Category Archives: Protect

Catching up again, part 2

Continuing from https://infogovnuggets.com/2019/01/04/catching-up-again/

  1. Pot calling the kettle black

    “Comey Tells House Panel He Suspected Giuliani Was Leaking FBI Information to Media,” The Wall Street Journal, December 10, 2018.  Former FBI Director Comey, who admitted to leaking information to a reporter through a law school professor, complains that someone else did it, too.

  2. Yes, we have no privacy

    “Thieves Can Now Nab Your Data in a Few Minutes for a Few Bucks,” The Wall Street Journal, December 10, 2018.  Following the series of major hacks of privacy data (e.g., Marriott, LinkedIn, Equifax, and Yahoo), “Every American person should assume all of their data is out there,” said one FBI agent.  Comforting.

  3. Duty to report

    “New Report Shows Olympics Executives Concealed Knowledge of Nassar Allegations,” The Wall Street Journal, December 11, 2018.  Executives knew information about sexual abuse allegations, and failed to report.  To whom did they breach a duty?

  4. Interesting intersection of the right to petition the government and your right to privacy

    “U.S. Investigating Fake Comments on ‘Net Neutrality,’” The Wall Street Journal, December 11, 2018. “Earlier this year, the FCC said it would upgrade its website to try to prevent fakery. … Several federal agencies warn that it is a felony to send falsified comments to the federal government when posting on websites soliciting opinions on federal rulemaking.”  What if the comments were anonymous?

  5. Lying or overspending on your expense account can get you canned

    “Under Armour Ousts Two Executives After Review of Expenses,” The Wall Street Journal, December 11, 2018. Complying with company policy and procedures is sort of kind of like a job requirement.  Even if you signed Jordan Spieth.  But how were they to know how much was too much?

  6. Weakest link?

    “Amazon, Amid Crackdown on Seller Scams, Fires Employees Over Data Leak,” The Wall Street Journal, December 11, 2018.  Employees bribed for access to inside information.  What’s your information worth to you?  To the briber?  To the (former) employee?  Do you have a policy against taking bribes?

  7. Collateral impact

    “Nissan-Renault Scandal Shows It’s Hard to Keep Car Alliances On Track,” The Wall Street Journal, December 12, 2018.  A scandal at your business partner can affect your company’s relationships.  Is that Governance?

  8. How do you deal with rumors?  Are they “information,” too?

    “Super Micro Finds No Malicious Hardware in Motherboards,” The Wall Street Journal, December 12, 2018.  This contradicts a prior report from Bloomberg.  How do you govern other sources of information?  Is using a trusted third party to investigate just standard crisis management planning?

  9. Should Compliance be more congenial?

    “Banks Get Kinder, Gentler Treatment Under Trump,” The Wall Street Journal, December 13, 2018.  Regulators are urged to be more collegial with the banks they regulate.  Is that better “Governance,” in the short term or in the long term?

  10. What does it say?

    “Renault Sticks With Carlos Ghosn as Internal Probe Finds No Illegality,” The Wall Street Journal, December 13, 2018.  What does it say to the rank-and-file when the Chairman gets arrested?  And when he’s thereafter kept in place?  The Board may have some explaining to do.

  11. What can your employer do with your information?

    “U.S. Companies Asked to Disclose More About Their Workers,” The Wall Street Journal, December 14, 2018.  Pension funds ask employers to disclose more information than the SEC currently requires.  Whose decision is that?  When and how can you object?

  12. Watch your contractors

    “Chinese Hackers Breach U.S. Navy Contractors,” The Wall Street Journal, December 15, 2018.  What’s this information worth, both to the US and to China?  How much do you look at the security at your vendors who process or create information for you? Are  they a weaker link than your employees? (See item 6, above.)

  13. Information and Governance and Compliance

    “PG&E Falsified Gas Safety Records, California Claims,” The Wall Street Journal, December 15, 2018.  From the explosion in San Bruno in 2010 (after which PG&E couldn’t find a bunch of inspection records relating to hundreds of miles of its pipelines) to more recent claims about fudging the records on pipeline locations, PG&E has had this problem for awhile.  For now, these are just allegations.  But what impact on every claim made against the company, and every claim made by it?  If they falsify safety records, do they falsify bills, too? “The [state regulator] last month expanded a continuing probe of PG&E’s safety practices and said it would explore the way the company is structured and managed.”  There seems to be a link between record-keeping and management and compliance and culture.

  14. Facebook, again

    “Facebook Bug Potentially Exposed Unshared Photos of Up 6.8 Million Users,” The Wall Street Journal, December 15, 2018.  One almost gets the idea that protecting your privacy is not a high priority for them.

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Coming up to speed

Marriott Says Starwood Data Breach Affects Up to 500 Million People,” The Wall Street Journal, November 30, 2018 (online).  Data breach potentially affecting passports and credit cards of as many as 500 million guests at Marriott’s Starwood properties, which were acquired in 2016.  They knew about this in September, but reflects a breach that may go back to 2014.

So, two years after an acquisition, the target’s information security practices blow up in the acquiror’s face.  What does that say about the acquiror’s duty to integrate the data practices and controls around information protection?

Does your M&A team think about information governance issues?  Is that an identified risk, with an identified (and owned) action plan?  Did the Board identify this as a risk?  What the value of this information considered part of the transaction value?  How was that reflected?

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Technology controls

“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?

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Crisis information

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?

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Your vendors

This blog focuses more on the intersection of Governance, Information, and Compliance than on the implications of information security.  But the topics do overlap.

So, what controls do you have in place to prevent from someone accessing your computer and changing the information there or, as important, changing how your computer operates?  That’s an identified risk, right?

“Russia Hacks Its Way Into U.S. Utilities,” The Wall Street Journal, July 24, 2018 A3.  Russian hackers gain access to sensitive information at utilities by compromising the utilities’ vendors and their access to the utilities’ systems.  Can the hackers take control of those systems or shut them down?

Does anyone recall the name of the HVAC contractor that was the entry point for the Target hack several years ago?  Contractors can be a massive IT security risk.

Is this part of Information Governance?

What duties do the directors of the utilities have to make sure processes are in place to prevent third parties from causing harm by accessing the company’s information and process control systems?  And to control the third parties who do have that access?  Is there a process?

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Verrry interesting

“Europe’s Privacy Law Fails to Stoke Demand for Cyber Insurance,” The Wall Street Journal, June 21, 2018 B10.  Companies aren’t buying as much privacy insurance as people thought.

Certainly, in the wake of the GDPR rollout, the risk of a privacy law violation has increased.  Apparently companies think that they have adequate controls in place, and don’t need the protection of insurance to backstop their controls.  Insurance is a mitigation in case your controls aren’t totally effective.

Are these companies doing the same with other risks to other assets?  Or is you private data somehow different?

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Inside job

“Tesla Accuses Former Employee of ‘Sabotage,'” The Wall Street Journal, June 21, 2018 B3. Did  a former employee hack Tesla’s manufacturing software and trade secrets and transfer information outside the company?  Was this for convenience, or was it theft?  Or to give to the press?

Do you have adequate controls to prevent this?  Or to discover it?  Who’s responsible if your controls fail?

Will the directors or senior officers be punished?  Did they fail in their obligations to protect the corporation’s assets?  Or is it just the shareholders who pay?  And pay, and pay.

 

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Happy Birthday!

Vendors with whom you deal can (and do) capture lots of information about you.  They use that information.  Hopefully to improve customer service.  Can they disclose what they know to others?  What if your traveling companions don’t know it’s your birthday because you don’t want them to know?

“What  the Airline Knows About The Guy in Seat 12A,” The Wall Street Journal, June 20, 2018 A11.  What information on you do airlines collect and how do they use it?

If the information is correct and used positively, that’s one thing.  What if it’s wrong, or used negatively?  What if it leaks?  What if it’s sold?

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Another ½ billion

This may appear to be more a straight compliance piece than an information governance piece, but consider that the officers and directors didn’t know or didn’t report things that they should have known about.  Truth or consequences?

“Wells Fargo Reaches Settlement In Lawsuit,” The Wall Street Journal, May 5, 2018 B10. Tentative settlement in suit alleging certain “current and former officers and directors of the bank had made false statements” affecting the stock price between 2014 and 2016.

The final paragraph of the article says,

The bank said Friday that it “denies the claims and allegations in the action and entered into the agreement in principle to avoid the cost and disruption of further litigation.”

One pauses to wonder if the current shareholders agree, it being their $480 million being spent to resolve the lawsuit, not the $480 million of said certain current and former officers and directors.  This is on top of the $1 billion fine paid last month.  Hopefully, the current and former shareholders will get some of the $480 million, less legal fees.

Telling fibs in connection with a company’s stock price can be real expensive for some one.  Not knowing about abusive sales practices is about the same as lying.  And how can you deny something yet still pay $480 million?  Who are they trying to fool this time?  At least now they can post nice ads on TV, claiming a re-invention.  Has the culture problem been fixed?

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Willie Sutton?

Willie Sutton (a famous bank robber) was reportedly asked, “Why do you rob banks?” He reportedly said, “Because that’s where the money is.” https://www.snopes.com/quotes/sutton.asp

“Hackers Plunder Crypto Exchange,” The Wall Street Journal, January 27, 2018 B5. More than $500 million in credits hacked from the Coincheck site in Japan.  One assumes virtual banks are easier to rob than brick and mortar banks.

This is a concrete example of the cost of a cyber breach.  But it also follows on from an earlier post (Law School Exam Question) equating cash money and information, in terms of value.

If businesses (including the Board of Directors) treated information assets as cash, and managing, protecting, and controlling the organization’s information as currency, would that be “information governance”?  Why do they handle information assets differently?  Why should the Board and the officers get a pass on this?  The shareholders certainly don’t.

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