ISO-27001 for Law Firms
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ISO-27001 for Law Firms LegalSEC Summit 2014 Thursday, 6/12/2014, 9:30 – 10:30 am ISO-27001 for Law Firms LegalSEC Summit 2014 Thursday, 6/12/2014, 9:30 – 10:30 am Introduction Andreas Antoniou Chief Information Officer Paul, Weiss, Rifkind, Wharton & Garrison LLP Jeff Franchetti Chief Information Officer Cravath, Swaine & Moore LLP Peter Kaomea Chief Information Officer Sullivan & Cromwell LLP 3 Agenda Why get ISO 27001 certified? What is ISO 27001? How to get ISO 27001 certified? 4 Why get ISO 27001 certified? ISO-27001 for Law Firms LegalSEC Summit 2014 5 Benefits of ISO 27001 Security Compliance 6 Benefits: Security • Law firms have high concentrations of Preventing Law Firm Data Breaches confidential information spanning Volume 38 Number 1 … hundreds or thousands of clients Shane Sims, a security practice director at Pricewaterhouse-Coopers, has said, “Absolutely • We are facing increasing data privacy we’ve seen targeted attacks against law firms in the regulation (EU-Data Protection Act, last 12 to 24 months because hackers, including state sponsors, are realizing there’s economic US Privacy laws in 46 states, PIPEDA, intelligence in those networks especially related to HIPAA Omnibus) business deals, mergers and acquisitions.” • Clients are increasingly interested in information security in Requests for Proposals, Engagement Letters, Audits, etc. • National security organizations have engaged many firms about the importance of protecting client confidences and about specific breaches 7 Protecting information helps protect firm brand 8 Benefits of ISO 27001 • ISO 27001 is: • Compliance •an internationally recognized, •externally certifiable standard • Security •that specifies a risk-based framework to •initiate, implement, maintain, and continuously mature information security within an organization. 9 Benefits: Demonstrates Due Care & Infosec Process Maturity 10 Benefits: Helps with Client Audits “…In addition, if your company is in possession of any Information Security certification (e.g. BSI, SSAE 16 CSA CCM, ISO 27001, PCI DSS) or audit reports, please provide them before filling out the questionnaire as they may be sufficient proof of proper Information Security in your company and no further engagement will be required.” 11 Benefits: High “Law” of the Land SOX HIPAA SOC2 ISO-27001/2 The Universe of Controls Privacy NIST / Laws FISMA 12 Benefits: Growing as Industy Standard Requests for 27001 Certification are and will continue to escalate rapidly * Certification counts do not only show law firms 13 ISO-27001 Momentum in the Legal Industry ISO 27001 Working Towards or Certified Investigating Certification Allen & Overy Buckley Sandler Bond Dickinson Cleary Gottlieb Steen & Hamilton Clifford Chance Davis Polk & Wardwell Cravath, Swaine & Moore Debevoise & Plimpton Hogan Lovells Fried, Frank, Harris, Shriver Irwin Mitchell Holland & Knight Linklaters Jones Day Orrick, Herrington & Sutcliffe Kramer Levin Paul, Weiss, Rifkind, Wharton & Proskauer Garrison Ropes & Gray Simpson Thacher & Bartlett Shearman & Sterling Sullivan & Cromwell Skadden, Arps, Slate, Meagher & Flom White & Case Taft Stettinius & Hollister von Briesen & Roper Wilmer Hale Winston & Strawn ISO-27001 is also used extensively in e-Discovery service providers (e.g., CDS, RVM, Daegis, Espion) 14 ISO 27001 is a superset of frameworks and regulations SOX HIPAA SOC2 ISO-27001/2 The Universe of Controls Privacy NIST / Laws FISMA 15 Benefits of ISO 27001 Certification • ISO 27001 is an internationally recognized, certifiable standard that specifies a risk-based framework to initiate, implement, maintain, and manage information security within an organization. Accordingly, it can help us to rationalize and prioritize our security initiatives and investments. • Information security is required to protect the confidentiality, integrity, and availability of client, firm, and personal data and by doing that protect brand and reputation. • Some clients are requesting it to augment or replace parts of their own audits. • An increasing number of law firms are achieving ISO certification and are reporting that it helps with information security audits by clients. • ISO 27001 is a “superset” of many other information security frameworks and regulatory controls. 16 What is ISO 27001? ISO-27001 for Law Firms LegalSEC Summit 2014 17 ISO Myths • It’s just a bunch of documents • It requires a huge investment in technology • It is only applicable to “big law” • It is something we can just pass off to our Security Manager 18 What is ISO 27001? • ISO 27001 is • an internationally recognized, • certifiable standard • that specifies a risk-based framework • to initiate, implement, maintain, & manage information security within an organization. 19 Maturity Models I.T. Value Predictive > Operational Proactive Excellence > automate Reactive > fight fires Chaotic > ad hoc > undocumented > unpredictable 20 PWC US Cybercrime report (June 2014) #1 issue that should concern you Spending on cybersecurity with a misaligned (or without a) strategy isn’t smart • Must prioritize security investments based on risk and impact to the business. • Must classify the business value of data assets. • Must have senior executive engagement and commitment. Need a System, Structure, Framework 21 ISO Standard documents http://www.iso.org ($130) First Edition – 2005 1. Scope 2. Normative references 3. Terms & definitions 4. ISMS 12 pages 5. Management Responsibility Setting up your System 6. Internal ISMS audits 7. Management Review 8. ISMS improvement Annex A – Control objectives • 11 Domains “Sister Document” • 39 Control Objectives ISO 27002 • 133 Controls 22 ISMS (Information Security Management System) First Edition – 2005 1. Scope Treatment ISMS 2. Normative references 3. Terms & definitions 4. ISMS 5. Management Responsibility 6. Internal ISMS audits Risk Mgt 7. Management Review Assessment Review 8. ISMS improvement Annex A – Control objectives • 11 Domains • 39 Control Objectives ISO 27002 • 133 Controls 23 Example: Laptop stolen from car • You can protect your laptop with a password • You can also encrypt your disk • You can add a policy that you can not leave your laptop in your car. • You can also ask your employees to sign a TOU statement • You can also train and make your employees aware of these risks (best practices) The controls are never just IT related. And only with these combined controls Easy? can we be confident in our security 24 ISO 27001 First Edition – 2005 1. Scope Treatment ISMS 2. Normative references 3. Terms & definitions 4. ISMS 5. Management Responsibility 6. Internal ISMS audits Risk Mgt 7. Management Review Assessment Review 8. ISMS improvement Annex A – Control objectives • 11 Domains • 39 Control Objectives • 133 Controls 25 Formal Process - Documentation 26 The (1st) standard contains 11 domains Standard Areas: Security Policy Domain Areas – 11 Control Objectives – 39 Organization Asset of Management Controls - 133 Security Human Resources Security Communica- Physical & tions & Environment Operations Security Management Information Access Security Control Incident Management Info.Systems Business Acquisition, Continuity Dev & Maint Management Risk & Compliance 27 Example: Security Policy Organization Human Physical & Comm & InfoSystems Info Security Business Security Asset Access Risk & of Resources Environment Operations Acquisition, Incident Continuity Policy Management Control Compliance Security Security Security Management Dev & Maint Management Management Domain Objective Control Control 28 Example: Human Resources Security Organization Human Physical & Comm & InfoSystems Info Security Business Security Asset Access Risk & of Resources Environment Operations Acquisition, Incident Continuity Policy Management Control Compliance Security Security Security Management Dev & Maint Management Management A 8.1 Prior to employment A 8.3 Termination or change of employment - Roles & Responsibilities - Screening - Termination responsibilities - Terms & Conditions of employment - Return of assets - Removal of access rights A 8.2 During Employment - Management responsibilities - Information security awareness, education & training - Disciplinary process 27002 29 ISO 27001 First Edition – 2005 1. Scope Treatment ISMS 2. Normative references 3. Terms & definitions 4. ISMS 5. Management Responsibility 6. Internal ISMS audits Risk Mgt 7. Management Review Assessment Review 8. ISMS improvement Annex A – Control objectives • 11 Domains • 39 Control Objectives • 133 Controls 30 Additional Details Who is involved? What does it cost? How long does it take? It4 –depends… 18Law months Firm dependentConsultant upon Registrar (optional) Senior• ScopeScope, Management Gap, Resource Availability CIO/• Budget,CurrentCSO Clientgap Demand DMS• Firm Admin capacity to efficiently make necessaryExample: changes Network• ScheduleISMS Admin expertise System• Willingness Admin to disrupt BAU Practice Lead Estimates http://www.bsigroup.org Human• Certification Resources Costs ($10K - $15K) Legal/ComplianceEducation & Risk Gap Analysis • Ongoing “Post-Certification”Remediation Costs: ($ 3KCertification – $5K) PhysicalAssessment Security & Planning 1-10 months 1-2 months 1 – 2 months 1 – 3 months • Consulting Costs ($0 – $80K) - optional Prepare & Validate Audit/Certify 31 © 2010 Pivot Point Security, Inc. How to get ISO 27001 certified? ISO-27001 for Law Firms LegalSEC Summit 2014 32 ISO-27001 “Road Map” to Certification The 12 Steps 1. We admitted we were powerless over alcohol—that our