5 questions to ask your CEO about cybersecurity

Why you need to go beyond compliance.

Businesses will continue to face a ton of cyber threats, some of which will impact organizations severely enough to require security measures that will reach far beyond compliance. A Ponemon Institute study showed that the average compromised record cost approximately $194 per record. Loss of business due to cyber breaches were estimated to be approximately $3 million.

As you can see, it’s important to make sure that the risk of cyber breaches is taken seriously.

Compliance standards will enable your organization to establish a solid baseline to deal with known risks, but this does nothing to address new and changing threats. Also, more sophisticated threats and vulnerabilities aren’t always known or covered in compliance. You need to have a risk-based approach to this, so that your organization will have a more cost-effective and comprehensive management of these risks.

One of the most common problems involving cybersecurity is the constantly and rapidly changing landscape of security risks. The ever-evolving business environment is changing faster than we’re able to keep up. The traditional way to approach this problem was to focus the majority of resources on the most important parts and create protection against those threats that are the biggest known. This of course, left some lesser important parts of the system vulnerable. In other words, there were some less dangerous risks that were left unprotected, that could possibly cause lost business and still make life hard.  This approach is no longer sufficient in our current day and age.

To approach this problem in the best way possible, advisory organizations have been promoting a different approach.

The National Institute of Standards and Technology (NIST) and the U.S. government have both issued some updated guidelines. (You can learn more about what NIST’s Cybersecurity Framework can do for you here.) While both involve recommendations to business organizations to make a shift towards real-time assessments and continuous monitoring of cyber risks, let’s consider what Homeland Security says are the five key questions to ask your CEO.

1. How specifically is the executive body of leaders kept up to date on the current level of cyber risks and impact to the business?

2. What currently is the level and impact of cyber risks to the business? What key plans or strategies exist to deal with risks that have been identified?

3. How specifically is our current cybersecurity program applying industry standards and best practices?

4. Throughout the course of a week, how many and what types of incidents are detected within the company? What threshold standard is used to alert the executive body of leaders?

5. Just how thorough is our cyber incident response plan? How many times a week or a month is it tested?

As you can see, these questions all lead you to a risk-based approach. With this approach, you’re not just adhering to compliance standards. You’re using a comprehensive approach that leverages best practices and industry standards to identify possible problems, along with processes in place to keep everyone informed. This will enable you to increase the chances of a fast and timely response to possible cybersecurity threats. It will also increase the chance of a quick and easy recovery, when and if such an event should occur.

Time is crucial in this matter. Early response actions can decrease the amount of negative impact to your organization and even possibly eliminate it altogether.  They key to this is planning. This is more than just having a checklist in place and then going down the list, checking off each task. It will involve continuous comprehensive, risk-based preparation in conjunction with your business leadership, public affairs, general counsel, system operators, continuity planners, CEO and your Chief Security Officers.


This article was originally posted on CSOOnline >

Three crucial keys to understanding HIPAA compliance

You already know how important it is to be HIPAA compliant. A lot of businesses, including registered marijuana dispensaries, get confused about the requirements, when it comes to dealing with protected health information. It can get a little fuzzy, if you’re not privy to the big picture.

The Health Insurance Portability & Accountability Act was created in order to set a standard for safeguarding private patient information. Any entity dealing with this kind of protected health information (PHI) is required to ensure all the mandatory processes, network and physical security protocols have been put in place. Prior to these laws, there was no standard for securing PHI. As the medical, healthcare and other covered entities began to technologically advance, there was a movement away from the paper process. More and more businesses began to use electronic data systems to provide clinically based functions, answer eligibility questions and pay claims.


Why is this important?

Keep in mind the major goal of the HIPAA compliance law is to protect the privacy of individuals’ PHI, while allowing covered businesses, including registered marijuana dispensaries, to work with new technologies. These technologies often assist and increase the efficiency and quality of the care provided. With the advance of these technologies comes increased risk of exposing PHI. Without the privacy rule, a patient’s information could very likely, without patient consent, end up being passed on to their employer.

This employer then could use the information to make personal decisions in the workplace. Another scenario could be a lender getting their hands on the patient’s health information and then using that to deny the patient’s application for a credit card, auto loan or home mortgage. In order to avoid this, it is imperative covered businesses do all they can to be HIPAA compliant.


Three keys to compliance: PIE

1. Protect against wrongful and impermissible abuse of PHI and other unauthorized disclosures. This includes ensuring compliance by your workforce.

2. Identify and secure against any threats to the safety of all PHI.

3. Ensure the safety, integrity, confidentiality, privacy and accessibility of all PHI transmitted, maintained, received and/or created.


A business associate can be any third party working with patient records and/or claims processing: accountants, attorneys, consultants, and registered marijuana dispensaries. If they service healthcare entities and have access to PHI, they are all included under HIPAA’s definition of business associates.

In summary, what you want to focus on is the big picture. Covered entities are required to protect patient health information. You are allowed to disclose PHI only to business associates whose services you use, granted you obtain satisfactory assurances. Therefore, your priority is to ensure your business associates will comply with HIPAA and safeguard the PHI they are transacting with throughout your relationship. Obtaining satisfactory assurances means getting it in writing, according to HIPAA compliance guidelines.


This article was originally posted on Worcester Business Journal>

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How much will non-compliance with GDPR cost you?

Any breach of the General Data Protection Regulation could lead to severe fines.

The General Data Protection Regulation (GDPR) went through four years of preparation and debate before being passed by the EU parliament last year. Strict GDPR requirements lay out how companies should process, store, and secure the personal data of EU citizens. The enforcement date is May 25, 2018, and any company not in compliance by that date could be in for a very nasty shock indeed.

The short answer to our question can be found in paragraph 5 of Article 83, which dictates that infringements can lead to fines of up to 20 million euros ($23.6 million at the time of writing) or 4% of the total worldwide annual turnover of the preceding financial year, whichever is higher. Little wonder then, that 92% of US multinationals surveyed by PwC named GDPR as a top priority, and 77% plan to spend $1 million or more on compliance.

Sky high fines?

The high ceiling on fines that will come in with GDPR will give data regulators much greater punitive power, in theory. In practice, we simply don’t know how fines will be levied.

Maximum fines are rare, but there’s currently a great deal of variance from country to country. For example, in the U.K. the Information Commissioner’s Office can issue fines up to 500,000 GBP, but the highest fine to date was 400,000 GBP ($532,158) for telecoms company TalkTalk, after a major data breach that exposed the names, addresses, dates of birth, phone numbers and email addresses of more than 150,000 customers, and bank account details and sort codes for thousands.

There’s some debate about whether high fines will be levied, and in what circumstances, but it’s possible that some data regulators will want to send a clear message by making an example of a company for non-compliance. Apparently, the European Data Protection Board (EDPB) will offer guidance on fines, but that guidance is not yet available and the first few cases are liable to set a precedent.

Reputational damage

The risk of GDPR fines isn’t just the fine amount, but also the fact that your company name will appear in headlines associated with a lack of security. The lasting damage to your brand is hard to quantify, but it seems likely that people concerned about privacy will avoid the brand if an association is made. In the aftermath of TalkTalk’s breach, for example, the company lost more than 100,000 customers.

A severe fine for non-compliance will generate a lot of news stories and any potential customer researching their options may find those stories and be influenced by them for years to come. The way companies collect and use data is coming under increasing scrutiny as privacy concerns among consumers grow, and that trend is only going to increase. Why take the risk?

Sensible security

With uncertainty about the level of fines that will be imposed, businesses need to invest some time and resources into researching GDPR. When Vanson Bourne surveyed 1,600 organizations, it found that 37% of respondents don’t know whether their organization needs to comply with GDPR, while 28% believe they don’t need to comply at all. Ignorance will not provide any protection from fines.

Compliance is a smart move, not just to avoid fines, but to safeguard your customer data. For the most part, the requirements are formalizing a set of principles that you should already be applying. Assess your privacy, hire or appoint a data protection officer, create a data breach plan that includes clear notification within 72 hours, and make sure you know where your data is at all times. Preparing for GDPR compliance is hardly an insurmountable task.

If this prompts companies to review the data they collect and assess whether they need to store it, then that’s a good thing. Too many companies have a data hoarding attitude and it creates unnecessary risk. There’s also no excuse for neglecting to create clear consent forms and privacy policies. Ultimately, companies should not be treating data protection as optional.

We can’t say for sure what non-compliance with GDPR will cost you, but there’s a good chance it will prove more expensive than compliance, and that’s the point.


This article was originally posted on CSOOnline >

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