This case was part of my independent research work in the field of Information Security. The aim of this study was to develop a complex case scenario and understand different facets of assessing an organizational Information Assurance program. Later part of the case involves risk assessment and remediation.
Case Background
SHMF Financial Services*, headquartered in New York City is a start-up financial firm which has started to provide various services like property and asset management, underwriting services, securities handling and tax consulting to its clients, which includes private organizations, government and individuals. SHMF Financial Services grew quickly in last one year with their number of customers increasing from 15 to 80.
Since SHMF Financial Services had major client base in various domains with some reputed organizations, their security strategies and controls need to be well-established and audited regularly internally as well as by their clients. SHMF Financial Services had a small security team to ensure compliance with several local laws and regulations (majorly SOX, GLBA, ISO 27002 and PCI DSS). Some of their important controls included role-based access controls, segregation of critical data, source code version control and physical security controls for protecting the customer data and complying with local regulations.
After the drastic increase in the number of clients, the company’s security and IT support needs to be revaluated. This case analyzes the key considerations to be assessed, identifies the current business and technical risks of SHMF Financial Services and provides contingency and mitigation actions.
Risk Identification and Assessment
Risk Statement 1:
Inability to provide fraud intelligence support and forensic supports which might lead to hefty legal fines and other legal complications.
Risk Drivers:
- Being a startup firm, SHMF does not have enough IT experts to prepare the company for disaster management which includes a disaster like cyber-attack, earthquake, flood or any other unexpected events.
- Lack of knowledge of IT Security team and collaboration of IT security team with the legal team.
Risk Statement 2:
Inability to maintain client satisfaction, prevent corporate reporting errors and potential frauds while ensuring regulatory compliance for clients, due to lack of effective SOD (Segregation of Duties) policies.
Risk Drivers:
- Inefficient access management policies SHMF: Earlier, SHMF had few clients and did not have proper access management policies in place. With the increasing capacity of data, accountability to maintain the system has increased for SHMF.
- SHMF currently uses same administrative accounts for privileged as well as non-privileged activities within SHMF. Furthermore, the internal software developer’s team does not have a software version control and change management procedures allowing anyone to make changes to the software code.
Risk Statement 3:
Inability to prevent unauthorized access to the internal IT systems leading to a data breach which might be accompanied with legal fines, customer loss and market reputation loss.
Risk Drivers:
- Due to ineffective security controls such as not enough firewalls to monitor incoming and outgoing data, use of insecure channels for transmission of data, use of emails to transfer critical financial data.
- SHM currently uses same administrative accounts for privileged as well as non-privileged activities within SHMF. Furthermore, the software developers do not have a software version control and change management procedures allowing anyone to make changes to the software code.
Risk Statement 4:
Inability to limit the collection and use of customer information and protect their privacy to what we believe would be useful to service their financial accounts, administer our business, or tell them about our services might lead to loss of customer trust and market credibility.
Risk Drivers:
- System vulnerabilities might not be able to store customer information in an encrypted way.
- Poorly developed internal software code to manage customer information and disregarding personal information.
Risk Statement 5:
Inability to adapt to any newly introduced U.S. governmental policies for financial auditing and transactions.
Risk Drivers:
- Lack of knowledge of IT folks and legal team and inability to stay current with the laws.
- Due to a stringent business model, it might not be possible for SHMF Financial Services to adapt quickly to any changing environment. No change management process might also serve as a risk driver.
Risk Remediation
Risk Remediation of the above mentioned risks is critical for successful operations of SHMF Financial Services. The three pillars of Security – Confidentiality, Integrity and Availability have to be maintained in order to keep the balance between the risks and costs. “Physical security measures, software password protection, and user access profiles are all basic tenets of confidentiality in the security framework. Access to information is not only limited to authorized personnel but is further restricted to use only for authorized purposes by authorized personnel.” (White, 2011)
Another pillar of Information Assurance Program is maintaining Integrity for the organization. The basic idea of providing integrity of system is to preserve the form of data at a static location as well as throughout it’s transmission from one place to another. The need of preserving integrity of data increase exponentially while handling personally identifiable information or data of high risk (e.g. PHI). Therefore, having secure communication channels within SHMF is essential.
Maintaining availability of data is a foremost goal of an Information Assurance program. The timely availability of stored data, through utilization of the security controls and hardware/software in place manages this facet of an Information Assurance program. “Availability is compromised when a malicious “denial of service” attack prevents customers or users from accessing a website or computer network.” (White, 2011)
There are several other controls that are essential for the mitigation of the risks mentioned above–
- An in-depth assessment of SHMF’s existing internal controls for segregation of user roles can provide insight into how they identify and manage financial risk, reflect the knowledge of the current security team, and provide valuable information on management’s views of the importance of documented procedures and compliance.
- The in-depth assessment can help the team to identify access controls for accountability and authorization of developers, administrators and other users.
- As mentioned above, the three pillars of information security should be protected by the information security team. This includes preventing access of outsiders to the internal systems, using secure communication channels within and outside the organization and providing appropriate authentication and user-access controls.
Through the above mentioned steps and protecting the IT Infrastructure through a thorough security assessment, SHMF Financial Services can expand their business. A safe and secure environment can assure the management and provide better support to other divisions of SHMF Financial Services.
Bibliography
White, Terro. (2011, May 13). What You Need To Know About Information Assurance These Days. Retrieved June 09, 2011, from Finance Article Directory: http://financearticledirectory.com/accounting/what-need-know-about-information-assurance-these-days.html
* All details (company name, setting, location etc.) used in this case study are purely fictitious and any resemblance to any company, business or person is purely coincidental.