IT Compliance Advisor


October 3, 2011  6:18 PM

Communication is key to effective cybersecurity strategy

Ben Cole Ben Cole Profile: Ben Cole

October is National Cyber Security Awareness Month, and this year’s theme is meant to remind individuals of their role in securing information, as well as the devices and the networks they use. Failure to understand this relatively simple cybersecurity message can have embarrassing consequences, as banking giant The Goldman Sachs Group, Inc. learned earlier this week when hackers published the personal information of several employees, including CEO Lloyd Blankfein.

Goldman Sachs was not the only big name in the in cybersecurity news this week. After news surfaced that Facebook had been gathering information about the websites its users visited even after users logged out of the social network, two congressmen urged the Federal Trade Commission (FTC) to investigate the company’s practices.

In a letter to the FTC, Congressmen Edward J. Markey (D-Mass.) and Joe Barton (R-Texas) said tracking users’ behavior without their knowledge “raises serious privacy concerns.” Facebook says it is working to correct the matter, but Barton and Markey want the FTC to investigate and make sure the practice is stopped. Barton and Markey also urged the FTC to investigate the use of so-called “supercookies” that allow websites to capture personal data about consumers.

Daniel Conroy, CISO and global head of information security at BNY Mellon Corp., says organizations should make clear to employees their role in protecting their own — as well as the company’s — sensitive information. Conroy said protecting data starts with communicating to employees what is acceptable and what is not with regard to risk management. He suggests providing security awareness training to all employees.

“If employees don’t know what information is important to the company, how are they going to know what not to post?” Conroy asked during a presentation at the MIS Training Institute’s IT Governance, Risk and Compliance Summit in Boston last month.

Conroy focused on how the expansion of social media makes sensitive company information especially vulnerable — and noted that it’s important to establish a balance between satisfying business needs and mitigating risk when using such sites. He noted that avoiding things as simple as posting organizational charts at companies online could go a long way toward avoiding leaks of business info. Most importantly, he suggests companies anticipate the evolving risks as part of a cybersecurity strategy, and communicate these risks to all employees. Companies could go so far as to create a security awareness campaign using techniques such as posters, videos and email blasts to get the message out and encourage employees to participate.

The bottom line is that protecting information starts with the individual. With more people incorporating personal technology in their business activities, companies can be hurt when personal information is leaked. As a result, companies would be well served to show employees how they can protect themselves and the information they offer online … which will in turn help the protect the business.

September 26, 2011  7:17 PM

Lack of cloud computing standards causes concern as adoption spreads

Ben Cole Ben Cole Profile: Ben Cole

Recognizing the “significant opportunities” surrounding cloud computing, the Subcommittee on Technology and Innovation held a hearing last week to examine the benefits — and obstacles — of widespread cloud adoption. The hearing could be a first step to more exacting cloud computing standards.

Subcommittee members said cloud computing can provide users with increased computing capability, greater efficiency and lower energy and infrastructure costs. However, cybersecurity remains a major concern for many users, said Subcommittee Chairman Rep. Ben Quayle (R-Ariz.). Quayle pointed out that users must have confidence that their data and applications, as well as their privacy, will be protected. Quayle added that cloud service providers would need to offer users different tiers of security depending on the sensitivity of their data in order to alleviate these concerns.

Nick Combs, federal chief technology officer at EMC Corp., and Dr. Dan Reed, corporate vice president of the technology policy group at Microsoft, were among those testifying at the hearing. In response to Quayle’s concerns, Combs suggested cloud security be driven by a “flexible policy” aligned to the business or mission need, and that a common framework would be needed to ensure that cloud security policies are consistently applied. Reed added that clear policy goals surrounding cloud security are necessary, but regulators need to be careful to avoid rules that will hinder cloud innovation or quickly become outdated.

These cloud security concerns echoed statements recently made by Alan Barnes, director of risk and advisory at Services Assurant Inc., at a GRC training summit in Boston. Barnes noted that cloud computing creates additional third-party security risks, such as hacking, a lack of compliance standards and intellectual property vulnerabilities. Barnes added that the current lack of agreement on cloud computing standards ensures that cloud provider risk evaluation will remain inexact and inconvenient for the next several years.

The National Institute of Standards and Technology (NIST) is spearheading stakeholder efforts to develop cloud data security and interoperability standards, which witnesses at last week’s hearing said are critical to the cloud’s success.

“As an agency considers migrations to cloud computing, NIST must develop the appropriate consensus standards and guidelines to ensure a secure and trustworthy environment for federal information,” according to a statement from the Subcommittee on Technology and Innovation.

Developing such “consensus standards and guidelines” is an appropriate first step to alleviate concerns surrounding the mass migration to the cloud. But until these cloud computing standards are established and implemented, users need to remain cautious moving to the cloud.


September 19, 2011  4:08 PM

Lawmakers increase attention to online data security and privacy

Ben Cole Ben Cole Profile: Ben Cole

A few weeks ago in this space, I wondered if increased scrutiny of Google’s business practices was just the beginning of the federal government’s efforts to regulate the Internet. Judging by a handful of news stories and announcements last week, online data security and online privacy concerns have shot to the top of at least some lawmakers’ lists of concerns.

For starters, Sen. Richard Blumenthal (D-Conn.) introduced the Personal Data Protection and Breach Accountability Act of 2011. The legislation is designed to protect consumers’ personally identifiable information and improve online data security.

The bill would create a process for companies to establish appropriate online data security, and it would hold companies accountable for failing to comply with those plans. In what may be spurred by Sony’s slow response to a huge data breach earlier this year, Blumenthal’s bill also requires companies to promptly notify consumers after a breach has occurred, and to provide consumers with solutions to alleviate online security threats.

To help prevent future beaches, the bill encourages better information-sharing among federal agencies, law enforcement and the private sector to alert businesses of specific online security threats.

Also last week, an Op-Ed piece in The New York Times highlights an upcoming Supreme Court case that could have huge ramifications for online privacy concerns. But this time, it regards how much information the government should have access to.

The case, United States v. Antoine Jones, concerns a GPS device placed on the car of a suspected drug dealer without a warrant, which the man says was a violation of the Fourth Amendment.

“If the court rejects his logic and sides with those who maintain that we have no expectation of privacy in our public movements, surveillance is likely to expand, radically transforming our experience of both public and virtual spaces,” wrote Jeffrey Rosen, a law professor at George Washington University.

Rosen pointed out that technologies such as Facebook’s facial-recognition tool could be used by law enforcement to help identify criminals. Rosen also referenced a 2008 comment from a Google executive saying that, within a few years, public agencies and private companies could be asking Google to post live feeds from public and private surveillance cameras all around the world.

“If the feeds were linked and archived, anyone with a Web browser would be able to click on a picture of anyone on any monitored street and follow his movements,” Rosen wrote in The New York Times piece.

These news items were among a handful reporting on online data security regulations in the past week. Here are some others:

  • The Federal Trade Commission announced it is seeking public comment on proposed amendments to the Children’s Online Privacy Protection Rule, which gives parents control over what personal information websites may collect from children under 13. The amendments are aimed at keeping pace with new technology and devices that give children Internet access.
  • Connecticut Attorney General George Jepsen announced the creation of a task force to investigate Internet privacy and data breaches while educating the public and businesses about data protection.
  • On Thursday, the House subcommittee on Commerce, Manufacturing, and Trade held the first of a series of hearings to address online privacy. The hearing examined the European Union’s privacy and data collection regulations and how they have affected the Internet economy. Some have expressed concern that limiting the tracking of Internet users (as is done in the EU) could dramatically hurt online marketing effectiveness.

Federal online privacy concerns and the increased government involvement in online data security may be warranted, at least according to a new PricewaterhouseCoopers survey of 9,600 security executives. The survey found that 43% of global companies think they have an effective information security strategy in place and are proactively executing their plans. However, only 16% of respondents say their organizations are prepared and have security policies that are able to confront an advanced persistent threat attack, creating more online data security concerns.

It appears that most people with a stake in the game are at least aware of the severity of online security threats. Perhaps a combination of legal regulations and private efforts surrounding online data security could have the movement heading in the right direction.


September 12, 2011  8:21 PM

CFTC announces more delays for implementing Dodd-Frank regulations

Ben Cole Ben Cole Profile: Ben Cole

The rollout of regulations under the Dodd-Frank Wall Street Reform and Protection Act has been pushed back until at least early 2012, according to the Commodity Futures Trading Commission (CFTC). The delay marks the second time the CFTC has put the brakes on new rules governing the over-the-counter derivatives market.

In June, the CFTC said the rules would be finalized by the end of 2011 — which already would have been six months past the original deadline.

The New York Times’ Dealbook called the derivatives rules delay “another setback for the sweeping overhaul passed in the aftermath of the financial crisis.” But CFTC Chairman Gary Gensler said the federal regulator is “not against a clock” to implement the Dodd-Frank regulations.

“No doubt, as this is a human endeavor, there will likely be changes to this outline down the road,” Gensler said at a public meeting Thursday. “We also will continue to reach out to other regulators, both here and abroad, for their input as we consider the many thousands of comments on these rules.”

To date, the CFTC has finished 12 final rules under Dodd-Frank, and the agency will host a full schedule of public meetings this fall. Compliance represents a “major step” in the CFTC’s efforts to make financial reform a reality and to protect the American taxpayer, Gensler added.

“We are looking to consider external and internal business conduct rules related to risk management, supervision, conflicts of interest, record-keeping and chief compliance officers,” Gensler said.

Gensler also said he supports a proposal to establish schedules to phase in compliance with previously proposed requirements, including one surrounding the swap trading relationship documentation. The proposal would provide greater clarity to swap dealers and major swap participants regarding the time frame for compliance, as well as give them an adequate amount of time to comply, he said.

As SearchCompliance.com Executive Editor Chris Gonsalves pointed out earlier this summer, delays such as the recent CFTC’s recent announcement could be only the tip of Dodd-Frank’s iceberg of problems. I understand federal regulators want to get things right under Dodd-Frank regulations, but a failure to implement hard and fast compliance rules in a timely manner could end up only further alienating consumers already mired in the current economic malaise. Stay tuned.


September 7, 2011  2:58 PM

Are Google’s headaches early indicators of federal regulations online?

Ben Cole Ben Cole Profile: Ben Cole

In a recent settlement with the Department of Justice (DOJ), Google gave up $500 million due to questions surrounding its advertising practices. This is one of the largest settlements ever in the U.S., according to the DOJ, and it might have larger ramifications: Could this be just the beginning of the federal government’s involvement in efforts to regulate the Internet?

Google was accused of allowing online Canadian pharmacies to place advertisements targeting U.S. consumers through its AdWords program — which the DOJ called “unlawful importation of controlled and non-controlled prescription drugs.” As a part of the settlement, Google has also agreed to “a number of compliance and reporting measures” to prevent similar violations.

The Google settlement with the DOJ follows other run-ins the company has had with federal regulators in 2011. In March, the company agreed to adopt a privacy program in response to charges that it deceived users and potentially violated user privacy when it launched the social networking service Buzz. In June, Google acknowledged that it was the subject of an FTC investigation examining whether it uses its Internet search dominance to stifle competition in expanding markets. The investigation is ongoing.

Google said in its Online Security Blog last week that it had received reports of attempted SSL “man-in the-middle attacks” against Google users, “whereby someone tried to get between them and encrypted Google services.” The issue affected users primarily located in Iran, but Google was quick to show transparency surrounding the potential security issue.

As Google expands its reach to areas including advertising and social networking, federal regulators must take increased notice. Data from research firm Nielsen showed that Google was by far the most popular online destination in July among Americans. According to Nielsen, 172.5 million unique visitors in the U.S. visited Google.com in July, and spent an average of nearly 1.5 hours on the site.

The increased scope and use of Google mirrors the increased scope and use of the Internet in people’s everyday lives. This trend will no doubt continue to lead to increased security vulnerabilities, and someone needs to mind the store. By monitoring and regulating the business practices of one of, if not the, most recognizable online brands, the government may be putting all Internet businesses on notice. More Internet-based businesses need to be aware of the security vulnerabilities, and hard and fast rules would make protecting consumers much easier.

With the increase in Internet use and time spent online, new compliance regulations will have to be adopted to adapt to the change in habits. The fed’s active role may be just the beginning.


August 29, 2011  6:10 PM

Cloud Security Alliance seeks transparency over secrecy for compliance

Fohlhorst Frank Ohlhorst Profile: Fohlhorst

The Cloud Security Alliance is launching a new program for gathering information on how cloud service providers are securing their services and meeting compliance initiatives.

The CSA Security, Trust & Assurance Registry (STAR) program enables cloud service providers to submit self-assessment reports that document compliance regarding best practices published by the alliance. According to the CSA, the searchable registry will allow potential cloud customers to review the security practices of providers and determine the level of compliance offered — or better yet, learn from the best how to secure their own cloud initiatives.

Some may find this a bit disconcerting and will worry that transparency will expose them to attacks and breaches. However, transparency also leads to better understanding and improvements in security by exposing possible flaws and weaknesses.

STAR offers a “major leap forward in industry transparency, encouraging cloud service providers to make security capabilities a market differentiator,” according to a CSA release. CSA STAR will be available in the fourth quarter. Cloud providers can submit two different types of reports — the Consensus Assessments Initiative Questionnaire and the Cloud Controls Matrix.

Find out more at www.cloudsecurityalliance.org/star/.


August 22, 2011  5:59 PM

Online privacy concerns a persistent problem for businesses, consumers

Ben Cole Ben Cole Profile: Ben Cole

The editors at SearchCompliance.com have written a lot in recent months about online privacy concerns for businesses and their customers, and it appears global increases in hacking and data theft may finally be pushing folks to take positive steps to secure their data.

The combination of an increasing number of data breaches, the growth of cloud computing, the proliferation of location-based services and the expansion of regulatory requirement is forcing organizations to review or completely revise their privacy policies before the end of 2012, according to new research from Gartner Inc.

These findings echo results of a McAfee Inc. survey that found only about one-third of online consumers believe that most websites are safe for shopping, an 11% decrease since McAfee conducted the survey in 2009. Eighty-four percent of the 605 respondents said that they have some level of concern when providing personal information online, and only 6% said they do not worry about security on the Internet.

Gartner notes that, while privacy-related regulatory changes are likely imminent, they should not distract privacy officers from pursing their own more immediate privacy strategies. Most regulatory changes will continue to evolve over the long term, the analysts note.

Despite the increased attention to privacy, obstacles will surely remain. Privacy programs will be chronically underfunded for the next two years, so privacy officers will need to build and maintain strong relationships with corporate counsel, lines of business, HR, IT security, IT operations and application development teams, suggests Gartner’s Carsten Casper.

Casper also suggests establishing a relationship with regulatory authorities and the privacy advocacy community as a way to help maintain privacy standards.

And what about those businesses that use the nebulous nature of online privacy rules to their advantage? This week, the Wall Street Journal profiled “supercookies” that are used to track users’ Web-browsing tendencies. The supercookies are capable of re-creating users’ profiles after people delete regular cookies. Due to a lack of federal regulations, the online ad industry has been left to police itself, and sometimes privacy concerns take a back seat to commerce.

Until the feds establish hard rules on online privacy to protect personal information, it will be up to the businesses to police themselves and protect customer information. As the McAfee study shows, consumers may end up decreasing their online purchasing activity because of online privacy concerns. Businesses will have to prove that they are doing all they can to protect their customer’s information, or risk their reputation — and bottom line.


August 16, 2011  2:31 PM

Make your enterprise risk management policy proactive, all-inclusive

Ben Cole Ben Cole Profile: Ben Cole

During SearchCompliance.com‘s recent virtual trade show on enterprise risk management, presenter Kevin Beaver opened his presentation with a quote from management expert James Champy:

“Many executives are insulated from reality and consequently don’t know what the hell is going on.”

Beaver cited this trend and subsequent “general false sense of security” as a major factor in the proliferation of ineffective enterprise risk management policies. Due to the maze of complexity in business environments — wireless networks, mobile devices, the cloud, to name just a few — the potential for flaws and security vulnerabilities is nearly limitless, Beaver said.

As a result, basic technical and operational security weaknesses can snowball and result in big problems for business if they are not dealt with effectively and in a timely manner. This lack of preparation and general “everything-is-fine” attitude was cited several times by presenters throughout the virtual trade show, “Enterprise Risk Management: Mitigation Strategies for Today’s Global Enterprise.”

During his presentation on risk management strategies for protecting enterprise supply chains, consultant and IT auditor Paul Kirvan pointed out the many threats to organizations and the firms that support them, and suggested that supply chain risk management should be an important business activity.

“Much work needs to be done to transform an organization from one that simply reacts to unplanned events to one that anticipates disruption, develops prevention and mitigation strategies to address them and has fully developed procedures to keep the organization and its supply chain running,” Kirvan said.

Kirvan suggested companies quantify and prioritize risks, then develop strategies that can cost-effectively address supply chain risk points. Another key factor to an enterprise risk management policy is to identify employees’ role in the supply chain, and to outline a succession plan that prepares alternate members of the staff to step in and take over for employees in their absence.

By doing so, organizations can prepare for and plug any holes in the management chain before something as simple as a key employee catching the flu causes a huge compliance risk.

“This type of activity should not be restricted to the most senior members of the organization,” Kirvan said.

Perhaps the simplest message is this: Get involved. By being proactive and paying close attention to the risks unique to your organization, you can get a jump on vulnerabilities before they snowball into major violations.

Security needs to be addressed now, and the true leaders focus their efforts before a security breach occurs, not after, Beaver said.

“Forget about what security analysts are saying, stop listening to scare tactics and focus on the basics: urgent flaws on most important systems,” he said.


August 4, 2011  8:15 PM

When it comes to PCI compliance standards, size doesn’t really matter

Fohlhorst Frank Ohlhorst Profile: Fohlhorst

Mention PCI compliance standards, and the typical business owner will probably spout off about how they are an expensive burden that offer little in return. However, PCI compliance can provide value in the form of savings and protecting business interests.

Case in point: An owner of two small magazine stores was surprised to discover that hackers had installed software on his registers and stolen credit card information. After an investigation, at the owner’s expense, he was out over $20,000 — half his annual profit.

“His experience highlights a growing threat to small businesses. Hackers are expanding their sights beyond multinationals to include any business that stores data in electronic form. Small companies, which are making the leap to computerized systems and digital records, have now become hackers’ main target,” according to a Wall Street Journal article.

In a sense, adhering to PCI compliance standards is becoming something like an insurance policy — one that protects businesses while eliminating unforeseen expenses. Driving that value is the fact that the payment card industry has come down hard on both retailers and other organizations that store or have access to credit and debit card information by imposing heavy penalties for violating PCI compliance standards.

That translates to SMBs focusing more on security and incorporating regular and automated systems management to maintain compliance and prevent hacking.

Luckily, standards exist, ones that make it that much easier to meet PCI compliance. Take, for example, PCI DSS — now in version two — which spells out what is needed to secure the data associated with payment card-based transactions.

PCI DSS shows it takes more than just encryption and secure data storage to meet PCI compliance. Businesses need to incorporate management mechanisms, actively manage their systems and perform audits. PCI DSS includes 12 requirements for building and maintaining a secure network, protecting cardholder data, maintaining a vulnerability management program, implementing strong access control measures, regularly monitoring and testing networks, and maintaining an information security policy.

It is those standards that show where additional value can be wrung out of PCI compliance. After all, improvements in security and operations always lead to measurable results.

Frank Ohlhorst is an award-winning technology journalist, professional speaker and IT business consultant with more than 25 years of experience in the technology arena. He has written for several leading technology and business publications, and was also executive technology editor at eWEEK and director at CRN Test Center.


July 25, 2011  2:00 PM

Little to celebrate after one year of Dodd-Frank compliance

Cgonsalves Chris Gonsalves Profile: Cgonsalves

As birthday parties go, this one was forgettable. Awful, really. One year into compliance with the Dodd-Frank Wall Street Reform and Protection Act, few are in a mood to fete the guest of honor, that bloated, convoluted, amorphous bundle of regulations that gave many businesses 12 months of headaches and FUD.

That’s not to say nobody is celebrating. The milestone was marked last Thursday by the official opening of the Consumer Financial Protection Bureau (CFPB), one of the 11 bureaucracies charged with administering Dodd-Frank, and the first new federal agency created in more than 10 years. So there’s at least one building full of Dodd-Frank revelers. It’s unlikely that’s who Treasury Secretary Tim Geithner was talking about when he sold Dodd-Frank on the promise that it was “designed to lay a stronger foundation for innovation, economic growth and job creation.”

But a win is a win, I suppose.

As for the rest of us, how well has the massive Dodd-Frank Act, with its 243 new rules administered by 11 different federal agencies, worked in its first full year on the books?

Consider:

  • Unemployment has risen to 9.2%; 22 million Americans can’t find work.
  • More than 44 million Americans are now on food stamps.
  • The so-called Misery Index, a measure of unemployment and inflation, is at a 30-year high.

Meanwhile:

  • The creation of new businesses in the United States is at a 17-year low.
  • The cost of compliance with Dodd-Frank will top $1.25B (including $329 million for the new CFPB) through 2012, according to a congressional report.
  • It will take regulated businesses an estimated 2,260,631 annual labor hours required to comply with the 10% of Dodd-Frank regs activated so far, according to The Heritage Foundation.

It’s been ugly, as critics have been quick to point out.

“Thanks to efforts like Dodd-Frank, the drivers of our economy are increasingly focused inward,” wrote Rep. Ed Royce (R-Calif.), a senior member of the House Financial Services Committee and part of last year’s Dodd-Frank Conference Committee. “Rather than looking to finance the next Google or Microsoft, businesses will be mired in complying with 2,300 pages of flawed rules and regulations.

“From the Consumer Financial Protection Bureau, with its half-billion dollar budget and virtually no accountability or oversight, to the new derivatives regulation, ‘compliance’ with ever-changing dictates will consume these firms,” writes Royce. “If the end result was a more stable financial system, this may be a cost worth bearing. Unfortunately, every indication points in the opposite direction; a fundamentally weaker financial system and a less vibrant economy. This is not an anniversary worth celebrating.”

Fellow Financial Services Committee member Rep. Sean Duffy of Wisconsin agrees. “Dodd-Frank was rammed through Congress on claims that by increasing government mandates and control over the private economy, we would see robust growth in our economy and greater economic security for our working families and small businesses,” Duffy says in an op-ed piece in The Washington Times. “One year later, with new business creation at a 17-year low and paralysis in the private sector, it’s clear that Dodd-Frank has woefully underdelivered.”

Duffy is among those offering new legislative efforts to roll back much of what Dodd-Frank has wrought. But with a stagnant economy, ongoing public suspicion of Wall Street, and partisan political battles continuing at a fever pitch, any quick action to make Dodd-Frank easier for the regulated parties seems unlikely.

And so we might be wise to celebrate a little at Dodd-Frank’s one-year anniversary. After all, 90% of its directives haven’t even hit yet. There’s a tsunami of regulations still stored up in the act’s endless pages, waiting to be unleashed. Uncountable hours and incalculable costs for compliance will spew forth in the coming years. So raise a glass and toast Dodd-Frank. This is as good as it gets. As bad as this year seemed, the worst may be yet to come.


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