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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.

With the ink barely dry on headlines about what could be the biggest security breach in history (identity thieves hacked into payment processor Heartland Payment Services, possibly gaining access to the credit-card information of millions of consumers) signing up for a credit-monitoring service may have jumped a few notches on your to-do list. After all, paying $12 or so a month seems like a small price to pay for the peace of mind that -- through regular alerts about activity on your credit reports and other monitoring services -- you'll be protected from identity theft. Right? Think again.

Wikipedia told the controversial U.K. advertising firm Phorm on Thursday not to spy on Wikipedia's users, saying the company's plan to monitor what sites people visit on the net invaded people's privacy. Wikipedia now joins Amazon.co.uk in opting out of the Big-Brother-esque marketing scheme and creating the possibility of a mass opt-out by the net's largest websites. Phorm wants to pay ISPs -- such as British Telecom -- to let it build marketing profiles of its subscribers by installing boxes inside the ISP that monitor every url users visit and every search they run. Using those profiles, Phorm can charge advertisers high rates to serve targeted ads. But in an email sent Thursday, Wikimedia.org told Phorm not to record anything about urls from domains it controls, ranging from Wikiquotes to Wikipedia -- one of the most popular sites on the net. Phorm operates an opt-out system for sites and ISP customers, but it would be virtually impossible to verify if the company actually complied with such requests. "The Wikimedia Foundation requests that our web sites including Wikipedia.org and all related domains be excluded from scanning by the Phorm / BT Webwise system, as we consider the scanning and profiling of our visitors' behavior by a third party to be an infringement on their privacy," the email read, according to a Wikimedia blog post.

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With Twitter firmly established as the "conversation place to be," marketers are beginning to look for where they fit in. And that means tools. For the uninitiated, Twitter is a service that lets individuals exchange 140-character messages-via computer or mobile device-with groups of "followers." The result is a fast-and-loose, multidimensional conversation that falls somewhere in between blogging and text messaging, happening in real time between millions of users around the world. Luckily, the Web interface for Twitter.com is just the start of many ways to interact with and glean intelligence from Twitter conversations. There is big potential value for tapping into the Twitter-stream for insights into what customers are saying about your company's brand and its market. "Millions are leaning on Twitter pretty hard as a way to network and communicate with contacts new and old," said John Jatsch, a social marketing expert and operator of Duct Tape Marketing. He added that marketers have many options for how to use Twitter, including connecting with customers, monitoring conversations and testing new ideas. To use Twitter to its fullest, b-to-b marketers should consider using the following handful of tools and services: ??Twitter clients. It doesn't take long for most Twitter users to move beyond using Twitter.com to post and monitor their posts or "tweets." There are much more powerful tools at your disposal for reading, filtering, searching and posting to Twitter.com. The list of Twitter clients includes popular Mac client Twitterific; Adobe Air-based clients such as Twhirl, Tweetr and Spaz; Firefox add-ons like Twitterfox and TwitBin; and software that lets you track multiple social engines-such as Facebook, FriendFeed and even instant messaging as well as Twitter-like Digsby and AlertThingy. A new client receiving a lot of buzz is TweetDeck, which features a huge but customizable user interface that makes it easier to track posts, re

The departments of Defense, State, and Health and Human Services have not met legal requirements meant to protect Americans' civil liberties, and a board that's supposed to enforce the mandates has been dormant since 2007, according to federal records. All three departments have failed to comply with a 2007 law directing them to appoint civil liberties protection officers and report regularly to Congress on the safeguards they use to make sure their programs don't undermine the public's rights and privacy, a USA TODAY review of congressional filings shows. An independent Privacy and Civil Liberties Oversight Board set up to monitor the departments hasn't met publicly since 2006; it no longer has members. Government missteps such as putting innocent people on terrorist watch lists and misusing administrative warrants, known as national security letters, "might have been dealt with much sooner if we had … cops on the beat to make sure there are standards that are being upheld," says Caroline Fredrickson, legislative director at the American Civil Liberties Union (ACLU). The lack of civil liberties officers at State and Health and Human Services is troubling because the departments hold passport and medical records, says James Dempsey, vice president of the Center for Democracy and Technology. "Security of that information is very important," he says, and these officers should monitor how it's used and shared. The Pentagon also has sparked concerns. Its Counterintelligence Field Activity office was criticized by the ACLU for wrongly tracking anti-war groups - a charge confirmed by the Pentagon in 2006. A 2007 law requires eight departments and agencies to have civil liberties officers and file reports. Justice, Homeland Security, Treasury, the CIA and the Office of the Director of National Intelligence have done so. Sens. Joe Lieberman, I-Conn., and Susan Collins, R-Maine, leaders of the Homeland Security committee, says departments not in compliance will b

Until now, lawsuits seeking to recover significant damages based on the loss of, or unauthorized access to, sensitive personal information have not been especially successful for plaintiffs. Most companies suffering data breaches have escaped by offering affected consumers inexpensive credit monitoring services. But two recent cases show plaintiffs a way to expose many previously safe companies to substantial claims for damages. Any company that thinks there are no risks in employing less than best practices for data privacy and security needs a wake up call. The headlines are all too familiar. Some well known consumer services company (or less known wholesale data processor) announces that millions of individual records containing names, Social Security numbers, account numbers and other sensitive information were left in a dumpster, saved to a stolen, unencrypted laptop, or stored on a misplaced USB drive or backup tape. The press is terrible, the company's stock takes a temporary plunge, and sometimes the Federal Trade Commission enters into a consent decree where the company promises to never do it again. But when affected individuals or groups of consumers tried to sue for damages, they seldom recover significant amounts. These cases have not often succeeded because the plaintiffs have been unable to prove actual pecuniary losses resulting from the security breach. Sure, if identify theft occurs the affected individuals can suffer significant emotional trauma, loss of time, etc. But Courts have been unwilling to award damages for anxiety, fear, and other emotional harm that can result from a data breach, for the risk of future identify theft, or for actual identity theft when the plaintiff could not prove that the theft occurred as a direct result of a data breach at a particular source. Most companies facing claims based on data breaches have been able to settle cheaply by offering to provide credit monitoring services, which most consumers do not use, resu

As I'm sure you know, former NSA analyst Russell Tice revealed that the agency spied on journalists and ordinary Americans - not just communications between the U.S. and overseas. Speaking on the Keith Olbermann show on MSNBC, Tice said: "The National Security Agency had access to all Americans' communications," he said. "Faxes, phone calls and their computer communications. … They monitored all communications." He made a further appearance on Olbermann Thursday (view above), in which he said that the NSA combined these illegal wiretaps with credit card and financial data. ""This [information] could sit there for ten years and then potentially it marries up with something else and ten years from now they get put on a no-fly list and they, of course, won't have a clue why," Tice said. "This is garnered from algorithms that have been put together to try to just dream-up scenarios that might be information that is associated with how a terrorist could operate," Tice said. "And once that information gets to the NSA, and they start to put it through the filters there . . . and they start looking for word-recognition, if someone just talked about the daily news and mentioned something about the Middle East they could easily be brought to the forefront of having that little flag put by their name that says 'potential terrorist'." Why were they monitoring reporters? New York Times reporter James Risen told Olbermann he thought it was a plot "to have a chilling effect on potential whistleblowers in the government to make them realize that there's a Big Brother out there that will get them if they step out of line."

Hackers, possibly from Asia, have stolen about a decade's worth of personal information on current and former UC-Berkeley students, the university announced Friday. The breaches involved records dating to 1999 at the school's health center that included Social Security numbers, health insurance information, immunization history and the names of treating physicians. No other treatment-related records were stolen, the university said, although self-reported medical histories of students who studied abroad were hacked. The school on Friday sent e-mails and letters to 160,000 people, including about 3,400 Mills College students who used or were eligible for University of California-Berkeley medical services. About 97,000 people are most at risk because their names and Social Security numbers could be connected by the hackers, said Steve Lustig, the university's associate vice chancellor for health and human services. "What's been taken is bits of data that the thief might put together into an identity," he said. The university traced the hackers back to Asia, possibly China, but the exact origin could not be pinpointed. UC and FBI investigators are probing the breaches, which apparently occurred over several months. An FBI spokesman said the agency was informed of the hacking immediately, but declined to provide more information. The thefts were discovered about a month ago, but system administrators did Advertisement not realize the breadth of the attack until April 21. The hackers disguised their work as routine operations and then left taunting messages for UC-Berkeley employees, said Shelton Waggener, the university's associate vice chancellor for information technology. The thieves accessed the information through the university Web site, he said. "You should think of it as a public building," Waggener said. "They got into the building properly, but then they broke into secure areas." Administrators at Mills College, which contracts with UC-Berkeley for

"Big Brother is watching. That is the message corporations routinely send their employees about using email. But recent cases have shown that employees sometimes have more privacy rights than they might expect when it comes to the corporate email server. Legal experts say that courts in some instances are showing more consideration for employees who feel their employer has violated their privacy electronically. Driving the change in how these cases are treated is a growing national concern about privacy issues in the age of the Internet, where acquiring someone else's personal and financial information is easier than ever. "Courts are more inclined to rule based on arguments presented to them that privacy issues need to be carefully considered," said Katharine Parker, a lawyer at Proskauer Rose who specializes in employment issues. In past years, courts showed sympathy for corporations that monitored personal email accounts accessed over corporate computer networks. Generally, judges treated corporate computers, and anything on them, as company property. Now, courts are increasingly taking into account whether employers have explicitly described how email is monitored to their employees."

Is it a violation of privacy that should be banned or a tool necessary to keep the internet running? Canada's privacy commissioner has opened an online discussion on deep packet inspection, a technology that allows internet service providers and other organizations to intercept and examine packets of information as they are being sent over the internet. "We realized about a year ago that technologies involving network management were increasingly affecting how personal information of Canadians was being handled," said Colin McKay, director of research, education and outreach for the commissioner's office. The office decided to research those technologies, especially after receiving several complaints, and realized it was an opportunity to inform Canadians about the privacy implications. Over the weekend, the privacy commissioner launched a website where the public can discuss a series of essays on the technology written by 14 experts. The experts range from the privacy officer of a deep-packet inspection service vendor to technology law and internet security researchers. The website also offers an overview of the technology, which it describes as having the potential to provide "widespread access to vast amounts of personal information sent over the internet" for uses such as: * Targeted advertising based on users' behaviour. * Scanning for unlawful content such as copyright or obscene materials. * Intercepting data as part of surveillance for national security and crime investigations. * Monitoring traffic to measure network performance.

In the 2002 film Minority Report, video billboards scanned the irises of passing consumers and advertised to them by name. That was science fiction back then, but today's marketers are creating digital signs that can display targeted ads based on information they extract from examining the contours of individual human faces. These smart signs are proliferating in commercial establishments and public places from New York's Times Square to St. Louis area shopping malls. They are a powerful innovation in advertising, but one that raises compelling privacy issues - issues that should be addressed now, before digital signs that monitor our behavior become the new normal. The most common name for this medium is digital signage. Most digital signs are flat-screen TVs that run commercials on a continuous loop in airports, gas stations, and anywhere else marketers think they can get your attention. However, marketers have had difficulty determining exactly who sees the display units, which makes it harder to measure viewership and target ads at specific audiences. The industry's solution? Hidden facial recognition cameras. The tiny cameras can estimate the age, ethnicity and gender of people passing by and can track how long a given person watches the display. The digital sign can then play an advertisement specifically targeted to whomever happens to be watching. Tens of millions of people have already been picked up by digital signage cameras. While camera-driven systems are the most common, the industry is also utilizing mobile phones and radio frequency identification (RFID) for similar purposes. Some companies, for example, embed RFID chips in shopper loyalty cards. Digital kiosks located in stores can read the information on the cards at a distance and then display ads or print coupons based on cardholders' shopping histories. Facial recognition, RFID and mobile phone tracking are powerful tools that should be matched by business practices that protect consu

In the 2002 film Minority Report, video billboards scanned the irises of passing consumers and advertised to them by name. That was science fiction back then, but today's marketers are creating digital signs that can display targeted ads based on information they extract from examining the contours of individual human faces. These smart signs are proliferating in commercial establishments and public places from New York's Times Square to St. Louis area shopping malls. They are a powerful innovation in advertising, but one that raises compelling privacy issues - issues that should be addressed now, before digital signs that monitor our behavior become the new normal. The most common name for this medium is digital signage. Most digital signs are flat-screen TVs that run commercials on a continuous loop in airports, gas stations, and anywhere else marketers think they can get your attention. However, marketers have had difficulty determining exactly who sees the display units, which makes it harder to measure viewership and target ads at specific audiences. The industry's solution? Hidden facial recognition cameras. The tiny cameras can estimate the age, ethnicity and gender of people passing by and can track how long a given person watches the display. The digital sign can then play an advertisement specifically targeted to whomever happens to be watching. Tens of millions of people have already been picked up by digital signage cameras. While camera-driven systems are the most common, the industry is also utilizing mobile phones and radio frequency identification (RFID) for similar purposes. Some companies, for example, embed RFID chips in shopper loyalty cards. Digital kiosks located in stores can read the information on the cards at a distance and then display ads or print coupons based on cardholders' shopping histories. Facial recognition, RFID and mobile phone tracking are powerful tools that should be matched by business practices that protect consu

"A federal prosecutor tracked down a Seattle fraud suspect in Mexico this year through his Facebook posts. A man's Twitter messages to fellow demonstrators at a recent protest in Pittsburgh led to an FBI search of his home and short-lived charges of interfering with police. The CIA and other U.S. intelligence agencies reportedly are investing in a software firm that monitors half a million social networking Web sites each day. There's nothing wrong with law enforcement agencies' using Internet technology to investigate crimes, Bay Area privacy advocates say. But they want the federal government to say how, when and why its agents look at Americans' social networking accounts."

"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 CEO who publicly posted his Social Security number on billboards and TV commercials as part of a campaign to promote his company's credit monitoring services was the victim of identity theft at least 13 times, a news report says. The Phoenix New Times reported that Todd Davis, CEO of LifeLock Inc., which is based in Tempe, Ariz., was victimized numerous times by identity thieves who apparently used his Social Security number to commit various types of fraud. Davis has previously admitted that he was the victim of an identity theft once in 2007, when a man in Texas used his Social Security number to take out a $500 loan which wasn't repaid and ended up being handled by a collection agency. The New Times reported that Davis has been a victim of similar ID theft at least a dozen more times."

Might not want to put much stock in Lifelock.

Insulin pumps are vulnerable to determined hackers who could also remotely mess up the readings of blood-sugar monitors, Jerome Radcliffe, a security researcher who has diabetes revealed at the Black Hat computer security conference, Las Vegas, Nevada. In other words, a hacker could cause a diabetic patient to receive either too much or too little insulin.

"Data broker ChoicePoint, the victim of a 2004 data breach affecting more than 160,000 U.S. residents, has agreed to strengthen its data security efforts and pay a fine for a second breach in 2008, the U.S. Federal Trade Commission said Monday. ChoicePoint, now a subsidiary of Reed Elsevier, will pay US$275,000 to resolve the newest FTC complaint. The FTC accused the company of failing to implement a comprehensive information security program to protect consumers' personal information, as required by the agency after the 2004 breach. The April 2008 breach compromised the personal data of 13,750 people, the FTC said in a press release. ChoicePoint turned off a "key" electronic security tool used to monitor access to one of its databases, and failed to detect that the security tool was turned off for four months, the FTC said. For a 30-day period, an unknown hacker conducted thousands of unauthorized searches of a ChoicePoint database containing sensitive consumer information, including Social Security numbers, the FTC said. After discovering the breach, the company notified the FTC. If the software tool had been working, ChoicePoint likely would have detected the intrusions "much earlier," the FTC said. "

"Sherry Natoli is followed everywhere she goes while shopping online, but she doesn't mind at all. Natoli, who owns a seashell business in Tampa, does all but her grocery shopping on the Internet and even opts in whenever she's asked whether she's willing to have her online movements tracked by websites." Companies have been monitoring our online behavior for almost as long as there's been an Internet, often using our online footsteps (cookies) whenever we search, browse or buy online. Tracking technology has advanced so much that everything from how long we linger over a product description to whether we are searching for sexual-dysfunction drugs can be collected and stored on individual profiles. Our profiles are numeric descriptions, not our real names, but in some cases, it's not hard to determine personal information behind the numbers. Privacy concerns abound, and several privacy and consumer groups are urging Congress to enact laws on what can and can't be collected and for how long.

There was no way I was ever going to convince my parents that Jimi Hendrix's music was good. More than anything, the youth culture was defined by its music. The chasm it created was called "the generation gap" a metaphor for the ideological differences that separated us. There is a new generation gap. It's not defined through music or politics or fashion, those ideas are shared much more among the generations than before. This time it's about privacy. My generation came of age thinking about "1984", the looming threat of "Big Brother" watching over all of us all of the time. It was the government or some group which would monitor all of our actions, know all our habits: who we associate with, what we watch, what buy. 1984 came and went. Nothing like "Big Brother" happened unless you count Apple computer's historic "Big Brother" commercial which ends with the slogan: "On January 24th, Apple Computer will introduce Macintosh. And you'll see why 1984 won't be like "1984". They were right - 2009 is. Personal details used to be considered private. We were careful about who knew what about us and certainly didn't post pictures of our friends, families and fantasies for all to see. Privacy does not seem to be valued anymore. Giving up one's privacy has become a rite of passage. It's what you leave at the portal when you sign up for any of the social networking sites on the internet. The sites are free - as long as you don't calculate the value of your identity, demographics, viewing and buying habits to advertisers. This isn't new, the Nielsen Ratings service has been assembling viewer information since the 1950s for television advertisers, but its methods were primitive in comparison to the two way constant information gathering that's done on the internet. In March 2009, Google initiated the use of "behavioral targeting", which uses information collected on someone's web-browsing behavior, such as the pages they have visited or the searches they have made, to selec

By now, many employees are uncomfortably aware that their every keystroke at work, from email on office computers to text messages on company phones, can be monitored legally by their employers. What employees typically don't expect is for the company to spy on them while on password-protected sites using nonwork computers. But even that privacy could be in jeopardy. A case brewing in federal court in New Jersey pits bosses against two employees who were complaining about their workplace on an invite-only discussion group on MySpace.com, a social-networking site owned by News Corp., publisher of The Wall Street Journal. The case tests whether a supervisor who managed to log into the forum -- and then fired employees who badmouthed supervisors and customers there -- had the right to do so. The case has some legal and privacy experts concerned that companies are intruding into areas that their employees had considered off limits. "The question is whether employees have a right to privacy in their non-work-created communications with each other. And I would think the answer is that they do," said Floyd Abrams, a First Amendment expert and partner at Cahill Gordon & Reindel LLP in New York. The legal landscape is murky. For the most part, employers don't need a reason to fire nonunion workers. But state laws in California, New York and Connecticut protect employees who engage in lawful, off-duty activities from being fired or disciplined, according to a report prepared by attorneys at the firm Proskauer Rose LLP. While private conversations might be covered under those laws, none of the statutes specifically addresses social networking or blogging. Thus, privacy advocates expect to see more of these legal challenges. In February, three police officers in Harrison, N.Y., were suspended after they allegedly made lewd remarks about the town mayor on a Facebook account. The officers mistakenly thought the remarks were protected with a password, but city officials view

Parents of 18,541 Metro Nashville students will receive letters next week outlining a security breach that put their children's Social Security numbers online for three months. Advertisement Boston-based Public Consulting Group Inc., which holds a five-year, $2.6-million-a-year contract with the state to collect student data from various districts, corrected the error March 31 after a parent using Google to search her daughter's name found it - along with personal data for the students and 6,000 parent names. Art Staehling learned Wednesday that his teenage daughter was on the list and said he's concerned what could happen to her identity. "I find it hard to believe that an established company had a problem of this magnitude," Staehling said. The consulting group will pay for parents of affected children to check all family members' credit reports through Experian and for a year of monitoring. One of the group's owners, Stephen Skinner, said the error happened when workers running a test Dec. 28 on random student data inadvertently stored a file to an insecure directory. They discovered the error March 5 and took down the file, which contained student names, gender, race or ethnicity, date of birth, Social Security number and, in some cases, parent names. But they were unaware Google's search engine had already found the file and indexed it. That's how the parent, who is also a Metro schools employee, found out about the breach weeks later. Public Consulting Group worked with Google to take the information down.