Category Archives: Risk

Do your customers have an alternative?

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?

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Filed under Access, Business Continuity, Interconnections, IT, Operations, Risk

Bait and switch?

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?

 

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Filed under Definition, Duty of Care, Governance, Information, Protect assets, Risk, Who is in charge?

WWW

“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.

  1. What’s the risk that your website collects or stores information in violation of the General Data Protection Regulation?
  2. 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?
  3. Will this open up a new market for Google-like and Facebook-like European competitors?
  4. How will the users in the EU react?
  5. 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.
  6. Is this Y2K revisited?
  7. Is this Information, Governance, or Compliance?  A combination of some all of those?

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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

Sniff test

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?

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Filed under Board, Compliance, Culture, Culture, Directors, Duty, Employees, Governance, Oversight, Oversight, Risk, Supervision, To report

Costly

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.

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Filed under Compliance (General), Culture, Governance, Risk, Risk assessment, Supervision

Lessons learned?

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.

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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

Drafts

A fascinating area for exploration is the drafts that led to the final version.  The dates, the wording, the recipients.  Why do people keep drafts?  Just because?

“Comey Originally Tougher On Clinton, The Wall Street Journal, November 7, 2017 A5.  A Republican Senator discloses that Comey’s early draft of the exoneration document used the language “grossly negligent,” the statutory test.

I’ve referred to July 5, 2016 as the Day that Information Governance Died.  That’s when the Director of the FBI announced his decision not to prosecute someone who had routinely violated the rules on handling secret documents, because “no reasonable prosecutor would bring charges.”  Not to get into the politics of things, but how can you argue that following the rules is required when the Secretary of State isn’t held to the standards that apply to a Navy seaman?

That being said, why do people hold on to drafts?  Because it’s easy?  Or because it’s hard to get rid of them?  There is seldom a reason to retain them beyond when the document is final.  Maybe a phrase or a paragraph.  But the entire document?  How can we convince people not to keep drafts?

 

 

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Filed under Compliance, Controls, Corporation, Discovery, Duty, Employees, Governance, Internal controls, Legal, Records Management, Risk