Awareness Training Series Management Awareness Training Dan Hadaway

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Awareness Training Series Management Awareness Training Dan Hadaway CISA, CISM Managing Partner infotex

Awareness Training Series Management Awareness Training Dan Hadaway CISA, CISM Managing Partner infotex

Objectives • What is IT Governance, and what does a typical IT Governance program

Objectives • What is IT Governance, and what does a typical IT Governance program look like? • What is the management team’s role in the IT Governance Program? • What is the ISO’s role? • What should the management team know to ensure proper IT Governance? • How can management help manage technology risk? infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

In this next section • We will become familiar with the “workshop portal” and

In this next section • We will become familiar with the “workshop portal” and this presentation. • We will hear credentials that can be used to log onto the workshop portal. • We will learn what is on the “workshop portal. ” infotex

Available Tools. . . • • IT Audit Test Types The ISO Job Description

Available Tools. . . • • IT Audit Test Types The ISO Job Description Awareness Training Procedure Management Awareness Training Procedure • Governance Policy Development Chart infotex

Available Tools. . . • Management Guidelines for Social Media • User Guidelines for

Available Tools. . . • Management Guidelines for Social Media • User Guidelines for Social Media • Management Talking Points for Mobile Banking and Social Media infotex

Available Tools. . . • Wireless Banking Article (Top Five Risks) • Wireless Banking

Available Tools. . . • Wireless Banking Article (Top Five Risks) • Wireless Banking Article • Wireless Banking Risk Assessment • Wireless Banking Due Diligence Kit infotex

Our Credentials • Information Security – CISAs, CISMs, CISSPs – Developed my first AUP

Our Credentials • Information Security – CISAs, CISMs, CISSPs – Developed my first AUP in 1988 – Updating our process annually – Been doing Annual UAT for banks since 2002 • GLBA, BSA, OFAC, FACTA, HIPAA • Assessments, IT Audits, Consulting • Managed Services (Network Monitoring) infotex

Nomenclature • Information Security Strategy • Information Security Program • IT Risk Management Program

Nomenclature • Information Security Strategy • Information Security Program • IT Risk Management Program • IT Governance Program Essentially the same thing. infotex

IT Governance Program • Combines: – Serve Business Mission – Manage Technology Risk (information

IT Governance Program • Combines: – Serve Business Mission – Manage Technology Risk (information security) infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

In this next section • We will learn five basic tenets of IT Governance

In this next section • We will learn five basic tenets of IT Governance that all management team members should know. • We will learn why IT Governance is concerned with Risk Management • We will learn “the one control” and why this workshop is important. infotex

#1 infotex

#1 infotex

#1: Serve the Mission Information Technology must be aligned with the Business Strategy of

#1: Serve the Mission Information Technology must be aligned with the Business Strategy of the bank! infotex

Strategy Alignment • Facilitate business tactics – Assists in business processes – Creates a

Strategy Alignment • Facilitate business tactics – Assists in business processes – Creates a competitive edge – Increases Communication with “all four corners of the bank” especially customers. – Provides accurate information to management infotex

Strategy Alignment • Deliver a Return on Investment – Tangible Return • Check 21

Strategy Alignment • Deliver a Return on Investment – Tangible Return • Check 21 takes advantage of quicker check processing. Imaging System reduces paper costs. • Fees charged for various services. – Intangible Return • Firewall mitigates risk of internet hacking. • On-line Banking provides convenience to customers. infotex

Management Role • Determine technologies that will best facilitate business tactics. • Determine appropriate

Management Role • Determine technologies that will best facilitate business tactics. • Determine appropriate time to deploy new technologies (Apply Pressure) infotex

Management Role • Search and Selection Process – Cost/Benefit Benefit/Risk When? ? ? –

Management Role • Search and Selection Process – Cost/Benefit Benefit/Risk When? ? ? – Risk Analysis – Requirements Definition – Request for Proposal infotex

Management Role • Negotiate Contracts (as per Vendor Management Procedure) • Implementation – From

Management Role • Negotiate Contracts (as per Vendor Management Procedure) • Implementation – From a user perspective – Return to risk analysis – Return to cost/benefit analysis – Return to features analysis • Ongoing Vendor Due Diligence (as per Vendor Management Procedure) infotex

When is the appropriate time? infotex

When is the appropriate time? infotex

infotex 1. Align IT with Business Strategy Roger’s Diffusion Theory of Innovation • Innovators

infotex 1. Align IT with Business Strategy Roger’s Diffusion Theory of Innovation • Innovators • Early adopters • Early majority • Late majority • Laggards Everett M. Rogers' Diffusion of Innovations

infotex 1. Align IT with Business Strategy Stages of Innovation • Knowledge • Persuasion

infotex 1. Align IT with Business Strategy Stages of Innovation • Knowledge • Persuasion • Decision • Implementation • Confirmation Risk Assessment? Security Controls Everett M. Rogers' Diffusion of Innovations

infotex 1. Align IT with Business Strategy Early Adopters in Banking • Physical Security

infotex 1. Align IT with Business Strategy Early Adopters in Banking • Physical Security • Information Security Dan’s Interpretation of Everett M. Rogers' Diffusion of Innovations

infotex 1. Align IT with Business Strategy Late Majority / Laggard • Virtualization •

infotex 1. Align IT with Business Strategy Late Majority / Laggard • Virtualization • Cloud Computing • Social Media • Telecommuting Softwareforcloudcomputing. com Dan’s Interpretation of Everett M. Rogers' Diffusion of Innovations

infotex 1. Align IT with Business Strategy Risk/Benefit Evolution Curve Value Price, Problems Features,

infotex 1. Align IT with Business Strategy Risk/Benefit Evolution Curve Value Price, Problems Features, Sophistication Time

infotex 1. Align IT with Business Strategy Risk/Benefit Evolution Curve Value Price, Problems Features,

infotex 1. Align IT with Business Strategy Risk/Benefit Evolution Curve Value Price, Problems Features, Sophistication Time

infotex 1. Align IT with Business Strategy Risk/Benefit Evolution Curve Price, Problems Value Early

infotex 1. Align IT with Business Strategy Risk/Benefit Evolution Curve Price, Problems Value Early Majority Late Majority Laggards Innovator Early Adopter Features, Sophistication Time

Digital Video Security • Innovators • Early adopters • Early majority • Late majority

Digital Video Security • Innovators • Early adopters • Early majority • Late majority • Laggards 2012 infotex

Secure Messaging • Innovators • Early adopters • Early majority • Late majority •

Secure Messaging • Innovators • Early adopters • Early majority • Late majority • Laggards 2012 infotex

Remote Access in Banks • Innovators • Early adopters • Early majority • Late

Remote Access in Banks • Innovators • Early adopters • Early majority • Late majority • Laggards 2010 infotex

Social Media in Banks • Innovators • Early adopters • Early majority • Late

Social Media in Banks • Innovators • Early adopters • Early majority • Late majority • Laggards 2011 infotex

Wireless Banking • Innovators • Early adopters • Early majority • Late majority •

Wireless Banking • Innovators • Early adopters • Early majority • Late majority • Laggards 2013 infotex

#2 infotex

#2 infotex

#2: Manage the Risk Information, Technology, and Information Technology expose the bank to risk!

#2: Manage the Risk Information, Technology, and Information Technology expose the bank to risk! infotex

#2) The Risk Spectrum • There is no such thing as 100% security! Ignore

#2) The Risk Spectrum • There is no such thing as 100% security! Ignore it? Obsession? infotex

#2) The Risk Spectrum • There is no such thing as 100% security! Ignore

#2) The Risk Spectrum • There is no such thing as 100% security! Ignore it? FFIEC Guidelines infotex

How do you decide? • There is no such thing as 100% security! Ignore

How do you decide? • There is no such thing as 100% security! Ignore it? Risk-based Remediation FFIEC Guidelines infotex

Principle Number Two Information Security is about ACCEPTING RISK. infotex

Principle Number Two Information Security is about ACCEPTING RISK. infotex

#3 infotex

#3 infotex

A process question When you are finished serving a customer, what do you typically

A process question When you are finished serving a customer, what do you typically do? A. Cross Customer Service off the to-do list. B. File the experience away as one you hope you’ll never have to do again. C. Learn from the experience and try to serve the next customer better. D. Move on to the next project. infotex

Fundamental #3 infotex

Fundamental #3 infotex

Which means. . . • No crossing it off the list. • No filing

Which means. . . • No crossing it off the list. • No filing it away. • No wishing you never have to deal with it again. infotex

And means. . . • Its cyclical. • You learn from each cycle. •

And means. . . • Its cyclical. • You learn from each cycle. • It is constantly improving (we hope). • It’s about managing risk and ensuring alignment with other business processes. infotex

And to improve. . • We must start by measuring. But remember that metrics

And to improve. . • We must start by measuring. But remember that metrics are all relative. infotex

Fundamental #3 infotex

Fundamental #3 infotex

#4 infotex

#4 infotex

Important Point Question A. Pretext Calling What is the Number 1 form of Identity

Important Point Question A. Pretext Calling What is the Number 1 form of Identity Theft? B. Drive-by Attacks (Trojan Horses installed by rogue websites. ) C. Insider Data Theft D. Phishing E. Other infotex

Source: Javelin Research 2009 Identity Fraud Survey Report a survey of 25, 000 adults.

Source: Javelin Research 2009 Identity Fraud Survey Report a survey of 25, 000 adults. infotex

4) It’s not really Technical People Technology Policy Process infotex

4) It’s not really Technical People Technology Policy Process infotex

IT requires a Team Approach • Risk must be measured and managed using a

IT requires a Team Approach • Risk must be measured and managed using a multi-disciplinary approach. • Risk is mitigated by establishing controls in the form of policies, procedures, and tools. • Risk Management Controls involve “all four corners of the bank. ” infotex

Four Corners of the Bank infotex

Four Corners of the Bank infotex

Four Corners of the Bank Board of Directors Customers Vendors Law Enforcement Academia Users

Four Corners of the Bank Board of Directors Customers Vendors Law Enforcement Academia Users Oversight Committee Management Team Technical Team infotex

Information Security Officer • Measures, Manages, Reports Information Security Risk • Interacts with all

Information Security Officer • Measures, Manages, Reports Information Security Risk • Interacts with all four corners. • Facilitates development and continuous improvement of security controls. • Delivers an Annual Report directly to the board. infotex

Information Security Officer • Works with Management to: – Measure and Control Risk –

Information Security Officer • Works with Management to: – Measure and Control Risk – Develop and enforce Security Controls – Plan Response to Negative Incidents (Policy Violation, Security, Disaster) – Manage Vendor Risk – Authorize Access to IT Assets – Inventory and manage IT Assets – Escalate Risk Acceptance Decisions (to the Board of Directors) infotex

#5 infotex

#5 infotex

infotex

infotex

Four Risk Factors Threats Likelihood Vulnerabilities Impact Severity infotex

Four Risk Factors Threats Likelihood Vulnerabilities Impact Severity infotex

Threats • Terrorists • Hackers • Scammers / Conmen /Fraudsters / Thieves • Vandals

Threats • Terrorists • Hackers • Scammers / Conmen /Fraudsters / Thieves • Vandals • Technology Itself • Users / Vendors • Nosy Neighbors • Ex-Spouses infotex

We can’t take it lightly • Zeus • Software suite designed to help hackers

We can’t take it lightly • Zeus • Software suite designed to help hackers attack banks. infotex

Marc Rogers, Purdue University infotex

Marc Rogers, Purdue University infotex

. . . zooming in. . . infotex

. . . zooming in. . . infotex

Vulnerabilities • • • Airplanes Ports Subway System Buildings Public Places • E-mail •

Vulnerabilities • • • Airplanes Ports Subway System Buildings Public Places • E-mail • Browsers • Network Access • Users • > 300 considered in Risk Assessment infotex

Impact Severity • Almost 3000 people • Financial System • Airlines • Convenience •

Impact Severity • Almost 3000 people • Financial System • Airlines • Convenience • Customers’ Identities • Horror Stories • Heartland Payment System ($7/card, 20, 000 cards) • Reputation infotex

Likelihood • It can happen on American Soil • Technology Itself Very High •

Likelihood • It can happen on American Soil • Technology Itself Very High • Pretext Calling High • Phishing High • Hacking Medium • Physical Breach Low – Still happens though! infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

In this next section • We will learn about the Federal Financial Institution Examination

In this next section • We will learn about the Federal Financial Institution Examination Council (FFIEC) and it’s published “guidelines” for information technology, and why these guidelines become audit frameworks. • We will see a quick summary of “management responsibilities for IT. ” • We will review a “map” of the typical bank’s IT Governance Program • We will learn how the management team “plugs in” to the IT Governance Program. infotex

Types of Risk • Transaction Risk – Data Corruption Problems – Social Engineering –

Types of Risk • Transaction Risk – Data Corruption Problems – Social Engineering – Customer Errors (Internet Banking) • Legal Risk – Obscene Jokes in E-mail – Privacy Violations – Unlicensed Software infotex

Types of Risk • Financial Risk – Early Adapter of Technology – Vendor Solvency

Types of Risk • Financial Risk – Early Adapter of Technology – Vendor Solvency – Cost of Security Breaches • Operational Risk – Virus Attacks – Denial of Service (Do. S) Attacks – Project Management Risk infotex

Types of Risk • Reputational Risk – Any Security Incident presents some reputational risk.

Types of Risk • Reputational Risk – Any Security Incident presents some reputational risk. – Poor Incident Response can turn a minor incident into a major incident. infotex

Types of Risk • Compliance Risk – GLBA – HIPAA, CIPA, SOX – PCI,

Types of Risk • Compliance Risk – GLBA – HIPAA, CIPA, SOX – PCI, BS 12000, ITIL, Cobi. T – BSA, OFAC, US Patriot Act – FACTA – SB 1386 infotex

Gramm Leach Bliley Act Specifically, Title V of the GLBA, called "Disclosure of Nonpublic

Gramm Leach Bliley Act Specifically, Title V of the GLBA, called "Disclosure of Nonpublic Personal Information, " is intended to ensure security and confidentiality of customers' records and information, protect the integrity of such information, and protect against unauthorized access to such information. infotex

Thank goodness for the. . . infotex

Thank goodness for the. . . infotex

The FFIEC • Federal Reserve System (FRB) • Federal Deposit Insurance Corporation (FDIC) •

The FFIEC • Federal Reserve System (FRB) • Federal Deposit Insurance Corporation (FDIC) • National Credit Union Administration (NCUA) • Office of the Comptroller of the Currency (OCC) • Office of Thrift Supervision (OTS) infotex

The FFIEC Information Security Work Program IT Audit Handbook Boilerplates Information Security Handbook IT

The FFIEC Information Security Work Program IT Audit Handbook Boilerplates Information Security Handbook IT Audit Work Program infotex

Awareness Training Series Management Responsibilities A quick summary infotex

Awareness Training Series Management Responsibilities A quick summary infotex

Summary of Responsibilities • Understand how IT aligns with bank and department business strategy

Summary of Responsibilities • Understand how IT aligns with bank and department business strategy and work with IT to ensure appropriate alignment. • Know the IT Governance program, how it works, the ISO’s role, and your role in the various sub-programs. • Be familiar with technology risk that the bank faces. • Enforce technology controls. • Activate awareness of staff members. infotex

What does an IT Governance Program include? (according to FFIEC Guidelines) infotex

What does an IT Governance Program include? (according to FFIEC Guidelines) infotex

The FFIEC Information Security Work Program How about a map? IT Audit Handbook Boilerplates

The FFIEC Information Security Work Program How about a map? IT Audit Handbook Boilerplates Information Security Handbook IT Audit Work Program infotex

IT Governance Program Policy Procedure Tools (standards, guidelines, applications, forms, websites, etc. ) The

IT Governance Program Policy Procedure Tools (standards, guidelines, applications, forms, websites, etc. ) The combined policy, procedures, and tools about a particular issue can be referred to as a “Program. ” infotex

Authentication Example AUP Authentication Procedures A procedure enforces a board level policy using tools

Authentication Example AUP Authentication Procedures A procedure enforces a board level policy using tools called for in the procedure. Passwords Out-of-Pocket Questions Visitor Authorization Process infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Risk Analysis Program infotex

Risk Analysis Program infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Access Management infotex

Access Management infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Incident Response Program infotex

Incident Response Program infotex

Incident Response • Awareness is an important part of incident response. • Board of

Incident Response • Awareness is an important part of incident response. • Board of Directors • Law Enforcement • Customers CIRT (Could be steering committee. ) ISO Everybody infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Asset Management Program infotex

Asset Management Program infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Business Continuity Program infotex

Business Continuity Program infotex

Business Continuity Program Business Continuity Plan Risk Analysis Scenario Responses Pandemic Ice Storm Tornado

Business Continuity Program Business Continuity Plan Risk Analysis Scenario Responses Pandemic Ice Storm Tornado Flood Fire infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Vendor Management Program Governance Policy Vendor Management Policy Search and Selection Contract Negotiations Threshold

Vendor Management Program Governance Policy Vendor Management Policy Search and Selection Contract Negotiations Threshold Risk Assessment Assigned Security Responsibility Security Sanctions Policy Ongoing Due Diligence Vendor Agreement Template Risk Analysis Procedure Threshold Risk Assessment Vendor Request Vendor Risk Determination Table Detailed Risk Assessment Checklists infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Security Standards infotex

Security Standards infotex

Security Standards infotex

Security Standards infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training User Awareness

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training User Awareness Training Customer Awareness Training Board of Directors Management Team infotex

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training Board of

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training Board of Directors User Awareness Training Customer Awareness Training Vendor Management Program Due Diligence Request Letter Management Team infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

IT Governance Policy Align IT with Business Board Member End Users (rotated) Management Team

IT Governance Policy Align IT with Business Board Member End Users (rotated) Management Team Define Governance Committee Membership Establish Steering Committee Authorize the ISO Requires Training at all levels Report Critical Security Breaches Delineates Annual Report to the Board infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

In this next section • We will learn why a multidisciplinary approach to technology

In this next section • We will learn why a multidisciplinary approach to technology risk assessments is critical. • We will find out the types of threats that need to be considered in a risk assessment. • We will see a typical risk assessment process. infotex

Summary: Managers Should • Clearly support all aspects of the information security program; •

Summary: Managers Should • Clearly support all aspects of the information security program; • Implement the information security program as approved by the board of directors; • Establish appropriate policies, procedures, and controls; • Participate in assessing the effect of security issues on the financial institution and its business lines and processes; infotex

Summary: Managers Should • Delineate clear lines of responsibility and accountability for information security

Summary: Managers Should • Delineate clear lines of responsibility and accountability for information security risk management decisions; • Define risk measurement definitions and criteria; • Establish acceptable levels of information security risks; and • Oversee risk mitigation activities. infotex

That’s straight out of FFIEC guidelines (page 6, Information Security Handbook) infotex

That’s straight out of FFIEC guidelines (page 6, Information Security Handbook) infotex

Information Security Program Equals IT Governance Program infotex

Information Security Program Equals IT Governance Program infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Risk Analysis Program infotex

Risk Analysis Program infotex

Four Primary Risk Assessments Business Impact Analysis Asset Criticality Analysis Technology Risk Assessment Vendor

Four Primary Risk Assessments Business Impact Analysis Asset Criticality Analysis Technology Risk Assessment Vendor Risk Determination infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2010/2011 • ISO Job Description & Interactions infotex

In this next section • We will learn the primary purposes of an IT

In this next section • We will learn the primary purposes of an IT Audit. • We will understand the need for riskbased auditing • We will learn the different types of audit tests. • We will be exposed to the need for good IT Audit metrics. infotex

The IT Audit infotex

The IT Audit infotex

Three Primary Purposes • Alignment with business mission • Appropriate risk management • Compliance

Three Primary Purposes • Alignment with business mission • Appropriate risk management • Compliance with applicable law infotex

Alignment w/ Business Mission • Strategy Alignment • Facilitate Execution of Business Tactics •

Alignment w/ Business Mission • Strategy Alignment • Facilitate Execution of Business Tactics • Demonstrate Return on Investment infotex

Risk Management Assurance • Test of Risk Assessment Process • Test of Management Awareness

Risk Management Assurance • Test of Risk Assessment Process • Test of Management Awareness • Test of Declared Controls • Test of User Awareness • Escalate Risk Acceptance decisions to the Board of Directors infotex

Comply with the Law! • FFIEC Guidelines as the Framework • Cobi. T as

Comply with the Law! • FFIEC Guidelines as the Framework • Cobi. T as Framework for SOX banks • State laws may introduce individual compliance framework needs (SB 1386 in California) infotex

Risk-based Auditing • Ensures testing is appropriate • Delivers Value to Audit Process •

Risk-based Auditing • Ensures testing is appropriate • Delivers Value to Audit Process • Relies heavily on bank risk assessment infotex

Risk-based Auditing • Test the controls that protect the highest value assets. • Test

Risk-based Auditing • Test the controls that protect the highest value assets. • Test the controls that protect the most likely targeted assets. • Test the controls that management has declared mitigate the MOST risk (highest delta control value). infotex

Risk-based Auditing Inherent Risk Residual Risk Delta Control infotex

Risk-based Auditing Inherent Risk Residual Risk Delta Control infotex

Types of IT Audit Tests • Technical • Non-technical infotex

Types of IT Audit Tests • Technical • Non-technical infotex

But first … • Capture-the-flag versus assessment infotex

But first … • Capture-the-flag versus assessment infotex

Types of IT Audit Tests • IT Governance Review – – GLBA Compliance Policy

Types of IT Audit Tests • IT Governance Review – – GLBA Compliance Policy and Procedure Review Testing of Non-technical Controls Involves interviewing “all four corners” of the bank infotex

Types of IT Audit Tests • Technical Vulnerability Assessments – Perimeter • Penetration Testing

Types of IT Audit Tests • Technical Vulnerability Assessments – Perimeter • Penetration Testing • Vulnerability Scanning of Perimeter • Confirmation – Internal Network • Vulnerability Scanning • Network Configuration Audit • Confirmation infotex

Types of IT Audit Tests • Social Engineering Tests – Two purposes • Test

Types of IT Audit Tests • Social Engineering Tests – Two purposes • Test Awareness • Test Incident Response – Spear Phishing – Pretext Calling – Password File Analysis – Orchestrated Attacks infotex

IT Physical Security • Physical Breach Tests • Walk-through’s • Dumpster Diving – Trash-can

IT Physical Security • Physical Breach Tests • Walk-through’s • Dumpster Diving – Trash-can Diving • Physical Security Checklists infotex

Checklist Tests • IT Governance • Physical Security • Network Configuration Audits Be careful

Checklist Tests • IT Governance • Physical Security • Network Configuration Audits Be careful that findings are risk ranked. infotex

Risk Metrics • Should be based on likelihood and impact • Some auditors will

Risk Metrics • Should be based on likelihood and impact • Some auditors will also factor in ease of remediation • You should be interested in residual risk, anticipated residual risk, and risk reduction (or “delta control”) infotex

Risk Metrics • Comparing risk from one year to the next, or from one

Risk Metrics • Comparing risk from one year to the next, or from one bank to the next, is difficult • What’s important is knowing that the management team understands the metrics and the risk infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

In this next section • We will learn the primary purposes of the annual

In this next section • We will learn the primary purposes of the annual Vendor Due Diligence Review. infotex

Vendor Management Program Governance Policy Vendor Management Policy Search and Selection Contract Negotiations Threshold

Vendor Management Program Governance Policy Vendor Management Policy Search and Selection Contract Negotiations Threshold Risk Assessment Assigned Security Responsibility Security Sanctions Policy Ongoing Due Diligence Vendor Agreement Template Risk Analysis Procedure Threshold Risk Assessment Vendor Request Vendor Risk Determination Table Detailed Risk Assessment Checklists infotex

Selection Process Risk Assessment Requirements Definition vs. RFP Responses Due Diligence Evaluation infotex

Selection Process Risk Assessment Requirements Definition vs. RFP Responses Due Diligence Evaluation infotex

Vendor Due Diligence Checklist • Makes the annual review go so much better! •

Vendor Due Diligence Checklist • Makes the annual review go so much better! • . . . at least after the first one. infotex

Vendor Risk Assessment Process Threshold Risk Assessment Risk Management Program Vendor Due Diligence Request

Vendor Risk Assessment Process Threshold Risk Assessment Risk Management Program Vendor Due Diligence Request Due Diligence Checklist Report to Board Detailed Risk Assessment Missing Controls infotex

Outputs of Annual Review ØMissing controls and anticipated safeguards should input into the IT

Outputs of Annual Review ØMissing controls and anticipated safeguards should input into the IT Risk Assessment. infotex

Remember this diagram? Risk Assessments Business Impact Analysis Technology Risk Assessment Vendor Due Diligence

Remember this diagram? Risk Assessments Business Impact Analysis Technology Risk Assessment Vendor Due Diligence infotex

Remember this diagram? Risk Assessments Business Impact Analysis Technology Risk Assessment Vendor Due Diligence

Remember this diagram? Risk Assessments Business Impact Analysis Technology Risk Assessment Vendor Due Diligence This (and missing vendor controls) is where Vendor Due Diligence plugs into the overall Risk Assessment Process. infotex

Outputs of Annual Review ØMissing controls and anticipated safeguards should input into the IT

Outputs of Annual Review ØMissing controls and anticipated safeguards should input into the IT Risk Assessment. ØThey will be deployed as per risk severity in a reasonable period of time. infotex

Outputs of Annual Review ØFinally, risk acceptance decisions should be escalated to the board

Outputs of Annual Review ØFinally, risk acceptance decisions should be escalated to the board of directors by the ISO in the Annual Report. infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

In this next section • We will learn some of the fundamental responsibilities of

In this next section • We will learn some of the fundamental responsibilities of the Information Security Officer. • We will see how the ISO interacts with various areas of the bank. • We will understand how we can utilize the ISO to better manage our own technology risk. infotex

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset

Access Management Risk Analysis Information Technology Governance Program Awareness Incident Response Governance Policy Asset Management Business Continuity Security Standards Vendor Management infotex

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training Board of

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training Board of Directors User Awareness Training Customer Awareness Training Vendor Management Program Due Diligence Request Letter Management Team infotex

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training User Awareness

Awareness Program Governance Policy Awareness Program Management Awareness Training Technical Awareness Training User Awareness Training Customer Awareness Training Board of Directors Management Team infotex

Risk Management Program Awareness Program Management Awareness Training Technical Awareness Training User Awareness Training

Risk Management Program Awareness Program Management Awareness Training Technical Awareness Training User Awareness Training Customer Awareness Training Board of Directors Management Team infotex

BAT Tools • Board Awareness Training (video webcast is available) • Annual Report –

BAT Tools • Board Awareness Training (video webcast is available) • Annual Report – Risk Analysis Executive Summary – Vendor Due Diligence Results – Summary of Critical Security Breaches – Strategy • Policy Approval Process infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

New Risks in 2011/2012 • Targeted Malware attacks (Zeus, Russian Business Network, Chinese, and

New Risks in 2011/2012 • Targeted Malware attacks (Zeus, Russian Business Network, Chinese, and spin-offs) • Social Media Usage (by employees AND the bank) • Mobile Banking Deployment infotex

Orchestrated Attacks • Usually combining: – Malware from drive-by attack sites – Phishing –

Orchestrated Attacks • Usually combining: – Malware from drive-by attack sites – Phishing – Pretext Calling • Assets Attacked: – Customer credentials – ACH – On-line Banking infotex

Social Media • Bank site risks – Compliance (disclosures) – Negative Comments – Poor

Social Media • Bank site risks – Compliance (disclosures) – Negative Comments – Poor Content • Employee risks – General Users – Management Team Members infotex

Horse Before the Cart: Top 5 Mobile Banking Risks infotex Wireless Banking Risks 1.

Horse Before the Cart: Top 5 Mobile Banking Risks infotex Wireless Banking Risks 1. 2. 3. 4. 5. Late Majority Adoption Tepid Adoption Security Risk Compliance Risk Strategic Risk infotex

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The

Today’s Agenda • Management Awareness Resources • Five Tenets of IT Governance • The IT Governance Program – The Risk Assessment – Information Technology Audits – Vendor Due Diligence – Awareness Training • New Risks for 2011/2012 • The 2011 Audit Results infotex

In this next section • We will learn some of the fundamental responsibilities of

In this next section • We will learn some of the fundamental responsibilities of the Information Security Officer. • We will see how the ISO interacts with various areas of the bank. • We will understand how we can utilize the ISO to better manage our own technology risk. infotex

ISO Job Description • The single point of contact. . . liaison. . .

ISO Job Description • The single point of contact. . . liaison. . . for all matters involving Information Security (and often IT Governance as a whole. ) • The “inside consultant” on IT Security Matters. • The person who teaches us how to manage technology risk. infotex

ISO Teams • Steering Committee: Member • Technical Staff: Member • CIRT: Team Leader

ISO Teams • Steering Committee: Member • Technical Staff: Member • CIRT: Team Leader • Risk Assessment: Team Leader • Vendor Management: Team Leader • Business Continuity Plan: sometimes the BCP coordinator, often not. infotex

What the ISO does. . . • Writes policies and procedures. • Filters vulnerability

What the ISO does. . . • Writes policies and procedures. • Filters vulnerability news down to what the bank needs to know. • Writes agendas and reports for various meetings. • Activates awareness through reminders, tests, and training. infotex

ISO Job Description • Maintain the IT Governance Program • Ensure through measurement and

ISO Job Description • Maintain the IT Governance Program • Ensure through measurement and testing that the controls in the IT Governance Program are adequate and are being enforced. • Escalate Risk Acceptance Decisions to the Board • Educate, Motivate, and Activate Awareness. infotex

Awareness Life Cycle Educate Motivate Activate infotex

Awareness Life Cycle Educate Motivate Activate infotex

Four Corners Board of Directors Customers Oversight Committee Management Team Vendors Users Technical Team

Four Corners Board of Directors Customers Oversight Committee Management Team Vendors Users Technical Team infotex

Board Level • Educate • Annual Report, Awareness Training • Motivate • Risk Analysis,

Board Level • Educate • Annual Report, Awareness Training • Motivate • Risk Analysis, VDD Results, Audit Findings • Activate • Policy Approval, Strategy, Budget infotex

Management Team • Educate • Motivate • Activate • Annual Awareness Training, Applicable Policies

Management Team • Educate • Motivate • Activate • Annual Awareness Training, Applicable Policies and Procedures (see distribution list) • Annual Report to the Board, Audit Results • Risk Analysis, Vendor Due Diligence infotex

Technical Team • Educate • Motivate • Activate • IT Audit Program, Security Standards,

Technical Team • Educate • Motivate • Activate • IT Audit Program, Security Standards, Policies and Procedures, Comprehension Testing, BCP Testing Plan • Auditing, Monitoring, Testing, Vulnerability Assessments • Vulnerability Reports, Conferences, CPE infotex

Users • Educate • Motivate • Activate • Acceptable Use Policy • Annual Awareness

Users • Educate • Motivate • Activate • Acceptable Use Policy • Annual Awareness Training, Comprehension Tests • Social Engineering Tests, Exercises, Reminders infotex

Customers • Educate • Motivate • Activate • Flyers, Knowledgeable Employees • Annual Awareness

Customers • Educate • Motivate • Activate • Flyers, Knowledgeable Employees • Annual Awareness Training • Stuffers, Web Site Announcements infotex

Vendors • Educate • Motivate • Activate • Due Diligence Request Letter, Phone Call

Vendors • Educate • Motivate • Activate • Due Diligence Request Letter, Phone Call • Contract Negotiations, Due Diligence Request Letter, AP New Vendor Form • Ongoing discussion emphasizing security. A call when something doesn’t seem right. infotex

On the Portal. . . • Information Security Officer Job Description infotex

On the Portal. . . • Information Security Officer Job Description infotex

How should we summarize? infotex

How should we summarize? infotex

Interactions infotex

Interactions infotex

ISO must interact with: • Board of Directors – Annual Report to the Board

ISO must interact with: • Board of Directors – Annual Report to the Board – Risk Acceptance Decisions – Policy Approval infotex

ISO must interact with: • Oversight Committee – Internal Auditing – Monitoring – Audit

ISO must interact with: • Oversight Committee – Internal Auditing – Monitoring – Audit Reports – Vulnerability Assessments infotex

ISO must interact with: • Management Team – Risk Analysis – Training – Vendor

ISO must interact with: • Management Team – Risk Analysis – Training – Vendor Due Diligence – Access Authorization Review – Budget – Incident Response infotex

ISO Must Interact With: • The you-wouldn’t-expect interactions – Human Resources • Policy Development

ISO Must Interact With: • The you-wouldn’t-expect interactions – Human Resources • Policy Development and Enforcement • Incident Response Team • Risk Assessment • Orientation – Marketing • Customer Awareness Training • Public Presence Security Controls • Use of Social Media infotex

ISO must interact with: • Technical Team – Security Standards – Incident Response –

ISO must interact with: • Technical Team – Security Standards – Incident Response – Vulnerability Assessments – Audits – Network Monitoring infotex

ISO must interact with: • Users (all employees) – Acceptable Use Policy – Annual

ISO must interact with: • Users (all employees) – Acceptable Use Policy – Annual Awareness Training – Policy Enforcement – Security Reminders and Notices – Testing – Incident Response – Answering Questions infotex

ISO must interact with: • Vendors – Vendor Risk Analysis – Vendor Due Diligence

ISO must interact with: • Vendors – Vendor Risk Analysis – Vendor Due Diligence Requirements – Risk Acceptance infotex

ISO must interact with: • Customers – Customer Awareness Training – Incident Response infotex

ISO must interact with: • Customers – Customer Awareness Training – Incident Response infotex

Thank you! Don’t forget the Evaluations! infotex

Thank you! Don’t forget the Evaluations! infotex

The Workshop Portal • List of boilerplates and related websites. • Electronic Version of

The Workshop Portal • List of boilerplates and related websites. • Electronic Version of Documents, Articles, and Boilerplates for your use. – mat 2009. infotex. com (all lower case) – Your user name. . . mat 2009 (all lower case) – Th 3!b@#1 is the password. • Portal is classified “internal use. ” infotex