“Wells Fargo Technology Under Scrutiny,” The Wall Street Journal, November 8, 2018 B11. Questions being raised about the technology the bank uses for cybersecurity and risk management.
Do you have the right technology to effectuate the controls you have placed around information? Will your regulators agree? If you are already on the regulator’s radar screen, will your controls measure up?
Filed under Controls, Corporation, Duty, Governance, Internal controls, IT, Oversight, Protect, Protect assets, Risk assessment, Security, Technology
I’m a bit of a knowledge management wonk, having been involved in the then-nascent KM movement within the inhouse legal community in the early 2000s. But there can be too much sharing.
“Sinclair Settles With U.S. on Ad-Sales Data,” The Wall Street Journal, November 8, 2018 B2. A media group settles lawsuit over alleged sharing of information among television station owners, that may have led to higher advertising rates.
An interesting side note is that this all came to light when Sinclair proposed to buy another company and had to undergo a government investigation.
Are there restrictions on how much information can be shared between and among competitors? Yes. They are call “antitrust laws.” And is there a risk of making a deal that subjects you to government scrutiny? Yes. The may discover all manner of minor and major sins.
Filed under Access, Communications, Compliance, Compliance (General), Controls, Corporation, Discovery, Duty, Governance, Information, Internal controls, Knowledge Management, Oversight
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
Hard to believe that people are still tripping over emails.
“Emails Raise Doubts on FBI Plan,” The Wall Street Journal, November 3, 2018 A3. Emails surface contradicting White House claims that moving the FBI from Pennsylvania Avenue in Washington D.C. (as proposed by the prior administration) would cost more than leaving it where it is (down the street from the Department of Justice and across the street from the Trump Hotel).
Perhaps there were “soft costs” involved in the move than weren’t considered, or there were other reasons for not moving the FBI from its current location, notwithstanding the higher cost. But it is embarrassing when emails coming to a different conclusion are discovered.
How transparent is your decision-making process? Do you allow for some contrary information in your final decision? Is that proactive information management of negative information? Do you have a policy or a procedure on this? Should you?
Have you ever misused your company credit card? How about used a company asset for your personal business?
“Gulfport CEO Exits Following Review,” The Wall Street Journal, November 2, 2018 B2. CEO resigns after investigation into his use of his company credit card (he had paid the charges back, eventually, without interest) and the company plane.
On departure, he gets $400,000 and 6 months of health care coverage. I don’t know whether that’s better than nothing.
The ground troops learn from their “betters.” Seeing the CEO get canned for policy violations firms up the perception of the seriousness with which the company treats violations of policy or procedure. More so than a ground troop getting canned.
Does your company publicize these stories?
“U.S. Charges Agents Of China Hacked Aviation Firms,” The Wall Street Journal, November 1, 2018 B4. Agents of the Chinese government indicted for trying to steal airline industry technology.
This is getting to be rather routine. One part of this is the value of Information, and the importance of information security. One part of this is Compliance, of course, as the US government is trying to protect the US information assets (although the company at issue probably had some responsibility for this as well, as well as their board of directors). And, of course, Governance, as the US government is prosecuting.
We all know the business case for cyber-security.
Filed under Access, Compliance, Compliance (General), Controls, Corporation, Duty, Duty of Care, Governance, Government, Information, Interconnections, Internal controls, IT, Oversight, Protect assets, Security, Third parties
What does it say when you try too hard to “manage” the information that gets out? Do you have the necessary “control” of that information? When you try to “control” it, what does it say about you when the information gets out anyway?
This sounds like “the risk of selectively releasing information.”
“Turkey Slams Saudis Over Lack of Clarity About Slain Journalist’s Body,” The Wall Street Journal, November 1, 2018 A9. Changing stories on the death of Jamal Khashoggi.
Apparently, there are international norms on what you need to say and how you need to say it, even if it information concerns events within a consulate. Was disclosure legally required? Maybe not, at least legally. But when you do disclose, it’s a good idea to do so honestly. Especially if someone else gets the information.
Filed under Accuracy, Communications, Compliance, Controls, Culture, Duty, Governance, Government, Information, Internal controls, To report