The Anatomy of Data Risk Management

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An article by Risk and Insurance Management Society, Inc. (RIMS) recently found in The National Law Review focused on Data Risk Management:

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Think of data as a living organism.

Just like a human body, data has various components and life support systems that must be maintained to ensure the whole thrives and survives. You can think of a data risk specialist as a doctor trying to keep the organism healthy through its various life stages.

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Data, our hypothetical patient, (you’re welcome Star Trek fans) needs a safe and healthy environment, a supportive lifestyle and good hygiene. Just as a doctor has to consider external threats (“do you smoke?”) so does the data risk manager.

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Let’s look at what this all means, and how this philosophy can be applied to your businesses policies and practices.

Data, our hypothetical patient, has three basic forms: paper, electronic and human memory.  A good data risk management plan must consider all three.

Controlling paper and electronic data is what we think of most when considering data security. This is your standard (or what should be standard) security policy, access controls procedures, system audits, and the like. It’s where security planning meets IT.

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Human memory is a little more elusive. Education, security training and a reward-demotion plan can help control human errors, as can confidentiality agreements, and project-specific security contracts. These are the tools of teachers and lawyers. Generally speaking, there are four key rules to protecting data in all its forms:

  1. Be stingy with sensitive data, internally and externally;
  2. Provide access to data on a need-to-know basis;
  3. Provide access only to that specific data, rather than entire data sets;
  4. Be deliberate in how data is handled, used and shared.

Data has a life cycle. If your data doesn’t, it should. Whether it’s government secrets or an online shopper’s credit card number, data is received or created within your company’s computer systems. It is used, maintained and stored. It is archived or destroyed. That data, in all cases, has three basic states: in action, in motion or at rest. Take the credit card number example: that information can be used, the card charged, or moved to another computer system, or archived. Use, motion, rest.

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There are four fundamental rules regarding the life cycle of data:

  1. If the organization doesn’t need it, don’t collect it.
  2. If data must be collected, collect only what is needed.
  3. If data is needed, control it and encrypt it.
  4. When data is no longer needed, get rid of it – SECURELY.

Now that we know what data looks like (paper, electronic, mnemonic) and how it lives (in action, in motion, at rest) we should consider those external threats, namely data breaches. A data breach is an incident (or series thereof) in which sensitive, protected or confidential information has potentially been viewed, stolen or used with unauthorized access. This can be a hacker attack, an internal company mistake that results in exposed information or, in some cases, corporate or government espionage. A data breach can be anything that jeopardizes data.

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These threats range from simple user negligence, operating or systemic issues, all the way to highly complex criminal attacks launched against your organization. As anyone who follows the tech news knows, sensitive consumer and business information has become a criminal commodity.

With this hostile environment in mind, it is imperative for the business to plan and prepare not only for the protection of their information, but also for the response and recovery of their data and business in the event of a data breach. For a data manager or security professional to fail to issue such a warning would be akin to that doctor not asking about smoking.

At the end of the day, data as an organism is more than an extended metaphor. It’s a means to look at your company’s data products in an abstract way and understand how it operates. This, in turn, will allow you to develop the proper health plan. Just like with our health, there is no single wonder pill. But there are data doctors out there who can analyze your businesses’ risk posture and recommend ways to get it in shape.

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Brian McGinley, senior vice president of data risk management at Identity Theft 911 offers this well-written piece on the timely topic.

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Risk Management Magazine and Risk Management Monitor. Copyright 2012 Risk and Insurance Management Society, Inc.

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National Law Forum

A group of in-house attorneys developed the National Law Review on-line edition to create an easy to use resource to capture legal trends and news as they first start to emerge. We were looking for a better way to organize, vet and easily retrieve all the updates that were being sent to us on a daily basis.In the process, we’ve become one of the highest volume business law websites in the U.S. Today, the National Law Review’s seasoned editors screen and classify breaking news and analysis authored by recognized legal professionals and our own journalists. There is no log in to access the database and new articles are added hourly. The National Law Review revolutionized legal publication in 1888 and this cutting-edge tradition continues today.