The IT (Amendment) Act, 2008 has established a strong data protection regime in the country, by requiring body corporates to implement ‘reasonable security practices’ to protect ‘sensitive personal information’. What is ‘reasonable security’ though? An organization is expected to have a comprehensive information security program, with appropriate controls that are commensurate with its information assets and risk assessment. In the event of a security breach, it should be able to demonstrate that its practices were in conformance with its written security policy, and that its controls were adequate. It is, however not that easy, since enterprises are outsourcing some of their
work, and they must manage information risk across a vast global network of Service Providers. Outsourcing thus brings into focus the practices followed by Service Providers, and their accountability.

Service Providers are subjected to ongoing assessments and on-site audits, which are labor intensive and costly for both the sides. Likewise, Service Providers with hundreds of Clients distributed in various geographies must submit themselves to several audits by the Clients. Moreover, the multiple assessments are based on different frameworks, questionnaires and audit approaches – clearly they result in wasted effort and time; and, of course, higher costs. It is the wish of both – Clients and Service Providers – that third-party evaluations that are standards-based, or framework-based, may ease the assessment burden. But how do they view the implementation of a standard, or best practices for security; and an assessment framework to validate that this has indeed made the organization secure? Again both of them will have a different perspective on this.