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Incident Mgmt Nov 08
 

Incident Mgmt Nov 08

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Presentation made at IAPP Toronto event concerning privacy incident and breach management in November 2008

Presentation made at IAPP Toronto event concerning privacy incident and breach management in November 2008

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Incident Mgmt Nov 08 Incident Mgmt Nov 08 Presentation Transcript

  • Incident Management Michael Power eHealth Ontario IAPP KnowledgeNet Toronto, Ontario November 2008
  • Notes
    • eHealth Ontario formed by regulation in September 2008.
    • The transition of SSHA into eHealth Ontario has commenced.
    • Comments today reflect experiences of SSHA only.
  • What’s involved… > Identify, contain, triage & remedy incidents. > Short term: Contain damage; Restore normal operations. > Long term: Avoid problems in future.
  • Privacy Incident : One or more events that may involve the unauthorized use, collection, disclosure, or disposal of personal or personal health information. Distinct from “breach”.
  • Security Incident : One or more events that have a significant probability of compromising business operations or threatening an organization’s information security .
  • Privacy Breach : One or more events confirmed to involve, or having a high probability of involving, the unauthorized use, collection, disclosure, or disposal of personal or personal health information.
  • Not every event is an incident. Internal – High Client - All Missing Equipment All Un-authorized Use Medium Privacy Medium Network Attack High Malware Severity to Trigger ESPIM Incident Type
  • Incident Management Framework
    • Strategy : Describes overall approach as well as operational and technical issues.
    • Concept of Operations : Describes the operational model.
    • Operating Directive : Describes IM-related practices.
    • Communications Plan : Describes IM-related communications: the “what”, “who” and “how”.
    • Procedures : Describes specific incident handling activities and steps with activities.
  • Developing Tactical Incident Management Capabilities
    • Train Legal / CRM / HR / Communications/Ops SMEs.
    • Create / Update checklists.
    • Create a quick reference guide for IM IRTs.
    • Conduct Table Top Exercise (TTE) to assess how incident scenarios handled.
    • Rehearse communications plan.
    • Identify metrics & create dashboard to monitor the program.
    • Conduct awareness sessions for people managers.
    • Conduct TTE annually.
  • Incident Management Initiation Process
    • Incident reported.
    • Incident triaged for seriousness and ESPIM criteria by Contact Centre.
    • Incident “ticket” transferred to ESPIM Program Manager.
    • Program Manager assesses incident category and type.
    • Program Manager designates IRT Lead/team members (e.g. ops/legal/communications/client liaisons) conducts briefing.
    • Program Manager transfers ticket to IRT Lead.
  • Incident Management: Activities
      • Detection and classification
    Triage and Re-classification Analyze Cause Develop Workaround Service Recovery Root Cause Analysis Develop Solution Implement & Roll-out 1 2 3 4 5 6 7 8 Division Dept Responsible Consult Inform Accountable Helpdesk Help Desk Receives a call Operations Create RFC Test & implement Privacy & Security Investigate & diagnose Identify workaround, test and document details, risks and impact Implement workaround Determine root cause and escalate Security operations Re-classify the incident and escalate Common Activities – Communications
  • Planning for Incident Management
  • Developing an Incident Management Model
  • EHealth Ontario ESPIM Team Structure
  • Metrics
    • Quantitative Metrics:
    • Mean time to initiate response to incidents by category
    • Mean time to complete response to incidents by category
    • Number of incidents that require external reporting or notification
    • Trend reporting on incident resolution time, by incident type and severity levels
    • Trend reporting on time to close post-incident analysis action items, by activity custody holder
    • Statistical reporting of number of incidents handled, by incident type and severity levels
    • Statistical reporting on % of incidents requiring external notifications
    • Statistical reporting of number of alerts and advisories issued, by type
    • Qualitative Metrics:
    • Summary of incidents handled
    • Client level of satisfaction with incident handling
    • Reporting on business impacts of incidents, including losses (and costs where possible)
  • Breach Communication Messages
    • The simplified facts.
    • What happened:
      • The Speed of discovery and reaction.
      • How we discovered it and what we did.
    • Triage and Containment Measures:
      • What we’re doing now.
    • Preventative Measures:
      • What we’re going to do to make sure this doesn’t happen again.
    • Contact/Communication details:
      • How you can get more information.
  • Problem…People
    • No “ands, ifs or buts”
      • Some people get really upset.
      • Some people you can’t “manage”.
      • Some people won’t understand.
      • Simply give them an outlet:
      • Send them to Org. Privacy Officer or Privacy Commissioner.
  • Service Providers
    • Outsourcing
      • May cause delay in response
      • Requires provider and client to be on same page
      • Need to anticipate responding to incidents
      • Need to coordinate media responses
      • Ensure outsourcing agreement addresses subject of incidents
    • Mandatory reporting of incidents
    • Right of audit
    • Prompt/periodic identification of subcontractors
  • Lessons Learned
    • Conduct Requirements/Needs Analysis
    • Conduct Table Top Exercise
    • Test Communication Plan
    • Develop Test/Use Cases/Scenarios specifically for IM program
    • Develop Tools/Templates wherever possible
    • Develop Checklist/Quick Reference Guide
    • Ensure Single Point of Contact
    • Communicate….Communicate...Communicate
  • Questions?
    • Michael Power
    • Vice President, Privacy and Security
    • eHealth Ontario
    • [email_address]