You Don't Have a CISO. Here's What's Actually Running Your Security.
Every cybersecurity framework, every compliance playbook, every vendor pitch deck assumes the same thing: somewhere in your organization, there's a Chief Information Security Officer making strategic security decisions, reporting to the board, and aligning risk management with business objectives.
For the vast majority of organizations in this country, that person doesn't exist.
Community banks, regional healthcare providers, manufacturing firms, school districts, municipal governments, logistics companies — these are organizations with real data, real regulatory obligations, and real attack surfaces. They handle PII, financial transactions, health records, and critical infrastructure. And in most of them, "security" is a responsibility stapled onto someone's existing job title, not a dedicated executive function.
I know because I'm one of those people. I manage network administration and IT security for a community bank. There is no CISO. There is no dedicated security team. There's me, a separate helpdesk team, and a managed service provider. And every framework, every audit checklist, and every piece of vendor marketing I encounter was designed for an organizational structure that looks nothing like mine.
This isn't a gap in my organization. It's the default state for most of the American economy. And the cybersecurity industry's refusal to design for it is one of the biggest unaddressed problems in technology leadership today.
The Myth of the Security Org Chart
The enterprise security model looks roughly like this: a CISO reports to the CEO or the board. Below the CISO sits a security operations team, a governance and compliance function, an identity and access management group, and some combination of architects, engineers, and analysts. This structure exists at large banks, Fortune 500 companies, federal agencies, and the organizations that write the frameworks everyone else is expected to follow.
Below a certain revenue threshold — and it's lower than most people think — that entire structure collapses into one or two people.
At a community bank with 150 employees and eight branches, you don't have a SOC. You have a network administrator who also reviews SIEM alerts. You don't have an IAM team. You have the same person managing Entra ID and Intune between firewall upgrades and server patching. You don't have a governance function. You have whoever the examiners talked to last time, trying to document controls in a format that maps to a framework designed for organizations fifty times your size.
This isn't a failure of leadership. It's a math problem. A qualified CISO commands a salary that exceeds the entire IT budget of most small organizations. Even the vCISO model — a virtual or fractional CISO engaged on a consulting basis — assumes a level of organizational maturity and budget allocation that many small firms haven't reached.
So what fills the gap? In practice, it's someone like me: a technical generalist with security credentials who absorbs the CISO function into an already full-time role. And that creates a set of challenges that the industry barely acknowledges.
The Three Problems Nobody Talks About
The authority problem. A CISO has organizational authority to set policy, approve architecture decisions, and escalate risk to the board. A network administrator who also handles security has none of that structural authority. When I identify a risk that requires budget, a process change, or an executive decision, I'm making a recommendation from a mid-level IT position — not delivering a mandate from the C-suite. The quality of the analysis is the same. The organizational weight behind it is not.
This matters most when security and convenience are in direct conflict — which is constantly. Enforcing multifactor authentication across the entire organization, restricting USB device access, requiring passkeys instead of passwords, blocking personal email on corporate devices — every one of these decisions creates friction. A CISO can absorb that friction because the role carries institutional authority. A network admin making the same recommendations is fighting an uphill political battle every time.
The scope problem. Enterprise security roles are specialized. One person handles detection and response. Another handles identity. Another handles compliance documentation. Another handles vendor risk management. When one person covers all of those functions — plus network infrastructure, endpoint management, server administration, and user support escalations — depth is the first casualty.
I can configure Trellix endpoint protection, manage Entra ID conditional access policies, review Elastic SIEM alerts, prepare for FFIEC examinations, evaluate vendor security postures, and plan infrastructure migrations. I do all of those things. What I can't do is give any single one of them the sustained, focused attention that a dedicated role would provide. The work gets done, but it gets done at the pace and depth that one person can sustain — which is fundamentally different from what a resourced security program delivers.
The development problem. CISOs have peer networks, board exposure, conference budgets, and professional development paths designed for their role. The person filling the CISO function at a small organization often has none of that. Certification costs come out of a limited training budget that also covers the helpdesk team. Conference attendance means the security function is unstaffed for a week. Peer networking happens on LinkedIn threads and Discord servers instead of CISO roundtables.
This creates an isolation problem that compounds over time. The person responsible for security decisions doesn't have regular access to the strategic conversations, threat intelligence briefings, and cross-industry perspective that inform good security leadership. They're making enterprise-grade decisions with small-organization resources and visibility.
What's Actually Working — Despite the Constraints
This isn't a doom-and-gloom assessment. Small organizations have structural advantages in security that large enterprises don't, and the people filling these hybrid roles have developed operational approaches that are worth studying.
Proximity to the business creates better risk intuition. A CISO at a large bank might never interact with the tellers processing wire transfers. The person managing security at a community bank walks past them every day. That proximity creates an intuitive understanding of where the operational risk actually lives — not where a framework says it should live, but where it shows up in practice. When I evaluate a threat, I'm not modeling an abstract attack tree. I'm thinking about specific people, specific processes, and specific vulnerabilities that I've observed firsthand.
Constraint forces prioritization. When you can't do everything, you're forced to identify what actually matters. Large security programs can afford to implement controls comprehensively — and often do, including controls that generate noise without reducing risk. A resource-constrained operator has to make hard choices about which risks get addressed first, which controls deliver the most value per hour invested, and which audit findings represent genuine danger versus checkbox compliance. That ruthless prioritization often produces a more effective security posture than a well-funded program that tries to cover everything equally.
Technical breadth enables faster pattern recognition. The network administrator who also handles security sees the full stack — infrastructure, identity, endpoints, email, cloud services, user behavior. A siloed SOC analyst sees only what the SIEM shows them. When something anomalous happens, the generalist often recognizes it faster because they understand how all the systems interact. They know that a specific authentication pattern is unusual because they configured the conditional access policy. They know that a particular network traffic spike is suspicious because they built the VLAN segmentation. That full-stack awareness is a genuine detection advantage.
What Needs to Change
The cybersecurity industry needs to stop designing exclusively for organizations that have dedicated security leadership and start building for the ones that don't.
Frameworks need a small-organization implementation track. NIST CSF, ISO 27001, and CIS Controls are valuable frameworks, but their implementation guidance assumes dedicated security personnel and established governance structures. A parallel implementation guide — designed for organizations where one or two people cover the entire security function — would dramatically increase adoption where it's needed most. Not a watered-down version. A right-sized one.
Vendor tools need to be operable by generalists. The security tooling market is built for specialists. SIEM platforms assume a dedicated analyst. EDR solutions assume a security operations workflow. IAM platforms assume an identity governance team. When the person configuring the tool is the same person administering the network, managing the servers, and answering escalated helpdesk tickets, the tool needs to deliver value without requiring full-time attention. That's a design problem, not a training problem.
The vCISO model needs to mature. Fractional CISO services exist, but the market is inconsistent. Some vCISOs provide genuine strategic leadership. Others provide a compliance checkbox — a name on an org chart for auditors to reference. Small organizations need a model that delivers real governance, real risk oversight, and real board-level communication at a price point that doesn't consume the entire security budget. That model is emerging, but it's not mature yet.
Professional development needs to account for hybrid roles. Certification bodies, training providers, and professional organizations need to recognize that the fastest-growing segment of cybersecurity professionals isn't specialists — it's generalists who carry security responsibility alongside other IT functions. Training programs, mentorship structures, and peer communities designed for this population would address the isolation problem and improve the quality of security decisions across thousands of organizations.
The Leadership Question
This is ultimately a leadership problem, not a technical one. The organizations that navigate it best are the ones where senior leadership — the CEO, the board, or the ownership group — understands that security is a business function, not an IT task. Where the person filling the security role, regardless of their title, has a direct line to decision-makers and the organizational support to act on what they find.
The title on the door matters less than the authority behind it. A network administrator with board access, a clear mandate, and adequate resources can deliver effective security leadership. A CISO with a title and no budget can't.
But the industry needs to meet these organizations where they are — not where the frameworks assume they should be. Because right now, the people actually defending most of America's critical infrastructure aren't CISOs. They're the generalists who said yes when someone asked, "Can you also handle security?" And they deserve tools, frameworks, and professional support designed for the job they're actually doing.
About Edith Forestal
Edith L. Forestal is a CISSP, CISM, and CASP+/SecurityX-certified cybersecurity professional and the founder of Forestal Security (forestalsecurity.com), a cybersecurity consulting platform focused on community banks and SMBs. He brings 23 years of law enforcement experience with the Kokomo Police Department to his cybersecurity work and holds a Master's degree in Cybersecurity and Information Assurance from Western Governors University.

