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Has your management team asked the following four questions about your organization's internal controls? 1) Have we identified the meaningful risks to our objectives? 2) Which controls are "key controls" that will best support a conclusion regarding the effectiveness of internal control in a particular process? 3) What information will be persuasive in assessing whether the controls are continuing to operate effectively? 4) Are we presently performing effective monitoring that is not unnecessary and costly testing? These questions appear in a white paper, "Effective Internal Control Systems for Rapidly Changing Markets: A New Opportunity," packed with answers for GRC professionals wondering if there is a better way to operate. The paper, authored by the GRC experts at advisory firm SMART Group, clearly lays out how controls monitoring processes can and should align with the "Guidance on Monitoring" COSO published earlier this year to help organizations strengthen the effectiveness and efficiency of their internal controls frameworks. Among other useful how-to information, the 12-page paper includes a five-step "Implementation Guide" for creating a better controls-monitoring program.

One of my predictions for last year was that privacy would be a growing concern among mainstream users. I didn't repeat that prediction this year, but perhaps I should have. The reason? Apparently, younger web users seem to care more about privacy controls. Or at least, they use them more. According to Facebook chief privacy officer Chris Kelly, more teenagers than adults use privacy controls on the social network, at a rate of 60% to about 25-30%. That's surprising given the conventional wisdom that younger Internet users tend not to care about the privacy of their data. A recent study from Computer Associates confirms that many teens are at least somewhat concerned with online privacy. That study showed that 79% of teens aged 13-17 who are members of a social networking site like MySpace or Facebook protect their profiles from the general Internet in some way (i.e., only allow friends or friends of friends to view their information). Profiles on Facebook, of course, are automatically protected from viewing by the Internet at large, but protecting them from the rest of your network requires additional steps. That teens are more likely to utilize Facebook's granular privacy controls points to one of two things that lead to the same conclusion: 1. Teens care more about online privacy than adults, or, 2. Teens are simply more aware of social networking privacy controls than adults.

"Part one of a two-part series: Facebook, the global phenomenon in Web-based social media, rolled out a massive overhaul of its privacy protection policies and technology this week-and in so doing may have drawn up a playbook for healthcare as well, industry experts say. The privacy upgrade gives its 350 million worldwide users increased control over who has access to some of, but not all, the information on their personal pages. These new, so-called "granular" controls-specifically those embedded in the site's "publisher" function, which enables a user to post new material to his or her Facebook pages-reach down to the level of discrete data elements. The new controls, for example, allow a user to restrict who gets to see each newly posted photo or typed comment"

With increasing dependency on information systems and advances in cloud computing, the smart grid and mobile computing, maintaining the confidentiality and integrity of citizens' personally identifiable information is a growing challenge. A new draft document from the National Institute of Standards and Technology (NIST) addresses that challenge by adding privacy controls to the catalog of security controls used to protect federal information and information systems.

Times West Virginian FAIRMONT - Two FBI police officers have been charged and one was arraigned Friday morning in Marion County magistrate court after videotaping high school girls who were trying on prom dresses at the Middletown Mall. According to an FBI press release, the two Clarksburg-based employees were charged with criminal invasion of privacy and conspiracy to commit video voyeurism by the Marion County prosecuting attorney's office. Gary Sutton Jr., 40, was charged with criminal invasion of privacy and being a party to a crime. And according to WDTV, a warrant has been issued for Charles Brian Hommema of Buckhannon. The charges stem from an event called the Cinderella Project that took place at the Middletown Mall in Fairmont that gave high school girls the opportunity to buy low-cost prom dresses. The event was sponsored by Hospice Care Corp. for the sixth year in a row and included $25,000 worth of dresses from Oliverio's Bridal Boutique in Clarksburg. The criminal complaint stated that the two men were on duty in the FBI's satellite control room, which coincidentally is located at Middletown Mall. The two allegedly stopped a security camera over a makeshift dressing room that had been set up to allow the girls to try on dresses during the event. The dressing rooms did not have ceilings, and the camera zoomed in and trained its focus on one particular dressing room for more than an hour. Several girls used that dressing room to try on prom dresses. The complaint stated that Sutton and Hommema were the only people in the control room and the only ones able to control the movements of the camera. The alleged activities were detected internally by the FBI and reported to the Department of Justice's Office of the Inspector General, prompting an investigation, according to the FBI release. "The FBI is committed to the timely and full resolution of this matter, but must remain sensitive to the privacy concerns of any potential victims

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On Wednesday, February 11, 2009, the Data Protection Working Party, an independent European advisory body on data protection and privacy, released its Working Document 1-2009 (.pdf) on pre-trial discovery for cross border civil litigation. The Working Document attempts to reconcile the tension between U.S. discovery rules and the European Union's Directive 95/46/EC (.pdf), which outlines the EU's privacy requirements. What follows is a summary of the Working Document and an analysis of how it begins to bridge the gap between U.S. discovery rules and the European privacy framework. The Working Document offers guidance to EU data controllers responding to U.S. discovery requests. As the Working Document explains, those controllers often find themselves in a bind. On the one hand, U.S. law allows for broad discovery, which may require a controller to provide, or "process," personal data of customers or employees. On the other hand, Article 7 of EU Directive 95/46 limits a member state's authority to process such data. Under Article 7, a member state may process personal data only if one of six identified grounds for processing applies. The Working Document considers the Article 7 grounds most likely to supply a legitimate basis for compliance with a discovery request - namely 1) consent, 2) necessary for compliance with a legal obligation, and 3) necessary for the purposes of a legitimate interest, where such interests are not "overridden by the interests for fundamental rights and freedoms of the data subject." Recognizing that the "interests of justice would be served by not unnecessarily limiting the ability of an organisation to act to promote or defend a legal right," the Working Document suggests that the third basis - necessary for the purposes of a legitimate interest - will often provide a ground for processing data in response to a U.S. discovery request.

At last, my summer reading list is complete!

In what it described as an historic document, the National Institute for Standards and Technology issued a special report entitled Recommended Security Controls for Federal Information Systems and Organizations. Special Publication 800-53, Revision 3, is historic in nature. For the first time, and as part of a continuing initiative to develop a unified information security framework for the federal government and its contractors, NIST has included security controls in its catalog for national security and non-national security systems in its latest revision, No. 3, of Special Publication 800-53. "The important changes described (in the publication) are part of a larger strategic initiative to focus on enterprise-wide, near real-time risk management; that is, managing risks from information systems in dynamic environments of operation that can adversely affect organizational operations and assets, individuals, other organizations, and the nation," Ron Ross, NIST's Federal Information Security Management Act implementation project leader, said in a message incorporated into the 220-page report. According to the document, the updated security control catalogue incorporates best practices in information security from the Department of Defense, intelligence community and civilian agencies to produce the most broad-based and comprehensive set of safeguards and countermeasures ever developed for information systems.

The Government Accountability Office issued another scathing report saying that federal agencies still don't do enough to secure government IT assets. "Persistent weaknesses in information security policies and practices continue to threaten the confidentiality, integrity and availability of critical information and information systems used to support the operations, assets and personnel of most federal agencies," Gregory Wilshusen, GAO director of information security issues, wrote in a 66-page report issued Friday. "Recently reported incidents at federal agencies have placed sensitive data at risk, including the theft, loss, or improper disclosure of personally identifiable information of Americans, thereby exposing them to loss of privacy and identity theft." In a written response accompanying the report, federal CIO Vivek Kundra said OMB is committed to the vision of a secure federal government, and are taking steps to make that vision a reality. OMB, he said, has initiated a review of the language in the current reporting instructions to identify and clarify confusion in the annual reporting. OMB also is working with the CIO Council and the Council of Inspectors General on Integrity and Efficiency to improve guidance to agencies. The GAO report also said that nearly all of the 24 major federal agencies last year had weaknesses in information security controls. "An underlying reason for these weaknesses is that agencies have not fully implemented their information security programs," Wilshusen said. "As a result, agencies have limited assurance that controls are in place and operating as intended to protect their information resources, thereby leaving them vulnerable to attack or compromise."

1. You get what you pay for. 2. Americans do not take information or security as seriously as they do their love for profit & cost savings. If one does not value what they are trying to protect accurately, the investment one is prepared to make will always be insufficient. Then there are hindsight and rationalization (a.k.a. politicians) - Karl The Government Accountability Office issued another scathing report saying that federal agencies still don't do enough to secure government IT assets. "Persistent weaknesses in information security policies and practices continue to threaten the confidentiality, integrity and availability of critical information and information systems used to support the operations, assets and personnel of most federal agencies," Gregory Wilshusen, GAO director of information security issues, wrote in a 66-page report issued Friday. "Recently reported incidents at federal agencies have placed sensitive data at risk, including the theft, loss, or improper disclosure of personally identifiable information of Americans, thereby exposing them to loss of privacy and identity theft." In a written response accompanying the report, federal CIO Vivek Kundra said OMB is committed to the vision of a secure federal government, and are taking steps to make that vision a reality. OMB, he said, has initiated a review of the language in the current reporting instructions to identify and clarify confusion in the annual reporting. OMB also is working with the CIO Council and the Council of Inspectors General on Integrity and Efficiency to improve guidance to agencies. The GAO report also said that nearly all of the 24 major federal agencies last year had weaknesses in information security controls. "An underlying reason for these weaknesses is that agencies have not fully implemented their information security programs," Wilshusen said. "As a result, agencies have limited assurance that controls are in place and operating as intended to protect their inf

The loss of personally identifiable information, such as an individual's Social Security number, name, and date of birth can result in serious harm, including identity theft. Identity theft is a serious crime that impacts millions of individuals each year. Identity theft occurs when such information is used without authorization to commit fraud or other crimes. While progress has been made protecting personally identifiable information in the public and private sectors, challenges remain. GAO was asked to testify on how the loss of personally identifiable information contributes to identity theft. This testimony summarizes (1) the problem of identity theft; (2) steps taken at the federal, state, and local level to prevent potential identity theft; and (3) vulnerabilities that remain to protecting personally identifiable information, including in federal information systems. For this testimony, GAO relied primarily on information from prior reports and testimonies that address public and private sector use of personally identifiable information, as well as federal, state, and local efforts to protect the security of such information. GAO and agency inspectors general have made numerous recommendations to agencies to resolve prior significant information control deficiencies and information security program shortfalls. The effective implementation of these recommendations will continue to strengthen the security posture at these agencies. Identity theft is a serious problem because, among other things, it can take a long period of time before a victim becomes aware that the crime has taken place and thus can cause substantial harm to the victim's credit rating. Moreover, while some identity theft victims can resolve their problems quickly, others face substantial costs and inconvenience repairing damage to their credit records. Some individuals have lost job opportunities, been refused loans, or even been arrested for crimes they did not commit as a result of identit

The loss of personally identifiable information, such as an individual's Social Security number, name, and date of birth can result in serious harm, including identity theft. Identity theft is a serious crime that impacts millions of individuals each year. Identity theft occurs when such information is used without authorization to commit fraud or other crimes. While progress has been made protecting personally identifiable information in the public and private sectors, challenges remain. GAO was asked to testify on how the loss of personally identifiable information contributes to identity theft. This testimony summarizes (1) the problem of identity theft; (2) steps taken at the federal, state, and local level to prevent potential identity theft; and (3) vulnerabilities that remain to protecting personally identifiable information, including in federal information systems. For this testimony, GAO relied primarily on information from prior reports and testimonies that address public and private sector use of personally identifiable information, as well as federal, state, and local efforts to protect the security of such information. GAO and agency inspectors general have made numerous recommendations to agencies to resolve prior significant information control deficiencies and information security program shortfalls. The effective implementation of these recommendations will continue to strengthen the security posture at these agencies. Identity theft is a serious problem because, among other things, it can take a long period of time before a victim becomes aware that the crime has taken place and thus can cause substantial harm to the victim's credit rating. Moreover, while some identity theft victims can resolve their problems quickly, others face substantial costs and inconvenience repairing damage to their credit records. Some individuals have lost job opportunities, been refused loans, or even been arrested for crimes they did not commit as a result of identit

"Facebook founder Mark Zuckerberg made some big announcements Wednesday from the company's headquarters in Palo Alto about changes to how users control and organize their information on the service. Zuckerberg has been criticized in the past for not caring about privacy, making statements that worry some. He once told TechCrunch that privacy was no longer the social norm. But the 26-year-old CEO has just done an about face. He told a room full of journalists, "It is a core part of our belief that people own and have control of all the information they upload.""

Can Zuckerberg be trusted not to reverse course - again. His immaturity as a leader and abuse of user trust makes one question everything that comes out of the man's mouth.

"Lora Bentley spoke with Anzen analysts Megan Brister and Jordan Prokopy via e-mail regarding behavioral advertising - what companies are doing, what regulators want to do and what we, as advertising consumers, need to know. With their coworker Miyo Yamashita, the analysts recently wrote a guest opinion for IT Business Edge. Bentley: Why are so many concerned about privacy when it comes to behavioral advertising? What is it about the Internet that convinces consumers that information they share there is not being used? Brister and Prokopy: Most concerns stem from the lack of transparency around data disclosure practices. While consumers may value a Web site's product and service offerings, they are generally unaware that businesses share their information with an extensive group of other businesses in order to deliver targeted advertising. This group includes news Web sites, advertising networks, profiling services, and Web analytics providers, to name a few. As Pamela Jones Harbour, a Commissioner at the Federal Trade Commission (FTC), discussed at the FTC Roundtable earlier this week, there is an asymmetry between consumer perceptions and business realities. Once consumers are informed of businesses' data handling practices, they will want to have more control over how businesses manage their information. As we discuss in our article, some businesses engaged in online behavioral advertising have been slow to adopt transparent consumer data management policies. This is a concern particularly for vulnerable groups, such as minors or non-English speaking consumers, because they may not understand legally written policies. Consumer advocacy groups argue that without knowledge and control over the collection, use, and disclosure of data, Web sites may misuse or expose sensitive data about consumers' health, lifestyles and finances."

"The U.S. Supreme Court Monday will hear arguments for and against the constitutionality of the oversight board established to monitor public company financial activity as part of the Sarbanes-Oxley regulation. The Sarbanes-Oxley Act was created and enacted into law partly in response to corporate accounting scandals such as Enron and WorldCom. The regulatory standard set out to reduce such fraudulent financial activities and provide an oversight mechanism for public companies. Part of the law includes the establishment of the Public Company Accounting Oversight Board (PCAOB), which consists of five members appointed by the Securities and Exchange Commission (SEC). The arguments to be heard this week relate directly to the PCAOB. While set up to regulate financial accounting at companies, those opposed to the board's powers argue that because its members are not appointed by the president, the board's control is unconstitutional based on the country's tenets of three branches of government. The challengers to the law say that the PCAOB lacks the presidential control required for executive branch agencies because the five members are appointed by the SEC, which doesn't fall under presidential powers. As a private agency in essence, the PCAOB is able to act as a government authority, which the Free Enterprise Fund believes to be unconstitutional. "

A new malware variant called Silon is targeting Internet Explorer users, attempting to intercept their sessions and steal credentials. "Researchers at security vendor Trusteer Inc. issued an advisory warning that the Silon Trojan can detect when a user initiates a Web login session in Internet Explorer. It intercepts the login session, encrypts the data and sends it to a command-and-control server where it is collected with credentials from other victims. In a more sophisticated attack, the Trojan targets people logging into their online bank accounts. New York, N.Y.-based Trusteer said Silon can inject sophisticated dynamic HTML code into the login flow between the user and their bank's Web server. The method involves using a webpage displaying a phony message asking the victim to verify their login details. If the victim complies with the request, the login credentials are sent to the command-and-control server, said Amit Klein, chief technology officer of Trusteer. "

Cable operators will sit in the hot seat Thursday as Congress reviews their plans to roll out targeted advertising amid fears that consumer privacy could be infringed if the companies were to track and record viewing habits. The House subcommittee on Communications, Technology and the Internet will hold a hearing that will look at new uses for digital set-top boxes, the devices that control channels and perform other tasks on the TV screen. Cable TV companies plan to use such boxes to collect data and direct ads more targeted to individual preferences. "We have recently called on Congress and the Federal Trade Commission to investigate cable's new interactive targeted TV ad system on both antitrust and privacy grounds," said Jeff Chester, executive director of the Center for Digital Democracy. He's concerned about Canoe Ventures, a consortium formed by the nation's six largest cable companies to oversee the rollout of targeted and interactive ads nationally. Chester worries that Canoe will track what consumers do in their homes. Currently, cable companies aim their ads based strictly on geography. Now, cable's goal is to take the Internet's success with targeted ads and transfer that to the TV medium. Thus, a household that watches a lot of Nickelodeon and the Disney Channel eventually could be targeted for theme parks promotions. This type of targeting is something broadcast TV can't do. For starters, Canoe plans to offer ads this summer that consider demographic factors such as age and income. Philadelphia-based Comcast Corp. and Cablevision Systems Corp. of Bethpage, N.Y., also have been testing or rolling out targeted ads outside the consortium. But cable operators are wary about being seen as trampling on consumer privacy and reiterate that they don't plan to target based on any personally identifiable information, such as someone's name and address. Canoe said it doesn't have plans this year to use set-top box data for ads. Instead, the first ads it pl

Google has moved forward the debate about privacy and Internet advertising, in its typical way, with deceptively simple engineering and a willingness to impose its way on others. On Wednesday, Google became the last of the big advertising companies to start keeping track of where Internet users surf online so ads can be shown to people based on what they might be interested in buying. In its approach to ad targeting, the company is responding to calls by the Federal Trade Commission and others to be more clear with users' information and control over the information it collects. It has created a window into part of its database, so users can see that Google has deduced that they are interested in "Anime & Manga" comics, or "Alternative-Punk-Metal" music or travel to Afghanistan. (Yes, those are on its list of 600 interest categories.) It also built technology to allow your browser to remember that you don't want Google (or its DoubleClick unit) to remember anything about you. It is more robust than the opt-out system used by many companies that rely on cookies in browsers. These are technical feats that other ad companies said would be too hard.

The organization charged with administering the Payment Card Industry Data Security Standard (PCI DSS) is trying to give merchants a compliance blueprint. The Prioritized Approach Tool offers six "milestones" that businesses should try to reach in their pursuit of compliance, said Lib de Veyra, the newly appointed chairman of the PCI Security Standards Council, which manages the guidelines. When faced with a standard as robust as PCI DSS, many companies, particularly the smaller merchants, need help deciding which risks they should address first, de Veyra told SCMagazineUS.com on Friday. The tool, to be published Tuesday on the council's website, also helps retailers and their acquiring banks demonstrate and measure progress. Rated by order of criticality, the milestones are: Limit data retention, secure the perimeter, secure applications, control system access, protect stored cardholder data and finalize remaining compliance efforts, ensuring all controls are in place. "You take care of Milestone One and you've significantly reduced the risk in the event of a data breach because, where's the data?" de Veyra said.

The recent U.S. stimulus bill includes $18 billion to catapult the health industry toward the world of electronic health records. This is sure to light a fire under every hungry security vendor to position itself as the essential product or service necessary to achieve HIPAA compliance. It should also motivate healthcare IT professionals to learn where their sensitive data is located and how it flows. To be sure, with federal money allocated through 2014 for the task of modernizing the healthcare industry there will be many consultant and vendor businesses that will thrive on stimulus money. Healthcare is unique in that storage of electronic health records is highly distributed between primary care physicians, specialist doctors, hospitals, and insurance/HMO organizations. Information has to be efficiently shared among these entities with great sensitivity towards patient privacy and legitimate claims processing. Patients want to prevent over zealous employers from performing unauthorized background checks on medical history; claim processors want to prevent paying fraudulent claims arising from targeted patient identity theft. The bill has two provisions which turn this into a tremendously challenging plan, and a daunting task for securing patient data: * Citizens will have the right to monitor and control use of their own health data. This implies a large centralized identity and access control service, or perhaps a federated network of patient registration directories. Authenticated users will be able to reach into the network of health databases audit use of their data and payment history. * Health organizations suffering loss of more than 500 patient records must publicly disclose the breach, starting with postings on the government's Health and Human Services website. This allows related organizations to trace the impact of the breach throughout the healthcare network, but care must be taken not to disclose vulnerabilities in the system to intruders

A group of federal agencies and private organizations, including the National Security Agency and the Department of Homeland Security, has released a set of guidelines defining the top 20 things organizations should do to prevent cyberattacks. The Consensus Audit Guidelines (CAG) describe the 20 key actions, referred to as security controls, that organizations should take to defend their computer systems. The controls are expected to become baseline best practices for computer security, following further public- and private-sector review. CAG is being led by John Gilligan, formerly the CIO for both the U.S. Air Force and the U.S. Department of Energy, and a member of the Obama transition team dealing with IT in the Department of Defense and various intelligence agencies. "We are in a war, a cyberwar," Gilligan said on a media conference call. "And the federal government is one of many large organizations that are being targeted. Our ability at present to detect and defend against these attacks is really quite weak in many cases." Borrowing an analogy he attributed to an unnamed federal CIO, Gilligan said, "We're bleeding badly and we really need triage and we need to focus on things that will keep this patient alive." The CAG initiative represents part of a larger effort, backed by the Center for Strategic and International Studies (CSIS) in Washington, D.C., to implement recommendations from the CSIS Commission report on Cybersecurity for the 44th Presidency.

Yesterday, the U.S. Supreme court announced its refusal to hear appeals against the banning of the Child Online Protection Act (COPA), effectively killing the bill. The American Civil Liberties Union called it "a clear victory for free speech," having fought the bill for ten years claiming it infringed on a website's freedom of speech. I've always advocated that it is the responsibility of parents to monitor their children's online activity. There are a ton of Web filtering and parental control applications available, many for free such as Blue Coat's K9 Web Protection. Especially with the country in the shape it's in now, my personal opinion is that the government has more pressing issues to attend to than babysitting children online. COPA was first passed in 1998, and made it illegal to display any pornographic material on a Web site without an access code or proof of age message. However, state courts began challenging the bill immediately, claiming it was unconstitutional and violated the First Amendment. Instead, it was ruled that parental controls should be used by individual families to block unwanted content, rather than the government determining what can and cannot be seen by all. (COPA was killed, not COPPA - Children's Online Privacy Protection Act)

Salesmen and parents know the technique well. It's called the takeaway, and as far as Keith Mularski is concerned, it's the reason he kept his job as administrator of online fraud site DarkMarket. DarkMarket was what's known as a "carder" site. Like an eBay for criminals, it was where identity thieves could buy and sell stolen credit card numbers, online identities and the tools to make fake credit cards. In late 2006, Mularski, who had risen through the ranks using the name Master Splynter, had just been made administrator of the site. Mularski not only had control over the technical data available there, but he had the power to make or break up-and-coming identity thieves by granting them access to the site. And not everybody was happy with the arrangement. A hacker named Iceman -- authorities say he was actually San Francisco resident Max Butler -- who ran a competing Web site, was saying that Mularski wasn't the Polish spammer he claimed to be. According to Iceman, Master Splynter was really an agent for the U.S. Federal Bureau of Investigation. Iceman had some evidence to back up his claim but couldn't prove anything conclusively. At the time, every other administrator on the site was being accused of being a federal agent, and Iceman had credibility problems of his own. He had just hacked DarkMarket and three other carder forums in an aggressive play at seizing control of the entire black market for stolen credit card information. ....In the end they would regret that decision. Iceman was right