Management Awareness Training

182
infotex Dan Hadaway CISA, CISM Managing Partner infotex Management Awareness Training Awareness Training Series

description

Awareness Training Series. Management Awareness Training. Dan Hadaway CISA, CISM Managing Partner i nfo t ex. 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? - PowerPoint PPT Presentation

Transcript of Management Awareness Training

Page 1: Management  Awareness Training

infotex

Dan Hadaway CISA, CISMManaging Partnerinfotex

Management Awareness Training

Awareness Training Series

Page 2: Management  Awareness Training

infotex

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?

Page 3: Management  Awareness Training

infotexinfotex

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

Page 4: Management  Awareness Training

infotexinfotex

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

Page 5: Management  Awareness Training

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

Page 6: Management  Awareness Training

infotex

Available Tools . . .

• IT Audit Test Types• The ISO Job Description• Awareness Training Procedure• Management Awareness

Training Procedure• Governance Policy

Development Chart

Page 7: Management  Awareness Training

infotex

Available Tools . . .

• Management Guidelines for Social Media

• User Guidelines for Social Media

• Management Talking Points for Mobile Banking and Social Media

Page 8: Management  Awareness Training

infotex

Available Tools . . .

• Wireless Banking Article (Top Five Risks)

• Wireless Banking Article• Wireless Banking Risk

Assessment• Wireless Banking Due

Diligence Kit

Page 9: Management  Awareness Training

infotexinfotex

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)

Page 10: Management  Awareness Training

infotexinfotex

Nomenclature

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

Essentially the same thing.

Page 11: Management  Awareness Training

infotexinfotex

IT Governance Program

• Combines:– Serve Business Mission– Manage Technology Risk

(information security)

Page 12: Management  Awareness Training

infotexinfotex

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

Page 13: Management  Awareness Training

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

Page 14: Management  Awareness Training

infotexinfotex

#1

Page 15: Management  Awareness Training

infotexinfotex

#1: Serve the Mission

Information Technology must be aligned with the Business Strategy of the bank!

Page 16: Management  Awareness Training

infotexinfotex

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

Page 17: Management  Awareness Training

infotexinfotex

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.

Page 18: Management  Awareness Training

infotexinfotex

Management Role

• Determine technologies that will best facilitate business tactics.

• Determine appropriate time to deploy new technologies (Apply Pressure)

Page 19: Management  Awareness Training

infotexinfotex

Management Role

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

Page 20: Management  Awareness Training

infotexinfotex

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)

Page 21: Management  Awareness Training

infotexinfotex

When is the appropriate time?

Page 22: Management  Awareness Training

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

Page 23: Management  Awareness Training

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

Page 24: Management  Awareness Training

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

Page 25: Management  Awareness Training

Late Majority / Laggard

•Virtualization•Cloud Computing•Social Media•Telecommuting

Dan’s Interpretation of Everett M. Rogers' Diffusion of Innovations

Softwareforcloudcomputing.com

infotex 1. Align IT with Business Strategy

Page 26: Management  Awareness Training

Risk/Benefit Evolution Curve

Val

ue

Time

Features, Sophistication

Price, Problems

infotex 1. Align IT with Business Strategy

Page 27: Management  Awareness Training

Risk/Benefit Evolution Curve

Val

ue

Time

Features, Sophistication

Price, Problems

infotex 1. Align IT with Business Strategy

Page 28: Management  Awareness Training

Risk/Benefit Evolution Curve

Val

ue

Time

Features, Sophistication

Price, Problems

Innovator

Early Adopter

Early Majority Late MajorityLaggards

infotex 1. Align IT with Business Strategy

Page 29: Management  Awareness Training

infotexinfotex

Digital Video Security

• Innovators • Early adopters• Early majority• Late majority • Laggards

2012

Page 30: Management  Awareness Training

infotexinfotex

Secure Messaging

• Innovators • Early adopters• Early majority• Late majority • Laggards

2012

Page 31: Management  Awareness Training

infotexinfotex

Remote Access in Banks

• Innovators • Early adopters• Early majority• Late majority • Laggards

2010

Page 32: Management  Awareness Training

infotexinfotex

Social Media in Banks

• Innovators • Early adopters• Early majority• Late majority • Laggards 2011

Page 33: Management  Awareness Training

infotexinfotex

Wireless Banking

• Innovators • Early adopters• Early majority• Late majority • Laggards

2013

Page 34: Management  Awareness Training

infotexinfotex

#2

Page 35: Management  Awareness Training

infotexinfotex

#2: Manage the Risk

Information, Technology,

and Information Technology

expose the bank to risk!

Page 36: Management  Awareness Training

infotexinfotex

#2) The Risk Spectrum

• There is no such thing as 100% security!

Ignore it? Obsession?

Page 37: Management  Awareness Training

infotexinfotex

#2) The Risk Spectrum

• There is no such thing as 100% security!

Ignore it? FFIEC Guidelines

Page 38: Management  Awareness Training

infotexinfotex

How do you decide?

• There is no such thing as 100% security!

Ignore it? FFIEC Guidelines

Risk-basedRemediation

Page 39: Management  Awareness Training

infotexinfotex

Principle Number Two

Information Security is about

ACCEPTING RISK.

Page 40: Management  Awareness Training

infotexinfotex

#3

Page 41: Management  Awareness Training

infotex

A process questionA process question

When you are finishedserving 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.

Page 42: Management  Awareness Training

infotexinfotex

Fundamental #3

Page 43: Management  Awareness Training

infotexinfotex

Which means . . .

• No crossing it off the list.• No filing it away.• No wishing you never have to deal

with it again.

Page 44: Management  Awareness Training

infotexinfotex

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.

Page 45: Management  Awareness Training

infotexinfotex

And to improve . . . .

• We must start by measuring.

But remember that metrics are all relative.

Page 46: Management  Awareness Training

infotexinfotex

Fundamental #3

Page 47: Management  Awareness Training

infotexinfotex

#4

Page 48: Management  Awareness Training

infotex

Important Point QuestionImportant Point Question

What is the Number 1 form

of Identity Theft?

A. Pretext Calling

B. Drive-by Attacks (Trojan Horses installed by rogue websites.)

C. Insider Data Theft

D. Phishing

E. Other

Page 49: Management  Awareness Training

infotexinfotex

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

Page 50: Management  Awareness Training

infotexinfotex

4) It’s not really Technical

TechnologyPeople

Policy Process

Page 51: Management  Awareness Training

infotexinfotex

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.”

Page 52: Management  Awareness Training

infotexinfotex

Four Corners of the Bank

Page 53: Management  Awareness Training

infotex

Four Corners of the BankBoard of Directors

OversightCommittee

ManagementTeam

Technical TeamUsers

VendorsLaw Enforcement

Academia

Customers

Page 54: Management  Awareness Training

infotexinfotex

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.

Page 55: Management  Awareness Training

infotexinfotex

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)

Page 56: Management  Awareness Training

infotexinfotex

#5

Page 57: Management  Awareness Training

infotexinfotex

Page 58: Management  Awareness Training

infotex

Four Risk Factors

Threats

Vulnerabilities

Impact Severity

Likelihood

Page 59: Management  Awareness Training

infotexinfotex

Threats

• Terrorists • Hackers• Scammers / Con-

men /Fraudsters / Thieves

• Vandals• Technology Itself• Users / Vendors• Nosy Neighbors• Ex-Spouses

Page 60: Management  Awareness Training

infotexinfotex

We can’t take it lightly

• Zeus • Software suite designed to help

hackers attack banks.

Page 61: Management  Awareness Training

infotexinfotex

Marc Rogers, Purdue University

Page 62: Management  Awareness Training

infotexinfotex

. . . zooming in . . .

Page 63: Management  Awareness Training

infotexinfotex

Vulnerabilities

• Airplanes • Ports• Subway System• Buildings• Public Places

• E-mail• Browsers• Network Access

• Users

• > 300 considered in Risk Assessment

Page 64: Management  Awareness Training

infotexinfotex

Impact Severity

• Almost 3000 people

• Financial System• Airlines• Convenience

• Customers’ Identities

• Horror Stories

• Heartland Payment System ($7/card, 20,000 cards)

• Reputation

Page 65: Management  Awareness Training

infotexinfotex

Likelihood

• It can happen on American Soil

• Technology Itself Very High

• Pretext Calling High• Phishing High

• Hacking Medium

• Physical Breach Low– Still happens though!

Page 66: Management  Awareness Training

infotexinfotex

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

Page 67: Management  Awareness Training

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

Page 68: Management  Awareness Training

infotexinfotex

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

Page 69: Management  Awareness Training

infotexinfotex

Types of Risk

• Financial Risk– Early Adapter of Technology– Vendor Solvency– Cost of Security Breaches

• Operational Risk– Virus Attacks– Denial of Service (DoS) Attacks– Project Management Risk

Page 70: Management  Awareness Training

infotexinfotex

Types of Risk

• Reputational Risk– Any Security Incident

presents some reputational risk.

– Poor Incident Response can turn a minor incident into a major incident.

Page 71: Management  Awareness Training

infotexinfotex

Types of Risk

• Compliance Risk– GLBA– HIPAA, CIPA, SOX– PCI, BS12000, ITIL, CobiT– BSA, OFAC, US Patriot Act– FACTA– SB1386

Page 72: Management  Awareness Training

infotexinfotex

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.

Page 73: Management  Awareness Training

infotexinfotex

Thank goodness for the . . .

Page 74: Management  Awareness Training

infotexinfotex

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)

Page 75: Management  Awareness Training

infotexinfotex

The FFIEC

Information Security

Work Program

IT Audit Work Program

Information Security

Handbook

IT Audit Handbook

Boilerplates

Page 76: Management  Awareness Training

infotex

Management Responsibilities

A quick summary

Awareness Training Series

Page 77: Management  Awareness Training

infotexinfotex

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.

Page 78: Management  Awareness Training

infotexinfotex

What does an IT Governance Program include?

(according to FFIEC Guidelines)

Page 79: Management  Awareness Training

infotexinfotex

The FFIEC

Information Security

Work Program

IT Audit Work Program

Information Security

Handbook

IT Audit Handbook

Boilerplates

How about a map?

Page 80: Management  Awareness Training

infotexinfotex

IT Governance Program

The combined

policy,procedures,

and toolsabout a

particularissue can be

referred to as a

“Program.”

Policy

Procedure

Tools (standards, guidelines,

applications, forms, websites, etc.)

Page 81: Management  Awareness Training

infotexinfotex

Authentication Example

A procedure enforces a board level

policy using tools called

for in the procedure.

AUP

AuthenticationProcedures

Passwords Out-of-Pocket Questions

Visitor Authorization Process

Page 82: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 83: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 84: Management  Awareness Training

infotexinfotex

Risk Analysis Program

Page 85: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 86: Management  Awareness Training

infotexinfotex

Access Management

Page 87: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 88: Management  Awareness Training

infotexinfotex

Incident Response

Program

Page 89: Management  Awareness Training

infotexinfotex

Incident Response

• Awareness is an important part of incident response.

CIRT

ISO

Everybody

• Board of Directors• Law Enforcement• Customers

(Could be steering committee.)

Page 90: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 91: Management  Awareness Training

infotexinfotex

Asset Management

Program

Page 92: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 93: Management  Awareness Training

infotexinfotex

Business Continuity Program

Page 94: Management  Awareness Training

infotexinfotex

Scenario Responses

Pandemic Ice Storm Tornado Flood Fire

Risk AnalysisBusiness

Continuity Plan

Business Continuity Program

Page 95: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 96: Management  Awareness Training

infotexinfotex

Procedure

Vendor Management Program

GovernancePolicy

Vendor Management

Policy

Search and Selection

ContractNegotiations

Security SanctionsPolicy

Assigned SecurityResponsibility

OngoingDue Diligence

ThresholdRisk Assessment

ThresholdRisk Assessment

Vendor AgreementTemplate

Vendor Request

Detailed Risk Assessment

Risk Analysis

Vendor Risk Determination Table

Checklists

Page 97: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 98: Management  Awareness Training

infotexinfotex

Security Standards

Page 99: Management  Awareness Training

infotexinfotex

Security Standards

Page 100: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 101: Management  Awareness Training

infotexinfotex

GovernancePolicy

AwarenessProgram

ManagementAwareness

Training

TechnicalAwareness

Training

UserAwareness

Training

CustomerAwareness

Training

Board of Directors

Management Team

Awareness Program

Page 102: Management  Awareness Training

infotexinfotex

GovernancePolicy

AwarenessProgram

ManagementAwareness

Training

TechnicalAwareness

Training

UserAwareness

Training

CustomerAwareness

Training

Board of Directors

Management Team

Vendor ManagementProgram

Due DiligenceRequest Letter

Awareness Program

Page 103: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 104: Management  Awareness Training

infotexinfotex

IT Governance Policy

CommitteeMembership

Board Member

ManagementTeam

End Users(rotated)

Establish SteeringCommittee

Authorize the ISO

Requires Trainingat all levels

Report CriticalSecurity Breaches

DefineGovernance

Align ITwith Business

Delineates Annual Report to the Board

Page 105: Management  Awareness Training

infotexinfotex

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

Page 106: Management  Awareness Training

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

Page 107: Management  Awareness Training

infotexinfotex

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;

Page 108: Management  Awareness Training

infotexinfotex

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.

Page 109: Management  Awareness Training

infotexinfotex

That’s straight out of FFIECguidelines (page 6,

Information Security Handbook)

Page 110: Management  Awareness Training

infotexinfotex

Information Security ProgramEquals

IT Governance Program

Page 111: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 112: Management  Awareness Training

infotexinfotex

Risk Analysis Program

Page 113: Management  Awareness Training

infotexinfotex

Four Primary Risk Assessments

Risk Assessments

VendorRisk Determination

Business Impact Analysis

TechnologyRisk Assessment

AssetCriticalityAnalysis

Page 114: Management  Awareness Training

infotexinfotex

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

Page 115: Management  Awareness Training

In this next section

• We will learn the primary purposes of an IT Audit.

• We will understand the need for risk-based auditing

• We will learn the different types of audit tests.

• We will be exposed to the need for good IT Audit metrics.

infotex

Page 116: Management  Awareness Training

infotexinfotex

The IT Audit

Page 117: Management  Awareness Training

infotexinfotex

Three Primary Purposes

• Alignment with business mission• Appropriate risk management• Compliance with applicable law

Page 118: Management  Awareness Training

infotexinfotex

Alignment w/ Business Mission

• Strategy Alignment• Facilitate Execution of Business

Tactics• Demonstrate Return on Investment

Page 119: Management  Awareness Training

infotexinfotex

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

Page 120: Management  Awareness Training

infotexinfotex

Comply with the Law!

• FFIEC Guidelines as the Framework• CobiT as Framework for SOX banks• State laws may introduce individual

compliance framework needs (SB1386 in California)

Page 121: Management  Awareness Training

infotexinfotex

Risk-based Auditing

• Ensures testing is appropriate• Delivers Value to Audit Process• Relies heavily on bank risk

assessment

Page 122: Management  Awareness Training

infotexinfotex

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).

Page 123: Management  Awareness Training

infotexinfotex

Risk-based Auditing

Inherent Risk Residual RiskDelta Control

Page 124: Management  Awareness Training

infotexinfotex

Types of IT Audit Tests

• Technical• Non-technical

Page 125: Management  Awareness Training

infotexinfotex

But first …

• Capture-the-flag versus assessment

Page 126: Management  Awareness Training

infotexinfotex

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

Page 127: Management  Awareness Training

infotexinfotex

Types of IT Audit Tests

• Technical Vulnerability Assessments– Perimeter

• Penetration Testing• Vulnerability Scanning of Perimeter• Confirmation

– Internal Network• Vulnerability Scanning• Network Configuration Audit• Confirmation

Page 128: Management  Awareness Training

infotexinfotex

Types of IT Audit Tests

• Social Engineering Tests– Two purposes

• Test Awareness• Test Incident Response

– Spear Phishing– Pretext Calling– Password File Analysis– Orchestrated Attacks

Page 129: Management  Awareness Training

infotexinfotex

IT Physical Security

• Physical Breach Tests• Walk-through’s• Dumpster Diving

– Trash-can Diving

• Physical Security Checklists

Page 130: Management  Awareness Training

infotexinfotex

Checklist Tests

• IT Governance• Physical Security• Network Configuration Audits

Be careful that findingsare risk ranked.

Page 131: Management  Awareness Training

infotexinfotex

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”)

Page 132: Management  Awareness Training

infotexinfotex

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

Page 133: Management  Awareness Training

infotexinfotex

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

Page 134: Management  Awareness Training

In this next section

• We will learn the primary purposes of the annual Vendor Due Diligence Review.

infotex

Page 135: Management  Awareness Training

infotexinfotex

Procedure

Vendor Management Program

GovernancePolicy

Vendor Management

Policy

Search and Selection

ContractNegotiations

Security SanctionsPolicy

Assigned SecurityResponsibility

OngoingDue Diligence

ThresholdRisk Assessment

ThresholdRisk Assessment

Vendor AgreementTemplate

Vendor Request

Detailed Risk Assessment

Risk Analysis

Vendor Risk Determination Table

Checklists

Page 136: Management  Awareness Training

infotexinfotex

Selection Process

Risk AssessmentRequirements

Definition vs. RFPResponses

Due Diligence

Evaluation

Page 137: Management  Awareness Training

infotexinfotex

Vendor Due Diligence Checklist

• Makes the annual review go so much better!

• . . . . . . at least after the first one.

Page 138: Management  Awareness Training

infotexinfotex

Vendor Risk Assessment Process

ThresholdRisk

Assessment

Vendor Due DiligenceRequest

Due Diligence Checklist

Missing Controls

RiskManagement

Program

Reportto Board

DetailedRisk Assessment

Page 139: Management  Awareness Training

infotexinfotex

Missing controls and anticipated safeguards should input into the IT Risk Assessment.

Outputs of Annual Review

Page 140: Management  Awareness Training

infotexinfotex

Remember this diagram?

Risk Assessments

VendorDue Diligence

Business Impact Analysis

TechnologyRisk Assessment

Page 141: Management  Awareness Training

infotexinfotex

Remember this diagram?

Risk Assessments

VendorDue Diligence

Business Impact Analysis

TechnologyRisk Assessment

This (and missing vendor controls)is where Vendor Due Diligence plugsinto the overall Risk AssessmentProcess.

Page 142: Management  Awareness Training

infotexinfotex

Missing controls and anticipated safeguards should input into the IT Risk Assessment.

They will be deployed as per risk severity in a reasonable period of time.

Outputs of Annual Review

Page 143: Management  Awareness Training

infotexinfotex

Finally, risk acceptance decisions should be escalated to the board of directors by the ISO in the Annual Report.

Outputs of Annual Review

Page 144: Management  Awareness Training

infotexinfotex

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

Page 145: Management  Awareness Training

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

Page 146: Management  Awareness Training

infotexinfotex

RiskAnalysis

Awareness

SecurityStandards

VendorManagement

BusinessContinuity

AssetManagement

Incident Response

AccessManagement

GovernancePolicy

Information Information TechnologyTechnologyGovernance Governance ProgramProgram

Page 147: Management  Awareness Training

infotexinfotex

GovernancePolicy

AwarenessProgram

ManagementAwareness

Training

TechnicalAwareness

Training

UserAwareness

Training

CustomerAwareness

Training

Board of Directors

Management Team

Vendor ManagementProgram

Due DiligenceRequest Letter

Awareness Program

Page 148: Management  Awareness Training

infotexinfotex

GovernancePolicy

AwarenessProgram

ManagementAwareness

Training

TechnicalAwareness

Training

UserAwareness

Training

CustomerAwareness

Training

Board of Directors

Management Team

Awareness Program

Page 149: Management  Awareness Training

infotexinfotex

Risk ManagementProgram

AwarenessProgram

ManagementAwareness

Training

TechnicalAwareness

Training

UserAwareness

Training

CustomerAwareness

Training

Board of Directors

Management Team

Page 150: Management  Awareness Training

infotexinfotex

• 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

BAT Tools

Page 151: Management  Awareness Training

infotexinfotex

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

Page 152: Management  Awareness Training

infotexinfotex

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

Page 153: Management  Awareness Training

infotexinfotex

Orchestrated Attacks

• Usually combining:– Malware from drive-by attack sites– Phishing– Pretext Calling

• Assets Attacked:– Customer credentials– ACH– On-line Banking

Page 154: Management  Awareness Training

infotexinfotex

Social Media

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

• Employee risks– General Users– Management Team Members

Page 155: Management  Awareness Training

infotexinfotex

Wireless Banking Risks

1. Late Majority Adoption2. Tepid Adoption3. Security Risk4. Compliance Risk5. Strategic Risk

infotex Horse Before the Cart: Top 5 Mobile Banking Risks

Page 156: Management  Awareness Training

infotexinfotex

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

Page 157: Management  Awareness Training

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

Page 158: Management  Awareness Training

infotexinfotex

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.

Page 159: Management  Awareness Training

infotexinfotex

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.

Page 160: Management  Awareness Training

infotexinfotex

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.

Page 161: Management  Awareness Training

infotexinfotex

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.

Page 162: Management  Awareness Training

infotexinfotex

Awareness Life Cycle

Educate

Motivate

Activate

Page 163: Management  Awareness Training

infotexinfotex

Four Corners

Board of Directors

OversightCommittee

ManagementTeam

Technical TeamUsers

Vendors

Customers

Page 164: Management  Awareness Training

infotexinfotex

Board Level

• Educate

• Motivate

• Activate

• Annual Report, Awareness Training

• Risk Analysis, VDD Results, Audit Findings

• Policy Approval, Strategy, Budget

Page 165: Management  Awareness Training

infotexinfotex

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

Page 166: Management  Awareness Training

infotexinfotex

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

Page 167: Management  Awareness Training

infotexinfotex

Users

• Educate

• Motivate

• Activate

• Acceptable Use Policy

• Annual Awareness Training, Comprehension Tests

• Social Engineering Tests, Exercises, Reminders

Page 168: Management  Awareness Training

infotexinfotex

Customers

• Educate

• Motivate

• Activate

• Flyers, Knowledgeable Employees

• Annual Awareness Training

• Stuffers, Web Site Announcements

Page 169: Management  Awareness Training

infotexinfotex

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.

Page 170: Management  Awareness Training

infotex

• Information Security Officer Job Description

On the Portal . . .

Page 171: Management  Awareness Training

infotexinfotex

How should we summarize?

Page 172: Management  Awareness Training

infotexinfotex

Interactions

Page 173: Management  Awareness Training

infotexinfotex

ISO must interact with:

• Board of Directors– Annual Report to the Board – Risk Acceptance Decisions– Policy Approval

Page 174: Management  Awareness Training

infotexinfotex

ISO must interact with:

• Oversight Committee– Internal Auditing– Monitoring– Audit Reports– Vulnerability Assessments

Page 175: Management  Awareness Training

infotexinfotex

ISO must interact with:

• Management Team– Risk Analysis– Training– Vendor Due Diligence– Access Authorization Review– Budget– Incident Response

Page 176: Management  Awareness Training

infotexinfotex

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

Page 177: Management  Awareness Training

infotexinfotex

ISO must interact with:

• Technical Team– Security Standards– Incident Response– Vulnerability Assessments– Audits– Network Monitoring

Page 178: Management  Awareness Training

infotexinfotex

ISO must interact with:

• Users (all employees)– Acceptable Use Policy– Annual Awareness Training– Policy Enforcement– Security Reminders and Notices– Testing– Incident Response– Answering Questions

Page 179: Management  Awareness Training

infotexinfotex

ISO must interact with:

• Vendors– Vendor Risk Analysis– Vendor Due Diligence Requirements– Risk Acceptance

Page 180: Management  Awareness Training

infotexinfotex

ISO must interact with:

• Customers– Customer Awareness Training– Incident Response

Page 181: Management  Awareness Training

infotexinfotex

Thank you!

Don’t forget the

Evaluations!

Page 182: Management  Awareness Training

infotex

The Workshop Portal

• List of boilerplates and related websites.• Electronic Version of Documents, Articles,

and Boilerplates for your use.– mat2009.infotex.com (all lower case)– Your user name . . . mat2009 (all lower case)– Th3!b@#1 is the password.

• Portal is classified “internal use.”