Category Archives: Technology Risk

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RIMS Risk Forum India 2021: Building Resilience As COVID, Cyberrisk Top Business Risks

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An increasingly key theme year over year, resilience is at the root of the latest Excellence in Risk Management India report from Marsh and RIMS—and the RIMS Risk Forum India 2021 virtual event, where the report was officially released today. In the second year of the COVID-19 pandemic, risk professionals in India reported acute short- and long-term concerns about the interconnected risks of COVID-19 cases, global economic recession, and surging cyberrisks amid shifts in work arrangements.

In addition to the death of more than 5 million people in India, the pandemic has taken a considerable economic toll on the region. “According to the Organization for Economic Co-operation and Development (OECD), India’s economy contracted by close to 8% in 2020, while the world’s economy contracted by 3.5%,” the report noted. “Despite the OECD’s projections for economic expansion—both in India and globally—in 2021 and 2022, the potential for a prolonged global recession remains a concern for organizations in India.

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Previously one of the top risks for India-based risk professionals before COVID-19, cyberrisk has also increased significantly with the pandemic and the shift to remote work. “The shift to a remote workforce necessitated by sweeping lockdowns to stem the spread of the pandemic is widely seen as having increased cyberrisk,” Marsh and RIMS noted. “The Indian Computer Emergency Response Team (CERT-In) data indicated that cyberattacks in India rose by 300% in 2020, according to news reports. And cyber risk remained elevated in 2021, with more than 600,000 cybersecurity incidents reported in the first six months of the year alone, according to CERT.”

The continuing pandemic, resulting fallout, and ever-growing cyberrisk have presented the biggest risks for organizations in India in 2021, and the survey indicates that local risk professionals expect these to dominate the agenda for businesses in the year to come.

Despite the considerable concern, few respondents said their company is fully prepared for the continued fallout from COVID-19 or future pandemics. Asked to rate their organization’s preparedness from 1 to 5 (not prepared to fully prepared, respectively), the majority of India-based risk professionals ranked their organization a 3, and only 10% said they are fully prepared. While cyberrisk has been a top threat for longer, preparation is not much better for the threat—only a quarter of Indian companies said they are fully prepared for a cyberattack. This is particularly concerning as “some extent of remote work is expected to remain, leading to concerns of increased cyberattacks due to unsecured home networks,” Marsh said in a press release.

According to the report, this underscores the imperative to develop robust risk management strategies for both current and emerging risks and to focus on building resilience. Marsh identified four “common behaviors among companies that are on the path to becoming more resilient”: anticipating risk, connecting risk management to business strategy, avoiding gaps in the perception of preparedness, and measuring relevant data. Marsh and RIMS explained these further, defining key pillars that have set successful businesses apart, and potentially also offering considerations for other organizations to develop more mature risk management programs:

  • Anticipation: Resilient companies expect the unexpected. They have crisis management plans in place, but they also dig deeper, look farther ahead. Consider that during the pandemic even organizations with thorough business continuity plans struggled. Why? Many of them didn’t fully anticipate the widespread, long-lasting damage a pandemic could create.
  • Integration: Another key behavior among resilient organizations is to fully integrate risk management with operations and strategy. Doing so increases the ability to develop effective responses. Most organizations do not connect resilience planning with their long-term investment strategy. Those that do make the connection are on the path to better mitigating financial exposure, reputational damage, business interruption, and other losses.
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  • Preparedness: On the journey to resilience, it’s important to develop an accurate perception of an organization’s preparedness. A false sense of security can halt an organization in its tracks. Companies often overestimate how quickly and effectively they will be able to respond to and recover from a given risk.
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  • Measurement: There is no shortage of data and analytics in today’s business environment. But consistently applying metrics can be a stumbling block. Many companies fail to conduct a high rate of modeling and forecasting even on risks they see as important. And among the companies that do so, most only model in select areas.

Marsh and RIMS recommended that organizations in India focus on resilience heading into 2022 and beyond. “Resilience means being able to absorb the impact from a range of emerging risks and depends in large part on having robust risk management strategies in place,” the report explained. “This includes anticipating risk, connecting risk management to business strategy, ensuring your organization’s perception of preparedness doesn’t lead to a false sense of security, and measuring relevant data.”

Respondents largely indicated that their organization planned to increase investment in risk management, with 55% saying they expect increased resources, 27% expecting investment to stay the same, and only 4% expecting a decrease. This could be a critical differentiator in navigating COVID-19 recovery and other emerging risks in 2022. Indeed, 42% cited budget at the most critical barrier to understanding the impact of emerging risks on risk management.

Among the takeaways from the report, Marsh and RIMS urged organizations to invest in preparedness. “Look beyond pandemic as you develop a risk management strategy that is prepared to respond to any number of emerging risks,” the report said. “For example, shifting work patterns have intensified an already escalating cyber risk landscape that calls for a range of responses, from scenario planning to financial quantification.”

In addition to a panel on the Excellence in Risk Management India report, the RIMS Risk Forum India 2021 virtual event includes a number of sessions that address resilience challenges and opportunities for risk professionals in India. The program includes keynote addresses by Ajay Srinivasan, chief executive officer at Aditya Birla Capital Limited (ABCL), and Dr. Soumya Kanti Ghosh, group chief economic advisor at the State Bank of India, as well as education sessions like “Cyber Risk Management: A Priority for a Resilient Economy,” “Climate Risk and Your Path to Resilience,” “What COVID-19 Has Taught Us About ESG Risks and Why Risk Management Needs to Change,” and “Breaking the Chain: How Understanding Business Interruption Exposures Can Mean Supply Chain Resilience.”

The RIMS Risk Forum India 2021 virtual event continues tomorrow, December 4, and sessions will also be available for on-demand viewing for the next 60 days. Registration can be found here: https://www.rims.org/events/rf/india-forum-2021

New York City’s New Biometric Information Law Governs Collection and Use of Consumer Health Data

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For risk professionals, the COVID-19 pandemic has increased the importance of ensuring customer and employee safety measures are incorporated into operations, processes and future strategies. As many businesses reopen from pandemic shutdowns or return from remote work arrangements, some enterprises are now exploring both the effectiveness and the risks associated with conducting health screenings that collect biometric information and other personal health data.

This month, New York City released the Biometric Information Law, a new measure that goes into effect on July 9 and imposes disclosure requirements on businesses that collect consumer biometric information.

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It also sets parameters on what they can do with that information, most importantly, prohibiting the exchange of biometric information for anything of value.

As detailed in recent client notice from the law firm Reed Smith, highlights from the law include:

  • The measure requires a business that “collects, retains, converts, stores or shares biometric identifier information of customers” to place a “clear and conspicuous sign” near all consumer entrances that, in plain language, discloses the collection, retention or sharing of biometric information.
  • It stipulates that it is unlawful to “sell, lease, trade, share in exchange for anything of value or otherwise profit from the transaction of biometric identifier information.”
  • It establishes “an ‘aggrieved’ consumer’s private right of action,” meaning that “[a]ny person who is aggrieved by a violation by this chapter is entitled to commence an action to enforce its protections.”

There are key exclusions, however, as “governmental agencies, employers, or agents” are expressly excluded from compliance with any provision.

New York is not the only state to enact a law attempting to govern how organizations can use biometric information. Arkansas, California, Illinois, Texas and Washington have also set guidelines for businesses.

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Indeed, the recent Risk Management Magazine article “Preparing for Biometric Litigation from COVID-19” addresses the imminent and critical questions businesses must answer when collecting and handling such data.

Sensitivities surrounding the confidentiality of biometric and other health information are not new in certain industries, such as healthcare. Further, even before COVID-19, risk professionals were already grappling with the risks associated with new biometric technologies and the data collected, especially with regard to facial recognition, wearables and even the rise in popularity of telehealth.

Now, with every organization on high alert about infectious diseases and how quickly they can interrupt business, health and safety have become top priorities for every risk professional in every sector.

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As risk professionals look to new technology for help with these concerns, monitoring the emerging regulation and security risks around health and biometric technology will become increasingly critical in balancing benefit and risk to their organizations.
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Data security will continue to remain a significant threat, but New York’s Biometric Information Law should serve as a reminder that what the organization does with that data can also have a lasting impact on the enterprise’s reputation and consumer trust.

For more information to help risk professionals manage new health technology and data, check out these articles from Risk Management Magazine:

How to Conduct Better Third-Party Risk Assessments

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Today’s enterprises operate in a complex digital ecosystem that connects customers, vendors and partners and through which data is shared and transactions are processed. Because much of this is done through outsourcing of systems and services to third parties, many enterprises have dramatically increased the scale and complexity of their risk surface.

While companies are reliant on third and fourth parties to do business and often benefit from using such external services, these relationships also pose a risk to the enterprise’s sensitive data. Enterprises rely on these third parties to fulfill essential services and often expect them to secure the enterprise’s data in the process. Unfortunately, this does not always happen. 

According to a survey by RiskRecon, a Mastercard company, and the Cyentia Institute, third-party risk practitioners said that 31% of their vendors could cause a critical impact to their organization if breached, while 25% claimed that half of their entire network could trigger severe impacts.

Recent catastrophic cybersecurity incidents like the SolarWinds case demonstrate that cyberrisk can come from supply chain layers beyond the company’s immediate third parties. These multi-party cyber breaches create a ripple effect and threaten to have a far greater impact than those affecting single companies.

Business leaders, third-party risk practitioners, and cybersecurity professionals are well aware of the potential impacts of third-party risk, yet many struggle to keep up. In fact, research shows that only 14% of third-party risk professionals are confident that vendors are capable of meeting third-party security requirements. Managing vendor risk can seem like an impossible problem, but the key is having greater visibility into your digital supply chain and monitoring the external parties that pose the greatest risks to your firm.

Traditional Risk Assessments vs. Continuous Third-Party Monitoring

Traditional risk assessment processes cannot fully address today’s dynamic cyberrisk landscape, as they can be difficult to validate, take a long time for both the vendor and the organization to process, and are pinned to a single point in time. Without a valid, current assessment, security teams are forced to prioritize vulnerabilities blindly, which ultimately compromises risk mitigation, and limits their value as an accurate barometer of third-party risk.

It can be easy and tempting to complete a third-party risk assessment in one month and then forget about it for another year, but third-party risk management is not a once-a-year project—it requires an ongoing program with ongoing monitoring. This may appear to be overwhelming, confusing and time-consuming. While there will always be more vendors to find, a well-structured and continuous third-party monitoring program can help your security team to prioritize.

It is also important to take action on the vulnerabilities these critical vendors produce and gain visibility into how to remediate these issues. Continuous third-party monitoring can not only help you identify and remediate risk, but can also serve as a helpful tool in communicating your organization’s security hygiene to board members or executive leadership.

Below are practical steps that cybersecurity teams and risk professionals can take to better manage their organization’s third-party cyberrisk:

  1. Ask the right questions: Build and collect security questionnaires that ask important questions about how a vendor is handling the company’s data. To better manage risk, security teams need insight into the technologies that are being used internally and externally by third parties, fourth parties, and beyond.
  2. Assign a risk rating: Based on the answers to the questionnaires, assign the vendor a risk rating. By having a clear understanding of a vendor’s security posture, the security team can then rank vulnerabilities in order of priority, so they know which issues to tackle first.
  3. Take action: Create custom-fitted risk action plans so you can immediately start engaging with your vendors on remediation. If a vendor’s cyber risk degrades or an element falls out of policy, you will be notified instantly. By having accurate visibility into supply chain risk, security teams can then use that information to make decisions about whom to share data with moving forward.

By utilizing these best practices, organizations can better manage their third-party risk, further reduce overall risk, increase cyber visibility, and improve the quality of vendor and supplier networks.

Successfully Navigating Identity Management Strategies

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For many CISOs, overseeing identity management represents a significant challenge and a substantial component of their broader security ecosystem. In a nod to its importance, the National Cyber Security Alliance even recently kicked off the first ever Identity Management Day. It is also central to a number of critical issues that urgently need a CISO’s attention, namely data access governance, data loss prevention and cloud application security.

When navigating the vital issue of identity, the top considerations include:

Data Access Governance

Data security spans two areas of organizational risk: unauthorized data use and privacy issues associated with authorized data processes. When evaluating an identity management strategy, it is imperative to start at a high level, which includes data access governance to limit access and meaningfully reduce the risk of loss or theft.

An effective end-to-end approach provides visibility and controls to identify risk and protect sensitive information across cloud and on-premise networks while also keeping digital communications compliant. This approach involves establishing a data governance program, which includes data inventory, data mapping, needs-based permissions and, ultimately, data retention and erasure. Critical components in overall data access considerations include understanding what data is being collected, where and how it is stored, who is accessing that data, protection mechanisms in transit and at rest, and how long the data is being retained.

Proper data access governance is essential to ensuring successful digital transformation as remote/hybrid work continues, both email and cloud apps remain core communication channels, and social media continues to drive business.

Data Loss Prevention

Protecting information both at rest and in motion are important elements of another identity management issue: data loss prevention (DLP). Data is lost due to negligent, compromised, or malicious users and it is important to approach DLP in manageable terms. For example, full data classification and discovery is idealistic for many. Complete reliance on both fronts is hard, if not impossible.

Traditional data loss prevention approaches, such as full data discovery, have arduous requirements and usually involve mandatory outsourcing for development and monitoring. In fact, many CISOs only want to tackle the DLP challenge once in their career.

Fortunately, modern strategies are available to manage DLP efforts that focus on protecting the most sensitive information in terms of content type, context, and user behavior. These include systems that issue accurate alerts, reduce investigation time, and focus security teams on risky user behavior rather than solely on classification violations.

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An approach that places an emphasis on user behavior, in addition to classification, is pivotal to identifying compromised accounts and phished users. Data does not lose itself, but proper DLP can stop bad actors and insider risks from siphoning critical assets.

Cloud Application Security

In a Cloud Security Alliance study of 200 IT professionals, 83% indicated that cloud security is a top area for improvement. This is not surprising in our current climate as CISOs are constantly struggling to ensure they have visibility and control over how users access and share sensitive data in the cloud. It only takes one compromised account to expose an organization to significant risk.

For example, according to a 2020 Proofpoint analysis of over 20 million cloud account users and thousands of cloud tenants across North America and Europe, attackers are increasingly abusing legitimate OAuth authorization apps to exfiltrate data and maintain persistence on specific cloud resources after compromising an account.

Over the last year, threat actors targeted 95% of organizations with cloud account compromise attempts, and more than half of organizations were successfully compromised at least once. Discovering cloud apps and reducing shadow-based IT—including third-party OAuth authorization apps—helps limit accessing and sharing data to only authorized users.

Every cloud app security broker (CASB) strategy needs to address how individuals handle data and the threats targeting them. It is imperative that threat visibility and adaptive controls extend to the most attacked people and operate effectively in the cloud.

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This includes deployment of multifactor authentication solutions, the ability to detect suspicious login attempts, and user education.
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Also, deployed cloud DLP policies need to align with those for email and on-premises file repositories. Finally, DLP incident management should be centralized and span across cloud apps.

The issue of identity management will continue to play a central role in security strategies for years to come. Focusing on data access governance, modern DLP and effective cloud app security can help significantly reduce an organization’s risk.