Category Archives: Compliance

What do major developments in big data, cloud, mobile, and social media mean? A CISO perspective..

Screen Shot 2013-02-26 at 6.52.56 PM

Tuesday afternoon the CISO-T18 – Mega-Trends in Information Risk Management for 2013 and Beyond: CISO Views session as presented focused on the results of a survey sponsored by RSA (link below).  It provided a back drop for some good conversation, but more so it gave me a nice environment to elaborate on some personal observations and ideas.  The first tweet I sent, hammered the main slide:

“Major developments with Big Data, Cloud, Mobile, and Social media” – the context and reality here is cavernous.. “

My analysis and near-random break down of this tweet are as follows with quotes pulled from the panel.

First off – be aware that these key phrases / buzz words mean different things to different departments and from each level (strategic executives through tactical teams). Big Data analytics may not be a backend operational pursuit, but a revenue generating front end activity (such as executed by WalMart). These different instantiations are likely happening at different levels with varied visibility across the organization.

Owning” the IT infrastructure is not a control to prevent the different groups from launching to these other ‘Major developments’.

The cost effectiveness of the platforms designed to serve businesses (i.e., Heroku, Puppet Labs, AWS, etc…) is what is defining the new cost structure. CIO and CISO must

>The cloud is not cheaper if it does have any controls. This creates a risk of the data being lost due to “no controls” – highlighted by Melanie from the panel.  <– I don’t believe this statement is generally true and generally FUD.

Specifically – There is a service level expectation by cloud service providers to compensate for the lack of audit ability those “controls”. There are motions to provide a level of assurance to these cloud providers beyond the ancient method established through ‘right to audit‘.

A method of approaching these challenging trends, specifically Big Data, below as highlighted by one of the CISO (apologies missed his name) w/ my additions:

  • Data flow mapping is a key to providing efficient and positive ‘build it’ product development. It helps understand what matters (to support and have it operational), but also see if anything is breaking as a result.
  • Breaking = violating a contract, breaking a compliance requirement, or negatively effecting other systems and user requirements.

Getting things Done – the CISO 

Two observations impacting the CISO and information technology organization include:

  1. The Board is starting to become aware and seeking to see how information security is woven within ERM
  2. Budgets are not getting bigger, and likely shrinking due to expectations of productivity gains / efficiency / cloud / etc…

Rationalization on direction, controls, security responses, must be be fast for making decisions and executing…

Your ability to get things done has little do with YOU doing things, but getting others to do things. Enabling, partnering, and teaming is what makes the business move. CIO and CISO must create positive build-it inertia.

Support and partner with the “middle management” the API of the business if you will.

  • We to often focus on “getting to the board” and deploying / securing the “end points” .. Those end points are the USERS and between them and the Board are your API to achieving your personal objectives.

Vendor Management vs procurement of yester-year

Acquiring the technology and services must be done through a renewed and redeveloped vendor management program. The current procurement team’s competencies are inadequate and lacking the toolsets to ensure these providers are meeting the existing threats. To be a risk adaptive organization you must tackle these vendors with renewed. Buying the cheapest parts and service today does not mean what it meant 10 years ago. Today the copied Cisco router alternative that was reverse engineered lacks an impressive amount of problems immediately after acquisition. Buying is easy – it is the operational continuance that is difficult. This is highlighted by the 10,000+ vulnerabilities that exist with networked devices that will never be updated within corporations that must have their risks mitigated, at a very high and constant cost.

Panel referenced the following report:

http://www.emc.com/microsites/rsa/security-for-business-innovation-council.htm

Thank you to the panel for helping create a space to think and seek answers, or at least more questions!

James DeLuccia IV

My RSA Conference Notes and perspective – Tuesday AM 2013

Today kicked off, for me, the RSA conference. The best part of these types of events is the onslaught of ideas shared between peers – generally through networking and random encounters in hallways (such as bumping into Bill Brenner). Thanks first off to RSA for creating the forum for these discussions to occur.

I have the privilege of speaking tomorrow, and look forward to the debate and flow of ideas that will ensue.
While reviewing some of the research provided to attendees, I had the following observations, and wanted to share them in entirety for debate and expansion:

Vendor management by procurement SHOULD include data plus asset chain of custody, and #infosec assurance to YOUR standards#RSAC

So basically – costs per breach are up; # attacks higher; 6 more days to resolve, & the same forms of attack #rsachttp://lockerz.com/s/285234702

Aren’t costs per breach up in 2012 to $8.9 million the result of our greater leverage of information technology & resulting value!

Most botnet, malware, & C&C operators manage MORE devices; across WIDER geographies, & generate a positive ROI. How is your information security?

#rsac Art’s presentation was good. Agree with Taleb perspective, but it must applied at Org to match robustness #infosec

Art Coviello gave an impassioned presentation that I thought was very good for a keynote at that level. Typically there is a risk of sales (which did occur at the end, of course) material, but a couple good analogies and mental positioning. I thought his analogy to Nassim Taleb’s AntiFragile was on point (and funny since I am 1/3 through it, so very fresh in the mind) for the security operations against the cyber threats. I would expand it though to include the business process and information security compliance program. I have found that the block and tackle of information security itself needs to be robust and antifragile. The lacking of these elements forfeits the benefits of the threat intelligence he describes.

This is especially poignant to me given the relative lack of volatility in the type of attacks that succeed against organizations, and their ongoing effectiveness in breaching our company defenses.

If you are looking to enjoy the keynotes (I would recommend at least Art and Scott Charney) live or on-demand here.

RSA thoughts and sessions .. to be continued ..

Best,

James DeLuccia

What the Cyber Executive Order means to your business, a critique

As expected for many months, the Executive Order entitled ‘Improving Critical Infrastructure Cybersecurity” has been signed and released.  There are numerous write-ups providing analysis and perspectives.  My favorites so far are from DWT , , and an article from American Banker.

What is important is businesses and leaders should take this in balance to their own business.  The first is – if you are not considered infrastructure plainly, you should analyze if and how you support those industries, because if so you will need to meet and participate in the realm of requirements that will roll forward from this EO.  The second is – if everybody is having serious problems on maintaining their business’ confidentiality, integrity of operations, and availability of services against foes, competitors, and nation states (as highlighted hundreds of times over the last few years) – how can Executives / Senior leadership / Board of Directors / and owners not consider this a risk that requires mature and top performer attention.

As I reviewed the EO with several clients this week (and I was both impressed with their interest and startled in some cases when the conversations shifted to ‘I don’t have to do this .. do I?’), I thought I would share several top points raised… I’ll update the list below over the next few weeks as the discussions continue:

  • “Sec2Critical Infrastructure. As used in this order, the term critical infrastructure means systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters.”
    • Virtual is an interesting point that I raise below in the riddle ..
  • “4.12(c) of this order to ensure the timely production of unclassified reports of cyber threats to the U.S. homeland that identify a specific targeted entity.”

    • The use of the phrase ‘timely’ instead of actionable was a highlighted environment.  The difference is that actionable means that information shared would be more real-time, while timely may not meet this test.
  • [updated 2/18/13] “10.(c) Within 2 years after publication of the final Framework, consistent with.. and Executive Order.. (Identifying and Reducing Regulatory Burdens).., agencies..shall..report to OMB on any critical infrastructure subject to ineffective, conflicting, or excessively burdensome cybersecurity requirements.”
    • This is an important section that will hopefully drive cross-standard acceptance, and at least conform to the principle of establishing a unified corporate compliance framework, as I articulated in my book back in 2008.

A few riddles to debate and seek to understand:

  • Is Amazon’s AWS considered Critical Infrastructure?  What about Microsoft Azure?  Expand that generally – what elements of PAAS, SAAS, IAAS are critical infrastructure.  
  • If they ARE the infrastructure (you know, that whole ‘Cloud’ thing is a pretty huge market and sometimes not always well understood what has shifted to a Cloud architecture), or what of the dependencies to the point that the Critical Infrastructure itself relies on these services (logging, alerting, big data analytics, etc…)

 

Still seeking,

James DeLuccia

My RSA 2013 Conference Session details

292927main_larry_prusak

I am looking forward to seeing the world in San Francisco for the RSA Conference this year!  It is always such a rich experience speaking with everyone throughout the week.  I have the privilege of speaking during one of the sessions, and invite all to stop by before and after for greater dialogue.

I am open to all suggestions on new research and new ideas in the ongoing adventure of developing information technology organizations balancing security and compliance.  A good deal of interest in managing the complexities of the abstraction of services and challenging the assumptions of our time.

You can reach me @jdeluccia during the event.

Here is the link to my RSA Conference details.

Always seeking,

James DeLuccia IV

Top 3 attributes for businesses to benefit from Data Analytics – an Information Security & Business process perspective

Screen Shot 2013-01-30 at 4.08.18 PMBig Data introduces an opportunity that organizations see when merging silo product operations together forming a service layer or an enhanced hybrid product. Big Data also requires exceptional enterprise intelligence from the perspective of establishing the scaffolding for enterprise grwoth. That scaffolding requires advanced information technology system and business process matrix visibility.  My thesis … let me elaborate below on a single thread here given this is a subject I have been developing on recently…

In order for Big Data to work it requires abundant access to systems, data repositories, and the merging and tweaking of data beyond original data owner expectations or comprehension. The enterprise that balances the advantage of Big Data analytics with superior scaffolding will appreciate higher run rates and profitability without unfunded cost centers and above trend OpEx generally. The opportunity of Big Data without this business intelligence will be squandered and the benefits not realized as a direct result.

The CIO has this ownership and it is the purview of the Audit Committee to ensure that these risks are understood and tackled. The Board of Directors have proven to value equally the aggressiveness of Data Analytics with the ongoing revaluation of the risk tolerance and acceptance points of the business. As one can imagine, this is a familiar yet distinct activity within the executive structure, but three key attributes / activities that indicate a successful approach are as follows:

  1. Vertical awareness - product awareness, strategy, and full line of sight for each major revenue center
  2. Scrum topical teams – risk assessments and activities linked to the product market research initiatives
  3. Senior strategy alignment – what does the Board seek in this DA movement; What does the CEO/CIO envision on these product expansions; What is the audit committee observations (meaning that they must have visibility and mindfulness to the impact)

Think Big Data is not huge business? … consider these figures:

  • Gartner: Big Data Market is Worth $3.7 Trillion, Generating Over 4 Million Jobs by 2015 – article
  • Good short presentation on value of pattern based strategies, by Gartner
  • $29B will be spent on big data throughout 2012 by IT departments.  Of this figure (Forbes)

Or a classic business case example:

“The cornerstone of his [Sam Walton’s] company’s success ultimately lay in selling goods at the lowest possible price, something he was able to do by pushing aside the middlemen and directly haggling with manufacturers to bring costs down. The idea to “buy it low, stack it high, and sell it cheap” became a sustainable business model largely because Walton, at the behest of David Glass, his eventual successor, heavily invested in software that could track consumer behavior in real time from the bar codes read at Wal-Mart’s checkout counters.

“He shared the real-time data with suppliers to create partnerships that allowed Wal-Mart to exert significant pressure on manufacturers to improve their productivity and become ever more efficient. As Wal-Mart’s influence grew, so did its power to nearly dictate the price, volume, delivery, packaging, and quality of many of its suppliers’ products. The upshot: Walton flipped the supplier-retailer relationship upside down.”Changing The Industry Balance of Power

A good (no paywall) article on Forbes here breaks down the IT spent related directly to Big Data and compares against prior years up to 2012 & by industry.  

Also check out this MIT Sloan article co-developed with IBM entitled Big Data, Analytics and the path from Insight to Value  - most interesting for me was page 23 relating to Analytics trumping intuition.  This relates to EVERY business process, product, sales opportunity, accounting, fraud detection, compliance initiative, security analytics, defense and response capabilities, power management, etc …  A worthwhile read for each executive.

Think strategically act vertically and influence horizontally – scale!

James DeLuccia IV

*See me speak at RSA 2013 on the topic – Passwords are Dead