In this series on defining your company’s information security classifications, we’ve already looked at Protected Information under state PII breach notification statutes, and PHI under HIPAA. What’s next? Customer information that must be safeguarded under the Gramm-Leach-Bliley Act (GLBA), a concern for any “financial institution” under GLBA.

GLBA begins with an elegant, concise statement of congressional policy: “each financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers’ nonpublic personal information.” Sounds straightforward, doesn’t it? Things get complicated, though, for three reasons: (1) the broad scope of what constitutes a “financial institution” subject to GLBA; (2) the byzantine structure of regulators authorized under GLBA to issue rules and security standards and to enforce them; and (3) the amorphous definition of nonpublic customer information.
Continue Reading Adding yet more class to Information Governance (Part 3)

All encryption tools are not created equal. Just ask the folks at Microsoft, who have recently demonstrated that encrypted Electronic Medical Record databases can leak information. Turns out that CryptDB, a SQL database add-on developed at MIT that allows searching of encrypted data, allows search queries to be combined with information in the public domain to hack the database. More on this in a minute. In the meantime, let’s consider the assumption that encryption is inviolate/ infrangible/ impervious to hacks. As I mentioned in an earlier post, encryption algorithms are too complex for most laypersons to understand, but we should at least wrap our heads around the concept that encryption is not a “set it and forget it” technology, nor is it foolproof.
Continue Reading Why encryption is less secure than you think

I’m here at RabbitHole, Inc., talking with the company’s Manager of Money in his office, which is buried in the Facilities Department, down in the building’s basement. I’m interviewing him to get a better sense of how RabbitHole manages money as a corporate asset.

Pardon my asking, but how much money does RabbitHole have?

“Frankly, no one knows – we don’t really keep track of that. We have boxes of paper currency stored off-site, but as for ‘active’ money, our employees keep that pretty much wherever they choose – in the network money systems, in their individual offices, in mobile wallets, and probably some stashed at home.”

But isn’t that your job? I mean, your title is “Manager of Money,” right? 
Continue Reading What if companies treated their money like their information?

While data breaches have become a common occurrence, the epic breach of the Office of Personal Management (“OPM”) records stands out for many reasons. The hackers obtained PII on at least 21.5 million people and accessed highly confidential background check and security clearance information, including personal details such as fingerprint data and financial history. But what is most shocking is that the federal government was aware of security flaws within OPM’s computer system for years before the breach, yet never addressed those vulnerabilities.
Continue Reading Failing to fix is fixing to fail (or get hacked)

 will be missed, but his wisdom will endure. Who else could have observed “No one goes there nowadays. It’s too crowded”? The information governance equivalent is “No one has information anymore. There’s too much of it.” In the last decade we have witnessed the systemic utilitization of computing power. Data used to be housed predominantly within a company’s own systems, but now, through remote storage, SaaS, PaaS, and other cloud solutions, more and more information is hosted by third-party providers. Also, as marketplace forces compel organizations to leverage or outsource functions that used to reside internally, operational service providers increasingly create, receive, maintain, and process information on the organization’s behalf.

It follows that information governance (the organization’s approach to satisfying information compliance and controlling information risk while maximizing information value) can no longer simply be an internally-focused exercise. IG “has come to a fork in the road, and must take it.” Service provider selection, contracting, and oversight are now primary vehicles of information governance – because when it comes to governing your organization’s information, “the future ain’t what it used to be.”
Continue Reading 90% of information governance is half contracting

I met this grumpy fellow in Sabi Sands, South Africa, and took this picture with my phone (nope, no zoom… wish he’d been further away). The experience reminded me of the fable about the Blind Men and the Elephant, a classic allegory for how we often do not perceive the big picture, but instead only the part we directly encounter. This fable has become a useful metaphor for Information Governance. In so many organizations, individual departments and functions have their own, limited perspectives on information, seeing only the issues and objectives with which they are directly familiar. Limited perspective yields limited perception – not a good thing for identifying, understanding, and controlling organizational risk. Information Governance is the means through which organizations can bridge across such silos and perceive the big picture of information compliance, risk, and value.

Actually, I prefer a different version, restyled as the Blind Elephants and the Man.
Continue Reading Information governance in perspective

So, your organization has committed to Information Governance, and you’ve been tasked with making it a reality. Now what?

You’ll need a framework on which to build your program, a platform that will help you bridge across siloed functions (IT, InfoSec, Legal/Compliance, Records Management, Internal Audit, Operations…) and siloed perspectives (privacy, data security, records & information management, litigation discovery…). You’ll also need to come to grips with three persistent barriers to operationalizing Information Governance:
Continue Reading The internal control platform for information governance