Alan Calder on IT Governance, information security & ISO 27001

The UK’s National Security Strategy (published 18 Oct 2010) identifies that, for the next five years, the four highest priorty risks faced by the UK are those arising from

• International terrorism;
• cyber attack;
• international military crises; and
• major accidents or natural hazards.

The reality, of course, is that international terrorists have an identifiable cyber capability, and any international military crisis is also likely to have an important element of cyber threat. And, as the information on which we depend to respond to almost any major national accident is stored in electronic information systems, you might argue that cyber risk is the most important risk facing the UK today. 

Cybersecurity standards

Cybersecurity standards are an important element in building a strong, resilient information and communications infrastructure. ISO27001 is the most significant international best practice standard available to any organisation that wants an intelligently organized and structured framework for tackling its own cyber risks. ISO27001, as a specification for an ISMS, is clear and precise; it also lists 133 key security controls that should be at the heart of any organisation’s approach to securing its information assets.

Many organisations, though, think it makes sense to implement ISO27001 without ever seeking external certification. The increased focus, at a national level, on responding appropriately to cyber risks undermines this approach – increasingly, organisations will want to know that their supply chain is resilient against cyber attack. Supplier audits can consume a lot of time, and an accredited ISO27001 certificate is clear evidence that an organisation has taken proper security steps and has obtained independent verification that these steps are in line with recognised international best practice.

For the Forth Valley NHS Board, the answer is now a resounding ‘Yes’. Of course, it should have been a ‘Yes’ before there was a data breach, and before sensitive patient details were put at risk. However, the Board has now recognised (and has formally committed to ensure) that the only USB sticks available for use by Board staff should be issued by the Board, and that these USB sticks should all be encrypted.

It is, in today’s world of portable media, a basic security step. ISO27001 control A.10.7.1 specifically deals with management of removable media and any organisation implementing this control must (amongst other things) use encryped memory sticks – which can be purchased with USB-resident encryption, so that they are simple to deploy and use in the workplace.

One of the most frequent questions I’m asked by CEOs is: “But what’s the real bottom-line benefit of more effective information security, or of an ISO27001-certificated Information Security Management System?”

One real benefit is the effective information security protects the bottom line. The reason you put money in a bank, is to protect it. The reason that you secure information, is to protect it – and the company that is responsible for the information. 

The recent security breach at ACS: Law has been widely reported. A law firm appears to have broken a basic law (the Data Protection Act), is now apparently under investigation by the Information Commissioner and by the Solicitors Regulation Authority and, in addition to the possibility of a fine of up to £500k, it faces unquantifiable current and future damage to its reputation, brand and future business. It’s not always clear that firms subject to this level of challenge will survive the resulting storms.

So, what might effective information security actually have cost ACS: Law? Well, a Web Application Penetration Test might have set them back £3k; implementation of an ISO27001 ISMS in a firm of this size might only have required an investment of about £10k (with another £3k or so for certification). Of course, effective information security also requires top management commitment as well as the deployment of internal time and resource – but, when you’re implementing an ISMS, you’re in control of the process. When you’re responding to a serious breach, you’re not.

Let me put it another way: an investment of about £20k, plus internal effort, might have been sufficient to prevent financial damages that could be somewhere between 10 and 100 times greater than the investment – or more. That’s the point about ‘unquantifiable damages’.

Prevention, in information security, is always better than cure.

Zurich Insurance UK not only lost 46,000 customer records, it took one year to discover the loss. The fact that the loss took place during what should have been a routine outsourcing operation just makes the matter worse. At £2.27m (reduced from £3.25m by agreeing to early settlement), the Zurich Insurance UK data loss works out to have cost the company nearly £50 per record – and that’s without the management time spent on dealing with the FSA investigation and the undoubted negative publicity which the report will generate.

The basics of data protection are still obvious: first, you have to be aware of the fact that you are in possession of personal data, and you have to be aware of how and where it is being processed. Then you have to take some basic steps: apply encryption, apply access control policies, apply secure transmission and receipt procedures (surely, after the HMRC CD-Rom fiasco most organisations would have got to grips with this idea?) and don’t allow personal data to be downloaded to USBs or other portable devices.

I covered exactly these basics at the most recent Data Privacy & Laws conference (video due out shortly, apparently) and the general response was: wouldn’t it be nice if we could get top management to understand that this is what we need to do? Well, perhaps £2.27m will help financial companies focus (although the long history of fines on financial sector companies for failing to protect personal data argues otherwise) better on this key responsibility of theirs.

The UK’s Financial Services Authority (FSA) this week fined Royal Bank of Scotland Group £5.6m for ‘failing to have adequate [IT] systems and controls in place to prevent breaches of UK financial sanctions’. The Australian IT News quite rightly identifies this as a massive failure in IT governance – which, of course, it is.

IT governance is defined as “a framework for the leadership, organizational structures and business processes, standards and compliance to these standards, which ensure that the organization’s IT supports and enables the achievement of its strategies and objectives.“ (IT Governance: a Pocket Guide)

“RBSG’s automated screening failed to screen the majority of trade finance SWIFT messages generated in the international trade transactions that it carried out,” said the FSA; it could have gone on to say something like: ‘RBSG’s Board of Directors evidently does not have in place any formal process for ensuring that it’s IT infrastructure supports and enables its compliance to UK laws and regulations or the achievement of its strategies and objectives,’ but it didn’t. That, nevertheless, appears to be the case.

It always seems to me a pity that organisations have to be pushed, by substantial fines, to do things that have significant business benefits – but there we are!

There’s a few more things I dislike about the Kindle – the naff little ‘key board’, for one, which doesn’t make for easy typing; the failure to number book pages for another – why does Amazon think it’s useful to use a page referencing system that is totally different from that which has been used for books since before Gutenberg?

And the Kindle’s automatic screen rotation is really annoying – if you lie on your side (reading on a beach, for instance) the screen can’t make up its mind which way to orientate itself and so keeps changing from landscape to portrait!

And try reading a book that has genealogies and other reference material, where you want to flip back and forth between different pages and sections (for instance, reading Wolf Hall, where supporting information is quite useful) – it’s just too hard!

As the UK enters its new age of austerity, with public sector organisations finding draconian budget cuts, one must fear that citizens’ personal data will be increasingly at risk. The UK public sector (led by the NHS) has never been that amazingly good at protecting personal and sensitive information, as newspaper articles and the Information Commissioner’s website regularly attest.

The ICO has just taken enforcement action against three councils who failed to protect personal information, including information about children. The council’s failings were all pretty standard: unencrypted USB sticks, unencrypted laptops, inadequate staff training and inadequate supervision. These are all relatively simple – if costly – to remedy; the basics – essential DPA policies and procedures should all of course be in place already.

What still seems to be missing, though, is a real committment, on the part of public authorities, to taking the business of data protection seriously – I guess that we’ll actually need to see a series of £500k fines being levied before we see the majority of organisations raising their game on the field of protecting their citizens.

A new AIIM study on SharePoint takeup has recently been published. This report builds on their survey of a year ago. Barb Mosher, writing about the AIIM report on CMS, draws this conclusion from the two surveys:

“SharePoint 2007 will be in use for a while to come, and SharePoint 2010 will likely see even more uptake by organizations for a number of reasons. The problems related to SharePoint, whether it’s 2007 or 2010, are not going to change. Not because of the platform itself, but because the strategy, planning and governance that are required to implement it are still not being taken seriously.

What will we see in surveys run next year? The way it looks now, nothing that different than this year or the year before.”

And that tends to be the story where project level governance is concerned: those organisations that plan ahead, that put in place methods for dealing with the wide range of SharePoint issues – from ghost sites through to backup failures – will usually end up with robust, effective and useful SharePoint services. Effective SharePoint governance really can be the difference between success and failure – both short and long term – with a SharePoint deployment. For this reason, Microsoft publish guidance on SharePoint Governance, and our own SharePoint Governance Toolkit helps with MOSS implementations.

The Economist’s extensive and interesting July article on CyberWar is essential reading for management in all organisations that have any reliance on the internet for communications, data sharing, business partnering, or business platforms.

The collateral damage for businesses, in any cyberwar, could be huge. Assuming, for the moment, that the Internet itself is able to survive most forms of war carried out across it, the reality is that many organisations simply don’t have adequate defences in place today to keep themselves protected and safe from the electronic warfare being waged acorss the infrastructure.

As a minimum, all organisations should take steps to secure their network perimeters. This is relatively straightforward to do: it involves a penetration testing exercise, carried out by an external, professional security testing company, who will identify all potential vulnerabilities in your network defences and provide you with structured advice as to what remedial steps should be taken.

You may form the view that cyberwar is not a significant threat for your business; there are, however, very close links between those currently involved in cybercrime, and those who might be involved in either cyberterrorism or cyberwar. Dr Mehan’s book, CyberWar, Cyberterror, Cybercrime, sets this all out very clearly. As result of what she’s saying, one has to assume that the only sensible course for the average organisation is to assume that they will be badly hurt if they don’t put their security house in order and to take the necessaty steps to ensure that their network defences are secure,

The Information Commissioner’s Office (ICO) has received over 1,000 reports of data breaches or losses since it was set up, and has issued a stern reminder that organisations must ensure that data is well protected. The biggest culprit is the NHS. The ICO’s Security Breaches Report shows the breakdown of breaches.

As we’ve said on our website (Data Protect Act Penalties), sooner or later the ICO will start levying fines for egregious breaches of the DPA – it would make sense to get one’s DPA compliance house in order before that happens, wouldn’t it? Simply buying and using the tools in our DPA Compliance Toolkit would prepare most organisations to face the worst!