The General Data Protection Regulation & The Duty to use Encryption

The General Data Protection Regulation, abbreviated to GDPR, raised a storm when it arrived. In reality, it merely tightened up on existing good practice according to digital security specialists Gemalto. The right to withhold consent and to be forgotten has always been there, for example. However, the GDPR brings a free enforcement service for consumers, thus avoiding the need for third party, paid assistance.

The GDPR Bottom Lines for Data Security
Moreover, the GDPR has penalties it can apply, of the order that might have a judge choking on his wig. Under it, data security measures such as pseudonymisation (substitution of identifying fields) and encryption (encoding including password protection) have become mandatory. Businesses must further respect their client data by:

a) Storing it in a secure environment supported by robust services and systems

b) Having proven measures to restore availability and access after a breach

c) Being able to prove frequent effectiveness testing of these measures.

The General Data Protection Regulation places an onus on businesses to report any data breaches. This places us in a difficult situation. We must either face at least a wrist slap upon reporting failures. Alternatively, pay a fine of up to ?10 million, or 2% of total worldwide annual turnover.

The Engineered Weak Link in the System
Our greatest threat of breach is probably when the data leaves our secure environment, and travels across cyberspace to an employee, stakeholder, collaborator, or the client themselves. Since email became open to attack, businesses and individuals have turned to sharing platforms like Dropbox, Google Drive, Skydrive, and so on. While these do allow an additional layer of password protection, none of these has proved foolproof. The GDPR may still fine us heavily, whether or not we are to blame for the actual breach.

How Hacking is Approaching Being a Science
We may make a mistake we may regret, if we do not take hacking seriously. The 10 worst data hacks Identity Force lists are proof positive that spending lots of money does not guarantee security (any more than having the biggest stock of nuclear weapons). We have to be smart, and start thinking the way that hackers do.

Hacker heaven is finding an Experian or a Dun & Bradstreet that may have shielded 143 million, and 33 million consumer records respectively, behind a single, flimsy cyber-security door. Ignorance is no excuse for them. They should simply have known better. They should have rendered consumer data unreadable at individual record level. The hackers could have found this too demanding to unpick, and have looked elsewhere.

How Data Encryption Can Help Prevent Hackers Succeeding
Encrypting data is dashboard driven, and businesses need not concern themselves about it works. There are, however, a few basic decisions they must take:

a) Purge the database of all information held without explicit permission

b) Challenge the need for the remaining data and purge the nice-to-haves

c) Adopt a policy of encrypting access at business and customer interfaces

d) Register with three freemium encryption services that seem acceptable

e) After experimenting, sign up for a premium service and be prepared to pay

Factors to Consider When Reaching a Decision
Life Hacker?suggests the following criteria although the list is a one-size-fits-all

a) Is the system fast, simple, and easy to operate

b) Can you encrypt hidden volumes within volumes

c) Can you mass-encrypt a batch of files easily

d) Do all other files remain encrypted when you open one

e) Do files automatically re-encrypt when you close them

f) How confident are you with the vendor, on a scale of 1 to 10

It may be wise to encrypt all the files on your system, and not just your customer data. We are always open to a hack by the competition after our strategic planning. If we leave the decision up to IT, then IT, being human may take the easy way out, and encrypt as little as possible.

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Strategy and Portfolio Management

 

A well planned strategy is the necessary bridge between brilliant leadership and excellent execution. Without it, your entire organisation cannot hope to respond quickly and effectively to challenges and changes within the landscape on which it operates.

Strategic planning involves identifying objectives, understanding what resources are needed to attain them, and then allocating the resources to the appropriate units to ensure they are used optimally towards the achievement of desired objectives. Among the end results which can be reflected by your team members are:

  1. Deeper understanding of the competitive environment;
  2. Snappy execution of plans;
  3. Faster, more aligned actions; and
  4. More intelligent and apt responses against strategic moves of the competition.

We understand the need to institute strategic management in such a way that your organisation can easily adapt to unforeseen developments. As such, all our solutions are formulated to make your organisation not only well-guided but also as dynamic as possible.

Strategy Formulation

Before you can proceed to map out any strategy for your company, you’ll have to study your company’s current environment. This will help you determine what courses of action should be taken to be able to navigate through such environment on your way to the end goal.

If you’re not a full time strategist, such a task can either be very daunting or deceivingly easy… the former can prevent your team from getting started, while the latter can lead your team astray.

Ideally, strategy formulation should be carried out as quickly and as efficiently as possible so you can move on to implementation before the competition can react. Our methods can enable your leaders to hit the ground running each time they set out on a strategic plan.

How?

  • We can assist in accurately applying strategic tools like SWOT and Gap analysis, then help integrate the results into an effective strategic plan.
  • We’ll train your team how to carry out effective research techniques so that the information they gather will really be what we need. This is because the tools mentioned earlier can only work effectively if the inputs were picked intelligently. Of course, if you want the entire process expedited, we can also conduct the research ourselves.
  • We’ll establish best practices for top-down, bottom-up, and collaborative strategic management processes. We’ll even show you how to organise and hold meetings where team members are constantly engaged and in-sync, so action plans can be developed and relayed fast.
  • We’ll see to it that strategies for all functional departments (such as IT management, supply-chain, HR, marketing, and legal) are in line with your business strategies, which should in, turn be aligned with your overall corporate strategy.

Strategy Evaluation

Your strategies have to be periodically assessed if you want to determine whether they are attuned to variations affecting your organisation. These changes may include new technologies, emerging competitors, new opportunities, as well as unexpected developments in the economic environment and political climate.

While no time limit is imposed for the build-up of resources vital to the attainment of a specific objective, the window of opportunity can shut on you before you can start amassing such resources. Given this possibility, it is important for your strategies to undergo evaluation processes that will determine whether you should pursue them or not.

Using only the most reliable evaluation techniques, we’ll help you establish whether:

  • Your strategies will place your company in a position that will give it competitive advantage or will erode whatever advantage the competition already has;
  • Your strategies are consistent with the landscape on which your company currently traverses;
  • They are realistic enough in relation to the resources you have on hand;
  • The associated risks have all been identified and the appropriate control measures have already been put in place;
  • The time frames for their full realisation are both realistic and acceptable.

Portfolio Management

In today’s highly competitive market, many of the more successful enterprises are driven by project-based systems.

Now, there’s always a tendency for project managers to become overenthusiastic and to come up with a number of projects that can’t be sustained by available resources. If your project-based company frequently runs out of resources, then either you just have too many projects running or too much is being allocated to a select few.

In both instances, the problem does not necessarily lie on the individual project managers themselves. Rather, what is needed is the ability to have full control over existing projects and investments.

Your leadership should be able to rank projects in terms of their impact to your organisation’s growth, positioning, and profitability. This will give you sufficient information when deciding which projects to pursue, prioritise, or shut down. These are the benefits you’ll gain from our services:

  • A vivid presentation of the big picture. Only when you can step back from all the detail and see the interplay of investments and resources will you be able to make wise decisions regarding how and where to position them.
  • The ability to distinguish between projects with the highest potentials and those that are outdated.
  • Access to expertise that will help you distribute your present IT infrastructure, human resources, financial resources, and facilities across running projects to obtain the biggest benefits for all stakeholders.

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How to Reduce Costs when Complying with SOX 404

Section 404 contains the most onerous and most costly requirements you’ll ever encounter in the Sarbanes-Oxley Act (SOX). In this article, we?ll take a closer look at the salient points of this contentious piece of legislation as it relates to IT. We?ll also explain why companies are encountering difficulties in complying with it.

Then as soon as we’ve tackled the main issues of this section and identify the pitfalls of compliance, we can then proceed with a discussion of what successful CIOs have done to eliminate those difficulties and consequently bring down their organisation’s IT compliance costs. From this post, you can glean insights that can help you plan a cost-effective way of achieving IT compliance with SOX.

SOX 404 in a nutshell

Section 404 of the Sarbanes-Oxley Act, entitled Management Assessment of Internal Controls, requires public companies covered by the Act to submit an annual report featuring an assessment of their company?s internal controls.

This ?internal control report? should state management’s responsibility in establishing/maintaining an adequate structure and a set of procedures for internal control over your company?s financial reporting processes. It should also contain an assessment of the effectiveness of those controls as of the end of your most recent fiscal year.

Because SOX also requires the public accounting firm that conducts your audit reports to attest to and report on your assessments, you can’t just make baseless claims regarding the effectiveness of your internal controls. As a matter of fact, you are mandated by both SEC and PCAOB to follow widely accepted control frameworks like COSO and COBIT. This framework will serve as a uniform guide for the internal controls you set up, the assessments you arrive at, and the attestation your external auditor reports on.

Why compliance of Section 404 is costly

Regardless which of the widely acceptable control frameworks you end up using, you will always be asked to document and test your controls. These activities can consume a considerable amount of man-hours and bring about additional expenses. Even the mere act of studying the control framework and figuring out how to align your current practices with it can be very tricky and can consume precious time; time that can be used for more productive endeavours.

Of course, there are exceptions. An organisation with highly centralised operations can experience relative ease and low costs while implementing SOX 404. But if your organisation follows a largely decentralised operation model, e.g. if you still make extensive use of spreadsheets in all your offices, then you’ll surely encounter many obstacles.

According to one survey conducted by FEI (Financial Executives International), an organisation that carried out a series of SOX-compliance-related surveys since the first year of SOX adoption, respondents with centralised operations enjoyed lower costs of compliance compared to those with decentralised operations. For example, in 2007, those with decentralised operations spent 30.1 % more for compliance than those with centralised operations.

The main reason for this disparity lies in the disorganised and complicated nature of spreadsheet systems.

Read why spreadsheets post a burden when complying with SOX and other regulations.

Unfortunately, a large number of companies still rely heavily on spreadsheets. Even those with expensive BI (Business Intelligence) systems still use spreadsheets as an ad-hoc tool for data processing and reporting.

Because compliance with Section 404 involves a significant amount of fixed costs, smaller companies tend to feel the impact more. This has been highlighted in the ?Final Report of the Advisory Committee on Smaller Public Companies? published on April 23, 2006. In that report, which can be downloaded from the official website of the US Securities and Exchange Commission, it was shown that:

  • Companies with over $5 Billion revenues spent only about 0.06% of revenues on Section 404 implementation
  • Companies with revenues between $1B – $4.9B spent about 0.16%
  • Companies with revenues between $500M – $999M spent about 0.27%
  • Companies with revenues between $100M – $499M spent about 0.53%
  • Companies with revenues less than $100M spent a whopping 2.55% on Section 404

Therefore, not only can you discern a relationship between the size of a company and the amount that the company ends up spending for SOX 404 relative to its revenues, but you can also clearly see that the unfavourable impact of Section 404 spending is considerably more pronounced in the smallest companies. Hence, the smaller the company is, the more crucial it is for that company to find ways that can bring down the costs of Section 404 implementation.

How to alleviate costs of section 404

If you recall the FEI survey mentioned earlier, it was shown that organisations with decentralised operations usually ended up spending more for SOX 404 implementation than those that had a more centralized model. Then in the ?Final Report of the Advisory Committee on Smaller Public Companies?, it was also shown that public companies with the smallest revenues suffered a similar fate.

Can we draw a line connecting those two? Does it simply mean that large spending on SOX affects two sets of companies, i.e., those that have decentralised operations and those that are small? Or can there be an even deeper implication? Might it not be possible that these two sets are actually one and the same?

From our experience, small companies are less inclined to spend on server based solutions compared to the big ones. As a result, it is within this group of small companies where you can find a proliferation of spreadsheet systems. In other words, small companies are more likely to follow a decentralised model. Spreadsheets were not designed to implement strict control features, so if you want to apply a control framework on a spreadsheet-based system, it won’t be easy.

For example, how are you going to conduct testing on every single spreadsheet cell that plays a role in financial reporting when the spreadsheets involved in the financial reporting process are distributed across different workstations in different offices in an organisation with a countrywide operation?

It’s really not a trivial problem.

Based on the FEI survey however, the big companies have already found a solution – employing a server-based system.

Typical server based systems, which of course espouse a centralised model, already come with built-in controls. If you need to modify or add more controls, then you can do so with relative ease because practically everything you need to do can be carried out in just one place.

For instance, if you need to implement high availability or perform backups, you can easily apply redundancy in a cost-effective way – e.g. through virtualisation – if you already have a server-based system. Aside from cost-savings in SOX 404 implementation, server-based systems also offer a host of other benefits. Click that link to learn more.

Not sure how to get started on a cost-effective IT compliance initiative for SOX? You might want to read our post How To Get Started With Your IT Compliance Efforts for SOX.?

Recognizing Your Carbon Footprint

Countless times we have heard of the term ?carbon footprint?. Perhaps we have seen and heard it on TV or read it in newspapers, magazines and published articles. Indeed, it has been an expression familiar to everyone as it is always associated with climate change, carbon emissions, global warming, pollution and other environmental issues. Carbon footprint is real. It exists and, in fact, continues to affect the world we live in.

Defining Carbon Footprint

Two essential words comprise the term carbon footprint. Fundamentally, ?carbon? means the carbon dioxide circulating in the atmosphere. It is also the general word used for other greenhouse gasses emitted into the air. On the other note, ?footprint? refers to impact or effect.

Think about the footprints people leave on the beach sand upon walking on the shore. That is exactly what carbon footprint is like. It’s about the impact humans leave on the earth in the form of carbon dioxide and other greenhouse gases.

Calculating Your Personal Carbon Footprint

The food we eat, products we use, vehicles we ride on and electricity we consume emit carbon dioxide. In fact, our activities, lifestyle, homes, and countries contribute to climate change. And carbon footprint is the best estimate we can get of the full impact our doings affect the earth. It quantifies the amount of our carbon emission. With this, knowing how to calculate your personal carbon footprint is important.

There are various standards in calculating one?s carbon footprint. There is the so-called ?lifestyle assessment? and the input-output analysis. Lifestyle assessment works by adding up all the feasible emission pathways while the input-output analysis involves determining the total emissions of a particular country, dividing it by the carbon-emitting sectors and estimating the overall emissions of each sector. The input-output analysis makes sure that no emission pathway is missed out.

Calculating your carbon footprint manually is an effective way for you to understand your emissions better. You just need a lot of patience to learn how each footprint is generated. Moreover, there are also several resources online that can help you calculate your carbon footprint. Online carbon calculators are abundant across the web. To make your life simpler, you can opt to try those online calculators and easily determine your carbon emissions. However, such calculators vary in scope. So make sure that the online carbon calculator, you choose, is one that?includes emissions both direct and indirect.

Avoiding Toe Prints

A toe print is a portion of a footprint. Sometimes, people are misled in their calculations because they only get a carbon toe print instead of a footprint. The idea is that, you should cover a smart scope of your carbon emissions. Not only measuring a portion, but the whole.

Say for example, running a conventional car. The carbon emitted from the car is not only the fuel combustion from the diesel or petrol.? Likewise, the carbon released as the gas was processed and transported to your nearby gasoline station is also an addition to your carbon footprint. If you do not understand this, you will end up calculating your direct emissions while neglecting the indirect ones.

Be wise in calculating your carbon footprint. And when in doubt, whether you are an individual or a business entity, you should seek help from experts who can do it right.

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