22 July 2017

Global Pulse: Resilience in Development...

The asymmetric threats cast upon the private sector on a daily basis across the globe, are rising and more complex.  As a result, Operational Risk Management is a discipline that has quickly matured in the past decade.  

Today, as we embark on this blog post number 1154 we can reflect on our amazing journey.  When you search Google from our location on "Operational Risk Management Blog" this blog is the number 1 link.

This endless journey encounters new insights and has transversed industry sectors to include financial services, energy, automotive manufacturing, aerospace, defense industrial base, pharmaceuticals and government both local and federal.  It has involved the following four fundamental principles of ORM:
  • Accept risk when benefits outweigh the cost.
  • Accept no unnecessary risk.
  • Anticipate and manage risk by planning.
  • Make risk decisions at the right level.
Whether the oversight and pursuit encountered the risks of fraud, economic espionage, workplace violence, natural disasters, terrorism or cyber vulnerabilities does not matter.  The threats and hazards that span the spectrum of Operational Risks to the enterprise are vast and increasingly diverse.  The discipline continues the quest to improve and to learn new lessons from both the private sector and government.  Now both of these need to also include a third dimension, that is evolving and could be the place to look for real innovation:  Non-Governmental Organizations. (NGO)

The NGO community is the environment that has now gone beyond response and is finally becoming more predictive:
Global Pulse is a United Nations initiative, launched by the Secretary-General in 2009, to leverage innovations in digital data, rapid data collection and analysis to help decision-makers gain a real-time understanding of how crises impact vulnerable populations. Global Pulse functions as an innovation lab, bringing together expertise from inside and outside the UN to harness today’s new world of digital data and real-time analytics for global development. The initiative contributes to a future in which access to better information sooner makes it possible to keep international development on track, protect the world’s most vulnerable populations, and strengthen resilience to global shocks.
There are plenty of situational awareness analogies that can be made to the risk management of vital private sector or government assets over the years.  Predictive operations have been evolving for years with the goal of preemptive capabilities to detect an attack on a Homeland.  The analysis of information from disparate sources is nothing new.  Link analysis and other methods of qualitative and human factors analysis give us the cues and clues to a possible evolving pattern of human behavior.

Yet what is fascinating now about the NGO perspective, is the intersection of Big Data and the mobile phone:
Wherever people are using mobile phones or accessing digital services, they are leaving trails behind in the data. Data gathered from cell phones, online behavior, and Twitter, for example, provides information that is updated daily, hourly and by the minute. With the global explosion of mobile phone-based services, communities all around the world are generating this real-time data in ever-increasing volumes. These digital trails are more immediate and can give a fuller picture of the changes, stressors, and shifts in the daily living of a community, especially when compared with traditional indicators such as annual averages of wages, or food and gas prices. This is especially crucial during times of global shocks, when the resilience of families and their hard-won development gains are tested.
These global shocks that are economic, geopolitical or as a result of climate change are at a macro level nothing more than environmental volatility.  This volatility in markets, government leadership, religious conflict and drought are what is driving the NGO development community to be more predictive and to be more preemptive.

In concert with this focus on predictive intelligence is the initiative "data philanthropy".  How can the data sets from our respective countries be shared to work on the really hard global problems together?  Open Data Sites is just the beginning.  You have to make sure that you recognize the attributes of "Big Data for Development" vs. the private sector or purely government:
Big Data for Development sources generally share some or all of these features: 
(1) Digitally generated – i.e. the data are created digitally (as opposed to being
digitised manually), and can be stored using a series of ones and zeros, and thus
can be manipulated by computers; 
(2) Passively produced – a by product of our daily lives or interaction with digital
services; 
(3) Automatically collected – i.e. there is a system in place that extracts and stores
the relevant data as it is generated; 
(4) Geographically or temporally trackable – e.g. mobile phone location data or
call duration time; 
(5) Continuously analysed – i.e. information is relevant to human well-being and
development and can be analyzed in real-time;
What if the private sector and the government started looking through a different lens?  Or perhaps the other way around.  Is the NGO development community capable of learning from the mistakes with data that intersect with privacy and national intelligence?  Operational Risk Management is just as much an imperative in the NGO environment, as we evolve in the integration of Big Data for global humanitarian initiatives.

When you really look at the opportunity and the challenge ahead, you must consider this intersection of data today in context with where development is still in its infancy.  Look at this visualization of Google search volume by language.  Notice the darkest parts of the planet Earth.  These are where the NGO community lives today, with little access to the Internet, regardless of language.  The human resilience factor necessary to evolve in these non-connected IP (Internet Protocol) deprived areas of the world, must be addressed as we aspire to become more predictive risk managers.

16 July 2017

Cyber Deterrence: Chief Information Warfare Officer (CIWO) is born...

In 2017 there has been a significant amount of news and dialogue on the topic of information security. America is now waking up to the reality that it's true vulnerability is critical infrastructure reliance on strategic networks and is worth analyzing in depth.

Operational Risk Management (ORM) in critical infrastructure sectors such as Energy, Finance, Transportation, Defense Industrial Base (DIB) and a dozen more, is alive and well. Yet the long view, requires a pivot from the cyber analogies of immune systems and daily hygiene scenarios simply to address cyber theft, denial of service, viruses and ransomware.

The growing priority problem-set is "Cyber Deterrence" and the U.S. is still a long way off from having this strategy in place. The current abilities of several known nation state adversaries, to launch and maintain a persistent attack on our critical infrastructure, requires a new and robust set of initiatives to solve this new reality and immediate cyber problem for national security.

The fusion of Homeland Security with U.S. Department of Defense planning to address "Cyber Deterrence" is necessary and beyond what has been accomplished to date. The attributes focused on "Continuity of Government" (COG) and "Continuity of Operations" (COOP) are paramount with solving the hard problem-set of U.S. Cyber Deterrence. Why?

A wider range of military cyber options are needed beyond diplomatic expulsions and economic sanctions and a clear policy framework must be in place for these deterrence options to be utilized against nation states.

The growing use of cyber offensive weapons requires an increased level of preparedness, offensive war games and planning including substantial integration with the U.S. private sector critical infrastructure companies. The resilience factors associated with Fortune 500 private sector companies is vital.

First, a substantial portion of the new problem-set, involves the use of offensive cyber weapons and the declaratory engagement policy with adversaries such as Russia, China, Iran and North Korea. This must include the key dialogue on attribution capabilities. Have you ever had a conversation with your information security team on the topic of attribution? If you haven't then now is the time to better understand this set of issues.

Second, the degree to which a private sector company has been under attack by non-state actors will in many cases provide an indicator of their current cyber deterrence capabilities. The question is, how would they respond and how resilient would they be if any new attacks were exponential in proportion to previous adversarial campaigns?

Third, the coordination with not only DOD and private sector companies also requires significant integration with the Department of Homeland Security (DHS), State Department and the Intelligence Community (IC).

Non-Kinetic cyber actions utilized by the military is not new. Strategic U.S. ICT (Information, Communications & Technology) capabilities working side-by-side and in concert with the military is now more necessary than ever. Private sector organizations interacting and engagement with USCYBERCOM to establish working relationships that include COG and COOP level planning also needs to accelerate.

So what?
The House has joined the Senate in calling for the Department of Defense to update its cyber strategy and to more clearly define the meaning of cyber deterrence.
The House on July 14 overwhelmingly passed the 2018 National Defense Authorization Act, which included a number of cyber-related amendments, including a provision directing the secretary of defense to "develop a definition of the term 'deterrence' as such term is used in the context of the cyber operations of the Department of Defense; and assess how the definition...affects the overall cyber strategy of the Department."
The Senate's draft of the NDAA establishes a U.S. cyber deterrence and response policy and calls on the administration to develop a clear cyber deterrence strategy.
The Chief Information Warfare Officer (CIWO) has been born...is it a myth?

09 July 2017

Mergers & Acquisitions: Achieving Trust Awareness...

Building relationships is a continuous process that requires an effective approach, mutual intent and clear understanding of the purpose.  Operational Risk Management is at the center of all kinds of Mergers and Acquisitions (M&A) activities.

Whether it is a mega-merger between Amazon and Whole Foods or even a planned meeting with a potential partner or client invested to discover the possibilities of working together;  you can improve the ratios of a positive outcome.

Developing new capabilities, launching a new solution or improving an existing line of business, requires a substantial investment in "Relationship Building."  A team of individuals with their respective areas of knowledge, subject matter expertise and mutual mission still require continuous hands on facilitation.

The building of relationships requires at the core, a persistent devotion to "Trust Awareness."  This means that you have to be conscientious about looking through your individual and organizational behaviors and messaging, that could in some way erode trust.  This trust awareness is the ability to detect anything that could diminish the possibility for the relationship to grow.

Building and growing trust with new partners, mentors, clients or customers requires an investment in time and resources to monitor, measure, document and adapt with change.  It requires a new level of transparency and focus on integrity.  Simultaneously, it means that you have to accept a new level of vulnerability.

Regardless of the logo on your business card or web site, the tag line of what you are about, or even the URL for your domain name, what are you doing today to build trust?  With your employees, co-workers, supply chain or channel partners.  What is the process and method you utilize to improve your trust awareness and to build stronger and lasting relationships?

Jeffrey Ritter says it best from his book "Achieving Digital Trust":
"Whether in government, in business, in classrooms, or at the dinner table, the ubiquitous presence of digital assets and devices enables us to do something radical—immediately seek out information that allows us to challenge and evaluate our trust in the decisions of others we are expected to follow. So, in addition to your own decision process being shaken, so too are the evaluations others make to trust your decisions. If you are a business leader, IT executive, information security manager, systems architect, elected public official, educator or stay-at-home parent, you have surely felt the discomfort.

As soon as you announce a decision, someone is thumb-typing on a device to find information to validate or contradict you. A few clicks and your questioner has acquired data that enables that person to question your decision process, view it differently, or weigh it with lesser confidence. Admit it, you surely have done the same when you are on the other side of the table, hearing the decisions, opinions, or guidance of others—a superior officer, a corporate manager, a business partner, a teacher, or even a spouse."
Building effective relationships between people in the digital age will certainly involve e-mail, iMessages, web sites and even Twitter.  How often do you read a persons name or see them perform before an audience and immediately do a "Google Search" or LinkedIn lookup?  What you see and read there, could influence you and how much you initially trust that person.

There are dozens of ways that due diligence is accomplished during any M&A activity including the asset inventory, testing and validation along with a forensic records review.  Yet in the initial days of the team coming together to identify, approach and cultivate a meaningful relationship with a new partner or buyer, the process is vital.  The methodology can mean your success ratio is improving, flat-lined or declining.

Step back and take a look at your relationship building capabilities.  Analyze why your success ratio is declining.  Understand the trust awareness factors that could be part of the answer to your achieving even greater digital trust.  The next step is to effectively identify and solve the problems that you will encounter as the M&A trends continue.

Building new relationships takes time and resources.  Yet, keeping those relationships effective and continuously growing "Trust Awareness" for years and decades requires even more.  Listening, learning and compassion...

02 July 2017

USA: Our Past and Future Destiny...

The United States of America turns 241 years old on Tuesday, July 4, 2017.  As the parades of celebration commence across the small towns and the mega-metropolitan cities, we have so much to be proud of and have so many accomplishments in these few short centuries.

The Founding Fathers really had no idea in 1776 what Operational Risks they would face or what our nation would look like now, as they were crafting our U.S. Declaration of Independence and later the U.S. Constitution.  All they knew was, that they were crafting something new and unique, in so many ways.  It has endured World Wars and this Republic has become ever more resilient to economic turmoil over the years.

The rest of the world needs the United States of America.  After all, how would they know about the existence of underground ice on Mars or other first discoveries by NASA.  How would many of the countries on our Earth continue to accelerate their abilities to produce greater food yields, preserve vital fresh water drinking sources or even power their transportation sector with clean energy?  Who invented the Internet?  We explore farther and innovate faster...

As Americans, we travel the world with our U.S. Passport and it gives us a glimpse into why this little book is so valuable.  Why it is so sought after.  Even most Americans might not realize that their U.S. Passport is not their property.  It is the property of the United States (Title 22, Code of Federal Regulations, Section 51.9).  It must be surrendered upon demand made by an authorized representative of the United States Government.

On page 16 and 17 of the U.S. Passport is the following quote:

"This is a new nation, based on a mighty continent, of boundless possibilities."  --Theodore Roosevelt

Theodore Roosevelt became the United States youngest President at age 42 in September of 1901.  The 25th President, William McKinley had been the third U.S. President to be assassinated after Lincoln and Garfield.  Now Teddy Roosevelt saw the possibilities and as Vice-President, took our country forward once again.

One can only imagine what our country will be like in another 241 years.  Where else in the solar system will we have new outposts?  How will we be assisting and cooperating with other countries to promote peace and justice?

So with that United States banner of "50 Stars and 13 Stripes" waving in the wind over your home in America this 4th of July, put your hand over your heart or salute our flag.  Remember how far we have come and how far we will be going as a nation together...

24 June 2017

Walking the Talk: Asymmetric Lessons Learned...

Operational Risk Management (ORM) is about "Walking the Talk." What are you advocating in your solutions or services and advice to clients or within your own organization? When you "Walk the Talk", this means that you believe in and demonstrate first to yourself and your own organization that you execute and comply with what you say is policy and is a key factor in your own Continuity of Business Operations.

You carry out in a demonstrable form the rule-sets, best practices, ethics and behaviors that you are asking your own customers and your suppliers to follow. Your failure to do so, can have tremendous ramifications.  Nicholas Weaver explains:
The payload of CrashOverride is rather elegant in its simplicity; in a way it’s reminiscent of how a toddler might sabotage the lights at home. Once CrashOverride is running on a control system, it begins by mapping out all the circuit breakers. Once the payload knows where all the switches are, it can launch the primary malicious attack, either by turning off all the switches or—potentially more catastrophically—by repeatedly flipping them on and off until the substation in question is isolated.
Asymmetric Warfare is about an indirect strategy and the ability to compromise your target through non-traditional methods.  You and your organization might just be a pawn in a more sophisticated, planned and smart attack on a much more worthy adversary. Whether the intended target is a Critical Infrastructure organization in the financial, energy or defense industrial base (DIB) doesn't really matter.

Supply Chain Risk Management (SCRM) is not just about validating where and how embedded circuits, EPROMs or other systems software are ensured for quality and without tampering. SCRM is about your vendors themselves being compliant within their own enterprise with the manufacturing of their own products or the operational environment of their solution ecosystem.

The trust and confidence of your extended partners, clients, contractors and key suppliers is ultimately about "Walking the Talk." 
Malicious and trusted insiders pose a range of challenges in terms of counterintelligence risks and physical threats, and experts say policy needs to catch up quickly to the new technologies available to help mitigate the problem.  Mackenzie Weinger is a national security reporter at The Cipher Brief
If you are a prudent CSO or CISO of a critical infrastructure product or services organization, beware. You may just be what the enemy needs to perpetuate their asymmetric operations on the Homeland. Beyond your own reputation being at stake, so too is the trust, safety and security of the entire economic infrastructure of the United States.

17 June 2017

Innovation: Investing in the Linchpins...

There are new innovation initiatives that have been launched across America and internationally over the past few years.  Each has a vertical or horizontal focus to attract a particular set of entrepreneurs, coders, researchers and founders or data scientists.

You may have seen the accelerators, the incubators, training boot camps or even the H4D class being offered in your particular U.S. city or university lately.  Behind these initiatives are leaders, executives and fellow startup founders/practitioners who have developed a combination of methodologies and strategies, to produce new products and problem-solving business platforms.

After several years of practicing and mentoring in this category and recently devoting 30+ hours of first hand observation, there are several insights that were discovered.

First off, the quality and experience of instructors, mentors and the support ecosystem is vital.  You must create a robust program to recruit, train and continuously facilitate the actual people who surround the accelerator, incubator or university class and are devoting their time and resources to volunteer.

The ecosystem itself requires tested and proven processes, business rules and significant buy-in by all contributors.  The volunteers need a set of program prerequisites, a framework and the coaching along the way, to make their experience just as valuable as the participants in the innovation entities program.  Many of the mature innovation programs do this already.

Second, the founders, subject matter experts, linchpins, content providers or problem-set sponsors should have their own meetings and live interactions before and after each iteration of the participants program.  As an example, if the incubator has a cohort that is in-residence over the course of 10 weeks, on Tuesday's from 4:30-7:30PM, then the volunteers should meet for 30 minutes before and 30 minutes afterwards.

Why?

During those 3 hours there are plenty of live interactions, new learning, comments and ideas generated with the actual program participants.  It is just as valuable for the volunteers to share and interact after each iteration or cohort meeting to prepare and to debrief.  Certainly some of the follow-up learning could be captured using Slack or other online tools, yet having those linchpins face-to-face and interacting live is ever so valuable.

So What?

The maturity of the systems and processes associated with the innovation initiative, will be a key factor in the long term success and longevity of a particular program.  Yet even a set of solid systems can be influenced and characterized simply by the combination and quality of people, who are interacting and supporting these systems.  The parallel effort and devotion of one-to-one development, training and post program-metrics of these instructors, mentors, problem-sponsors and facilities or resources donors is paramount.
If you are an innovation engine producing new entrepreneurs and business startups that utilizes an ecosystem of volunteers, your future success will be directly linked to these vital linchpins...

04 June 2017

Decision Advantage: The Business of Information Assurance...

The CxO's in the Global 500 are evermore involved in the state of asymmetric warfare over Intellectual Property (IP), Economic Espionage and the simple but effective use of ransomware.  The "Decision Advantage" and national security implications, intersect with international commerce and the consistent security vs. privacy policy debates.

How would you invest resources to Deter, Detect, Defend and Document (4D) within your enterprise, if you knew that your organization would be continuously vulnerable for the next 6 years?  What would you change, if this was the current state of play:
"A recent study from the RAND Corporation, a global policy think tank, determined that among any given entity's stockpile of zero-day vulnerabilities, only 5.7 percent of these bugs will be discovered and publicly disclosed by a second party within a year's time. (Note that the study does account for additional groups that may also find some of the same bugs but decide to secretly hoard them.) Moreover, the study found that exploits and their corresponding vulnerabilities have an average life expectancy of 6.9 years before they are uncovered and patched."
You won't have to invest more dollars in your pest extermination company such as Orkin to address these kind of bugs.  The software vulnerabilities that exist in your organization, will be unknown to you long enough for the adversaries to live and operate freely inside your company, for months if not years.

The mindset shift that is necessary now, is to view the enterprise as any major change management initiative.  One that is continuously evolving based upon market shifts and new product introductions.  You have to be "Adaptive" and you must respond to the competitions new marketing campaigns.

Why is it so hard for you, to take the "Strategy of Business" and make the leap to the "Strategy of Information Security?"

When the competitor launches a new feature set and the corresponding Ad campaign, how do you pivot?  What do you do to counter the potential erosion of your market share?  How much money and resources are devoted to the new roll-out, brand recognition and sales events?

Can you imagine sitting back and doing nothing for months or years, while your adversaries in business are exploiting your slow and weak response in the marketplace?

The nation-states and Crime, Inc. is betting on the reality that you don't take Information Security seriously in your organization.  They do their research to see what Global 500 organizations are keeping their Information Technology budgets flat, year-to-year.  They use this Intelligence to stack rank their list of targets for the software vulnerabilities they are buying each day on the "Deep Web."

Is your Chief Information Security Officer (CISO) still reporting to the Chief Information Officer (CIO)?  Is your Chief Privacy Officer (CPO) even part of your Senior Staff?  Can you show a line item increase for Information Security in your year-to-year budget, to address the change management reality and strategy of your enterprise?

Have you and your Board of Directors had a briefing yet on "The Shadow Brokers?"  What does it all mean for your enterprise?

It means that the traditional way of thinking about protecting and defending your organization is over.  It means that the standard "Go-to-Market" strategy and "Competitive Intelligence" investments that you are making should incorporate a parallel "Information Assurance" program.

The business of an "Adaptive Enterprise Architecture" and "Decision Advantage" requires bold new thinking and even harder changes of personal and organizational behavior.

So what?

The truth and reality of your business survival means a significant change in strategy and in investment.  Do your own research within your own organization this week.  Get the numbers and the data to show how much you are spending next budget cycle on Information Assurance vs. last year.

Find out where the budget is being allocated year-to-year and why?  You know how to do this.  Just like you have been doing it, with the Marketing and Sales Department.

What is the opportunity?

Sometimes the digital truth is difficult and in the end, the trusted reality becomes almost "Darwinian".  Survival in the next decade will be about your "Decision Advantage" at the speed of Digital Trust...

28 May 2017

Memorial Day 2017: Honoring All of Our Fallen...

On Memorial Day 2017 in the United States, we remember those who have defended our freedoms and our Republic.  As the sound of modern aircraft lift off in the distance and the 50 stars and 13 stripes of our flag wave in the wind, we pause.

This day, is about a visit to Arlington National Cemetery or another ceremony, to stand and remember those who you once knew:


Neil was just one of those who have served our country with distinction and honor in Special Operations.  A man who did not die, as a result of fighting in the Civil War, World War I or II, the Korean War, or Vietnam.  He served our country with courage in the Global War on Terrorism (GWOT):

"Neil Christopher Landsberg of Frederick, Maryland, passed away May 9, 2013. Born January 13, 1980 in Wichita, Kansas, he attended Thomas Johnson High School, Frederick, MD and Valley Forge Military Academy in PA. He graduated from the Citadel, Charleston, SC and served with distinction as a Captain in USAF Special Operations receiving the Air Force Commendation Medal, Air Force Achievement Medal, Meritorious Service Medal, Defense Service Medal, Afghanistan Campaign Medal, and Global War on Terrorism Service Medal. He was employed by Blackbird Technologies."

As we bow our heads this Monday, May 29, 2017, think about our United States and about the less than 1%.  The less than 1% of U.S. citizens who have made so many sacrifices in life, for our country.  You also have to include a tremendous thank you, to all of those family and friends who were and still are the support system for our service members.

Just up the Potomac River in Langley Virginia, there are 125 or so Stars on a Memorial Wall.  These remember those individuals from the CIA who have also fallen, in the line of duty to our nation.  They too are acknowledged and remembered this Memorial Day.

 What can you do on this day to "Honor our Fallen":
  • Donate or volunteer for a cause that was important to them
  • Write them a letter
  • Talk about them
  • Fly the American flag high
As you navigate your daily routine on Tuesday, reflect on all that Neil and the hundreds of thousands of others have given their life for:
"We the People of the United States, in Order to form a more perfect Union, establish Justice, insure domestic Tranquility, provide for the common defence, promote the general Welfare, and secure the Blessings of Liberty to ourselves and our Posterity, do ordain and establish this Constitution for the United States of America."

20 May 2017

Board of Directors: 4D Strategy Revisited...

The Board of Directors are convening this week and there is an item back on the agenda, we haven't seen for sometime:

Recovery Time Objective (RTO) Recovery Point Objective (RPO)

These Business Continuity (BC) and Disaster Recovery (DR) parameters are being addressed for good reason.  WannaCry and the impending Tsunami of cyber worms attacking our critical infrastructure across the globe.

Designing a resilient and fault-tolerant architecture for your Operational Risk Management (ORM) strategy shall focus on critical assets and the impact of unidentified single points of failure.  Implementing a highly available IT infrastructure and resilient applications to quickly respond to major incidents or a disaster scenario is vital in our 24x7x365 operations.

Beyond a revisit to the ability to recover from a sudden disaster, the Board of Directors may be asking Senior Management about the global standard for Information Security:  ISO 27001:
The ISO/IEC 27000 family of standards helps organizations keep information assets secure.

Using this family of standards will help your organization manage the security of assets such as financial information, intellectual property, employee details or information entrusted to you by third parties.
 More importantly for organizations who may say to themselves, "well we are safe because we are in the cloud" is the standard ISO 27017:

ISO/IEC 27017:2015 gives guidelines for information security controls applicable to the provision and use of cloud services by providing:

- additional implementation guidance for relevant controls specified in ISO/IEC 27002;

- additional controls with implementation guidance that specifically relate to cloud services.


As an example, Amazon Web Services Cloud Compliance enables customers to leverage their utilization of ISO 27001 standards.  Yet there are shared responsibilities  that you must be aware of within the shared responsibility model when it comes to the relationship with your organization and AWS:

While AWS manages security of the cloud, security in the cloud is the responsibility of the customer. Customers retain control of what security they choose to implement to protect their own content, platform, applications, systems and networks, no differently than they would for applications in an on-site datacenter.


So what?

If you retain ownership and control over your content within a cloud implementation architecture, what about answers to these highly relevant questions:
  1. What does our organization need to comply with the laws pertaining to privacy and data protection?
  2. Who will have access to content?
  3. Where will storage of content be located physically /  geographically?
  4. How will the content be secured both physically and virtually?
So in this environment of shared responsibility let us ask a simple question.  Who is accountable for the configuration of the AWS provided security group firewall?  This is an area of your responsibility including all operating system, network and firewall configurations.

The Board of Directors needs to revisit Business Continuity Planning and Disaster Recovery with the CIO and all IT stakeholders at your organization, including ISP's and any third party infrastructure suppliers.

Why?

The "Business" is in many cases out of "Synch" with the Information Systems / Data Management / Privacy / Security side of the enterprise.  The WannaCry issues may not impact your organization directly because you have already patched or your systems and are beyond the vulnerabilities of this Operating System specific threat.

Where the business is heading in the next six to nine months with mergers, acquisitions and even consolidation, will impact your overall enterprise architecture. The business pace of change will most likely be months even years ahead, of where the IT infrastructure is today and it must become more resilient.

In order to understand that an attack is actually occurring, normal results have to be documented and a historical trend has to be established. What is normal? How do you know what normal looks and feels like? You document, store, record and analyze what normal is. If you have done this for long enough and across the potential targets the attacker is trying to exploit, then you will know the second an unauthorized result takes place.

The Take Away

Documenting the behavior of people, processes, systems and external events is a vital component of a complete strategy for risk mitigation. Understanding what normal "is", begins with effective documentation and analysis. Many organizations begin to document long after it is too late or as a result of a significant business disruption. Documentation remains to be a challenge for many, and a task that attackers know is likely to be left undone or behind schedule.

Conclusion

You must create the culture and the due diligence to see that your IT strategy becomes part of the fabric of the organization internally and with outsourced partners or suppliers. Only then will the attacker realize that this combination to deter, detect, defend and document is alive and growing in your enterprise. This is when attackers become discouraged, afraid, uncertain and ultimately ready for a new and less formidable adversary.

Attackers use tools to exploit a vulnerability to create an action on a target that produces an unauthorized result, to obtain their objective.  These "4D" lessons should put you on the way to creating a more survivable business.

14 May 2017

Digital Illiteracy: Trust Decisions in a Global Race...

Executive Management and the Board of Directors are asking Chief Information Officers (CIO) and CISO's about WannaCry this weekend.  The illiteracy and complacency of key officials in business and governments across the globe are again evident today:
"The ransomware strain WannaCry (also known as WanaCrypt0r and WCry) that caused Friday’s barrage appears to be a new variant of a type that first appeared in late March. This new version has only gained steam since its initial barrage, with tens of thousands of infections in 74 countries so far today as of publication time. Its reach extends beyond the UK and Spain, into Russia, Taiwan, France, Japan, and dozens more countries."
If you are an Operational Risk Management (ORM) professional in your particular organization, you may be on high alert.  You may have had a few sleepless nights since Friday, as the wave of infections propagated across systems and networks running Microsoft operating systems.

Are you or your organization a victim?  Why?

The illiteracy and complacency of senior management across commercial and government enterprises about information security, continues to plague our critical infrastructure sectors and institutions.  In 2017, this fact is our greatest vulnerability and threat.

How does any legitimate organization both public and private explain being subjected to an exploit, that has been known about for months?  What excuse could there possibly be, for not having patched a system, that is most likely far beyond "Out-of-Date"?  There will be many excuses told and so many others trying to explain to the Board of Directors about the lack of funding or the vast complexity of a systems network.  Yet here we are in 2017, with the same set of complacent attitudes and practices still in existence.

Emily Dreyfuss at Wired.com sums it up nicely from a government perspective:
"All of this underscores how digital illiteracy at every level of government endangers the security of the nation and the functioning of democracy. It takes a multi-pronged, concerted approach, with smart internal policies, federal legislation, tech savvy diplomats, and a willingness to realize information security is a critical skill for the defense of the nation—all of which is incredibly difficult to achieve even when a government is functioning well."
At the dawn of the World Wide Web, many of us in the "Information, Communications & Technology" (ICT) industry, understood and studied the new ecosystem and battle space evolving before us.  All of those subject matter experts and government officials, have been immersed in the Internet environment for over 20 years.  Even to this day, we wonder why executives still "Don't get it."

In many cases we understand that not every executive is going to understand the tech vulnerabilities of ransomware.  Yet are the same executives capable of understanding the simple concept of Disaster Recovery Planning?  The ability to accomplish incremental and daily back-ups of data?  We think they also can understand the concept of patching systems that are vulnerable.

The budgets devoted to ICT are in many cases a mystery to illiterate executives.  CIO's and Chief Information Security Officers (CISO) would most likely say in general, that they do not have enough resources to fight the battle.  This is known.

TrustDecisions that occur within the ranks of senior management are now maturing to the point of focus on building digital trust across the enterprise.  The decisions to trust between humans is different than the decisions to trust between machines.  Or is it?

Achieving Digital Trust requires a vast yet easily comprehended set of rules and policies.  Is the United States losing the race for "Digital Trust?"  Consider this blog post from Jeffrey Ritter:

"Advances toward digital trust, whether enabling commerce or government autocracy, require enormous resources to create the inter-dependencies and inter-operabilities that enable digital information to be functional and useful. The conspicuous absence of those resources is simply leaving the United States on the sideline. The disruption of digital trust may likely gain such momentum that no amount of “catch-up” investments will enable the combined assets of government and industry to catch up in the global, wired marketplace that now exists."

Executive management across America has a choice.  You as an individual could raise your education and awareness level on your ICT landscape, in several ways.  This in turn, may reduce the overall level of illiteracy and complacency across our critical infrastructure domains.  This will eventually lower our vulnerability over time.  Here is one solution:  StaySafeOnline.org

Let us start the lesson by defining the landscape and the battle space.  What is the "Deep Web?"  It is that part of the online universe, that is not indexed by traditional search engines.  But how large is it?  When asked this question to many executives, they have no idea.  Not a clue.

The "Deep Web" is 500+ times larger than the surface web and growing.  The "Deep Web" is 7500+ terabytes vs. 19 terabytes that Google and others capture.  Wake up and realize the magnitude of the problem-set, as you consider the next budget allocations for the safety and security of your enterprise.

The Trust Decisions you make with your colleagues, partners, employees, customers, communities and countries, will either make you more trustworthy, or will erode and erase trust.  At the pinnacle of your next major Trust Decision, ask yourself whether you are truly "Achieving Digital Trust..."

06 May 2017

Quiet Professional: A Leader Remembered...

Leadership has been written about since humans have been writing and recording history.  How leaders have been described, documented and chronicled over our existence here on Earth, comes back to the definition of leadership:  noun, the act or instance of leading - the office or position of a leader.

The leader and the characteristics of a particular person, are typically what is written about to document someone who is in a position of leadership.  It may start as an oldest sibling, leading younger sisters or brothers when Mother or Father is not around, or even deceased.

It may have all started in a school or church group, or as camp counselor, President of that social group, and then someday even also as a Mother or Father.  Leaders and leadership have so many facets and is in many cases just present, or absent in someone's life.

Over history, the definition of a person who has been or is a current leader, has several synonyms:

Synonyms boss man, captain, chief, foreman, head, headman, helmsman, honcho, jefe, kingpin, boss, master, taskmaster

In the broad and complex world we live in, these synonyms only describe a small facet of what true leadership is all about.  The vast realm of Operational Risk Management (ORM) also gives us additional context, when it comes to true leadership and the goal of ever increasing our overall safety, security and trust.

When someone writes your eulogy as an Operational Risk Leader, what will they say.  How will they describe you?  Perhaps none of the synonyms above are even mentioned.  Why?

It is because you are known as a "Quiet Professional."  Someone who is a leader and continues to exemplify the act of leading in so many ways and far too detailed to describe in words.  Yet you continue to aspire to improve, to listen, to learn.  You don't know it yet, but at your eulogy, others will describe you as a "Quiet Professional."

The "Quiet Professional" operates through life serving others, doing their best to continuously learn and improve on their greatest skills.  Yet at the same time, the true leader also recognizes the areas of knowledge and expertise they don't possess and so they will create alliances with others who do.

The small group, the team, the cohort, the class, the board, the executive office, the assembly, the country - they have a combination of leaders who are diverse in their skills, knowledge and aspirations and yet simultaneously, they have the same single mission.

How others will describe you and your leadership at your eulogy, is completely in your control as a human.  What are the characteristics of your particular way of leading and operating as a "Quiet Professional (QP)?"  Maybe it will sound like this:

QP was a person that not many people knew very well and that was just fine with them.  QP worked on becoming and performing each day, as the best they could be, with each person they encountered in life, one-to-one.  As a brother or sister, as a mother or father, as a friend and servant leader of others.

QP was always watching out for others.  Looking around the corner or over the horizon.  It was for three reasons.  Curiosity, building trust and continuous learning.  It was because QP always wanted to improve and to aspire for that next level of perfection.  QP wanted others close to them to feel safe and secure.

QP wanted others to feel as if they could do anything and could achieve anything.  What ever their particular mission was that day, month or year.  QP wanted those closest to them to know, they were always going to be cared for and looked after,  no matter what happened.

QP will always be remembered for their kind heart and tremendous courage.  QP will be remembered for their fierce competitiveness and simultaneous compassion.  They will be remembered for their ability to love.  Their ability to forgive.  And QP will always be remembered for their leadership.

Are you a "Quiet Professional?"...

30 April 2017

Complacency Risk: The Next Attack...

 In Ronald Kessler's book "The Terrorist Watch" you get the impression that this journalist, author and nonfiction story teller is walking a thin line. A line between telling us too much, because it could compromise national security and not telling us enough, so that the public can really visualize what the truth is.

"Inside the desperate race to stop the next attack". This book tag line says it all.
Drawing on unprecedented access to FBI and CIA counterterrorism operatives, New York Times bestselling author Ronald Kessler presents the chilling story of terrorists’ relentless efforts to mount another devastating attack on the United States and of the heroic efforts being made to stop those plots.

Kessler takes you inside the war rooms of this battle—from the newly created National Counterterrorism Center to FBI headquarters, from the CIA to the National Security Agency, from the Pentagon to the Oval Office—to explain why we have gone so long since 9/11 without a successful attack and to reveal the many close calls we never hear about. The race to stop the terrorists, Kessler shows, is more desperate than ever.

Never before has a journalist gained such access to the FBI, the CIA, the National Counterterrorism Center, and the other agencies that are doing the unheralded work of finding and capturing terrorists.

Ronald Kessler’s you-are-there narrative tells the real story of the war on terror and will transform the way you view the greatest problem of our age.
OK, so what? So how does this war on terror and media leaks within the context of Operational Risk impact your institution or organization? Here are a few ways:
  • Will your company have staffing challenges as a result of new immigration legislation or limits on H1-B Visas? Remember the 9/11 hijackers?
  • Will your institution require new systems and processes to meet increased compliance or regulatory mandates? Remember the Patriot Act?
  • Will you or a senior staff member be the target of a kidnapping, ransom or extortion plot at the hands of a terrorist cell? Remember Danny Pearl?
  • Will your organization be impacted by the leaks in the press regarding your operational strategy or Board Room discussions? Remember pretexting at Hewlett Packard (HP)?
Sharing information. Too much or not enough. The paradox of our generation as we all go digital. The speed of business in the connected economy and 24 hour news cycles has created a beast that will not ever be tamed or controlled.

Operational risks are a result of the continuous challenges to the collection, dissemination and analysis of information. Think about your own institution and those who hold the keys to the most valuable information.

Those who disclose operational secrets could be putting that "deal" in jeopardy just as easily as putting that "life" in harms way. Those who try to sleep at night in close proximity of their "Blackberry" know the feeling of information overload, or starvation. Both represent operational risks that keep the same people grabbing the Prilosec OTC or the AmbienCR.

Ronald Kessler's book is a wake-up call for all of us in the United States. A Presidential election is behind us and there has been over eight years of testing and waiting by those who wish to do us harm.
"To many fail to recognize that al Qaeda's long-term goal is to send the US the way of the Roman Empire. And too many in the press are willing to take the chance of compromising the lives of innocent Americans by running stories that gratuitously disclose operational secrets."
The risk of complacency is and will continue to be our greatest threat...

22 April 2017

Go Fast or Go Far: Professionals of Operational Risk...

As the sun sets less than a mile from the Pacific ocean, dozens of security researchers from across Los Angeles are converging on this modern technology office park.  The meeting presentation this evening, will be focused on unveiling vulnerabilities within one of sixteen U.S. Critical Infrastructures.  Why?

Operational Risk Management (ORM) is a discipline that is a dynamic matrix, of columns and rows of the architecture and intersections of your entire enterprise.  The places and ways that the organization is exposed to potential failures of people, processes, systems or other external events.

Think about how many people you have working with you, the number of locations they work and travel, the number of technology devices running software to compute algorithm operations to enable your particular mission.  Think about all the potential ways that adverse weather and natural disasters or the simple loss of electrical power or communications in a few square blocks of your city, will impact you today.

Security researchers are also converging into a conference room somewhere in your organization this week, to discuss and show evidence of your organizations vulnerabilities today.  They might be experts in "Ruby on Rails" or how to optimize "SecDevOps".

They might be experts in counterintelligence or the detection of rogue/activist human behavior by analyzing open source social media.  They might be experts in using offensive tools, operating armored vehicles and flying aircraft into hostile environments.  Among them are also your legal experts in privacy and regulatory compliance.

Why these individual professionals are working 24x7 to expose, document and provide evidence of your vulnerabilities is complex.  Yet you should know, that they are doing it because they understand that your adversaries are also hard at work, to do the same.  Is it a competitor or a nation state?  Is it a disgruntled employee or an external extremist?  Is it the next tornado, hurricane or earthquake?  The landscape is vast and is continuously changing by the minute.

As an executive within your organization, when was the last time you devoted an hour or even two, to lock yourself in the same room with your Operational Risk professionals.  To see what they are working on to Deter, Detect, Defend and Document, all that is happening in their environment today.

What if you had that hour to turn off your busy executive life and so what might you learn?
You might learn that your organization is being attacked every day by "Spear Phishing" experts from the other side of the globe.  More importantly, the source of the attacks is by an organized cadre of criminal experts in social engineering and SQL injection.

You might learn that one of your employees has set up a Twitter account with an anonymous user name and identity.  The daily "Tweets" are telegraphing your corporate strategy to your competitors or leaking proprietary internal protected information about rogue co-workers behavior.

You might learn that the Commercial-Off-The-Shelf (COTS) sensor you utilize within your flagship transportation vehicle, is being exploited by a highly trained clandestine military unit from another country.

You might learn that a key manufacturing location is about to be surrounded by environmental activists who are planning to camp out on your entrance until their demands are met.
So what?

The question is necessary to get to the bottom line.  It helps to define the purpose for why you have these resources working with you.  The reason that they are working 24x7 to keep you and your organization even more aware and resilient.  Why they are converging on a conference room in Los Angeles after working all day to learn about new vulnerabilities?

Take the time this week to meet with them.  Ask them the question.  Listen to their answers.  You might be surprised at what you hear.  You will probably learn something new.  Work with them to improve the Operational Risk Management (ORM) capabilities and functions within the enterprise.

"If you want to Go Fast go alone.  If you want to Go Far, go together".
--African Proverb

15 April 2017

Insider Threat: Duty of Care in the Workplace...

The summer of 2017 is approaching and soon thereafter the world will view the new documentary film "Risk" by Laura Poitras, about Wikileaks founder Julian Assange.  This week in Washington, DC, the CIA characterized Wikileaks as a "non-state hostile intelligence service".

Almost the same day, another case of insider threat was unveiled by the US Attorney for the Southern District of New York.  The alleged theft of proprietary trading code for a trading platform from a financial services firm by a software engineer named Dmitry Sazonov will not be the last case in 2017.

The ongoing theft of trade secrets and proprietary data from both private organizations and our governments remains a global epidemic.  A tremendous amount of effort continues by Operational Risk Management professionals, to address the growing plague.  Insider Threat's as a whole and the theft of trade secrets, continues as a significant challenge for CISO's, Chief Privacy Officers and the Human Resources executives.

Whether the incident is the lone software engineer, the contractor analyst, or a disgruntled employee does not matter.  They all are motivated for different reasons to carry out their actions as a "Trusted Insider".  Mark Pomerleau explains that technology alone may not be the answer:

Insider threats have disclosed and improperly removed troves of sensitive information from government networks that compromise secrets and highly secretive security programs. While various technical and cyber-enabled monitoring tools have been applied to prevent such actions, the intelligence community’s top counterintelligence officer believes understanding the human element is the most important component.

“The mind of the insider threat: That is what I believe to be the critical component of stopping, if we can,” the individual that wants to be nefarious and do malicious behavior, said William Evanina, the national counterintelligence executive within the Office of the Director of National Intelligence.


All the technology and software will not be able to eliminate this kind of "Insider Threat" for continuous monitoring.  It is however a key component no different than any other layered-defense risk management system.  Sometimes, it just comes down to good management practices from one person to another.

The education necessary for mid-tier management is imperative, if this layer of defense in the enterprise is going to work effectively.  Observing first hand an fellow employees behavior in the workplace or after hours in social settings, could be the "Early Warning System" each organization has been seeking for decades.

The learning and education associated with elevating managements understanding and policy implications in the workplace around counterproductive work behaviors is vital.  A malicious insider who is trusted in the workplace environment may be there operating for years.  Yet what are some of the key areas of observable behaviors:
  • Production Deviance:  Poor attendance, poor quality of work, misuse of resources and time
  • Property Deviance:  Destruction of property, misuse of information and theft
  • Indirect Aggression:  Unsafe behaviors, politically deviant behaviors
  • Direct Aggression:  Inappropriate verbal or physical behavior
Source:  Assessing The Mind of the Malicious Insider  White Paper - Security Policy Reform Council - INSA - Insider Threat Subcommittee
"Introducing sophisticated new tools and effective monitoring immediately raises a host of questions that require further discussion to assess how best to incorporate them in Continuous Evaluation programs. These include how to balance privacy and security, assess the impact on workplace morale, determine the triggers for undertaking additional monitoring and action, and incorporate oversight and protections for civil liberties."
The 21st century organization with flexible work schedules, telecommuting, work from home policies and the utilization of cloud computing will accelerate the "Insider Threat".  The naive enterprise that perpetually operates without a comprehensive education and continuous learning program in place, does so at its own peril.

Simultaneously, the organization shall utilize the corporate governance tools known for years as the Office of Professional Responsibility, Employee Assistance Program (EAP) and other emerging capabilities such as Ginger.io.

You have an opportunity to provide your organization with the protection of your intellectual property and trade secrets, while synchronizing the privacy and civil liberties of your employees.  Wikileaks or some other entity will exist for years to come.  Your particular "Trusted Insider" will not be the last person to steal proprietary or classified information or be the perpetrator of workplace violence.

As a senior executive in your organization, your "TrustDecisions" will make the Duty of Care difference...

09 April 2017

Critical Infrastructure: Maritime Cyber Resilience...

The Maritime Cyber Resilience evolution continues in the United States.  Strategic ports for commerce and our Transportation Command (TRANSCOM) of the Department of Defense, are adapting to the threat.  The Critical Infrastructure Protection domains and the Operational Risk Management professionals are continuously on alert.

The resilience standards for protecting the Critical Infrastructure of U.S. ports and the Cyber domain, traditionally would fall to U.S. Homeland Security and then the United States Coast Guard (USCG).  TRANSCOM also has its own Cyber components that may interface with the seaport maritime infrastructure including our commercial ports.

There is significant collaboration that must be coordinated with commercial private sector carriers and companies:

Military Sealift Command (MSC) provides high-quality, efficient and cost-effective ocean transportation for the Department of Defense and other federal agencies during peacetime and war.

USTC will execute sealift movements through Military Sealift Command (MSC) and Surface Deployment and Distribution Command (SDDC). Planners within these organizations will work together to provide optimal transportation solutions that are cost efficient and operationally effective and are within policy and law.

  • Surface Deployment and Distribution Command (SDDC) provides commercial sealift for customers through Liner Service.
  • Charter vs. Liner Vs Organic: By policy USTRANSCOM must consider commercial assets before organic assets. Charter and Liner services are commercial methods of moving cargo with different benefits.
How vast is the Cyber landscape for the U.S. Coast Guard's mission regarding Homeland Security across the maritime facilities across the nation?
The U.S. Coast Guard (USCG) oversees approximately 800 waterfront facilities that, among other activities, transfer hazardous liquids between marine vessels and land-based pipelines, tanks or vehicles. These “maritime bulk liquid transfers” increasingly rely on computers to operate valves and pumps, monitor sensors, and perform many other vital safety and security functions. This makes the whole system more vulnerable to cybersecurity issues ranging from malware to human error, and is the reason behind a new voluntary cybersecurity guide for the industry.
 So what?

The current cyber threat environment for TRANSCOM is a parallel focus with the USCG, as they are both operating at commercial maritime facilities and seaports.  The single set of standards they rely on for establishing, maintaining and testing their respective Cyber Domain readiness, is the NIST Cybersecurity Framework:

Recognizing that the national and economic security of the United States depends on the reliable functioning of critical infrastructure, the President under the Executive Order "Improving Critical Infrastructure Cybersecurity" has directed NIST to work with stakeholders to develop a voluntary framework for reducing cyber risks to critical infrastructure. The Framework will consist of standards, guidelines, and best practices to promote the protection of critical infrastructure. The prioritized, flexible, repeatable, and cost-effective approach of the framework will help owners and operators of critical infrastructure to manage cybersecurity-related risk while protecting business confidentiality, individual privacy and civil liberties.

TRANSCOM and the USCG are both operating in maritime domains, in concert with private commercial enterprises.  The growing interdependent systems being utilized for cargo logistics, navigation and other computer automation systems, provides some insight into the vulnerability landscape from a Cyber perspective.

Still to this day, other Critical Infrastructure sectors that are far more advanced in their defense of their Cyber domains, are trying to increase their resilience.  The current nation state adversaries who are operating within the Financial and Commercial Facilities sector alone, gives us some degree of awareness on the magnitude of the current problem-set.

Utilizing the NIST standard across Critical Infrastructure sectors as the baseline is only the start.  Raising the bar of Cybersecurity Readiness and Defense across the maritime and seaport domains adds tremendous new challenges.

As the U.S. Department of Defense moves personnel, supplies and utilizes commercial port facilities they will be constantly interacting with private sector entities and assets they have little control over. The Cyber domain vulnerabilities that may occur with these commercial enterprises is unknown.  The U.S. Coast Guard does not regulate the commercial companies and their state of Cyber readiness directly:

American ports, terminals, ships, refineries, and support systems are vital components of our nation’s critical infrastructure, national security, and economy. Cyber attacks on industrial control systems could kill or injure workers, damage equipment, expose the public and the environment to harmful pollutants, and lead to extensive economic damage. The loss of ship and cargo scheduling systems could substantially slow cargo operations in ports, leading to backups across the transportation system. A less overt cyber attack could facilitate the smuggling of people, weapons of mass destruction, or other contraband into the country.

In short, there are as many potential avenues for cyber damage in the maritime sector as there are cyber systems. While only some cyber attack scenarios in the maritime sector could credibly lead to a Transportation Security Incident, we must identify and prioritize those risks, take this threat seriously, and work together to improve our defenses.


The Maritime Cyber Resilience challenges are similar to other Critical Infrastructure sectors, yet how mature is the collaboration with Defense, Homeland Security and Commercial Private Sector organizations?

01 April 2017

True North: A Decision to Trust...

When you awakened this morning did you immediately know your "True North"?  Are you heading in the direction of your passion in life?  How do you know when you are off course and need to correct your path before it is too late?

This metaphor for knowing and feeling whether you are on the right path for your passion, begins with a visual sign.  A star in the distance to keep you focused and on track.  A reminder.  You know the one I am talking about.  Maybe it's the magnet on your refrigerator.  Is it a person?  Is it a place?  Or just a 3M Post-It note, placed strategically at your desk, to keep you centered.

Your particular "True North" is what keeps you going every day.  At certain intervals however, course corrections are always necessary, yet you don't want to deviate too long away from your desired outcome.

Any Operational Risk "Professional" understands the true mission because somewhere along the path, they have encountered difficulties and significant hardships.  And they have adapted.  They have pivoted.  They have endured the negative emotions and counter productive environment, to survive another day.

Now, think about the most difficult time in your life and how you were able to navigate back to "True North".  How did you do it?  How were you able to stay on course?  This is how.  You made a series of "Trust Decisions".

You made a decision to trust someone, something or some direction to navigate towards your "True North".  Who is it?  What is it?  Where is it?  Perhaps more importantly, Why is it?

Whether you are heading in the right direction requires a perseverance and a belief.  It means that you will have many emotions as you travel forward in the hours, weeks, years and decades ahead.  You can expect that to be the case, no matter what happens.

As you navigate your path towards your "True North" you must reflect along the journey.  What have you learned?  Why is this important?  It is because of these lessons and the knowledge that you have learned, that will now make a difference and influence your next "Trust Decision".
  • A Decision to Trust incorporates data that comes from a network of sensors.  These points of data collection are important to the future of your survival.  They are where you must continue to improve, correct and test in order to be assured that they are operating effectively and as planned.
  • A Decision to Trust is a series of calculations, that involves the data you are collecting from sensors.  The calculations and formula is different for each node or mechanism, that you are utilizing to achieve the outcomes you seek.
  • A Decision to Trust becomes automated, once you have the highest assurances that you can rely on your sensors and believe in the calculations.
Once you have determined your course and are relying on your sensors to be accurate, discipline is the final quest.  What discipline do you follow?  This is where you may now have the greatest risk of failure.  The risk you deviate from your discipline.  You forget your "True North".

Your direction and your ability to reach your destination, will be ultimately determined by your discipline...

God speed!

27 March 2017

Privacy Law: Scanning the Legal Horizon...

As our new knowledge-based organizations begin the startup phase, the thought of all of the implications of collecting and storing information may be secondary to raising capital.  However, once you have the core team in place and the business begins to scale, maybe it is time to look over the horizon.

Once you have reached the point in your companies growth curve to consider the hiring of a CFO and even an outside "General Counsel", the regulatory engine must be established within the enterprise.  Today, even the CISO in any major business across the United States has been challenged by rapidly changing digital privacy laws the past two years.

Especially in California, the CalECPA went into effect January 1, 2016 and in general is focused on law enforcement:
The landmark California Electronic Communications Privacy Act bars any state law enforcement agency or other investigative entity from compelling a business to turn over any metadata or digital communications—including emails, texts, documents stored in the cloud—without a warrant. It also requires a warrant to track the location of electronic devices like mobile phones, or to search them.
The simple fact that a company is doing business in the State of California and has employees operating there, puts a significant set of requirements and compliance issues that are top of mind.  This is why you see technology-oriented companies who have their Headquarters based here, developing robust guides for working within federal and state privacy laws.

A "Chief Information Security Officer" is not only charged with protecting the data within a confidentiality, integrity and assurance framework, but also working in tandem with the General Counsel and a Chief Privacy Officer.  The standards and the laws have significant hurdles that also require prudent Operational Risk Management strategies.

Now take all of this into consideration as your begin to plan for implementing an "Insider Threat Program" (InTP) within your organization.  The addition of a Human Resources component, Chief Information Officer and even perhaps 3rd Party Cloud supply chain vendors will all be in play.

So What?

So what is the legal profession in California focused on these days?  Just take a look at the Agenda for a March 2017 event at Berkeley Law:

Cybersecurity Regulatory Enforcement

New regulators, new laws, and new norms are causing cybersecurity responsibilities to proliferate. This discussion will feature insights on how cybersecurity lawyers navigate the growing thicket of information security rules from the perspective of both companies pursued by the FTC and multinationals operating under different legal regimes. It will consider challenges posed by insider breaches and obligations arising from the General Data Protection Regulation.


Practitioners Panel

Privacy practitioners from leading law firms and major online companies will share insights on how to stay afloat in increasingly turbulent waters.

Privacy Award

BCLT is proud to bestow its annual Privacy Award this year on

Susan Freiwald, University of San Francisco Law School
Nicole Ozer, ACLU of California

in recognition of their leadership in securing passage of CalECPA, which establishes the “gold standard” of a judicial warrant for government access to communications, location data and other information about our daily lives.


Keynote: Too Close for Comfort – AI, Cloud Computing, and Privacy 

Recent advances in artificial intelligence, robots, and machine learning are enabled by big data, digital cameras, and cloud computing. These advances open an enormous Pandora’s box in terms of security and privacy. Groundbreaking AI researcher Ken Goldberg will present potential responses, such as a concept for “Respectful Cameras,” a privacy-preserving system for industrial automation. He will explain why claims of an impending “Singularity” are greatly exaggerated and will propose an alternative, “Multiplicity,” where diverse groups of humans work together with diverse groups of machines to innovate and to solve complex problems.

Government Access

With digital evidence central to an increasing number of criminal and foreign intelligence investigations, government demands for access seem to steadily increase. From varying perspectives, this panel will explore emerging issues in government access to data stored with third parties.

Artificial Intelligence and the Right to an Explanation

The General Data Protection Regulation requires that organizations explain to individuals the logic behind decisions rendered by algorithms. This policy is aligned with growing efforts in the machine learning community to improve the interpretability of outputs. This panel will examine a broad range of efforts to address interpretability and potential biases in complex algorithmic systems.

Consent and Contract under EU Data Protection Law


EU privacy regulation continues to have worldwide relevance, especially affecting U.S.-based companies. This session will examine how consumer data can continue to be collected and used given the different approaches in the EU and U.S. to consensual mechanisms for authorizing personal data processing.


The CISO and the entire team of Operational Risk Management professionals at your organization, should be monitoring and creating new strategies to protect the organization.  Scanning the legal horizon on what the new challenges are and how to prepare, is the sign of a sound business strategy.

19 March 2017

Startup Strategy: Opportunity of Digital Trust in a New Era...

The startup ecosystem of new ideas for SaaS platforms or mission based digital solutions are becoming evermore robust, in our growing economy.  As a result, Operational Risk professionals are more in demand to help new co-founders adapt to the legal, compliance and consumer transparency requirements, that will soon descend upon them.

It makes sense, that when you are starting a new company you first are focused on the product/mission and who the intended market or user will be.  Yet soon after this is defined and the "Go-to-Market" strategy is in place, there is a tremendous amount of Operational Risk design and implementation of internal capabilities, that will be required.  In just Social Media, here is just one example:
"As social networks continue to mature, they increasingly take on roles they may not have anticipated. Moderating graphic imagery and hate speech, working to address trolling and harassment, and dealing with dissemination of fake news puts companies like Facebook and Twitter in powerful societal positions. Now, Facebook has acknowledged yet another challenge: Keeping your data safe from surveillance. That’s harder than it may sound. When you post something publicly on a social network, anyone can view it—including law enforcement or federal agencies."
Since the dawn of the Internet, new startup companies have been developing algorithms and bots to scour the vast landscape of "data oceans" for relevant content.  As public Internet tools, databases and consumer-oriented web sites were developed for even Blogs (Blogger.com) such as this one, other companies were figuring out how to capture the data content in their searchable systems.

Years later, startups developed ways to develop the API as a new product-set, so that other companies could embed and utilize a set of data or capability and have it more integrated with a new set of functionality or service mission.  What is one company in this category focused on Twitter?  Gnip.com:
"PowerTrack provides customers with the ability to filter a data source’s full firehose, and only receive the data that they or their customers are interested in. This is accomplished by applying Gnip’s PowerTrack filtering language to match Tweets based on a wide variety of attributes, including user attributes, geo-location, language, and many others. Using PowerTrack rules to filter a data source ensures that customers receive all of the data, and only the data they need for your app."
So what?

If you are a startup company that is planning on a pledge to your customers to "Keeping your data safe from surveillance," just as the juggernaut Facebook is also currently doing, you have a tremendous amount of work and new processes/systems to get in place.  You are embarking not only on the steep growth curve of adding new customers and revenue; you are simultaneously under the mandate to help achieve a higher level of "Digital Trust" with those same customers.

Developing the policy alone is only the start.  Here is how Twitter is addressing it:

"To be clear: We prohibit developers using the Public APIs and Gnip data products from allowing law enforcement — or any other entity — to use Twitter data for surveillance purposes. Period. The fact that our Public APIs and Gnip data products provide information that people choose to share publicly does not change our policies in this area. And if developers violate our policies, we will take appropriate action, which can include suspension and termination of access to Twitter’s Public APIs and data products."

How Facebook and Twitter and Snapchat or LinkedIn and all of the hundreds of Social Media companies will scale up enforcement, is now the big question.  Maybe they have the deep pockets and resources to build and operate their "Digital Trust" business unit.  What about the new startup with only 6 or 7 figures in the bank from a seed or even "A" round of funding?

The policy implications and new federal laws being drafted in the United States and the European Union may be good indicators of where the future requirements will be defined for a new startup.  In the EU this week, the G20 finance ministers are converging on the topic of "Cyber Crime" soon after a recent indictment:
"Two intelligence agents from Russia, another G20 member, with masterminding the 2014 theft of 500 million Yahoo accounts. The indictment was the first time U.S. authorities have criminally charged Russian spies for cyber offences including for computer fraud, economic espionage, theft of trade secrets, and wire fraud."
How will the new startup who is focused on addressing transparency, privacy, and surveillance now "Enable Digital Trust of  Global Enterprises."  Here is a glimpse from the latest PwC CEO Survey:

"Yet, if forfeiting people’s trust is a sure-fire route to failure, earning their trust is the single biggest enabler of success. As an example, the progression from assisted to augmented to autonomous intelligence depends on how much consumers and regulators trust machines to operate on their own. That, in turn, depends on whether those who create the machines have the right risk and governance structures, the means to verify and validate their claims independently and the mechanisms to engage effectively with stakeholders."

"In short, trust is an opportunity, not just a risk. Many CEOs recognise as much: 64% think the way their firm manages data will be a differentiating factor in future. These CEOs know that prioritising the human experience in a virtual world entails treating customers with integrity."


Welcome to the new era of achieving Digital Trust...

12 March 2017

Vault 7: Adapt to Live Another Day...

When you spend enough time in any austere environment, you begin to respect it's abilities to change rapidly.  You begin to respect the changing natural forces and how these new potential threats could become a new Operational Risk in just minutes.  The decisions that you make in the next few seconds, could mean a positive outcome or a significant catastrophe.

Will you turn right or go left?  Will you accelerate or slow down?  Will you ascend or descend?  These decisions that you make in your quest to adapt to your changing austere environment will forever be remembered.  Whether they are stored in the synapses of the brain or the log files of an autonomous system executing code, the trust decision is evident.

How long has it been since you really took a deep look at your decisions the past minute, hour or day?  This analysis of the evident decisions made and the environment that you are operating in will forever allow for growth or death.

Systems thinking and the continuous learning of a changing environment can happen at 12,000 feet above sea level at minus 10 degrees, or within the climate-controlled data centers or corporate offices of your global enterprise.  What are you doing today to help achieve new levels of trust, in order to survive another day?

Why is it that so many individuals are surprised when they get a call from their CxO or even corporate counsel that sounds like this?  "It looks like our Intellectual Property or Trade Secrets, are now in the hands of our competition".  "Our enterprise is encountering significant new risks to our ongoing operations and we must adapt immediately'.
Introduction
Just as American and European critical infrastructure executives were beginning to wrap their minds around the devastation of the Office of Personnel Management, ransomware erupted onto the scene. We then experienced concentrated DDoS attacks such as the Mirai botnet attack on Dyn, which enabled a quantum leap for cyber criminals of even the most novice of technical aptitude to wreak havoc on targeted organizations at the click of a button or for less than one bitcoin. Unfortunately, adversaries continue to evolve, and cyber defense remains a reactionary culture. Numerous, persistent and adaptive, cyber-adversaries can more easily, remotely and locally besiege critical infrastructure systems, than information security personnel can repel the incessant barrage of multi-vector attacks. Now, all techno-forensic indicators suggest that an under-discussed cyber-kinetic attack vector will ubiquitously permeate all critical infrastructure sectors due to a dearth of layered bleeding-edge military grade cyber security solutions. Unless organizations act immediately, in 2017 The Insider Threat Epidemic Begins.
Some people are surprised.  Yet it is the small team of "Operational Risk Professionals" in your enterprise, that have been continuously training, operating in clandestine and unknown environments and learning each day, for this moment.  They are not surprised.  They are the people who have designed their operations and systems to be resilient, to endure austere environments and to adapt to live another day.

Seek out these people in your organization.  Find the expert individuals in each of the departments or business units, that also interface with your external environment and supply chain.  Now look inside and in the mirror.  Where are the vulnerabilities inside?  How can you adapt your operations to create trust with employees and simultaneously make your organization more resilient?
Take the “Vault 7” CIA data Wikileaks released this week. Assuming it is legitimate, it originated from a network that presumably has a very small attack surface. Wikileaks expressly claims that the data is from “an isolated, high-security network situated inside the CIA’s Center for Cyber Intelligence in Langley, Virgina,” and experts agree that seems likely. And knowing that CIA networks are probably secure and defended supports the notion that the the data was either leaked by someone with inside access, or stolen by a well-resourced hacking group. It’s far less likely that a random low-level spammer could have just casually happened upon a way in.
 Build digital trust in your organization by better understanding the entire surface for potential attacks.  Analyze the rules that are in place now and how they might need to be changed according to the continuously changing environment you operate in.

Finally, adapt to live another day...