Problems of Implementing Information Security Management Systems

News about various information security attacks against companies appears almost every day. The sources of these attacks vary from cyber-criminals who want to steal companies’ data to demand a ransom, to current or former employees who want to create damage to the organization. The best way to defend organizational critical assets is to implement an Information Security Management System that secures all sensitive assets from confidentiality, availability and integrity perspective. An Information Security Management System offers top management a framework for sensitive information flow control. This framework includes with a risk assessment that considers the security threats and vulnerabilities of the company’s assets. Companies usually implement Information Security Management System only after they have a functional quality management system, which brings clarity and optimization to the company’s processes. Current approaches on creation and implementation of effective Information Security Management System are very theoretical and thus difficult to use in practice. The main objective of this paper is to present an Information Security Management System implementation method in the case of a small company by defining the basic steps in achieving a fully functional Information Security Management System. The proposed methodology considers the top management Information Security Management System objectives, organizational context, risks assessment and third parties expectations fulfillment.

In the wave of the progressive informatization process, Korean enterprises are making a vast amount and range of investments in the information security sector in order to counter the information dysfunction. In addition, to achieve an objective evaluation thereon, they have been increasingly exhibiting a preference for a certification system of information security management, as developed by the government This study aims to reduce the possible trials and errors while promoting the establishment and certification of the information security management system by enterprises. To satisfy this purpose, this study presents the defects by item found during the certification process of the information security management system of a number of enterprises. By analyzing the derived defects, we have outlined the issues to be attended to among enterprises at each stage of the establishment of an information security management system. The study also presents a reference model for conducting a self check, so that companies may be able to self-verify the completeness of their establishment of the information security management system. Through the results of this study, enterprises will be able to self-verify their completeness levels when promoting the establishment and certification of the information security management system, and improve the efficiency and effectiveness thereof so as to raise the general level and awareness among enterprises of the importance of information security.

This study examines the effect of an Information Security Management System (ISMS) on organizational performance in a Small and Medium Business (SMB), with a focus on Red Mango Ltd. The study employed a correlational survey design to assess the relationship between ISMS implementation and organizational performance. Primary data was collected from 44 respondents, including management and staff, through structured questionnaires. The convenience sampling technique was used for respondent selection, and data analysis was conducted using the Statistical Package for Social Sciences (SPSS) version 25. Correlation and regression analyses were applied to determine the relationship and effect of ISMS on organizational performance. Findings revealed that ISMS is well-implemented at Red Mango Ltd, with clear policies, structured roles and responsibilities, and comprehensive employee training on security measures. Employees are well-informed about acceptable usage of information security systems, and security incidents are promptly reported. However, several challenges hinder ISMS implementation, including leadership issues, technical system difficulties, personnel constraints, and financial limitations. Despite these challenges, ISMS adoption has led to significant benefits, including regulatory compliance, optimized business processes, cost savings, improved information security awareness, enhanced company reputation, and increased productivity. The study further established a strong positive correlation between ISMS implementation and organizational performance at Red Mango Ltd. Regression analysis indicated that a unit increase in ISMS adoption results in a 0.495 increase in organizational performance, confirming its significant impact. The study concludes that effective ISMS implementation enhances security, improves operational efficiency, and contributes to overall business success. Organizations are encouraged to address implementation challenges through leadership commitment, technical capacity building, and financial investment to fully realize ISMS benefits.

The article justifies the imperatives of applying the situational approach to information security management (ISM). We modified the model of the Information Security Management System (ISMS), which is the basis of ISO/IEC 27005: 2011: we added the “Decision Making” stage after the “Determining the main criteria” step. The solution is to choose an approach to proccesing information security risks — their assessment, impact and taking — based on certain criteria. Using the developed algorithm, we implemented a cognitive software module of the information system management (ISM) in an educational institution. The use of the cognitive software module has significantly reduced the labor costs of specialists in the Information Security (IS) Department, including automation of the reporting procedures. The application of the situational approach allowed us to integrate a person into the automated system to ensure the cybersecurity of the educational sector.

This paper examines using a requirements management tool as a common thread to managing the complexity of information security systems. Requirements management provides a mechanism to trace requirements through to design, implementation, operating, monitoring, reviewing, testing, and reporting by creating links to associated, critical artefacts. This is instrumental in managing complex and dynamic systems where change can impact other subsystems and associated documentation. It helps to identify the affected artefacts through many layers. Benefits to this approach would include better project planning and management, improved risk management, superior change management, ease of reuse, enhanced quality control and more effective acceptance testing. It would also improve the ability to audit, especially at a time when outsourcing of security functions is occurring throughout the world. ISO 27001:2006 provides a model for the implementation of an Information Security Management System (ISMS) that can be tailored by an organization. It is proposed that employment of a requirements management tool could manage the traceability aspects of an ISMS.

Click to increase image sizeClick to decrease image size Notes 1. "As a result of increasing interconnectivity, information systems and networks are now exposed to a growing number and a wider variety of threats and vulnerabilities. This raises new issues for security." OECD Guidelines for the Security of Information Systems and Networks, July 25, 2002, at p. 7, available at www.oecd.org/dataoecd/16/22/15582260.pdf. 2. Although not the subject of this article, it is important to note that countries are also enacting cybercrime legislation to make clear that certain online activities are illegal and to assist law enforcement in efforts to prosecute cyber criminals. To that end, the Privacy and Computer Crime Committee of the American Bar Association Section of Science & Technology Law has recently undertaken a project to develop a Model Cybercrime Law for the UN International Telecommunication Union's (ITU) Cybersecurity Work Programme to Assist Developing Countries. See also the International Guide to Combating Cybercrime published by this Committee, available at http://www.abanet.org/dch/committee.cfm?com=ST202003. 3. See the Appendix for a compilation of some of the key laws and regulations governing information security. 4. See, e.g., EU Data Protection Directive and HIPAA, cited in the Appendix. 5. See, e.g., E-SIGN, UETA, and UN Convention cited in the Appendix. 6. See, e.g., Kimberly Kiefer and Randy V. Sabett, Openness of Internet Creates Potential for Corporate Information Security Liability, BNA Privacy & Security Law Report, Vol. 1, No. 25 at 788 (June 24, 2002); Alan Charles Raul, Frank R. Volpe, and Gabriel S. Meyer, Liability for Computer Glitches and Online Security Lapses, BNA Electronic Commerce Law Report, Vol. 6, No. 31 at 849 (August 8, 2001); Erin Kenneally, The Byte Stops Here: Duty and Liability for Negligent Internet Security, Computer Security Journal, Vol. XVI, No. 2, 2000. 7. See, e.g., Wolfe v. MBNA America Bank, 485 F.Supp.2d 874, 882 (W.D. Tenn. 2007); Guin v. Brazos Higher Education Service, Civ. No. 05-668, 2006 U.S. Dist. Lexis 4846 (D. Minn. February 7, 2006); and Bell v. Michigan Council, 2005 Mich. App. Lexis 353 (Mich. App. February 15, 2005) (all affirming a negligence cause of action). See also, In Re TJX Companies Retail Security Breach Litigation, 2007 U.S. Dist. Lexis 77236 (D. Mass. October 12, 2007) (rejecting a negligence claim due to the economic loss doctrine, but allowing a negligent misrepresentation claim to proceed). 8. See, e.g., American Express v. Vinhnee, 2005 Bankr. Lexis 2602 (9th Cir. Bk. App. Panel, 2005); Lorraine v. Markel, 2007 U.S. Dist. Lexis 33020 (D. MD. May 4, 2007). 9. Available at www.pcisecuritystandards.org. 10. Available at www.cabforum.org. 11. ISO/IEC 27001, Information Technology—Security Techniques—Information Security Management Systems—Requirements (October 2005) (hereinafter "ISO/IEC 27001"), available for purchase at http://www.standards-online.net/InformationSecurityStandard.htm. 12. Directive 95/46/EC of the European Parliament and of the Council of October 24, 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter "EU Data Protection Directive"). 13. See statutes listed in the Appendix. 14. See statutes listed in the Appendix. 15. Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), 42 U.S.C. 1320d-2 and 1320d-4, (providing that "each person … who maintains or transmits health information shall maintain reasonable and appropriate administrative, technical, and physical safeguards: (A) to ensure the integrity and confidentiality of the information; (B) to protect against any reasonably anticipated: (i) threats or hazards to the security or integrity of the information; and (ii) unauthorized uses or disclosures of the information; and (C) otherwise to ensure compliance with this part by the officers and employees of such person," at 42 U.S.C. 1320d-2(d)(2). 16. Gramm-Leach-Bliley Financial Services Modernization Act ("GLB"), Pub. L. No. 106-102, 113 Stat. 1338 (November 12, 1999), at §§ 501 and 505(b), 15 U.S.C. §§ 6801, 6805, providing that "[E]ach financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers' nonpublic personal information." 17. See, Gramm-Leach-Bliley Act ("GLB"), Public Law 106-102, §§ 501 and 505(b), 15 U.S.C. §§ 6801, 6805, and implementing regulations at 12 C.F.R. Part 30, Appendix B (OCC), 12 C.F.R. Part 208, Appendix D (Federal Reserve System), 12 C.F.R. Part 364, Appendix B (FDIC), 12 C.F.R. Part 568 (Office of Thrift Supervision) and 16 C.F.R. Part 314 (FTC). 18. Final HIPAA Security Regulations, 45 C.F.R. Part 164. 19. There have also been efforts in the United States to pursue comprehensive federal privacy similar to the approach taken by many other countries. See e.g., Microsoft position paper at www.microsoft.com/presspass/download/features/2005/PrivacyLegislationCallWP.doc. Although it remains to be seen whether that approach will ultimately be adopted, it is clear that the combination of U.S. state and federal law has, in effect, imposed a comprehensive obligation of security with respect to all personal information held by all companies. 20. See, e.g., FTC enforcement actions regarding In the Matter of Sunbelt Lending Services, Inc.; In the Matter of Petco Animal Supplies, Inc.; In the Matter of MTS, Inc., d/b/a Tower records/Books/Video; In the matter of Guess?, Inc.; FTC V. Microsoft; and In the Matter of Eli Lilly and Company cited in the Appendix. 21. See, e.g., FTC enforcement actions regarding In the Matter of CardSystems Solutions, Inc.; United States v. ChoicePoint, Inc.; In the Matter of DSW Inc.; and In the Matter of BJ's Wholesale Club, Inc. cited in the Appendix. 22. See list in the Appendix. 23. See, e.g., Guin v. Brazos Higher Education Service, Civ. No. 05-668, 2006 U.S. Dist. Lexis 4846 (D. Minn. February 7, 2006) and Bell v. Michigan Council, 2005 Mich. App. Lexis 353 (Mich. App. February 15, 2005). 24. 205 Mich. App. Lexis 353 at ∗16 (Mich. App. 2005). 25. 2006 U.S. Dist. Lexis 4846 at ∗9 (D. Minn. 2006). 26. Wolfe v. MBNA America Bank, 485 F.Supp.2d 874, 882 (W.D. Tenn. 2007). 27. In Re TJX Companies Retail Security Breach Litigation, 2007 U.S. Dist. Lexis 77236 (D. Mass. October 12, 2007), at pp. 28–29. 28. Ibid. 29. The Homeland Security Act of 2002 defines the term "information system" to mean "any equipment or interconnected system or subsystems of equipment that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information, and includes—(A) computers and computer networks; (B) ancillary equipment; (C) software, firmware, and related procedures; (D) services, including support services; and (E) related resources." Homeland Security Act of 2002, Pub. L. 107-296, at Section 1001(b), amending 44 U.S.C. § 3532(b)(4). 30. See, e.g., Australia, Information Privacy Principles under the Privacy Act 1988, Principle No. 4, available at www.privacy.gov.au/publications/ipps.html; AICPA and the Canadian Institute of Chartered Accountants (CICA), Generally Accepted Privacy principles, Principle No. 8, available at http://infotech.aicpa.org/Resources/Privacy/Generally+Accepted+Privacy+Principles; APEC, Privacy principles, Principle No. 7, available at http://austlii.edu.au/∼graham/APEC/APECv10.doc; US-EU Safe Harbor Privacy Principles, available at www.export.gov/safeharbor/SHPRINCIPLESFINAL.htm; Direct Marketing Association, Online Marketing Guidelines, available at www.the-dma.org/guidelines/onlineguidelines.shtml. 31. Directive 95/46/EC of the European Parliament and of the Council of October 24, 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter "EU Data Protection Directive"). 32. EU Data Protection Directive, Preamble at Para. 46. 33. EU Data Protection Directive, Article 17(1). 34. See statutes listed in the Appendix. 35. See statutes listed in the Appendix. 36. See generally, Bruce H. Nearon, Jon Stanley, Steven W. Teppler, and Joseph Burton, Life after Sarbanes-Oxley: The Merger of Information Security and Accountability, Jurimetrics Journal, Vol. 45, 379–412 (2005). 37. American Express v. Vinhnee, 336 B.R. 437; 2005 Bankr. Lexis 2602 (9th Cir. December 16, 2006). 38. Ibid., at p. 444. 39. Ibid., at p. 445. 40. Ibid., at pp. 446–447. 41. Ibid., at p. 449. 42. See, e.g., National Association of Corporate Directors, Information Security Oversight (2007). 43. Sarbanes-Oxley Act, Section 302. 44. See, e.g., GLB Security Regulations (Federal Reserve) 12 C.F.R. 208, Appendix D-2.III(A). 45. HIPAA Security Regulations, 45 C.F.R. Section 164.308(a)(2). 46. See, FTC Decisions and Consent Decrees listed in the Appendix, including Microsoft Consent Decree at II, p. 4; Ziff Davis Assurance of Discontinuance, Para. 27(a), p. 7; Eli Lilly Decision at II.A. 47. FISMA, 44 U.S.C. 3544(a). 48. E. Michael Power and Roland L. Trope, Sailing in Dangerous Waters: A Director's Guide to Data Governanc e , American Bar Association (2005), p. 13; Roland L. Trope, "Directors' Digital Fiduciary Duties," IEEE Security & Privacy, January/February 2005 at p. 78. 49. Caremark International Inc. Derivative Litigation, 698 A.2d 959 (Del. Ch. 1996). 50. Bell v. Michigan Council, 2005 Mich. App. Lexis 353 (Mich. App. February 15, 2005), at pp. 11–13 (noting that harm was foreseeable, but Board took no action). 51. Securing Cyberspace: Business Roundtable's Framework for the Future, Business Roundtable, May 19, 2004 at pp. 1, 2; available at www.businessroundtable.org/pdf//20040518000CyberSecurityPrinciples.pdf. The Business Roundtable is an association of chief executive officers of leading U.S. corporations with a combined workforce of more than 10 million employees in the United States. See www.businessroundtable.org. 52. Information Security Governance: A Call to Action, Corporate Governance Task Force Report, National Cyber Security Partnership, April 2004, pp. 12–13, available at www.cyberpartnership.org/InfoSecGov4_04.pdf. The National Cyber Security Partnership (NCSP) is led by the Business Software Alliance (BSA), the Information Technology Association of America (ITAA), TechNet, and the U.S. Chamber of Commerce in voluntary partnership with academicians, CEOs, federal government agencies, and industry experts. Following the release of the 2003 White House National Strategy to Secure Cyberspace and the National Cyber Security Summit, this public–private partnership was established to develop shared strategies and programs to better secure and enhance America's critical information infrastructure. Further information is available at www.cyberpartnership.org. 53. GLB Security Regulations (OCC), 12 C.F.R. Part 30, Appendix B, Part III.A and Part III.F. 54. See, e.g., Homeland Security Act of 2002 (Federal Information Security Management Act of 2002) 44 U.S.C. Section 3542(b)(1); GLB Security Regulations (OCC), 12 C.F.R. Part 30 Appendix B, Part II.B; HIPAA Security Regulations, 45 C.F.R. Section 164.306(a)(1); Microsoft Consent Decree at II, p. 4. 55. See, e.g., 44 USC 3532(b)(1), emphasis added. See also FISMA, 44 U.S.C. Section 3542(b)(1). Most of the foreign privacy laws also focus their security requirements from this perspective. This includes, for example, the EU Privacy Directive, Finland's Privacy Law, Italy's Privacy Law, and the UK Privacy Law. Also in this category is the Canadian Privacy Law. 56. Although they often focus on categories of security measures to address. See, e.g., HIPAA Security Regulations, 45 C.F.R. Part 164. 57. See, e.g., FDA regulations at 21 C.F.R. Part 11 (procedures and controls); SEC regulations at 17 C.F.R. 257.1(e)(3) (procedures); SEC regulations at 17 C.F.R. 240.17a-4 (controls); GLB regulations (FTC) 16 C.F.R. Part 314 (safeguards); Canada, Personal Information Protection and Electronic Documents Act, Schedule I, Section 4.7 (safeguards); EU Data Privacy Directive, Article 17(1) (measures) available at http://europa.eu.int/comm/internal_market/privacy/docs/95-46-ce/dir1995-46_part1_en.pdf. 58. See, e.g., HIPAA 42 U.S.C. 1302d-2, and HIPAA Security regulations, 45 CFR 164.306; COPPA, 15 U.S.C. 6502(b)(1)(D), and COPPA regulations 16 C.F.R. 312.8; IRS Rev. Proc. 97-22, sec. 4.01(2); SEC regulations 17 C.F.R. 257. See also UCC Article 4A, Section 202 ("commercially reasonable" security procedure), and Microsoft Consent Decree. 59. "Appropriate" security required by: HIPAA 42 U.S.C. 1302d-2, and HIPAA Security regulations, 45 CFR 164.306; EU Data Protection Directive, Article 17(1). 60. EU Data Protection Directive, Article 17(1) (emphasis added) 61. See, e.g., Belgium—Belgian Law of 8 December 1992 on Privacy Protection in relation to the Processing of Personal Data, as modified by the law of 11 December 1998 Implementing Directive 95/46/EC, and the law of 26 February 2003, Chapter IV, Article 16(4); Denmark—Act on Processing of Personal Data,; Act No. 429 of 31 May 2000 (unofficial English translation), Title IV, Part 11, Section 41(3); Estonia—Personal Data Protection Act; Passed February12, 2003 (RT1 I 2003, 26, 158), entered into force October 1, 2003, Chapter 3, Sections 19(2); Greece—Law 2472/1997 on the Protection of Individuals with regard to the Processing of Personal Data (as amended by Laws 2819/2000 and 2915/2001); Article 10(3); Ireland—Data Protection (Amendment) Act 2003; Section 2.-(1)(d) and First Schedule Article 7; Lithuania—Law on Legal Protection of Personal Data, January 21, 2003, No. IX-1296, Official translation, with amendments April 13, 2004, Article 24(1); Netherlands—25 892—Rules for the protection of personal data (Personal Data Protection Act) (Unofficial translation); Article 13; Portugal—Act on the Protection of Personal Data (transposing into the Portuguese legal system Directive 95/46/EC of the European Parliament and of the Council of October 24, 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data), Article 14(1); Slovakia—Act No 428 of July 3, 2002 on personal data protection; Section 15(1); Sweden—Personal Data Act (1998:204); issued April 29, 1998, Section 31; and UK—Data Protection Act 1998, Schedule 1, Part I, Seventh Principle. 62. See, e.g., Finland—The Finnish Personal Data Act (523/1999), given on 22.4.1999, Section 32(1); Germany—Federal Data Protection Act as of January 1, 2003, Section 9; Hungary—Act LXIII of 1992 on the Protection of Personal Data and Public Access to Data of Public Interest, Article 10(1); Italy—Personal Data Protection Code, Legislative Decree No. 196 of 30 June 2003, Sections 31 and 33; Spain—Organic Law 15/1999 of December 13 on the Protection of Personal Data, Article 9. 63. 5 USC Sec. 552a. 64. 5 U.S.C. § 552a (d)(10) (emphasis added). 65. 42 U.S.C. 1320d-2(d)(2). 66. See, Gramm-Leach-Bliley Act ("GLB"), Public Law 106-102, §§ 501 and 505(b), 15 U.S.C. §§ 6801, 6805, and implementing regulations at 12 C.F.R. Part 30, Appendix B (OCC), 12 C.F.R. Part 208, Appendix D (Federal Reserve System), 12 C.F.R. Part 364, Appendix B (FDIC), 12 C.F.R. Part 568 (Office of Thrift Supervision) and 16 C.F.R. Part 314 (FTC) (emphasis added). 67. Cal. Civil Code § 1798.81.5(b). 68. See UN Convention at Article 9(3), 9(4), and 9(5). 69. ISO/IEC 27001, Information Technology—Security Techniques—Information Security Management Systems—Requirements (October 2005). See text at footnotes 157–169, infra. February 1, 12 C.F.R. Part 30, Appendix B (OCC), 12 C.F.R. Part 208, Appendix D (Federal Reserve System), 12 C.F.R. Part 364, Appendix B (FDIC), 12 C.F.R. Part 568 (Office of Thrift May 16 C.F.R. Part 44 U.S.C. Section 45 C.F.R. 164. See of the on by of the Technology and Homeland Security of the Committee on the United States 21, 2007 at p. (noting that FTC under the GLB Act as a for the obligation to maintain reasonable and appropriate available at See also, of the the on Information and the Committee on U.S. House of on April 21, 2004, at p. 5 (noting that is an of reasonable and appropriate measures in of the available at See, e.g., FTC Decisions and Consent Decrees listed in the Appendix. See, e.g., National Association of Insurance for Information Model available at in at See, e.g., Consent Decrees listed in the Appendix. 78. See, e.g., Guin v. Brazos Higher Education Service, Civ. No. 05-668, 2006 U.S. Dist. Lexis 4846 (D. Minn. February 7, 2006) and Bell v. Michigan Council, 2005 Mich. App. 353 (Mich. App. February 15, 2005). Guin v. Brazos Higher Education Service, Civ. No. 05-668, 2006 U.S. Dist. Lexis 4846 (D. Minn. February 7, 2006). Bell v. Michigan Council, 2005 Mich. App. Lexis 353 (Mich. App. February 15, 2005). Committee on available at See, e.g., Italy—Personal Data Protection Code, Legislative Decree No. 196 of 30 June 2003, B, § Act No 428 of July 2002 on personal data § the Appendix, Act, B, Section Act, Section the Appendix, Act, Article Act, Section Act, 16(4); Act, Section 41(3); Act, Section Act, Section 32(1); Act, Section 9; Act, Article 10(3); Act, Article 10(1); Act, Article 24(1); Act, Article 13; Act, Article 14(1); Act, Section 15(1); Act, Article 9; Act, Section 31; UK Act, Schedule 1, Part I, Seventh Act, Article 7. the Appendix, Act, Schedule 2, Section Act, Act, Schedule 1, 4.7 Principle 7, Act, Section Act, Section Act, B, Sections and Act, Sections 17 and the Appendix, Act, Section A Security § Act, Section Decree the Appendix, Decree the Appendix, Act, Section Principle 4; Act, Article Act, Article Act, Sections and Act, Section Act, Section Act, Section Act, B, Sections and Act, Sections 17 and Bruce & Digital Security in a & at p. See, e.g., HIPAA Security Regulations, 45 C.F.R. Section See, e.g., Microsoft Consent Decree at II, p. 4; Ziff Davis Assurance of Discontinuance, Para. p. Eli Lilly Decision at II.B; GLB Security Regulations, 12 C.F.R. Part 30, Appendix B, Part See, e.g., Microsoft Consent Decree at II, p. 4; Eli Lilly Decision at See, e.g., FISMA, 44 U.S.C. Sections and GLB Security Regulations, 12 C.F.R. Part 30, Appendix B, Part See, e.g., In Electronic July 30, Financial Council, 2; available at See, e.g., Microsoft Consent Decree at II, p. 4; GLB Security Regulations (OCC), 12 C.F.R. Part 30 Appendix B, Part Eli Lilly Decision at II.B; HIPAA Security Regulations, 45 C.F.R. Section Information Security Management Act of 2002 44 U.S.C. Section See, e.g., Microsoft Consent Decree at II, p. 4; GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section Information Security Management Act of 2002 44 U.S.C. Section See, e.g., GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part Information Security Management Act of 2002 44 U.S.C. Section See, e.g., Microsoft Consent Decree at II, p. 4; GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part See, e.g., GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section See, e.g., HIPAA Security Regulations, 45 C.F.R. Section See, e.g., United States v. Cir. See, e.g., Inc. v. also v. or of to with and of See, e.g., HIPAA Security Regulations, 45 C.F.R. Section GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part and Part FISMA, 44 U.S.C. Sections and Microsoft Consent Decree at II, p. 4; Ziff Davis Assurance of HIPAA Security Regulations, 45 CFR Section and and on HIPAA Security of & Section of Science & Technology Law, No. April 2003, at p. 2, available at See, e.g., HIPAA regulations 45 C.F.R. Sections and GLB Regulations, 12 C.F.R. 208, Appendix and 12 C.F.R. Part 30, Appendix B, Part Microsoft Consent at p. 4. HIPAA Security Regulations, 45 C.F.R. Section GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Sections and GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section and Ziff Davis Assurance of Discontinuance, Para. 25, p. 6. HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part Ziff Davis Assurance of Discontinuance, Para. p. 5 and Para. 25, p. 6. HIPAA Security Regulations, 45 C.F.R. Section GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part Ziff Davis Assurance of Discontinuance, Para. 25, p. 6. GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part Ziff Davis Assurance of Discontinuance, Para. 25, p. HIPAA Security Regulations, 45 C.F.R. Sections and Ziff Davis Assurance of Discontinuance, Para. 25, p. 6. Ziff Davis Assurance of Discontinuance, Para. 25, p. 6. HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section HIPAA Security Regulations, 45 C.F.R. Section Ziff Davis Assurance of Discontinuance, and 26, pp. HIPAA Security Regulations, 45 C.F.R. Section GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part See, e.g., FISMA, 44 U.S.C. Section HIPAA Security Regulations, 45 C.F.R. Section Ziff Davis Assurance of Discontinuance, Para. p. 5. Ziff Davis Assurance of Discontinuance, Para. p. 7. HIPAA Security Regulations, 45 C.F.R. Section Microsoft Consent Decree at II, p. 4. FISMA, 44 U.S.C. Section Eli Lilly Decision at GLB Security Regulations, 12 C.F.R. Part 30, Appendix B, Part Ziff Davis Assurance of Discontinuance, Para. and p. 7; Eli Lilly Decision at HIPAA Security Regulations, 45 C.F.R. Section Microsoft Consent Decree at II, p. 4; Ziff Davis Assurance of Discontinuance, Para. and p. 7; Eli Lilly Decision at GLB Security Regulations, 12 C.F.R. Part 30, Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section and GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section Microsoft Consent Decree at II, p. 4; Eli Lilly Decision at Microsoft Consent Decree at p. 5. Ziff Davis Assurance of Discontinuance, Para. p. 7. See, e.g., of the of the of National on 21, at See, e.g., GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part See, e.g., GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part HIPAA Security Regulations, 45 C.F.R. Section and GLB Security Regulations, 12 C.F.R. Part 30 Appendix B, Part Wolfe v. MBNA America Bank, 485 F.Supp.2d 874, 882 (W.D. Tenn. 2007). See Bell v. Michigan Council, 2005 Mich. App. Lexis 353 (Mich. App. February 15, 2005). See Guin v. Brazos Higher Education Service, Civ. No. 05-668, 2006 U.S. Dist. Lexis 4846 at (D. Minn. February 7, 2006) that a was the to and a of a was not a of a of reasonable The Financial is a of U.S. federal agencies, that the Board of of the Reserve Insurance the National the of the of the and the of Thrift on on in an Internet 8, 2006 at p. available at on on in an Internet 8, 2006 at p. available at Guide for the Guidelines Information Security December available at Information Security July available at See National Institute of and Management Guide for Information Technology No. available at ISO/IEC 27001, Information Technology—Security Techniques—Information Security Management Systems—Requirements (October 2005) (hereinafter "ISO/IEC ISO/IEC § for is the and of International and is of a of the of with and a in that the The American National Institute the United States. See, The also in and in related to including The of make its with the United States. See ISO/IEC 27001, § (emphasis added). ISO/IEC 27001, § ISO/IEC 27001, § ISO/IEC 27001, § 164. ISO/IEC 27001, § ISO/IEC 27001, §§ and 6. ISO/IEC 27001, §§ and 8. ISO/IEC 27001, §§ ISO/IEC that with an International not in from legal p. 1. EU Data Protection Directive, Article 8. Article Data Protection on the processing of personal data to health in health February 15, at pp. available at (emphasis in See list of state laws in Report, Security and Laws of 15, 2005 at Appendix available at Code, § Rev. Stat. Available at www.pcisecuritystandards.org. See list in the Appendix. See, e.g., 16 CFR Section Health Insurance Portability and Accountability Act Security Regulations, 45 C.F.R. § HIPAA security regulations to in the Act Security Regulations, 12 C.F.R. Part 30 Appendix B, Part security regulations to information in the financial Homeland Security Act of 2002 § 1001(b), amending 44 U.S.C. § and § amending 44 U.S.C. § information and information systems from unauthorized and regulations, 21 C.F.R. Part 11. See, e.g., Cal. Civil Code § 1798.81.5(b). See April 2, the Matter of of the Act of of Information and Information Services, No. No. April 2, at available at (hereinafter Wolfe v. MBNA America Bank, 485 F.Supp.2d 874, 882 (W.D. Tenn. 2007). in an Internet 12, 2005 available at This was by an on on in an Internet 8, available at of No. 25, The is an See, e.g., HIPAA Security Regulations, 45 C.F.R. § at p. 6. Ibid., at p. 3. Ibid. v. National 2007 U.S. App. Lexis 2007), at p. 13. See, e.g., on of Security Breach Personal of Privacy of April 2006 (hereinafter at pp. at note , at p. a of such in the United States and a of the number of individuals Privacy at IRS Rev. Proc. § See list of statutes in the Appendix. on for Access to Information and Part of A to Appendix, at 12 C.F.R. Part 30 (OCC), 12 C.F.R. Part (Federal Reserve System), 12 C.F.R. Part (FDIC), and 12 C.F.R. Part 568 (Office of Thrift 29, Vol. No. 29, at p. (hereinafter the maintains personal information that the not in the laws the to the or of the information, than the individuals of any of the security of the See, e.g., Code § Rev. Stat. § Code, § Stat. § Code § 2007 The also any combination of of information that to or the such as and or and See, e.g., Breach to the of & Financial Services, December 15 USC Section This that with the of at 15 USC Section and are of in this and are of in this See, and of a Duty to Information Security Computer & L. See and to Law the Protection of Personal BNA Privacy & Security Law Report, 19, p. May See at on the of the Framework for Electronic and Services, with focus on the 26, available at Science and Technology Committee, House of Internet of July 24, at Para. of the Privacy of Canada, for in to Privacy available at See Privacy Breach of the Privacy available at Privacy available at See, of the Privacy to the Law of February at available at Available at Available at to information to state

The purpose of this study was to investigate and analyze the assumptions and requirements for the implementation of Information Security Management System (ISMS). Methodology: To check assumptions security management system implementation is the population of Tabriz hospitals. Review the requirements and assumptions are based on the standard ISO / IEC 27001, ISO / IEC 27002 test target setting and ISO 27001 standard questionnaire containing 33 questions in 11 control is used. The data were analyzed using descriptive and inferential statistical method that factors in the implementation of information security management system was confirmed. As well as to identify factors contributing to the implementation of information security management system and factor analysis, structural equation model was used PLS smart software that based on its findings to impact and indirect aspects of implementation effectiveness of the system. Results: Using the software, smart-PLS and using structural equation modeling confirmatory factor analysis was performed to measure the test of convergent validity, divergent validity, reliability Security and reliability of observable variables and quality test and measurement model of the 101 comments experts, all the prerequisites and requirements, including information security policy, the organization of information security, asset management, human resources in terms of security, physical and environmental security, communications and operations management, access control, use, development and maintenance, incident management information security, business continuity management and compliance with laws in secure level at %99 is forecast in Tabriz hospitals are effective information security management system. Conclusion: According to prioritize the factors affecting information security management system, operating (after) the most monitors and agents (after) the supply and implementation of information security management system least affected are in Tabriz hospitals.

This paper proposes a technique for the design and implementation of the information security management system (ISMS) for small and medium enterprises (SMEs). The technique is based on ISO 27001 standard ISMS requirements object model. The model was designed using methods and tools of the information security integral engineering (ISIE) framework, so the first part of the paper also briefly describes some features, components and engineering methods within the ISIE framework, which are important in practical applications but were presented insufficiently or were not presented at all in the previous papers. Along with the description of a general ISMS design and implementation method, the paper provides an example of the application of this method to design ISMS for city medium telecommunication SME. The paper also gives the evaluation of the technique's efficiency.

Information Security Management System (ISMS) implementation in Institution is an effort to minimize information security risks and threats such as information leakage, application damage, data loss and declining IT network performance. The several incidents related to information security have occurred in the implementation of the Academic System application in Indonesian higher education. This research was conducted to determine the maturity level of information security practices in Academic Information Systems at universities in Indonesia. The number of universities used as research samples were 35 institutions. Compliance with the application of ISO 27001:2013 standard is used as a reference to determine the maturity level of information system security practices. Meanwhile, to measure and calculate the level of maturity using the SSE-CMM model. In this research, the Information System Security Index obtained from the analysis results can be used as a tool to measure the maturity of information security that has been applied. There are six key areas examined in this study, namely the role and importance of ICT, information security governance, information security risk management, information security management framework, information asset management, and information security technology. The results showed the level of information security maturity at 35 universities was at level 2 Managed Process and level 3 Established Process. The composition is that 40% of universities are at level 3, and 60% are out of level 3. The value of the gap between the value of the current maturity level and the expected level of maturity is varied for each clause (domain). The smallest gap (1 level) is in clause A5: Information Security Policy, clause A9: Access Control, and clause A11: Physical and environmental security. The biggest gap (4 levels) is in clause A14: System acquisition, development and maintenance and clause A18: compliance.  Â

Özet Bu çalışmanın amacı, ISO 500’de yer alan kooperatiflerin web sitelerinin incelenerek sürdürülebilirlik çatısı altında sürdürülebilirliğin sosyal, ekonomik ve çevresel boyutlarına göre mevcut durumlarını ortaya koymaktır. Bu kapsamda, kooperatiflerin Kurumsal Sosyal Sorumluluk, ISO 9001 Kalite Yönetim Sistemi, ISO 14001 Çevre Yönetim Sistemi, ISO 27001 Bilgi Güvenliği Yönetim Sistemi, ISO 22000 Gıda Güvenliği Yönetim Sistemi, ISO 45001 İş Sağlığı ve Güvenliği Yönetim Sistemi, ISO 50001 Enerji Yönetim Sistemi sertifikasyon durumu incelenmiştir. Betimsel tarama modelinde olan araştırmada amaçlı örneklem yöntemiyle seçilen yedi kooperatifin web siteleri taranmıştır. Araştırmada içerik analizi yöntemlerinden yüzde ve frekans analizi kullanılmıştır ve veriler arasındaki korelasyon incelenmiştir. Analizler sonucunda sürdürülebilirlik kavramı kapsamında incelenen parametrelerle kooperatiflerin ISO 500 sıralaması arasında anlamlı bir ilişkinin olmadığı görülmektedir. Bununla birlikte kooperatiflerin tamamının sosyal sorumluluk projeleri yaptığı, %86’sının kalite (ISO 9001), %71’inin çevre (ISO 14001), iş sağlığı ve güvenliği (ISO 45001) ve gıda güvenliği (ISO 22000), %29’unun enerji güvenliği (ISO 50001) ve %14’ünün bilgi güvenliği (ISO 27001) yönetim sistemlerine sahip olduğu belirlenmiştir.

This paper proposes an organizational management model for implementing the Information Security Management System (ISMS) Plan, Do, check and Act (PDCA) framework to achieve an improved balance between the effectiveness and efficiency of an organizations ISMS. Specifically describing the role of managerial structure and organizational structure in realizing the ISMS framework. Demonstrating the drawbacks in organizational structure that were reduced and the enhanced workflow within the organization due to the improved managerial role distinction regarding information security management. Projecting the effects of the proposed parallel loosely coupled approach when managing an ISMS related project within an organization.

The subject of research in the article is the management of vulnerabilities in the information security management system. The purpose of the work is to consider modern standards that establish and regulate the management of vulnerabilities and risks associated with vulnerabilities. The article considers the process of integration of vulnerability management into information security management system and its form. Conclusions: modern information security management system does not properly take into account vulnerabilities and risks associated with vulnerabilities, the current regulatory framework of Ukraine almost does not regulate and does not set requirements for information security systems in the field of vulnerabilities. Currently, the processes of risk management and assessment are entrusted to administrators, so effective management of vulnerabilities requires a clear system of rules and methodologies. The development of such a system is a promising task, and in the process of modernization of standards, requirements of Ukraine after some time will become a necessity. When adding a quality vulnerability assessment system, such a system will be clear, standardized and will serve as a guide to action in a particular situation

The growth of computers and of information technology has been explosive. As a result, information technology has been widely applied in every aspect of our life—from business, government, education, finance, health-care, aerospace to national defence. Computers, especially networked computers, have brought benefits to us and improved our lives. However, surveys and reports from various industry associations and security organizations suggested that only a few organizations can successfully protect their information assets. Organizations realize that information security is a complex issue, involving both human and technical factors. This paper is an attempt to empirically assess the maturity of Information Security Management System (ISMS) implementation in selected IT Service organizations in terms of confidence of their employees on their Information Security Management System.

Рассматриваются законодательные акты в области защиты банковских транзакций в национальной системе массовых электронных платежей (НСМЭП), ее структура. Проводится анализ основных источников угроз конфиденциальности, целостности и доступности данных, рассматриваются основные требования стандартов к функциям системы управления информационной безопасностью, программные средства технических систем безопасности информации в банковских институтах Национального банка Украины.

In developing standards and guidelines required by the Federal Information Security Management Act (FISMA), NIST consults with other federal agencies and offices as well as the private sector to improve information security, avoid unnecessary and costly duplication of effort, and ensure that NIST standards and guidelines are complementary with standards and guidelines employed for the protection of national security systems. In addition to its comprehensive public review and vetting process, NIST is working with the Office of the Director of National Intelligence (ODNI), the Department of Defense (DOD), and the Committee on National Security Systems (CNSS) to establish a common foundation for information security across the federal government. The common foundation for information security will provide the Intelligence, Defense, and Civil sectors of the federal government and their support contractors, more uniform and consistent ways to manage the risk to organizational operations, organizational assets, individuals, other organizations, and the Nation that results from the operation and use of information systems. In another collaboration initiative, NIST is working with public and private sector entities to establish specific mappings and relationships between the security standards and guidelines developed by NIST and the International Organization for Standardization and International Electrotechnical Commission (ISO/IEC) 27001, Information Security Management System (ISMS). NIST Special Publication 800-53A is a companion publication to NIST Special Publication 800-53, not a replacement or update. Special Publication 800-53 remains the definitive NIST recommendation for employing security controls in federal information systems.