Risk Management and Business Context

This week I attended the RSA Security Analytics Summit in Washington D.C. and had the incredible opportunity to meet one of the smartest individuals to date. Nate Silver was the keynote and he covered a lot of ground including 1) an analogy of the proliferation of information via the printing press in 1440 and the most recently the world wide web in 1990; 2) The End of Theory: The Data Deluge Making the Scientific Method Obsolete; 3) The 538 method and lessons from the 2012 elections; 4) the influence of bias in big data 5) the “Signal-to-Noise” ratio which results in increased variables that occur along with the need for a true distribution model to enable trend effective trend analysis; 6) the limitation of technology in some cases where technology was deemed more powerful and a better predictor than the human brain and 7) the use of mathematics to help with predictive modeling. As you can see from the list of topics the presentation was truly engaging and thought provoking.

Signal To Noise Ratio_opt

Towards the end of the presentation Nate Silver provided a suggested approach that not only solidified his presentation but provided actionable guidance in how to better use data as a predictor. The suggested approach is as follows:

1) Think Probabilistically
2) Know Where You’re Coming From
3) Survey the Data Landscape
4) Try, and Err

When given the above guidance, which is clearly outlined in his book The Signal and the Noise, I instantly was able to relate to point number 2….”know where you are coming from” to risk management. The reason why it resonated with me so much is that I am a communications major and studied countless hours both in theory and practice on intra/inter personal relationships. As I work with organizations and listen to the different approaches to risk management using predictive analysis I find people in the risk management profession often overlook the power of knowing where people or in this case risks are coming from within the organization. Risks to financial data or healthcare records are different from risks to a conference room portal application. People must apply common sense to sophisticated models of risk analysis. The only way to get common sense is to drive context into the relationship of the risk to the expected results or impact to the business.

The need for context (common sense) has never been greater. As you look to drive your risk management or even security practices within our organization you must have all four elements in place not just 1, 3 and 4. Context of the risk will empower you to respond in a logical, appropriate, timely and effective manner. Context will also enable you to ensure the people, departments, divisions understand the impact to their world and can also enables the conversations you need to have executive leadership for relational visibility into the risks that truly impact the their world. Without context you will provide less meaningful data and increase the risk exposure to your organization.

In closing I recommend reading Nate Silver’s book The Signal and The Noise and look forward to seeing how all of you apply his astute suggested approach.

S2N Book

Shire Pharmaceuticals Drives Into the Future of Healthcare

Some would say that there is nothing more gratifying than helping people in need. In the case of Shire Pharmaceuticals, helping people with life-altering conditions to lead better lives is core to their business and their culture. Based nearby in Lexington, Massachusetts, Shire focuses on developing treatments for conditions in neuroscience, rare diseases, gastrointestinal, internal medicine and regenerative medicine. The need to stay on the cutting edge of healthcare is paramount to the organization and information security has played a key role in that mission.

Shire’s Senior Director of Information Risk Management & Security, Bob Litterer, came to the company tasked with developing a world class information security function aligned to their business goals. Like so many CISOs today, Bob knew the importance of information security as a business enabler, but needed to drive awareness and create a security culture that embraced their business. In his words, “we didn’t want perform security for security’s sake”. He was also tasked with reducing costs associated with changing compliance requirements, drive-up efficiency, and managing acceptable risk tolerances so the organization could continue to innovate and stay competitive. Quite a tall order when there is so much on the line.

Like any good leader, Bob knew he needed a great team behind him – so he brought in one of our alliance partners OpenSky who helped build a comprehensive Governance, Risk and Compliance (GRC) platform based on RSA Archer.

As you heard from Peter Ridgley, Lead Consultant from OpenSky, explain in the video, Shire was able to quickly spotlight where there was a need for improvement as well as areas where they were successfully hitting the mark. The visibility through RSA Archer allows Shire to do a drill down review of each area to determine how they can improve driving credibility into the management of the program as well as demonstrates its depth.

Additionally, Shire is now able to continue that assessment on a regular basis to report progress, showcase how the information security organization is aligned with the goals of the business, and ensure they are always able to meet changing business needs and compliance requirements.

While this project is impressive in and of itself I am happy to share with you that Shire has earned an important industry accolade as well. Just last week, the company was awarded the OCEG GRC Achievement Award at the 2013 Compliance Week Conference which recognizes organizations that make great strides in improving and integrating their approaches to governance, risk management and compliance. Working with OpenSky, Shire leveraged the OCEG Redbook to provide a framework for managing the GRC Program and it has been paying off in spades. Thanks to the dedication of Shire and OpenSky as well as the power of RSA Archer, Shire gets to take home this honor and we couldn’t be happier.

GRC – A Performance Management Platform or A Success Management Platform?

On May 1st French Caldwell posted a blog titled GRC Will be a Performance Platform in which he references a blueprint that provides a practical approach for identifying the goals of ERM programs in terms of strategic business objectives, and linking that to an underlying GRC architecture that can drive business performance benefits. But isn’t that too limiting?

Performance Management is merely a solution category and doesn’t do GRC platforms justice! When considering how GRC platforms span across Finance, Operations, Legal and IT providing organizations ways to manage risks, demonstrate compliance and ensure governance business performance benefits is only one output and to me only represents how an organization has done historically against business objectives. This is important but not all the benefits that a GRC Platform can and should provide a company.

When organizations use GRC platforms that also includes Big Data Risk Analytics not only will they be able to report on past performance to various levels, domains and to different audiences but they will also be able to predict the future. Future performance, future risks, future efficiencies, and most important future opportunities for success. Big Data risk analytics within a GRC Platform should model out opportunities for growth that drive success within each domain. So I think that GRC platforms will not be performance management but  “Success Management Platform”. Might this be a new category?

PS – I would have really enjoyed the panel with Paul Proctor and Network Frontier’s Dorian Cougias. Not only do I find business predictive and risk management conversations interesting I also am equally if not more fascinated by conversations with “the security geeks” of the world as they save our businesses every day. We should all find them fascinating!

imagesCAH4BEPD

RSA Archer GRC Summit – 10th Year!!

I am happy to announce that RSA will be hosting the 10th annual RSA Archer GRC Summit in Washington D.C., June 12-14, 2013 at the Omni Shoreham Hotel.

As I have actively helped plan these events since 2006  I am humbled at the continued momentum these events have achieved and is driven by the premier GRC community with over 10,000 active members. The momentum continues this year with a record number of attendees (800+) and an agenda that includes over 35 client led presentations on GRC implementation strategies and best practices, 15 technical breakout sessions on the RSA Archer GRC Platform, over 10 birds of a feather round table discussions and executive collaboration from over 500 global organizations.

In addition to the great line up of content for both technical and business GRC practitioners within the IT, Finance, Operations and Legal domains there will be three outstanding  keynotes during the three day event. One of the keynotes that I have had the pleasure to meet and listen to is Bruce Bueno de Mesquita. Bruce is a Silver Professor of Politics, New York University; Senior Fellow, Hoover Institution, Stanford University. Coauthor of The Dictator’s Handbook and author of The Predictioneer’s Game.

Bruce has been on The Daily Show, The Cobert Report and has performed in numerous Ted Talks including a great presentation titled: Predicts Iran’s Future 

Why is Bruce Bueno de Mequita the perfect person to keynote at the 2013 RSA Archer GRC Summit? Risk Analytics of course!!

Over his long tenure as a professor and political consultant, Bruce has conferred with experts on all the world’s most pressing issues and fed their knowledge into a vast and highly sophisticated computer model of global affairs.

This combination of wide-ranging expertise and high-power analytics allows him to make strikingly accurate predictions of world events and speak with authority on the
power dynamics of everything from office politics to international summits.

I will continue to provide updates on the most valuable, highly anticipated and attended GRC event in the industry.

Until then…..keep thinking GRC.

Heat maps: not quite so hot anymore?

On the face of it, a colorful heat map looks like a great way of visualizing the risks that could affect an enterprise. They’re easy to produce from spreadsheet data and they provide a simple view of the potential impact and likelihood of a range of risks, that can be used to help raise awareness of risk generally and to communicate the risk assessment to senior management.

So what’s wrong with heat maps? Why are security professionals cooling in their attitude towards them?

Because, as I’ve said before, the two-dimensional view of risks based on severity and likelihood are no longer enough.

Risk Heat Map
Old School Risk Heat Map

Enterprises need to go far beyond the focus on inherent and residual risks that’s typical of a heat map and incorporate more dimensions, including assets, threats, vulnerabilities and controls. They want to look at risk relationships and mitigation tracking, with an approach to risk analysis that enables a quantitative assessment of all risks to all parts of the enterprise.

Although risk management information systems (RMIS), enterprise risk management (ERM), business continuity planning and crisis response are all specialized areas in their own right, the lines between them are starting to blur as the realization dawns that these management areas are all fundamental to an enterprise’s ability to survive and thrive.

A spreadsheet-driven approach is simply no longer up to the increasingly complex risk analysis job—and can even become a risk in itself. As Chris Duncan puts it, it’s like being armed with only a rock in the middle of a gunfight: you soon realize you need a lot more firepower.

So what’s the answer?

Heat maps can’t give you a rounded view of risks. Good risk management involves taking external and internal perspectives and modeling risk in relational diagrams, decision trees, heat maps, or even quantitative models involving at-risk simulations. So heat maps are one view but they’re not THE view.

Think about the difference between the Google Maps ‘Map View’, ‘Satellite View’ and ‘Street View’. It’s Street View that will give you the most comprehensive view of the location you’re searching for, letting you pan around to see not only the building you’re looking for but also the environment you’ll be entering.

In much the same way, when it comes to risk management, you need to use multi-dimensional models that let you view risk data from different perspectives and enable creation of risk intelligence, so that you can make informed decisions enhanced by risk simulations from quantitative models.

Multi-Demensional Risk Heat Map Cluster

Doing this right also involves combining high performance analytics (HPA) so that, instead of collating the different views on a monthly basis, you can collect, analyze and predict risk outcomes in near-real time. Combining all perspectives in this way means you get a much richer, multidimensional view of risk—and is exactly why using just a heat map is an archaic idea. A possible multidimensional view is represented in the above graph.

In the end it becomes possible to see the effect of each risk on different areas of the enterprise. Each enterprise domain—such as IT, legal, finance, operations—can view each risk and determine, for example, how the domains intersect; whether it’s a geopolitical risk; whether it’s an external or an internal risk; who is responsible; and what the impact on the enterprise will be in financial, reputational or other terms.

New RSA Archer Community and Exchange are live

 
At EMC we want to empower you to grow your GRC program according to your organization’s unique governance, risk and compliance processes—and of course, help you get the best out of the RSA Archer Suite.

So we’ve injected fresh energy into our online forums, the RSA Archer Community and Exchange, and moved them onto a new platform. You’ll find they offer more intuitive navigation that makes participation more straightforward, and powerful new features that make collaboration even easier.

Between them, the Community and Exchange provide an active user community and an online exchange of applications, content, services, and integrations. They sit under the umbrella of the new EMC GRC Ecosystem that addresses your broader GRC issues and offers more strategic-level discussions around GRC as a practice.

As a member of the RSA Archer Community, you can achieve value sooner by taking a more direct role in the direction of the RSA Archer product roadmap, and using a platform that’s continually being improved by its most innovative users. You’ll significantly reduce your learning curve by sharing ideas with your peers, as well as getting advice from GRC specialists about strategies and best practice around Archer product use and configuration.

The RSA Archer Community and Exchange are not just places you go, but things you do; participation in them becomes a way of life for GRC professionals.

Discover the RSA Archer Community now >>>

Discover the RSA Archer Exchange now >>>

Your business. Your solution. Your community.

RSA Archer Community

RSA Conference Talks Big Data

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I just came back from the RSA Conference in San Francisco where I couldn’t turn a corner without someone talking about how Big Data was revolutionizing the security industry. In fact, there was one session that stood out during the conference for me. It was titled “Managing Advanced Security Problems Using Advanced Security Analytics” where Eddie Schwartz, VP and CISO of RSA moderated a panel comprised of four industry analysts including Scott Crawford, Research Director of Enterprise Management Associates; John Kindervag, Senior Analyst at Forrester Research; Neil MacDonald, VP & Gartner Fellow of Gartner and; Jon Oltsik, Senior Principal Analyst from Enterprise Strategy Group.

The panel discussion covered quite a bit of ground including defining what Big Data actually means, the acceptance within security organizations of using big data analytic techniques as well as the prediction of when security professionals will embrace big data analytics and finally how big data can be the answer to the advanced threat problem with it’s incredible scalability and high speed analytics.

Discussion point that I agree with:

1)     Everyone from the moderator to the panel participants acknowledged that the current approach that companies are taking to manage the advanced threat problem fail due to lack of event context and constraints in traditional IT architecture. The panel also pointed out that there are many organizations that are not changing their ways from traditional perimeter based security, anti-virus, etc. due to “what we don’t know won’t hurt us” mentality which leaves the security teams with archaic technology that leaves them with no visibility into the threats that affect their business.

Discussion point that I did not agree with:

1)     Heat maps are a must to provide visualization. This is something I cannot agree with as the notion of a heat map is even to a risk professional becoming obsolete as they only provide a two dimensional view into the risks that could affect the business. They are not multidimensional and only provide areas of risks vs. different views into key risk issues with details.  I have seen organizations phase out heat maps and phase in multidimensional models that provide a way to view risk data from different dimensions so you get a risk portfolio vs. just pretty colors from a heat map. It also should result in creating risk intelligence so organizations can make informed decisions which can and should be enhanced by risk simulations from quantitative models. What was funny was in another meeting right after the session I was handed a “global threat” heat map of the world which showed different threat colors by country on the size of a business card…..which was of no use.

The conclusion to the session did send me away with a good feeling because what I heard was that by using Big Data it solves many things that GRC programs should do which is breakdown information silos, automate the capture of information, normalize/correlate data and organize the information to be able to respond to risks in an organized/prioritized fashion. Sound familiar? I just can’t wait to see the scale of information capture and speed of analytics better enable the “R” in GRC.

‘I don’t understand what you’re trying to tell me’: Why taxonomy is so important to eGRC

Taxonomy, the science or practice of classification, is all about specifying the relationships between entities and giving them agreed names.

I can’t count the number of times that clashing taxonomies have caused me difficulties: mis-interpreting what a friend is telling me, a boss not being on the same page, my direct reports looking at me like I’m from Mars. I remember a time when I was four years old, around the holidays, asking over and over again for ‘milk yolk’ while my mom tried desperately to figure out what I wanted. After 10 minutes of trying everything, she finally got it when I described what the drink looked and tasted like. I was after eggnog, of course.

As I explained in my last blog, when it comes to eGRC it’s critical to create common processes. A big part of this is providing consistent naming conventions so that everyone is talking the same language and there’s less chance of miscommunication. I gave the simple example of an ‘incident’ management process and an ‘issues’ management process that were identical except for what the stages in the process were called (largely just a difference in using ‘issue’ vs ‘incident’). But of course many taxonomy differences won’t be as obvious or straightforward as that example.

Naming conventions are important because they frame people’s understandings of what’s happening and what they need to do. They let people identify the context quickly and hand off information and activities without going through the palaver that my mom and I went through.

The issue of taxonomy often comes to the fore when you’re assigning labels to elements and workflow activities within software applications that are part of your eGRC strategy. People need to be comfortable with what things are called if they’re to use technology effectively; and it can take months to negotiate these naming conventions. Make sure you allow for this in your planning. Dealing with taxonomies effectively is a critical success factor for eGRC.

Good GRC taxonomy website:
Open Compliance & Ethics Group

Why GRC matters to IT security teams

 

 

 

 

 

Expectations of IT security have never been higher. I talked about this a bit in my last blog . But if you don’t believe me there’s a great paper by Enterprise Strategy Group (ESG) that nicely sums up why businesses are calling for much more sophisticated, business-oriented approaches to IT security. You can find it here (look under ‘white papers’ in the right-hand navigation area)

So if you’re in charge of IT security in your organization, what do you do to meet these expectations?

If you said ‘convince the business to invest in eGRC’ then you’re ahead of the innovation curve and are taking your program to the next level.

What happens without eGRC?

Organizations that haven’t invested in eGRC are typically mired in manual processes, trying to manage security using Word documents, spreadsheets and email. They can’t connect anything to anything and have to duplicate work all the time. One IT security manager told me that his team asks the operations team to answer questions specific to FFIEC regulations in January; and then in February asks the same questions of the same people for the purposes of SOX compliance.

This kind of thing is happening in a million different ways all the time. A recent article from Computerworld, titled “Feds want uber cybersecurity compliance standard”, illustrates this as well.

It quotes Jerry Archer, CISO at Sallie Mae, who is presenting his IT-GRC strategy at the RSA Archer eGRC Roadshow in Indianapolis tomorrow (October 13). Speaking at the SINET Innovation Summit in Boston, Jerry said his agency spent 40% of its budget on complying with regulations. “What is needed is automating compliance to reduce the bite it takes from the budget,” he said.

The kicker is the response that Jerry’s remark got from Josh Corman, director of security intelligence at Akamai. He congratulated Jerry on the 40% figure, saying: “For some it’s 100%.”

The article goes on to note that “the trouble with regulations is that they drive security architectures and prevent data loss that may have little real impact, while ignoring thefts that could be devastating.”

What happens with eGRC?

So how does GRC help? For one thing, it helps you automate compliance processes and efforts so security teams can focus attention, budget and strategy on the threats that truly matter to their business.

Organizations that have invested in eGRC (assuming they’ve adopted best practices and made careful strategy and technology choices) can:

  • Automatically map policies, control standards, control procedures, authoritative sources and assessment questions to one another and see the relations between any and all
  • Track the whole life-cycle of security incidents, reliably prioritize incidents in line with business impact and objectives, automatically assign actions to respond to incidents, and report on incidents in a way that provides meaningful business context to senior management
  • Identify gaps in compliance and satisfy common compliance requirements with a ‘one-to-many’ approach

I’ve said it before and I’ll say it again: eGRC is about enterprise-wide collaboration, visibility and control. It’s time for IT security functions to lead the charge to achieve these things. Not only is it the only way to deliver value to the business, but it will make life so much easier for you!

Recommended Reading:

The ESG Information Security Management Maturity Model, a paper by Jon Oltsik, Senior Principal Analyst, ESG (July 2011)

‘I didn’t see you!’ or, why visibility and control are vital to eGRC

By Alex Bender, Director, eGRC Programs and Strategy, EMC

The other day I saw a car accident. It made me think back to an accident I had years ago, which involved a car appearing so fast I didn’t see it until we were about to collide. The only thing I could do was to swerve wildly to avoid the collision, thereby losing control of my car and crashing — but at least not into the other car.

Thinking back to that accident and the aftermath — the hours spent on a litany of phone calls to my insurance company, getting repair quotes, getting the car to the garage, making alternative arrangements while I was without my car — I couldn’t help but think about the importance of visibility and control in business, as much as in life. The impacts of the lack of visibility and control are extremely apparent in the car accident example – life changing.

See more, act faster, spend less

When you have visibility you can see where you’re headed and plan appropriately to get there. When you have control you don’t have to just react wildly to changes in your environment; you can act with efficient deliberation to avoid situations that are harmful to your organization.

Lack of visibility and control, conversely, can result in a car crash for your organization; and the crash itself is just the beginning of the toll taken on time and resources. If, despite your best efforts, you’ve been unable to avoid an incident, then visibility and control play a vital role in helping you to respond effectively to the aftermath: to minimize the time and money spent identifying what went wrong, fixing the problem and dealing with the legal, operational and financial fallout.

Requirements for visibility and control

In a previous ‘two-part’ blog I wrote about the importance of collaboration across departments for effective eGRC. Well, visibility and control are the fundamental enablers of effective collaboration. So the question becomes: how do you achieve them? You can’t just wave a magic wand. Organizations of all sizes and types are struggling with eGRC issues precisely because they don’t have the visibility and control they need.

I think that for any strategy, approach or tool to give you eGRC visibility and control, it needs to have three attributes:

  • Integration. As long as information relating to eGRC is held in disparate and disconnected systems or dealt with through disconnected processes (probably using ad-hoc tools, excel spreadsheets, word docs and many times just quick conversations), you can never get a clear view of what you know, what you’ve don’t know, what’s happening and how it all relates. Conversely, if you can bring everything together in one place, not just as a central dumping ground but in a way that lets you connect it in meaningful ways, then you’re most of the way to having the visibility you need — to be proactive, rather than always firefighting, and to see the big picture that lets you take a strategic approach to solve your business needs.
  • Automation. One of the difficulties in achieving integration and in dealing with the results is that there’s just so much to integrate and manage in a manual way. Too much to have a hope of doing it effectively without technological help. With the best will in the world, spreadsheets won’t cut it. Manually pulling data from hundreds and or thousands of systems won’t cut it.

To avoid being swamped by information and actions, to be able to act and respond in a controlled way, you need tools that will help you up the eGRC learning curve and that will automate processes wherever possible. But you do not want to automate a bad process since that will just make bad things happen efficiently. Sometimes it is important to revamp a process while you are implementing your eGRC solutions and strategy. Questions to ask yourself are:  Do you have to respond to each new policy or regulatory requirement from scratch or do you have access to eGRC content that prevents you from having to continually reinvent the wheel? Do your processes depend on someone remembering to email someone else or do you have workflow management tools that automatically enforce standard processes? It’s obvious which answers suggest an organization more in control of eGRC.

  • Usability. However integrated and automated your eGRC efforts are, it will be of little avail if it’s too hard for people, especially non-experts in eGRC, to understand what’s going on or what they need to do. Usability is a critical requirement because visibility is only valuable if people understand what they’re seeing; and control is only valuable if people are willing to pick up the ball and do something useful with it. So you want the flexibility to be able to adapt automated processes to fit the way you work; you want to be able to present information to busy executives in ways that they understand; you want to make it easy for people to collaborate, not put them off with impenetrable technology.

When you’re looking at approaches to eGRC and assessing tools that might help you develop eGRC strategies and processes, keep these criteria in mind.

Recommended Reading:

OCEG – Red Book 2.0 (GRC Capability Model)