Dealing with Privacy, Security and IT. And trying to build bridges between these domains.
Monday, October 14, 2013
Robert's Law of security and technology progress
And finally within the last month (as of this is being written) the fingerprint recognition capability within the new iOS 7 had it’s security questioned. The new capability allows anyone with a new Iphone 5S
Labels:
Apple,
data breach,
Dropbox,
Ios,
proactive,
reactive,
RFID,
Security,
security by design
Tuesday, July 9, 2013
Security/Privacy Personnel, should they be the same?
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I have been on the peripheral of the discussion about Privacy and Security for awhile. The debate is concerning how Privacy personnel are not familiar with IT security process. And I believe its time to take the bull by the tail and face the situation, so to speak.
My thesis is that there needs to be a concerted effort to develop a liaison group involving people that feel comfortable in both areas of Privacy and IT Security. These people should understand how data is used within the IT, and what expectations Privacy places on the organization.
SO let’s explore
In the vast majority of enterprises, (those that have a IT department and also are concerned by privacy, as all companies should be) there are Privacy officers that deal solely in the Privacy realm (Privacy policy, governance etc) and the IT personnel whose function it is to enhance/maintain/deploy process to Secure the network assets from the 'bad guy'
But before we delve into this much further, let’s explore some of the foundations of these two organizations.
Privacy requirements come from various requirements, regulations, laws. They are formulated/created, either by gov't or professional organizations. Examples include: the PCI DSS, SOX, GLBA, PIPEDA, EU Directive, to name but a few.
These regulations/laws, for the most part are drafted by lawyers, civil servants, professional committees. I transgress with a quick joke. What is a camel? A horse designed by a committee.
The point is that, as written, these regulations are not written for the 'common man'. They deal with the legal aspects of privacy and as such, written in 'legalize'. So to be able to interpret them, create processes to address them, and ensure compliance with the same, it requires individuals that can understand those same rules. That is, one with expertise in the legal and/or regulator profession.
Security comes from the technical world, the idea of what kind of security appliances are needed to monitor/secure the systems/network/infrastructure that are in place within the organization. The understanding of networking protocols, threats and vulnerabilities etc. needs someone who understands the technical complicated the Security realm
So far so good.
We also understand that to have Privacy, one must have Security, or otherwise the organization’s public reputation, never mind its ability to function under gov't rules and industry regulation oversight may be in jeopardy. (IE data breaches etc).
However, how many Privacy officers know anything about a 'DMZ' or DLP appliance (to name but two Technical Security phases/gobbledygook). That is the Security guy’s responsibility, right?
How many security personnel understand the ramifications of a stolen laptop with an encrypted disk, with PII from Customers in the US, or if the PII is from those customers that are located within the EU. That is the privacy department issue?
So that is the dilemma. Each department’s needs to 'use' the other’s expertise. But is there is no common language? One group doesn't know what it does not know and the other assumes that everything is addressed. This scenario is a problem waiting to happen.
So let’s take an example. But please note that the following example is only being used to highlight my point. It is an over simplification of the issues.
A new network is being developed to support an application that is being rolled out shortly. This application contains PII/PHI information. In one of the meetings the CPO makes it clear that this type of information needs to be protected/secured. The Security guys go to the back room and incant some magic spells over a rack of computers/servers (sorry I could not help myself) and POOF, out comes a Security policy/procedure etc. plan for the roll out.
The plan contains the proper role based security rules(RBAC), checks, logs etc. The Security guys go out for a drink to celebrate the culmination of designing a 'fool proof' Security envelope (as if there was such a thing).
The Privacy person figures out that the proposed process meets the needs and regulations and goes home with a smile on his/her face. The only people who are authorized to see the information will have the ability to view the PII/PHI info.
However, did anyone look at how support is going to done for this application? The Privacy professional is not a techie and does not know what the 'normal' infrastructure for support/maintenance development for an application is. And why should he/she? Right?
WRONG
The CPO has no idea that during the development and support phases of the project, that copies of the real data may be created to provide a more realistic test bed for QA/ regression testing.(see my previous blog entry for a further discussion concerning this issue).
Did anyone look at the possibility that there may be data leakage within the test/regression system? (PII info that can be emailed in the clear from a developer workstation)? Did the person responsible for Privacy understand the need for a possible Security hardware deployment within the test environment to prevent data leakage. And where should that hardware be deployed? How do third parties access the data for testing? Should they be able to see the test (or Production data)? Should this be considered with a BCP (business contingency planning) document?
The people responsible for Security understand the basic Security 'triad' (CIA. Confidentiality, Integrity and Availability) and have created a process that addresses these requirements. In this case the Security personnel, and may be the network administrator, have designed a comprehensive plan to secure the network where the new application will live on.
But what do they understand about issues like: if a disk drive goes missing, even if it is encrypted, they may still need to notify gov't authorities (EU directive)? And this must be detailed in any contingency planning.
Do they know that they need to talk to the Privacy department to look at how test data is used and abused?
The above mentioned questions are rather over simplified. And of course during the normal working day, the Security department and the Privacy department would talk to each other. BUT
The old adage is very relevant here. 'I don't know what I don't know' or in the case of the Security personnel they don’t know enough of the Privacy realm to make sure everything is addressed. And the Privacy officer does not know how the data is used, to the point that she/he would not know to look into areas that are not obvious IE Test Bed, Third party issues etc..
So what is the answer? Cross train personnel. (Easier said then done).
Have the security department take a course like the CIPP, offered by the International Association of Privacy Professionals. This will allow for the same individuals some insight into the issues pertaining to privacy.
Have the Privacy personnel take a certification course like the SECURITY+ offered by CompTIA. However this may be more problematic because there is an assumption that the person taking this course (or one that is similar) has some basic knowledge in networking and IT in general.
Failing that, Have the people in the CPO office at least try to get the basis of Security down, so the next time the two groups meet they can at least talk a common language. And this would help in reducing the chance of something being missed, and projects coming in on time.
I have been on the peripheral of the discussion about Privacy and Security for awhile. The debate is concerning how Privacy personnel are not familiar with IT security process. And I believe its time to take the bull by the tail and face the situation, so to speak.
My thesis is that there needs to be a concerted effort to develop a liaison group involving people that feel comfortable in both areas of Privacy and IT Security. These people should understand how data is used within the IT, and what expectations Privacy places on the organization.
SO let’s explore
In the vast majority of enterprises, (those that have a IT department and also are concerned by privacy, as all companies should be) there are Privacy officers that deal solely in the Privacy realm (Privacy policy, governance etc) and the IT personnel whose function it is to enhance/maintain/deploy process to Secure the network assets from the 'bad guy'
But before we delve into this much further, let’s explore some of the foundations of these two organizations.
Privacy requirements come from various requirements, regulations, laws. They are formulated/created, either by gov't or professional organizations. Examples include: the PCI DSS, SOX, GLBA, PIPEDA, EU Directive, to name but a few.
These regulations/laws, for the most part are drafted by lawyers, civil servants, professional committees. I transgress with a quick joke. What is a camel? A horse designed by a committee.
The point is that, as written, these regulations are not written for the 'common man'. They deal with the legal aspects of privacy and as such, written in 'legalize'. So to be able to interpret them, create processes to address them, and ensure compliance with the same, it requires individuals that can understand those same rules. That is, one with expertise in the legal and/or regulator profession.
Security comes from the technical world, the idea of what kind of security appliances are needed to monitor/secure the systems/network/infrastructure that are in place within the organization. The understanding of networking protocols, threats and vulnerabilities etc. needs someone who understands the technical complicated the Security realm
So far so good.
We also understand that to have Privacy, one must have Security, or otherwise the organization’s public reputation, never mind its ability to function under gov't rules and industry regulation oversight may be in jeopardy. (IE data breaches etc).
However, how many Privacy officers know anything about a 'DMZ' or DLP appliance (to name but two Technical Security phases/gobbledygook). That is the Security guy’s responsibility, right?
How many security personnel understand the ramifications of a stolen laptop with an encrypted disk, with PII from Customers in the US, or if the PII is from those customers that are located within the EU. That is the privacy department issue?
So that is the dilemma. Each department’s needs to 'use' the other’s expertise. But is there is no common language? One group doesn't know what it does not know and the other assumes that everything is addressed. This scenario is a problem waiting to happen.
So let’s take an example. But please note that the following example is only being used to highlight my point. It is an over simplification of the issues.
A new network is being developed to support an application that is being rolled out shortly. This application contains PII/PHI information. In one of the meetings the CPO makes it clear that this type of information needs to be protected/secured. The Security guys go to the back room and incant some magic spells over a rack of computers/servers (sorry I could not help myself) and POOF, out comes a Security policy/procedure etc. plan for the roll out.
The plan contains the proper role based security rules(RBAC), checks, logs etc. The Security guys go out for a drink to celebrate the culmination of designing a 'fool proof' Security envelope (as if there was such a thing).
The Privacy person figures out that the proposed process meets the needs and regulations and goes home with a smile on his/her face. The only people who are authorized to see the information will have the ability to view the PII/PHI info.
However, did anyone look at how support is going to done for this application? The Privacy professional is not a techie and does not know what the 'normal' infrastructure for support/maintenance development for an application is. And why should he/she? Right?
WRONG
The CPO has no idea that during the development and support phases of the project, that copies of the real data may be created to provide a more realistic test bed for QA/ regression testing.(see my previous blog entry for a further discussion concerning this issue).
Did anyone look at the possibility that there may be data leakage within the test/regression system? (PII info that can be emailed in the clear from a developer workstation)? Did the person responsible for Privacy understand the need for a possible Security hardware deployment within the test environment to prevent data leakage. And where should that hardware be deployed? How do third parties access the data for testing? Should they be able to see the test (or Production data)? Should this be considered with a BCP (business contingency planning) document?
The people responsible for Security understand the basic Security 'triad' (CIA. Confidentiality, Integrity and Availability) and have created a process that addresses these requirements. In this case the Security personnel, and may be the network administrator, have designed a comprehensive plan to secure the network where the new application will live on.
But what do they understand about issues like: if a disk drive goes missing, even if it is encrypted, they may still need to notify gov't authorities (EU directive)? And this must be detailed in any contingency planning.
Do they know that they need to talk to the Privacy department to look at how test data is used and abused?
The above mentioned questions are rather over simplified. And of course during the normal working day, the Security department and the Privacy department would talk to each other. BUT
The old adage is very relevant here. 'I don't know what I don't know' or in the case of the Security personnel they don’t know enough of the Privacy realm to make sure everything is addressed. And the Privacy officer does not know how the data is used, to the point that she/he would not know to look into areas that are not obvious IE Test Bed, Third party issues etc..
So what is the answer? Cross train personnel. (Easier said then done).
Have the security department take a course like the CIPP, offered by the International Association of Privacy Professionals. This will allow for the same individuals some insight into the issues pertaining to privacy.
Have the Privacy personnel take a certification course like the SECURITY+ offered by CompTIA. However this may be more problematic because there is an assumption that the person taking this course (or one that is similar) has some basic knowledge in networking and IT in general.
Failing that, Have the people in the CPO office at least try to get the basis of Security down, so the next time the two groups meet they can at least talk a common language. And this would help in reducing the chance of something being missed, and projects coming in on time.
Sunday, July 7, 2013
Robert Galambos's Updated Resume
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Robert Galambos
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Career Profile:
Over seventeen years of experience as presales engineer and consultant
in the software industry, combining high-level sales and marketing knowledge
with deep operational experience, technical savvy and cross-functional
communication abilities. Extensive experience supporting sales initiatives,
managing customer relationships, handling customer service calls and
consultations, and maximizing client ROI on software solutions.
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Areas of
Strength
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Professional Experience
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COMPUWARE 1996
to 2013
Leading
provider of IT software, services and best practices to deliver peak
performance for technologies worldwide.
Sales Engineer & Consultant
- Provided technical analysis concerning Data Privacy to facilitate completion of RFI and RFP responses for various clients, with 85 percent success ratio.
- Delivered high-impact presentations to clients leveraging strong technical skills.
- Managed interoperability and alliance between software solutions and customers’ strategic business plans.
- Helped potential clients understand, compare and contrast several IT solutions.
- Collaborated with sales to develop cost justifications, business proposals and responses to RFI/RFPs.
- Engaged and coordinated post-sales implementation engagements.
- Helped close a minimum $2 million dollar sales 13 years in a row.
- Anointed to learn, support and sell two entire product lines, due to the unique requirement of both English and French support and sales.
- Contributed to a team that achieved a minimum 97 percent maintenance renewal.
- Liaised with Product Development and Marketing departments, perform client sales management, and report on industry/market trends, competition, and needs.
- Maintained extensive and specialized knowledge of COMPUWARE’s products, customers and competition, to enhance customer service ability and stay current on company offerings.
- Produced detailed phone support, personal product demonstrations and on-site evaluations of clients’ current software solutions.
- Responded to requests for information or pricing in an efficient manner and prepared sales package proposals.
- Trained and lectured clients, staff and executives on various solutions, including Data Privacy and Application Auditing.
- Facilitated customers and partners, as well as on-site professional services support such as installations and configurations upon deployment of software.
- Created, updated and disseminated training materials for 10 different software products on both mainframe and mid-tier/distributed environments.
- Served as Project Manager/Team Lead developing and updating training material with a specific timeline and with the participation of 10 team members.
- Gained proficiency in MS Windows, MS Office, Salesforce.com, and Data Privacy Solution Mainframe.
- Was one out of two people chosen (out of 24) to be a mentor for the Professional Development Program, training non-IT professionals to be support personnel.
- Worked in various realms, including ETL, Data Privacy in the testing space, Data Management and Data Optimization for both short-term and long-term sales cycles.
MONTREAL TRUST / BANK
OF NOVA SCOTIA 1984 to 1996
Premier
financial institution providing personal, commercial, corporate and investment
banking services to individuals, small and medium-sized businesses,
corporations and governments.
Principal Analyst & Team Lead
- Oversaw the team responsible for financial systems, including general ledgers, accounts receivable and accounts payable within the Trust Unit.
- Apprised management of more efficient methodologies to ensure better business decisions.
- Provided guidance, instruction, direction and leadership to the team to achieve key results for clients.
- Coached and matured the skill level of direct reports in order to continue their long-term development and ensure solid succession planning and departmental success.
- Liaised with Payroll, HR and Executive Offices as a subject matter expert.
- Gained proficiency in COBOL, IDMS, and IBM Multiple Virtual Storage
- Created “What if” scenarios and provided support for non-technical end-users.
- Designed major conversion project for Pension Plan Changes/Acquisition (BNS).
- Worked with the Finance Team to determine the ongoing business needs and requirements for the reporting of all assets, sales, redemptions, management fees, trailer fees, and advisory fees.
Certifications
Security+
- Knowledge of security concepts, tools, and procedures to react to security incidents, to ensure that security personnel are anticipating security risks and guarding against them.
CIPP/C: Certified
Information Privacy Professional/Canada
- Demonstrates understanding and application of Canadian information privacy laws, principles and practices at the federal, provincial and territorial levels.
- Requires completion of Certification Foundation Exam and CIPP/C Exam.
CIPP/IT: Certified
Information Privacy Professional/IT
- Entails understanding privacy and data protection practices in the development, engineering, deployment and auditing of IT products and services.
- Necessitates completion of Certification Foundation Exam and CIPP/IT Exam.
IBM Certified
Database Administrator – DB2 9 DBA for z/OS
- Validates capability of performing intermediate to advanced tasks related to database design and implementation, operation and recovery, security and auditing, performance, and installation and migration/updates specific to the z/OS operating system.
Education
Concordia University, Montreal,
Québec
Bachelor of Commerce, Accounting (1979)
Wednesday, June 12, 2013
Robert Galambos Visual Resume

In the world where presentations can make or break a sale, a project, or a policy, I thought it would be a great idea to create something to showcase my MS PowerPoint skill set.
Visual Resume
Monday, May 27, 2013
Musing of Big Data and Privacy
Big Data and Privacy. Or should a
Big Box store figure out if someone is pregnant?
Is that Private?
Now, this blog is not the place to have a detailed discussion about this, but needless to say the mathematical model that was developed was successful in more the 87% to predict, based solely on buying habits, which of their clients were pregnant. They were then able to target the pregnant customers with coupons, flyer's, etc in hopes getting them to buy more ‘STUFF’,
Is that Private?
So what is Big Data? Is it the
latest 'fashion statement' from the IT world? A bunch of numbers, letters, that
represent something or someone? Something of an asset?
All the above and more. Basically it
is the information, or data, that is generated by everyone and everything. Examples of Big Data include
this particular blog entered on the web, the decoding of the human genome, the
buying habits for your customers, your credit score etc.
Its 'stuff'.
Google’s CEO Eric Schmidt stated:
“From the dawn of civilization until 2003, humankind generated five exabytes of
data. Now we produce five exabytes every two days…and the pace is
accelerating.”
SO that is Big Data. But how does it
concern privacy? Before we go there, lets reflect this issue.
Companies are generating great
mounds of data. Everything from what you purchase in grocery items (those
Customer loyalty cards) to what credit cards you use and where.
This is an asset to the company. It
is something that can be analyzed, inspected, and reported on, all for the
purpose to get the upper edge from their competitors, a better understanding
of the customers,how to market/target them to get the best results, What tickles their fancy so to speak? Maybe get that same customer to buy
milk from your company as well as the clothing that they buy now.
While doing the research for this
blog I came across an interesting case study concerning this issue.
A major Big Box chain’s (not
Wal-Mart) department of thinkers (not a real department but could have well
been named that) got together to try to see if they could 'predict' which of
their customers were pregnant.
The reason was if they can get that
pregnant customer to start buying the 'stuff' needed for the happy occasion, they
could influence their buying patterns in the future. A better 'bottom' line
(pun intended).
They had all this raw data about
their clients and their buying habits. They can mine the information (Big Data)
and determine if there were any patterns. And the results were, to say the
least, eye opening.
Now, this blog is not the place to have a detailed discussion about this, but needless to say the mathematical model that was developed was successful in more the 87% to predict, based solely on buying habits, which of their clients were pregnant. They were then able to target the pregnant customers with coupons, flyer's, etc in hopes getting them to buy more ‘STUFF’,
This was done without the a client
filling out a form letting the company know they were expecting, Ms Jane Doe customer
had yet to buy a single diaper etc. The mining of this client’s information from the
company database which indicated her buying habits, was the only determining
factor.
That is what Big Data is, and what
it can do.
Can you see the issues in privacy in
all this? Actually, there are really three different issues when dealing with
Big Data.
Is what the company doing legal?
Is it ethical?
Is it acceptable to the general
public?
Let tackle the legality first.
It’s not a simple answer. There are
a lot of variables involved. Where does the customer live? Did he/she give
permission to the company to use the data collected for internal (and maybe
external) use? These are but two questions that privacy officers need to deal
with, address and ultimately sign off on.
Generally speaking, we can assume,
when a customer signs up for a loyalty card, there would be some form of
authorization to use the data. Or at least best practices demands such sort of
disclosure, if nothing else. And this may be the easiest of the three
questions.
Is it ethical?
PHD theses have been written about this very question for 'years'. There is no gov't review panel to determine if it is or not ethical, but the question is still very valid. One education site states that ' ethics refers to standards of behavior that tell us how human beings ought to act in the many situations..'
PHD theses have been written about this very question for 'years'. There is no gov't review panel to determine if it is or not ethical, but the question is still very valid. One education site states that ' ethics refers to standards of behavior that tell us how human beings ought to act in the many situations..'
http://www.scu.edu/ethics/practicing/decision/framework.html
While there is no stand fast rules
on what is and is not ethical, one can, if for no other reason, look into
the mirror and ask the question? Is this ok?
Is it then acceptable?
Going back to the story above, let’s see what happened. After the store created the model, they started sending flyer's, coupons that would target the would be moms. Examples, like diapers coupons , flyer's featuring cribs etc. were sent out to the targeted group.
Well, you can imagine what happened next. Many irate customers wondered, first of all, how did this company know they were expecting. Even more damaging to the company’s reputation was the fact that they were sending baby oriented coupons to non pregnant clients. And what if those target accounts were teenagers, and/or single, and/or religious?
Going back to the story above, let’s see what happened. After the store created the model, they started sending flyer's, coupons that would target the would be moms. Examples, like diapers coupons , flyer's featuring cribs etc. were sent out to the targeted group.
Well, you can imagine what happened next. Many irate customers wondered, first of all, how did this company know they were expecting. Even more damaging to the company’s reputation was the fact that they were sending baby oriented coupons to non pregnant clients. And what if those target accounts were teenagers, and/or single, and/or religious?
A public relations nightmare. In
fact, while doing the research, I was surprised that this had not been thought
out more thoroughly in the marketing department of the company.
All these factors play in the realm
of Big Data. And privacy is just one of those factors.
Ultimately, the people responsible
for privacy need to assure themselves that the use of the data is within legal
constraints.
It can be more complicated if that
data being analyzed is sent out to another company. There are 'mounds' of
companies whose only job is to message the data and make sense of it. They can
then market to those clients with targeted campaigns as successfully as
possible(the pregnant ladies from the above example), to get the best return on
the data. (the Big Data).
Big Data means being able to see
trends and patterns, not determining individuals buying habits per say.
No one in Costco cares if the individual named Robert will buy a steak or a bottle of milk. What they do care about is influencing the group that Robert ‘belongs to’ so they can somehow how influence that targeted group to buy both products (as an example).
So an argument concerning privacy can go something like this:
Its not the PII information of a particular person that is being used (for the most part) for this type of analysis, but that a customer bought an item and he is middle aged, 6 foot, lives in a middle class area, Etc. And he belongs to a statistical group that represents 25% of the customer base in a particular region.
Maybe. But then again is that the only usage of these great mounds of data?
No one in Costco cares if the individual named Robert will buy a steak or a bottle of milk. What they do care about is influencing the group that Robert ‘belongs to’ so they can somehow how influence that targeted group to buy both products (as an example).
So an argument concerning privacy can go something like this:
Its not the PII information of a particular person that is being used (for the most part) for this type of analysis, but that a customer bought an item and he is middle aged, 6 foot, lives in a middle class area, Etc. And he belongs to a statistical group that represents 25% of the customer base in a particular region.
Maybe. But then again is that the only usage of these great mounds of data?
The debate on Big Data, how to
handle it, and the ramifications on privacy will continue. What we need to do,
is have the dialog, ask the questions, figure out what can and should be done.
The concerns won't go away, and ignoring the issues will only make it worse. We all need to first understand the issues and then try to make 'a go at it.' And at same time making sure we don't shot ourselves in the foot.
The concerns won't go away, and ignoring the issues will only make it worse. We all need to first understand the issues and then try to make 'a go at it.' And at same time making sure we don't shot ourselves in the foot.
Wednesday, May 22, 2013
Testing, in the black box (ATV), Security & Privacy

How Automate Testing Vehicles (ATV) should include Pentesting.
Why should privacy officers get involved in development, regression testing process?
Why does IT need to improve their testing strategies?
Pitfalls in Testing, Security/Privacy concerns is what drives people to have nightmares. Privacy officers need to have a better understanding of the environment they work in. The IT people need to embrace the notion that Privacy/Security starts from the beginning. So in that way the chances of being on a front page of a newspaper because of a breach and/or a failure will be minimized. NO ONE wants to phone the CIO about a problem like this. It is a team effort.
I do have to warn you, the reader, that some of the material may be a little IT oriented. But in an organization where one needs to satisfy a number of different objectives, I would suggest at least a basic knowledge of the IT process is needed. And that the IT personnel need to understand the present compliance/regulator landscape.
Some definitions are warranted before I begin.
ATV or Automated Testing Vehicle. What is it? Why do I care? And is it a 'best practice'? (one of the most over used phrase at present).
The idea is fairly simple. Having a set of scripts (automated) that can be run to test the system in question. The objective is to test the system before any changes are implemented. The process should set up the files that will be used for testing(see one of my previous blog posts concerning using data for testing), then run the test scripts, and afterwards run the comparison reports and highlight items of concern from the test just executed. All this is done in an automated fashion. Rather simple concept, but one that can be 'processes' changing in a good way.
Well there is more to this. But let me define another term or two first.
IT systems that are down cost money in lost revenue, and good will to the enterprise. As an example, in 2012 Google had an outage.
Google June 2012 down for 10 min.
The ball park figure cost that Google suffered was calculated at about $750,000. And that was for 10 minutes. Now I am not suggesting all downtime costs are that much. It depends on the circumstances, but I am sure no one would like to find out for their own companies.
Another good example of the costs is sited at costs of web down time per industry
This site allows you to calculate the cost of a web site being down per industry/application. Its an eye opener to say the least.
In another 'word', downtime is BAD/EXPENSIVE *Yea I know that is two words*. But joking aside we need to reduce unavailability as much as possible.
PenTesting. Wikipedia link The Information Systems Audit and Control Association(ISACA) defines Penetration Testing as "A test of the effectiveness of security defences through mimicking the actions of real-life attackers."
(For the reader who is more concerned with Privacy/Security, please read on)
So now let's proceed. When an application change happens IT personnel (or a designated organization) tests the changes (IE regression testing). They test the change to see if it works. Now depending on the process that is followed, a user may also test/approve the same series of changes to the application for user approval. Fine, right? Do you notice something missing in the above? In fact, there is more then one item here that needs to be defined/explored.
For many organizations testing to maintain the basic functions within an application does happen in a haphazardly way. Sure the change is tested and to get to the enhancements, some basic functions are tested as well, But, based on my anecdotal experiences, on many occasions, the entire core functions of the changed application are not testing on a consistent bases. A test of the all the basic core functions should also be completely tested whenever there is a change.
As an example, if the application in question is some public facing web application (a web store as an example), basic function testing should also be done. Test for example, the ability to add/change a Credit card information and make sure that the update still works. Test adding an item to the shopping cart etc.
So if the new function within the application fails, you have verified that the basic core functions, the one you need to keep the doors open, will still operate.
Imagine if an error occurs at your bank, yet the basic functions were tested successfully with the 'improved mobile bank portal' (the change that will be implemented). Then logic would dictate that the basic functions should still work (you can still pay bills) even if the enhancement of the bank's mobile app does not. Corrections can be retested and implemented with minimal cost/embarrassment to the organization.
I am therefore advocating that there should be standard testing scripts that confirm, even with the changes that are going to be implemented, that ALL the core functions still are accessible.
So to implement a process like this, you first need to map out the basic functions that you can not live without. Once that is done and scripts are created, an automated process should be created. When ready, a series of script can be executed with little human intervention. (less change for human error). The 'Best Practice' (there is that phase again) would be something along the lines of submitting the scripts and going home. When you get into the office the following day the results are ready for analysis/correction etc.
This should ensure that at even if the new change fails. You, the customer, can still do business with the organization in question. This is what some people call a ATV (see above). This process can be called your insurance policy.
However, lets' takes this further. Why just test the basic functionality of the application? Should we also test for Security/Privacy issues? Should the company's Privacy/Security office ensure that this type of testing, verification is also included within an ATV and executed whenever anything changes?
Absolutely!
A process that includes PenTesting (see above) is something one should consider adding to the above mentioned ATV. With any change there is always a chance that a vulnerability is created that may not have been there before.
Any failure can by it's very nature, cause the potential to expose sensitive information. It can be business secrets, and/or Personnel Identifiable Information (PII) to name but two potential headaches.
There is software in the marketplace that has the capability to engage/test/analyze applications for vulnerabilities. Some of the software I have previously mentioned as well as others which are available with the capabilities needed.
So I suggest that one creates an ATV process that includes the basic functionality of the application/system in question as well as additional testing for security/privacy. All this should be automated so that more extensive testing can be executed as well as reducing the chance for human error.
Privacy officers need to ensure that any changes that are implemented will not cause exposure that may be costly. IT people need to make sure that the basic systems functions still run, no matter what is changed.
Finally, while no one can claim in absolute terms that there will be no issues, following these basic concepts can help reduce the chance that the CIO needs to be called because of an issue.
Monday, May 6, 2013
Privacy for IT, Security for PO, Privacy by Design PdB.
So far I have tried to tackle how different professionals look at privacy differently and how stakeholders are an important piece of the pie
What I am going to try to address within this post is how technical ideas affect privacy and security, as well.
I will also attempt to provide some guidance concerning some of the issues I will discuss here.
Please note, I have no relationships with any of the companies that I mention here, or any in any other posts that I have written. Also, it is up to the reader to do their own due diligence.
Now, the reader may have some level of knowledge of the 'tecky' stuff but I will try not to make any assumptions. What I want to do is to highlight some aspects, describe them for those who may not be as technically inclined, and provide some resources where more research can be done.
Some lay people use the words security and privacy interchangeable. While security is needed to maintain privacy, it can mean other things as well. For example, physical security of a public facing office (banks, insurance agents offices etc) is generally accepted that it need to be addressed, to protect the employees (non privacy issue) and protect the companies customers from data breaches, which is a privacy concern.
What I am going to deal with here is security that is needed to protect Personal Identifiable Information (PII)
So lets get started.
Security
Hopefully, when a developer starts coding for a new application, or making enhancements to an existing application, he/she will know how to code to prevent security holes within the code. But as we all know, we are all human.
SO what can we do?
A new type of software is emerging that can help developers to highlight what they should be coding. This is in a form of questions/guidance that can be based on questions/queries from a knowledge base. The objective is to build into the design document (this is the document that concern how the programs work together and coded, given the requirements of the application being worked on). This would then place into the design document specifications of the required defences that need to be incorporated within the code.
The two software products that I am aware that falls within this category are:
1) SD Elements (http://www.sdelements.com)
2) Security Innovations (https://www.securityinnovation.com)
Both have there strength and weaknesses. They also tackle this aspect of security coding in a very different way.
As an analogy, let us use the example of your car (or your friends, car if you don't have one <S>), or boat, bike etc. Which is cheaper? Is it changing your oil every x KM/Miles, or waiting for the engine to seize when the oil can no longer do its job?
On average it costs about $4,000 to fix a vulnerability in an application (SD Elements). According to White Hat Security (https://www.whitehatsec.com/resource/stats.html) on average, there are 56 vulnerabilities per website (2012). So let's do some math, Shall we?
It will cost $4,000 times 56 on average to fix all the problems with security on a public facing websites, for a total of, and average of $224,000.
You can close your mouth now.
And to top it all off 85% of all websites White Hat tested had one vulnerability. And to make matters worse, it took, on average, 193 days from the date the issue was detected until it was resolved. Never mind that 61% of the White Hat tested websites that had vulnerabilities were never fixed in the first place.
In other words, the best practices, as well as the ROI, demand that we need to try to nip this issue in the bud. It follows that company's policy should have security requirements and processes be part of the design phase of any project.
Privacy
At this point let me highlight a series of documents, white papers that have been produced by the Information & Privacy Commissioner of Ontario Canada. (IPCO) Dr Ann Cavoukian PH. D.
The premise advocated by the IPCO is that of Privacy by Design (PbD). It goes in to much more depth that is beyond the scope of this blog but I encourage you to head over there and explore.
There are two sides to the equation. Security for the professional IT people and Privacy for the legal 'minds'. How in essence they are complementary and how they must exists together.
As a note here, one of the white papers on the sir 'Privacy and Security by Design: A convergence of Paradigms' talks about what I am writing about here. It was released in Jan 2012.
I do have to make an admission to the reader. I started writing these blogs, and this one in particular, before I had any notion of this white paper's existence. When i did discover the PbD white papers i realized the concepts, topics, and themes were similar to the issues I have explored in my blogs,
I will continue along this road next time. I will highlight examples of different forms of testing for security and ideas of privacy.
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