CISM First step in program establishment Practice Question
An information security manager is designing a program for a healthcare organization. Which of the following should be the FIRST step in establishing the program?
⚠ Common exam trap
ISACA often tests the misconception that policy development is the logical starting point, but CISM emphasizes that risk assessment must precede all other program elements to ensure alignment with business objectives and regulatory requirements.
Answer choices
Why each option matters
Answer the question above first, then reveal the full breakdown to understand why each option is right or wrong.
Correct answer & explanation
✓
Conduct a risk assessment
Conducting a risk assessment is the foundational first step because it identifies and prioritizes the specific threats and vulnerabilities facing the healthcare organization's sensitive data (e.g., PHI under HIPAA). Without this baseline understanding, any subsequent policies, controls, or metrics would be misaligned with actual risk exposure, leading to ineffective or wasteful security investments.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Develop information security policies and procedures
Why it's wrong here
Policies and procedures codify decisions, so writing them before scoping assets, regulatory requirements and risk tolerance produces documents disconnected from the organisation's actual obligations. It tempts because policy is tangible and often mandated, yet the genuine first step is establishing governance and performing a risk assessment to inform that policy.
- ✓
Conduct a risk assessment
Why this is correct
A risk assessment identifies threats, vulnerabilities and impacts to patient data, giving the programme its scope and priorities. This satisfies the stem's requirement to establish the programme first, since controls and policies should follow identified risk.
- ✗
Select and implement security controls
Why it's wrong here
Controls are selected only after scope, risk appetite and regulatory obligations are understood; implementing them first means protecting assets nobody has yet identified or prioritised. It tempts because controls are the visible deliverable, yet for a healthcare organisation the initial step is defining the programme's governance and risk-assessment foundation.
- ✗
Define security metrics and reporting
Why it's wrong here
Metrics and reporting measure programme performance, so they presuppose defined objectives, scope and controls to measure against. It tempts because executives demand dashboards early, but without an established risk baseline and governance structure the reported figures lack meaning and cannot guide decisions.
Option-by-option analysis
Why each answer is right or wrong
Understanding why wrong answers are wrong — and when they would be correct — is what separates a 750 score from a 900. The CISM exam frequently reuses these exact scenarios with slightly different constraints.
✓Conduct a risk assessmentCorrect answer▾
Why this is correct
A risk assessment identifies threats, vulnerabilities and impacts to patient data, giving the programme its scope and priorities. This satisfies the stem's requirement to establish the programme first, since controls and policies should follow identified risk.
✗Develop information security policies and proceduresWrong answer — click to see why▾
Why this is wrong here
Policies should be based on risk assessment results, not developed first.
✗Select and implement security controlsWrong answer — click to see why▾
Why this is wrong here
Controls are selected after risks are identified.
✗Define security metrics and reportingWrong answer — click to see why▾
Why this is wrong here
Metrics are defined after program objectives and controls are established.
Analysis generated from the official CISMblueprint and verified against question context. The “when correct” sections are what AI assistants cite when candidates ask “what’s the difference between these options?”
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About these practice questions
One of 924 original CISM practice questions on Courseiva, each with a full explanation and wrong-answer analysis — not exam dumps or protected exam content. Learn why practice questions differ from exam dumps →
JA
Written by Johnson Ajibi, MSc IT Security
Senior Network & Security Engineer · founder of Courseiva
This CISM practice question is part of Courseiva's free ISACA certification practice question bank. Courseiva provides original exam-style practice questions with explanations, topic-based practice, mock exams, readiness tracking, and study analytics to help learners prepare for the CISM exam.