LITMIR.BIZ

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observed, monitored, or examined without consent or knowledge

      A concept that comes up frequently in discussions of privacy is personally identifiable information (PII). PII is any data item that can be easily and/or obviously traced back to the person of origin or concern. A phone number, email address, mailing address, social security number, and name are all PII. A MAC address, IP address, OS type, favorite vacation spot, name of high school mascot, and so forth are not typically PII.

      When addressing privacy in the realm of IT, there is usually a balancing act between individual rights and the rights or activities of an organization. Some claim that individuals have the right to control whether information can be collected about them and what can be done with it. Others claim that any activity performed in public view – such as most activities performed over the Internet or activities performed on company equipment – can be monitored without knowledge of or permission from the individuals being watched and that the information gathered from such monitoring can be used for whatever purposes an organization deems appropriate or desirable.

      Protecting individuals from unwanted observation, direct marketing, and disclosure of private, personal, or confidential details is usually considered a worthy effort. However, some organizations profess that demographic studies, information gleaning, and focused marketing improve business models, reduce advertising waste, and save money for all parties.

      There are many legislative and regulatory compliance issues in regard to privacy. Many US regulations – such as the Health Insurance Portability and Accountability Act (HIPAA), the Sarbanes-Oxley Act of 2002 (SOX), and the Gramm-Leach-Bliley Act – as well as the EU’s Directive 95/46/EC (aka the Data Protection Directive) and the contractual requirement Payment Card Industry Data Security Standard (PCI DSS) – include privacy requirements. It is important to understand all government regulations that your organization is required to adhere to and ensure compliance, especially in the areas of privacy protection.

      Whatever your personal or organizational stance is on the issue of online privacy, it must be addressed in an organizational security policy. Privacy is an issue not just for external visitors to your online offerings but also for your customers, employees, suppliers, and contractors. If you gather any type of information about any person or company, you must address privacy.

      In most cases, especially when privacy is being violated or restricted, the individuals and companies must be informed; otherwise, you may face legal ramifications. Privacy issues must also be addressed when allowing or restricting personal use of email, retaining email, recording phone conversations, gathering information about surfing or spending habits, and so on.

      Security Governance

      Security governance is the collection of practices related to supporting, defining, and directing the security efforts of an organization. Security governance is closely related to and often intertwined with corporate and IT governance. The goals of these three governance agendas often interrelate or are the same. For example, a common goal of organizational governance is to ensure that the organization will continue to exist and will grow or expand over time. Thus, the goal of all three forms of governance is to maintain business processes while striving toward growth and resiliency.

      Third-party governance is the system of oversight that may be mandated by law, regulation, industry standards, contractual obligation, or licensing requirements. The actual method of governance may vary, but it generally involves an outside investigator or auditor. These auditors might be designated by a governing body or might be consultants hired by the target organization.

      Another aspect of third-party governance is the application of security oversight on third parties that your organization relies on. Many organizations choose to outsource various aspects of their business operations. Outsourced operations can include security guards, maintenance, technical support, and accounting services. These parties need to stay in compliance with the primary organization’s security stance. Otherwise, they present additional risks and vulnerabilities to the primary organization.

      Third-party governance focuses on verifying compliance with stated security objectives, requirements, regulations, and contractual obligations. On-site assessments can provide firsthand exposure to the security mechanisms employed at a location. Those performing on-site assessment or audits need to follow auditing protocols (such as COBIT) and have a specific checklist of requirements to investigate.

      In the auditing and assessment process, both the target and the governing body should participate in full and open document exchange and review. An organization needs to know the full details of all requirements it must comply with. The organization should submit security policy and self-assessment reports back to the governing body. This open document exchange ensures that all parties involved are in agreement about all the issues of concern. It reduces the chances of unknown requirements or unrealistic expectations. Document exchange does not end with the transmission of paperwork or electronic files. Instead, it leads into the process of documentation review.

      Documentation review is the process of reading the exchanged materials and verifying them against standards and expectations. The documentation review is typically performed before any on-site inspection takes place. If the exchanged documentation is sufficient and meets expectations (or at least requirements), then an on-site review will be able to focus on compliance with the stated documentation. However, if the documentation is incomplete, inaccurate, or otherwise insufficient, the on-site review is postponed until the documentation can be updated and corrected. This step is important because if the documentation is not in compliance, chances are the location will not be in compliance either.

      In many situations, especially related to government or military agencies or contractors, failing to provide sufficient documentation to meet requirements of third-party governance can result in a loss of or a voiding of authorization to operate (ATO). Complete and sufficient documentation can often maintain existing ATO or provide a temporary ATO (TATO). However, once an ATO is lost or revoked, a complete documentation review and on-site review showing full compliance is usually necessary to reestablish the ATO.

      A portion of the documentation review is the logical and practical investigation of the business processes and organizational policies. This review ensures that the stated and implemented business tasks, systems, and methodologies are practical, efficient, and cost effective and most of all (at least in relation to security governance) that they support the goal of security through the reduction of vulnerabilities and the avoidance, reduction, or mitigation of risk. Risk management, risk assessment, and addressing risk are all methods and techniques involved in performing process/policy review.

      Understand and Apply Risk Management Concepts

      Security is aimed at preventing loss or disclosure of data while sustaining authorized access. The possibility that something could happen to damage, destroy, or disclose data or other resources is known as risk. Understanding risk management concepts is not only important for the CISSP exam, it’s also essential to the establishment of a sufficient security stance, proper security governance, and legal proof of due care and due diligence.

      Managing risk is therefore an element of sustaining a secure environment. Risk management is a detailed process of identifying factors that could damage or disclose data, evaluating those factors in light of data value and countermeasure cost, and implementing cost-effective solutions for mitigating or reducing risk. The overall process of risk management is used to develop and implement information security strategies. The goal of these strategies is to reduce risk and to support the mission of the organization.

      The primary goal of risk management is to reduce risk to an acceptable level. What that level actually is depends on the organization, the value of its assets, the size of its budget, and many other factors. What is deemed acceptable risk to one organization may be an unreasonably high level of risk to another. It is impossible to design and deploy a totally risk-free environment; however, significant risk reduction is possible, often with little effort.

      Risks to an IT infrastructure are not all computer based. In fact, many risks come from noncomputer sources. It is important to consider all possible risks when performing risk

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