An overview of why an organization needs a Privacy Incident Response Plan, the elements of the Privacy Incident Response Life Cycle Model, and items to consider when developing a Privacy Incident Response Plan.
The document discusses incident management and response. It covers topics such as defining incidents and objectives of incident management, roles and responsibilities in incident response, developing incident response plans and procedures, testing and reviewing plans, and ensuring integration with business continuity and disaster recovery plans. The goal is to establish capabilities to effectively detect, investigate, respond to and recover from security incidents to minimize business impact.
Understand and apply concepts of confidentiality, integrity and availability, Apply security governance principles,
Understand legal and regulatory issues that pertain to information security in a global context, Develop and implement documented security policy, standards, procedures, and guidelines, Understand business continuity requirements
Contribute to personnel security policies, Understand and apply risk management concepts, Understand and apply threat modeling, Integrate security risk considerations into acquisition strategy and practice, Establish and manage information security education, training, and awareness
This document discusses information risk management and the role of the information security manager (ISM). It covers topics like implementing a risk management program, risk assessment methodologies, information security controls, and integrating risk management into business processes. The document is intended to represent approximately 33% of the content on the CISM examination.
The document discusses the roles and responsibilities of an Information Security Manager (ISM). It explains that an ISM is responsible for developing, implementing, and managing an information security program to align with the organization's information security strategy and business objectives. This involves directing people, processes, and policies to identify controls, create control activities, and monitor control points. It also requires the ISM to ensure commitment from senior management and cooperation across organizational units. Effective information security programs require balancing security, cost, and business needs.
EHR meaningful use security risk assessment sample documentdata brackets
Under the HIPAA Privacy and Security Rule, business associates are required to perform active risk prevention and safeguarding of patient information that are very important to patient privacy. The HITECH act allows only minimum necessary to be disclosed when handling protected health information (PHI).
This security risk assessment exercise has been performed to support the requirements of the Department of Health and Human Services (HHS), Office for the Civil Rights (OCR) and other applicable state data privacy laws and regulations. Upon completion of this risk assessment, a detail risk management plan need to be developed based on the gaps identified from the risk analysis. The gaps identified and recommendations provided are based on the input provided by the staff, budget, scope and other practical considerations
The document is a HIPAA GAP assessment report for ABC Company conducted by FishNet Security. It summarizes the objectives of assessing ABC Company's compliance with HIPAA privacy and security rules. The assessment found variances between ABC Company's environment and controls and the standards required by HIPAA. The report provides high-level findings and recommendations to help ABC Company achieve compliance as a covered entity. Detailed technical findings are included in an appendix.
IT has deployed the appropriate security controls. You've updated your policies and procedures and raised awareness. And you've got your incident response plan in place. What could possibly go wrong? The answer is: the plan itself. All the planning and preparation in the world won't protect your business from a data breach if the response plan doesn't work. It's necessary to ensure that your response plan stays current and functional.
This webinar will provide a checklist of items to review when auditing your response plan. It will also review how often you should audit, test, and update your plan.
The document discusses incident management and response. It covers topics such as defining incidents and objectives of incident management, roles and responsibilities in incident response, developing incident response plans and procedures, testing and reviewing plans, and ensuring integration with business continuity and disaster recovery plans. The goal is to establish capabilities to effectively detect, investigate, respond to and recover from security incidents to minimize business impact.
Understand and apply concepts of confidentiality, integrity and availability, Apply security governance principles,
Understand legal and regulatory issues that pertain to information security in a global context, Develop and implement documented security policy, standards, procedures, and guidelines, Understand business continuity requirements
Contribute to personnel security policies, Understand and apply risk management concepts, Understand and apply threat modeling, Integrate security risk considerations into acquisition strategy and practice, Establish and manage information security education, training, and awareness
This document discusses information risk management and the role of the information security manager (ISM). It covers topics like implementing a risk management program, risk assessment methodologies, information security controls, and integrating risk management into business processes. The document is intended to represent approximately 33% of the content on the CISM examination.
The document discusses the roles and responsibilities of an Information Security Manager (ISM). It explains that an ISM is responsible for developing, implementing, and managing an information security program to align with the organization's information security strategy and business objectives. This involves directing people, processes, and policies to identify controls, create control activities, and monitor control points. It also requires the ISM to ensure commitment from senior management and cooperation across organizational units. Effective information security programs require balancing security, cost, and business needs.
EHR meaningful use security risk assessment sample documentdata brackets
Under the HIPAA Privacy and Security Rule, business associates are required to perform active risk prevention and safeguarding of patient information that are very important to patient privacy. The HITECH act allows only minimum necessary to be disclosed when handling protected health information (PHI).
This security risk assessment exercise has been performed to support the requirements of the Department of Health and Human Services (HHS), Office for the Civil Rights (OCR) and other applicable state data privacy laws and regulations. Upon completion of this risk assessment, a detail risk management plan need to be developed based on the gaps identified from the risk analysis. The gaps identified and recommendations provided are based on the input provided by the staff, budget, scope and other practical considerations
The document is a HIPAA GAP assessment report for ABC Company conducted by FishNet Security. It summarizes the objectives of assessing ABC Company's compliance with HIPAA privacy and security rules. The assessment found variances between ABC Company's environment and controls and the standards required by HIPAA. The report provides high-level findings and recommendations to help ABC Company achieve compliance as a covered entity. Detailed technical findings are included in an appendix.
IT has deployed the appropriate security controls. You've updated your policies and procedures and raised awareness. And you've got your incident response plan in place. What could possibly go wrong? The answer is: the plan itself. All the planning and preparation in the world won't protect your business from a data breach if the response plan doesn't work. It's necessary to ensure that your response plan stays current and functional.
This webinar will provide a checklist of items to review when auditing your response plan. It will also review how often you should audit, test, and update your plan.
This document discusses information security management and auditing. It covers topics such as access controls, logical and physical security, security objectives, risk management, incident response, and controls for remote access, removable media, and audit logging. The goal is to provide assurance that an organization's security policies ensure confidentiality, integrity and availability of information assets.
Information security management (bel g. ragad)Rois Solihin
This document discusses the information security life cycle, which includes 6 steps: 1) security planning, 2) security analysis, 3) security design, 4) security implementation, 5) security review, and 6) continual security. It focuses on the first two steps of security planning and security analysis. For security planning, it covers asset definition, security policy, security objectives, and security scope. For security analysis, it describes the key activities of asset analysis, impact analysis, threat analysis, exposure analysis, vulnerability analysis, analyzing existing security controls, and risk analysis to define security requirements.
Fraudulent Methods for Attacking Bank Networks and Prevention 2014Aladdin Dandis
The document outlines modules for a training course on banking security, including topics like banking fraud, hacking methodologies, malware, cyber crimes, and encryption. The first module introduces key security concepts like confidentiality, integrity, availability, risk management, and the principle of least privilege. It also discusses social engineering, security costs, and the importance of training.
Get information on the HIPAA Omnibus rule and how the revised regulations will impact not only healthcare organization but also covered entities and other IT providers - OConnor Davies - NYC CPA Firm.
Business case for information security programWilliam Godwin
This document presents a business case for establishing an information security program. It outlines the background, value, scope, and components of the program. The program aims to safeguard corporate information assets, establish security standards, comply with regulations, and align IT services with business needs. It involves categorizing data, determining risk appetite, analyzing business impacts, developing a security strategy and plans, and implementing controls. The goal is to effectively manage risks and threats, drive process maturity over time, and provide continuous improvements.
This document discusses auditing information systems infrastructure and operations. It provides guidance on evaluating key aspects of IS operations, including service level management, third party management, operations procedures, maintenance, data administration, capacity and performance monitoring, problem management, change management, backup and recovery provisions, and disaster recovery plans. The purpose is to ensure that IS processes meet organizational objectives and strategies.
The document outlines a systematic approach to risk assessment that includes analyzing infrastructure, security requirements, threats, risks, and developing a risk treatment plan. It discusses applying this methodology to risk assessments of SCADA environments. Key challenges with SCADA assessments include long lifecycles, different impacts of incidents, new interconnections, and constraints during technical testing. The document also provides some examples of common issues found during SCADA assessments, such as insecure protocols, physical access problems, and a general lack of security processes and awareness.
Its time to rethink everything a governance risk compliance primerEnclaveSecurity
Governance, Risk, & Compliance (GRC) is more than a catchy acronym – it is an approach to business culture. GRC is a three-legged stool that is necessary to effectively manage and steer the organization. This presentation will provide an introduction to GRC and discuss the collaboration and sharing of information, assessments, metrics, risks, policies, training, and losses across business roles and processes. GRC helps identify interrelationships in today’s complex and distributed business environment.
Module 4 disaster recovery student slides ver 1.0Aladdin Dandis
The document discusses various topics related to business continuity and disaster recovery planning. It defines key concepts like fault tolerance, failover, availability, clustering, backups (cold, hot), and server types (cold, warm, hot). It also discusses replication, the five nines availability standard, and considerations for small to medium sized businesses developing continuity plans.
MBM eHealthCare Solutions HIPAA-HITECH & Meaningful Use Risk AnalysisCharles McNeil
The document provides an overview of HIPAA and HITECH privacy and security requirements for small healthcare practices, including risk analysis. It discusses key aspects of HIPAA, including the Privacy Rule, Security Rule, and HITECH Act. It outlines the requirements for conducting a risk analysis under the HIPAA Security Rule and Meaningful Use Stage 2, including identifying ePHI, threats, vulnerabilities, and implementing security updates. The presentation emphasizes that third-party assistance may be needed to properly conduct a HIPAA-compliant risk analysis given the expertise required and resources of small practices.
This document discusses various frameworks for IT governance, including COBIT, ISO 27001, ITIL, and others. It defines key terms like governance, risk management, and compliance. Governance ensures objectives are met and risks managed, while management plans and executes activities. IT governance is concerned with IT delivering business value and managing risks. The frameworks provide guidance on implementing and maintaining effective IT governance and security programs.
The HIPAA Security Rule establishes national standards to protect individuals’ electronic personal health information that is created, received, used, or maintained by a covered entity. The Security Rule requires appropriate administrative, physical and technical safeguards to ensure the confidentiality, integrity, and security of electronic protected health information. The Security Rule is located at 45 CFR Part 160 and Subparts A and C of Part 164.
HIPAA Security Rule list 28 adminstrative safeguards, 12 Physical safeguards, 12 technical safeguards along with specific organization and policies and procedures requirements. EHR 2.0 HIPAA security assessment services help covered entities to discover the gap areas based on the required and addressable requirements.
There are two main rules for HIPAA. One is a rule on privacy and the other on Security.
The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections. The Privacy Rule is located at 45 CFR Part 160 and Subparts A and E of Part 164.
How often the security should be reviewed?
Security standard mentioned under HIPAA should be reviewed and modified as needed to continue provision of reasonable and appropriate protection of electronic protected health information.
Confidentiality
Limiting information access and disclosure to authorized users (the right people)
Integrity
Trustworthiness of information resources (no inappropriate changes)
Availability
Availability of information resources (at the right time)
http://ehr20.com/services/hipaa-security-assessment/
New Ohio Cybersecurity Law RequirementsSkoda Minotti
Skoda Minotti’s Risk Advisory Services Group and Insurance Services Group are working closely with insurance industry licensees to meet the considerable requirements under the Ohio cybersecurity law. This presentation provides more detailed information about the law, and assists you with your understanding and implementation of the requirements.
Redspin HIPAA Security Risk Analysis RFP TemplateRedspin, Inc.
RFP Template for healthcare organizations to use when looking for a qualified information security assessment firm to perform a HIPAA Security Risk Analysis as defined in the HIPAA Security Rule 45 CFR 164.308(a)(1)(A).
Meaningful Use and Security Risk AnalysisEvan Francen
Presentation delivered by FRSecure president, Evan Francen to the 100+ Iowa CPSI User Group attendees on October 18th, 2011.
Meaningful Use Core Requirement "Security Risk Analysis"
As an information security professional, it is your role to take on the cybersecurity challenges in your organization. That is where a solid understanding of Risk Management comes in. Risk Management is a lot like a chess game. To succeed you need to understand the risks ahead and be able to plot future scenarios, to weigh up the relative impacts and then plan accordingly. Scroll through this slideshare to learn about 4 essential frameworks.
Cyb 690 cybersecurity program template directions the follAISHA232980
This document provides an overview of some of the key legal and ethical challenges related to cybersecurity. It discusses how organizations have an ethical responsibility to protect user data from hackers. When data breaches do occur, organizations are often partially at fault for not adequately protecting information. The document also discusses the importance of building and maintaining trust with employees. It notes that employees should feel comfortable reporting any wrongdoing through appropriate whistleblowing channels. Finally, it mentions some of the trade-offs that must be considered when addressing these challenges, such as privacy versus security and individual rights versus public safety.
This document provides an overview of cybersecurity offerings from KMicro Tech, including cybersecurity consultancy and advisory services, compliance and governance services, cybersecurity assurance and secure infrastructure services, and managed security services. Key services outlined include risk assessments, security policy development, penetration testing, firewall management, identity and access management, security information and event management, and incident response. The document provides high-level descriptions of each service offering.
Information Security Governance and Strategy Dam Frank
The document discusses information security governance and strategy based on ISO 38500:2008. It covers key aspects of IT governance including evaluating who makes IT decisions, directing the implementation of decisions, and monitoring conformance. The six principles of IT governance outlined are responsibility, strategy, acquisition, performance, conformance, and human behavior. An IT governance model is illustrated showing how the principles relate to evaluating, directing, and monitoring IT processes.
Identity Theft ResponseYou have successfully presented an expaLizbethQuinonez813
The CEO has tasked you with developing an identity theft response plan for your financial organization. This plan will outline procedures for responding to potential cyberattacks involving theft or compromise of customers' personally identifiable information (PII). You will need to consider responses to both internal incidents, like a rogue employee accessing records, and external incidents, such as a hacker breaching systems. The plan will need to address regulatory compliance, communication with leadership and authorities, and recovery of operations should PII be stolen. It will also help the organization avoid damages to its reputation and legal liability in the event of an identity theft incident.
ZoomLens - Loveland, Subramanian -Tackling Info RiskJohn Loveland
Most companies do not adequately manage information risk until a crisis occurs. With vast amounts of data being created and stored in various locations, it is difficult for companies to understand all the data they hold and the associated risks. A framework is proposed to help companies better understand their data by categorizing it based on risk level and access needs. This would allow companies to prioritize higher risk data and focus security investments more effectively.
This document discusses information security management and auditing. It covers topics such as access controls, logical and physical security, security objectives, risk management, incident response, and controls for remote access, removable media, and audit logging. The goal is to provide assurance that an organization's security policies ensure confidentiality, integrity and availability of information assets.
Information security management (bel g. ragad)Rois Solihin
This document discusses the information security life cycle, which includes 6 steps: 1) security planning, 2) security analysis, 3) security design, 4) security implementation, 5) security review, and 6) continual security. It focuses on the first two steps of security planning and security analysis. For security planning, it covers asset definition, security policy, security objectives, and security scope. For security analysis, it describes the key activities of asset analysis, impact analysis, threat analysis, exposure analysis, vulnerability analysis, analyzing existing security controls, and risk analysis to define security requirements.
Fraudulent Methods for Attacking Bank Networks and Prevention 2014Aladdin Dandis
The document outlines modules for a training course on banking security, including topics like banking fraud, hacking methodologies, malware, cyber crimes, and encryption. The first module introduces key security concepts like confidentiality, integrity, availability, risk management, and the principle of least privilege. It also discusses social engineering, security costs, and the importance of training.
Get information on the HIPAA Omnibus rule and how the revised regulations will impact not only healthcare organization but also covered entities and other IT providers - OConnor Davies - NYC CPA Firm.
Business case for information security programWilliam Godwin
This document presents a business case for establishing an information security program. It outlines the background, value, scope, and components of the program. The program aims to safeguard corporate information assets, establish security standards, comply with regulations, and align IT services with business needs. It involves categorizing data, determining risk appetite, analyzing business impacts, developing a security strategy and plans, and implementing controls. The goal is to effectively manage risks and threats, drive process maturity over time, and provide continuous improvements.
This document discusses auditing information systems infrastructure and operations. It provides guidance on evaluating key aspects of IS operations, including service level management, third party management, operations procedures, maintenance, data administration, capacity and performance monitoring, problem management, change management, backup and recovery provisions, and disaster recovery plans. The purpose is to ensure that IS processes meet organizational objectives and strategies.
The document outlines a systematic approach to risk assessment that includes analyzing infrastructure, security requirements, threats, risks, and developing a risk treatment plan. It discusses applying this methodology to risk assessments of SCADA environments. Key challenges with SCADA assessments include long lifecycles, different impacts of incidents, new interconnections, and constraints during technical testing. The document also provides some examples of common issues found during SCADA assessments, such as insecure protocols, physical access problems, and a general lack of security processes and awareness.
Its time to rethink everything a governance risk compliance primerEnclaveSecurity
Governance, Risk, & Compliance (GRC) is more than a catchy acronym – it is an approach to business culture. GRC is a three-legged stool that is necessary to effectively manage and steer the organization. This presentation will provide an introduction to GRC and discuss the collaboration and sharing of information, assessments, metrics, risks, policies, training, and losses across business roles and processes. GRC helps identify interrelationships in today’s complex and distributed business environment.
Module 4 disaster recovery student slides ver 1.0Aladdin Dandis
The document discusses various topics related to business continuity and disaster recovery planning. It defines key concepts like fault tolerance, failover, availability, clustering, backups (cold, hot), and server types (cold, warm, hot). It also discusses replication, the five nines availability standard, and considerations for small to medium sized businesses developing continuity plans.
MBM eHealthCare Solutions HIPAA-HITECH & Meaningful Use Risk AnalysisCharles McNeil
The document provides an overview of HIPAA and HITECH privacy and security requirements for small healthcare practices, including risk analysis. It discusses key aspects of HIPAA, including the Privacy Rule, Security Rule, and HITECH Act. It outlines the requirements for conducting a risk analysis under the HIPAA Security Rule and Meaningful Use Stage 2, including identifying ePHI, threats, vulnerabilities, and implementing security updates. The presentation emphasizes that third-party assistance may be needed to properly conduct a HIPAA-compliant risk analysis given the expertise required and resources of small practices.
This document discusses various frameworks for IT governance, including COBIT, ISO 27001, ITIL, and others. It defines key terms like governance, risk management, and compliance. Governance ensures objectives are met and risks managed, while management plans and executes activities. IT governance is concerned with IT delivering business value and managing risks. The frameworks provide guidance on implementing and maintaining effective IT governance and security programs.
The HIPAA Security Rule establishes national standards to protect individuals’ electronic personal health information that is created, received, used, or maintained by a covered entity. The Security Rule requires appropriate administrative, physical and technical safeguards to ensure the confidentiality, integrity, and security of electronic protected health information. The Security Rule is located at 45 CFR Part 160 and Subparts A and C of Part 164.
HIPAA Security Rule list 28 adminstrative safeguards, 12 Physical safeguards, 12 technical safeguards along with specific organization and policies and procedures requirements. EHR 2.0 HIPAA security assessment services help covered entities to discover the gap areas based on the required and addressable requirements.
There are two main rules for HIPAA. One is a rule on privacy and the other on Security.
The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections. The Privacy Rule is located at 45 CFR Part 160 and Subparts A and E of Part 164.
How often the security should be reviewed?
Security standard mentioned under HIPAA should be reviewed and modified as needed to continue provision of reasonable and appropriate protection of electronic protected health information.
Confidentiality
Limiting information access and disclosure to authorized users (the right people)
Integrity
Trustworthiness of information resources (no inappropriate changes)
Availability
Availability of information resources (at the right time)
http://ehr20.com/services/hipaa-security-assessment/
New Ohio Cybersecurity Law RequirementsSkoda Minotti
Skoda Minotti’s Risk Advisory Services Group and Insurance Services Group are working closely with insurance industry licensees to meet the considerable requirements under the Ohio cybersecurity law. This presentation provides more detailed information about the law, and assists you with your understanding and implementation of the requirements.
Redspin HIPAA Security Risk Analysis RFP TemplateRedspin, Inc.
RFP Template for healthcare organizations to use when looking for a qualified information security assessment firm to perform a HIPAA Security Risk Analysis as defined in the HIPAA Security Rule 45 CFR 164.308(a)(1)(A).
Meaningful Use and Security Risk AnalysisEvan Francen
Presentation delivered by FRSecure president, Evan Francen to the 100+ Iowa CPSI User Group attendees on October 18th, 2011.
Meaningful Use Core Requirement "Security Risk Analysis"
As an information security professional, it is your role to take on the cybersecurity challenges in your organization. That is where a solid understanding of Risk Management comes in. Risk Management is a lot like a chess game. To succeed you need to understand the risks ahead and be able to plot future scenarios, to weigh up the relative impacts and then plan accordingly. Scroll through this slideshare to learn about 4 essential frameworks.
Cyb 690 cybersecurity program template directions the follAISHA232980
This document provides an overview of some of the key legal and ethical challenges related to cybersecurity. It discusses how organizations have an ethical responsibility to protect user data from hackers. When data breaches do occur, organizations are often partially at fault for not adequately protecting information. The document also discusses the importance of building and maintaining trust with employees. It notes that employees should feel comfortable reporting any wrongdoing through appropriate whistleblowing channels. Finally, it mentions some of the trade-offs that must be considered when addressing these challenges, such as privacy versus security and individual rights versus public safety.
This document provides an overview of cybersecurity offerings from KMicro Tech, including cybersecurity consultancy and advisory services, compliance and governance services, cybersecurity assurance and secure infrastructure services, and managed security services. Key services outlined include risk assessments, security policy development, penetration testing, firewall management, identity and access management, security information and event management, and incident response. The document provides high-level descriptions of each service offering.
Information Security Governance and Strategy Dam Frank
The document discusses information security governance and strategy based on ISO 38500:2008. It covers key aspects of IT governance including evaluating who makes IT decisions, directing the implementation of decisions, and monitoring conformance. The six principles of IT governance outlined are responsibility, strategy, acquisition, performance, conformance, and human behavior. An IT governance model is illustrated showing how the principles relate to evaluating, directing, and monitoring IT processes.
Identity Theft ResponseYou have successfully presented an expaLizbethQuinonez813
The CEO has tasked you with developing an identity theft response plan for your financial organization. This plan will outline procedures for responding to potential cyberattacks involving theft or compromise of customers' personally identifiable information (PII). You will need to consider responses to both internal incidents, like a rogue employee accessing records, and external incidents, such as a hacker breaching systems. The plan will need to address regulatory compliance, communication with leadership and authorities, and recovery of operations should PII be stolen. It will also help the organization avoid damages to its reputation and legal liability in the event of an identity theft incident.
ZoomLens - Loveland, Subramanian -Tackling Info RiskJohn Loveland
Most companies do not adequately manage information risk until a crisis occurs. With vast amounts of data being created and stored in various locations, it is difficult for companies to understand all the data they hold and the associated risks. A framework is proposed to help companies better understand their data by categorizing it based on risk level and access needs. This would allow companies to prioritize higher risk data and focus security investments more effectively.
This document discusses the importance of information sharing between the public and private sectors regarding cybersecurity. It argues that collaboration is key to fighting cybercrimes effectively. While private sectors fear sharing information due to liability and regulatory concerns, timely sharing of technical data on threats could help detection and prevention. Developing trust between sectors is important for effective communication. The document also examines incentives that could encourage information sharing, such as legal protections and liability waivers for shared breach information. Overall it promotes greater cooperation between public and private stakeholders in cybersecurity.
This document discusses the need for small to medium sized hospitals to implement an incident response plan and cyber incident response team (CIRT) to properly handle security incidents. It notes that most such organizations currently lack dedicated resources to properly address cybersecurity issues. The document then outlines some of the key legal implications of health data privacy laws and proposes adapting the established Incident Command System model used in emergency response to structure a CIRT. Specific recommendations are provided regarding the necessary skills, tools, and processes a CIRT would need to effectively prepare for, identify, contain, eradicate, recover from, and follow up on security incidents.
Privacy Breaches In Canada It.Can May 1 2009canadianlawyer
This document summarizes three key questions an organization faces after suffering a privacy breach:
1. Do they have to tell anyone about the breach? Laws in Canada currently only explicitly require notification for health information breaches in Ontario, but notification requirements are developing quickly in other areas.
2. What should they do about the breach? Organizations should investigate the breach, secure any compromised systems or information, and consider notifying affected individuals.
3. Can they be liable for the breach? Laws allow for potential liability, though the extent depends on factors like an organization's security measures and response to the breach. Overall liability in this area is still developing.
Responding to a Company-Wide PII Data BreachCBIZ, Inc.
Many small employers falsely believe they can elude the attention of a hacker, yet studies have shown the opposite is true; a growing number of companies with fewer than 100 employees are reporting data breaches every year.
INCIDENT RESPONSE PLAN FOR A SMALL TO MEDIUM SIZED HOSPITALIJNSA Journal
Most small to medium health care organizations do not have the capability to address cyber incidents within the organization. Those that do are poorly trained and ill equipped. These health care organizations are subject to various laws that address privacy concerns, proper handling of financial information, and Personally Identifiable Information. Currently an IT staff handles responses to these incidents in an Ad Hoc manner. A properly trained, staffed, and equipped Cyber Incident Response Team is needed to quickly respond to these incidents to minimize data loss, and provide forensic data for the purpose of notification, disciplinary action, legal action, and to remove the risk vector. This paper1 will use the proven Incident Command System model used in emergency services to show any sized agency can have an adequate CIRT.
This document analyzes data from the Privacy Rights Clearinghouse database on data breach incidents reported from 2005 to 2015. Some key findings include:
- Hacking or malware were behind 25% of breaches, while insider leaks accounted for 12% and unintended disclosures 17.4%.
- Payment card data breaches increased substantially after 2010 likely due to malware targeting point-of-sale systems.
- The healthcare sector experienced the most breaches followed by government and retail. Personally identifiable information and financial data were the most commonly stolen records.
- While credit card and bank account information is frequently dumped online, accounts for services like Uber, PayPal and poker saw increased dumping.
- Organizations must strengthen
Cyber risks troubling organisations
The document discusses data breaches, how they occur, and common types like insider leaks and payment card fraud. It provides a case study on Anthem, a large US health insurer that suffered a major data breach in 2015 affecting 80 million customers. Anthem ultimately paid $115 million to settle lawsuits. The document concludes with lessons learned from the Anthem breach and recommendations for preventing data breaches like maintaining system documentation, having an IT security framework, and conducting continuous auditing.
MCCA Global TEC Forum - Bug Bounties, Ransomware, and Other Cyber Hype for Le...Casey Ellis
This document summarizes key topics from a presentation on cybersecurity issues and legal considerations, including:
1) Cyberattacks pose a significant and growing threat, with annual global costs of cybercrime estimated to rise from $3 trillion currently to $6 trillion by 2021. Data breaches continue to mount in size and frequency.
2) Responding to cyber incidents involves substantial costs beyond direct remediation, including brand impact, lost revenue, legal claims, and government fines. Companies are often under-resourced to address cybersecurity issues fully.
3) Bug bounty programs and security researchers can help companies identify vulnerabilities, but legal risks remain around disclosure of vulnerabilities to regulators or the public. Careful management
Bug Bounties, Ransomware, and Other Cyber Hype for Legal CounselCasey Ellis
This document summarizes a presentation on cybersecurity legal issues for companies. It discusses the growing costs and impacts of cyberattacks like data breaches and ransomware. Bug bounty programs that hire security researchers are presented as a way for companies to find vulnerabilities, but they may also increase legal obligations to notify breaches. The role of legal counsel in addressing these issues is examined, including maintaining technical competence. Elements of effective cybersecurity programs and incident response planning are outlined to help mitigate risks and consequences.
What every CEO needs to know about Califorinia's new data breach lawDavid Sweigert
California's new Assembly Bill 1710 will require companies to offer 12 months of free credit monitoring (at a cost of around $100 per person) to customers affected by a data breach. For organizations that experience a breach of 1,000 customer records, this will result in costs of around $100,000. The bill takes effect on January 1, 2015. It adds further legal liability for companies holding data on California residents and shows that data breaches are inevitable, so companies need strong data security practices as well as breach response and recovery plans.
This document discusses information security for informatics professionals. It begins with an introduction of the speaker, Amy Walker, which details her experience in healthcare, informatics, and security. The presentation will cover IT security pillars, constructing policies and procedures, security standards and risk assessment strategies, system architecture and design, and an overview of security issues and solutions. Examples of data breaches and related fines are provided to illustrate security risks faced by healthcare organizations. Frameworks and best practices for security are also outlined to help attendees strengthen their organization's security posture.
WCIT 2014 Matt Stamper - Information Assurance in a Global ContextWCIT 2014
This document provides an overview of a presentation on information assurance in a global context. It discusses why information assurance matters given increasing dependencies on accurate data. It also covers definitions of security, privacy and information assurance. Additionally, it outlines regulatory requirements, frameworks, technologies like IoT and cloud computing, and lessons from cross-border regions. The presentation agenda is included which covers these topics over several pages in more depth.
Complacency in the Face of Evolving Cybersecurity Norms is HazardousEthan S. Burger
Complacency in the face of evolving cybersecurity norms is hazardous. Executives and boards are often reluctant to adopt comprehensive cybersecurity policies due to costs and contradictory advice. However, failing to take action increases regulatory and legal risks. Cyberattacks are difficult to defend against and are becoming more sophisticated. Small and medium enterprises are particularly vulnerable targets but may underestimate threats due to limited resources. Government efforts to work with businesses on cybersecurity have been inconsistent, creating uncertainty around compliance. Cyberbreaches can result in significant litigation and liability for companies, especially as legal standards continue developing. Comprehensive and strategic planning is needed to address diverse cyberattack risks.
This document summarizes an article from The Corporate Governance Advisor on tools for boards to oversee cybersecurity risk. It discusses the business impacts and litigation/regulatory risks of cyber attacks. It outlines how boards have an oversight duty to ensure proper information and reporting systems exist to manage cybersecurity risk. The document provides examples of cybersecurity disclosure from companies like Target and Home Depot. It discusses SEC guidance on cybersecurity disclosure and notes boards must exercise oversight in good faith to avoid liability for failures.
Before the Breach: Using threat intelligence to stop attackers in their tracks- Mark - Fullbright
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Legal Issues in Data Privacy and Security: Response Readiness Before the BreachDawn Yankeelov
The document summarizes legal issues related to data privacy and security breaches. It discusses (1) the relevant cost-benefit analysis that courts consider for data security, (2) examples of court orders regarding document productions and computer forensics in litigation, and (3) that parties are responsible for errors made by their vendors. The document then provides an agenda on legal issues in data privacy and security, including anticipating threats, incident response, and applying relevant laws and frameworks.
Similar to Does Your Organization Have A Privacy Incident Response Plan? (20)
Legal Issues in Data Privacy and Security: Response Readiness Before the Breach
Does Your Organization Have A Privacy Incident Response Plan?
1. Article: Does Your Organization Have A Privacy Incident Response Plan? (Print Version) Page 1 of 6
Article: Does Your Organization Have A Privacy Incident Response Plan?
May 2007 Newsletter
Printer Friendly Version
Author: William L. Dana, CISSP, CISM, CBCP, CIPP
With 14 years of experience, Mr. Dana’s career has provided a diverse experience not only in the designing, installation,
integration, and maintenance of network systems but also in areas of information security and information privacy
assurance. He has over 8 years of experience in information security and over 6 years of experience as a Privacy
Engineer supporting Federal Agencies and Commercial clients. Bill is currently working with ISACA’s National Capital Area
Chapter in DC to help establish the Information Privacy / Privacy Governance Committee for the Chapter. Bill can be
reached for comments or interests in the Privacy Committee at b.dana@dana-enterprises.com.
In today’s world of the “Information Age” where virtually every organization is not only “online” but is interconnected or
has some form of electronic data sharing activities with at least one other organization, it is not a case of “IF” an
organization will have a privacy breach —it is a question of “WHEN” it will occur. While this may sound pessimistic or
even fatalist, it is not only a safe assumption to make but should be the foundation an organization uses to prepare its
privacy incident response plan or program. Looking back over the last two years, the shift from “IF” to “WHEN” can be
supported by facts like:
Within the United States, between January 10, 2005 and March 20, 2007 there have been 520 privacy breaches
reported that have involved over one-hundred-and-four (104) million records.[1]
At least 30 states have enacted Privacy Breach Notification Laws [2] as a result of significant privacy breaches.
Notification requirements vary between states (organizations with an international presence will also be faced with
notification requirements for the countries where they have a presence) in regard to issues such as identifying
what is considered to be a breach that requires notification and the time frame for notifying.
While there are no Federal notification requirements [3] depending on the business sector your organization is in,
Federal Statues such as, Safeguard Rule of the Gramm-Leach-Bliley Act [4], The Health Insurance Portability and
Accountability Act’s (HIPAA) Security and Privacy Rule [5], or The Fair and Accurate Credit Transactions Act‘s
(FACTA) record disposal rule [6] may be factors impacting how an organization responds to and handles a privacy
breach.
Although the majority of breaches currently reported are technology related, privacy breaches still occur with
hardcopy documents (see Table 1, Recent Privacy Breaches Involving Paper Documents). A breach involving
hardcopy documents can be just as serious as one involving technology.
A privacy breach can be an “internal incident” where information is exposed to unauthorized personnel within an
organization (e.g. salary information for an employee is disclosed to other employees), or it can be an “external
incident” where information is disclosed to or obtained by parties outside the organization (e.g., stolen computers,
hackers, incorrect mailings, etc.).
Table 1 – Recent Privacy Breaches Involving Paper Documents [7]
# of
Date Organization Description
Records
1/21/06 California Army National Stolen briefcase with personal information of National Guardsmen including a “Hundreds”
Guard “seniority roster,” social security numbers and dates of birth.
6/8/06 Univ. of Michigan Credit Paper documents containing personal information of credit union members were 5,000
Union (Ann Arbor, MI) stolen from a storage room.
6/13/06 U.S. Dept of Energy, Current and former workers at the Hanford Nuclear Reservation were notified 4,000
Hanford Nuclear that their personal information may have been compromised, after police found
Reservation (Richland, WA) a 1996 list with workers’ names and other information in a home during an
unrelated investigation.
2/20/07 Back and Joint Institute of 20 boxes containing social security numbers, photocopies of driver’s license “Hundreds”
Texas (San Antonio, TX) numbers, addresses, phone numbers and private medical history of chiropractic
patients were found in a dumpster.
Why Should My Organization Have a Privacy Incident Response Plan?
Without question, a privacy breach is a very costly event for an organization. It is currently estimated that an
organization can expect to spend about $182.00 [8] per compromised record to respond to and mitigate a privacy
breach (up from an estimated cost of $132 per record in 2005). In addition to the cost aspect, a privacy breach can
result in your organization getting the attention of news media, industry regulatory agencies, and attorney generals, not
to mention your organization’s customers. How your organization responds to and handles a privacy breach can have a
dramatic impact both financially and with regard to public opinion.
Think of the Privacy Incident Response Plan (PIRP) in the terms of a contingency plan that provides a framework for how
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2. Article: Does Your Organization Have A Privacy Incident Response Plan? (Print Version) Page 2 of 6
an organization will respond, identifies key team members, and allows your organization to respond in a coordinated
manner to minimize damage and prevent a bad situation from getting worse. Once your organization has a PIRP in
place, it will have a platform for mock incidents to be conducted to train personnel, evaluate the plan for gaps, and be
better prepared to respond in a coordinated manner and to handle multiple notification requirements.
My Organization Already Has a Computer Security Incident Response Program. Is That Not Enough?
Odds are no—having just a computer security incident response program (CSIRP) will provide only a small part of what
will be needed to respond to and handle a privacy incident. Most CSIRPs are designed to monitor, detect, and respond to
network based incidents. However, most CSIRPs are not prepared to conduct in-depth data analysis to assess the types
and scope of information that maybe involved in data breaches. Some other areas that your organization’s CSIRP may
not address but which are necessary to consider when handling a privacy incident are:
Responding to and handling paper-based data breaches;
Supporting all the phases in the life cycle of a privacy incident beyond the traditional incident response life cycle
illustrated in Figure 1;
Determining scope, risk, and impact of the breach based on analysis of the information involved with the breach;
Coordination of various internal and external notification requirements with regulators, law enforcement,
customers, senior management, and/or stockholders;
Handling potential incident notifications that come from outside of the organization (e.g., phone call from local
media);
Assuming that an outside agent contacting the organization about a suspected breach is a “Good Samaritan”
rather than considering that the outside agent could be a “malicious actor” with hostile intentions.
What Are The Phases of a Privacy Incident Life Cycle a That Should be Covered by a Privacy Incident
Response Plan?
Part of what makes the privacy incident life cycle unique is that like most privacy programs and policies, it draws on the
principles of “Fair Information Standards”[10] and is therefore much more transparent and involves a lot more
communication than does a typical CISRP, or even a Continuity of Operations Plan / Contingency Plan / Disaster
Recovery Plan (COOP / CP / DRP). The other unique aspect of this life cycle is that it is very probable that any
organization will be operating in multiple phases simultaneously.
Currently there is no definitive life cycle model that can be pointed to (as there is with a CSIRP or Contingency Planning).
Most privacy incident life cycle models should have phases similar to the following ones: Detection Analysis,
Containment, Notification, Recovery, and Monitoring / Preparing. To provide a reference point for discussion of the
privacy incident life cycle, the following Privacy Incident Response Life Cycle Model [11] in Figure 2, has been created to
provide an illustration of what a Privacy Incident Response Plan should address.
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The Incident Detection and Identification phase (or the Detect/Analysis Phase in a CISRP) involves both reactive and
proactive processes that gather, monitor, or receive potential incident information from internal and external sources as
well as from monitoring for indications with tools like intrusion detection systems. Your organization’s CISRP may very
well be the primary group responsible for this activity. However, there will be new monitoring points that a Computer
Incident Security Response Team (CISRT) or Coordination Center may need to include: digital rights management [13]
systems, content management systems, breach prevention systems, privacy/ethics hotlines, and of course the news
media. Once the incident is identified, some initial triage is done to classify/categorize, prioritize, and validate the initial
information, begin documentation of the incident, and the eventually hand off the information to the Incident Analysis
and Screening Phase. With the declaration of a privacy incident a Privacy Incident Response Team (PIRT) specific for the
incident would be assembled and assume coordination and oversight of the incident response.
The Privacy Incident Analysis and Screening phase, while it may involve the CISRT, should be overseen by the
assembled Privacy Incident Response Team, which would be made up of key members called for in the PIRP. Part of the
PIRT would include a small workgroup which would include personnel that are knowledgeable about the business
process, systems, and data involved in the breach. It would be this small workgroup’s task to conduct the detailed
analysis based on the information available to develop an information data model that would identify to the greatest
extent possible what records/information have been compromised. With the identification of an incident as a privacy
incident, it becomes imperative and critical that an organization not just know the basic facts (when it happened, if the
breach is still occurring, how it occurred, where it occurred, etc.) but also start identifying information about the actual
data involved:
Who is the Source/Owner of the data within the Organization and what IT systems are involved?
Initial estimate of how much data may be involved (e.g., an entire database, a set of tables from a database,
10,000 records, etc.).
The time period and/or age of the data affected by the incident (e.g., between current and 3 months ago,
between 3 to 5 years ago, etc.).
Who currently knows about the incident (e.g., already in the newspapers, internal within organization, or just the
response teams and the person that notified the organization of the incident)?
Who was involved with events leading up to the time when the incident occurred?
What protection was in place prior to the event and what protection
may still be in place (e.g., data encryption, digital rights)?
Will data forensic services be needed?
Are formal and controlled “Chain of Custody” protocols required for evidence collection and protection?
While the Incident Analysis and Screening Phases initial objective is to define the boundaries and ranges of data
involved, typically the group conducting the detailed analysis will continue to refine the information data model through
out the remaining phases of the life cycle until either (a) the data is recovered and can be verified that it was not
compromised or (b) a mitigation strategy has been fully implemented (e.g. accounts closed, credit monitoring services,
etc.).
Containment
During Phase 3, which could potentially occur simultaneously with Phase 1 and/or Phase 2 depending on the incident, the
PIRT begins to contain the incident (and prevent additional information from being disclosed if the incident is still on
going) and assess the impacts of the breach. Containment for a privacy incident could require:
Securing Data Processing Operations to prevent further disclosure of information.
Containment of what employees know about the incident to only what they need to know, especially during the
early stages of the response; containing rumors as much as possible.
Limiting who represents or speaks for the organization about the incident with the media, law enforcement,
regulators, affected individuals, and to the employees within the organization.
Containing or withholding details about the incident from the media due to investigation by law enforcement or to
prevent the perpetrator from learning exactly what is contained in the data, as they may not be aware of what
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they have.
Containment could also involve having to invoke a “blackout period” for trading stock by the organization’s
employees.
Breach Assessment
The Breach Assessment step of Phase 3 is where the impact to the organization begins to be determined based on the
information data model that was constructed and refined by the Incident Analysis and Screening process. A Breach
Assessment for a privacy incident should draw on elements from the organization’s risk management plans (corporate as
well as IT) and potentially could rely on some of the same processes used during the damage assessment phase from
the organization’s COOP / CP / DRP.
The breach assessment should include:
Estimated risk and probability that the breach will result in identity theft of the impacted individuals.
Identification of what jurisdictions are involved (e.g. in what states are the impacted individuals located, are
foreign countries involved, etc.).
Identification of the external stakeholders requiring notification about the incident.
What type of notification is required and when is it required by law or regulation?
Should all impacted parties receive the same notification information as would be required by the most stringent
law or will impacted parties receive different notification information based on the laws for where they reside?
Recommendations related to voluntary notification and involvement of law enforcement.
Should external consultants be obtained (e.g., legal counsel, public relations firm, investigative or forensic
services)?
Just as a COOP / CP / DRP has some standard basic scenarios for response defined (i.e., hurricane, flooding, etc.), a
PIRP should have some standard response plans that can be used by the organization as a starting point for both
handling the incident at its discovery and then modifying the standard response in order to address the requirements of
a particular incident. As an example, some of the standard response plans that an organization might need to develop
are for:
An incident that involves employee records only;
An incident that involves the loss of Business Proprietary records;
An incident that involves the compromise of customer and consumer data;
Use of a third party to manage response or notification aspects of an incident.
Similar to Phase 2, an organization may have a specific team that handles the breach assessment activities for the PIRT
for a number of reasons, one being that it is very possible that the breach assessment may have to occur simultaneously
with either Phase 1 or Phase 2; it would then need to be revised and updated as detailed information became available.
Having some standard response plans to start from could mean the difference that keeps a bad day from getting worse,
such as when the incident is discovered at the same time the media arrives to interview the management team. Having
these plans in place to address not only initial handling procedures but also a generic response can allow an organization
to begin mitigation efforts and notification efforts faster than if they were to start from scratch.
In the context of this article, “response” and “notification” are considered two separate functions. “Response” refers to
activities the organization engages in to prepare for the notification process and necessary remediation activities
required; and “notification” is defined as formally notifying the impacted individuals of the compromise and of the
mitigation efforts to prevent identity theft.
Response
Where the prior phases were oriented more towards data collection and analysis of the incident, in Phase 4 the
organization finalizes and implements the proposed “response plan” as part of the output from the Breach Analysis step
of Phase 3. During Phase 4 a number of things may be occurring concurrently throughout the organization.
Call Center Staff is being trained and provided a script for when calls come in to be able to respond.
Procurement Office may be arranging for provisions for impacted individuals to receive credit monitoring services
and/or credit reports.
Accounts Receivable staff may be closing and voiding affected accounts and establishing new accounts for the
impacted individuals;
IT Staff may be upgrading systems with patches or installing additional monitoring and auditing functions for
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impacted systems.
Notification
The notification step of this phase involves the arduous task of complying with various local, state, federal, or
international laws to individually notify each affected person that his or her personal information has been compromised
(and should not be confused with other messages that may have been sent out to affected parties in other stages). This
notification typically will provide detailed information about the breach (as appropriate based on any law enforcement
investigation in process), steps taken to prevent it from happening, how the individual whose data was involved may be
impacted, identification of any steps the individual may have to take to protect him or herself, what the organization is
doing for the individual, and who to contact with questions or for more information.
As part of this step, the organization would notify any regulatory agencies about the incident, if they had not already
done so. The organization may also need to send notifications about the incident to its vendors, clients, and creditors.
The activities initiated in the notification step will be moderate to long term tasks that will need to be tracked until they
are closed out. There is also the potential that follow-up notifications to some of the individuals will be required.
With any incident, but possibly more so with a privacy incident, the Post-Incident Review could be critical for the
organization in the days to come after the incident has been “closed out.” One of the goals of the Post-Incident Review
should be the development of a final report that documents the entire incident and includes a detailed timeline of events,
a formal documentation of decisions made, and a log of all incident related data. [14]
Every incident response system, regardless of what it is designed to respond to, is a constantly changing and adapting
system to identify, respond to, and maybe even prevent new threats. One of the final steps that should always be taken
before closing out an incident, no matter how good or bad the outcome was, is to conduct a Post-Incident Review.
Seldom will there be an incident from which an organization or a response team will not be able to learn something.
More often than not, necessary changes to procedures are identified.
As your organization monitors compliance with privacy requirements and periodically evaluates the effectiveness of your
response plan, don’t forget to also monitor what is going on with other organizations. There is always the potential to
learn something from an incident involving another organization. With the publicity recent privacy incidents have been
getting, there is a wealth of actual incidents against which you can evaluate your plan (or as the starting point for
developing one) by conducting a tabletop exercise and simulating the incident as if it had occurred at your organization.
Things to Remember When Developing a Privacy Incident Response Plan
First and most importantly, do not forget about the paper documents within the organization. While the information and
technology systems may be the primary source for a potential privacy breach your plan still has to take into account and
be ready to handle the loss or theft of paper records. An incident involving paper documents may also prove the hardest
to respond to and handle if the organization does not have an effective records management system.
Secondly, your Privacy Incident Response Plan is not a stand-alone document and should ultimately be interdependent
on a number of other plans and/or programs your organization has put in place as part of its corporate governance [15]
such as the:
Risk Management Plan (both Organizational and Information Technology);
Continuity of Operations / Contingency Plan / Disaster Recovery / Business Resumption Plans;
Communications Plan / Crisis Communications Plan;
Information Systems Inventories / Business Process Models / Data Models;
Computer Security Incident Response Plan / Physical Security Incident Response Plan.
Your Privacy Incident Response Plan will need to involve a cross-functional team that should have senior level
participation. Some of the representation that the team will need to have from within the organization is: Legal Counsel,
Corporate Communications / Public Relations, Human Resources, Chief Information Officer, Chief Privacy Officer, Chief
Risk Officer, as well as representation from the business or data owner for the information involved in the breach.
Another key point to handling a privacy incident and developing a privacy incident response plan is the need for timely,
accurate, and appropriate communications both within your organization between departments and employees, and
external to your organization with customers, media representatives, regulators, and law enforcement officials. However,
in order to have timely, accurate, and appropriate communications your organization will need to have solid information
about what happened, how it occurred, what information was affected, how the incident was detected, and what
mitigating controls were in place.
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