Showing posts with label operational risk. Show all posts
Showing posts with label operational risk. Show all posts

Saturday, January 17, 2026

Intelligence Sharing: Responsibility to Provide...

Back in the summer of 2008, the "Need to Know" was now finally becoming extinct. Intelligence Communities around the globe began ever so slightly changing their behavior.

The Office of the Director of National Intelligence (ODNI) had released it's Information Sharing Strategy:

The Office of the Director of National Intelligence was announcing the first-ever strategy to improve the ability of intelligence professionals to share information, ultimately strengthening national security.

The "Responsibility to Provide" attitude combined with a "Rule-set" reset could get the entities moving the right direction. Risk Managers in institutions in the private sector have been grappling with this business issue for multiple decades.

The reality that the FBI, NSA, CIA and DHS are sharing more effectively will only be evident in actual behaviors, not technology.

The new mantra "Responsibility to Provide" would be repeated over and over but where is the evidence?  

The culture shift was predicated on the ability to manage risks associated with mission effectiveness and disclosure of sensitive information. A Trusted Environment.

This new information sharing model is not revolutionary and requires the same care with privacy, information security and civil liberties that we all expect when it comes to personal identifiable information.

Adding new incentives to share information or rewards for doing so will soon be the norm and the behavior changes will be evident. Great care will be given to the ability to protect sources and methods of collection.

Creating a "Single Information Environment" (SIE) will improve the ability for analysts and investigators to get access earlier and to discover what exists. Enhancing collaboration across the IC community would be a strategic goal and has been a dream for over twenty years.

So let's go back to the "Trust Model" for a minute:

  • Governance: The environment influencing sharing.
  • Policy: The "rules" for sharing.
  • Technology: The "capability" to enable sharing.
  • Culture: The "will" to share.
  • Economics: The "value" of sharing.

A 500 day plan was then in place. The integration has now been reemphasized even today. Let's make sure that our vigilance continues and on this Martin Luther King Jr. weekend, our spirits are reenergized...

Saturday, January 18, 2020

Corporate Social Responsibility: An Era for New Leadership...

Here are a few of this mornings top news stories. It seems that Operational Risks have us surrounded and yet many organizations are still in denial that anything will impact them directly:

Libyan Oil Exports Blocked Ahead of Berlin Peace Conference
By Salma El Wardany
January 18, 2020, 4:46 AM PST Updated on January 18, 2020, 7:16 AM PST

World News
China reports new virus cases, raising concern globally before key holiday
Published Sat, Jan 18 20206:34 AM EST

Why Iran plane disaster protests mark most serious test yet

By Amir Azimi BBC Persian service 18 January 2020

U.S. Government Confirms Critical Browser Zero-Day Security Warning For Windows Users

Davey Winder Cybersecurity

How long will this naivete go on in your company, city, state or country?  Maybe it's time for more Corporate Social Responsibility and a renewed focus on training new leaders.

As the finger pointing continues and the documents of the day are debated, there is one strategy that has been with us for many years, and many have forgotten.  It is called Corporate Social Responsibility (CSR). CSR is gaining new emphasis around the globe:

Mary Parker Follett's (1869-1933) thoughts on democracy, society and management have inspired business leaders in fits and starts during the 20th century and they deserve to be revisited as we move forward in this century.

What is the important role that businesses play in society?  She gave serious attention to what we now call corporate social responsibility, a topic of great interest in today's boardrooms and business schools.

One thing is certain. All of the employees and citizens on the planet want leadership and courage from the ordinary person next door.
The citizen soldier who is willing and capable of leading the people around them in the face of a sudden catastrophic crisis.
In the midst of an important ethical decision. In the moment of the day, are "Leaders Born, Not Made"?  What would Mary Parker Follet and Laura Tyson have to say:

"Leaders can be taught, and should be keen on sharpening their skills as rigorously as a surgeon. In 1933, she put it plainly: managers must realise that they, as professional[s], are assuming grave responsibilities, that they are taking part in one of the large functions of society, a part which, I believe, only trained and disciplined [business people] can hope to take with success."

As the Operational Risks continue to surround our corporate enterprises, it's imperative we look at where we are spending our money and deploying our resources.

What would happen to our preparedness, readiness and recovery capabilities if we just reallocated 5% of the corporate marketing budget to the Risk Management budget?

If we did, then we might find ourselves with fewer calls to the Court house, State house and the White House.

Saturday, November 24, 2018

Predictive Profiling: The Human Firewall...

In Harrison Ford's 2006 movie Firewall the viewer is entertained with a combination of a Seattle bank heist, kidnapping and good old fashioned Hollywood chase and fight scenes. There is even a degree of deception and conspiracy mixed in, to spice up the story line. The plot is full of social engineering lessons, that even those with little knowledge of high technology can learn a thing or two.

While the actual high technology bank heist turns out to be nothing more than a simple stealing of account numbers and a transfer of $10,000 from 10,000 high net worth customers, the movie title is a ploy. In only one short sequence is there any focus on the fact that the bank is being attacked on a daily basis from other locations on the other side of the globe.

Those attackers using new and increasingly sophisticated strategies, are consistently giving financial institutions new challenges to secure their real assets; binary code.

In early 2005, a criminal gang with advanced hacking skills had tried to steal GBP 220 million (USD 421 million) from the London offices of the Japanese banking group Sumitomo and transfer the funds to 10 bank accounts around the world. Intelligence on the attempted theft via key logging software installed on banks' computers has been circulating in security circles since late last year after warnings were issued to financial institutions by the police to be on the alert for criminals using Trojan Horse technology that can record every key stroke made on a computer.
In this case and even in the movie, the "Insider" is a 99.9% chance. A person has been bribed, threatened or spoofed in order for the actual fraud or heist to occur. The people who work inside the institution are far more likely to be the real source of your crime, rather than the skilled hacker using key logging software. More and more the real way to mitigate these potential risks is through behavior profiles and analysis.

The human element, which relates to awareness, can't be ignored any longer. And this can only be changed through education, training, and testing of employees. An organization that procures technology worth millions, is naive if you don't invest in educating your employees to make the investment worthwhile.

Sometimes the human element stands alone. Awareness, detection and determination of threat, deployment, taking action and alertness are key ingredient for security.

Predictive Profiling comes into play as organizations recognize that detecting threats starts long before the firewall is compromised, falsified accounts established and bribes taken.

The Israeli Airline El Al has known for a long time the power of the "Human Factor" as a force in security. An empowered, trained and aware group of people, will contribute to the layered framework as a force multiplier that is unequaled, by any other technology investment.

Firewall The Movie, was a wake-up call for those institutions who still have not given their employees more of the skills and tools, for detecting human threats long before any real losses occur.

Friday, September 21, 2018

Calm Before The Storm: Time to Dare and Endure...

"This is no time for ease and comfort.  It is time to dare and endure."
  --Winston Churchill

Have you ever felt the calm before the storm?  Literally, you can feel it.  Yet this is exactly the time you should not be complacent.  It is a time to Think, to Plan and to Act.

Almost each day the headlines from our global news feeds tells the story.  Countries, Corporations, Communities and Chief Executive Officers seemingly caught off guard.  Surprised by the threat of the cyclone, the ransomware, the drought, or the economic volatility.

Over-The-Horizon (OTH) thinking requires a mindset, that anticipates change.  It embraces the calm before the storm.  Yet it is the uncertainty of an unpredictable world, that should motivate you.  You have seen it before, as the environment you operate in reaches a place and feeling of calm.

Your focus should be on better understanding the indicators.  What are the indicators in your particular environment, that signals the warning?  How will you know when it is time to act and to be more proactive, in your situational awareness?  When will you engage in purposeful thinking and planning to increase your readiness to act?

History has recorded incidents of economic downturn that have caught some investors and corporations off guard.  There have been communities suddenly consumed by fire, tornadoes or cyclones.  How many places of work and worship, are now the crime scenes of active shooters and/or terrorist bombers?  When was the last time a key leader or linchpin at your company was diagnosed with cancer?

Operational Risk Management (ORM) is a discipline that never sleeps.  It is your mechanism and systems for continuously thinking, planning and then executing in anticipation of change.  When was the last time your team actually had a dialogue about the vital topic of your organizational "Business Continuity?"

You see, complacency is one of our greatest threats.  It is the thought that it will never happen to us.  It is the thought that you are invincible.  Guess what?  You are only seconds away from catastrophic change.  To your country, corporation, community or your most vital personnel.

It is time to dare and endure.  You have the power to begin right now.

Tap the icon for your calendar and look at the next 60 days.  Certainly there are at least one week where you have 2 days you could devote to leading your team.  Gathering them together, away from the distractions of your enterprise.

The strategy to challenge your leaders, to ask them to think, to engage in spirited dialogue and the outcomes you seek, will produce organizational endurance.  What are you waiting for?

Sunday, May 13, 2018

InTP: Insider Threat Via Critical Infrastructure...

The private sector organizations of the United States are vital to the protection and security of the Homeland.  The private sector owns a majority of our assets and Critical Infrastructure Protection (CIP) remains a priority as a result of the latest asymmetric threats.  Securing Critical Infrastructure sectors includes:
  • Chemical:
  • Commercial Facilities:
  • Communications:
  • Critical Manufacturing:
  • Dams:
  • Defense Industrial Base:
  • Emergency Services:
  • Energy:
  • Financial Services:
  • Food and Agriculture:
  • Government Facilities:
  • Healthcare and Public Health:
  • Information Technology:
  • Nuclear Reactors, Materials, and Waste:
  • Transportation Systems:
  • Water and Wastewater Systems:
The National Strategy to Secure Cyberspace, emphasizes the importance of public/private partnerships in securing these critical infrastructures and improving national cyber security.
Similarly, one focus of the Department of Homeland Security is enhancing protection for critical infrastructure and networks by promoting working relationships between the government and private industry.

The federal government has acknowledged that these relations are vital because most of America’s critical infrastructure is privately held.  Further, the networks of our global super-infrastructure are tightly “coupled”—so tightly interconnected, that is, that any change in one has a nearly instantaneous effect on the others.

Attacking one network is like knocking over the first domino in a series: it leads to cascades of failure through a variety of connected networks, faster than most human managers can respond.

We realize that there are many facets of CIP, yet where should we be allocating resources?  The vigilance within our organizations has not changed and is based upon previous studies done by CERT and the US Secret Service:
"A system administrator, angered by his diminished role in a thriving defense manufacturing firm whose computer network he alone had developed and managed, centralized the software that supported the company’s manufacturing processes on a single server, and then intimidated a coworker into giving him the only backup for that software. Following the system administrator’s termination for inappropriate and abusive treatment of his coworkers, a logic bomb previously planted by the insider detonated, deleting the only remaining copy of the critical software from the company’s server. The company estimated the cost of damage in excess of $10 million, which led to the layoff of some 80 employees." U.S Secret Service and CERT Coordination Center/SEI Insider Threat Study: Computer System Sabotage in Critical Infrastructure Sectors

Insider Characteristics

The majority of the insiders were former employees.

• At the time of the incident, 59% of the insiders were former employees or contractors of the affected organizations and 41% were current employees or contractors.

• The former employees or contractors left their positions for a variety of reasons. These included the insiders being fired (48%), resigning (38%), and being laid off (7%).

Most insiders were either previously or currently employed full-time in a technical position within the organization.

• Most of the insiders (77%) were full-time employees of the affected organizations, either before or during the incidents. Eight percent of the insiders worked part-time, and an additional 8% had been hired as contractors or consultants. Two (4%) of the insiders worked as temporary employees, and one (2%) was hired as a subcontractor.

• Eighty-six percent of the insiders were employed in technical positions, which included system administrators (38%), programmers (21%), engineers (14%), and IT specialists (14%). Of the insiders not holding technical positions, 10% were employed in a professional position, which included, among others, insiders employed as editors, managers, and auditors. An additional two insiders (4%) worked in service positions, both of whom worked as customer service representatives.


Making sure that you have a robust workplace awareness program is yet one key component in addressing the "Insider Threat" and our resilience.

More importantly, the timing may have been the perfect launch point for other malfeasance from non-state actors who lie in their "Lone Wolf" mode, waiting to strike.

And while the scenario could be well contained, the timing could create opportunities for the "Black Swan" outlier inside your enterprise.

It's never to early to plan for the unimaginable, all happening in the same geography and the same time frame.  Revisit your "Insider Threat Program" (InTP) and Critical Infrastructure Resilience today...

Saturday, July 29, 2017

OPS Risk: Choosing Service Over Self-Interest...

Accountability and ownership are two vital elements of any operational risk professionals mindset, if they are to accomplish real results.  In order to gain this mindset as a professional, you have to be able to work along side others, who have these ingrained into their character and DNA.

What are you accountable for in your team or organization?  You are accountable for the stewardship of your particular mission at this point in time with a clear vision of the results that are envisioned.

You are not accountable to anyone but yourself and the team you have assembled for this particular set of tasks and outcomes.  The Operational Risks that you will encounter and those that you decide to mitigate or avoid are entirely up to you and your team, long before you set out to accomplish the mission.

Do you have ownership of the results desired?  You must have ownership of the operational risks that may and will occur if you and your team are to survive whatever known and unknown challenges may come your way.  Who are some of the best of the best in the profession of Operational Risk Management (ORM) over the past few decades?

Neil Armstrong and Buzz Aldrin are just two:
Of course, it was less than a year later that Armstrong himself would make the biggest step. After a three day trip to the moon, Armstrong, Aldrin and Collins entered lunar orbit on July 19. On July 20, Armstrong and Aldrin began their descent towards the surface inside Eagle, the lunar landing module. The flight to the surface did not quite go as planned. During the descent several alarms from the flight guidance computer distracted the astronauts. The onboard computers were inundated with extraneous radar information, but the alarms were determined not to be a problem. 
But Armstrong also noticed he and Aldrin were flying faster than expected across the lunar surface and were likely going to overshoot their landing site. As the Eagle passed 1,500 feet above the surface, Armstrong saw they were heading for a crater. He thought this might be a good option as it would have “more scientific value to be close to a large crater.” But the steep slope and big rocks did not provide a safe place to land. 
As they continued to fly over areas covered with large rocks and boulders, Armstrong took over control of the Eagle and continued flying it manually. He was able to use his training from the LLTV to maneuver as they continued to descend to the surface. But all of the maneuvering was using up propellant. At 200 feet above the surface, Armstrong finally was able to find a place to land. 
Aldrin: Eleven [feet per second] forward. Coming down nicely. Two hundred feet, four and a half down.
Armstrong: Gonna be right over that crater.
Aldrin: Five and a half down.
Armstrong: I got a good spot.
Aldrin: One hundred and sixty feet, six and a half down. Five and a half down, nine forward. You’re looking good. 
As they passed 75 feet mission control in Houston determined the Eagle only had 60 seconds of fuel left. Armstrong says he wasn’t terribly concerned about the low fuel situation, “typically in the LLTV it wasn’t unusual to land with 15 seconds left of fuel.”
About 40 seconds later Armstrong made a final few maneuvers before announcing the landing was complete. 
Armstrong: Shutdown.
Aldrin: Okay. Engine stop.
Houston: We copy you down, Eagle.
Armstrong: Houston, Tranquility Base here. The Eagle has landed.
Think about your team.  Is the boss dictating from the top on your every move or are they side-by-side with equal accountability and ownership of the results of the mission.  NASA puts rock star top gun pilots behind the controls of lunar missions for a good reason.  It is because they know that they are not in control, ultimately the pilots are working together.

So if you find that in your next corporate or organizational project that the boss from afar is telling you what to do at every moment, it's time to eject.  A true Operational Risk professional understands the mission and the desired results.

They have accountability and ownership of the tasks necessary to achieve the results.  Their stewardship of the project, with their fellow team members will be able to adapt to any changing environment or sudden challenges.

If you are the boss that has responsibility for the team and the successful outcome of the mission, what have you done to enhance each of their skills, knowledge and experience to deal with operational risks?    You may be asking at this point "How" do I do this?  This isn't about giving you suggestions or to show you where it is working and how to do it.

This is about service before self-interest and your ability to think of yourself as an equal on the team. Just one more vital asset with the same sense of accountability and ownership for the overall mission. That's it.

Your team needs you as one more set of brains, hands and talents to solve the operational risks that will be on their way.  How you behave and perform in light of these new found challenges, may very well be the one thing that determines whether your team lives, or survives.
To serve. To be safe. To know what freedom feels like.
Author, Peter Block - Stewardship - Choosing Service Over Self-Interest
Neil Armstrong was a true Operational Risk Professional...God speed.

Saturday, June 24, 2017

Walking the Talk: Asymmetric Lessons Learned...

Operational Risk Management (ORM) is about "Walking the Talk." What are you advocating in your solutions or services and advice to clients or within your own organization? When you "Walk the Talk", this means that you believe in and demonstrate first to yourself and your own organization that you execute and comply with what you say is policy and is a key factor in your own Continuity of Business Operations.

You carry out in a demonstrable form the rule-sets, best practices, ethics and behaviors that you are asking your own customers and your suppliers to follow. Your failure to do so, can have tremendous ramifications.  Nicholas Weaver explains:
The payload of CrashOverride is rather elegant in its simplicity; in a way it’s reminiscent of how a toddler might sabotage the lights at home. Once CrashOverride is running on a control system, it begins by mapping out all the circuit breakers. Once the payload knows where all the switches are, it can launch the primary malicious attack, either by turning off all the switches or—potentially more catastrophically—by repeatedly flipping them on and off until the substation in question is isolated.
Asymmetric Warfare is about an indirect strategy and the ability to compromise your target through non-traditional methods.  You and your organization might just be a pawn in a more sophisticated, planned and smart attack on a much more worthy adversary. Whether the intended target is a Critical Infrastructure organization in the financial, energy or defense industrial base (DIB) doesn't really matter.

Supply Chain Risk Management (SCRM) is not just about validating where and how embedded circuits, EPROMs or other systems software are ensured for quality and without tampering. SCRM is about your vendors themselves being compliant within their own enterprise with the manufacturing of their own products or the operational environment of their solution ecosystem.

The trust and confidence of your extended partners, clients, contractors and key suppliers is ultimately about "Walking the Talk." 
Malicious and trusted insiders pose a range of challenges in terms of counterintelligence risks and physical threats, and experts say policy needs to catch up quickly to the new technologies available to help mitigate the problem.  Mackenzie Weinger is a national security reporter at The Cipher Brief
If you are a prudent CSO or CISO of a critical infrastructure product or services organization, beware. You may just be what the enemy needs to perpetuate their asymmetric operations on the Homeland. Beyond your own reputation being at stake, so too is the trust, safety and security of the entire economic infrastructure of the United States.

Saturday, May 06, 2017

Quiet Professional: A Leader Remembered...

Leadership has been written about since humans have been writing and recording history.  How leaders have been described, documented and chronicled over our existence here on Earth, comes back to the definition of leadership:  noun, the act or instance of leading - the office or position of a leader.

The leader and the characteristics of a particular person, are typically what is written about to document someone who is in a position of leadership.  It may start as an oldest sibling, leading younger sisters or brothers when Mother or Father is not around, or even deceased.

It may have all started in a school or church group, or as camp counselor, President of that social group, and then someday even also as a Mother or Father.  Leaders and leadership have so many facets and is in many cases just present, or absent in someone's life.

Over history, the definition of a person who has been or is a current leader, has several synonyms:

Synonyms boss man, captain, chief, foreman, head, headman, helmsman, honcho, jefe, kingpin, boss, master, taskmaster

In the broad and complex world we live in, these synonyms only describe a small facet of what true leadership is all about.  The vast realm of Operational Risk Management (ORM) also gives us additional context, when it comes to true leadership and the goal of ever increasing our overall safety, security and trust.

When someone writes your eulogy as an Operational Risk Leader, what will they say.  How will they describe you?  Perhaps none of the synonyms above are even mentioned.  Why?

It is because you are known as a "Quiet Professional."  Someone who is a leader and continues to exemplify the act of leading in so many ways and far too detailed to describe in words.  Yet you continue to aspire to improve, to listen, to learn.  You don't know it yet, but at your eulogy, others will describe you as a "Quiet Professional."

The "Quiet Professional" operates through life serving others, doing their best to continuously learn and improve on their greatest skills.  Yet at the same time, the true leader also recognizes the areas of knowledge and expertise they don't possess and so they will create alliances with others who do.

The small group, the team, the cohort, the class, the board, the executive office, the assembly, the country - they have a combination of leaders who are diverse in their skills, knowledge and aspirations and yet simultaneously, they have the same single mission.

How others will describe you and your leadership at your eulogy, is completely in your control as a human.  What are the characteristics of your particular way of leading and operating as a "Quiet Professional (QP)?"  Maybe it will sound like this:

QP was a person that not many people knew very well and that was just fine with them.  QP worked on becoming and performing each day, as the best they could be, with each person they encountered in life, one-to-one.  As a brother or sister, as a mother or father, as a friend and servant leader of others.

QP was always watching out for others.  Looking around the corner or over the horizon.  It was for three reasons.  Curiosity, building trust and continuous learning.  It was because QP always wanted to improve and to aspire for that next level of perfection.  QP wanted others close to them to feel safe and secure.

QP wanted others to feel as if they could do anything and could achieve anything.  What ever their particular mission was that day, month or year.  QP wanted those closest to them to know, they were always going to be cared for and looked after,  no matter what happened.

QP will always be remembered for their kind heart and tremendous courage.  QP will be remembered for their fierce competitiveness and simultaneous compassion.  They will be remembered for their ability to love.  Their ability to forgive.  And QP will always be remembered for their leadership.

Are you a "Quiet Professional"?...

Saturday, April 01, 2017

True North: A Decision to Trust...

When you awakened this morning did you immediately know your "True North"?  Are you heading in the direction of your passion in life?  How do you know when you are off course and need to correct your path before it is too late?

This metaphor for knowing and feeling whether you are on the right path for your passion, begins with a visual sign.  A star in the distance to keep you focused and on track.  A reminder.  You know the one I am talking about.  Maybe it's the magnet on your refrigerator.  Is it a person?  Is it a place?  Or just a 3M Post-It note, placed strategically at your desk, to keep you centered.

Your particular "True North" is what keeps you going every day.  At certain intervals however, course corrections are always necessary, yet you don't want to deviate too long away from your desired outcome.

Any Operational Risk "Professional" understands the true mission because somewhere along the path, they have encountered difficulties and significant hardships.  And they have adapted.  They have pivoted.  They have endured the negative emotions and counter productive environment, to survive another day.

Now, think about the most difficult time in your life and how you were able to navigate back to "True North".  How did you do it?  How were you able to stay on course?  This is how.  You made a series of "Trust Decisions".

You made a decision to trust someone, something or some direction to navigate towards your "True North".  Who is it?  What is it?  Where is it?  Perhaps more importantly, Why is it?

Whether you are heading in the right direction requires a perseverance and a belief.  It means that you will have many emotions as you travel forward in the hours, weeks, years and decades ahead.  You can expect that to be the case, no matter what happens.

As you navigate your path towards your "True North" you must reflect along the journey.  What have you learned?  Why is this important?  It is because of these lessons and the knowledge that you have learned, that will now make a difference and influence your next "Trust Decision".
  • A Decision to Trust incorporates data that comes from a network of sensors.  These points of data collection are important to the future of your survival.  They are where you must continue to improve, correct and test in order to be assured that they are operating effectively and as planned.
  • A Decision to Trust is a series of calculations, that involves the data you are collecting from sensors.  The calculations and formula is different for each node or mechanism, that you are utilizing to achieve the outcomes you seek.
  • A Decision to Trust becomes automated, once you have the highest assurances that you can rely on your sensors and believe in the calculations.
Once you have determined your course and are relying on your sensors to be accurate, discipline is the final quest.  What discipline do you follow?  This is where you may now have the greatest risk of failure.  The risk you deviate from your discipline.  You forget your "True North".

Your direction and your ability to reach your destination, will be ultimately determined by your discipline...

God speed!

Sunday, March 12, 2017

Vault 7: Adapt to Live Another Day...

When you spend enough time in any austere environment, you begin to respect it's abilities to change rapidly.  You begin to respect the changing natural forces and how these new potential threats could become a new Operational Risk in just minutes.  The decisions that you make in the next few seconds, could mean a positive outcome or a significant catastrophe.

Will you turn right or go left?  Will you accelerate or slow down?  Will you ascend or descend?  These decisions that you make in your quest to adapt to your changing austere environment will forever be remembered.  Whether they are stored in the synapses of the brain or the log files of an autonomous system executing code, the trust decision is evident.

How long has it been since you really took a deep look at your decisions the past minute, hour or day?  This analysis of the evident decisions made and the environment that you are operating in will forever allow for growth or death.

Systems thinking and the continuous learning of a changing environment can happen at 12,000 feet above sea level at minus 10 degrees, or within the climate-controlled data centers or corporate offices of your global enterprise.  What are you doing today to help achieve new levels of trust, in order to survive another day?

Why is it that so many individuals are surprised when they get a call from their CxO or even corporate counsel that sounds like this?  "It looks like our Intellectual Property or Trade Secrets, are now in the hands of our competition".  "Our enterprise is encountering significant new risks to our ongoing operations and we must adapt immediately'.
Introduction
Just as American and European critical infrastructure executives were beginning to wrap their minds around the devastation of the Office of Personnel Management, ransomware erupted onto the scene. We then experienced concentrated DDoS attacks such as the Mirai botnet attack on Dyn, which enabled a quantum leap for cyber criminals of even the most novice of technical aptitude to wreak havoc on targeted organizations at the click of a button or for less than one bitcoin. Unfortunately, adversaries continue to evolve, and cyber defense remains a reactionary culture. Numerous, persistent and adaptive, cyber-adversaries can more easily, remotely and locally besiege critical infrastructure systems, than information security personnel can repel the incessant barrage of multi-vector attacks. Now, all techno-forensic indicators suggest that an under-discussed cyber-kinetic attack vector will ubiquitously permeate all critical infrastructure sectors due to a dearth of layered bleeding-edge military grade cyber security solutions. Unless organizations act immediately, in 2017 The Insider Threat Epidemic Begins.
Some people are surprised.  Yet it is the small team of "Operational Risk Professionals" in your enterprise, that have been continuously training, operating in clandestine and unknown environments and learning each day, for this moment.  They are not surprised.  They are the people who have designed their operations and systems to be resilient, to endure austere environments and to adapt to live another day.

Seek out these people in your organization.  Find the expert individuals in each of the departments or business units, that also interface with your external environment and supply chain.  Now look inside and in the mirror.  Where are the vulnerabilities inside?  How can you adapt your operations to create trust with employees and simultaneously make your organization more resilient?
Take the “Vault 7” CIA data Wikileaks released this week. Assuming it is legitimate, it originated from a network that presumably has a very small attack surface. Wikileaks expressly claims that the data is from “an isolated, high-security network situated inside the CIA’s Center for Cyber Intelligence in Langley, Virgina,” and experts agree that seems likely. And knowing that CIA networks are probably secure and defended supports the notion that the the data was either leaked by someone with inside access, or stolen by a well-resourced hacking group. It’s far less likely that a random low-level spammer could have just casually happened upon a way in.
 Build digital trust in your organization by better understanding the entire surface for potential attacks.  Analyze the rules that are in place now and how they might need to be changed according to the continuously changing environment you operate in.

Finally, adapt to live another day...

Sunday, February 19, 2017

Problem-Solving: Transparency of Startup Operational Risks...

The lifeblood of an organization is comprised of several key components to sustain and continuously grow the enterprise.  Founders, senior management, engineers, financial and legal subject matter expertise usually comes first.  Then once the minimum viable product or solution is ready for the intended market there is a mad dash to add the sales and business development resources.

Startup mentality that initiates the planning, demand generation and "Go-to-Market" execution for the growth engine have higher Operational Risk exposure.  Many founders and new entrepreneurs who have engineering or operational expertise, underestimate the need for substantial growth engine investment early in the startup timeline.

How many times have you attended "Demo Days" or other such events intended for the startup founders to pitch their new App or service solution, begging for a first customer?  You must recognize that the new Artificial Intelligence interface, the optimized algorithm or the faster encrypted communications is not going to create a new market overnight.

Entrepreneurs require a substantial immersion into the business environment of problem-solving.  It begins with the customer or client who detects that there is an area of risk that needs remediation.  How do you think companies like Symantec and McAfee first started?  The personal computers that were becoming so pervasive were encountering something now called malware.

Solving problems from the customers perspective requires a deep and focused process with the owners, operators and end users.  It requires substantial time being embedded at the customer level or with the people who perform their daily tasks.  You need to understand the risks that the customer is experiencing.

This "Diagnostic-to-Prescriptive" process is not new.  Yet how many times have those "Demo Day" entrepreneurs or "Accelerator" graduates ended their pitch, with a plea for a first customer?  This is a recipe for failure.

How can this be changed or addressed, in order to increase the number of successful new businesses?  What should we be doing to assist these new entrepreneurs in embracing the "Operational Risks" of a customer and inventing a new solution to solve their problems?

The engineers and inventors should embrace the idea of finding customers first, who have real and risk sensitive problems they can solve.  It is not enough to just change an interface, reduce the pricing and copy an App, to do the same general function.  How long will it now take for Snap to begin building their own data centers and infrastructure?

Entrepreneurs that utilize the "Go-to-Market" strategy early in their growth cycle, will simultaneously increase exposure to substantial Operational Risks.  Take that great idea or new "Minimum Viable Product" to an established business in the industry sector you think is going to listen.  Find the right business to adopt you as a problem-solver with this new solution and take the time to learn.

Once you have lived with the same problem across several different businesses, agencies or governments, it might be time to launch the "Go-to-Market" strategy for a single industry sector or country to start.  The learning phase and early adoption of a multitude of business development processes, will establish a more solid foundation for launching the new product / solution.

When you look at Snapchat and its growth cycle, it was not obvious up front, how privacy was going to be such a tremendous risk to the business.  How you can pivot quickly from understanding your customers appetite for transparency, to also provide a robust privacy policy program, is just one way to build a trusted set of repeat customers.
Snapchat Transparency Reports are released twice a year. These reports provide important insight into the volume and nature of governmental requests for Snapchatters' account information and other legal notifications.

Saturday, February 04, 2017

Higher Purpose: A Mission of Trust...

As you walk into that next meeting with another co-worker or even a colleague for a coffee catch-up, pause and reflect.  Think about how you could (1) make this encounter not only productive and (2) simultaneously enhance the relationship of trust.

All too often we are focused on getting something of value from the meeting.  We are blinded by the purpose of the meeting or have preconceived ideas on how the time together will be of value, or a waste of time.  Now think differently.

A true professional in any business, unit, agency or organization is there to "Build Trust".  The day-to-day or hour-to-hour interactions you have with others is vital.  A true professional in any domain, industry or vocation, can aspire to a higher purpose than the normal roles of a stated job description.

One thing is certain when it comes to meeting with other people and the value or outcomes obtained, trust is a major factor in the future outcomes of the relationship.  Have you ever wondered why certain people you meet, take so long to trust you?  How are you going to accomplish your intended purpose working with this superior or subordinate if they don't trust you?  What about that new client or business partner?

At the most fundamental level, the trust gurus and authors have been writing about a spectrum of trust for eons:
Zero Trust >>>>>Trust Exists >>>>>Implicit Trust

From ground zero of your first encounters with another person, your goal is to move towards a point on the spectrum where "Trust Exists".  Then your goal is to keep moving to the right and towards a place of "Implicit Trust".  This is when you don't even think about it anymore.  How many people do you know where this is the case, even within your own family?

So what?

As an Operational Risk professional, velocity is everything.  Yet you already know that uncontrolled velocity alone can be fatal.  The risk factors associated with business, government or the manufacturing process of a highly engineered electronic component are always present.  Always changing.  Creating new obstacles or new harm.  In our current state, 24x7x365 pervasively connected society, the trust factors are even more important and vital to moving towards "Implicit Trust".

Here are a few examples in the news this past year, where Operational Risk Management (ORM) was a factor:
Samsung Galaxy Note 7

On 2 September 2016, Samsung suspended sales of the Galaxy Note 7 and announced an informal recall, after it was found that a manufacturing defect in the phones' batteries had caused some of them to generate excessive heat, resulting in fires and explosions. A formal U.S. recall was announced on 15 September 2016.
Yahoo

When Yahoo said on Thursday that data from at least 500 million user accounts had been hacked, it wasn't just admitting to a huge failing in data security -- it was admitting to the biggest hack the world has ever seen.

Until Thursday, the previous largest known hack was the 2008 breach that hit almost 360 million MySpace accounts, according to a ranking by the "Have I been pwned" website. Like the Yahoo breach, the hack was only publicly disclosed this year after data was offered on a hacker forum.
National Healthcare Fraud

Attorney General Loretta E. Lynch and Department of Health and Human Services (HHS) Secretary Sylvia Mathews Burwell announced today an unprecedented nationwide sweep led by the Medicare Fraud Strike Force in 36 federal districts, resulting in criminal and civil charges against 301 individuals, including 61 doctors, nurses and other licensed medical professionals, for their alleged participation in health care fraud schemes involving approximately $900 million in false billings.
National Security Agency

A federal contractor suspected in the leak of powerful National Security Agency hacking tools has been arrested and charged with stealing classified information from the U.S. government, according to court records and U.S. officials familiar with the case.

In each one of these few example cases, relationships between people started with a meeting encounter.  Over time, the product, service or personal relationship outcomes involved a failure of people, processes, systems or external events.  The core components of Operational Risk Management (ORM).

Raising the level of trust across personal, business or government encounters is only possible, with effective "TrustDecisions".  The Decisions to Trust another person, product or service have several elements.  These are vital for the mission to grow towards "Implicit Trust" and simultaneously with the safety and security necessary to reduce the risk of failure.

The Mission

The mission as a co-founder of a new startup or the CEO of a Global 500 is to ensure the survival of the organization. We all know the failure rate for new companies. Just ask Dun & Bradstreet for the statistics or even your local Venture Capitalist who is celebrating failures these days. So beyond just the survival of the organization, is the imperative to establish a cultural and operating environment where people feel encouraged, creative and unencumbered to fulfill their job requirements and goals.

The Take Away

Operational Risks are inherent in any new or established business endeavor. The earlier the Operational Risk Management (ORM) design begins in the trusted relationship evolution, the more resilient you will ultimately become. The framework of the system-of-systems, the look and feel of the cultural environment and the end state visions are all at stake. Take the time and include the expertise to work on the "TrustDecisions" foundation of your enterprise.

Ensure the survivability of the new products or service solutions, that are so valuable to our economy and our nation.  Embrace Operational Risk Management early in your relationships and allow it's presence while it preserves all that you have worked for and dreamed of...

Sunday, November 20, 2016

Intuition: Security in a World Without Borders...

"Technology is not going to save us.  Our computers, our tools, our machines are not enough.  We have to rely on our intuition, our true being."  --Joseph Campbell

On a crisp Fall morning, one week after the U.S. National Election we were lining up outside the Harry S. Truman Building outside the United States Department of State.  The Bureau of Diplomatic Security - Overseas Security Advisory Council was hosting it's 31st Annual Briefing.

This years briefing was focused on "Security in a World Without Borders" and as we passed through our ID check and screening, the anticipation was high.  It's private sector constituents from the Fortune Global 500 to the small U.S.-based professional services firm had one key similarity.

Leaders in attendance recognize that their business is integrated forever with a exponentially expanding system of interconnected machines.  CxO's across the globe are competing for business in the era of "The Fourth Industrial Revolution" where the vulnerabilities extend beyond the Critical Assets of the enterprise.

This years keynote address was by Richard Davis, CEO of U.S. Bancorp.  His talk was heartfelt by many as he recounted his rise from the days at the branch level securing the vault.  Now he emphasized most of his effort was focused on Operational Risk Management (ORM).  Data, Identities and Distributed Denial of Service (DDoS) were on his mind everyday now.

Beyond the threats of a Post-ISIL Levant and operating in a world of Transnational Organized Crime, the room was almost full on Day 2 for this 10:45AM panel discussion:  "Developing an Insider Threat Program" and was moderated by Elena Kim-Mitchell, ODNI.

The OSAC participants on the panel were:
  • Roccie S., Capital One | Financial
  • Stanley B., Rolls-Royce North America | Defense Industrial Base
  • Joseph L., Southern Company | Energy
Each of these experts described the high-level architecture of their respective organizations design and approach to an "Insider Threat Program" (InTP) and they had consensus on one key element.

The "Human Factor".  The point that they all wanted to insure the audience understood clearly, is that all of the analytics software, data loss prevention (DLP) tools and sophisticated technology was not going to stop a determined and motivated adversary.

So what?

Your intuitive abilities as a human shall not be ignored or discounted.  How many times have you said to yourself, "I knew something wasn't right with that person".  In fact, many times we are alerted to the anomalous behavior of a co-worker because we have the human-factors of intuition that is working 24x7 in our brains.

Gavin de Becker has said it best in his book "The Gift of Fear," yet we must not forget that behavior is something that can be applied to everyone:
  • We seek connection with others.
  • We are saddened by loss and try to avoid it.
  • We dislike rejection.
  • We like recognition and attention.
  • We will do more to avoid pain then we will do to seek pleasure.
  • We dislike ridicule and embarrassment.
  • We care what others think of us.
  • We seek a degree of control over our lives.
As our software systems learn and we begin to rely more often on the algorithms to recognize, translate and predict, we must not lose sight of our human intuition.  Do you have it?  Yes.  Are you using it more often and more effectively?  We hope you will be.

How often have we all said, the signs were there.  How many times are the clear and present indicators in the workplace being ignored?  A organizations "Duty of Care" is continuously at stake.  Human Factors alone, just as software systems alerts alone will continuously expose the enterprise to significant loss events.  Here is just one example from the Washington Post:

The Pentagon’s Defense Security Service announced this year that contractors will be required to implement programs that are designed “to detect, deter and mitigate insider threats.” Contractors will be required to designate a senior insider threat official to oversee the program and provide training on how best to implement it.

While many details of the Martin case are not yet known, it is clear that it is not good for Booz Allen to have a second employee charged with stealing secrets from one of its most important customers, officials said.

What is the solution?

Government contractors, private sector businesses and their small and medium enterprises that are within the supply chain ecosystem for products and services, are continuously challenged.  They are under the growing umbrella of a myriad of federal acquisition guidelines.

In addition, various export, civil liberties and privacy laws focused on preserving the integrity and trust of the United States in an international marketplace, are compliance mandates for your global commerce.

New solutions are required as a result of the increasing spectrum of threats from individuals in the workplace, to the cyber nexus infiltrating your trade secrets and theft of intellectual property.

The TrustDecisions “Insider Threat Program” (InTP) has been designed from the ground up with organizations operating in highly regulated “Critical Infrastructure” sectors, including Financial, Energy and the Defense Industrial Base (DIB).

Many companies have already started the establishment of an “Insider Threat Program” (InTP).  Utilizing Subject Matter Experts from TrustDecisions will provide your organization with the confidence and continuous assurance that you stay on course.

“Achieving Trust” with employees, clients and suppliers is paramount in our digital 24x7x365 economy.  Designing and adapting the InTP to your unique culture and the changing threat landscape is a vital strategy.

Saturday, November 12, 2016

Exponential Innovation: Systems Risk with Beneficiaries...

When you have the opportunity to watch or attend TED, how does it make you feel?  Do you get the sense that the person behind the story, the idea, the innovation, is more genuine and sincere?

What about those advocating for "Exponential" change?  Individuals and organizations that have made the leap beyond incremental change and invention and are on to the concept of "Exponential Innovation".  The xPrize Foundation is a perfect example.

How can big ideas, bold inventions and people with exponential thinking accelerate their cause, advocate their blueprint or design a creative new alternative?  They need a system.  A model and community platform for ingesting ideas, testing prototypes, adapting designs and fostering continuous experimentation.

Why do you need a new system in your organization?  Let us start with some simple mathematics.  Multiply the number of people in your organization x 2.  Now think about the number of products, initiatives or major changes that you successfully implemented over the course of the last 12 months.  How many?

It is a safe estimate that each of your employees has at least two new ideas or bold ways to improve or change a product or process in your organization each working day.  500 employees x 250 working days = 250,000 potential ideas, changes or exponential innovations.  How did you capture these and utilize a system to capitalize on them, for your organization and those you serve?

What does this new innovation system have to do with Operational Risk Management (ORM)?

The Operational Risks associated with an organizational system for capturing, nurturing and producing new found Intellectual Capital are vast.  The goal however is to simultaneously accelerate, share and produce a collective thought leadership within the greater public-private community.  This in itself creates new challenges, in order to minimize the potential for significant losses and external risk events.

Across all the domains for "Exponential Innovation" from Healthcare, Space Travel, Artificial Intelligence and Ocean studies to name a few, lies one of the greatest barriers to our ultimate progress.  Adapting to the ecosystem of people utilizing the product or service.

Total immersion in the marketplace or with the customer, the beneficiary of the new product, service or invention, is a significant factor for future success.  The single factor of time, being embedded with the actual end user, recipient or beneficiaries of the new found innovation, is directly proportional to the Operational Risk exposures.

Think about it.  When was the last time your CEO or chosen leader was embedded with the customer for more than a few hours or a day?  How often is the scientist, designer or engineer using the product or system side-by-side the beneficiary?  Not often enough or long enough.

Sure we have all heard the mantra about "Managing by Walking Around" for decades, yet why do we continue to see the outcomes of this failure at well managed companies such as Wells Fargo and Samsung.  Operational Risk Management (ORM) shall be a component of any major initiative and a necessary competency in any dangerous or high risk environments.

From the decks of aircraft carriers to the trading on Wall Street and within the test trials of new pharmaceuticals, to the Yottabytes of data across the Internet, Operational Risk Management (ORM) is more relevant than ever on an exponential scale.  Just ask Elon Musk, Warren Buffet, Bill Gates or Ash Carter what they think...

Sunday, October 02, 2016

Homegrown Violent Extremism: Vigilance of Intelligence...

Since the Boston Marathon terrorist attack on Patriots Day, April 15th, 2013 the spectrum of Operational Risks that have descended upon the region and the country are vast.  People, processes, systems and external events are the state-of-play.  If you own a backpack and you are taking it on public mass transit or to a public event soon, remember this.  The new normal has finally arrived in the United States of America, again.

What does the face of terrorism look like?  London understands.  Oslo now understands.  FOB Chapman understands.  New York City.  San Bernardino.  Orlando.  Dallas.  Even as we begin the analysis of this latest U.S. based event in context with all the similarities of past episodes of terror, we are left with one absolute known.  Operational Risk Management is essential, no matter who you trust and how much you trust them.  The public now understands this once again and regardless of how much we may want to continue to enjoy our civil liberties and privacy, you never know when or how this will happen again.

Why is it that Israel and other nations that are so far more advanced in their Operational Risk strategies, still witness numerous incidents of terror?  Because it is impossible to eliminate.  It is only possible to mitigate the risks and likelihood of occurrence.  Public safety and security incidents of this magnitude are the visible metric we all judge to make sense of our progress.  Our only hope is better intelligence.  Lisa Ruth explained this over four years ago:

Intelligence is the best, the only, way to defeat the terrorists. To tackle the terrorist threat, we need all the weapons in our intelligence arsenal. That starts with intelligence requirements from the entire community that are well-focused and well-targeted. It means funding and a mandate to succeed. It means strong collection. We need human intelligence, which comes from case officers recruiting sources on the ground to give us information. We need electronic information, including telephone intercepts and static listening devices. We need overhead photography. We also need open source information such as web sites, facebook pages and other publicly available information. We need analysis, putting the pieces together. And we need decision makers who trust the intelligence services and listen to what they are saying. Washington Times, 9/14/2012

So in the dark shadows and behind closed doors, the whispers continue to debate how Boston Patriots Day 2013 could have happened?  How On December 2, 2015, 14 people were killed and 22 were seriously injured in a terrorist attack at the Inland Regional Center in San Bernardino, California, which consisted of a mass shooting and an attempted bombing.  Why didn't the intelligence we had already, provide the warning in time, in the midst of a glaring yellow or red flag?  As the analysis continues and the best and the brightest determine the lessons learned, we can only pray, that our process changes take place and citizens behaviors are modified.  Erroll Southers explains why we have more work ahead of us:
 At the same time, the radicalization process is not brief. Extremism smolders like a hot coal, an idea that grows into a violent fire fueled by anger, conflicts of identity, feelings of humiliation and marginalization.. It is important for the public to understand that removing any one of these elements cannot fully disrupt radicalization. All of these and other root causes need to be addressed in the effort to not just apprehend terrorists, but dissuade the radicalization that leads to terrorism.
There will be numerous accounts of heroism, people who saw or reported details that could have helped stop any of these Homegrown Violent Extremist (HVE) events.  What matters most from this point forward is that "John Q. Citizen" realizes the importance of being ever vigilant.  Having a continuous sense of personal vigilance is our only hope.  Whether in the crowd at the next marathon or in a lonely office cube, off Route 123 does not matter.  The goal is the same and we must not lose sight of our mutual responsibilities and unified purpose.
Godspeed America!
  1. An expression of good will when addressing someone, typically someone about to go on a journey or a daring endeavor.

Sunday, May 15, 2016

Know Your Customer: ISP Future Horizon...

The American public is changing their behavior as a result of the privacy and security failures across the private sector business policy landscape.  As the latest NTIA survey data reveals again, online commerce is being impacted and government agencies are now trying to further communicate there is a growing problem:

Lack of Trust in Internet Privacy and Security May Deter Economic and Other Online Activities
May 13, 2016 by Rafi Goldberg, Policy Analyst, Office of Policy Analysis and Development

Every day, billions of people around the world use the Internet to share ideas, conduct financial transactions, and keep in touch with family, friends, and colleagues. Users send and store personal medical data, business communications, and even intimate conversations over this global network. But for the Internet to grow and thrive, users must continue to trust that their personal information will be secure and their privacy protected.

NTIA’s analysis of recent data shows that Americans are increasingly concerned about online security and privacy at a time when data breaches, cybersecurity incidents, and controversies over the privacy of online services have become more prominent. These concerns are prompting some Americans to limit their online activity, according to data collected for NTIA [1] in July 2015 by the U.S. Census Bureau. This survey included several privacy and security questions, which were asked of more than 41,000 households that reported having at least one Internet user.

Perhaps the most direct threat to maintaining consumer trust is negative personal experience. Nineteen percent of Internet-using households—representing nearly 19 million households—reported that they had been affected by an online security breach, identity theft, or similar malicious activity during the 12 months prior to the July 2015 survey. Security breaches appear to be more common among the most intensive Internet-using households.

This survey is indeed only one facet of a much larger topic and pervasive problem.  Digital Trust is the output of making affirmative "Trust Decisions" with computing devices. Whether they are machine-to-machine, person-to-machine, or machine-to-person requires several technology engineering elements and business rules, that are understood and agreed upon.  The question is by whom?

Consumers who are using the Internet for communications and commerce and are the victims of Identity theft, stolen funds or other fraudulent schemes, are just the first wave of targets for transnational organized crime (TOC).  We have known this since the invention of virus scanners and bug bounty programs, in the early days of the 21st century.

Yet fifteen plus years later, the government is doing a study on the consumers feelings about privacy and security.  As a business or a consumer, we understand that the speed of commerce and technology is always far ahead of the regulations and the laws.  When enough people or businesses seem to be harmed, then the momentum begins for policy shifts and new laws are sometimes enacted after thousands of pages of semantic negotiation.

The answers and the outcomes we seek will come.  However, they will not first be solved by politicians and lawyers.  They will be mostly solved by our brilliant mathematicians, software engineers and data scientists.  At this point in time, we are getting so much closer to achieving digital trust through new innovations and inventions.  Just look at IBM Watson.

It is now time for business and commerce to begin the process of finding the truth.  Why do we continue to allow the levels of known bad actors to operate inside and within our networks?  It's a numbers game and it is because the criminals also employ the smartest social engineers and data scientists.

Digital Trust in the next fifteen years will mean something different than it does today.  We will have found the formula along the journey, the new equations and the rules agreed upon by all to make online and digital commerce more safe and secure.  So what will we do today and tomorrow, until the engineers and scientists save the day?

At this point in time, it is simply called "Know-Your-Customer"(KYC).  If this was utilized more effectively across critical infrastructure sectors beyond finance in our digital economy, then we would be making some progress.  Where are we talking about next? 

The FTC and FCC are well on their path to defining those critical elements of improving the trust that consumers have using their digital tools with ICT and on service providers web sites.  Yet even to this day, you still can find the criminals using and leveraging our own Internet Service Providers (ISP) to launch their attacks and perpetuate their fraudulent schemes.  How will this ever be deterred?  Could a version of KYC work with the ISP's?

Even with a global banking system in place you have pockets of greed and deceit.  Rogue nations or territories that have become the go-to-locations for the transnational organized crime syndicates to flourish.  Yet we can do much better, than we are today.

Just ask any "BlackHat" hacker from Eastern Europe who they prefer to do business with.  Query the experts that exist on the dark side and you will find the ISPs they prefer to do business with.  One day the regulators will realize this is where the business of e-crime has an opportunity for change and additional reform.  It will be more than just opening an account to gain access to the Internet.  It will be about scaling up our systems to a future horizon with new rules and robust real-time behavioral predictive analytics.  In the mean time:
May 11, 2016 
In testimony before Congress today, the Federal Trade Commission outlined its work over the past 40 years to protect consumers’ privacy at a hearing convened to examine privacy rules proposed by the Federal Communications Commission.

Chairwoman Edith Ramirez and Commissioner Maureen Ohlhausen testified on behalf of the Commission. The testimony before the Senate Judiciary Committee’s Subcommittee on Privacy, Technology and the Law provided background on FTC law enforcement efforts, policy work and consumer and business education programs related to protecting consumers’ privacy.

The testimony highlighted the FTC’s extensive history of privacy-related work. The testimony noted that the agency has brought more than 500 privacy-related enforcement cases in its history against online and offline companies of varying sizes, including companies across the internet ecosystem. In addition, the testimony highlighted a number of recent cases of note.

The testimony also provided information on the FTC’s policy work in the privacy area, going back to its first internet privacy workshop in 1996. The testimony noted that recent policy work has been based on principles featured in the FTC’s 2012 privacy report, and also highlighted workshops and reports related to the Internet of Things, big data, and other issues, including cross-device tracking.

The testimony also described the FTC’s extensive consumer and business education efforts related to privacy, including the FTC’s Start With Security campaign for businesses, and the newly-updated IdentityTheft.gov.

Saturday, May 07, 2016

The Third Offset: Seeking the Speed of Trustworthiness...

The U.S. national security "Insider Threat Score" is on it's way as a result of the aftermath of the Office of Personnel Management (OPM) hack.  The National Background Investigation Bureau (NBIB) is now standing up operations within the Pentagon umbrella.  Operational Risk Management (ORM) professionals are tracking this closely for good reason.  Social media activities such as this one, could one day be a factor in that score.

Simultaneously, the NIST Special Publication 800-160 2nd Draft has been released.  This document entitled:  Systems Security Engineering "Considerations for a Multidisciplinary Approach in the Engineering of Trustworthy Secure Systems" addresses a key component in the national security mosaic.

So if the goal of creating the "Insider Threat Score" is to help automate and maintain the process for better understanding trustworthiness, then the NIST publication should be at the center of the table at the National Background Investigation Bureau.  Why?  Definitions in Appendix B of the SP 800-160 Second Draft:

Trustworthiness: An attribute associated with an entity that reflects confidence that the entity will meet its requirements.

Note: Trustworthiness, from the security perspective, reflects confidence that an entity will meet its security requirements while subjected to disruptions, human errors, and purposeful attacks that may occur in the environments of operation.

Trust: A belief that an entity will behave in a predictable manner in specified circumstances.

The degree to which the user of a system component depends upon the trustworthiness of another component.

Note 1: The entity may be a person, process, object, or any combination thereof and can be of any size from a single hardware component or software module, to a piece of equipment identified by make and model, to a site or location, to an organization, to a nation-state.

Note 2: Trust, from the security perspective, is the belief that a security- relevant entity will behave in a predictable manner while enforcing security policy. Trust is also the degree to which a user or a component depends on the trustworthiness of another component (e.g., component A trusts component B, or component B is trusted by component A).

Note 3: Trust is typically expressed as a range (e.g., levels or degrees) that reflects the measure of trustworthiness associated with the entity.
The future of the automation of the clearance process, continuous monitoring of "Insider Threat Scores" and the trustworthy secure systems software engineering for accomplishing this remains mission critical.  The "Cleared Community" of private sector "Defense Industrial Base" (DIB) contractors will also be impacted by the convergence of both.

So who are the personnel who could be impacted by these two converging initiatives:
  • Individuals with systems engineering, architecture, design, development, and integration responsibilities; 
  • Individuals with software engineering, architecture, design, development, integration, and software maintenance responsibilities; 
  • Individuals with security governance, risk management, and oversight responsibilities;
  • Individuals with independent security verification, validation, testing, evaluation, auditing, assessment, inspection, and monitoring responsibilities;
  • Individuals with system security administration, operations, maintenance, sustainment, logistics, and support responsibilities;
  • Individuals with acquisition, budgeting, and project management responsibilities;
  • Providers of technology products, systems, or services; and
  • Academic institutions offering systems security engineering and related programs.
As the government moves towards more trustworthy secure computing systems the private sector will be there to assist.  Yet the future of our trusted environments will depend on how often we perform and how well we perform without error.

Software is continuously changing and the fear of changing it too often, has been one of our greatest downfalls.  That fear of change has created our largest exposures to continued exploits and attacks, by our most sophisticated adversaries.  Remember, Edward Snowden worked for a private sector contractor.

There are a few trustworthy organizations that have realized this fact and are now on an accelerating path for reaching a higher level of trust.  With their software systems and their people.  However, they did this with a leap of faith and the understanding that the speed to reach more trusted computing environments, was absolutely vital.

Look around the Nations Capital beltway and you will find a few examples of the ideal innovation architecture strategy that will propel us into that next level of trustworthiness.  An affirmative decision to trust is now before us and the time we take to make that trust decision is our greatest challenge.  Will it be hours, minutes, seconds or nanoseconds?  Marcel Lettre, undersecretary of Defense for Intelligence has this perspective:
"The intelligence community’s role in what Pentagon planners call “the third offset”—the search for continuing technological advantage over enemies—will feature robotics, artificial intelligence, machine learning and miniaturization. They will be applied in the areas of “pressing for global coverage capabilities, anti-access/area denial, counterterrorism and counter-proliferation, cybersecurity and countering insider threats,” Lettre said.

He said Defense is reaching out to obtain the expertise of its industrial partners, including Silicon Valley, while workforce planners are focused on “bringing in another generation skilled at innovating in the technology sector.”

Sunday, January 24, 2016

Adverse Consequences: Enabling Digital Trust of Global Enterprises...

In the World Economic Forum 2016 - Global Risks Report, there are several insights and alarms that Operational Risk Management (ORM) professionals and the Board of Directors are quickly analyzing.  This years Davos, Switzerland Annual Meeting and report has the underlying theme of the "Fourth Industrial Revolution".

Our first insight, is the rise in "Cyber Dependency" that is called out in the "Risk-Trends" Interconnections Map.  It is tied directly to the following technological "Global Risks" ranked by highest impact:
  1. Cyberattacks
  2. Critical Information Infrastructure Breakdown
  3. Adverse Consequences of Technological Advances
  4. Data Fraud or Theft
#1 makes sense in the Upper Right Quadrant of High Impact and High Likelihood.  The alarms however are going off, with #2 and #3 for several reasons.  First, they are in the Upper Left Quadrant of "High Impact" and "Low Likelihood".  Why does this create concern?

The Upper Left Quadrant has risks that some of the most experienced OPS Risk professionals will pay attention to the most.  This is the place that organizations usually ignore with people and resources and where enterprises are caught off guard or blindsided by asymmetric threats.  These are the risks that no one has really exercised for and is not actively developing proactive hypotheses, to address in a real-time crisis.

There are two other risks shared in this same Upper Left Quadrant in 2016:
  • Weapons of Mass Destruction
  • Spread of Infectious Diseases
These are risks that nation states spend hundreds of millions of dollars each year collecting intelligence on and devoting substantial resources to try and keep the likelihood of these occurring, as low as humanly possible.  The impact on humanity is far to great not to devote attention to these, yet the private sector is rarely involved.

Now, let's consider the other two in the same quadrant, slightly less in impact and just a little higher in likelihood.  What does each really mean as a global risk?

"Critical Information Infrastructure Breakdown": "Cyber dependency increases vulnerability to outage of critical information infrastructure (e.g. internet, satellites, etc.) and networks causing widespread disruption.

"Adverse Consequences of Technological Advances"
:   Intended or unintended adverse consequences of technological advances such as artificial intelligence, geo-engineering and synthetic biology causing human, environmental and economic damage. 
  • global risk is an uncertain event or condition that, if it occurs, can cause significant negative impact for several countries or industries within the next 10 years.
  • global trend is a long-term pattern that is currently taking place and that could contribute to amplifying global risks and/or altering the relationship between them.
Although organizations may recognize the benefit of cyber technologies for their bottom lines, they may not be fully internalizing cyber security risks and making the appropriate level of investment to enhance operational risk management and strengthen organizational resilience. Particular attention is needed in two areas that are so far under-protected: mobile internet and machine-to-machine connections. It is vital to integrate physical and cyber management, strengthen resilience leadership and organizational and business processes, and leverage supporting technologies. (Page 23 of WEF_GRR16)
The combination of the two aforementioned technological global risks, are almost invisible to the major stakeholders of our vital organizations and governments.  This is because the focus on "Cyberattacks" and "Data Fraud or Theft" has dominated the news cycles.  It makes sense.  However, we must consider this:
As is often the case, however, public-private partnership can be held back by lack of trust and misaligned incentives. Businesses may fear exposing their data and practices to competitors or to law enforcement agencies. And the private sector’s primary interest in rapid recovery and continuity of business operations may not align with the public sector’s primary interest in apprehending and prosecuting perpetrators. In addition, governments need to balance their investments in cyber offensive weapons and efforts to enhance capabilities for cybersecurity and defence. (Page 83 of WEF GRR16)
 Cyber Dependency.  A long-term pattern that is currently taking place that could contribute to amplifying global risks and/or altering the relationship between them.  The underlying root cause of the disruption and the perceived risks are focused on the integrity of "Digital Trust"and the continuity of "Trust Decisions":

  • Machine-to-Machine
  • Person-to-Person
  • Business-to-Business
  • Government-to-Government
  • Country-to-Country

Business Executives and Leaders of Nation States, have one thing in common.  Their employees and their citizens are evermore connected by mobile digital devices.  Their economic engines of banking, finance and trading are dependent upon the confidentiality, integrity and assurance of data.  The abilities and the opportunities by the mass of humanity to continuously leverage their personal digital devices, is simultaneously a global risk.  So what?

You see, the 2016 Global Risks Report is flawed.  It relies on an outdated and soon to be irrelevant set of four Quadrants.  The axis of Impact and Likelihood, are no longer capable of addressing risk management and the human perceptions of both.  On the planet Earth, in the Internet ecosystem of 500 Billion computing machines, lies the answer to our future quest:

Enabling Digital Trust of Global Enterprises...

Sunday, January 10, 2016

Privacy Engineering: Mobile Standards for Digital Trust...

The landscape for software engineering standards within corporate organizations, is now on the radar of Operational Risk Management (ORM) experts.  What are the privacy and security related engineering design standards, that are being utilized at JP Morgan Chase, Citibank or Paypal for mobile App development?

Effective and standardized "Privacy Engineering" of mobile applications at organizations in Critical Infrastructure sectors such as Finance and Banking is just one example.  It is soon to be a greater focus of the Federal Trade Commission (FTC) and other U.S. regulators.  Why?

"Trust Decisions" are being made by consumers each day, as millions of of mobile banking customers download an application to their Android or iOS smart phones.  The consumer then has immediate exposure to the quality of the software engineering, by the UX/design and developer of the software App.  The standards being utilized by each organization for designing and engineering those Apps with privacy and security, may vary by who developed the application and for what particular operating system.

So what?  U.S. financial institutions software engineering departments and other highly regulated industries will be a continued and concentrated focus by the Federal Trade Commission (FTC).  Standards for privacy software engineering and disclosure of the rules will become even more of a critical factor.  Why?
As a result, to act within the time constraints of deadlines, the presence of fiercer competition, and the looming threat of higher lost-opportunity costs, you have no choice—you must presume the trustworthiness of the information you acquire to make decisions. Deciding now requires you to acquire the information you need from the most accessible source, with zero time to ask the important questions: “Where did this information come from? Who put this report together? Has the data been confirmed to be accurate? Who actually authored the analysis? Does this bank statement reflect all of our deposits?”

Answering these types of questions is inherent to how we make good decisions. You seek information that serves as fuel for your decision. You work hard to validate that the information can be trusted. You calculate toward your decision, constantly evaluating whether the information holds up its reliability. But in today’s 24/7/365, wired decision-making landscape, there is no time to ask those questions. Those controlling the information you need understand that pressure and require you to presume their digital information is trustworthy and reliable for making your decisions. Thus, to gain control of digital information is to succeed in imposing an enormous handicap—removing your ability to challenge its trustworthiness by asking the right questions.  Source:  Achieving Digital Trust by Jeffrey Ritter.
Is it possible to redesign mobile banking Apps, so that all Android or iOS software engineers must adhere to privacy and security engineering standards of practice?  The human-based "Trust Decisions" about whether to trust an application with personal identifiable information (PII) is currently buried in legal disclosures.  The privacy disclosures are written by lawyers, all different and in most cases never read, by the consumer prior to downloading the App.  Opt-in or Opt-out?

The future of mobile App Privacy and Security Trust engineering for consumers will be in the hands of government regulators soon and in concert with other laws associated with information security, such as the GLBA Safeguards Rule.  "Cyber Trust" indicators or other vital warning systems may be in the works.  Buyer Beware is the theme.

For years consumers have been looking at FDA Nutrition Labels and other Federal oriented tools, to provide more visible and rapidly effective disclosure.  Since the human being is making "Trust Decisions" on whether to download a software application to their computing device, they also may desire a method to quickly ascertain if the App is "Trustworthy."

Can they trust the application according to their particular appetite for risk?  What information will be shared with 3rd parties?  How will your information be used and collected while you are using or not using the application?  Here is one example of how a future warning "Privacy Label" may look before a consumer is permitted to download an application to their computing device.

What does the consumer experience today?  As one example, currently when you visit the App Store on an iOS mobile device such as the iPad, and then search for "Chase", the top choice is an App named Chase Mobile.  When you click on the "Get" button, it changes to "Install".  When you click on "Install" it prompts you to Sign In to iTunes Store.  Once you sign-in, the Chase Mobile App downloads to your device, the button then changes to "Open."

When you open the Chase Mobile App, it opens the first screen to "Log On".  There is a small "Privacy" button in the top left corner of the screen, however there is not an easy to understand Privacy Label that is visible before you actually "Log On" to Chase.  In the case of selecting the Privacy button in the upper left corner, it then reveals dozens of pages of legal documents explaining online privacy policy and U.S. consumer privacy notices.  There is however one easier to view grid, under the privacy notice that is helpful in understanding whether Chase shares personal information and whether as a consumer, you can limit this sharing.

The Critical Infrastructure sectors of the U.S. economy, that has a daily interface with consumers through mobile software Apps are now on notice.  Chief Legal Counsels, Chief Information Officers, Chief Privacy Officers and Software Engineering personnel, must address the reality of human behavior and how "Trust Decisions" impact legal risk and the ultimate perception of the corporate brand.