How do you protect information in the event of an Event? Is this part of your business continuity plan? You do have a business continuity plan, right? Do you have a process to safeguard information you will need to resume operation?
“Second Black Box Eludes Search Teams,” The Wall Street Journal, November 3, 2018 A6. Divers are still searching for the cockpit voice recorder following the crash of Lion Air flight 610 in Indonesia.
Planes carry two “black boxes,” one a flight data recorder (which captures a lot of equipment operating data) and the other a cockpit voice recorder (which captures conversation in the cockpit). The information on these two boxes (which are actually neon orange) is used to determine the cause of a crash.
What information does your company generate that you would need to run your business following an “Event,” such as a computer crash or a hurricane, or whatever? Is that part of your normal operating policies and procedures? If you can’t get to that information, can you restart or run your business?
Is this an Information point (protecting information) , or a Governance point (having processes and procedures to protect mission-critical information), or a Compliance with policies and procedures?
Filed under Access, Business Case, Collection, Controls, Corporation, Duty, Governance, Information, Internal controls, Oversight, Protect, Protect assets, Risk, Use, Value
“Data Curbs Put Facebook in Bind,” The Wall Street Journal, July 31, 2018 B4. The GDPR in Europe places new restrictions on Facebook’s business model. The new rules make it harder for Facebook to get advertising revenue based on the views by users of the platform.
How well does your company prepare for changes in the law? Is this on your risk matrix?
What happens to your business if you or your customers can’t get to the Internet?
“Visa Hit by Outrage In Parts of Europe,” The Wall Street Journal, June 2, 2018 B12. Users of Visa cards in Europe couldn’t use their cards on Friday as the result of a hardware failure.
Are you prepared for a hardware failure that prevents your customers from reaching you? Is this an aspect of information governance? Business continuity planning? Both?
You make some promises, or strong indications, to a star performer that he or she is so above average, next year you will get ___ a year early. [Fill in the blank]
How do you handle a change in direction?
“Goldman’s Rising Stars Told to Hold,” The Wall Street Journal, May 26, 2018 B9. Two years ago, a group of high-potential employees were told they were on the fast track and would get promoted before the rest of their class. Now they are told there is no fast track this year.
How do you handle it when you have to tell your star performer that she/he’s not going to get what you told them they were going to get? Have you just put your crown jewels into play? How do you rebuild trust and confidence in your best and brightest?
Is this Information or Governance or just bad management? Does it matter whether you told them in writing or not? Is that a risk that was considered?
“New EU Rule Puts Scare Into Websites,” The Wall Street Journal, May 26, 2018 B4. US websites block access by people in the EU to avoid breach of new GPDR.
This raises several interesting questions.
- What’s the risk that your website collects or stores information in violation of the General Data Protection Regulation?
- Is it better to cut off service to people in the EU rather than to take the risk that you don’t comply with EU privacy legislation?
- Will this open up a new market for Google-like and Facebook-like European competitors?
- How will the users in the EU react?
- Just how hard is it to comply with the GDPR? You write a policy and take some internal steps to control your use of consumer information.
- Is this Y2K revisited?
- Is this Information, Governance, or Compliance? A combination of some all of those?
Filed under Access, Business Case, Compliance, Compliance (General), Controls, Corporation, Duty, Governance, Government, Interconnections, Internal controls, IT, New Implications, Oversight, Privacy, Protect assets, Risk, Technology
What happens to compliance when the CEO and her boyfriend collaborate to create a culture of secrecy and fear?
“Partners in Blood,” The Wall Street Journal, May 19, 2018 C1. Reports from the trenches at Theranos, which said it was able to run a range of tests from a few drops of blood; it couldn’t. SEC charges company with fraud, and investors lose millions.
While the implications of a relationship of the CEO goes to Governance, are there also links to Compliance and Information? What impact did the culture have on the company’s compliance? How do investors know about the nature of a CEO’s personal relationships leaking into the corporate environment?
Who should have seen this and reported it to someone? Why didn’t the directors smell a rat?
Filed under Board, Compliance, Culture, Culture, Directors, Duty, Employees, Governance, Oversight, Oversight, Risk, Supervision, To report
“Wells Nears $1 Billion Settlement,” The Wall Street Journal, April 20, 2018 B1.
Wells Fargo is about to be (has been) fined close to $1 billion for irregularities regarding auto loans, auto insurance, and mortgage loans. This is the civil side. This is in addition to the $185 million for the account cramming scandal in 2016, where the bank opened new accounts and credit cards that consumers did not request. The Chief Risk Officer is also retiring.
Once again, the shareholders pay mightily for the sins of (mis-)management.
“In a First, U.S. Firms Reveal Workers’ Pay Gap With CEO,” The Wall Street Journal, March 12, 2018 A1. US law requires disclosure of comparison of CEO’s pay to that of the median worker in the CEO’s company.
Noodle on this for a minute. Who “owns” the information as to what you earn? Do you? If so, you could, if you wanted to, publish that information or post it on your door. Does your employer encourage you not to do that? Who’s hiding what from whom? Would you be interested to learn that Joe in the next cubicle is paid 10% more than you are? Is his job or his qualifications that much different? Why don’t companies post this information by position? Why are you nervous about posting your salary? Are you embarrassed?
I am not sure what to say about the Nunes memo about the DOJ and the FBI and the FISA court, and classified information and governance and compliance. Too political to be educational.
So, the right-hand news item instead. “Fed Limits Wells Fargo Growth, Replaces Directors,” The Wall Street Journal, February 3, 2018 A1. Following a pretty bad year or two, following the customer cramming schedule or the auto insurance. A former CEO. Lower bonuses. Now the government takes control of a large bank and replaces the directors. Restricts the bank’s future growth. A 6% stock value drop, before this week’s really bad sell-off. Cost: $300-400 million. Government says, “We cannot tolerate pervasive and persistent misconduct at any bank ….”
What’s the value of compliance? Is it the possible loss of your ability to control your company? Is this a lesson for directors, in that they may lose their positions (but they don’t have to refund their fees)(yet- the derivative suits are coming soon). They didn’t even do that to BP! The Chief Risk Officer is also retiring later this year.
Business case for compliance or better risk management? For knowing what’s going on in your company? Not sure what the lesson is for the shareholders.
Filed under Board, Business Case, Compliance, Compliance, Compliance Verification, Controls, Corporation, Directors, Duty, Duty of Care, Employees, Governance, Inform market, Inform shareholders, Internal controls, Oversight, Oversight, Protect assets, Risk, Risk Assessment, Risk assessment, Supervision, To report
Cybersecurity involves protecting the enterprise from internal or external attack and responding after the enterprise has been attacked. How do you ensure your business continues to operate if its cybersecurity is breached? It’s not just sending notices to affected customers and paying for credit watches.
“Banks Create Cyber Doomsday System,” The Wall Street Journal, December 4, 2017 B1. By requiring banks and credit unions to back up their data so that operations can be restored after a breach. This also protects confidence in the overall banking system.
Do you have a business continuity plan? Does it address how you will access your critical information so that you can continue to operate?
What’s surprising is that this is newsworthy.
Filed under Access, Board, Business Case, Business Continuity, Controls, Corporation, Directors, Duty, Duty of Care, Governance, Information, Interconnections, Internal controls, IT, Operations, Oversight, Protect assets, Protect information assets, Security, Value