Authored by:
Michael Kiefer, General Manager
BrandProtect
You are a target. Your institution is a target.
The rapid adoption of social media is creating serious security challenges for the
banking industry. In the near future, it is likely you will need to respond to a social
media incident impacting you, your board, your employees, your customers and
your loss reserves.
Welcome to the Internet. And welcome to your next headache. Social media
threats are an area seemingly beyond your control but well within your regulatory
responsibility.
So as a bank officer or director, how should you protect yourself from attacks that
target your rights, revenue and reputation but never touch your IT network?
Reports of data compromises and security breaches triggered by social media
are in the news almost every day. The ingenuity of Internet criminals continues to
surprise and amaze law enforcement.
How should you adapt your existing risk management and incident response
framework to accommodate threats such as identity theft, reputation extortion,
phishing (email attacks), Vishing (Voice attacks that compromise accounts),
SMShing (Cell phone Text message attacks), YouTube, Twitter, Facebook and a
whole host of evolving, new and yet to be named attacks, venues and buzz
words that can often times seem overwhelming?
In other words, how should your risk management and incident response
framework anticipate what former Secretary of Defense Donald Rumsfeld called
the “unknown unknowns?
"There are known knowns. These are things we know that we know. There are known
unknowns. That is to say, there are things that we know we don't know. But there are
also unknown unknowns. There are things we don't know we don't know."
Donald
Rumsfeld
As you plan for the unknown unknowns of social media, the massive public
relations SNAFUs of Domino’s Pizza (Employees/conduct/YouTube) and
Barclays (Blog posts/pre corporate disclosure) should weigh heavily on your
mind.
Not too long ago, Toby Bell, a leading analyst at Gartner Research, published a
paper entitled “Policies and Procedures to Manage Enterprise Internet
Reputation.”
The Gartner team discussed social sites that can have an impact on corporations
and brands. They found that “social media is an unfamiliar territory for
enterprises, with very different rules for engagement,” and that “…social media
blurs the demarcations between public and private information, increasing the
likelihood that consumers will unintentionally or negligently say publicly what they
meant to say privately.”
The Net-Net is that bank officers and directors need to understand the risks of
these mediums and have a clear plan for monitoring, managing and mitigating
threats that can and will occur.
New factors impacting your risk management framework
These threats bulleted below illustrate the type of social media infractions that
can occur against your brand on the Internet.
Quick! Who owns these threats? And, how will you respond when they happen?
The ownership of these threats is not always clear.
Socially networked enterprises risk business disruption, brand damage, and even
loss of consumer Personal Identifiable Information (PII).
Since the attacks occur beyond the network perimeter or outside the firewall, IT
is only marginally involved. Branding and marketing and public relations are
interested but lack the process necessary to manage risk. E-business and
human resources are shared services that provide training and development
capabilities. Corporate legal, security and fraud don’t have the budget. Ops
doesn’t have the staff. So who is responsible?
No clear ownership of social media risks creates additional risks. Do not assume
someone else is paying attention.
The lack of organizational ownership plus the other unknown unknowns of social
media leave many shareholders, executives and board members wondering
about their risk exposure.
Enter Enterprise Internet Risk Management
Online attacks, identity theft and Internet fraud can never be completely defeated, only mitigated.
As a result, there is now urgency for someone to immediately establish an
enterprise-wide state of readiness to combat brand abuse from social media and
identify ways to reduce the severity of reputational risk to the corporate brand.
Organizations must attest to the effectiveness of their internal processes.
An enterprise-wide approach is necessary to properly manage these rapidly
evolving threats.
Enterprise Internet Risk Management (EIRM) eliminates traditional silos where
each area of the organization manages risks separately and instead builds
capacity using integrated processes, people and technology all working to
minimize the damage that can be inflicted on both corporate brands and
customer trust.
In adopting EIRM, there are certain industry best practices to keep in mind:
These industry best practices are captured by the Brand Protection Roadmap set
out in Figure 2:

In essence, this strategy postulates that certain policies, processes and
procedures should be established in the early stages of a brand protection
program to ensure a high probability of success. An effective brand protection
strategy should contemplate such issues as resource and process requirements,
timelines, deliverables and expected outcomes, and often includes the following
elements:
One of the primary objectives of an effective brand protection program is to
enable organizations to establish long-term policies, strategies and processes
that involve cross-functional participation to improve online asset management.
With this type of long-term corporate focus on risk management and prevention,
companies can often minimize the damages resulting from online criminal
activity, as illustrated in Figure 3.

To gain access to these benefits, however, it’s important for organizations to look
for service providers with a key set of capabilities, including:
As the CMO Council report states:
“A company’s reaction to a breach affects the brand trust, which is why
marketers must generate comprehensive response plans. A company that delays
its response to a breach, provides vague statements, or refuses to comment
altogether only increases that damage to its reputation that began with the
breach itself. A response plan should be designed to demonstrate, quickly,
www.fmsinc.org 6 © 2009 Financial Managers Society, Inc.
clearly and publicly, that a company is fully committed to addressing the problem
and undoing any real or potential damage to customers.”
To mitigate the negative effects of security breaches, organizations are finding it
necessary to develop formal incident response programs (IRPs). However, at a
time when organizations need to be most prepared, many banks are finding it
challenging to assemble an IRP that not only meets minimum requirements (as
prescribed by Federal bank regulators), but also provides for an effective
methodology to manage social media security incidents for the benefit of the
bank and its customers.
Designing an incident response plan (IRP)
Internet attacks on your brand in a planned and coordinated fashion is critical to
the success of your EIRM program.
First, understand that prevention is probably impossible. Every bank is
susceptible to the many evolving threats including threats from disgruntled
employees and customers.
Formal incident response planning combined with strong internal awareness
training will not prevent future incidents but will allow you to rapidly reduce the
level of brand damage.
While regulatory agencies mandate certain IRPs be part of your information
security program, social media and brand related attacks fall into a grey area
outside of Information Security’s responsibility.
Using Federal Bank guidance to incorporate social media brand attacks into IRP
is a simple process. Developing a social media or a brand attack IRP is in the
bank’s best interest and will make your brand stronger over the long-run.
In many ways an IRP is similar to disaster recovery planning. A solid IRP will
anticipate the unknown unknowns and work to patch weak points in the brand
perimeter. The need for comprehensive response programs is real and required
by the banking industry.
Although preparation may require considerable time and cost, the benefits can
be well worth these expenditures.
Metrics for performance management
When adopting an online brand protection strategy, a final issue to consider is
the availability of robust performance metrics that enable you to measure the
effectiveness of the approach at an enterprise level. In this way, companies can
assure that the business value of protecting their brands and various intangible
assets gets measured, acted upon and assessed by executive management.
For most organizations, experience shows that the most common forms of online
infractions are likely to occur on an ongoing basis, rather than as isolated
incidents. From a managerial perspective, then, it is important to design and
manage these infractions via a corporate performance scorecard that is aligned
with the corporate ‘balanced scorecard’. Metrics must be calibrated in a way that
will help determine the business value of the harm being brought to the brands
and defined in such a way that is meaningful to the stakeholder groups
represented on the cross-functional brand protection council.
The most actionable metrics and scorecards are simple and easy to read by
frontline employees, middle managers and executives alike. They do not simply
provide a tally of brand abuse, but track the level of severity, incidence levels and
cost to the organization in the form of lost revenue, lost ‘shopping intenders’ and
recovery costs.
The best metrics include associated actions and rates of success in mitigating
brand abuse and fraudulent activity. This is where the executive management will
be most interested in the process to protect the brand and evaluate the business
value of the brand protection process in and of itself. The best case will deliver a
true ROI measure; in the least, specific actions and outcomes will be tracked and
measured. Realistically, most companies should strive to mitigate as much of the
most harmful damage as possible, allocate resources to the most harmful
activities and take steps to educate customers and employees alike about the
various forms of Internet-based criminal activity. In this way, companies can
begin to protect the integrity of their brands by mitigating and managing their
online risk exposure.
Before the rise of e-business and the Internet, criminals were mostly interested in
stealing tangible assets. Similarly, business executives focused largely on
building business value through the accumulation of tangible assets. The Internet
has changed much of that, and has dramatically heightened sensitivity toward
the value of the corporate brand, as it remains largely exposed and vulnerable on
the Internet.
Without putting an appropriate online brand protection strategy in place,
however, companies are at risk of compromising more than their brand
reputations. As the statistics cited earlier note, they also face the very real threat
of incurring measurable financial costs – ranging from lost sales and lost
customers to a quantifiable erosion of market value.
By bringing online brand protection to the top of the corporate agenda, and
implementing specific strategies, processes and measures to protect their
brands, corporate executives can safeguard their hard-earned customer trust. At
the same time, they can establish safe and effective strategies for leveraging the
limitless opportunities offered by the Internet. This, in turn, can enable organizations to protect their online revenue streams, their customers’ online
experiences and their brand equity.
By identifying the appropriate brand protection partner, you can put a process in
place to respond internally to online brand abuse. With this type of process in
place, you gain the peace of mind of knowing that you are relying on industry
best practices – and you free up your internal resources to remain focused on
core competencies.
According to Forrester Research, there is a “… high correlation between
perception of protection and revenue per customer.” By working with a brand
protection partner who understands your corporate priorities, leverages best-of-breed
technological expertise, integrates human intelligence into the analytical
process and responds proactively to attacks on your brand, you can begin to
reap those tangible benefits while mitigating and managing your online risks.
About the Author
Michael M. Kiefer, General Manager, BrandProtect. A recognized network
security expert and IT and risk visionary, Mr. Kiefer brings more than 25 years of
network, telephony, Internet and disaster recovery experience to his role at
BrandProtect, where he is responsible for Global operations. He is also a board
member of FS-ISAC. He can be reached by email at mkiefer @ brandprotect.com
or contacted at 224.766.300