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It was only a matter of time! Auditor accuracy being examined in lawsuit may signal change in PCI and other compliance processes.

When CardSystems Solutions was hacked in 2004 in one of the largest credit card data breaches at the time, it reached for its security auditor's report. In theory, CardSystems should have been safe. The industry's primary security standard, known then as CISP, was touted as a sure way to protect data. And CardSystems' auditor, Savvis Inc, had just given them a clean bill of health three months before. Yet, despite those assurances, 263,000 card numbers were stolen from CardSystems, and nearly 40 million were compromised. More than four years later, Savvis is being pulled into court in a novel suit that legal experts say could force increased scrutiny on largely self-regulated credit card security practices. They say the case represents an evolution in data breach litigation and raises increasingly important questions about not only the liability of companies that handle card data but also the liability of third parties that audit and certify the trustworthiness of those companies. "We're at a critical juncture where we need to decide . . . whether [network security] auditing is voluntary or will have the force of law behind it," says Andrea Matwyshyn, a law and business ethics professor at the University of Pennsylvania's Wharton School who specializes in information security issues. "For companies to be able to rely on audits . . . there needs to be mechanisms developed to hold auditors accountable for the accuracy of their audits." The case, which appears to be among the first of its kind against a security auditing firm, highlights flaws in the standards that were established by the financial industry to protect consumer bank data. It also exposes the ineffectiveness of an auditing system that was supposed to guarantee that card processors and other businesses complied with the standards. Credit card companies have touted the standards and the auditing process as evidence that financial transactions conducted under their purview are secur

When the director of IT at a Boston-based, midsize pharmaceutical firm was first approached to participate in a data leakage audit, he was thrilled. He figured the audit would uncover a few weak spots in the company's data leak defenses and he would then be able to leverage the audit results into funding for additional security resources. "Data leakage is an area that doesn't get a lot of focus until something bad happens. Your biggest hope is that when you raise concerns about data vulnerability, someone will see the value in allowing you to move forward to protect it," the IT director says. But he got way more than he bargained for. The 15-day audit identified 11,000 potential leaks, and revealed gaping holes in the IT team's security practices. (Read a related story on the most common violations encountered.) The audit, conducted by Networks Unlimited in Hudson, Mass., examined outbound e-mail, FTP and Web communications. The targets were leaks of general financial information, corporate plans and strategies, employee and other personal identifiable information, intellectual property and proprietary processes. Networks Unlimited placed one tap between the corporate LAN and the firewall and a second tap between the external e-mail gateway and the firewall. Networks Unlimited used WebSense software on two servers to monitor unencrypted traffic. Then it analyzed the traffic with respect to company policy. Specifically, Networks Unlimited looked for violations of the pharmaceutical firm's internal confidentiality policy, corporate information security policy, Massachusetts Privacy Laws (which go into effect in 2010), Health Insurance Portability and Accountability Act (HIPAA), and Security and Exchange Commission and Sarbanes-Oxley regulations. Auditor Jason Spinosa, senior engineer at Networks Unlimited, says that while he selected the criteria for this audit, he usually recommends that companies take time to determine their policy settings based on their risk

DESPITE SIGNIFICANT IMPROVEMENTS since the U.S. Sarbanes-Oxley Act of 2002 became effective, the continuing cost of compliance with the act's Section 404 requirements remains a concern for board members and management. A periodic operational audit of the Section 404 program can provide valuable information to executive management and the audit committee, and potentially identify areas where significant costsavings can be realized. Whether the Section 404 program is managed by the finance department, internal auditing, or another organization, it's an excellent candidate for this type of review, particularly if the focus remains on program efficiency. Several questions, based on The IIA's publication Sarbanes-Oxley Section 404: A Guide for Management by Internal Control Practitioners, can be used as the basis for the audit. The questions cover issues ranging from ensuring that operating management takes ownership of its processes, to achieving fewer and more effective key controls, to determining whether the external auditor's reliance on management testing has been optimized.

Premier Election Solutions (formerly Diebold Election Systems) admitted in a state hearing Tuesday that the audit logs produced by its tabulation software miss significant events, including the act of someone deleting votes on election day. The company acknowledged that the problem exists with every version of its tabulation software. The revelation confirmed that a problem uncovered by Threat Level in January, and reiterated in a report released two weeks ago by the California secretary of state's office, has widespread implications for election jurisdictions around the country that use any version of the company's Global Election Management System (GEMS) software to tabulate votes. "Today's hearing confirmed one of my worst fears," said Kim Alexander, founder and president of the non-profit California Voter Foundation. "The audit logs have been the top selling point for vendors hawking paperless voting systems. They and the jurisdictions that have used paperless voting machines have repeatedly pointed to the audit logs as the primary security mechanism and 'fail-safe' for any glitch that might occur on machines. To discover that the fail-safe itself is unreliable eliminates one of the key selling points for electronic voting security."

The offshoring of business processes has become increasingly popular. Fueled by advancements in technology, the benefits of offshoring are primarily attributable to the savings from lower personnel costs at foreign locations. According to the Global Financial Services Offshoring Report 2007 by Deloitte & Touche U.SA LLP, over 75% of major financial institutions report offshoring a portion of their operations. Some economists estimate that up to one-third of total U.S. employment in services may ultimately be offshored (Steve Lohr, "At IBM, a Smarter Way to Outsource," The New York Times, July 5, 2007). Offshore entities often operate in developing countries such as India, China, Pakistan, the Philippines, and Vietnam. The offshoring of business processes generally takes two forms: outsourcing to an unaffiliated offshore entity (offshore outsourcing), or ownership and operation of an affiliated offshore entity (AOE). Many multinational companies have AOEs. For example, Accenture has more employees in India than in the United States; IBM is projected to have more than one-quarter of its workforce in India by 2010; and companies like General Electric, Eli Lilly, Google, and Microsoft are expanding their R&D centers in India and China (House Committee on Science and Technology, June 12, 2002). Offshoring and the Auditing Profession The potential benefits of offshoring have not been ignored by the accounting profession. In past years, several large public accounting firms began using AOEs to perform certain nonaudit procedures for their U.S.-based clients. For example, Ernst & Young uses AOE employees to prepare client tax returns (Vanessa Houlder, "E &Y Sends Compliance Work Offshore," Financial Times, July 11, 2007), and a number of accounting firms use AOEs to print documents for delivery to clients. The largest international public accounting firms have recendy begun testing the offshoring of certain auditing procedures on very large U.S. audit engagements to thei

Brief descriptions and links to professional certifications in information security, physical security, audit, investigations, business continuity and more. Certifications provide a way to expand and/or demonstrate professional expertise. A wide variety of certifications are available in security and related disciplines. This directory will compile brief descriptions of certs in information and physical security, business continuity, audit and other areas, with links to details from the issuing organizations. Notes: -- This list will be updated and expanded at The Security Certification Directory on csoonline.com. -- Vendor-specific security certifications will be added in the near future.

"In light of a spike in identity theft and the frequency with which personal information is stored on portable devices, the American Institute of Certified Public Accountants (AICPA) and the Canadian Institute of Chartered Accountants (CICA) have expanded Generally Accepted Privacy Principles (GAPP) to include protocols for securing and disposing of personal information. "Safeguarding personal information is one of the most challenging responsibilities facing an organization, whether such information pertains to employees or customers," said Everett C. Johnson, CPA, chair of AICPA/CICA Privacy Task Force and a past international president of ISACA, a global information technology association. "We've updated the criteria of our privacy principles to minimize the risks to personal information." GAPP offers guidance and best practices on securing portable devices, breach management and ensuring continued effectiveness of privacy controls. The guidance additionally covers disposal and destruction of personal information. The principles are designed for chief privacy officers, executive management, compliance officers, legal counsel, CPAs and CAs offering technology advisory services. "Portable tools such as laptops and memory sticks provide convenience to employees but appropriate measures must be put in place to secure them and the data they contain," said Donald Sheehy, CA.CISA, CIPP/C, associate partner with Deloitte (Canada) and a member of the AICPA/CICA Privacy Task Force. "We must stay abreast of technological advances to assure that proper measures are put into place to defend against any new threats." Created by the AICPA/CICA Privacy Task Force, GAPP is designed to help an organization's management team assess an existing privacy program or address privacy obligations and risks. The principles provide a framework for CPAs and CAs to offer privacy services to their clients and employers, such as advisory services, privacy risk assessments and attestation or

"Despite concerns from some privacy groups and U.S. lawmakers about behavioral advertising, most large advertising networks generally comply with a set of privacy and data-handling standards adopted by the Network Advertising Initiative a year ago, the NAI said in a report released Wednesday." ...NAI, whose members include Google, Yahoo and Advertising.com, should be praised for doing a compliance report after skipping it for several years, said Ari Schwartz, vice president and chief operating officer CDT. However, the group should consider using a third party to audit compliance of its privacy guidelines, instead of having NAI staff do the audits, he said. In addition, while NAI members appear to be following most of the guidelines, some of the privacy safeguards are "weak," including the data retention standard, he said. "There's no maximum for data retention -- they just have to state what their data retention policy is," Schwartz added. The NAI report doesn't lessen the need for new privacy laws, Schwartz said. Several online advertising networks are not members of NAI, and the recent public pressure has led to the NAI updating 8-year-old guidelines last year and issuing a compliance report for the first time in several years, although the group had promised regular reports, he said. "It seems that when there's regulatory pressure, they actually do comply with what they said they were going to do," he said. "We certainly wouldn't want to see any regulatory pressure lifted."

Worth a read. The story changes quite a bit from the top to bottom of the story.

Government Information Security Podcasts As a GovInfoSecurity.com annual member, this content can be used toward your membership credits and transcript tracking. Click For More Info Probing Federal IT Security Programs: Gregory Wilshusen, GAO February 23, 2009 Government Accountability Office auditors will have a busy spring, examining a number of federal government programs aimed at securing government information systems and data. In an interview with GovInfoSecurity.com, Gregory Wilshusen discusses how the GAO is looking at how private industry and two dozen federal agencies employ metrics to measure the effectiveness of information security control activities. Other current GAO information security investigations he discusses include: Federal Desktop Core Configuration intended to standardize security features on personal computers purchased by the government. Trusted Internet Connection initiative aimed at slashing government Internet connections to fewer than 100 from more than 2,000. Einstein automated networking monitoring program run by U.S Computer Emergency Readiness Team. Gregory Wilshusen is director of information security issues at GAO, where he leads information security-related studies and audits of the federal government. He has more than 26 years of auditing, financial management and information systems experience. Before joining GAO in 1997, Wilshusen served as a senior systems analyst at the Department of Education as well as the controller for the North Carolina Department of Environment, Health and Natural Resources.

From the Heartland data breach to the new Massachusetts data protection law, privacy is the hot topic in business and government. In an exclusive interview, Peter Kosmala, assistant director of the International Association of Privacy Professionals (IAPP), discusses: The top privacy topics in business and government; How organizations are tackling these issues; The potential impact of state and federal privacy legislation; The value of the Certified Information Privacy Professional (CIPP) credential. Kosmala oversees product management for the IAPP with specific oversight of distance learning products, privacy certifications and industry awards programs. He also manages business development efforts between the IAPP and peer organizations in the information security, information auditing and legal compliance arenas as well as organizations based in the Asia-Pacific region. The IAPP, based in York, Maine, was founded in 2000 with a mission to define, promote and improve the privacy profession globally. Kosmala oversees product management for the IAPP with specific oversight of distance learning products, privacy certifications and industry awards programs. He also manages business development efforts between the IAPP and peer organizations in the information security, information auditing and legal compliance arenas as well as organizations based in the Asia-Pacific region. The IAPP, based in York, Maine, was founded in 2000 with a mission to define, promote and improve the privacy profession globally.

Industry Insiders Discuss HIT and HIPAA Issues March 30, 2009 by Astrid Fiano, Writer A significant part of President Obama's health care reform agenda is the push for implementing more health care technology. In the health care field privacy is always a major concern, and was the impetus of the Health Insurance Portability and Accountability Act of 1996--protecting the privacy of individually identifiable health information in all formats, and the confidentiality provisions of the Patient Safety Act--protecting identifiable information being used to analyze patient safety events. So those in the health care industry now wonder will the Administration's focus on health IT (HIT) present more challenges to privacy concerns? As part of a continuing focus on HIT issues, DOTmed interviewed industry expert Kirk J. Nahra, a partner in the Washington D.C. legal firm of Wiley Rein LLP, specializing in privacy and information security for the health care and insurance industries, and named an expert practitioner by the Guide to the Leading U.S. Healthcare Lawyers. DOTmed also interviewed Lise Rauzi, Vice President, Training Development, for Health Care Compliance Strategies (HCCS). HCCS provides online training compliance for employees. Nahra notes that regardless of the rising concern over privacy and the new HIT legislation, there have already been formal HIPAA security rules on electronic information in place for several years--the health care industry compliance has just been inconsistent. The problem -- to the extent there is one -- is that HIPAA rules are process-oriented, Nahra explained. The rules don't tell an entity what to do, but rather what to evaluate--a standard set of questions, but without a standard set of answers. For example, a covered entity has to have an internal audit, but the rules do not tell the entity how best to carry out that internal audit. Not surprisingly, different businesses have different ideas on how to implement their HIPAA evaluations

Things to think about for auditors during a downturn

As IT environments are becoming more complex, enterprises are relying on them more than ever before, said Michael Juergens, principle at Deliotte & Touche, told attendees at an ISACA CACS audit and compliance conference. He identified 10 areas in which complexity makes IT more difficult to monitor. "This list is designed to get you thinking about your environments and if currently scheduled IT audit procedures will evaluate this risks," Juergens said. "The list is in no particular order, is by no means a comprehensive list, and will vary by environment. There may be a greater or lesser risk depending on your industry, technology, business processes, and other factors," he added. He said that auditors should make a careful risk assessment at any enterprise that uses external cloud computing solutions. A key risk for compliance is simply keeping track of the data and recovering it if part of the cloud goes down. IT administrators must have insight into the cloud to enable forensics if an investigation is required. Juergens added that virtualization, often a key component of private clouds, carries the same risks as public clouds. The key issue is finding and tracing data, which can move to different servers within a virtualized environment. During this economic downturn, many companies will face disgruntled employees and will need to be able to control their access. "Specific attention items should be: timely removal of access, periphery security, internal security architecture, physical security and badge location, help desk procedures, workstation security and IDS management," Juergens said. Layoffs can harm an organization even without disgruntled employees. Many help desks and incident response teams will be understaffed, and Juergens advised that now is a good time to re-examine security procedures. A related risk could occur if an employee takes on the responsibilities of another, combining tasks that were previously segregated for compliance purposes. En

Heartland Payment Systems CEO discusses breach, previews speech Not a week had passed after the announcement of what some have described as the largest data breach ever, when the CEO of Heartland Payment Systems, Robert Carr, began calling for better industry cooperation and new efforts directed at preventing future breaches. Recently, Carr announced that trials will begin late this summer on an end end-to-end encryption system Heartland is developing with technology partners. It is expected to be the first system of its kind in the U.S. The company is also pushing for an end-to-end encryption standard. At the upcoming Practical Privacy Series in Silicon Valley, Carr will discuss the Heartland breach and the role industry, including privacy professionals, must play to prevent future breaches. Here's a preview: IAPP: Many companies have experienced breaches. What made yours different? Ours was different because we are a processor and had passed six years of PCI audits with no problems found. Yet, within days of the most recent audit, the damage had begun. IAPP: Did you have a chief privacy office or a privacy professional on staff before your breach? Do you now? Ironically, when we learned of the Hannaford's breach, we hired a Chief Security Officer who started just three weeks before the breach began. IAPP: In the era of mandatory breach reporting, what is the trajectory of consumer reaction? As a processor it is difficult to really know this. Our customers are merchants who accept card payments. IAPP: Do you think consumers will become numb to breach notices? I believe that many are numb to so many intrusion notices. IAPP: Are breach notices good public policy? Do the notices provide an incentive for companies to change or improve practices? I don't think so. Nobody wants to get breached and the damage caused by a breach is sufficient reason for most of us to do everything we can to prevent them. IAPP: What has Heartland done differentl

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.

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.

Companies in the technology, media and telecommunications industries (TMT) significantly reduced investment in security spending in 2008, according to a new survey from Deloitte Touche Tohmatsu. The third edition of the Deloitte TMT Global Security Survey reveals that 32 percent of respondents reduced their information security budgets, while 60 percent of respondents believe they are "falling behind" or still "catching up" to their security threats -- a significant increase from 49 percent over the previous year. "This year's results indicate companies are explicitly scaling back. With funding decreasing and the threats increasing, it is more important than ever for TMT companies to be highly cost efficient in addressing their security risks," said Irfan Saif, a principal in Deloitte & Touche LLP's Audit and Enterprise Risk Services practice. "Companies that do not have a sound understanding of their security risk profile, or who under-invest in security now, may find themselves exposed to significant and increasingly sophisticated threats that they are not equipped to mitigate." With the proliferation of digitized assets, security should claim a significant portion of a company's overall IT budget. However, only 6 percent of respondents allocate 7 percent or more of their total budget to IT security. This year represents a significant decline from the previous edition of the survey, which showed that 36 percent of the respondents allocated 7 percent or more of their budget to IT security. The survey also indicates that declining security investment is hindering adoption of new security technologies, with only 53 percent of respondents considering their organizations to be early adopters, or part of the early majority, down from 67 percent in 2007. Companies are focusing more effort on optimizing solutions that are already in place rather than investing in cutting-edge technology that can be capitalized upon during economic recovery.

Several years ago I was helping firms prepare for their first SOX (Sarbanes-Oxley) compliance audits. Following is one of the experiences I had training corporate executives, staff and even auditors about the benefit of selling change...

I walked into the Chief Information Officer's office, not k

"Web users are not yet deleting Flash cookies as often as they shed more traditional cookies, but that doesn't mean it's a good idea to use Flash technology to track consumers online. That's according to a new report commissioned by media audit company BPA Worldwide. The report, authored by analytics expert Eric Peterson, warns that the use of Flash cookies, also called "local shared objects," to override consumers' choices could invite new privacy laws. "With the attention given to consumer privacy on the Internet at both individual and governmental levels, we believe that companies making inappropriate or irresponsible use of the Flash technology are very likely asking for trouble, (and potentially putting the rest of the online industry at risk of additional government regulation)," writes Peterson, CEO and principal consultant at Web Analytics Demystified. "

Flash cookies may draw additional legislation for the online advertising industry.

"The number of fraudulent IRS websites taken down in 2008 soared to 3,030, up more than 240 percent from 2007, according to a GAO analysis of Internal Revenue Service data, suggesting a sharp increase by criminals to draw unassuming taxpayers to faux tax agency websites to steal identities and money. In a Government Accountability Office audit, made public Thursday, the GAO credited the IRS for implementing programs to prevent, detect and resolve identity theft, but said the tax agency needs to do a better job in assessing the effectiveness of its initiatives. And, as it relates to potential online abuse, the IRS should be more consistent in enforcing security controls. "

There is an old axiom in marketing circles that it costs more money to acquire new customers than to retain and service your old ones. In this precarious financial environment, the focus for many companies is now on keeping the existing customers satisfied, rather than worrying only about adding new ones to the fold. Since the business environment has slowed for now, showing your clients additional "value added" services rather than simply a lower price, for example, will be critical. Companies should be taking an introspective look for differentiating factors in the areas of security and privacy "value," and how they can leverage what they uncover - a competitive advantage. How can an organization best position their privacy and security programs to be used as a competitive advantage? First, of course, you need to ensure that your privacy and security program is robust, well-tested, formally documented and meets or exceeds whatever legislation that your company is subject to or regulated against. It is also important to give your customers a point of reference about the validity of your programs so they easily translate the value into a currency they recognize. Further, you should take advantage of any other internal and external audits, assessments and oversights that you can reasonably share with external parties by crafting the results of these documents as a consumable for external parties. It has been my experience that clients, especially their security teams, really appreciate this effort. Another innovative way to deliver a competitive advantage today is in the realm of vendor management. This discipline is quickly becoming an increasingly high-profile topic of discussion and interest between clients, customers and their service providers. The onus is on you anyway to demonstrate oversight of your third-party service provider(s). This is where you should also have the "value add" conversation and validate why your clients placed their trus

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