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This FFIEC Financial Privacy InfoBase contains resource documents, audio presentations, and interactive training material for FFIEC agency examiners. InfoBase resources are organized to support independent study and research and are not presented as formal linear training.

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The French parliament on Thursday voted down an Internet piracy law, which had largely been expected to pass. The "Creation and Internet" law, which won the preliminary approval of the parliament last week, would compel Internet service providers to take graduated actions against customers accused of illegally downloading copyrighted material. After warning a customer against such actions for a third time, an ISP could suspend the person's Internet access for up to a year. Because the bill was expected to pass, few members of parliament were present for the final vote on the bill, according to the Associated Press. Opponents of the legislation, led by the Socialist party, rejected the measure by a vote of 21 to 15. The legislation had the support of the ruling UMP party, to which President Nicolas Sarkozy belongs, as well as the support of the Recording Industry Association of America. Backers of the bill intend to re-introduce an amended version within the coming weeks, according to reports. The entertainment industry has suggested to the United States' Congress that it should consider adopting European methods of combating copyright infringement. The United States, members of the European Union, and other countries may also consider making ISPs liable for infringement through international treaties.

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In a world of increasingly savvy and inter-connected customers, an organization's approach to information privacy may offer precisely the competitive advantage needed to succeed. Privacy is essential to creating an environment that fosters trusting, long-term relationships with existing customers, while attracting opportunity and facilitating the development of new ones. Spend the morning with me and nine privacy leaders from major corporations: Intel; IBM; Sun Microsystems, Inc.; Microsoft; Facebook; HP; Privacy Analytics Inc.; Ontario Lottery and Gaming Corporation; Peratech Limited; and GS1 Canada as they present their latest innovations in Privacy-Enhancing Technologies (PETs). You will appreciate how "Privacy by Design" - embedding PETs into the architecture of new systems - protects privacy, without compromising performance or security - a positive-sum not zero-sum outcome.

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Chris Nolter Department store proprietor John Wanamaker is famously said to have quipped, "Half the money I spend on advertising is wasted; the trouble is, I don't know which half." The founder of Wanamaker's department store is known as the "father of modern advertising." His innovations, in late 19th-century and early 20th-century Philadelphia and New York, included publishing reliable prices in advertisements, copyrighting pitches, offering money-back guarantees and hiring a full-time writer to produce ad copy. A century later, advertising professionals have gotten more sophisticated and adapted to radio, television, outdoor and digital media. Wanamaker's observation about the value and effectiveness remains profound for merchants and manufacturers, as well as for media outlets that have seen broadcasting or print-advertising dollars reduced to digital pennies. The Internet has made the amount of space that can be filled with advertising virtually infinite, while the recession has all but emptied the advertising coffers of automakers, financial services firms and real estate companies. While digital media has disrupted the traditional ad business, it also presents the tantalizing promise to answer Wanamaker's question. Prior generations of digital advertising gave us spam and banner ads that tempted us with animated mortgage holders wildly dancing on the roof of their home or prizes for whacking a mole. The new proposition is that digital ads will allow advertisers to target audiences and track their returns on investment, and provide users with advertising and content that is more relevant. More than 400 advertising networks have come into existence to sell ad space on the expanding inventory of Web sites and pages. These networks connect advertisers with online publishers, often shopping ad space that a Web site's own sales staff cannot fill. Many of the networks cater to niches, such as food, wine, cars or sports. Increasingly, they are selling access to a

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According to Gartner Group report, there are 141.1 million mobile payment-ready devices in circulation and that the vast portion of the world's population (mostly in Asia) is actively using NFC and other techniques to pay for items via mobile. However, the US is lagging wildly in this regard, with nearly no activity in the space at present even though two-thirds of young people would be happy to wave their phones in front of a candy machine to grab a bite. Sadly, two-thirds of older folks would balk at the opportunity.

"The ubiquity of online advertising is a product of its importance to the internet economy, said a group of consumer advocates Wednesday during a debate on the future of online advertising. But the impact of new targeted advertising methods on consumer privacy and its potential to manipulate online experiences was the subject of heated argument at the event, sponsored by the Information Technology and Innovation Foundation. Privacy does not mean the same thing to all consumers in all situations, said Progress and Freedom Foundation Senior Fellow Berin Szoka. Advertisements are attempts to capture user attention - the "great currency of the Internet" - and when successful support a wide range of valuable content, he said. But in online life, "consumers have many values," Szoka added. "Privacy is one of them," he said, but it is not an absolute. Consumers must sometimes trade privacy for content, he said. "There is no free lunch." As more information and entertainment migrates to the internet, Szoka said it is "critical…that we find a way to support this media." Targeted advertising can fit the bill, he suggested - especially if technology gives users more control over their own preferences. Most consumers don't understand that advertising is a necessity for today's internet, he said. New technologies like targeting need to be given a try, he said, so content providers can recoup the value of their advertising - down 25 percent since 2000, he noted. Center for Digital Democracy founder Jeff Chester said Szoka's ideas about advertising's future represented a "false dichotomy." The real debate should be over the rules that regulate advertiser content, he said. Chester warned of a "Targeting 2.0″ system in which neuroscience combined with massive databases not only serve ads, but target content to users. "It's about influencing our behavior without our consent," he said. Chester pointed to the subprime lending cr

"Today, the Federal Trade Commission opened new areas of a "virtual mall" with content that will help kids learn to protect their privacy, spot frauds and scams, and avoid identity theft. The FTC Web site, www.ftc.gov/YouAreHere, introduces key consumer and business concepts and helps youngsters understand their role in the marketplace. The FTC is the nation's consumer protection agency. "YouAreHere presents practical lessons about money and business in a fun and familiar setting," said David Vladeck, Director of the FTC's Bureau of Consumer Protection. "The new content takes kids behind the scenes to raise their awareness of advertising and marketing, pricing and competition, fraud and identity theft. At the FTC's online mall, visitors play games, watch short animated films, and interact with customers and store owners. They can design and print advertisements for a shoe store, investigate suspicious claims in ads and sales pitches, learn to identify the catches behind bogus modeling schemes and vacation offers, and guess the retail prices of various candies based on their supply, demand, and production costs. At the Security Plaza, visitors can build a social networking page and see the unintended consequences of posting personal information. They also get tips on how to keep their computers safe while they're online. In the arcade, visitors can play Info Defender 3 and protect Earthlings from Cyclorian invaders who would steal their identities. The game teaches the importance of protecting personal information, including Social Security numbers. For parents and teachers, the site offers detailed fact sheets with ideas for related activities. Teachers can use the site to complement lessons in consumer economics, government, social studies, language arts, and critical thinking. The National Council for Economic Education has developed a lesson plan that prominently features YouAreHere; it is available on the Parents and Teachers page. "

"Facebook CEO Mark Zuckerberg has just written an open letter to Facebook users regarding a privacy overhaul that is due to hit the site in the next few weeks. Soon, users will be able to selectively choose, on a per-post basis, who can see the content they post to the site. Facebook is also going to remove regional networks entirely, largely because some of those networks (like China) consist of millions of users, which makes them useless from a privacy standpoint. If these changes sound familiar, it's because Facebook actually announced them way back in July. Zuckerberg also notes that Facebook now has 350 million users ? it has added a whopping 50 million of them in the last two and a half months. Alongside the regional network change, privacy controls will be simplified. As Facebook rolls out the new privacy settings, users will be presented with a page designed to walk them through the new options. Depending on your current privacy level, Facebook will make recommendations, though you'll be able to change them as usual. "

"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."

"A new study from the Pew Charitable Trust has found that every one of the credit cards offered by the country's 12 largest credit card issuers are bad deals for consumers and have practices the Federal Reserve has defined as "unfair or deceptive." The Trusts' Health Group's Safe Credit Cards Project, titled STILL WAITING: "Unfair or Deceptive" Credit Card Practices Continue as Americans Wait for New Reforms to Take Effect also compared credit union card programs and found them sharply better. "Although credit unions control only a small portion of credit card outstandings, comparisons between credit union and bank product models illustrate options available to consumers and potential benchmarks for future regulatory rulemaking efforts," the organization said. The observed credit unions presented a distinct alternative to credit card pricing and other practices of the observed banks, the report said. "In July 2009, median advertised interest rates on cards from the 12 largest credit unions were between 9.90 and 13.75% annually, depending on a consumer's credit profile-approximately 20% lower than comparable bank rates," the report said. "Meanwhile, credit union penalties were generally less severe than those of banks." "

"This presentation contains statements of a forward-looking nature which represent our management's beliefs and assumptions concerning future events. Forward-looking statements involve risks, uncertainties and assumptions and are based on information currently available to us. Actual results may differ materially from those expressed in the forward-looking statements due to many factors, including without limitation, the impact that the significantly unfavorable economic conditions confronting the United States may have on our business, the results and effects the security breach of our processing system may have on us, including the costs and damages we may incur in connection with the claims arising from such breach that have been made and may in the future be made against us, the extent of cardholder information compromised and the possibility that such security breach could cause us to lose customers or make it difficult for us to obtain new customers, the possibility that we may not be successful in developing and implementing an end to end encryption solution, the possibility that if we are successful in developing and implementing an end to end encryption solution it may not prevent future security breaches of our payment processing system, and additional factors that are contained in the Company's Securities and Exchange Commission filings, including but not limited to, the Company's annual report on Form 10- K for the year ended December 31, 2008. We undertake no obligation to update any forward-looking statements to reflect events or circumstances that may arise after the date of this presentation. Topics / Agenda - The Future of Electronic Payments * What Is The Problem? The Cybercrimes Arms Race * Who Is Heartland Payment Systems? * What Happened and What Has/Will It Cost? * What Did We Do About It and What Are We Doing Now? * Massive Quantity/Quality of Breaches Call for Enhanced Solutions * Our New Solution Called E3 -

"On January 20, 2009, Heartland Payment Systems reported discovering malicious software in its payment processing system, a security breach of potentially massive magnitude given that the company's handles 100 million transactions per month for more than 250,000 businesses. While the monetary and data loses following from the penetration of Heartland's systems -- the compromise that lasted for months -- are still being determined, the financial impact on Heartland's stock price alone was devastating. " The breach, in conjunction with the economic downturn, led to the loss of about $500 million in shareholder value, more than three-quarters of the company's market capitalization, two months after the news was announced. And then there's the cost of more than several dozen breach-related lawsuits filed against the company this year and related expenses. According to slides presented in August at a National Retail Federation Conference by Robert O. Carr, Heartland's founder, chairman and CEO, the breach cost the company $32 million in legal fees, fines, settlements, and forensics during just the first half of the year.

The Federal Bureau of Investigation is expanding beyond its traditional fingerprint-focused collection practices to develop a new biometrics system that will include DNA records, 3-D facial imaging, palm prints and voice scans, blended to create what's known as "multi-modal biometrics." Slideshow: The changing face of biometrics How the Defense Department might institutionalize war-time biometrics "The FBI today is announcing a rapid DNA initiative," said Louis Grever, executive assistant director of the FBI's science and technology branch, during his keynote presentation at the Biometric Consortium Conference in Tampa. The FBI plans to begin migrating from its IAFIS database, established in the mid-1990s to hold its vast fingerprint data, to a next-generation system that's expected to be in prototype early next year. This multi-modal NGI biometrics database system will hold DNA records and more.

Both panels that advise the national coordinator for health IT plan to focus on privacy and security standards needed to support meaningful use of electronic health records when they meet later this month, according to notices in today's Federal Register. The Health IT Policy Committee, led by Dr. David Blumenthal, the national coordinator for health IT, will direct more of its discussion at its upcoming Sept. 18 meeting on health information privacy and security as it makes progress in defining meaningful use under the stimulus law, according to the notice. Likewise, the companion Health IT Standards Committee, which meets Sept. 15, will concentrate on refining standards recommendations made by its privacy and security work group. At the Standards Committee's previous meeting Aug. 20, its privacy and security workgroup presented standards for authentication, authorization, auditing and secure data transmission of health information in EHR products as well as the infrastructure that hosts them. The work of the panel includes protecting data inside an enterprise as well as data exchange between enterprises, "because security is an end to end process," noted Dr. John Halamka, the committee's chairman in a post on his blog, "Life as a Healthcare CIO."

Joshua Corman would seem an unlikely critic of IT security vendors. After all, he works for one. Yet Corman, principal security strategist for IBM's Internet Security Systems division, is speaking out about what he sees as eight trends undermining the ability of IT security practitioners to mount an effective defense against online outlaws. Having worked for the vendor side, Corman says he is uniquely positioned to grasp its weaknesses up close. And so, with a PowerPoint presentation on the "8 Dirty Secrets" of the market in hand, he has traveled to seminars and worked the phones, hoping to motivate a change for the better. Here is the breakdown of those 8 dirty secrets and what Corman sees as practical ways to keep the vendors honest. [Related podcast: The Dark Side of the Security Market] Click here to find out more! Dirty Secret 1: Vendors don't need to be ahead of the threat, just the buyer This is the problem that leads to the seven "dirty secrets" that follow. In essence, Corman said, the goal of the security market is to make money, not to ensure the customer's security. Tom Vredenburg, regional IM manager for Houston-based Wartsila Corp., said Corman's take is consistent with what he has experienced in the trenches. "Not only has security become a phantom deliverable, but the vendors themselves have become equally tough to pin down and evaluate. Are they software sellers or risk managers? Are they service providers or network designers? Am I buying partnerships or licenses? Most of them don't know themselves what they are -- only that they need to sell something that most people don't really want to buy in the first place -- insurance."

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.

Free, vendor-neutral online Data and Privacy in Web 2.0 Summit on August 13th. Thought leaders will present a series of webcasts discussing best practices and case studies on legal issues in online social communities, implications of the smart grid and the Cloud, privacy policies and more: http://www.brighttalk.com/summit/dataprivacy2 Web 2.0 services have been rapidly growing because of the value they offer to businesses and individuals alike. However, with so much information at stake and so little control of employees and customer activities online, how do companies ensure consumer and businesses' data are secure and safe from misuse and malware-related data breach? This summit will focus on minimizing leakage from people, devices and data on the move, keeping consumer and businesses' data secure and safe from misuse and malware-related data breach.

Many people are scaling back their summer vacation plans because of the current economic situation. Some are staying closer to home. Others may be taking shorter vacations. But it's important to remember that when you travel, your risk of exposure to fraud and identity theft may increase. It's a fact that people tend to let their guard down while on vacation. Criminals know this. Identity theft is often a crime of opportunity. Don't be a vacationer who presents a crook with that opportunity. Your personal information, credit and debit cards, driver's license, passport, and other personal information are the fraudster's target. A few minutes spent planning before you travel can help reduce the risk that a fraudster will ruin your vacation. Here are some tips to help you avoid any nasty surprises:

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Over the past six months, many of us have become desensitized to the staggering number and size of layoffs that continue to occur almost daily. But the reality for the IT industry is that layoffs have a different effect on those of us in the industry whose mission it is to protect the company's reputation, intellectual property, confidential data (both electronic and hard copy) and business operations. Knowledge Center contributor Gregory Shapiro outlines seven steps IT professionals can take to protect their company's data before a layoff is implemented. Unlike individual employee terminations, which are customarily unannounced and immediate, layoffs present a larger threat to corporations because they leave the door open to both intentional and unintentional data loss, leakage and integrity problems. When employees sense impending layoffs or are told in advance and kept on for a limited time to transition, that is when rumors and panic consume the employees. It's then that the company's sensitive data can be compromised. For this reason, the strategy for any corporation planning a layoff should include setting policies and making sure practices are in place to secure their sensitive data now. Steps to protect company data before a layoff is implemented

Ironic

IT practices such as identity management, email and URL filtering, virus scanning and electronic monitoring of employees can get companies that do business globally into a heap of trouble if deployed without an understanding of global data privacy laws. The warning was one of several alarms raised in a presentation on global privacy best practices by Gartner Inc. analysts Arabella Hallawell and Carsten Casper at the recent Gartner Risk Management and Compliance Summit in Chicago. Always a thorny issue, the protection of personally identifiable information (PII) is made more complicated in a world where there is limited agreement on how best to do that. According to the Gartner analysts, the world is divided into three parts when it comes to data privacy laws: countries with strong, moderate or inadequate legislation. The European Union, under the European Union Directive on Data Protection, possesses the strongest privacy regulations, followed by Canada and Argentina; Australia, Japan and South Africa have moderate to strong, recent legislation; laws in China, India and the Philippines are the least effective or laxly enforced. The United States has the dubious distinction of occupying two categories -- the strong column, due to the 45 state breach notification laws on the books, and the weak column, because of the lack of a federal law. Even among the three categories, nuances abound. Under the European Union Directive, member countries enact their own principles into legislation, and some laws (like Italy's) are more stringent than the directive's standards. Russia's very recent law is modeled after the strong EU laws, but how it will be enforced remains questionable. And in the U.S., state breach notification laws vary, with Nevada and Massachusetts proposing the most prescriptive data privacy legislation to date.