Data Leakage Prevention – Protecting Sensitive Information

When DuPont lost $400 million in intellectual property, it wasn’t because a hacker from the other side of the world infiltrated their system. The information was simply stolen by a former employee. Alarmingly, data loss incidents are not always caused by deliberate actions.

A file containing personal information accidentally attached to an email and sent to multiple recipients; financial data stored in a USB pen drive, accidentally left in a restaurant; or bank account data of colleagues, inadvertently posted on a company website – these are also some of the everyday causes of data loss.

A report done by research company Infowatch regarding global data leaks in 2010 showed that there were actually more accidental data leaks in that year compared to intentional ones. Accidental leaks comprised 53%, while intentional leaks comprised 42% (the rest were unidentified).

But even if they ?only? happened accidentally, breach incidents like these can still be very costly. The tens of thousands of dollars that you could sometimes end up paying in civil penalties (as in the case when you lose other people?s personal information) can just be the beginning. More costly than this is the loss of customer and investor confidence. Once you lose those, you could consequently lose a considerable portion of your business.

Confidential information that may already be leaking out right under your nose

With all the data you collect, process, exchange, and store electronically every day, your IT system has surely now become a storehouse of sensitive information. Some of them, you may be even taking for granted.

But imagine what would happen if any of the following trade secrets fell into the wrong hands: marketing plans, confidential customer information, pricing data, product development strategies, business plans, supplier information, source codes, and employee salaries.

These are not the only kind of data that you should be worried about. You could also get into trouble if your sloppy IT security fails to protect employee or client personal information such as their names; social security numbers; drivers license numbers; or bank account numbers and credit/debit card numbers along with their corresponding PINs.

In some countries, you could face onerous data breach notification requirements and heavy fines when these kind of data are involved.

There are now more holes to plug

It’s not just the different varieties of sensitive electronic information that you have to worry about. Because these data can take on different forms, i.e. data-at-rest, data-in-motion, and data-at-the-endpoints, you also need to take aim at different areas in your IT system.

Sensitive information can be found ?at rest? in each of your employees? hard disks, in your servers, storage disks, and in off-site backup disks. They can also be found ?in motion? in email, instant messaging, social networking messaging, P2P file sharing, ftp, http, and so on.

That’s not all. Your highly mobile workforce may have already introduced yet another high-risk area into your system: data-at-the-endpoints. This includes USB flash-disks, laptops, portable hard disks, CDs, and even smartphones.

The main challenge of data leak prevention

Having been made aware of the various aspects of data leakage, have you already come to grips with the extent of the task at hand?

There are two major things you need to do here to prevent data leakage.

One, you need to identify what data you have that can be considered as sensitive/confidential information. Of course you have financial information and employee salaries in your files. But do you also store personally identifiable information? Do you have trade secrets that are stored in electronic form?

Two, you need to pinpoint their locations. Are they only on your hard disks and laptops? Or have they made their way to flash drives, CDs/DVDs, or portable HDDs? Are they being transmitted through email or any other file transfer media?

The reason why you need to know what your sensitive data are as well as where they are is because you would like all efforts of securing them to be as efficient and unobtrusive as possible.

Let’s say, as a way of protecting your data, you decide to implement encryption. Since encryption can consume a lot of storage space and significantly reduce performance, it may be impractical to encrypt your entire database or all your files. For the same reason, you wouldn’t want to encrypt every single email that you send.

Thus, the best way would be to encrypt only the data that really need encryption. But again, you need to know what data needs to be encrypted and where those data can be found. That alone is no simple task.

Not only will you need to deal with the data you already have, you will also have to worry about the data that will go through your systems during the course of your day-to-day transactions.

Identifying sensitive data as it enters or leaves your system, goes through your network, or gets stored in your file system or database, and then applying the necessary security actions should be done automatically and intelligently. Otherwise, you could end up spending on a lot of man-hours or, worse, wasting them on a lot of false positives and negatives.

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Saving Energy Step 3 ? Towards a Variable Energy Bill

Do you remember the days when energy was so cheap we paid the bill almost without thinking about it? Things have changed and we have the additional duty of reducing consumption to help save the planet. This is the third article in our mini-series on saving energy. It follows on from the first that explored implementing a management system, and the second listing practical things to implement on the shop floor. These open up the possibility of the variable energy bill we expand on as follows.

If ?variable energy bill? sounds strange to you, I used the unusual turn of phrase to encourage you to view things in a different light. We need to move on from the ?pie chart? mentality where we focus on the biggest numbers like materials, facilities and labour, and zoom in on energy where we can achieve similar gains faster with less pain. But first, we need to see beyond the jargon that governments and consultants love, and get to grips with the reality that we can vary our energy bill and bring cost down.

As executives we recognise this, although other pressures distract us from accepting it as a personal goal. And so we delegate it down the organisation to a level where it becomes ?another crazy management idea? we have to follow to stay out of trouble. I read somewhere that half the world?s organisations do not have energy as a defined objective to monitor in the C Suite. No wonder commerce is only pecking away at energy wastage at a rate of 1% per year.

Find out where you are ?spending energy? and relate this to your core business. If there are places where you are unable to make a connection, challenge the activity?s right to exist. Following the energy trail produces unexpected benefits because it permeates everything we do.

  • Improved product design reducing time spent in factory
  • Streamlined production schedules reducing machine run times
  • Less wear on equipment reducing costly maintenance
  • A more motivated workforce that is prouder of ?what we do?

As you achieve energy savings you can pass these on in terms of lower prices and greater market share. All this and more is possible when you focus on the variables behind your energy bill. Run the numbers. It deserves more attention than it often gets.

How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

The Matrix Management Structure

Organizations exploit matrix management in various ways. A company, for instance, that operates globally uses it at larger scale by giving consistent products to various countries internationally. A business entity, having many products, does not assign its people to each product full-time but assign those to different ones on a part time basis, instead. And when it comes to delivering high quality and low cost products, companies overcome industry pressures with the help of many overseeing managers. In a rapidly changing environment, organizations respond quickly by sharing information through a matrix model.

Understanding the Matrix Management Structure

A basic understanding of matrix management starts with the three key roles and responsibilities that applies in the structure.

  • Matrix Leader ? The common person above all the matrix bosses is the matrix leader. He ensures that the balance of power is maintained in the entire organization by delegating decisions and promoting collaboration among the people.
  • Matrix Managers ? The managers cooperate with each other by defining the respective activities that they are responsible for.
  • Matrix Employees – The employees have lesser direct authority but has more responsibilities. They resolve differing demands from more than one matrix managers while they work things out upwards. Their loyalty must be dual and their relationships with managers must be maintained.

Characteristics of a Matrix Structure

Here are some features that define the matrix management structure:

  • Hybrid Structure ?The matrix structure is a mix of functional and project organization. Since it is a combination of these two, matrix management is hybrid in nature.
  • Functional Manager ? When it comes to the technical phases of the project, the functional manager assumes responsibility. The manager decides on how to get the project done, delegates the tasks to the subordinates and oversees the operational parts of the organization.
  • Project Manager ? The project manager has full authority in the administrative phases, including the physical and financial resources needed to complete the project. The responsibilities of a project manager comprise deciding on what to do, scheduling the work, coordinating the activities to diverse functions and evaluating over-all project performance.
  • Specialization ?As the functional managers concentrate on the technical factors, the project managers focus on administrative ones. Thus, in matrix management, there is specialization.
  • Challenge in Unity of Command ? Companies that employs matrix management usually experience a problem when it comes to the unity of command. This is largely due to the conflicting orders from the functional and project managers.

Types of Matrix Structure

The matrix management structure can be classified according to the level of power of the project manager. Here are three distinct types of matrix structures that are widely used by organizations.

  • Weak Matrix ? The project manager has limited authority and power as the functional manager controls the budget of the project. His role is only part-time and more like a coordinator.
  • Strong Matrix ? Here, the project manager has almost all the authority and power. He controls the budget, holds the full time administrative project management and has a full time role.
  • Balanced Matrix ? In this structure type, both the project and functional managers control the budget of the project. The authority and power is shared by the two as well. Although the project manager has a full time role, he only has a part time authority for the administrative staff to report under his leadership.

Successful companies of today venture more on enhancing the abilities, skills, behavior and performances of their managers than the pursuit of finding the best physical structure. Indeed, learning the fundamentals of the matrix structure is essential to maximize its efficiency. A senior executive pointed out that one of the challenges in matrix management is not more of building a structure but in creating the matrix to the mind of the managers. This comes to say that matrix management is not just about the structure, it is a frame in the mind.

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