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How Active Governance Can Advance Proactive Risk Intelligence

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Boards, regulators and leadership teams are demanding more and more of risk, compliance, audit, IT and security teams. They are asking them to collaboratively focus on identifying, analyzing and managing the portfolio of risks that really matter to the business.

As risk management programs evolve to more formal processes aligned with business objectives, leaders are realizing that by developing a proactive mindset in risk and compliance management, teams can provide added value to help the organization gain agility by identifying new opportunities as well as managing down-side risk. Organizations with this new perspective are more successful in orchestrating change to provide a 360-degree view of both risk and opportunity.

Risk teams that are further along on the journey of leveraging proactive approaches to risk management look not only within the organization but beyond to supplier, third party and customer ecosystems. This means developing a view across the larger enterprise infocosm, to ensure alignment of people, processes and technologies.

An essential prerequisite to proactive risk management is a shift from passive to active governance. To build an active governance competence effectively, governance needs to be “active, engaged and embedded,” rather than “passive, reactive and irrelevant.”

Active governance means being thoughtful about alignment and interlocks policy, risk, compliance, quality and operational programs. Proactive risk intelligence throughout the organization can help it advance by aligning policies, procedures, facilitating an enterprise view of issues and orchestrating change to mitigate risk.

Align Policies, Procedures and Roles

Once proactive risk intelligence is understood and embraced as a concept, the next step is to develop agile and consistent policies that truly reflect and produce desired behavior. This means aligning business strategy and appetites with prescribed behavior, which is typically described not only through policies, but also through procedures, and embedded in role descriptions. It is important to make governance traceable in this way. Likewise, it is critical to make sure roles and responsibilities are aligned with policies and procedures so that employees, partners and third parties are empowered to do the right thing.

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Foundational is consistency between policies and procedures in similar roles across geographies, cultures and business units. Some key things you can do to help your organization include:

  • Align Policies to Business Objectives — Ensure responsible management and oversight of resources by aligning policy to business intent. You can do this by mapping policies to risk tolerances and compliance requirements. Be explicit when defining legal and ethical boundaries.
  • Resolve Global/Local Conflicts in Policies and Procedures — Improve active governance by resolving local/global dissonance—often a policy at one level can contradict a similar overlapping policy at another level—it’s important to iron out discrepancies so that people have confidence in the policy and know it stands for something the organization values.
  • Engage the Right Subject Matter Experts for Policy Creation and Review — Policy life-cycle management can really help. Be sure to include alerts and intelligence to ensure policies reflect compliance to new and changing regulations and business obligations. Establish the right roles and responsibilities for creating, editing, reviewing and publishing polices. Automated workflow can help make this seemingly monumental task achievable. Empower the right decision-making processes for governance of policies and allocation of resources.

Gain an Enterprise View of Issues and Remediation

Now that your organization is looking at risks in the context of appetites, tied to policies that reinforce desired behavior, based on a common language, the next step is rapid, complete issue resolution. Mature organizations can provide a portfolio of issues and incidents, facilitating a 360 view.

By looking at all the incidents and issues tied to a risk, process or asset, your team will begin to develop a preventive capability, and be able to ‘right-size’ remediation investments. Key things you can do to help your organization include:

  • Manage issues as a portfolio — Look at issues across all sources, through a common process, across all aspects of the organization. Not only issues arising from audit, risk management and privacy and compliance teams, IT and security, but also extended to research and development, quality, environmental health and safety and human resource groups.
  • Develop a Proactive, preventive capability  — Think in terms of future changes and what issues may arise in risk and compliance management. For example, getting teams involved early in initiatives such as mergers and acquisitions, new product or service launches or expansion into new markets.
  • ‘Right-Size’ remediation investments — Optimize investments in remediation through end-end root cause analysis—when business units look at an issue in isolation, investments can be made that solve the problem locally, but push symptoms to an upstream or downstream process. Looking at issues across, down and through will help build the 360 views that get at the real root cause and appropriate remediation.

Orchestrate Change across Risk Processes

Creating proactive risk intelligence as a competency is in many ways all about orchestrating change. Continuous value creation is demanded of successful organizations in today’s dynamic world. When collaborative risk teams focus on continuous improvement, they will spot opportunities for operational efficiency and savings that can be used to fund innovations. As organizations mature, collaborative teams can be supported by risk and compliance centers of excellence, shared services and innovation labs.

  • Build a community dedicated to the vision of risk intelligence — Bring people and partners on board with a proactive mindset. Make sure continuous improvement fuels and funds innovation across and within core processes of governance, risk, compliance, privacy and security.
  • Continuously innovate — Manage a portfolio of innovation projects to mature centers of excellence, shared services and distinctive risk and compliance competencies. Leverage technologies to accelerate innovation and gain economies of scale.
  • Continuously improve — A formal investment program identifies synergies and funds strategic initiatives, certification and training programs.

The GRC journey is about orchestrating change to gain a competency of risk intelligence. It requires a proactive mindset and anticipation of future problems needs and changes.

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Active governance is the first step in supporting change and building a competency of proactive risk intelligence by planning and thinking ahead at every stage of the risk management process.

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Active governance goes beyond general oversight to ensure alignment and interlock strategy, through policy, procedures and roles in the operational fabric of the organization and carries through to suppliers, customers and third parties. By starting with these core aspects of active governance, you are in your way to creating a competency of proactive risk intelligence in your organization.

Amicus Supports Government’s Position in Mach Mining vs. EEOC

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On Nov. 3, six advocacy groups representing the interests of workers and plaintiffs’ class action lawyers filed an amicus brief with the U.S. Supreme Court in Mach Mining v. EEOC, No. 13-1019. A copy is here.

Authored by the Civil Rights Clinic of the Dickinson School of Law and The Impact Fund, the amicus brief represents the collective views of multiple public interest organizations, including the National Employment Lawyers Association, The Impact Fund, the American Association of Retired Person, the Asian Americans Advancing Justice-Asian Law Caucus, Disability Rights California and Public Counsel.

The amicus brief was filed in support of the U.S. Equal Employment Opportunity Commission, which filed its Reply Brief with the SCOTUS on Oct. 27, 2014. In supporting the government’s position, the amicus asserted that the brief represents the “perspective of the victims of workplace discrimination whom Title VII is intended to protect.”

Given the importance of this case and the issue presented, the new amicus brief is well worth a read by employers.

The Context and the Stakes

Mach Mining v. EEOC is a big case for employers and for government enforcement litigation. In a game-changing decision in December 2013, the U.S. Court of Appeals for the Seventh Circuit ruled that an alleged failure to conciliate is not an affirmative defense to the merits of an employment discrimination suit brought by the EEOC.

That decision had far-reaching, real world significance to the employment community, for it means the EEOC is virtually immune from review in terms of the settlement positions it takes prior to suing employers: “pay millions or we will sue and announce it in a media release.”

We have blogged on this case at various points before, as the litigation winded through the lower courts and culminated in the precedent-setting decision of the Seventh Circuit reported at 738 F.3d 171 (7th Cir. 2013). Readers can find the previous posts here and here and here.

In essence, the Seventh Circuit determined that the EEOC’s pre-lawsuit conduct in the context of conciliation activities cannot be judicially reviewed. Subsequently, in what many SCOTUS watchers found ironic, even though the EEOC prevailed in the Seventh Circuit, the Government also backed Mach Mining’s request for SCOTUS review to resolve the disagreement among the courts of appeals regarding the EEOC’s conciliation obligations. Given the stakes, the SCOTUS accepted Mach Mining’s petition for certiorari in short order to resolve this issue.

Amicus Briefs for the Defense

Employer groups have lined up behind Mach Mining to support reversal of the Seventh Circuit’s decision. Seyfarth Shaw LLP submitted an amicus brief to the U.S. Supreme Court on behalf of the American Insurance Association in Mach Mining. For blog readers interested in our amicus brief, a copy is here.

Amicus Brief Filed In Support of the EEOC

The amicus submission to the Supreme Court asserts that interpreting Title VII to allow judicial review of conciliation efforts by the EEOC would harm alleged victims of discrimination by violating the mandate of the statute that conciliation remain confidential. Judicial review, the amicus brief asserts, would chill full and frank settlement discussions; expose sensitive information about pre-lawsuit negotiations to the public, and hurt the cases of allegedly injured workers because federal judges might be potentially influenced by irrelevant settlement communications. The amicus brief also argues that if the SCOTUS interprets the statute to allow judicial review of pre-lawsuit conciliation efforts by the EEOC, dismissal is an overly harsh remedy where those efforts are determined to be inadequate (and instead the parties should be ordered to engage in further settlement negotiations).

The point of the amicus brief about compromising the impartiality of federal judges—by exposing the court to settlement discussions in conciliation—is somewhat surprising. Federal judges conduct mediations and settlement conferences as a matter of course, and are “exposed” to settlement discussions routinely.

Next Up on the Docket

Mach Mining’s answering brief is due on Nov. 26, 2014, and then the SCOTUS will set the case for oral argument for January 2015. We will keep our readers updated as developments occur in this litigation.

This post was previously published on the Seyfarth Shaw website here.

The Impact of Collaboration in Cyber Risk Insurance

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Former FBI Director Robert Mueller once said, “There are only two types of companies: those that have been hacked and those that will be. Even that is merging into one category: those that have been hacked and will be again.” This is the environment in which risk managers must protect their businesses, and it isn’t easy.

Cyber risk is not an IT issue; it’s a business problem. As such, risk management strategies must include cyber risk insurance protection. Until recently, cyber insurance was considered a nice-to-have supplement to existing insurance coverage. However, following in the wake of numerous, high-profile data breaches, cyber coverage is fast becoming a must-have. In fact, new data from The Ponemon Institute indicates that policy purchases have more than doubled in the past year, and insiders estimate U.S. premiums at around $1 billion today and rising.

But is a cyber policy really necessary? In short, yes. As P.F. Chang’s China Bistro recently discovered, commercial general liability (CGL) policies generally do not include liability coverage to protect against cyber-related losses. CGL policies are intended to provide broad coverage, not necessarily deep coverage. Considering the complexity of cyber risks, there is a real and legitimate need for specialized policies that indemnify the insured against cyber-related loss and liability.

The fact is, cyber risk is a problem all its own.

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The cyber threat is pervasive, and attacks are increasing exponentially. Cyberattack trends are also shifting constantly. An attack can come from multiple directions and in multiple forms, targeting different information and outcomes: an attack launched by a hacker group intent on making a political statement, malware that enters the network through a third-party service provider to steal credit card information, or a data breach perpetrated by a trusted insider seeking competitive intellectual property (IP).

In this complex, dynamic threat landscape, the ability to accurately assess risk becomes a monumental undertaking. If we accept that every organization has been hacked or will be again, it’s clear that prior incidents are no longer relevant or legitimate indicators of a company’s risk. Similarly, stagnant security checklists required by many insurers are hardly representative of actual, ever-changing cyber risk. Traditional risk assessment methodologies that rely on these elements to determine pre-binding risk simply have no place in today’s world.

Risk Assessment for the Cyber Era

The industry needs assessment methods consistent with the changing threat landscape. That means real-time, active assessment of an entity’s entire business ecosystem including upstream and downstream threats, as well as the often overlooked insider threat. What this provides is a holistic understanding of an entity’s vulnerabilities, high priority risks and security maturity.

In the current cyber environment, it’s implicit that every organization will be the victim of a cyberattack and that there will be some cyber loss as a result. Thus, savvy underwriters are looking beyond mere ticks on a checklist to determine insurability; rather, they’re looking for security maturity and cyber resilience.

The more cyber resilient an organization, the faster it can identify a cyberattack, stop it and recover from the impact. Data loss is expected. It’s the severity of the data loss that will impact the company’s business, damage its brand and customer loyalty and erode investor confidence.

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Those organizations that can quickly and effectively minimize the risk and get back to business are generally considered a safer bet.

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This is where organizations can realize the benefits of holistic cyber insurance assessment. All too often, critical data is uncovered after a breach occurs. By implementing a proactive risk assessment before an attack occurs, the organization can gain in-depth intelligence about its highest priority risks before an incident, not years later when it’s too late to do anything about it. A pre-binding assessment provides the right data at the right time to inform risk management decisions and align resources with an organization’s highest priority risks.

Additionally, organizations that adopt continuous proactive assessment and ongoing risk mitigation demonstrate mature security practices, which indicate an organization’s ability to return to regular operations faster following a cyber incident.

Partners Against Cybercrime

Historically, there has been an antagonistic relationship between the insurer and client, but in the wake of catastrophic data breaches, these two sides are now finding common ground. For instance, several insurance brokers today are requiring a holistic, pre-binding risk assessment before a company can receive a policy. This benefits both the insurer and the pre-insured by providing invaluable insights about the company’s security, often revealing unexpected weaknesses and new priorities. Some policies also tie risk assessment to financial incentive to encourage ongoing risk mitigation. This becomes a virtuous circle situation for the insured, as it gets the benefit of reduced premiums after risk maturity has been measured, which allows the company greater insight and the ability to be proactive about reducing security risks.

For decades, the bargaining power has been with the insurer. With a revised approach, and in keeping with the demands of today’s cyber landscape, the relationship between insurer and insured has become collaborative as both sides work together to identify and mitigate risk. In this way, cyber insurance becomes an avenue for companies to improve cybersecurity, not to simply offset risk.

How Retailers Can Better Mitigate Black Friday Risks

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Black Friday Shopping Risks

With the biggest shopping events of the season, retailers face tremendous amounts of both risk and reward as sales and door-busters draw in eager consumers all week. In 2013, Thanksgiving deals brought in 92.1 million shoppers to spend over $50 billion in a single weekend, the National Retail Federation reports.

The National Retail Federation issued crowd management guidelines for retailers and mall management officials to use when planning special events, including Black Friday, product launches, celebrity appearances and promotional sales. General considerations to plan for and curtail any crowd control issues include:

  • Remind and retrain all employees about your store’s emergency protocols to address potential risks facing employees and customers.
  • Dedicate knowledgeable employees to communicate and manage crowds, from arrival to departure, and resolve any potential conflicts that may arise.
  • Strategically place sale items throughout the store to help disperse crowds and manage traffic flow.
  • Request the assistance of local law enforcement if large crowds are expected and arrange for additional security services.
  • Educate employees about relevant policies and procedures and advise them who to contact in the event of a situation.

Last week, the U.S. Department of Labor’s Occupational Safety and Health Administration also issued a public letter to retailers urging companies to plan ahead for better in-store safety for both employees and customers. According to OSHA’s “Crowd Management Safety Guidelines for Retailers,” crowd management plans should, at least, include:

  • On-site trained security personnel or police officers
  • Barricades or rope lines for pedestrians that do not start right in front of the store’s entrance
  • The implementation of crowd control measures well in advance of customers arriving at the store
  • Emergency procedures in place to address potential dangers
  • Methods for explaining approach and entrance procedures to the arriving public
  • Not allowing additional customers to enter the store when it reaches its maximum occupancy level
  • Not blocking or locking exit doors

Brick-and-mortar retailers are not the only ones at greater risk. Companies that operate call centers must also be prepared for a drastic increase in customer inquiries and purchases. According to communications intelligence firm Cognia, 69% of U.S. contact centers carry out credit card payments over the phone and 84% record calls, making their archives particularly vulnerable to potential breaches.

“The first thing to highlight with respect to call center compliance at peak times is that this pressure is unlikely to create new issues, but will amplify existing ones. Attackers / threat actors (the bad guys) will also be aware that this is the time at which procedures are most likely to slip, and social engineering vulnerabilities that have previously been identified can be exploited,” said Tom Evans, Cognia’s chief security officer.

“There are challenges but, from a risk perspective, there is also an opportunity to fine-tune the risk management system under pressure. At these peak times, issues will be visible that would go undetected during business as usual operation,” Evans noted. “There is an opportunity to be proactive and to use the pressure around these peak sales times to identify bad practice that, during less pressured periods, is probably limited to one or two individuals or occasional occurrences, and therefore very hard to spot. Even the most dependable employee under the pressure on big queues may resort to a shortcut to get the job done. Identifying these means that controls can be put in place to prevent them being used again, and therefore the overall risk management position improved.”

To improve security and PCI compliance, Evans recommends that companies focus on areas that have lower security controls overall. For example, seasonal employees, over-spill call centers, and work at home agents may all be components of a contingency plan for peak periods that introduce vulnerability that can be mitigated.