February 23, 2012

Risk Awareness Concerns and Organizational Risk Management System Potential Integration(s)

Photo courtesy of meship.com

By: Lisa DuBrock, CPA, CBCP, MBCI

Recently in an article written by Subrata Guha entitled “New ISO IEC 20000-1: Alignment with ISO 27001”, Guha makes the point that, “…. since ISO 20000-1 and ISO 27001 are so closely linked, there is a strong argument that these two standards should be implemented as a single management system – and, that the new release of ISO 20000-1 makes this process easier than ever before.

I contend that the melding of those 2 standards is certainly an excellent idea —especially since some well-defined areas such as incident management, change management, and security management link up so well. And, I believe that many companies have done just that; whether they implement the standards together or individually and then knit the individual management systems and overlapping control structures together.

What I’d like to propose today is — depending on your own corporate and organizational culture — to consider a coupling of two other standards that have a natural affinity to work together.  Those standards are ISO/IEC 27001:2005 Information Security Management System and ASIS SPC.1 Organizational Resilience:  Security, Preparedness and Continuity Management System.

Both the ISO 27001 and the ASIS SPC.1 standards build their foundation on the concept that management identifies, adopts, implements, monitors, updates and, most importantly, manages their related management system(s) based on that particular organization’s appetite for risk – i.e. Risk Appetite.

As with any organization’s business management system (BMS), the process of implementing that BMS to a standard (i.e. ISO 27001 or ASIS SPC.1) begins with and is based on the scope that the organization sets for its BMS.

In this instance, both ISO 27001 and ASIS SPC.1 adhere to the management system requirements of: Management Commitment (including resourcing, training and awareness, and approval of the system), Internal Audit, Management Review and Continual Improvement.

Both of these standards also require a statement of applicability (SOA).  However they differ in how the SOA is defined.  In SPC.1 the SOA documents the strategic weighting of security management, preparedness, emergency management, disaster management, crisis management and business continuity management.   In ISO 27001 the SOA is a documented statement describing the control objectives and controls that are relevant and applicable to the organizations ISMS.

What really differs between these standards, however, is the context of the risk process.  For ISO 27001, the context is based on the information assets identified within the scope of the management system.  Within SPC.1 the Organizational Resiliency Management System is based on legal and other requirements, information about significant hazards and threats and protection of critical not just information assets (physical, intangible, environmental and human).

By having an organization integrate the implementations of both ISO 27001 and ASIS SPC.1 standards simultaneously, it would almost be a certainty that a stronger and more clear understanding of risk and what is needed for that organization’s mitigation of those risks (i.e. to be more secure) would be achieved.

If you agree or not with this opinion, please share your comments and inputs regarding this potential integrated approach.

Privacy and Security Controls in Your Corporate Board Room — Perhaps a Review is Necessary

Photo courtesy of blog.dattobackup.com

In a recent article written by NICOLE PERLROTH a potential risk mitigation event was revealed and should be cause for all organization’s to re-verify that camera’s used in their corporate board rooms are properly and verifiably protected from hackers.

Ten years ago, videoconferencing systems were complicated and erratic, and ran on expensive, closed high-speed phone lines. Over the last decade, however, videoconferencing — like everything else — migrated to the Internet.

Now, many businesses use Internet protocol videoconferencing — a souped-up version of Skype — to connect with colleagues and customers. Most of these new systems were designed with visual and audio clarity — not security — in mind.

Click here to read this full article and become aware of how easily professional security experts were able to hack into the board room conference cameras of unsuspecting companies of all sizes.

If applicable, please pass this info along to those risk management and IT / information security team members in your own organization.

Google Plans to Alter Privacy Policy and Terms of Service

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The actions and decisions of Google can potentially affect many information security teams in organizations across the globe.  With that thought in mind, a recent announcement by Google to alter its privacy policy and terms of service to reflect the fact that it is now going to combine data from its various services into a single user profile may well be an event that requires close study, review and evaluation regarding an organization’s own existing privacy policy – i.e. particularly where services such as Google are involved.

It goes without saying that this privacy change by Google needs to also be closely reviewed where individual use of Google is employed as well.

In a recent article written by Thomas Claburn, Claburn is quick to point out that critics of the change have been quick to question Google’s decision.

This article also references Sen. Richard Blumenthal (D-Conn.) who said in a reaction blog posting that he’s troubled by the lack of an opt-out mechanism, and, David Jacobs, consumer protection fellow at the Electronic Privacy Information Center (EPIC), expressed concerns that Google’s changes decrease the ability of users to control how their personal information is being used.

Click here to read Claburn’s full article, and, be sure to utilize the useful links in that article to dig more deeply into the reference documents and related postings to this potential privacy risks.

Additional stories about this controversial decision by Google are also listed below:

Google Says Privacy Change Won’t Affect Government Users” by Jaikumar Vijayan

Google Stirs Up Privacy Hornet’s Nest” by Sharon Gaudin

Google Privacy Policy: Who Will be Affected and How You Can Choose What Information Gets Shared” by Cecilia Kang

Google Seeks to Clarify New Privacy Policy” by Doug Gross

Lawmakers Press Google on Privacy Policy Changes” (Reuters)

If applicable, please pass this information along to those information security and risk management team members in your organization, those members of privacy rights protection groups in your community and to members of your family who use Google on a daily basis.

Business Continuity Planners May Face “Frictionless Sharing” Risks from New Facebook Apps

Photo courtesy facebook.com

While information security and privacy rights protection teams within organizations continue to monitor the potential privacy risks that Facebook may be presenting to their employees, a new announcement was made today indicating that Facebook is now adding over 60+ new applications within their auto-share technology.

Click here to read a Facebook company blog covering this news as released by Facebook’s director of platform Cal Sjogreen.

As you will read, Facebook users can now immediately begin adding these new apps to their timelines.

As Sjogreen states, “…the apps are all set up to use the “frictionless sharing” function on the social network, meaning that users only have to give an app permission to share information once. After that, the app updates automatically to a user’s profile, letting their friends know instantly what they may be eating, studying or listening to at any given moment.”

While it may be too early to accurately assess any additional risks these apps may present to existing business continuity plans, it may be a good idea to inform information security specialists, risk managers and HR privacy managers of this event.

PS-Prep strategy planning teams in the private sector, in local community disaster preparedness groups and even risk mitigation discussions among family and friends may warrant a close watching of this recent announcement.

E-Discovery No Stranger on Campus

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In response to a few recent inquiries and comments from readers working in the educational field, and, in particular for those readers working in a university campus information security department, who requested that more discussions and information be presented on the topic of e-discovery relevant to a university campus environment, our staff would like to present a listing of recent postings and articles addressing this growing dynamic within the “discovery” process itself.

Dian Schaffhauser, a writer who covers technology and business related topics for a number of various publications, has recently written and posted an article entitled “An e-Discovery Primer”  — and, this information may be a great reference resource to offer anyone who wants to learn the basics of e-Discovery.

To this point, it is also important to realize that the “discovery” process is neither something new nor is this process limited to the digital era.  As Seth Gilbertson, associate counsel for the State University of New York states, “…discovery is the process of saving and producing records and other evidence pertaining to an activity that may be the subject of litigation.”

If applicable, or even if you are new to the discussions and risk mitigation potentials embedded in the e-discovery process, click here  to read Schaffhauser’s full article.

E-Discovery Guideline and Toolkit offering posted on the EDUCAUSE website presents e-discovery issues for universities to consider.

E-Discovery Trends: Potential ESI Sources Abound in Penn State Case” by Doug Austin

E-Discovering Reference” article by Spolanka

School districts wrestling with ABCs of electronic discovery, compliance” by Beth Pariseau, Senior News Writer

“Hey @wfryer looking for the 411 on eDiscovery: http://bit.ly/9hcxe9 (your wiki) Bottom line: do schools have to archive STUDENT email?”

The E-Discovery Question   – Don’t panic over the new regulations, but make sure your school’s policy is clear.

If applicable, please add your inputs, comments and experiences of e-discovery challenges you might have had to face in your university campus environment.

Information Security Lesson from Recent Zappos Breach Incident

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In the event that anyone on your organization’s information security team becomes complacent about the need to be ever diligent about maintenance and updating of information security levels in your organization — a privacy breach incident recently announced at Zappos.com should be adequate reminder that risk mitigation in this area is a 24/7 ongoing area of responsibility.

Zappos CEO Tony Hsieh had to recently notify customers by email stating that the Zappos web marketplace system location that houses customer privacy centric information was compromised — asking them to create a new password for their accounts immediately.

We’ve spent over 12 years building our reputation, brand, and trust with our customers,” Hsieh said in his email. “It’s painful to see us take so many steps back due to a single incident. I suppose the one saving grace is that the database that stores our customers’ information was not affected or accessed.”

Click here to view a copy of that email along with Hsieh’s email message to Zappo’s employees.

Although you never want to face such a situation in your own organization, certainly, Zappos’ reaction to this incident may contain valuable lessons to pass along to your own in-house information security, crisis and risk management and disaster preparedness teams.

Hacker “Yama Tough” Threatens Release of Source Code for Norton’s Antivirus Software

Photo courtesy of reuters.com

For our readers who utilize Norton’s Antivirus software applications as part of their organization’s information security plans, be aware of a story recently released on the Reuters’ news related website announcing that “Hackers are to release full Norton Antivirus code on Tuesday”.

It appears that a hacker who goes by the name of “Yama Tough” is threatening to release the full source code for Symantec Corp’s flagship Norton Antivirus software.

Click here to read more about this developing story as reported by Frank Jack Daniel.

If applicable, please pass this information along to those disaster preparedness and network security planning team members in your organization.

Online Privacy Risks and Predictions for 2012

 

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With 2012 now well on its way, online privacy related risks will become an important issue to information security and risk management team members in today’s global village of organizational inter-relationship activities, as well as, for the growing number of consumers who are relying more and more on online communication tools and applications to conduct their day to day purchases.

As online businesses grew in 2011 – through innovative technologies in advertising, cloud services and mobile apps – the call for improved levels of online privacy controls rang loudly and repeatedly throughout the industry.

With the collection and usage of consumer data spreading like wildfire across a myriad of emerging online businesses, 2011 was a year of extraordinary change for online privacy,” said Chris Babel, CEO of TRUSTe.   “Along with the excitement about the potential of innovative online technologies, the industry was also forced to address both trepidation and concern for the safety and respect of consumers’ personal privacy. TRUSTe  is pleased to share some of our privacy expectations for the New Year.”

Leveraging its unique vantage point, TRUSTe  posted on the ITBusinessEdge website  the following predictable events or trends to take place in the year ahead:

  1. There will be increased levels of activity by the FTC to go after websites with high levels of privacy violations related to 3rd party tracking.
  2. Mobile self-regulatory guidelines regarding online behavioral advertising (OBA) will grow In 2012.
  3. Knowledge of and practical applied experience with laws and regulations regarding privacy will become an even hotter job skill to have in 2012.
  4. There will be much more use of location-based technologies.
  5. Yanks abroad will most likely be forced to follow the EU individual privacy standards whenever doing business in Europe.
  6. Most likely there will be no comprehensive privacy legislation passed by the U.S. Congress in 2012.
  7. One of the 2012 Presidential candidates will announce plans for a new cabinet post — Secretary of Online Privacy.

If any of our readers have come across additional privacy related predictions for 2012, please share them in the comments section below…..

If applicable, pass this information along to those risk mitigation specialists in your organization who might view an online privacy breach issue as a serious economic disruptive event to their organization.

Click here  to view more details of these predictions.

Information Risk, Data Breach and Career Domain Websites Launched by ISMG

The Information Security Media Group (ISMG) recentlyannounced the debut of three (3) new international media sites:

  1. InfoRiskToday – which site addresses information security, risk management, fraud and compliance concerns that affect all organizations and industry sectors.
  2. DataBreachToday – will provide news, insights and education on data breach prevention, response and notification.
  3. CareersInfoSecurity – will provide a single-stop for the latest news, insights, training and education on career strategies, skills and trends for information security and risk management professionals at all levels.

Concurrent with the launch of these three new sites, ISMG also will debut soon a new, updated design for its existing sites: BankInfoSecurity; CUInfoSecurity; GovInfoSecurity and HealthcareInfoSecurity.

Click here  to read more about these new and free resource opportunities to be presented to business continuity, emergency / risk management and PS-Prep strategy planning team members.

Data Security and Privacy Issues Predicted in 2012 — NO SURPRISES

 

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As many of our readers, who are risk management team members in their organizations, work on their 2012 disaster preparedness plans and risk mitigation strategies relevant to their organizations, information security and privacy will remain high on their lists of considerations. 

Recently, an article, written by Richard L. Santalesa, attempted to address these concerns by providing a list of several events predicted to occur in 2012 that will occur across the privacy and data security landscape…. 

A quick summary of just some of those predicted events are as follows: 

     There will most likely be a significant revamp of the EU’s Data Protection Regulations – e.g. a potential requirement to designate a privacy officer within an organization, increased enforcement powers and penalties, and perhaps stronger protection for children under 18. 

     Perhaps the final version of the U.S. HIPAA breach notification rule will make a long awaited appearance, along with guidelines per Stage 2 of the electronic record incentive program within the HITECH Act, in 2012. 

     In 2012, the FTC will likely its finalized Privacy Report, formally titled “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.” 

     Better development of information security and data protection language in contracting agreements for cloud services will help provide guidance on cloud contracting issues addressing audit assurances, cloud security and accreditation, e-discovery issues, security controls and allocation of liability and responsibility for data security, to name but a few. 

     Continued data breach activity in 2012 will force many organizations to review their existing insurance policies to see what is and what is not covered in their business interruption insurance policies.  

     A growing importance in 2012 “of key buzz words that implicate data security and privacy issues, such as are BYOD (“Bring Your Own Device”) and COIT (“Consumerization of Information Technology”). 

Click here to view more about the predictions listed above as well as to read the full collection of Christine Marciano’s predictions of data security and privacy related activities to occur in 2012.

 

If applicable, please pass this information along to your other risk management or information security team members.