Governance, Risk Management and Compliance Flashcards

1
Q

Control Framework

Examples

A

These are used to create a governance program to enable compliance with security and privacy requirements

ISO 27014 - Governance of Information Security
ISO 38501 - Governance of Information Technology

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2
Q

What characteristics should control frameworks have?

A

Consistent - in line with Sr. Mgmt guidance and expectations with regards to security and data privacy goals

Measurable - provides a way to determine progress and set goals or KPIs

Standardized - rely on standards or results from one organization or part of an organization that can be compared in a meaningful way

Comprehensive - Should cover the minimum legal and/or regulatory requirements

Modular - A framework that can withstand the changes of an organization because the controls or requirements needing modification are reviewed and updated

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3
Q

Governance

A

Ensures the business focuses on core activities, clarifies WHO in the organization has the authority to make DECISIONS, create POLICY, determines ACCOUNTABILITY for actions and RESPONSIBILITY for outcomes and addresses how expected performance will be evaluated.

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4
Q

Compliance

A

Refers to actions that ensure behavior complies with established rules/policies

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5
Q

Data Subject

A

An individual who is the subject of personal data

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6
Q

Data Steward

A

Responsible for data quality, content, context, and associated business rules

from class “responsible for data integrity”

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7
Q

Data Owner

A

Hold legal rights and complete control and accountability of a single piece or set of data elements

usually the department head or business unit manager for the office that has created or collected a certain dataset.

The data owner will be identified in the create phase.

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8
Q

Data Custodian

A

Responsible for the safe custody, transport, storage of the data and implementation of business rules

The data custodian is any person or entity that is tasked with the daily maintenance and administration of the data. The custodian also has the role of applying the proper security controls and processes as directed by the data owner.

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9
Q

Data Controller

A

A person who determines WHY and HOW PERSONAL DATA is processed

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10
Q

Data Processor

A

Any person who processes data on behalf of the data controller

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11
Q

Data Protection Officer (DPO)

A

Normally APPOINTED by the Data Controller and Data Processor

Responsible for ensuring the strategy and implementation of DATA PROTECTION requirements are in COMPLIANCE with data standards/requirements/laws (e.g. GDPR)

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12
Q

Due Care

A

Setting best or reasonable practices as a responsible organization should do

“Do the Right Thing”

Every employee in the organization should do their job correctly, following policies, procedures, and best practices

The company did all it could have reasonably done to prevent.. breach, what ever…

They exercised due care

Note: Auditors care about due care

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13
Q

Due Diligence

A

Providing a record or history of compliance and enforcement

Providing evidence that you are doing the right thing.. e.g. proof a policy was followed

Note: Auditors care about due diligence

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14
Q

Corporate Governance

A

the system of rules, practices, and process by which a company is directed and controlled

begins with policy

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15
Q
  1. Policies?

Corporate Policies?

A
  1. the foundation of corporate governance

Mandatory rules, practices and processes authorized and sponsored by Sr. Mgmt and followed by everyone under penalty if broken

  1. Requirements derived from regulatory/legal, contractual, or social/ethical compliance
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16
Q

How is Policy Implemented?

A

Management must adopt:

Standards/Frameworks
Baselines
Procedures
Guidelines

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17
Q

How should you adopt standards/frameworks to implement policy?

A

HW, SW, documents are deployed universally throughout the organization

Specific technologies are used in uniform ways

Standards are mandatory, everyone must follow them

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18
Q

How should baselines be used to implement policy?

A

The minimum level of protection or settings for specific platforms or environments should be established as a baseline

Baselines are derived from standards and are mandatory

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19
Q

How should Procedures be used to implement policy?

A

Step by step required and mandatory actions on how to accomplish or maintain the directives of the policy should be documented and followed

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20
Q

How should Guidelines be used to implement policy?

A

Not mandatory but used as best practices, recommendations, suggestions or advice for accomplishing a goal

e.g. optional, non-binding

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21
Q

Executive committees for governance

  1. Purpose
  2. Who is on the committee
A
  1. Determine Organizational requirements and determine Governance, Risk Management and Compliance
  2. Board of Directors, Shareholders, Stakeholders and Senior Management
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22
Q

Risk Management

A

identifying threats and vulnerabilities and quantifying and addressing risk associated with them

identify industry, legal and regulatory requirements and addressing risk associated with them

a cyclic, systematic process for monitoring, identifying, analyzing, evaluating/assessing risk to determine risk response: mitigating, transferring, avoiding, and accepting risk

To mitigate or reduce risk to acceptable levels
Includes Risk Analysis, Cost/Benefit Analysis, Deploying counter measures or safeguards, auditing, insurance, Business Continuity Planning, education, training, etc.

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23
Q

What measure does a Qualitative Risk Assessment use to assess risks?

A

Qualitative risk assessments use nonnumerical categories that are relative in nature, such as high, medium, and low. Quantitative assessments use specific numerical values such as 1, 2, and 3.

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24
Q

Risk Appetite

AKA, Desc

A

Risk appetite is the level, amount, or type of risk that the organization finds acceptable.

Organization is prepared to accept this amount or level of risks to meet its objectives

AKA Risk Tolerance

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25
Q

Organizations have four main ways to address risk?

A

Avoidance
Acceptance
Transference
Mitigation

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26
Q

Risk Avoidance

A

removing the technology or activity to remove the risk

it means leaving a business opportunity because the risk is simply too high and cannot be compensated for with adequate control mechanisms—a risk that exceeds the organization’s appetite.

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27
Q

Risk Acceptance

What should never happen with respect to managing risk?

AKA

A

The opposite of avoidance; the risk falls within the organization’s risk appetite, so the organization continues operations without any additional efforts regarding the risk

NEVER accept risk without avoiding, mitigating and transferring as much as possible based on business/compliance/due care conditions

Risk Retention

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28
Q

Risk Transference

A

The organization pays someone else to accept the risk, at a lower cost than the potential impact that would result from the risk being realized; this is usually in the form of insurance or outsourcing. This type of risk is often associated with things that have a low probability of occurring but a high impact should they occur.

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29
Q

Risk Mitigation

A

The organization takes steps to decrease the likelihood or the impact of the risk (and often both); this can take the form of controls or COUNTERMEASURES and is usually where security practitioners are involved.

30
Q

Internal Compliance Items

A

Mission/Vision Statement
Selected Strategies
Goals and Benchmarks

31
Q

External Compliance Items

A

Legislation/Legal

Regulatory/Oversight

Industry Standards

Customer Requirements

32
Q

List Compliance Standard Requirement Types

A

Regulatory/Legal

Contractual

Ethical/Social

33
Q

How should corporate policies/compliance requirements be tested/verified?

A

Compliance audit, either internal or external to ensure the company does what they say they do to comply with legal/regulatory, contractual, and ethical standards

34
Q

Laws Considered for GRC

A
International Law
State Law
Federal Law
Privacy Law
Criminal Law
Common Law/Tort
35
Q

International Law

A

Rules that govern relations between countries

36
Q

State Laws

A

typically refers to laws of each US state but can refer to geographic divisions (e.g. state, provinces) within any country

37
Q

Privacy Law

A

Laws that generally protect the rights of an individual within a country; Can extend to PII of the individual housed in a different country

38
Q

Federal Law

A

The body of laws used to govern a sovereign nation

39
Q

Criminal Law

A

Typically rules and statutes that define contact prohibited by government to protect the SAFETY and well-being of the public, punishable by jail, death, fines, loss of certain individual rights

40
Q

Common Law (Tort)

A

Laws that seek to COMPENSATE victims for injuries suffered at the hand of another ex Lawsuit

41
Q

Investigations considered for GRC

A

Operational
Civil
Criminal

42
Q

Operational Investigation

What are potential penalties?

A

An investigation performed by the organization related to internal digital or other malfeasance

Penalty may include release from the company

43
Q

Civil Investigation, Penalties, Standard of Proof?

A

In the US and other countries, civil investigations are governed by Federal Rules of Civil Procedure

Based on TORT law, they seek to remedy a conflict between parties

Penalties are usually MONETARY and/or result in a court order

Standard of proof is a preponderance of evidence

44
Q

Criminal Investigation

Who governs/performs and what are potential penalties?

A

In a criminal case, it is the STATE against the individual which a jury or judge must find guilty

Penalties may include incarceration, monetary fines or death

45
Q

What are the concerns when a cloud provider becomes involved in an investigation?

A

Control over data
Multi-Tenancy
Data Volatility
Evidence Acquisition (especially e-disovery)

46
Q

E-discovery

What ISO relates to e-discovery?

A

Any process in which ELECTRONIC data is sought, located, secured, and searched with the intent of using it as EVIDENCE in a LEGAL case

ISO 27050

47
Q

Legal Hold

A

If a party reasonably anticipates litigation it must SUSPEND its routine document retention destruction policy and put in place a hold on relevant documents

48
Q

Spoliation

A

The intentional or accidental DESTRUCTION or ALTERATION of data that is either under legal hold or lawfully requested by a court

49
Q

Production - GRC

A

The PRESENTATION of the requested data to the court or to the requesting party

50
Q

Agent of the Government

A

When a PRIVATE citizen who has been given government AUTHORIZATION to act on behalf of the government, they must follow the same rules as the government

51
Q

Warrant

A

A court order AUTHORIZING law enforcement to gain entry and to search for items or persons for seizure

52
Q

Subpoena

A

A written legal order summoning a witness or requiring evidence to be submitted to a court

53
Q

Doctrine of plain view

A

Allows law enforcement to seize objects not described in a WARRANT when executing a lawful search or seizure if they observe the object in plain view and has PROBABLE cause to believe that it is connected with a criminal activity

54
Q

Extradition

A

The REMOVAL of a person from a requested state to a requesting state for criminal prosecution or punishment

55
Q

Jurisdiction

A

The authority granted by law to the courts to rule on a legal matter and render judgments according to the subject matter of the case and the GEOGRAPHICAL region in which the issue took place

56
Q

Harmonization of Law

A

the process of creating common standards across the internal market specifically in the EU

The process of achieving technical EQUIVALENCY and enabling interchangeability between different standards with OVERLAPPING functionality. Harmonization REQUIRES an architecture that documents key points of interoperability and associated interfaces ex. the user of directives in the EU

57
Q

Rules of Evidence Admissibility

A
  1. Be AUTHENTIC - the evidence needs to be tied back to the scene
  2. Be ACCURATE - evidence must maintain authenticity and veracity throughout the evidence lifecycle
  3. Be COMPLETE - all evidence should be collected, including evidence that support and that can diminish the reliability of the other incriminating evidence
  4. Be CONVINCING - evidence should be easy to understand and believable to a jury
  5. Be ADMISSIBLE - evidence must be able to be used in a court of law
58
Q

Digital Forensics Phases

A
  1. Collection - identifying, labeling, recording, and acquiring data from a possible source of relevant data
  2. Examination - processing collected data
  3. Analysis - analyzing the results of the examination
  4. Reporting - reporting the results of analysis
59
Q

Chain of Custody

A

A complete, verifiable record of handling evidence from the moment of acquisition through destruction or return

A chronological paper trail documenting evidence that was gathered, who had it and when (documenting and controlling evidence handling)

Integrity is the upmost importance

Must be maintained while evidence is identified, gathered, protected, accessed and presented

60
Q

Non-Repudiation

A

The ability to prove that the evidence is the original as acquired from the system

61
Q

Probative Value

A

Evidence that has some benefit to the court case or interest to the court. It must prove something.

62
Q

Provenance

A

The ability to track back to the original creation of the evidence

63
Q

How do you capture Digital Evidence in order to ensure you gather all that may be available given time?

A

Start from the volatile forms then go to more persistent forms

Volatile items cant be recovered after a reboot

64
Q

Order of Volatility

A
  1. Live system info (RAM, process list, unsaved work, encryption keys, etc.)
  2. Virtual memory (Paging file/swap file, temp file)
  3. Physical media - HD, DVD, USB, printouts
  4. Backups and networks - back up media server logs files, cloud storage
65
Q

Shadow IT

A

Shadow IT, occurs when cloud users access and use cloud systems and resources that have not been authorized by their organization.

Unsanctioned or unapproved cloud workloads or utilization of unapproved devices or VMs within the enterprise

66
Q

Risk Profile

A

The willingness of an organization to take on risk as well as the threats it will be exposed to

67
Q

Exposure

A

Actual or anticipated damage from a threat

68
Q

How do you calculate Annual Rate of Occurrence?

A

Asset Value (AV) x Exposure Factor (EF) = Single Loss Expectancy

of incidents/ # of years = ARO

69
Q

How do you calculate Annual Loss Expectancy?

A

Single Loss Expectancy (SLE) x Annual Rate of Occurrence (ARO) = Annual Loss Expectancy

70
Q

Controls Gap

How is this calculated?

A

The amount of risk that is mitigated implementing countermeasures

Controls Gap = Total Risk - Residual Risk
If I am 100% exposed, and after mitigation, I am 5% exposed, then controls gap is 95%

71
Q

Residual Risk

A

smaller amount of risk that remains after mitigation or transference or avoidance and must be accepted