Here are 10 steps to protecting your organization’s privacy data and intellectual property.
As a preface, begin with the understanding that you already have all the resources you need.
Discussions with colleagues in a large forensics accounting firm that specialize in anti-fraud investigations, money laundering and anti-terror funding (ATF), confirm what I’ve suspected for a long time.
Armies of junior analysts working for the large accounting firms who have never seen or experienced a fraudulent event and are unfamiliar with your business operation are not a reasonable replacement for careful risk analysis as done by people who are familiar with the business.
Step # 1- Do not do an expensive business process mapping project.
Many consultants tell organizations that they must perform a detailed business process analysis and build data flow diagrams of data and users who process data. This is an expensive task to execute and extremely difficult to maintain that can require large quantity of billable hours.
That’s why they tell you to map data flows. The added value of knowing data flows inside your organization between people doing their job is arguable. There are much better ways to protect your data without writing out a 7 digit check. Here is the first one you should try out. Select the 10 most valuable data assets that your company owns.
For example – proprietary mechanical designs of machines, detailed financials of a private company being acquired, and details of competitive contracts with large accounts. In a few interviews with finance, operations, IT, sales and engineering, you can nail down those key assets.
After you’ve done that, schedule a 1 hour meeting with the CFO and ask her how much each asset is worth in dollars. In general, the value of a digital, reputational, physical or operational asset to a business can be established fairly quickly by the CFO in dollar terms – in terms of replacement cost, impact on sales and operational costs.
Step #2 – Do not develop a regulatory compliance grid.
There is no point in taking a non-value-added process and spend money making it more effective.
My maternal grandmother, who spoke fluent Yiddish would yell at us – ”grosse augen” when we would pile too much food on our plates. "Grosse augen" (or as my folks put it) is having eyes that are bigger than your capacity. Yes, US publicly traded companies are subject to multiple regulations – if the company sells to customers and stores and processes PII (personally identifiable data) they will have to deal with PCI DSS 1.1, California State Privacy Law, Sarbanes-Oxley PCI DSS 1.1 protects one asset – payment card number and magnetic stripe, while Sarbanes-Oxley is about accounting records.
Yes, there are a few commercial software products that map business processes, databases and data elements to multiple regulations; their goal is to help streamline the work involved in multiple regulatory compliance projects – eliminating redundancy where possibility using commonality.
Looking at all the corporate governance and compliance violations; cases such as Hannaford supermarkets and AOL – it’s clear government regulation has not made America more competitive nor better managed.
Step #3 – Identify the top 5 data assets in your business and valuate them
I saw an article recently that linked regulatory compliance mandate and asset cost. Definitely not true – the value of an asset for a company is whatever operational management/CFO say it is. Asset value has nothing to do with compliance but it has everything to do with a cost effective risk control plan.
For example – a company might think that whole disk encryption on all company notebook computers is a good idea – but if only 20 people have sensitive data – why spend 1 million dollars on mobile device data encryption when you can solve the problem for less than 5k?
Step #4 – Do not store PII
The absolutely worst thing you can do is a project to analyze data retention and protection regulations that govern each of the sensitive data elements that need protecting, and working with legal and compliance consultants who know the relevant regulations.
VISA has it right. Don’t store credit cards and magnetic strip data. It will not help the marketing guys sell more anyway – and you can give the money you save on some fancy database encryption software to the earthquake victims in Myanmar and China.
Step #5 – Monitor your outsourcing vendors
Despite the hype on trusted insiders, most data loss is from business partners. You can write a non-disclosure agreement with an outsourcing vendor and trust them, but you must verify their compliance and prevent unauthorized data leaks.
The best story I had in years was in a meeting with the VP internal audit at a medium sized bank in Israel. He took a sales call with me and I pitched our extrusion prevention technology from Fidelis Security Systems as a way to protect their customer data. He said – look Danny, we don’t need technology – we’ve outsourced everything to a very large bank and their data center security is world-class.
Two weeks later, the big bank had a serious data breach event (a high school student hacked into the internal network of the bank from a public Windows-based kiosk and helped himself to some customer lists. Two months later, the small bank was reported to be looking to get out of their outsourcing contract. Don’t rely on contracts alone – use people and DLP technology to detect data leakage.
Step #6 – Do annual security awareness training but keep it short and sweet
Awareness is great but like Andy Grove said – “A little fear in the workplace is not necessarily a bad thing”. Have everyone read, understand and sign a 1 page procedure for information security. Forget interview projects and expensive self-assessment systems – what salesman in his right mind will take time to fill out one of those forms – if he doesn’t update his accounts on salesforce.com?
Install an extrusion detection system at the network perimeter. Prosecute violators in real time. Do random spot checks on the read-and-understand procedure. Give demerits to the supervisors and managers if their employees don’t pass the spot check.
Step #7 – Calculate value at risk of your top 5 data assets
ISO 27001 and PCI DSS 1.1 checklists are great starting points but they focus on whether a particular technology, policy or control has been implemented, and not whether these controls are cost-effective security countermeasures against internal and external attackers.
Use Practical Threat Analysis with a PTA risk library for ISO 27001 or PCI DSS 1.1 and you will be able to build a cost-effective risk mitigation plan based on asset values, threat probabilities and estimated damage levels.
Step #8 – Ask your vendors and colleagues difficult questions
After you’ve done a practical threat analysis of your risk exposure to attacks on sensitive customer data and IP you will be in better position than ever to know what policies, procedures and technologies are the most effective security controls. You’ll be in an excellent position to ask difficult questions and negotiate terms with your favorite vendor.
While the attitude of many companies is to hold data protection protections close to their chests, it is valuable to talk to your colleagues at other companies in the same market and get a sense of what they have done and how well the controls perform.
Step #9 – Resist the temptation to do a customer data integration (CDI) project.
Customer data is often stored in many applications and locations in a large organization. The knee-jerk reaction of IT is to do a big data integration project and get all the digital assets under one roof. There are three reasons why this is a terrible idea.
- (a) Most of these projects fail, overrun and never deliver promised value
- (b) If you do succeed in getting all the data in one place, it’s like waving a huge red flag to attackers – heah , come over here – we have a lot of sensitive data that is nicely documented and easily accessible. Companies with enterprise software systems such as SAP and Oracle Applications are three times more likely to be attacked.
- (c) Ask yourself – would Google have succeeded if with global data integration strategy?
Step #10 – Prepare a business care for data loss prevention before evaluating products
Despite claims that protecting data assets is strategic to an enterprise, and IT governance talk about business alignment and adding value – my experience is that most organizations will not do anything until they’ve had a fraud or data security event.
The first step to protecting customer data and IP in any sized business from a individual proprietorship to a 10,000 person global enterprise is laying the case at the door of the company’s management. This is where executives need to take a leadership position – starting with a clear position on which data assets are important and how much they’re worth to the company.
Practical threat analysis is a great way to identify and assess threats to your business and evaluate the potential business impact in dollars and cents to your operation using best-practice risk models provided by the PTA Professional threat modeling tool.
Cross-posted from Israeli Software