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Enterprise role management is key in efficiently managing user access rights and enforcing access policies such as segregation of duties. Roles help companies group coarse- and fine-grained access rights (like access to and functionality within a financial accounts application) into groups, called enterprise roles. These enterprise roles map to job functions and are only allowed access rights that don't violate segregation of duties. For instance, a financial clerk role can't contain fine-grained access rights that allow someone in the role to access the accounts receivable and accounts payable parts of the financial application. The processes and tools necessary for effective role management consist of role mining and design (automatic discovery and management of roles based on existing access rights and entitlements data), role recertification (a process performed typically every six months when a business role custodian certifies what access rights should belong to a role), and access recertification (a process performed typically every 3-6 months to ensure all user access is understood and was granted in an audited way).

Twitter posts may seem different from e-mail, but legally they aren't, so more companies are including them in their e-discovery policies, reports InformationWeek's Bob Evans. The subject is more than a little confusing, Evans finds, but one thing is clear: If you do have a policy on Twitter posts, it had better be enforced.

There is pervasive fear of identity theft. Victims spend an extraordinary amount of time and money recovering from it. The government is doing something about it, but businesses may not be pleased to hear that the government's latest action is another unfunded mandate. New rules concerning identity theft prevention at financial companies go into effect on Friday May 1, 2009, but for most organizations, complying with the FTC's Red Flags Rule could be as simple as writing down rules and procedures already in place and having them certified by the Board. The rules are about procedures, not about data security, said Tiffany George, attorney for the division of privacy and identity protection at the FTC. She spoke on Tuesday at the FTC's workshop for businesses held on the campus of Fordham University in New York City. "The Red Flags Rule covers what to do when, despite our best efforts, thieves steal data," she said. As new regulations go, the FTC's Red Flags Rule will be less painful than many other recently enacted rules. For example, while Sarbanes-Oxley is considered a burden to many public companies, requiring several full-time staff, the Red Flags Rule can likely be handled by legal or compliance staff already in place.

There are four "high risk" areas that aren't getting the attention they deserve as financial institutions work toward complying with the ID Theft Red Flags Rule, says a leading industry compliance expert. Many institutions have already complied with the regulation and have done their risk assessment to identify covered accounts and determined what red flags they need to be monitoring. But there are areas that should be considered "high risk" and aren't getting the attention they deserve from institutions, says Sai Huda, CEO of Compliance Coach. The Red Flags Rule is a risk-based regulation. As such, Huda says, compliance should be approached from a risk management and not a purely technical perspective, and institutions should ask these questions: * Which accounts are more at risk to identity theft? * Which red flags represent higher risk? * Which detection and response procedures are commensurate with the risks? * Which service providers pose greater risk? * What controls exist to mitigate the risks? The big question that most institutions have at top of mind is "What about enforcement?" Huda says the federal banking regulators are taking a risk-based, top-down approach when assessing institutions. "They are first assessing whether the [institution] has implemented a risk-based program and how it is overseeing compliance," he says. "If the program is risk-based and sound, they will limit their scope. If not, then they will dig deeper."

Consumers, who become victims of identity theft through access to public records, do not have a clue as to how they became a victim. They cannot know unless the fraudster who "legally accessed" the public information is caught and confesses that they used or sold the information for identity theft. Most often end users of stolen identities are caught, not the kingpins. Illegal immigrants who purchase identities on the street sometimes for hundreds of dollars do not know the source. * What can an identity thief do with a name and SSN? Here is a short list. * Make a fake Social Security Card (see image below) * Make a fake Medicare Card and get medical treatment and Medicare benefits * Use the fake Social Security Card to get a driver's license or passport * Get a job and government benefits. * Get credit and open new financial accounts * Get housing, utilities and phone service * Get insurance * Thieves use fake ID to elude law enforcement by pretending they are you.

Some American Express card members' accounts may have been compromised by an employee's recent theft of data, the company said Thursday. American Express Co. spokeswoman Susan Korchak said a "relatively small portion" of card members was involved, but declined to be more specific. The former employee has been arrested and the company is investigating how the data was obtained, she said. The company is in the process of notifying affected card members by letter. In one such letter sent last week, American Express Privacy Officer Alfred Silipigni said he was informing the member of "an unfortunate issue" concerning his card. "We recently learned that certain account data was acquired without authorization by an employee who is no longer with the company," he wrote. "The former employee has been arrested, and we are cooperating with law enforcement authorities with their ongoing investigation." American Express declined to disclose any more details about the incident beyond what was in the letter. The company has put additional fraud monitoring and protection controls on the accounts at issue, Korchak said. American Express has about 39 million corporate, small business and consumer cards in force in the United States.

Difficult economic times can be the breeding ground for increased fraudulent activities. In July 2009, the Financial Crimes Enforcement Network (www.fincen.gov) published its 12th edition of The SAR Activity Review - By the Numbers. SARs (Suspicious Activity Reports) are one key aspect of FinCEN's efforts related to its responsibility for regulatory administration of the Bank Secrecy Act of 1970. Many different financial industries such as banks, credit unions, insurance companies, check-cashing services, broker/dealers, and casinos are required to complete and file SARs. According to FinCEN's press release on the SAR Activity Review, "The report reveals that of the 20 different violation types tracked, seven of the categories relate specifically to fraud and all seven showed an increase in SAR filings during the year. While these categories represent one-third of the possible violation types, they accounted for nearly half of the increase in total SAR filings from 2007 to 2008, with all of the fraud categories seeing double-digit increases in percentage of filings in 2008. These categories are: check fraud, mortgage loan fraud, consumer loan fraud, wire transfer fraud, commercial loan fraud, credit card fraud, and debit card fraud." Could any of this apply to you? Are your control and monitoring processes able to identify these examples of common patterns of suspicious activity that FinCEN has identified?

CSOs in healthcare organizations know that the Health Information Technology for Economic and Clinical Health (HITECH) Act, signed into law in February 2009, includes new privacy requirements that experts have called "the biggest change to the health care privacy and security environment since the original HIPAA privacy rule." These include: New requirements that widen the definition of what Personal Health Information (PHI) information must be protected and extend accountability from healthcare providers to their business associates; Lower thresholds, shorter timelines, and stronger methods for data breach victim notification; Effective immediately, increased and sometimes mandatory penalties with fines ranging from $25,000 to as much as $1.5 million; More aggressive enforcement including authority to pursue criminal cases against HIPAA-covered entities or their business associates. No doubt, the HITECH Act raises the stakes for a data breach. But regulations aside, data breaches can hurt your organization's credibility and can carry huge medical and financial risks to the people whose data is lost. We've managed hundreds of data breaches and helped thousands of identity theft victims. Through this we've learned firsthand that compliance doesn't necessarily equal low risk for data breach. For the well being of the business and patients, healthcare organizations and their partners need to take the most comprehensive approach to securing PHI.

There is no simple technology solution to protect children from bullying, pornography, sexual predation and other online threats, a new study says. The highly anticipated report -- results of a year-long study ordered by 49 state attorneys general -- found that "a combination of technologies, in concert with parental oversight, education, social services, law enforcement, and sound policies by social-network sites and service providers, may assist in addressing specific problems that minors face online," according to a draft of the report reviewed by The Wall Street Journal. The report also found that the risks that minors face on the Web -- notably bullying and harassment by peers -- aren't very different from those they face in the real world. The report is scheduled to be issued Wednesday by the Internet Safety Technical Task Force, led by Harvard University's Berkman Center for Internet and Society. Task-force members included representatives of several top Internet and security companies, including News Corp.'s MySpace, Google Inc., Time Warner Inc.'s AOL and Facebook Inc. (News Corp. also publishes the Journal.) The 278-page report is a boon for the Web companies, which have long argued that technology isn't the sole solution to the dangers kids face online. It is a disappointment for those in favor of stricter technological controls, such as age-verification and filtering tools.

Travelers arriving at U.S. borders may soon be confronted with their laptops, PDAs, and other digital devices being searched, copied and even held by customs agents -- all without need to show suspicion for cause. Notices are being proposed by the Privacy Office at the U.S. Department of Homeland Security (DHS), which last week released a report approving the suspicionless searches of electronic devices at U.S. borders. The 51-page Privacy Impact Assessment also supported the right of U.S. Immigration and Customs Enforcement agents to copy, download, retain or seize any content from these devices, or the devices themselves, without assigning any specific reason for doing so.

Online crime is increasingly hitting small and mid-size companies in the U.S., draining those entities' bank accounts through fraudulent transfers. The problem has gotten so bad that a financial services group recently sent out a warning about the trend, and the Federal Deposit Insurance Corporation (FDIC) issued an alert today. "In the past six months, financial institutions, security companies, the media and law enforcement agencies are all reporting a significant increase in funds transfer fraud involving the exploitation of valid banking credentials belonging to small and medium sized businesses," says a bulletin sent on Aug. 21 to member financial institutions by the Financial Services Information Sharing and Analysis Center, (FS-ISAC). The FS-ISAC is part of the government-private industry umbrella working with the Department of Homeland Security and Treasury Department to share information about critical threats to the country's infrastructure. The member-only alert described the problem and told its members to implement many of the precautions and monitoring currently used to detect consumer bank and credit card fraud.

Health IT industry leaders and privacy advocates are watching carefully to see how the federal government will enforce expanded health data breach notification rules set to take effect this week, Federal Computer Week reports. HHS' breach-notification rule, which applies to HIPAA-covered entities and business associates, is scheduled to take effect tomorrow. The Federal Trade Commission's companion rule, which applies to personal health record vendors and other non-HIPAA-covered entities, is scheduled to take effect Thursday. The federal economic stimulus package mandated the creation of both rules.

"Recently, the Federal Trade Commission (FTC) has gotten tough with US companies that have not lived up to their own privacy promises to European consumers. In particular, it has filed complaints against seven US companies that claimed that they were adhering to the European Union's Safe Harbor Program, but allegedly were not. (The FTC issues or files a complaint when it has "reason to believe" that the law has been or is being violated, and it appears to the Commission that a proceeding is in the public interest. The complaints themselves are not a finding or ruling that the named parties have violated the law.) By taking action, the FTC has shown that the Safe Harbor program, as applied to US companies, is not a set of empty promises. Rather, the FTC is keeping watch over businesses and will sanction those that misrepresent their own policies. In this column, I will explain how the Safe Harbor program works, and also discuss the recent FTC enforcement actions."

Hospital CIOs, chief information security officers, and privacy officers are working diligently to keep their names off that wall. But they are dealing with a regulatory environment that is still in flux. A final rule that will strengthen HIPAA privacy and security safeguards is due out before the end of the year. HHS also has proposed a rule for the accounting of disclosures from electronic records. The biggest shift under way may be a new enforcement regime as the HHS Office for Civil Rights (OCR) shifts gears from only reacting to data breach reports to begin random audits of the privacy and security safeguards of large and small providers and their business associates. Another new wrinkle under the HITECH Act is that state attorneys general can file civil lawsuits for HIPAA violations.

State and federal lawmakers continue to introduce bills regulating the collection, use and security of consumer and personal information. The proposed federal bills could change the national privacy framework. At the same time, regulators and the plaintiffs' bar remain focused on privacy and security issues and continue to initiate enforcement actions and class action suits. This program will address these developments and provide tips for managing privacy concerns in an era of fast-changing privacy laws.

Last week, the government took another step toward closing a legal loophole in federal privacy and security rules for emerging Health 2.0 information technology applications by issuing proposed rules aimed at covering an estimated 900 companies and organizations offering personal health records and electronic systems connected to them. The Federal Trade Commission was careful to point out its new interim proposed rule on federal breach notification requirements for the developers of electronic PHR systems did not apply to covered organizations or their business associates as defined by the Health Insurance Portability and Accountability Act of 1996, heretofore the key federal privacy and security regulation. The FTC, operating under new authority given it by the American Recovery and Reinvestment Act of 2009, noted that its new rule seeks to cover previously unregulated entities that are part of a Health 2.0 product mix. FTC staff estimates that about 200 PHR vendors, another 500 related entities and 200 third-party service providers will be subject to the new breach notification rule. The staffers estimate that the 900 affected companies and organizations, on average, will experience 11 breaches each per year at a total cost of about $1 million per group, per year. Costs include investigating the breach, notifying consumers and establishing toll-free numbers for explaining the breaches and providing additional information to consumers. Pam Dixon, founder and executive director of the World Privacy Forum, said that this isn't the first involvement of the FTC in healthcare-related regulation, noting the consumer protection agency joined with the Food and Drug Administration in a joint statement on the marketing of direct-to-consumer genetic tests. The FTC also has worked in the field of healthcare competition. She noted the compliance deadline with the FTC's "red flag rules" on provider organizations that provide consumer credit to patients for installment payment

Set of podcasts providing a road map through the 4th Amendment of the Constitution, particularly a 4th Amendment search. Intended to give you a step-by-step approach through the 4th Amendment to the Constitution of the United States as it applies to searches, your expectation of privacy and related issues.

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This tip is part of Mitigating Web 2.0 threats, a lesson in SearchSecurity.com's Data Protection Security School. Visit the lesson page or our Security School Course Catalog for additional learning resources. Social networking, a term relatively new to the computing vernacular, has already become part of the cultural norm for a great proportion of Internet users. Even more recently, the use of online communities to establish and build connections among those with shared interests has become part of the corporate world as well. As professional social networks such as LinkedIn and Blue Chip Expert continue to grow, and professional groups gain in popularity on once-personal sites like Facebook and MySpace, enterprise security and risk management professionals must face the reality that these sites are emerging conduits for the unauthorized disclosure of confidential corperate information. Add the use of public social networking tools to the list of concerns, and the effectiveness of the traditional corporate security perimeter is further diminished. However, a robust set of policy, process and architecture aids in mitigating the risks of being social. Broadly, social networking is described as software that lets people interact, rendezvous, connect, play or collaborate by use of a computer network. This definition covers the popular social networking sites, including those mentioned above, as well as blogs, wikis, RSS, podcasts, tags, and more recently, search engines. While there are numerous benefits to social network solutions, including reducing costs and increasing collaboration, we'll focus on addressing the risks.

Those who are superstitious may believe that bad things happen on Friday the 13th, but we will leave it to each individual and entity to formulate conclusions regarding the Health Information Technology for Economic and Clinical Health Act (the HITECH Act), which Congress passed late on Friday, February 13, 2009, and President Obama officially signed into effect on February 17, 2009. The HITECH Act addresses various aspects relating to the use of health information technology (H.I.T.), including providing for federal funding by way of grants and incentive payments in order to promote H.I.T. implementation. This Alert focuses, however, on Subtitle D of the HITECH Act, which includes important, new and far-reaching provisions concerning the privacy and security of health information that will materially and directly affect more entities, businesses and individuals in more diverse ways than ever before. These changes are further elaborated upon below, but this Alert can only highlight certain prominent issues under the HITECH Act and is by no means a comprehensive review of this lengthy and complex Act. For questions and additional guidance on the HITECH Act, contact your Fox Rothschild attorney or the authors of this Alert. New Privacy and Security Requirements * Security Breach Notification Requirements: Security breach notification requirements under the HITECH Act go into effect 30 days after the date that interim final regulations are promulgated, which will be no later than 180 days after the date of enactment of the HITECH Act (August 16, 2009). Covered entities, business associates and vendors who handle personal health records are required to abide by breach notification requirements. Violations of this requirement by vendors would be treated as an unfair and deceptive act or practice in violation of the Federal Trade Commission Act. If a breach affects more than 500 individuals of a particular state, notice also must be provided to prominent media outl

Another report on Sears getting slapped on the wrist for questionable data collection. Gee, why don't businesses take information law seriously? Maybe because it is more profitable to ignore it and pay a small fine? Not impressed by Obama's enforcement of privacy law.

Sears today agreed to settle Federal Trade Commission charges that it failed to disclose the depth of consumers' personal information it collected via a downloadable software application. The settlement calls for Sears to stop collecting data from the consumers who downloaded the software and to destroy all data it had previously collected. If Sears advertises or disseminates any tracking software in the future, it must clearly and prominently disclose the types of data the software will monitor, record, or transmit, the FTC stated. Sears must also disclose whether any of the data will be used by a third party, the FTC said.