Professional Memo on Risk Management

Before you begin this assignment, be sure you have read the Small Merchant Guide to Safe Payments documentation from the Payment Card Industry Data Security Standards (PCI DSS) organization. PCI Data Security Standards are established to protect payment account data throughout the payment lifecycle, and to protect individuals and entities from the criminals who attempt to steal sensitive data. The PCI Data Security Standard (PCI DSS) applies to all entities that store, process, and/or transmit cardholder data, including merchants, service providers, and financial institutions.

Purpose of this Assignment

You work as an Information Technology Consultant for the Greater Washington Risk Associates (GWRA) and have been asked to write a professional memo to one of your clients as a follow-up to their recent risk assessment (RA). GWRA specializes in enterprise risk management for state agencies and municipalities. The county of Anne Arundel, Maryland (the client) hired GWRA to conduct a risk assessment of Odenton, Maryland (a community within the Anne Arundel County), with a focus on business operations within the municipality.

This assignment specifically addresses the following course outcome to enable you to:

  • Identify ethical, security, and privacy considerations in conducting data and information analysis and selecting and using information technology.

Assignment

Your supervisor has asked that the memo focus on Odenton’s information systems, and specifically, securing the processes for payments of services. Currently, the Odenton Township offices accept cash or credit card payment for the services of sanitation (sewer and refuse), water, and property taxes. Residents can pay either in-person at township offices or over the phone with a major credit card (American Express, Discover, MasterCard and Visa). Over the phone payment involves with speaking to an employee and giving the credit card information. Once payment is received, the Accounting Department is responsible for manually entering it into the township database system and making daily deposits to the bank.

The purpose of the professional memo is to identify a minimum of three current controls (e.g., tools, practices, policies) in Odenton Township (either a control specific to Odenton Township or a control provided by Anne Arundel county) that can be considered best practices in safe payment/data protection. Furthermore, beyond what measures are currently in place, you should highlight the need to focus on insider threats and provide a minimum of three additional recommendations.  Below are the findings from the Risk Assessment:

  • The IT department for Anne Arundel County requires strong passwords for users to access and use information systems.
  • The IT department for Anne Arundel County is meticulous about keeping payment terminal software, operating systems and other software (including anti-virus software) updated.
  • Assessment of protection from remote access and breaches to the Anne Arundel network: Odenton Township accesses the database system for the County when updating resident’s accounts for services. It is not clear whether a secure remote connection (VPN) is standard policy.
  • Assessment of physical security at the Odenton Township hall: the only current form of physical security are locks on the two outer doors; however, the facility is unlocked Monday-Friday, 8am-5pm (EST), excluding federal holidays.
  • Employee awareness training on data security and secure practices for handling sensitive data (e.g., credit card information) are not in place.
  • The overarching conclusion of the risk assessment was that Odenton Township is not fully compliant with the PCI Data Security Standards (v3.2).

Note: The Chief Executive for Anne Arundel County has asked for specific attention be paid to insider threats, citing a recent article about an administrator from San Francisco (see Resources). Anne Arundel County wants to understand insider threats and ways to mitigate so that they protect their resident’s personal data as well as the County’s sensitive information. These are threats to information systems, including malware and insider threats (negligent or inadvertent users, criminal or malicious insiders, and user credential theft).

Expectations and Format

Using the resources listed below, you are to write a 2-page Professional Informational Memo to the Chief Executive for Anne Arundel County that addresses the following:

  • Risk Assessment Summary: Provide an overview of your concerns from the risk assessment report. Include broad ‘goal’ of the memo, as a result of the risk assessment, the broad recommendations. Specific Action Steps will come later. The summary should be no more than one paragraph.
  • Background: Provide a background for your concerns. Briefly highlight why the concerns are critical to the County of Anne Arundel and Odenton Township. Clearly state the importance of data security and insider threats when dealing with personal credit cards. Be sure to establish the magnitude of the problem of insider threats.
  • Concerns, Standards, Best Practices: The body of the memo needs to justify your concerns and clarify standards, based on the resources listed below, at minimum. The PCI DSS standards are well respected and used globally to protect entities and individual’s sensitive data. The body of the memo should also highlight three current controls that are considered best practice; that is, you should highlight the positive, what is currently in place, based on the risk assessment.
  • Action Steps: Provide a conclusion establishing why it is important for Anne Arundel County to take steps to protect residents and county infrastructure from insider threats based on your concerns. Recommend a minimum of three (3) practical action steps, including new security controls, best practices and/or user policies that will mitigate the concerns in this memo. Be sure to include cost considerations so that the County is

getting the biggest bang for the buck. The expectations are not for you to research and quote actual costs, but to generalize potential costs. For instance, under the category of physical security, door locks are typically less expensive than CCTV cameras.

  • Be sure to review the PowerPoint presentation (in pdf format) Effective Professional Memo Writing that accompanies these instructions.
  • Use the Professional Memo template that accompanies these instructions.
    • Use four section subtitles, in bold.
      • Risk Assessment Summary
      • Background
      • Concerns, Standards, Best Practices
      • Action Steps
    • Do not change the font size or type or page margins.
    • Do not include any graphics, images or ‘snips’ of any content from copyrighted sources. The PCI Standards (PCI DSS) document is copyrighted material.
    • Paragraph text should be single spaced with ONE ‘hard return’ (Enter) after each paragraph and after each section subtitle. Note: Do not create a new ‘paragraph’ after each sentence. A single sentence is not a paragraph.
    • ‘Subject’ is the subject of your memo, not the course name or number.
    • Be sure to remove any remaining ‘placeholder’ text in the template file before submitting.
    • The length of the template when you download it is NOT the intended length of the entire memo. Your completed memo should be between 1.5 pages and 2 pages (total document, including the To:/From:/Re:/Subject header).

*Note: the Professional Memo is to be in a MS Word file and all work is to be in the student’s own words (no direct quotes from external sources or the instructions) *

APA documentation requirements:

  • As this is a professional memo, as long as you use resources provided with or linked from these instructions, APA documentation is NOT required.
  • Citing material or resources beyond what is provided here is NOT required.
  • However, you should use basic attribution and mention the source of any data, ideas or policies that you mention, which will help establish the credibility and authority of the memo.
    • For example, mentioning that the Payment Card Industry Data Security Standards (PCI DSS) identify a certain control as best practice holds more weight than simply stating the control is a best practice without basic attribution.
    • Mentioning that Wired Magazine reported that a City of San Francisco IT technician effectively hijacked and locked 60% of the city’s network capacity, is more effective than saying “I read somewhere that…”

Resources

1.Examples of Security Breaches Due to Insider Threats

San Francisco Admin Charged With Hijacking City’s Network

Microsoft database leaked because of employee negligence

General Electric employees stole trade secrets to gain a business advantage Former Cisco employee purposely damaged cloud infrastructure

Twitter users scammed because of phished employees

  • PCI DSS Goals:

(source: https://www.pcisecuritystandards.org/merchants/process)

3.      References

FBI. (2021). The Insider Threat: An Introduction to Detecting and Deterring an Insider Spy. https://www.fbi.gov/file-repository/insider_threat_brochure.pdf/view

PCI DSS. (2021, Feb. 12). Payment Card Industry Security Standards. https://www.pcisecuritystandards.org/

Jingguo Wang, Gupta, M., & Rao, H. R. (2015). Insider threats in a financial institution: Analysis of attack-proneness of information systems applications. MIS Quarterly, 39(1), 91-A7. https://search-ebscohost- com.ezproxy.umgc.edu/login.aspx?direct=true&db=bth&AN=100717560&site=ehost- live&scope=site

Professor Messer. (2014). Authorization and access control [Video file]. YouTube. https://www.youtube.com/watch?v=6aXMuJPkuiU

U.S. DHS. (2021). Insider Threat. https://www.dhs.gov/science-and-technology/cybersecurity- insider-threat

Wizuda. (2017). Data anonymisation simplified [Video file]. YouTube. https://www.youtube.com/watch?v=m9UxV4XaXwg

Yuan, S., & Wu, X. (2021). Deep learning for insider threat detection: Review, challenges and opportunities. Computers & Security. https://doi- org.ezproxy.umgc.edu/10.1016/j.cose.2021.102221

Keywords: risk assessment, insider threats, data security

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