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ARMReN Seminar Thursday, 13 September 2007. Balancing Access and Privacy: Using Risk Management to Walk the Tightrope Dr. Victoria Lemieux 13 September, 2007 ARMRen research workshop on Access and Impact Liverpool University, Foresight Centre.
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ARMReN SeminarThursday, 13 September 2007 Balancing Access and Privacy: Using Risk Management to Walk the Tightrope Dr. Victoria Lemieux 13 September, 2007 ARMRen research workshop on Access and Impact Liverpool University, Foresight Centre
Free flow of information: A competitive imperative • Global investment banking relies on the free flow of information across borders and institutions • Trading • Fund transfers • Global mergers & acquisitions • Asset management • Other business activities executed on a global scale
Credit Suisse: A Case in Point • Credit Suisse is a leading global bank headquartered in Zurich • It is focussed on serving its clients in three business lines: investment banking, private banking and asset management • For the second quarter of 2007, net income totalled CHF 3.2 billion and had CHF 1,629 billion worth of assets under management • Total staff worldwide is 45,000 • Credit Suisse operates in approximately 50 countries globally
Federal Information Security Management Act Data Protection Act Bank for International Settlements (Basel II) Japanese Financial Services Agency GrammLeachBliley EBK/ Swiss BankingSecrecy California SB1386 Patriot Act Financial Services Authority Monetary Authority of Singapore Sarbanes Oxley Federal Financial Institution Examiners Council International Standards Organisation The Legal and Regulatory Landscape & Climate
Data Privacy Regulation: A Growth Market • Almost every country in which Credit Suisse now operates has some form of data privacy/data protection legislation or regulation • Data privacy legislation/regulation is on the rise • Growing public concern about data security • Recent examples *Facebook *J.P Morgan Chase *Monster *Nationwide *Wikipedia *Bank of America
Information Management Compliance – What Could be Easier? Achieving information management compliance boils down to three simple steps: 1. Identify relevant laws and regulations 2. Identify records to which laws/regulations apply 3. Ensure records are created & handled in accordance with applicable laws/regulations It’s not as easy as it seems!
Which Records? IM Email Web Content Rich Media
Which Solutions ECM EDRMS Digital Rights Management Centralised Device Management Storage Solutions Encryption
Challenge/Response • How the RM community support financial services firms in meeting the IM compliance challenge: • Support a risk-based approach
What is risk management? Risk Management is an ongoing process used to: • Identify potential risks associated with business activity • Identify the potential impact and severity associated with the risk • Identify strategies and activities that can implemented to mitigate or eliminate the risk • Assign responsibilities and track progress of risk management activities • Why is risk management important? • Rise of the ‘Risk Society’ • Rise of accountability frameworks (e.g., SOX, COSO) in which risk management figures prominently • Rise of RIM-related threats • Compliance complexity • Risk management as an appraisal tool
How Risk Management can help Strike the Right Balance • Identify the risks. • Lack of clarity re: application of law to different records • Absence of controls for particular devices • Technical weaknesses in recordkeeping solutions • Categorize the risks. • Rank the risks. • Accept or look for ways to mitigate the risks • Develop risk mitigation action plan • Track and monitor plan
Identifying risks • Risk assessment • Business context + business functions/activities Business Context Business Activities Risk Vulnerabilities Threats
Categorizing risk • Operating Risks:Those risks associated with business process and technical operations and the challenges of providing service delivery globally – including Loyalty Risk addressing any staff related exposure. • Legal Risk addressing any risks around non-compliance with legal/regulatory requirements, or risk of litigation • Technology Risks:Those risks associated with the ability to control future technology direction and to use technology to provide a competitive edge. • Financial Risks: Those risks that have an adverse effect on the financial condition of the company or the achievement of Credit Suisse’s sourcing objectives. • Business Risks:Those risks that have an adverse effect on Credit Suisse’s business operations or competitive position in the marketplace – including Reputation Risk.
Ranking risk • Probability is the likelihood that a risk will occur • Impact is the consequences of a given risk once it occurs • Risk management entails estimating probability and impact • The measurement of probability and impact can be qualitative, quantitative, or a combination of the two • It is important to assess the inter-dependency of risks as well as assessing each risk independently
Risk treatment options • Avoid • Accept • Transfer • Reduce
5 7 8 9 4 6 1 2 3 Risk mitigation Action Required to Desensitize Risk • Mitigation Plans reduce the level of risk. Risks are mitigated either by stabilizing or limiting the impact of the underlying assumption or desensitizing the outcome. • Similar techniques can be used to identify risk mitigation strategies as can be used to identify risks Action Required to Stabilize Impact Probability
Tracking and monitoring • Measure that risk treatment strategies have had the intended results • Monitor risks over time to detect increases or decreases in their ranking • Monitor that procedures and information gathered during the risk identification, risk measurement and risk treatment phases were accurate and complete • Identify where improved knowledge would have helped to reach better decisions • Identify lessons to be learned from the risk management process • Assess whether risk management processes are adequate and being fully implemented.