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CYBER PLAN ACTION FOR POLICY DEVELOPMENT AND MANAGEMENT

All companies should develop and maintain clear and robust policies for safeguarding critical business data and sensitive information, protecting their reputation, and discouraging inappropriate behavior by employees. Many of these types of policies already exist for “real world” situations, but may need to be tailored to your organization and updated to reflect the increasing impact of cyberspace on everyday transactions, both professional and personal. As with any other business document, cyber security policies should follow the good design and governance practices — not so long that they become unusable, not so vague that they become meaningless, and reviewed on a regular basis to ensure that they stay pertinent as your business needs change. Please note that this document does not address all policy requirements for businesses that fall under legislative acts or directives, such as the Health Insurance Portability and Accountability Act, Sarbanes-Oxley Act, or other federal, state, or local statutes.

Establish security roles and responsibilities. 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 (RBAC), but this tool is of little use without well-defined procedures and policies to govern the assignment of roles and their associated constraints. Such policies need to clearly stated, at a minimum.  

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 circumstances defining when to adopt one role over another.

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 personally identifiable information (PII) 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 serve as the champion for process and technical improvements to PII handling.

Establish an employee Internet usage policy. 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 (short breaks to surf the web or perform personal tasks online have been shown to increase productivity). At the same time, rules of behavior are necessary to ensure that all employees are aware of boundaries, both to keep them safe and to keep your company successful. Some 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 of behavior 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 the employees of the businesses’ Internet usage policies so that all employees are on notice.

Establish a social media policy. 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 behavior 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 and strong passwords for social networking accounts, since very few social media sites enforce strong authentication policies for users.

Lastly, 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 when using social media. Taking the time to educate your employees on the potential pitfalls of social media use, especially in tandem with geo-location services, maybe the most beneficial social networking security practice of all.

Identify potential reputation risks. All organizations should take the time to identify potential risks to their reputation and develop a strategy to mitigate those risks via 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 method).
  • 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.

All businesses should set a policy for managing these types of risks and plans 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 cyberspace, practical measures to prevent those risks from materializing, and reference plan to respond and recover from potential incidents as soon as they occur.

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