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New Preliminary Cybersecurity Framework Champions Risk Management

Cybersecurity

In February, President Obama issued an executive order instructing the Commerce Department to lead a task force of security experts and industry insiders to develop a voluntary framework to reduce cyberrisk. Last week, the National Institute of Standards and Technology officially released an initial draft of the cybersecurity framework and announced a 45-day open comment period for public input.

The full Preliminary Cybersecurity Framework can be viewed here on the NIST website. After the review period and subsequent revisions, a more complete version will be released in February.

Risk management is a primary focus of the new framework, from the language used to analyze potential exposure to express endorsements in the policy itself. According to a press release, “The Preliminary Framework outlines a set of steps that can be customized to various sectors and adapted by both large and small organizations while providing a consistent approach to cybersecurity. It offers a common language and mechanism for organizations to determine and describe their current cybersecurity posture, as well as their target state for cybersecurity. The framework will help them to identify and prioritize opportunities for improvement within the context of risk management and to assess progress toward their goals.”

Under Secretary of Commerce for Standards and Technology and NIST Director Patrick Gallagher, who was tasked with overseeing development of the framework, emphasized the risk management as a critical component of strengthening national infrastructure in line with the president’s executive order. “We want to turn today’s best practices into common practices, and better equip organizations to understand that good cybersecurity risk management is good business,” Gallagher said.

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“The framework will be a living document that allows for continuous improvement as technologies and threats evolve. Industry now has the opportunity to create a more secure world by taking ownership of the framework and including cyber risks in overall risk management strategies.

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The framework outlines key functions that should organize cybersecurity activities: Identify, Protect, Detect, Respond and Recover. These functions are designed to aid the risk manager in evaluating, communicating and fortifying against cyberrisks. The document even suggests itself as a potential opportunity for risk managers to seize the opportunity to get involved in proactive cyberrisk strategy. It reads, “The functions also align with existing methodologies for incident management, and can be used to help show the impact of investments in cybersecurity.”

Authors also added the following visual to highlight the critical role of risk management at every level of suggested implementation:

Risk Management in Cybersecurity Framework

In a blog post, the White House encouraged businesses to evaluate the initial framework and their current cyberrisk position, and to consider their cyber risk appetite in the form of a projected target state for cybersecurity.

California Town Must Improve Risk Management or Lose Insurance Coverage

Insured City

One southern California town has officially been warned that their insurance will be cut off if city officials do not adopt risk management policies.

Irwindale’s insurer, the California Joint Powers Insurance Authority, issued a performance improvement plan on August 28 and said city liability and workers compensation insurance will be terminated if it does not adopt the measures. Allegations of corruption have cast a pall over the police department and local government, and the city has been forced into almost $2 million in settlement payouts over the past five years, according to the Pasadena Star News.

“They’re on notice that they need to improve their risk management practices within the city’s operations, specifically in the police department, to maintain their insurance coverage with our agency,” JPIA’s risk management program manager Bob May told the paper.

Irwindale has been mired in controversy over the past few years.

Of 24 police officers, three are on paid administrative leave and the department is conducting 14 internal affairs investigations. A local woman recently filed a $20 million lawsuit against the city, alleging that an officer sexually assaulted her during a traffic stop. Police Lt. Mario Camacho has been accused of retaliation by an officer under his command and of sexual harassment by a female cadet. Four city officials are charged with of misappropriation of public funds, embezzlement and conflict of interest resulting from a series of lavish trips to New York City that utilized over $200,000 of public funds.

Under the guidelines from JPIA, the city must hire a permanent human resources manager and council members must complete training on council relations and cooperation. If they do not complete the improvement plan, they risk losing coverage and will have to go to the open market or self-insure.

In September 2011, the JPIA issued a similar warning to the city of La Puente, Calif. As part of the “healthy members program” criteria, which outlines what members should do to stay within risk management guidelines, Insurance Journal reported that the town’s performance improvement plan required that La Puente “hire a permanent city manager, give notice of any harassment and retaliation complaints, and send council members to etiquette classes to learn how to get along.” The city recently completed the program and remains insured.

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So far, the only town to be officially cut off by the California Joint Powers Insurance Authority is Maywood. The city was dropped in 2010 and the lack of insurance forced the local government to lay off almost all of its employees and disband the police department.

TRIA: Not Just a Big City Issue

The following is an excerpt from the RIMS executive report “Terrorism Risk Insurance Act: The Commercial Consumer’s Perspective.” The report is available for download here.

Opponents and skeptics of TRIA express concern that the program is tailored to benefit only major metropolitan cities such as New York City, Chicago, San Francisco, etc.; however, major cities are not the only ar­eas facing the very real threat of terrorism, as the 1995 Oklahoma City bombing made evident. Additionally, while the recent attacks in Boston occurred in a major city, they did not occur in a major financial center or area that would be seen as exclusive to such a city. They occurred during a marathon race and city celebration; similar events take place throughout the country on almost a daily basis.

On January 31, 2012, the National Consortium for the Study of Ter­rorism and Responses to Terrorism (START) released its “Hot Spots of Terrorism and Other Crimes in the United States, 1970 to 2008” report to the Department of Homeland Security. This report found that more than 2,600 terrorist events, defined as “the threatened or actual use of il­legal force and violence by a non-state actor to attain political, economic, religious, or social goal through fear, coercion, or intimidation,” occurred in the United States during those years.

On April 29, 2010, the Heritage Foundation published a list of thirty known terrorist plots that had been foiled in the United States following 9/11. These plot targets included a shopping mall in Columbus, Ohio; gas pipelines in Wyoming; and a federal building in Springfield, Illinois. This again shows that major cities are not the only targets of terrorists.

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On September 8, 2011, The Daily Beast published 10 additional foiled plots that had occurred after April, 2010, one of which was a plot to target Christmas tree lighting in Portland, Oregon.19

These lists and studies are highlighted because they show that major cit­ies are not the only terrorist targets in the United States. Any venue that brings together a large group of people is a potential target for terrorism whether it be a sports venue, a hospital, a school or university, a large commercial building, a utility, place of worship or Christmas tree light­ing.

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Businesses and organizations, whether in New York or Columbus, Ohio, need adequate terrorism coverage and the market stability TRIA provides to manage that risk.

On Thin Ice

Truck in Snow

You may have seen “Ice Road Truckers” on the History Channel. If not, it might be worth your time to watch an episode. I’m not a regular viewer, but for me the show is an occasional guilty pleasure. And now it’s in its seventh season, so I’m not the only one who’s watching.

It’s also a look at basic risk management in some of the toughest conditions on the planet—semis traveling on seasonal routes in remote areas of Alaska and Canada. This season follows drivers for the Polar Bear trucking company located in Manitoba, Canada. Seven truckers, often making their trips alone, drive fully loaded semis over frozen lakes, battling the elements to deliver building supplies, heavy equipment, gravel—you name it. Conditions are desolate and often 55 degrees below zero.

To take it even further, Polar Bear and a rival company—owned by a former, and bitter, Polar Bear employee—are competing for delivery assignments. Not completing an assignment means no pay for the drivers, more work for the competition and also that a village somewhere doesn’t get a delivery of badly needed supplies.

I know from personal experience that when it gets down to the 20s and teens here in New York, all kinds of things can happen to heavy equipment. With my commuter train, for instance, engines need to be kept running all night to make sure the trains are operational on cold, icy mornings; and signaling equipment can go on the blink, delaying trains and throwing off schedules. I can’t imagine what it must be like at 55 degrees below zero!

The Polar Bear trucking company can only do so much for drivers who must maneuver icy roads over a frozen lake. The drivers themselves put their lives on the line to make their deliveries. As more and more trucks traverse the roads, the ice highways become pitted. Friction from trucks and temperature changes mean the ice also gets thinner—producing hair-raising episodes, where the ice is moving and trucks get stuck in giant pools of melt. Will they get the truck out? Or will it go right through the ice? Anyway, you get the idea.

Cast member Joey “The King of Obsolete” Barnes has a large collection of vintage CATs and trucks from the 1930s to 1970s. Many are unique pieces of equipment that he has reassembled from miscellaneous parts. In one episode, Joey uses one of his reconstructed trucks to help another driver pull a semi, hauling a flatbed of heavy equipment, out of a deep patch of melting ice. In the same episode, driver Art Burke discovers his truck is having fuel pump and/or fuel line problems. He never really figures out which, but to start the truck and keep it running, he has to manually feed fuel to the engine. Sure enough, the truck again doesn’t start—in the middle of a vast ice landscape—but Art somehow manages to get fuel to the engine and keep it going.

Since it’s impossible for me to watch a show like this without thinking about the risk management implications, I noted two distinct risk management styles. Joey keeps a lot of heavy equipment and spare parts and is ready for any emergency. To stay on schedule, Art heads out over the treacherous ice, knowing he is having engine trouble, but trusting his skills and experience to get him through. Not only do these drivers have to foresee and manage dangerous risks, but the camera and production crew are often traveling right alongside them. And so their safety and liability is an issue as well.

I’m sure that risk managers can relate to these disparate styles. Oddly, they both work, even in these extreme conditions, because both Joey and Art both know their jobs, the conditions and equipment so well. It’s risk management in its most raw form and there are lessons to be gleaned. But don’t take my word for it, see for yourself and be prepared for a nail-biter.