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Corporate Security

Planning an Active Shooter Drill, Why Once is Not Enough

Posted on October 17, 2013 8:25 am by Caroline Ramsey-Hamilton Comment

Almost every day I get a note that a hospital or corporate facility is planning to have an Active Shooter Drill.  That is always good news because it is a critical part of preparedness that protects not only against an active shooter incident, but also prepares the staff for other emergencies, but it may not be enough.

I’ve found that to be really effective, drills need to be supplemented with short training sessions, and also awareness programs that teach staff to be on their toes, or “situationally aware”.   Security awareness training doesn’t have to be a full time job and it doesn’t have to be expensive.

One of the best ways to create an on-going security awareness program is to make a 12-month calendar, with an activity for each month, or better yet, every two weeks.   Here’s a list of activities I use:

1.  Start with a one page newsletter.  You can have the marketing department help, or use WordPress to design your
own newsletter and email it out to all the staff.  Whether your staff is 100 people or 6000 people, it’s a great way to promote the security program.

2.  Send out very short emails highlighting news items about security incidents at other companies, especially ones in your industry, for example, hospitals.  If there’s a terrible incident at another hospital, cut and paste the story and email it to everyone.  In fact, if you’re an IAHSS or ASIS member, their publications have great stories about different security situations.

3.  Use seasonal reminders.  Now that it’s late October and daylight savings time is almost over, send an email reminding staff how to stay alert when they leave the facility after dark and head for their car.  How to use the escort service, if that’s available, or how to use your keys as a weapon in a potential incident.

4.  Buy posters to put in the cafeteria, or in the elevators that serve as reminders about the concept of staying alert and aware of your surroundings at all time.

I have interviewed more than 8000 staff members in the last 10 years, and they welcome these reminders and feel more secure just because you are keeping awareness up.   Remember, it also reminds everyone that there is a Security Department, and that is working every day to keep them safe.

The Department of Homeland Security also provides free brochures and charts you can print out and give to employees, or you can email them for the staff member to print out and put in their purse.  There are wallet sized cards, and lots of other great information you can use in your own active shooter awareness program.

Check out the preliminary OIG Report, which was leaked to Time Magazine on their swampland.com site at

Read more: http://swampland.time.com/2013/09/16/exclusive-navy-yard-dropped-its-guard-pentagon-inspector-general-says/#ixzz2f6qWCshc

 

 



Will the Risk of the Sequester Affect Security Budgets in 2013?

Posted on February 26, 2013 9:59 am by Caroline Ramsey-Hamilton Comment

Every time the TV is on, every anchor is crying about the dreaded Sequester.

Will it have an impact on security budgets?  I have seen security budgets, especially for the facilities security departments, swing from almost unlimited budgets after 2001, to bare bones in 2009 and 2010, and thought they were trending back up for 2013.

Now, with the uncertainty about what a Sequester  actually is, (please note my use of the capital “S”), how will it affect our security departments?

Obviously, the most obvious casualty are the government contractors who’s contracts may be arbitrarily cut, and civilian managers of federal programs will see lost days and furloughs.

The trickle-down effect will probably extend to state, county and municipal governments, too.   So that means it’s even more important to start budgeting new security controls so that the most important get the funding!

One of the themes we go over in our webinar programs is how important it is to create a COST JUSTIFICATION and Return on Investment information so that you can create a business case for every control you need to improve security.

And one more thought on the Sequester – we often see an increase in crime, white collar crime and fraud when things are unsettled and people aren’t sure what’s going to happen next.

Maybe it’s a good time to do another risk assessment?  Maybe the Sequester is the next new Threat!

 

 



Data-Driven Security: The Best Way to Improve Security for Anything, Anywhere

Posted on February 5, 2013 3:44 pm by Caroline Ramsey-Hamilton Comment

How can you improve your security program?  Are we talking about a seaport?  A church?  A manufacturing facility?  A gas pipeline?  An office building?  Corporate Headquarters?   Zoo?  Hospital?  Bank?  Clinic?  City Hall?  Harbor?  Stadium?  Government Agency?

It doesn’t matter what you need to protect — if you decide it is a critical asset, it needs good, continually improving security, and
an on-going assessment program is the fastest, easiest way to get it.

If wonderful, dedicated you, (as the security pro), don’t know what’s working and what’s not, how can you improve the overall program, unless you wait for an “precipitating event”, like a THEFT, like an ASSAULT, like a FLOOD, or a HURRICANE, or a POWER LOSS, and then you immediately start working on that and making sure THAT particular disaster doesn’t happen again!
Meanwhile, everything else is slowly losing energy due to lack of constant attention.

And so let’s say you are the Super Bowl, and the power went out!  Terrible. Inexcusable.  And you’re busy getting a 2nd or 3rd backup generator to make sure THAT POWER LOSS never happens again.

This problem with this model – fixing what’s broken and ‘learning from experience’ is that it’s always a day late.  You’re always chasing after something that already happened.

Instead, you can  set up a program so that you use to continually evaluate the current condition, assess the risk, and then improve the security controls, based on THAT RISK ASSESSMENT.

Tony Robbins used to call it CANI –

  • Constant And Never-ending Improvement.  You can accomplish this by setting up regular assessments and then adjusting or tweeking the security controls to adjust to the new, or more aggressive threats.
    “Regular” assessments can be monthly, quarterly, semi-annually, annually, bi-annually, whatever schedule suits you and the organization.   The idea is that by continually reassessing your last improvement,and changing the threats and risk level,
    you can create a dynamic, data-driven security program that improves the security profile dramatically, without having to
    suffer through another triggering event!
    The concept of CANI – Constant And Never-ending Improvement can breathe life into your security program, you can use it to improve your health, your fitness level, your guitar playing, your _______________________.
    You fill in the rest!

 

 



Preview of the Webinar on Workplace Violence Prevention

Posted on March 27, 2012 5:28 pm by Caroline Ramsey-Hamilton Comment

Companies often don’t think about preventing workplace violence until there is an incident that affects them, or a company similar to them, or geographically close.  As soon as something happens close to home, they want to get serious and do something about it right away.

Workplace violence prevention is actually a process that, like in quantum physics, when we talked about the observed particle, just putting management’s attention on the potential problem will start the prevention process.

A good place to start is with adjusting and updating your policies.  Perhaps your policy is outdated, or hasn’t been publicized in your organization.   Time to dust it off and make sure it includes these critical elements:

1.  It says:  We have a total no-weapons policy in this company.

2.  Employees are REQUIRED to report any potential, or even suspected workplace violence situations or incidents.

3.  There is an approved company form which every employee has electronically, to use
if necessary.

4.   Every employee has to attend a violence prevention training course, or active shooter drill, or both, annually.

The policy is the first step.  Next, the policy has to be approved by the management or by the Board, and then sent to every employee, along with an affirmation agreement that they sign saying they read the policy and understand it.

More tomorrow… or attend our special workplace violence webinar.  You can sign up at:

http://t.co/rKBuoDgt



Use A Data-Driven Security Program to Transform Organization Security

Posted on February 22, 2012 2:45 pm by Caroline Ramsey-Hamilton Comment

Data-Driven Security

How to Target, Focus and Prioritize
The Security Program

  by Caroline Ramsey-Hamilton

Management has to have Metrics

Management of a security program is no different than management of cash flow, employee productiveness, profitability, or any other set of metrics that organizations use to measure how well something is being done, and how it could be improved. Historically, however, security has been run by a few unique professionals, perhaps with a military or law enforcement background and the security program has existed in a vacuum, with few ways to measure it’s effectiveness and value to the organization, except to list what hasn’t happened!

Security officers may complain that management is not listening to their complaints, including not making enough money available to implement new technology, or to fix a loophole that has the potential to create havoc in the organization. Many security conferences feature sessions with titles like “How to Sell Security to Management” and try to address this disconnect between senior management and their security programs.

Peter Drucker, the world famous management consultant, said “If you can’t measure it, you can’t manage it.”

Very recent improvements in security technology, camera technology and its integration with computer networks and information security has allowed a massive amount of data to be collected.  Everything from digital images, to incident reporting and tracking, and even internet-based reporting of technical vulnerabilities, allow management metrics to be applied to the management of the security program to target the program to be maximally effective, to focus the available dollars in the areas which would provide the most protection for the least amount of money, and to prioritize the controls that need to be improved or implemented, based on their return on investment.

Security has never been more important to the organization. Many court cases recently have been decided on the basis of whether the organization was using ‘due care’ and utilizing every ‘reasonable’ security precaution. Existence of adequate security has become very important in premises liability cases and will likely become equally important in future litigation.

Risk assessments are the foundation of a data-driven security program. Through the process of risk assessment, managers can measure the effectiveness of the organization’s total security program, including analyzing the value of the organizational assets, the threat level (based on the mission of the organization), the existing vulnerabilities, and the effectiveness of existing controls. Basing the risk assessment on the concept of data-driven security means that real numbers are used in the following areas:

1. Determining the value of the assets of the organization, including the facilities, the personnel, products, production facilities, raw materials, transportation, vehicles, information technology equipment, data and information. In additional to quantifying present day replacement value, the sensitivity of various information assets and a determination of their criticality to the main mission of the organization must be determined.

2. Analyzing the Threat Level affecting the organization, including analyzing of incident report logs which would indicate how many potential intrusions have been attempted, as well as an analysis of physical intrusion indicators, such as missing badges, any security incidents, and any indications of industrial espionage which have been reported, either at the facility under review, or at any of the organization’s other facilities. Industry data on intrusions in similar companies or analogous agencies is also very helpful in determining threat level.

Many companies now use reports which quantify threat data, including statistics on criminal activity by exact location, by zip code (such as the Uniform Crime Index) as well as many information sources of weather data, such as NOAA (U.S. National Oceanographic and Atmospheric Administration, various international associations and government agencies.

3. Identifying vulnerabilities in the organization, including surveying individuals at every level of the organization, from the receptionist to the CEO.  To ascertain the weaknesses in the way the employees comply with security, there are new electronic survey tools,( like Risk Watch®)  which measures security compliance against published standards such as FEMA 426, (How to Protect Buildings Against Terrorist Attacks). control standards.  New regulations, like Joint Commission, Behavioral Health and Workplace Violence (OSHA 3148) require such compliance-based
baseline assessment surveys.

4. Identifying potential categories of loss, which would include components like direct losses (damage/destruction), injury or death to either staff or patients/customers/vendors; theft of property or product,  theft of data/information,  and loss of an organization’s reputation. These loss categories are used to quantify the effect of threats on the organization because you can estimate the loss impact on various functions of the organization.

5. Safeguards (Controls) include all the possible controls that could protect an organization either by reducing the likely of a threat occurring, or reducing the amount of damage that the organization sustains from a threat that materializes. Controls are quantified by:

a. Life Cycle of the Control – How Long They are Good for.

b. Cost to Implement the Control to 100% in the organization

c. Indication of the percentage that the control is already implemented in the organization

By accumulating data in these 5 categories, it becomes possible to run scenarios that pair the threat and vulnerability, match it to organizational assets, analyze the loss potential, and evaluate the cost effectiveness of a variety of different controls.

Advantages of a Data-Driven Security Program

The primary advantage of a data driven security program is that it provides support for the security function within the organization by being able to illustrate directly how security not only protects the organizational assets, but also, how the security profile changes over time.

In addition, it becomes possible to benchmark the various plants and facilities against themselves, and against both domestic and international standards, including military standards for the Defense Industrial Base. For example, if a multinational company with facilities and networks around the world can analyze their security based on the principle of a data-driven security program, then they can instantly identify the areas or facilities that have problems and address them much more quickly and effectively than they could if they were depending on a fuzzy, quantitative assessment method. When an organization makes the decision to adopted a more disciplined approach to analyzing security risk, they must also use all the other typical management functions such as planning, development of a budget and incorporation of the plan into the organization’s overall planning.

After the initial baseline risk assessment, and using the input from the analysis, the organization can began to develop implementation strategies to address the vulnerabilities identified in the assessment. As each vulnerability is addressed, cost-effective mitigation strategies can be put in place.

At the same time,  the security plans and policies can be measured so that policy changes can be made, if necessary, or training and awareness programs can focus in the areas that need reinforcement with the organization.

The Security director, using his already established budget and implementation timelines for each safeguard, can then manage the improvements, using either internal staff or he can make the decision to outsource the additional controls (or their implementation).

These improvements can be tracked themselves, to establish how effective they are in their individual tasks, and also can be periodically re-assessed to see how the organization’s total security profile has improved.

The first benefits from a data driven security program emerge during this implementation phase because not only can you measure how much more effective the new security configurations are, but there is an additional value-added component of
re-acquainting the employees with the security program and increasing awareness across the organization.

To ensure continued value in the program, collection mechanisms such as automated incident response, threat reporting and vulnerability reviews must be automated. There are new security software programs that evaluate and analyze these types of data and can dramatically increase the effectiveness of a data-driven security program.

This type of data-driven security program creates a security program that becomes a baseline for management to quickly assess the security profile of the entire organization.  It makes it easier to provide a safe, and secure workplace for both management and employees, and may decrease the possibility of a workplace violence incident, theft or domestic or international terrorist attack.

This data-based concept of risk management creates a bridge between executive management and the security professionals in the organization who now have an avenue for open communication, discussion and consideration of the role of security throughout the organization.

 

About the Author

Caroline Ramsey-Hamilton is the founder of Risk Watch International, and a leading security risk assessment expert.  She was a Charter member of the National Institute of Standards and Technology’s Risk Management Model Builders Workshop from 1988 to 1995.  From 1996-1998, she served on the working group to create a Defensive Information Warfare Risk Management Model,  (DIWRM2) under the auspices of the Office of the Secretary of Defense.  She was also a member of the National Security Agency’s Risk Rating Workshop and the IBM Data Governance Working Group to create a Data Governance model for the nation’s largest banks.

She has developed specialized risk assessment programs for HIPAA, Information Security, FFIEC, GLBA, Sarbanes Oxley, and corporate security programs including working with The Clearinghouse, large investment banks, the Federal Reserve and a variety of other Federal agencies on Risk Assessment guidelines.   In addition, she is a member of the ASIS Physical Security Council, SARMA( the Security Risk Management Association) based inWashington, D.C.  Ms. Ramsey-Hamilton is certified in Homeland Security and Anti-Terrorism and recently received a lifetime achievement award from the Anti-Terrorism Accreditation Board and the Maritime Security Council.

Hamilton works around the world on critical risk issues including a new set of risk assessment guidelines for the Nuclear Regulatory Commission, a risk model for airport security and a risk model for medication error with Philadelphia Children’s Hospital.

She has completed Risk Assessments for over twenty-five U.S. government agencies including the Department of Defense, the Technical Support Working Group, and the Nuclear Regulatory Commission, and many healthcare organizations including Cleveland Clinic, HCA, Sheikh Khalifa Medical City, the University of Miami Medical Center and many more.  She has written several books and articles over twenty-five different publications.

www.caroline-hamilton.com

caroline.r.hamilton@gmail.com

 

 

TWEET: http://twitter.com/riskalert



Data-Driven Security – Using Metrics to Focus & Target Security Programs

Posted on February 9, 2012 6:34 pm by Caroline Ramsey-Hamilton Comment

Security programs can be dramatically improved by using a metrics-based assessment to focus them on the areas of greatest threat, and to use metrics as a management tool to keep the security program targeted on the areas that need the most attention.

Using a data-driven approach – that is, using real numbers to measure
and quantify security, always results in tangible improvements.

Management of a security program is no different than management of any other department, whether it’s human resources, cash flow, employee productiveness, profitability, or any other set of metrics that organizations use to measure how well something is being done, and how it could be improved.

Security officers may complain that management is not listening to their complaints, including not making enough money available to implement new technology, or to fix a loophole that has the potential to create havoc in the organization.

Most security conferences feature sessions with titles like “How to Sell Security to Management” and try to address this disconnect between senior management and their security programs. Peter Drucker, the world famous management consultant, said “If you can’t measure it, you can’t manage it.”

Fortunately, recent improvements in security technology and in development of wider reporting of threats and vulnerabilities, allow management metrics to be applied to the management of the security program to target the program to be maximally effective, to focus the available dollars in the areas which would provide the most protection for the least amount of money, and to prioritize the controls that need to be implemented,  based on their return on investment.

Risk assessments are the foundation of a data-driven security program. Through the process of risk assessment, managers can measure the effectiveness of the organization’s total security program, including analyzing the value of the organizational assets, the threat level (based on the mission of the organization), the existing vulnerabilities, and the effectiveness of existing controls.

Basing the risk assessment on the concept of data-driven security means that real numbers are used in the following areas:

1.  Determining the value of the assets of the organization, including the facilities, the personnel, the security systems and the current controls.

2.  Analyzing the Threat Level, based on either internal incident reports, or industry data, including the Uniform Crime reports. 

3. Identifying vulnerabilities in the organization, including surveying individuals at every level of the organization, from the local facility manager to the CEO to find out how they are implementing security in their workplace.

4. Identifying potential categories of loss, which help focus the security program on the problem areas.

5. Analyzing current Controls that are currently in place, or that could be added to protect an organization.

By gathering data in these 5 categories, it becomes possible to run scenarios that pair the threat and vulnerability, match it to organizational assets, analyze the loss potential, and evaluate the cost effectiveness of a variety of different controls and prioritize security controls by “bang for the buck”.

Using data-based security builds a bridge between executive management and the security professionals in the organization who now have an avenue for open communication and consideration of the role of security throughout the organization.

 

 

 



Threat Modeling is the Exciting, Sexy Part of Risk Assessment

Posted on January 26, 2012 6:09 pm by Caroline Ramsey-Hamilton Comment

As a risk assessment professional, when I get into a risk discussion, most security people want to talk about THREAT!  Threat is the most sexy and exciting part of doing a risk assessment.

Threats are exciting all by themselves.  Think about all the threats you can name:

All the natural disasters like Earthquakes, Tornadoes, Storms, Hurricanes, Tsunamis, Lightning, Floods

Crimes like Homicide, Assault, Rape, Burglary, Theft, Kidnapping, Blackmail, Extortion

Terrorism like Sabotage, Explosions, Mail Bombs, Suicide Bombs

All the IT Threats like Malicous Code, Disclosure, Data Breaches, Theft of Data

And about 50 more including Chem/Bio incidents, Magnetic waves, High Energy Bursts, Microbursts, Contamination and Reputation Damage.

Each of these threats could theoretically occur at any time, but we try to establish a pattern of how often they have occurred in the past, in this location, in this county, in this country, in the company, etc.   So NASA, for example, gets thousands of hacker attacks, but another company, like the local Salvation Army, gets 1 every 10 years.

Same model for natural disasters, although you might have to factor in climate change, it’s easy to get the threat incidents for hurricanes in Florida, snow storms in Cleveland, earthquakes in northern California, etc.

We also like to examine industry specific data to see if some threats are higher in a certain industry, like the high incidence of workplace violence incidents in hospitals and high risk retail establishments (like Wawa or 7-11).

Another factor we use in calculating threat likelihood is how the threat could actually affect different types of assets…. for example, would an earthquake damage a car?  Probably not. Would it cause damage to an old historical building – probably (unless it had been retrofitted).  Could it cause loss of life, or injuries (think Haiti).

So I use a multidimensional model that takes the threats list (I have a standard list of 75 threats that I use), and map it to each potential loss, based on the ‘asset’ that might be affected.

The more data you get, the better your model will be, and the more value it will have as a decision support tool!

 



Outlook on Risk & Security Compliance in 2012 – What to Expect.

Posted on January 1, 2012 6:59 pm by Caroline Ramsey-Hamilton Comment

This New Year’s Eve, I thought at times my neighbors were using a rocket launcher and several assault rifles to shoot up the New Year.  Lucky for me,  I spent the awake time to contemplate the outlook for risk, threat and security issues for 2012 and here’s what I see for 2012.

1.  Government-Mandated Compliance Is Here to Stay for the Healthcare Industry.

I remember when the IT departments are many hospitals thought George W. was going to revoke the HIPAA Security Rule.  It never happened, and this year, for the first time, there is a regulatory body in place that is intent on REAL ENFORCEMENT.

The Dept. of Health & Human Services, Office of Civil Rights,  has expanded HIPAA Security and Privacy Rules to include “Business Associates” including lawyers working in healthcare, and the infamous “3rd Party Providers” who do everything from warehouse data to taking over the IT function of a hospital, and this trend will continue as pressure builds from consumers who’s medical and financial data continues to be compromised.

2.  Workplace Violence Prevention will become an OSHA mandate, if not in 2012, at least by 2015.  Based on the slug-like pace of OSHA, who only recently provided directives for high risk industries, and the pressure from the more than 30 states who have passed their own regulations,  the pressure to stop the number of incidents and to lower their intensities will increase and management will be forced to address it as a major corporate issue.

3.  Pressure on the financial industry to protect consumer information will increase.  Like many other areas, pressure is increasing to prevent the enormous data breaches we saw in 2011, like Tricare, the recent Stratfor hack by Anonymous, Wikileaks and HealthNet breaches.  Consumers are the squeaky wheel and they want the convenience of plastic and internet use, and they will not tolerate breaches, and they are all registered voters!

The FFIEC has already tightened up on both risk assessment standards, as well as
authentication guidelines for all financial institutions.

 

There will be a increase in requirements for risk assessment as an accountability feature to force managers to maintain better security in all areas of their organizations. 

Accountability means that individual managers will be held responsible for the decisions they make regarding other people’s:

1.  Financial Data

2.  Medical Records

3.  Safety from both Violence & Bullying in their workplaces.

Budgets can be cut, and staff can be reduced but consumers are demanding protection of their information, and themselves, and the regulators will make sure they get it in 2012!



HAS 60 MINUTES EXPOSED THE SEC SECRET – No Penalties for Big Banks?

Posted on December 5, 2011 5:06 pm by Caroline Ramsey-Hamilton Comment

On Sunday evening, December 5th,  60 MINUTES aired what I think is a ground-breaking bit of investigative reporting on how the SEC allowed big banks and mortgage companies to violate Sarbanes Oxley (SOX) requirements with total impunity.

Since the American public is still suffering from the mortgage meltdown – they are looking for answers and looking for punishment.  Crime and punishment usually go together in the Justice Department and law enforcement communities.

“You do the Crime – You do the Time”.

So one person is arrested for a victimless crime, like shoplifting a candy bar, but a big company, like Countrywide, or Bank of America, can crash a worldwide economy, lie on federal forms, commit perjury and saw intense financial destruction to millions of people, and they are allowed to keep the fortunes they made through this risky behavior, and, even better, there’s no jail time, no fines commensurate with crime, and no penalty for openly flaunting federal laws!!

WOW – what kind of message does this send?

For me, concerned day after day with helping organizations comply with federal mandates and laws, like SOX, and HIPAA, and OSHA, this makes a parody of compliance enforcement.

Companies spend millions of dollars to comply with these regulations, which are passed to protect the American public from exactly what just happened.  To find that the regulators are the ones who ignored the falsified attestations, forgave the lack of compliance and let these 21st century robber barons keep their ill-gotten gains makes me, and about 200 million other people, sick!

 



OSHA Starts New Enforcement Initiative for Workplace Violence Issues

Posted on October 1, 2011 2:38 pm by Caroline Ramsey-Hamilton Comment

On September 8, OSHA issued a new directive about enforcement activity on workplace violence issues.  This directive (CPL 02-01-052) takes effective on Sept. 8, 2011 and is called Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents.  It details new procedures for the OSHA inspectors, but it is also a valuable document to show employers what they can expect.

The directive follows the shocking news that in 2010, 18% of workplace fatalities were caused by assaults and violent acts, while only 14% were caused by falls, according to the Bureau of Labor Statistics.

Workplace violence incidents are even higher in the hospital and healthcare industries.

The new inspection directive shows how OSHA inspectors are going to look at employers to see whether they have performed a workplace violence analysis.  These assessments follow the security risk assessment model and should take into account the threat level at the organization, the history of incidents and examination of trends, and whether ‘accepted’ controls have been implemented at the place of employment.

Some of the ‘accepted controls’ they will be examining include:

  • Having a recent workplace violence analysis
  • Having a formal workplace violence training program in place
  • Showing the employer had incident reports to identity possible threat levels
  • Methods the employer used to inform employees of the risk of workplace violence
  • Evidence the employer has a workplace violence prevention plan in place
  • Evidence the employer has a current security plan
  • There are also a set of recommended physical controls that include proper lighting, cameras, curved mirrors, etc.

For more information, or a copy of the document, email info@riskwatch.com.




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