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AFM INTERNAL AUDIT NETWORK MEETING MUTUAL ONE GROVE PARK, LEICESTER

AFM INTERNAL AUDIT NETWORK MEETING MUTUAL ONE GROVE PARK, LEICESTER Current ‘Hot Topics’ in Information Security Governance Auditing David Tattersall 03 March 2011. WHO ARE MUTUAL ONE ?. Mission Statement “To enhance the competitiveness of mutuals”. WHAT DOES MUTUAL ONE DO ?.

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AFM INTERNAL AUDIT NETWORK MEETING MUTUAL ONE GROVE PARK, LEICESTER

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  1. AFM INTERNAL AUDIT NETWORK MEETING MUTUAL ONE GROVE PARK, LEICESTER Current ‘Hot Topics’ in Information Security Governance Auditing David Tattersall 03 March 2011

  2. WHO ARE MUTUAL ONE ? Mission Statement “To enhance the competitiveness of mutuals”

  3. WHAT DOES MUTUAL ONE DO ? • We facilitate collective action amongst mutuals across 4 broad areas: • Internal audit • Compliance, risk and governance • Events • Collective procurement • We are very committed to supporting the mutual sector so that it thrives, not just survives • More details on the above can be found on www.mutual-one.co.uk

  4. Current ‘Hot Topics’ in Information Security Governance Auditing Contents • Definition of ‘Information Security’ • What Information do we need to secure? • Why do we need to secure information? • Auditing Information Security • Frameworks • Emerging Themes • Questions

  5. Information Security…. ….protecting information and information systems from unauthorised access, use, disclosure, disruption, modification or destruction. Wikipedia – Nov 2010

  6. CIA ‘triangle’

  7. What information needs protecting? Customer Company Employee Confidential Bank / card Product / ideas

  8. But why….? • Regulatory Requirements • Financial Services Authority

  9. FSA Fines….

  10. But why….? • Regulatory Requirements • Financial Services Authority • Data Protection Act 1998

  11. ICO Fines….!!!

  12. ICO Fines….!!!

  13. But why….? • Regulatory Requirements • Reputation Damage • Financial Cost

  14. Estimated Cost of a Data Breach: • Data Loss incidents cost between £365k and £3.92m to manage • Average cost per lost record = £64 • Biggest cost per lost record is lost business - £29 • Other costs include: • customer communication • recompense • operational costs • financial penalty • Increased 7% in past year, 36% in past two years Source: Ponemon Institute / PGP 2009 Annual Study - Global Cost of a Data Breach report

  15. Auditing InfoSec Dependent upon: • Organisation • Operating environment – regulated firm? Compliance to external requirements (e.g. PCI-DSS)? • Size and nature of IT environment i.e. is control requirement proportionate? • Risk appetite

  16. Auditing InfoSec - Frameworks • ISO27001 / 2 • ISO/IEC 27001:2005 – Information Security Management Systems – Requirements • ISO/IEC 27002:2005 – Code of Practice for Information Security Management • COBIT • FSA Paper – Data Security in Financial Services (Apr 2008) • Payment Card Industry – Data Security Standards

  17. Auditing InfoSec Emerging Themes: • FSA split into Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA)

  18. Data Security in Financial Services (April 2008) – New Regulation ?? • Governance – managing systems and controls • Training and Awareness • Staff Recruitment & Vetting • Controls • Physical Security • Disposing of Customer Data • Managing Third-party Suppliers • Internal Audit and Compliance Monitoring

  19. Auditing InfoSec Emerging Themes: • FSA split into Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) • Outsourcing / key suppliers

  20. FSA Fines…. • Result of a lack of oversight on key outsourced service • Third Party Assurance

  21. Third Party Assurance • Due diligence • Relationship management • Contracts / service level agreements • Ongoing review of security arrangements • Third party assurance

  22. Auditing InfoSec Emerging Themes: • FSA split into Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) • Outsourcing / key suppliers • Internal Threats – who are our employees?

  23. Can you trust your employees?

  24. Who are our employees? • Initial recruitment process • background checks • CRB checks • credit checks • Recruitment of temporary staff • Ongoing vetting of staff

  25. Auditing InfoSec Emerging Themes: • FSA split into Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) • Outsourcing / key suppliers • Internal Threats – who are our employees? • Internal Threats – how is the internet used?

  26. Web-based email / social networking

  27. “To block or not to block….?” Reasons to block…. • Introduction of malware, spyware, virus • Bandwidth usage • ‘Time-wasting’ • Data Leakage • Accidental • Intentional • Data aggregation • REPUTATION!

  28. “To block or not to block….?” Reasons to allow…. • Networking opportunities • Knowledge sharing • Communication with staff • Marketing ability / customer engagement • Increased staff morale

  29. “To block or not to block….?” Controls to consider (if allowing social networking sites) • Solid risk assessment • Training and awareness • Usage policies • Granular web-site controls (next-gen firewalls) • Data leakage software

  30. Beware….proxy avoidance…

  31. Auditing InfoSec Emerging Themes: • FSA split into Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) • Outsourcing / key suppliers • Internal Threats – who are our employees? • Internal Threats – how is the internet used? • Portable Media Devices – Encrypted?

  32. Ongoing Problem

  33. Laptop Security • Encryption • Laptop policy – cannot rely on adherence • Asset Register • Laptop sharing

  34. Auditing InfoSec Emerging Themes: • FSA split into Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) • Outsourcing / key suppliers • Internal Threats – who are our employees? • Internal Threats – how is the internet used? • Portable Media Devices – Encrypted? • Smart Phones

  35. Smart Phones

  36. Auditing InfoSec Emerging Themes: • FSA split into Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) • Outsourcing / key suppliers • Internal Threats – who are our employees? • Internal Threats – how is the internet used? • Portable Media Devices – Encrypted? • Smart Phones • What next….? Cloud Computing?

  37. Cloud Computing • Security • Regulatory Compliance • Location • Segregation • Recovery • Auditability • Longevity • Costs

  38. ANY QUESTIONS ?

  39. Work TogetherRespect each other and our clients and through teamwork achieve a common goal Share KnowledgeOur aim is to enlighten and add value through experience Communicate ClearlyAt all levels, to achieve the optimum outcome Deliver Quality Service We can be relied upon and trusted to meet agreed objectives Anticipate and Respond to ChangeWe aim to be proactive and innovative; by being adaptable we address tomorrow's challenges today

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