By Gant Redmon
My ‘tween daughter is super social. She seems to have a new best friend forever—or BFF, as the kids say—every couple of months. But a BFF the privacy professional should stick with month in and month out is the chief security officer (CSO), because we make a wicked good match.
We privacy folks shouldn’t be intimidated by the security wonks. They even have a playful side to them. I knew one who would stop and change the password and lock any workstation he came by that was left open and unlocked. What a kidder…
So after you finish this article, walk down the hall and invite your CSO to lunch, your treat. Why? Well, here are four good reasons to pick up that tab.
Think of the CSO as your own little privacy NORAD who will give you real-time insight to potential dangers. They’re the early warning system for losses of personal information. You know how most companies know they’ve had a breach? They get a phone call—it could be from a customer, a regulator, or a credit card issuer. This is not how you want to learn of the problem. You want a CSO who knows how to get a hold of you fast, just like a good BFF should. And they need to know what to look for. This is where you come in: to make privacy concerns part the CSO’s thought process.
Here are some ways the CSO can think like your BFF.
Scenario 1: Stolen Laptop
Fred from finance has his laptop stolen when his house is broken into. The CSO may have focused on getting Fred a new laptop and restoring info from backup. But did he think about what data was on the laptop? Did the information match definitions of PII or PHI? How does that relate to the data breach regulations affecting the company? The CSO hears “lost laptop,” but you think “lost information.” You can lead him along the path to privacy righteousness.
Scenario 2: Malware
Malware is detected on the HR and engineering servers, and log files show files have been accessed by an IP address assigned to an Internet service provider in Kazakhstan. The CSO will focus on closing the vulnerability and ridding the system of malware. How fast will he or she also determine which files have been accessed and what was in those files? I’d be willing to bet it will be faster if he knows how important it is for you to determine if the intruder made off with protected information.
Scenario #3: Insider Threat
Your network monitoring tool throws an alert that Rissa, the receptionist, has been removing files from the CFO’s laptop just as your company is set to announce quarterly results. The CSO may think his job is done when he reports Rissa to HR and she’s marched out of the building. Will he think of analyzing Rissa’s computer to see where that information might have been sent? You’ll certainly want to know.
The second reason why the CSO should be your BFF is CSOs have skills and staff resources that you don’t. Do you know how to analyze a log file or take an image of a disk? Most of us don’t. The CSO’s team is the only source for answering four questions required to determine if a breach has occurred in the eyes of state and federal regulators. First, a breach is generally only reportable if information is accessed or acquired. That analysis is clearly in the CSO’s domain.
Second, if it was accessed or acquired, was it encrypted at the time? The answer is complicated when you consider the loss may have occurred when the data was in transit or at rest. This will take serious forensic footwork.
Third, what information was accessed or acquired? State breach notice laws define personal information. If the information accessed or acquired doesn’t meet the definition, then you’re not required to report. The CSO is your gatekeeper to these files you will need to review to determine if they contain personal information. You’ll also need to know where those affected live, because we look at individuals’ state citizenship to determine applicable state law for breach notices. The CSO has the tools and technology to give us the information we need to determine if we have a reportable breach on our hands.
The third reason why the CSO should be your BFF is that by collaborating, both your roles are strategic to the business with real impact on the customer or client experience. The CSO will have a hand in the company’s mobile, social media and cloud strategies but needs the CPO’s guidance in launching these strategies. For example, a healthcare organization realizes doctors are communicating with patients on the doctors’ personal unencrypted e-mail accounts. The CSO wants to roll out a patient site for communications with doctors in a secure environment. A number of vendors offer such patient sites, but which will keep the company on the right side of HIPAA/HITECH? You may not know log files, but you know HIPAA. When you take a seat at the table next to the CSO for purposes of patient interaction, you have promoted yourself from a basic compliance function to a strategic contributor.
Reason number four why the CSO should be your BFF is that they have money. I know that sounds a tad shallow, but privacy offices are not known for lavish budgets. Some in management feel that traditional compliance functions should be kept on a strict fiscal diet so they don’t become strong enough to hamper the business. IT and security don’t suffer from such reduced rations. Network security is red hot these days, and money is being spent. Got a tool that helps the CSO identify privacy issues in everyday security incidents? You may find the CSO’s budget a lot easier to tap than your own.
Still intimidated? You shouldn’t be. Just think of all the insight you’ll be getting, the strategies you’ll learn and the skills you’ll walk away with—just by becoming BFFs with your CSO. And don’t forget the last part: The CSO has the dough to implement those security prevention programs that may just save your company at some point in the near future.
Now, how about that lunch?
Gant Redmon is general counsel and VP of business development at Co3 Systems. Gant has practiced law for 19 years, 15 of which as in-house counsel for security software companies. Prior to joining Co3 Systems, Gant was general counsel of Arbor Networks, now part of the Danaher Corporation.
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