utilizing a quantitative risk approach glenn r. wilson to drive strategic it compliance va scan...
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Utilizing a Quantitative
Risk Approach
Glenn R. Wi lson
TO DRIVE STRATEGIC IT COMPLIANCE
VA SCAN OCTOBER 3, 2013
Classifying IT Risk
Data risk
• Breach, loss, corruption, unavailability
Operational risk
• Performance degradation, denial of service, outages
Non-compliance risk
Common IT Risks Unauthorized data access and changes
Data loss, corruption, unavailability
Denial of service attacks, malware
Physical device failure, theft or destruction
Inadequate system capacity, network architecture
Poor application coding, failed implementations
Inadequate change management controls
Regulatory compliance violations
Common IT Risk Impacts Reduced customer satisfaction permanent customer loss
Business process interruption lost productivity / revenues
Penalties, fines, sanctions, reputational damage, personal liability
Fraud, identity theft, loss of financial assets
Failure to achieve core business objectives
What are the common themes? Mission risk Monetary loss Legal liability
Why Comply?
Compliance reduces exposure to penalties and litigation
Compliance provides a baseline for risk management
Compliance is integral to proper corporate governance
Compliance requires a business to adopt best practices
Compliance promotes organizational effectiveness
What does it mean to be “in compliance”?
How do you know when you have achieved it?
How do you sustain a state of compliance?
What do we have to comply with?FERPA, HIPAA, HITECH, GLBA, SOX, PCI DSS, FISMA, ECPA, COPPA, EFTA, Bank Secrecy Act, USA Patriot Act, Basel II Accord …
The short answer: “industry standards, federal, state and local laws”
How many organizations put this statement into their policies and aren’t exactly sure what they are obligating themselves to?
In Compliance
Approaching Compliance “Compliance should be the floor, not the ceiling, of your efforts” “It’s the
fundamental layer for every security program.” (Rafael Diaz, CISO of the State of Illinois, quoted by Security Magazine from a Nov 2012 Chicago SC Congress event of SC Magazine)
Other speakers warned against using compliance as the be-all-end-all of an information security program.
“Compliance is a great hammer – if you have a nail”. “Don’t use a hammer if you have a screw”. “Using a FAIR report (Factor Analysis of Information Risk), which can translate the risk into real dollar amounts, making it easier to sell to the C-suite”. (Ward Spangenberg, CISO of Pearl.com, formerly of online gaming giant
Zynga, quoted by Security Magazine from a Nov 2012 Chicago SC Congress event of SC Magazine)
Source: http://www.securitymagazine.com/blogs/14-security-blog/post/83788-cisos-look-past-compliance-for-new-solutions-to-old-problems
Successfully Achieving Compliance
Know your organization’s specific compliance exposure
Know the processes by which its objectives are achieved
Gain executive level support
Obtain managerial and staff commitment
Where do you start?
The invariable starting point is…
Business Impact Assessment
Compliance is not equal to Risk Management (although achieving compliance does mitigate risk)
Can achieving compliance create risk? Yes. What kinds? Operational, Financial, Legal
Failure to achieve compliance is itself a risk category
Realities of Compliance
Drivers of Compliance What is the primary driver of organizational compliance?
Non-compliance risk – Penalties, sanctions, liabilities
Other risk drivers: Financial, Reputational, Operational & Individual risk
Who primarily drives organizational compliance?
Board? Executive Management? Compliance Officers? Internal Auditors? Middle Management?
Effective programs are driven by a culture of compliance and align withthe organization’s strategic planning
Degrees of Compliance To what extent should an organization ‘be in compliance’
with a given regulatory requirement or industry standard?
100%? 80%? 50%? 0%?
How fast should an organization achieve compliance?
How long should an organization be in compliance?
How far? How fast? How long?
Ris
k
Compliance
How does risk vary with compliance?
Risk Versus Compliance
Greater compliance can decrease risk at many levels
Greater compliance may increase risk at many levels
Risk Mitigation Versus Cost
What costs may be associated with risk mitigation?
Financial resources Human resources Competitive advantage loss
Ris
k
Cost
Diminishing Return
“Selling” Compliance
The need for compliance sells itself
The degree of compliance needs to be driven to
levels appropriate for the organization.
Compliance costs can be expensive at many levels
Risks are well known but often not well understood
Do not overstate the merits or consequences
Do determine and promote impact awareness
Quantifying Risk To Drive Compliance
Are numbers persuasive? Join now for only $19.95 per month 4 out of 5 dentists recommend sugarless gum More doctors smoke Camels than any other cigarette (133,597 surveyed) Gartner Group says that 43 percent of companies were immediately put
out of business by a “major loss” of computer records, and another 51 percent permanently closed their doors within two years — leaving a mere six percent “survival” rate; (homelandsecuritynewswire.com Feb 19, 2010)
Qualitative
• Faster, not data intensive• More cost-effective or is it? It does not provide numerical impact making cost benefit analysis difficult• Analysis based on likelihood and impact • Results stated in terms of low, med, high or similar numerical scale• Good for prioritizing risk and identifying high risks that need immediate mitigation
Quantitative • Data intensive simulation and decision analysis• Results stated in terms of probabilities and costs• Primary advantage is the cost benefit analysis for efficient use of resources• Results that are not clear will be qualitatively determined
Not every risk requires or is suited to quantitative analysis Define a criteria for meaningful quantitative analysis of your organization’s risks Identify technique(s) to be utilized and develop methods for consistent application Define the expected outputs of the chosen quantitative analysis methods
Qualitative vs Quantitative Analysis
Like
lihoo
d
ImpactLow Med High
Low
Med
Hig
h
Risk / Impact Models
Which Likelihood - Impact pairs should be analyzed?
Risk / Impact Assessments Inherent risk = high (9/10), Residual risk = medium (6/10) Risk = (Probability) x (Impact) More scientific ‘closed form’ methods exist using Convolution and
Fourier Transforms which require large amounts of data to calculate frequency and severity distributions to obtain an aggregate losses (expected, unexpected, confidence levels)
‘Open form’ solutions such as Monte Carlo simulation and Latin Hypercube sampling that evaluate scenarios for frequency and severity
of losses by generating random numbers using each type of distribution (identified using actual loss data).
Risk / Impact Distribution Calculations
Events and
Losses
Risk Loss Matrix
Frequency &
Loss ImpactDistribution
s
Value
At Risk
Calculation
Periodic
Aggregate Loss
Distribution
PROB IMPACT RISK20% $5,000.00 $1,000.00 3% $25,000.00 $750.00
10% $12,000.00 $1,200.00 7% $9,000.00 $630.00
35% $75,000.00 $26,250.00 Pn% $In $Rn
𝑓 (𝑥 )=𝑎0+∑𝑛=1
∞
(𝑎𝑛cos𝑛𝜋 𝑥𝐿
+𝑏𝑛sin𝑛𝜋 𝑥𝐿 )
VaR = VaR12 + VaR22 + 2 * C2* VaR1 * VaR2
PeriodicAggregate Loss
EF = (((TP×(C/E))×(VF×AP))/100)
Risk / Impact Calculation Models
EF: Exposure factor (% loss of asset)TP: Threat probabilityC: Criticality factorE: Effort requited to exploit the threat
Risk Exposure = ALE = SLE * AROALE: Annualized Loss ExpectancySLE: Single Loss ExpectancyARO: Annual Rate of Occurrence
Risk Score = log(10Risk Score1+10Risk Score2)Likelihood Score =log(10Likelihood Score1 + 10Likelihood Score2)Consequence Score = Risk Score – Likelihood Score
Σan: Sum of the asset riskΣram: Risk sum for each combination of criterion,
vulnerability and threat per assetCm: Criterion value for the current combinationVm: Vulnerability risk level for current combinationOm: Threat occurrence for current combination
Adrian Munteanu, Alexandru Ioan Cuza University, Iasi, Romania Information Security Risk Assessment: The Qualitative Versus Quantitative DilemmaManaging Information in the Digital Economy: Issues & Solutions 228
Abbas Asosheh, Bijan Dehmoubed, Amir Khani Tarbiat Modares University Tehran, IranA New Quantitative Approach for Information Security Risk Assessment2009 IEEE
Xun Guo Lin & Richard JarrettDivision of Mathematical and Information SciencesA Practical Approach to Quantitative Risk AssessmentCanberra & MelbourneRisk Conference, Wellington, 2009
Return On Security Investment (ROSI) – A Practical Quantitative ModelWes Sonnenreich, Jason Albanese and Bruce StoutSageSecure, LLC 116 W. 23rd St., 5th Floor, NY, NY 10011 USAJournal of Research and Practice in Information Technology, Vol. 38, No. 1, February 2006
Risk = Σan (Σram (Cm*(Vm*Om)))
Practical ConsiderationsWhat are the primary objectives of quantifying risk to drive compliance? To quantify in whole or in part losses, expenses and liability
(Some quantification is better than none) To use the methods and results to inform executive decision makers
What are the most useful numbers to consider? Loss Expectancies (single and recurring) Occurrence (actual or estimated) Asset Value (tangible and intangible) Recovery Costs Long Term Costs
Establishing Impact Scales Risk appetite is organization specific
with dependencies on:
Industry Business Mission Capitalization and Cash Flow Board and Executive Management
Define risk / loss levels in terms of:
Monetary value Liabilities / penalties Mission specific factors
IMPACT LOSS $ SCOREInsignificant $10,000 1
Minor $100,000 2Moderate $500,000 3
Severe $1,000,000 4Disastrous $10,000,000 5
IMPACT LOSS (Units) SCOREInsignificant 500 1
Minor 1,000 2Moderate 2,500 3
Severe 5,000 4Disastrous 10,000 5
Is this a valid quantitative analysis?
Annual threat probability 75% Incident cost $1,000,000 Weighted cost $750,000Annual counter cost $600,000Cost benefit $150,000
Case Specific Factors
What are the case specific factors?
Risk type and nature Basis for numeric values Cost types considered
Compliance Checklists Strengths Identifying gaps and deficiencies (a very necessary activity)
Weaknesses× Prioritizing remediation of deficiencies× Tracking corrective actions× Cost management× Resource deployment× May not result in value to the organization× Does not ensure adequate security or risk mitigation× May lead to an overburden of overlapping / unnecessary controls
Making The Case
How related or specific is the compliance type to your business?
Exactly what are the associated compliance risks?
What are the expected costs and impacts to comply?
How much return will be realized in reduction of risk or increased effectiveness?
Numbers are most persuasive when they are validly derived, understandable and relevant to a given situation. They can be mixed with qualitative factors.
The new XYZ federal ecommerce regulatory act will go into effect in 3 months. Even though your organization derives significant revenue from ecommerce activities, the new act is not on the radar of executive management even though you first brought the need to comply to their attention 18 months ago and again 3 months ago. You are not directly responsible for ecommerce revenues but are responsible for operating the organization’s ecommerce system within ‘industry standards, applicable federal, state and local laws. Major infrastructure reconfiguration and architectural changes are needed to comply. How can you re-approach the subject with executive management to gain the necessary support?
! According to the last quarter financials, $6k per hour or 46% of revenues come from ecommerce activities.
! There is a new threat vector that we have never faced before and there is a high probability that within months our system will be exploited if it is not hardened to the new standard. The IDS upgrade will cost $200k, and to comply within 3 months it will require 300 staff hours and $240k off peak ecommerce downtime.
! If we do not act and an incident occurs, it will likely be viewed as “willful negligence” and we would incur the maximum fine of $10k a day plus average clean up costs of $80 per affected record of which we have 2 million. Our ecommerce operation could be disrupted or suspended by an external investigation for 7-10 days.
! Every week that this project is delayed will cost an additional $20k in peak downtime and $10k in shift differential compensation.
Example – XYZ Act Compliance
Case 1 – PCI DSS Essential Elements of Compliance: Secure collection, handling, storage and transmission of card-
holder data, quarterly system scan by a PCI SSC Approved Scanning Vendor (ASV), annual SAQ
Non-Compliance Risk: The payment brands may, at their discretion, fine an acquiring bank $5,000 to $100,000 per month for PCI compliance violations which will pass to the merchant. Bank will also most likely either terminate your relationship or increase transaction fees. PCI is not a law.
Compliance Risk: Potential adverse effects on business processes and IT workload
Added Value: Mitigate risk of cardholder data breach, improved IT vendor contractual relations
Quantifying Risk Factors
Payment card revenue (gross and relative amounts) Payment card transactions (gross and relative amounts) Current transaction and processing fees Cost to achieve compliance Recurring costs
Case 2 – Sarbanes Oxley (SOX) Essential Elements of Compliance: Publicly traded companies must maintain all controls needed
for accurate financial reporting. Financial reports require an internal controls report.
Non-Compliance Risk: Exchange de-listing, loss of investor confidence, loss of liability insurance. Incorrect submissions carry up to a $1 million fine and 10 years in imprisonment. Willful incorrect violations allow for up to $5 million fine and 20 years imprisonment.
Compliance Risk: Drain on available resources, business process changes, IT requirements are not well defined and attempts to comply may not pass an external audit.
Added Value: More reliable financial and asset controls, increased market capitalization
Quantifying Risk Factors
Stock ownership Current market capitalization Industry sector volatility
Case 3 – E911 Essential Elements of Compliance (Virginia): All PBX/MLTS installed after July 1, 2009 must
provide ANI and ALI to the local PSAP for 911 calls unless alternate methods of notification have been approved. (Article 8. Emergency Calls on Multiline Telephone Systems.§ 56-484.23)
Non-Compliance Risk: (Varies by state) Fines, OSHA sanctions, worker’s compensation claims caused by safety violation, common law liability, reputational damage
Compliance Risk: Significant cost to upgrade or replace existing phone system, business interruption, transient risk of media relation issues
Added Value: Employee trust, increased productivity, public goodwill, decreased liability
Quantifying Risk Factors
Age of the existing phone system Cost to upgrade versus replace Number of facilities, geographic distribution and occupancy habits Case law
Case 4 – Gramm Leach Bliley (GLBA) Essential Elements of Compliance: Protect consumers’ personal financial information held by financial
institutions. There are three principal parts to the privacy requirements: the Financial Privacy Rule, the Safeguards Rule and pretexting provisions. The safeguard rule requires a plan that “contains administrative, technical, and physical safeguards” to “insure the security and confidentiality of customer information; protect against any anticipated threats or hazards to the security or integrity of such information; and protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer.
Risk of Non-Compliance Risk: Fines up to $100,000 for each violation, Personal liability to officers and directors of up to $10,000 for each violation, Criminal penalties include imprisonment for up to 5 years. More serious willful violations call for the fine will be doubled and imprisonment for up to 10 years. (Monetary losses (immediate and future), reputational damage, personal liability)
Risk of Compliance: Business process and operational change management
Added Value: Customer relations, decreased legal liability
Quantifying Risk Factors
Implementation / recurrent costs versus volume / revenue associated with qualifying financial activities
Comments? Questions?
Glenn R. Wilson, IT Audit ManagerOld Dominion University, Norfolk, VA
gwilson@odu.edu
757-683-3202
Thank you!
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