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The Information Risk and Treatment Balancing Act |
Information is both a
risk and a resource when thinking about organisational resilience, including
business continuity. There are plenty of examples of information losses that
have caused major embarrassment, cost a considerable amount of money to resolve
and resulted in a loss of trust as well as clients. These have included hacking
and cyber attack problems, lost memory devices, leaving files on the train or
selling off filing cabinets with records still in them. They even involve being photographed on the
way to an important meeting carrying a document the content of which can be
easily read from the photographs. Organisations involved have ranged from small
business to multi-nationals and public sector bodies. The nature of information
as a risk is well publicised, as a result, even if after the fact of its loss.
The assessment and treatment of information risks is perhaps less well
understood in practice as such losses continue to occur. How well thought
through is your information risk strategy? Do you fully understand the nature
of this risk and have you treated it properly? No one wants to see his or her
organisation’s reputation in the gutter due to the loss of sensitive
information, be it commercial or personal.
Information is also a
key resource when it comes to business recovery. Systems and processes are not
useable if the information they require is not available in an accurate, up to
date and workable form. Often it may take longer to get information, with
proven integrity, loaded back onto a system than to recover the hardware
itself. Perhaps this was the problem when it came to the interruption to bank
account access experienced in the UK and Ireland in the recent past. The concept
of the Recovery Point Objective, the time by which information must be
recovered to meet the Recovery Time Objectives of critical processes, is well
documented but perhaps less well implemented. If you haven’t gotten into the
weeds on this one your recovery strategies may well not deliver as you had
hoped. In addition some recovery strategies themselves introduce information
risks that may not have existed before the business disruption that caused the
strategies to be invoked. Take for example home working. How secure is
sensitive or personal information, including emails, when this is your selected
recovery option? It is not clear that all organisations have assessed this risk
and put in place appropriate steps to treat it. The UK Information Commissioner
has had recourse, for example, to fine an organisation in the past for
information uploaded onto the web accidentally from a home computer during home
working.
There is legislation
to cover information risks with the potential for significant fines and websites
that name and shame those found responsible for the loss of personal and
sensitive information. Currently the EU is reviewing this legislative framework
and the outcomes of this work could significantly strengthen the approach taken
with those organisations that compromise such information. Planning for this
issue isn’t just about what do to when information may be lost but includes a
more careful analysis of what information you gather in the first place, how
you store it, for how long you keep it, who you allow to access it and how it
can be recovered in time. Added to this is the complication of where
information ends up and how people actually access it, sometimes without
organisations perhaps being aware. This covers issues as diverse as portable
laptops, photocopier memory storage and Bring Your Own Devices (BYOD) such as
phones or tablets. The scale of the problem can be considerable.
A key place to start
is with an information policy. Such a policy could useful set out the
principles by which information is to be governed, from initial collation to
storage and use/sharing. It should also include destruction and disposal
guidance that can be applied to information no longer of use or technology that
is not required or obsolete. Such guidance should also cover the eventuality of
the invocation of recovery strategies as well as how damaged or irreparable
equipment that could hold information is to be safely managed. You can find out
much more about this issue at the ICO’s website. Go have a look and educate
yourself on this risk and resource.