iso-27001 for law firms -...

ISO-27001 for Law Firms LegalSEC Summit 2014 Thursday, 6/12/2014, 9:30 – 10:30 am

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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

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Agenda

Why get ISO 27001 certified?

What is ISO 27001?

How to get ISO 27001 certified?

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Why get ISO 27001 certified? ISO-27001 for Law Firms LegalSEC Summit 2014

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Benefits of ISO 27001

Security Compliance

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Benefits: Security

• Law firms have high concentrations of confidential information spanning hundreds or thousands of clients

• We are facing increasing data privacy regulation (EU-Data Protection Act, US Privacy laws in 46 states, PIPEDA, HIPAA Omnibus)

• 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

Preventing Law Firm Data Breaches Volume 38 Number 1 … Shane Sims, a security practice director at Pricewaterhouse-Coopers, has said, “Absolutely we’ve seen targeted attacks against law firms in the last 12 to 24 months because hackers, including state sponsors, are realizing there’s economic intelligence in those networks especially related to business deals, mergers and acquisitions.”

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Protecting information helps protect firm brand

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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.

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Benefits: Demonstrates Due Care & Infosec Process Maturity

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&uact=8&docid=emehkF6xMIu0zM&tbnid=wgUqJCe7hj9IpM:&ved=0CAUQjRw&url=http://www.diabetesmine.com/designcontest/about-the-summit/target-logo&ei=-8qYU-q-FojisATI5YK4Bw&bvm=bv.68693194,d.cWc&psig=AFQjCNFxKoMXbGrCj0_eY5eWIS6EBw5tHA&ust=1402608758816016

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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.”

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Benefits: High “Law” of the Land

HIPAA

SOX

SOC2

Privacy Laws

ISO-27001/2 The Universe of Controls

NIST / FISMA

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Benefits: Growing as Industy Standard

Requests for 27001 Certification are and

will continue to escalate rapidly

* Certification counts do not only show law firms

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ISO-27001 Momentum in the Legal Industry

ISO-27001 is also used extensively in e-Discovery service providers (e.g., CDS, RVM, Daegis, Espion)

ISO 27001 Certified

Allen & Overy Bond Dickinson Clifford Chance Cravath, Swaine & Moore Hogan Lovells Irwin Mitchell Linklaters Orrick, Herrington & Sutcliffe Paul, Weiss, Rifkind, Wharton & Garrison Simpson Thacher & Bartlett Sullivan & Cromwell White & Case

Working Towards or Investigating Certification

Buckley Sandler Cleary Gottlieb Steen & Hamilton Davis Polk & Wardwell Debevoise & Plimpton Fried, Frank, Harris, Shriver Holland & Knight Jones Day Kramer Levin Proskauer Ropes & Gray Shearman & Sterling Skadden, Arps, Slate, Meagher & Flom Taft Stettinius & Hollister von Briesen & Roper Wilmer Hale Winston & Strawn

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ISO 27001 is a superset of frameworks and regulations

HIPAA

SOX

SOC2

Privacy Laws

ISO-27001/2 The Universe of Controls

NIST / FISMA

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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.

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What is ISO 27001? ISO-27001 for Law Firms LegalSEC Summit 2014

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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

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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.

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I.T.

Maturity Models

Chaotic > ad hoc > undocumented > unpredictable

Reactive > fight fires

Proactive > automate

Predictive > Operational Excellence

Value

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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

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ISO Standard documents

First Edition – 2005 1. Scope 2. Normative references 3. Terms & definitions 4. ISMS 5. Management Responsibility 6. Internal ISMS audits 7. Management Review 8. ISMS improvement Annex A – Control objectives

• 11 Domains • 39 Control Objectives • 133 Controls

http://www.iso.org ($130)

“Sister Document”

ISO 27002

12 pages

Setting up your System

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ISMS (Information Security Management System)



ISO 27002

ISMS

Mgt Review

Risk Assessment

Treatment

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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

can we be confident in our security Easy?

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ISO 27001



ISMS

Mgt Review

Risk Assessment

Treatment

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Formal Process - Documentation

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The (1st) standard contains 11 domains

Organization

of

Security

Security

Policy

Human

Resources

Security

Info.Systems

Acquisition,

Dev & Maint

Access

Control

Risk &

Compliance

Physical &

Environment

Security

Asset

Management

Business

Continuity

Management

Communica-

tions &

Operations

Management Information

Security

Incident

Management

Standard Areas:

Domain Areas – 11

Control Objectives – 39

Controls - 133

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Example: Security Policy

Domain

Objective

Control

Control

Organization

of

Security

Security

Policy

Asset

Management

Physical &

Environment

Security

Human

Resources

Security

Comm &

Operations

Management

Access

Control

InfoSystems

Acquisition,

Dev & Maint

Business

Continuity

Management

Info Security

Incident

Management

Risk &

Compliance

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Example: Human Resources Security

Organization

of

Security

Security

Policy

Asset

Management

Physical &

Environment

Security

Human

Resources

Security

Comm &

Operations

Management

Access

Control

InfoSystems

Acquisition,

Dev & Maint

Business

Continuity

Management

Info Security

Incident

Management

Risk &

Compliance

A 8.1 Prior to employment

- Roles & Responsibilities - Screening - Terms & Conditions of employment

A 8.2 During Employment

- Management responsibilities - Information security awareness, education & training - Disciplinary process

A 8.3 Termination or change of employment

- Termination responsibilities - Return of assets - Removal of access rights

27002

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ISO 27001



ISMS

Mgt Review

Risk Assessment

Treatment

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Law Firm Consultant (optional)

Registrar

Prepare & Validate Audit/Certify

Senior Management CIO/CSO DMS Admin Network Admin System Admin Practice Lead Human Resources Legal/Compliance Physical Security

http://www.bsigroup.org

Example:

Additional Details

© 2010 Pivot Point Security, Inc.

Who is involved?

It depends…

• Scope • Current gap • Firm capacity to efficiently make necessary changes • Schedule

Estimates • Certification Costs ($10K - $15K) • Ongoing “Post-Certification” Costs: ($3K – $5K)

• Consulting Costs ($0 – $80K) - optional

4 – 18 months dependent upon

• Scope, Gap, Resource Availability

• Budget, Client Demand

• ISMS expertise

• Willingness to disrupt BAU

Education & Risk Assessment

1 – 2 months

Gap Analysis & Planning

1 – 3 months

Remediation

1-10 months

Certification

1-2 months

What does it cost? How long does it take?

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How to get ISO 27001 certified? ISO-27001 for Law Firms LegalSEC Summit 2014

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ISO-27001 “Road Map” to Certification

1. We admitted we were powerless over alcohol—that our lives had become unmanageable.

2. Came to believe that a power greater than ourselves could restore us to sanity.

3. Made a decision to turn our will and our lives over to the care of God as we understood Him.

4. Made a searching and fearless moral inventory of ourselves.

5. Admitted to God, to ourselves, and to another human being the exact nature of our wrongs.

6. Were entirely ready to have God remove all these defects of character.

7. Humbly asked Him to remove our shortcomings.

8. Made a list of all persons we had harmed, and became willing to make amends to them all.

9. Made direct amends to such people wherever possible, except when to do so would injure them or others.

10. Continued to take personal inventory, and when we were wrong, promptly admitted it.

11. Sought through prayer and meditation to improve our conscious contact with God as we understood Him, praying only for knowledge of His will for us and the power to carry that out.

12. Having had a spiritual awakening as the result of these steps, we tried to carry this message to alcoholics, and to practice these principles in all our affairs.

The 12 Steps

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1. We admitted we were powerless over security—that our lives had become unmanageable.

2. Came to believe that a power greater than ourselves could restore us to sanity.

3. Made a decision to turn our will and our lives over to the care of ISO 27001.

4. Made a searching and fearless moral inventory of systems.

5. Admitted to ISO, to ourselves, and to another human being the exact nature of our wrongs.

6. Were entirely ready to have ISO remove all these defects of character.

7. Humbly asked ISO to remove our shortcomings.

8. Made a list of all systems we had harmed, and became willing to make amends to them all.

9. Made direct amends to such people wherever possible, except when to do so would injure them or others.

10. Continued to take personal inventory, and when we were wrong, promptly admitted it.

11. Sought through corrective and preventative actions to improve our conscious contact with ISO, praying only for knowledge of ISO’s will for us and the power to carry that out.

12. Having had a spiritual awakening as the result of these steps, we tried to carry this message to other law firms, and to practice these principles in all our affairs.

The 12 Steps to ISO Certification

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1. Obtain Management Buy-in

2. Apply a Project Management Framework

3. Perform Gap Analysis

4. Define Scope

5. Publish an ISMS Policy

6. Perform Risk Assessment

7. Develop a Risk Treatment Plan

8. Publish a Statement of Applicability

9. Implement Controls and Procedures

10. Operate, Monitor and Measure the ISMS

11. Perform an Internal Audit

12. Certification

Cravath, Swaine & Moore LLP SCOPE: A framework of information security management processes, practices and controls that ensure the confidentiality, integrity, and availability of firm wide IT infrastructure and services that enable the business processes and activities supported by Document Management Service (DMS), Email Services (EMS), Litigation Document Storage Service (LDSS) & Remote Access Services (RAS). Paul, Weiss, Rifkind, Wharton & Garrison, LLP SCOPE: Information Security Management System (ISMS): a framework of processes and control specifications to the configuration, provision, and management of Document Management Service (DMS), Email Service (EMS), Remote Access Services (RAS), and Mobile Device Management Services (MDMS) protecting client and firm information assets globally. These activities take place in the SunGard co-location data center located in New Jersey and within the Paul Weiss offices located in NY, NY. Sullivan & Cromwell LLP The ISMS (Information Security Management System) supports and protects the security of Sullivan & Cromwell LLP client and firm data and associated confidential information residing in NY, NY.

Questions?

Are you ready to pitch ISO 27001 within your own firms?

Visit the ILTA Knowledge Bank to download a consolidated version of this presentation.

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ADDITIONAL SLIDES

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ISO 27001:2013 – Second Edition



Second Edition – 2013 1. Scope 2. Normative references 3. Context of the organization 4. Leadership 5. Planning Support 6. Operation 7. Performance Evaluation 8. Improvement Annex A – Reference controls


http://www.iso.org ($130)

iso-27001 for law firms -...

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