Liberty Valley Chapter hosted by The Vanguard Group and the
closing keynote to the IT bank examiners from all of the Federal
Financial Institutions Examination Council - FFIEC agencies [Federal Reserve,
FDIC, Office of the Controller of the Currency, NCUA, and State Liaison
Commission]) - yet, there was resonance from both groups on several
points. This three part blog post is intended to share a few of the key points
and some of the feedback from the live audience.
The key themes were:
The Power of Integration, The Problem of Extreme Complexity, and the
Importance of Frameworks. There was
another important theme, “Excellence,” which I’ll deal with separately.
Deploying security controls and solutions is necessary, but
not sufficient. Compliance requirements
and contracts with business partners or payment card processors mandate that
security controls and security best practices are in place such as separation
of duties, change control, encryption of sensitive data, least privilege access
control, and separation of development, test, and production environments.
However, putting a check in the box that a required control
is deployed does not mean that the control is effective. A key attribute of any control is integration. The more highly that a control is integrated
the more effective it will be. That integration
can be with business processes or with technology.
In the photo above, the lock and unlock security functions
are integrated with the key. It is
effortless to lock the car when you park.
Contrast that to the case of manual door locks. With manual locks, each time you park, you
have to make a decision (a risk analysis), “Is it worth climbing all around the
car to lock the doors or am I in a safe enough place to leave them unlocked?”
Yes, the car had locking capability, but because it wasn’t
integrated, much of the time the car was left unlocked.
Every time you plan a security control or deploy a security
capability, think integration; think about the key fob. If you make it effortless, you raise
effectiveness.
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