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Risk Assessment & Compliance

What Churches Need to Know About Security Risk Assessment!

Posted on February 23, 2013 11:39 am by Caroline Ramsey-Hamilton Comment

the problems that churches face has changed since the 1950s.  Churches were considered “safe”, but the Sikh temple shootings in Wisconsin, shootings in Colorado Springs Churches, and the burning of black churches, have changed the security posture of churches.

Take a look at violence in churches today.  In 2008, the FBI recorded 23,547 crimes attributed to location code for “Church/ Synagogue/Temple”.  Deaths from church attacks rose 36% in 2012 according to the January 30, 2013 edition of Christianity Today.  Guns were used in nearly 60 percent of all “deadly force incidents” at churches since 1999 according to Carl Chinn who has been tracking these incidents.

Arson incidents are so widespread that the Dept. of Justice has a National Church Arson Task Force, and “Arson at churches has been a problem for a long time,” said Patrick Moreland, an executive with the Wisconsin-based Church Mutual Insurance Co., which insures 63,000 houses of worship.

No church leader, or church member wants their place of worship to become a crime scene, as the country watches it unfold on CNN.  And there’s a pro-active way to analyze a church’s security profile

And determine:

  • How Likely the Church is to have a Violence Incident
  • What Other Churches in the area are experiencing
  • What the Threat Level is in your Geographic Area
  • Exactly What Controls You Need to Add to Stay Safe

A Security Risk Assessment is a quick, easy to use model that can take streams of data and information and use these actual events to produce a simple report that can track the threat levels, and match these to potential and existing controls to see how existing controls can be implemented, what new controls need to be added, and how to do it all in a cost-effective way.

One of the key points of a security risk assessment is that it measures solutions in terms of COST-EFFECTIVENESS.  No one wants to over-spend on something and not have enough money left for a critical security element.

Out in the field, we often find that controls are not effectively implemented, or they are not 100% implemented, and if there’s even a 10% gap, it’s just like the control never existed at all.

And you don’t need to be an expert to perform a security risk assessment on your church, school, temple or summer camp.  There are new automated software applications, like Church Facilities Risk-Pro, similar to the app on your iphone, that will do the assessment for you, showing you the data you need, and even writing and formatting the reports for you.

The Control Reports become a blueprint for improving security and can become part of a 3-year plan that will protect the physical facility, the congregation, and the entire community.



Assessing School Security Takes on New Dimensions after Sandy Hook Tragedy

Posted on December 17, 2012 2:40 pm by Caroline Ramsey-Hamilton Comment

After 30 years of security risk assessment experience and working with hundreds of schools, hospitals, facilities, I have to say that schools have not taken school security seriously.

Obviously there are the social pressures including mental health screening, proposed assault weapons bans, gun owner screening, etc., but these are the thing that won’t change overnight. EVEN IF THEY ARE LEGISLATED, it takes time to implement, and
implementation may not be perfect.

TODAY IS THE DAY TO DO A SCHOOL VIOLENCE ASSESSMENT – not tomorrow, not after new gun laws, not after the holidays — TODAY.

There are indicators you can look for to see if your school is at risk of an active shooter incident. And ways to be prepared if the unthinkable happens and an active shooter comes to your school.

Strong, simple access control is the most effective solution, and yes, this may mean that
a plain glass front door or window is not enough. Glass is easily broken, and yes, it means that all staff must be a little more accountable, and it probably means a red phone or connection to the local police.

There is a simple school risk assessment program that will give guidance on what you need to do TODAY, what controls you need to implement, what threats are most likely to occur. These can be accessed on the www.riskandsecurityllc.com website.

Some things are preventable, some aren’t. But lockdown drills, alarm systems, and active monitoring of cameras are just a few of the 60 controls every school should have in place to protect our precious children.

 

About Caroline Ramsey-Hamilton

Caroline Ramsey-Hamilton is a leading expert in assessing risk in different areas, including security risk assessments, workplace violence and security for hospitals, cybersecurity, nuclear security, and also measuring compliance with security standards like FEMA 426-428, Joint Commission, HIPAA and OSHA. She is currently working on a universal set of easy security tools that will make it easy to assess risk in a variety of companies, agencies and business. Her company, Risk & Security LLC, works with more than 500 clients around the world using a program that standardizes site surveys and assessments and makes it easier to compare facilities and measure their level of security. Caroline is a member of the ASIS Physical Security Council, the ASIS Information Technology Security Council, the Security Assessment Risk Management Association (SARMA), and a Board member of the IAHSS (International Assoc. for Hospital Safety & Security) in Florida. She received the Distinguished Service award from the Maritime Security Council, and the ATAB Distinguished Service award in 2011. You can reach Caroline at caroline-hamilton@att.net or thru her web site at www.riskandsecurityllc.com She posts breaking security & risk alerts at www.twitter.com/riskalert.

 



Why the HIPAA Risk Analysis should be finished by December 31, 2012

Posted on September 4, 2012 1:48 pm by Caroline Ramsey-Hamilton Comment

The federal regulators from the U.S. Department of Health and Human Services are from the Office of Civil Rights.  They think that breaches in patient information protection is a violation of the patient’s civil right!   Regulators commonly assess fees for non-compliance and some are as high as $4 milion dollars.

Because the OCR just came out with new Audit Guidelines this summer (email me and I’ll send you a copy), we all can see that the visits to healthcare organizations are still speeding up, and even more rules are coming this fall as they reconcile the HIPAA Security Rule with the HIPAA Privacy Rule with the Breach Notification Rule.  I call this:  MEGA HIPAA!

Because the current HIPAA rules have been in place for over ten years, and because the new Rules may be much more complex, it makes sense to finish your 2012 HIPAA Risk Analysis for either Security or Privacy, or both, before December 31, 2012.

My experience with federal regulators and auditors leads me to believe that a HIPAA Security Risk Analysis that is finished before the end of this calendar year will go a long way in reassuring regulators that there is, at least, a formal process in place to assess the risks to patient medical information.

A new software program is based on my original free Data Collection Guide,and can be used to complete these important security rules at a fraction of the cost of older, out-of-date risk analysis programs. Or do it on a spreadsheet.

Remember, you can also use it in your Meaningful Use Risk Assessment.  A two-for-one.

My advice:  Take the easy way out.  Finish the Risk Analysis!

 

 



Man Wants to Commit Suicide at Hospital to Donate his Organs!

Posted on March 6, 2012 8:29 am by Caroline Ramsey-Hamilton Comment

Suicidal Man Triggers an Evacuation in Denton, Texas.

The emergency department at Texas Health Presbyterian Hospital was evacuated after an armed man threatened to shoot himself in the hospital’s parking lot, as reported in a newspaper article. The man had sent suicidal messages to his ex-wife. She contacted police, who in turn began tracking the man’s cell phone. He was found in his vehicle, which was parked in front of the hospital’s ED. Police cleared the ED while they negotiated with him for about 45 minutes. The man told police he chose the hospital because he wanted to donate his organs after he killed himsel



Man Makes Meth in his Car in Hospital Parking Lot

Posted on March 5, 2012 7:18 pm by Caroline Ramsey-Hamilton Comment

Hospital security cameras showed that a
33-year-old man was making meth in his car in the facility’s
parking lot before the vehicle became engulfed in flames.
The man was burned over 80 percent of his body and
later died of his injuries. The car, which was in the Horizon
Medical Center lot, was captured on security video that
showed the man mixing ingredients just before there was
fireball inside the car. A sheriff’s office detective working
security at Horizon requested assistance to put out the fire.
In examining the site, he noticed canisters and other possible
drug-related items in the car and called the drug task force,
according to news accounts



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



Why Violence in Hospitals is Increasing

Posted on January 9, 2012 5:13 pm by Caroline Ramsey-Hamilton Comment

Why Violence in Hospitals is Increasing

Violence is not a concept that people usually associate with hospitals.  For years, hospitals have been seen as almost a sanctuary of care for the sick and wounded in our society.   However, the perception of hospitals has been changing over the last fifteen years due to a variety of factors. 

  1. Doctors are no longer thought of as “Gods”.  This means they are
          are more easily blamed when a patient’s condition deteriorates.
     
  2. Hospitals are now regarded as businesses.  This perception has been
           been aggravated by television in shows like a recent “60 Minutes”, as well as
           by the effects of the recession on jobs and the loss of health insurance.
  3. Lack of respect and resources (funding) for hospital security departments
              Rather than being seen as a crucial protection for the hospital staff and
          patients, many security departments are chronically underfunded and used
          for a variety of non- security functions, such as making bank deposits for
          the hospital gift shop. 
  4. ASIS Security Association issued it’s industry guidelines for Workplace
         Violence     Prevention in September 2011, in conjunction with the SHRM – the
         Society for Human Resources Management to address this issue.

    The federal government   issued a guidance document for dealing with violence issues in healthcare,   OSHA 3148.01R, 2004, Guidelines for Preventing Workplace Violence for Health Care & Social Service Workers.

To Learn more:  join my webinar on Thursday, January 12th at 12 noon Eastern time by
       Clicking on this link:  https://www2.gotomeeting.com/register/835835290.



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!



Crime and Punishment II – Sentencing of Rod Blagojevich

Posted on December 7, 2011 6:01 pm by Caroline Ramsey-Hamilton Comment

Today marks a historic day in the State of Illinois.  While the previous governor is still in prison on corruption charges, out-going, loud-mouth Rod Blagojevich is in court to receive his sentence on federal corruption charges.

This is a great moment for the judge and the judicial system to hand out a sentance that will help PERMANENTLY end the endemic corruption in the Illinois executive branch.

Americans always point out corruption issues in other countries — but this is the MidWest — the Heartland of America.  In fact, I know people who ONLY hire people from the midwest because they think they are more honest and more hardworking.

So I hope that this verdict will uphold justice because I firmly believe that a country is only as good as it’s justice system.  It defines everything else that happens (read my previous post on the SEC failures to enforce).

Every judicial decision, even a non-decision, sends out a strong message to the next potential corrupt politican that the State of Illinois, and the US as a whole, cannot allow corruption in our elected officials!

 



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!

 




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