Policies to Manage Cyber Risk

By Mark Borkowski

”Cyber Crime is the Fastest Growing Crime in the World”

“30% Increase in the Level of Cyber Crime has occurred in the Last Two Years.”

It’s not if you will get hacked, it’s when you get your private business data hacked and stolen. Do you have the insurance coverage for a cyber attack?

I spoke to George Longo, president of Towerhill Insurance. He is an expert in the area of cyber insurance. He believes that all companies should develop and maintain clear and robust policies for safeguarding critical business data and sensitive information, protecting their reputations and discouraging inappropriate behaviour by employees.

Many companies already have these types of policies in place, but they may need to be tailored to reflect the increasing impact of cyber risk on everyday transactions, both professional and personal. As with any other business document, cyber security policies should follow good design and governance practices—not so long that they become unusable, not so vague that they become meaningless, and reviewed regularly to ensure that they stay pertinent as your business’ needs change.

Security Roles

One of the most effective and least expensive means of preventing serious cyber security incidents is to establish a policy that clearly defines the separation of roles and responsibilities with regard to systems and the information they contain. Many systems are designed to provide for strong role-based access control, but this tool is of little use without well-defined procedures and policies to govern the assignment of roles and their associated constraints. At a minimum, such policies need to clearly identify company data ownership and employee roles for security oversight and their inherent privileges, including:

  • Necessary roles, and the privileges and constraints accorded to those roles
  • The types of employees who should be allowed to assume the various roles
  • How long an employee may hold a role before access rights must be reviewed
  • If employees may hold multiple roles, the conditions defining when to adopt one role over another

Longo believes that depending on the types of data regularly handled by your business, it may also make sense to create separate policies governing who is responsible for certain types of data. For example, a business that handles large volumes of personal information from its customers may benefit from identifying a chief steward for customers’ privacy information. The steward could serve not only as a subject matter expert on all matters of privacy, but also as the champion for process and technical improvements to handling of personally identifiable information.

Private Policy

Privacy is important for your business and your customers. Continued trust in your business practices, products and secure handling of your clients’ unique information impacts your profitability. Your privacy policy is a pledge to your customers that you will use and protect their information in ways that they expect and that adhere to your legal obligations.

Your policy should start with a simple, clear statement describing the information you collect about your customers (physical addresses, email addresses, browsing history, etc.) and what you do with it.

It’s important to create your privacy policy with care and post it clearly on your website. It’s also important to share your privacy policies, rules and expectations with all employees and partners who may come into contact with that information. Your employees need to be familiar with your privacy policy and what it means for their daily work routines.

Internet Usage

The limits on employee Internet usage in the workplace vary widely from business to business. Your guidelines should allow employees the maximum degree of freedom they require to be productive (for example, short breaks to surf the Web or perform personal tasks online have been shown to increase productivity). At the same time, rules for behaviour are necessary to ensure that all employees are aware of boundaries, both to keep themselves safe and to keep your company successful. Some guidelines to consider:

  • Personal breaks to surf the Web should be limited to a reasonable amount of time and to certain types of activities.
  • If you use a Web filtering system, employees should have clear knowledge of how and why their Web activities will be monitored, and what types of sites are deemed unacceptable by your policy.
  • Workplace rules for behaviour should be clear, concise and easy to follow. Employees should feel comfortable performing both personal and professional tasks online without making judgment calls as to what may or may not be deemed appropriate. Businesses may want to include a splash warning upon network sign-on that advises employees about the company’s Internet usage policy so that all employees are on notice.

Social Media

Social networking applications present a number of risks that are difficult to address using technical or procedural solutions. A strong social media policy is crucial for any business that seeks to use social networking to promote its activities and communicate with its customers. At a minimum, a social media policy should clearly include the following:

  • Specific guidance on when to disclose company activities using social media, and what kinds of details can be discussed in a public forum
  • Additional rules of behaviour for employees using personal social networking accounts to make clear what kinds of discussion topics or posts could cause risk for the company
  • Guidance on the acceptability of using a company email address to register for, or get notices from, social media sites
  • Guidance on selecting long, strong passwords for social networking accounts, since very few social media sites enforce strong authentication policies for users

All users of social media need to be aware of the risks associated with social networking tools and the types of data that can be automatically disclosed online. Taking the time to educate your employees on the potential pitfalls of social media use, especially sites with geo-location services, may be the most beneficial social networking security practice of all.

Reputation Risks

All organizations should take the time to identify potential risks to their reputations and develop a strategy to mitigate those risks with policies or other measures as available. Specific types of reputation risks include:

  • Being impersonated online by a criminal organization (e.g., an illegitimate website spoofing your business name and copying your site design, then attempting to defraud potential customers via phishing scams or other methods)
  • Having sensitive company or customer information leaked to the public via the Web
  • Having sensitive or inappropriate employee actions made public via the Web or social media sites

Longo believes that all businesses should set a policy for managing these types of risks and plan to address such incidents if and when they occur. Such a policy should cover a regular process for identifying potential risks to the company’s reputation in cyber space, practical measures to prevent those risks from materializing and plans to respond and recover from incidents as soon as they occur.

Mark Borkowski is president of Mercantile Mergers & Acquisitions Corporation. Contact:

www.mercantilemergersacquisitions.com

Towerhill Insurance & Risk Management: Contact: glongo@towerhillinsurance.ca or

tel: 905-890-6610 ext. 221.

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