. Prioritize Knowledge Transfer: Focus on high-priority tasks and items like incident response plans and ongoing security initiatives. Clear the deck so the outgoing CISO can concentrate on the knowledge transfer. Do not assign them any new tasks that may divert their focus. Ensure that relevant company personnel facilitate the knowledge transfer. Failure to do so may result in the outgoing CISO neglecting steps they consider common knowledge or simply forgetting to include topics not documented elsewhere.
2. Reinforce Security Controls: The company should conduct an immediate access audit and revoke non-essential privileges. The company must assign a suitable interim CISO if a successor isn't ready. As mentioned in Scenario 1, maintaining compliance, especially in an abbreviated timeline, is crucial.
3. Fast-Track Succession Planning: Expedite the hiring process while ensuring stability through interim arrangements. Consider using vCISO services as a bridge until the company finds, hires, and onboards a suitable successor.
4. Collaborate on Messaging: Create clear, concise communications that reassure internal and external audiences.
5. Test and Update Critical Processes Where the CISO plays a Key Role:?Ensure that Business Continuity and Disaster Recovery plans are updated to reflect the interim structure. Test the plans to ensure their effectiveness. Validate that the company's Incident Response Plan is also current. Perform a tabletop exercise to ensure clear communication lines.

Recommended Severance Package

• Compensation: Equivalent to 4–6 months' salary.
• Benefits Continuation: Extended healthcare and retirement benefits.
• Bonuses: Payment of earned or deferred bonuses.
• Legal Protections: Indemnification, insurance coverage, and mutual non-disparagement clauses.

Severance Package Rationale

• A more significant severance acknowledges the challenges of a compressed timeline.
• It incentivizes full cooperation and secures post-departure availability for urgent needs.
• Fairness in compensation reinforces trust and enhances the organization's reputation.

Scenario 3 - Negative Circumstances: Confrontational Separation with Limited or No Notice

Scenario Overview

In confrontational scenarios, the relationship between the CISO and the organization deteriorates, resulting in a sudden termination with less than a week's notice. These situations are inherently high-risk, requiring swift and decisive action.

Best Practices

1. Immediate Security Actions:??To mitigate insider threats, especially privileged access, revoke all access within 24 hours. Monitor the outgoing CISO's online activity for anomalies or unauthorized activity. Consider whether this event rises to the level of a security incident and act accordingly. This consideration is crucial for public companies.
2. Knowledge Preservation:??Before departure, capture as much critical documentation as possible. Engage senior staff to fill gaps. Depending on the security group structure, it may be preferable to leverage resources outside of the security group.
3. Handle Messaging Carefully: If collaboration is feasible, involve the CISO in messaging to maintain professionalism. If not, ensure all communications are neutral and focused on continuity.
4. Crisis Management: Reassure employees internally and manage stakeholder confidence externally.

Recommended Severance Package

• Compensation: Equivalent to 6–12 months' salary.
• Benefits Continuation: Extended healthcare and retirement contributions.
• Bonuses: Payment of earned or deferred bonuses.
• Legal Protections: Indemnification, extended D&O or E&O insurance, and confidentiality agreements.

Severance Package Rationale

• A generous package can help to de-escalate tensions and reduce the likelihood of retaliatory actions or legal disputes from either party.
• It can help secure cooperation for post-exit needs, such as regulatory inquiries, knowledge gaps, or unresolved projects.
• It demonstrates professionalism and preserves the organization's reputation, even under challenging circumstances.

Conclusion

The lack of best practices for a CISO transition poses a significant risk. Whether the separation is amicable or confrontational, a thoughtful approach that includes clear plans, fair severance packages, and professional communication can ensure a smooth transition for the organization, the departing CISO, and their incoming successor. Considering the "The Great CISO Resignation" piece by Rick Crandall of the National Cybersecurity Center (NCC), these transitions will likely increase in frequency.

The best practices I suggested in this article can help mitigate risks and reinforce trust, respect, and professionalism—qualities that define any successful leadership transition. By addressing these gaps, organizations can better prepare for the inevitable leadership changes and ensure security and stability.

I invite your thoughts and input.