Regulatory Reality:

CISO

1

March 6, 2013  5:19 PM

Security Standards: What’s in a name?



Posted by: David Schneier
assess, assessment, assessments, Audit, auditor, audits, CISO, community bank, control, controls, credit union, credit unions, data security, framework, information security, information security office, infrastructure, ISO, risk assess, risk assessment, risk assessments, risk management, risk-based

I had an interesting phone call recently with someone in a CISO-type position.  They were looking for a consultant to help them keep a seat warm working with information security risk assessments and were hoping to find a resource with practical experience using the NIST 800-53 standard.  It was...

October 22, 2012  2:09 PM

Are banks unfairly scrutinized?



Posted by: David Schneier
ACH, assess, assessment, assessments, Audit, auditor, audits, banking, banks, business, CISA, CISO, community bank, compliance, credit unions, CU, exam, examination, examinations, examiner, examiners, exams, FFIEC, financial institutions, general controls, GLBA, identify theft, identity theft, information security, information security office, Information Technology General Controls, internal audit, internal controls, ITGC, NPPI, observations, oversight, personally identifiable informaiton, PII, privacy, risk assess, risk assessment, risk assessments, risk management, risk-based, risks

A few years back when I first cut over to working somewhat exclusively with financial institutions I memorized an elevator speech that still somewhat defines who I am and what I do professionally.  Part of the speech pointed out that my firm helped "banks and credit unions meet regulatory...


September 21, 2012  3:44 PM

Are self-assessments the right way to go?



Posted by: David Schneier
assess, assessment, assessments, Audit, bank, banking, CISO, CISSP, compliance, compliance officer, compliant, credit union, credit unions, CU, disaster, disaster recovery, DR, enterprise risk, enterprise risk management, ERM, exam, examination, examinations, examiner, examiners, exams, framework, governance, GRC, guidance, information security, information security office, infrastructure, ISO, oversight, policy, procedure, regulation, regulations, regulations audit, regulatory, regulatory guidance, risk assess, risk assessment, risk assessments, risk management, risk-based, risks, technology

About a decade ago a family member chastised me for having an auto repair shop do my oil changes for me.  She (yeah, you’re reading that right – “she”) pointed out how ridiculously easy it was to drain the old oil, replace it with the new stuff and check a wide variety of fluid levels,...


November 29, 2010  3:19 PM

You can’t have partial regulatory compliance



Posted by: David Schneier
assessment, Audit, CISO, compliance, compliance officer, HIPAA, ISO, PII, regulatory, Regulatory Compliance

I recently decided to establish an automatic link between my personal checking account and a mutual fund account that was established for my son years ago when he was a baby.  The account was originally funded with a gift from a family member and while it's grown reasonably well percentage-wise,...


September 5, 2010  5:17 AM

Managing today’s privacy threats and security risks



Posted by: David Schneier
CISO, compliance, Facebook, GLBA, information security, ISO, LinkedIn, NCUA, PII, regulatory, Regulatory Compliance, Security, social network

A few months back, the big blinking light in the middle of the information security radar was a story about how someone had harvested all sorts of personal...

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August 2, 2010  9:29 PM

Where’s the information security oversight?



Posted by: David Schneier
Audit, bank, banking, bcp, CISO, compliance, compliance officer, FDIC, FIL, GLBA, information security, regulatory, Regulatory Compliance, Security, vulnerability test

We were watching a baseball game the other night when one of Microsoft's recent IE8 security commercials aired.  It's the one where a fictitious bank is set up and people off the street, deceived by its appearance, wind up turning over boat loads of personally identifiable information (PII)...


November 12, 2009  1:44 PM

Information security officers are a must



Posted by: David Schneier
Audit, business continuity planning, CISO, compliance, GLBA, information security, information security office, ISO, Regulatory Compliance, Vendor Management

I was talking with a client last week about a perceived gap in their organization.  Despite having to address multiple regulations cutting across several oversight bodies, they were lacking a single point of contact or central coordinator for all information security related activities.  Their...


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