Category Archives: Third parties

When is a record no longer a record?

If you are looking to invest, it would be nice to know if the broker who has been recommended to you has a history of complaints by his/her customers or employers.  If you are the prospective broker, it would be good to be able to present a clean record, even if your record isn’t clean.

“Brokers Purge Their Records,” The Wall Street Journal, November 19, 2018 B1. Brokers can request that complaints be expunged from the records of the industry-funded regulator.  So, were you to ask you would be told there’s no record.

So, what is a clean record worth, when a dirty record can be so easily laundered?  I guess there may be multiple definitions of “record,” one of which is documentation of a business activity or decision, and the other of which is a conviction.

On the internet, no one knows you’re a dog.

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Filed under Access, Accuracy, Controls, Definition, Information, Records Management, Third parties, Value

Governance?

Who governs access to the White House?  The Executive or the Judiciary?

“Judge Grants CNN’s Press-Pass Motion,” The Wall Street Journal, November 17, 2018 A3.  Reporter’s due process rights “appear to have been violated” when his access to the White House itself is restricted.

Who controls access to your building?  To your floor?  To your office?  To your desk?  To your computer?  To your company’s information?

How do they do it?

In the absence of a written rule, who governs what behavior is permitted in a press briefing within the White House?  The White House?  The “press corps”?  The courts?  The Secret Service?

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Filed under Access, Controls, Culture, Duty, Governance, Government, Internal controls, Third parties, Who is in charge?

Another one

“UC System is Sued for Data On Admissions,” The Wall Street Journal, November 16, 2018 A2.  Is the state university using race inappropriately in making admissions decisions?

The government has different obligations with respect to information than a private company.  Government also collects a lot of information.  What controls are in place to allow and to prevent the disclosure of this information?  What about for non-core activities, like running the state’s university system?

 

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Filed under Access, Collect, Compliance, Compliance, Controls, Duty, Governance, Government, Internal controls, Management, Third parties, To report, Use

External governance

“Rebuke at Wells Shows Clash,” The Wall Street Journal, November 15, 2018 B1.  Chief administrative officer (and former head of HR) at Wells placed on leave after the Office of the Comptroller of the Currency criticizes the oversight that she and the bank’s chief auditor provided.

If your company interacts with government regulators (and whose doesn’t?), is the government effectively a part of your governance structure?  Or is government a separate component of Governance, whether that is Compliance Governance or Information Governance?  Or just “Governance”?

And what does it say about communications when the government holds up a senior official for poor oversight?  What about the board?  Highly visible to the worker bees.

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Filed under Board, Communications, Compliance, Compliance, Compliance (General), Controls, Corporation, Duty, Employees, Governance, Government, Internal controls, Management, Oversight, Oversight, Third parties, To report

Very interesting

“Beware the ‘Free’ Internet,” The Wall Street Journal, November 15, 2018 A2.  How much money do Facebook, Twitter, and Google get from allowing others to access you based on your data?

The article makes an interesting comparison to Wikipedia, where a large amount of information is made available for free, without advertising.  That’s truly free.  As opposed to social media.

How much is your data worth?  To you?  To Google?  Do you agree with the implicit bargain, whereby you give use of your information in return for cat videos and an endless stream of ads?

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Filed under Access, Collect, Controls, Information, Internal controls, Management, Ownership, Third parties, Use, Value

Access

“CNN Sues the White House, Seeks Return of Press Pass,” The Wall Street Journal, November 14, 2018 A3.  Can the White House refuse to let in a member of the press into the White House for being rude?

Avoid for now the political implications of this, and what the First Amendment and the Fifth Amendment provide.  Think instead about who can deny a single individual access to information, while providing access to 190 other people.

Who is entitled to access information in your company?  What controls are in place to make sure that people who shouldn’t have access don’t get access?  Who determines what those controls are?  Who enforces them?  Is part of this culture?

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Filed under Access, Compliance (General), Controls, Culture, Duty, Governance, Government, Internal controls, Policy, Third parties, Uncategorized

Where’s Rosemary Woods?

“Trudeau Says Canadians Heard Khashoggi Tapes,” The Wall Street Journal, November 13, 2018 A7. Canadian intelligence officials hear audio tapes related to killing.

One assumes that this is a tape of some conversation picked up by intelligence folks after the killing, and not a recording of the killing itself.  Unless someone wanted to have proof for the boss.  Perhaps intelligence agencies spy on other governments or phone calls.

Often, people think information governance is all about the written word.  But the spoken word is information, too, whether it is recorded or not.  It’s just a problem of proof.  Is someone listening or taping your conversation?  Would it matter?

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Filed under Access, Accuracy, Communications, Controls, Definition, Duty, Governance, Government, Information, Internal controls, Risk assessment, Security, Third parties