Showing posts with label Governance. Show all posts
Showing posts with label Governance. Show all posts

Monday, November 3, 2025

Securing APIs at Scale: Threats, Testing, and Governance

As organizations embrace microservices, cloud-native architectures, and digital ecosystems, APIs have become the connective tissue of modern business. From mobile apps to microservices architectures, APIs power virtually every digital interaction we have. As API usage explodes, so do the potential attack vectors, making robust security measures not just important, but essential. 

API security must be approached as a fundamental element of the design and development process, rather than an afterthought or add-on. Many organizations fall short in this regard, assuming that security measures can be patched onto an existing system by deploying security devices like Web Application Firewall (WAF) at the perimeter. In reality, secure APIs begin with the first line of code, integrating security controls throughout the design lifecycle. Even minor security gaps can result in significant economic losses, legal repercussions, and long-term brand damage. Designing APIs with inadequate security practices introduces risks that compound over time, often becoming a time bomb for organizations.

Securing APIs at scale requires more than just technical controls; it demands a lifecycle approach that integrates threat awareness, rigorous testing, and robust governance.
 

The Evolving Threat Landscape


APIs are attractive targets for attackers because they expose business logic, data flows, and authentication mechanisms. According to Salt Security, 94% of organizations experienced an API-related security incident in the past year. The threats facing APIs are constantly evolving, becoming more sophisticated and targeted. Here are some of the most prevalent and concerning threats:

  • Broken Authentication & Authorization: This is a perennial favourite for attackers. Weak authentication mechanisms, default credentials, or insufficient authorization checks can lead to unauthorized access, allowing attackers to impersonate users, access sensitive data, or perform actions that they shouldn't. Think of a poorly secured login endpoint that allows brute-forcing, or an API that lets a regular user modify administrative settings.
  • Injection Flaws (SQL, NoSQL, Command Injection): While often associated with web applications, injection vulnerabilities are equally dangerous in APIs. Malicious input, often disguised within legitimate API requests, can trick the backend system into executing unintended commands, revealing sensitive data, or even taking control of the server.
  • Excessive Data Exposure: APIs are designed to provide data, but sometimes they provide too much data. Overly broad API responses might inadvertently expose sensitive information (e.g., user email addresses, internal system details) that isn't necessary for the client's function. Attackers can then leverage this exposed information for further exploitation.
  • Lack of Resource & Rate Limiting: Unrestricted access to API endpoints can lead to various attacks, including denial-of-service (DoS) or brute-force attacks. Without proper rate limiting, an attacker could bombard an API with requests, overwhelming the server or attempting to guess credentials repeatedly.
  • Broken Function Level Authorization: Even if a user is authenticated, they might have access to functions or resources they shouldn't. This often occurs when access control checks are not granular enough, allowing a user with basic permissions to perform actions intended only for administrators.
  • Security Misconfiguration: This is a broad category encompassing many common errors, such as default security settings that are left unchanged, improper CORS policies, verbose error messages that reveal system details, or unpatched vulnerabilities in underlying software components.
  • Mass Assignment: This occurs when an API allows a client to update an object's properties without proper validation, potentially allowing an attacker to modify properties that should only be controlled by the server (e.g., changing a user's role from "standard" to "admin").
  • Denial-of-Service (DoS): A DoS attack on an API aims to make the API unavailable to legitimate users by overwhelming it with requests or exploiting vulnerabilities. This can lead to service disruptions, downtime, and potential reputational damage. This is usually accomplished by the attackers using techniques like, Request Flooding, Resource Exhaustion, Exploiting vulnerabilities.
  • Shadow APIs: These are the APIs that operates within an organization's environment without the knowledge, documentation, or oversight of the IT and security teams. These unmanaged APIs represent a significant security threat because they expand the attack surface and often lack essential security controls, making them an easy entry point for cybercriminals.

Proactive Testing: Building Resilience


Given the complexity and scale of API ecosystems, a proactive and comprehensive testing strategy is crucial. Relying solely on manual testing is no longer sufficient; automation is key. Following are some of the testing techniques:
 
  • Static Application Security Testing (SAST): SAST tools analyze your API's source code, bytecode, or binary code without executing it. They can identify potential vulnerabilities like injection flaws, insecure cryptographic practices, and hardcoded secrets early in the development lifecycle, allowing developers to fix issues before they reach production.
  • Dynamic Application Security Testing (DAST): DAST tools interact with the running API, simulating real-world attacks. They can identify vulnerabilities like broken authentication, injection flaws, and security misconfigurations by sending various requests and analyzing the API's responses. DAST is excellent for finding vulnerabilities that only manifest during runtime.
  • Interactive Application Security Testing (IAST): IAST combines elements of SAST and DAST. It works by instrumenting the running application and monitoring its execution in real-time. This allows IAST to provide highly accurate vulnerability detection, pinpointing the exact line of code where a vulnerability resides and offering context on how it can be exploited.
  • API Penetration Testing: Beyond automated tools, ethical hackers perform manual penetration tests to uncover complex vulnerabilities that automated scanners might miss. These "white hat" hackers simulate real-world attack scenarios, trying to exploit logical flaws, bypass security controls, and gain unauthorized access to the API.
  • Fuzz Testing: This technique involves feeding a large volume of malformed or unexpected data to an API endpoint to stress-test its resilience and uncover vulnerabilities or crashes that might not be apparent with standard inputs.
  • Schema Validation: Enforcing strict schema validation for all API requests and responses helps prevent malformed inputs and ensures data integrity, significantly reducing the risk of injection attacks and other data manipulation exploits.
  • Runtime Protection: This refers to the measures and tools implemented to safeguard APIs while they are actively listening and processing requests and responses in production environment. This form of protection focuses on real-time threat detection and prevention, ensuring that APIs function securely during their operational lifespan. API runtime protection is crucial because it addresses threats that may not be caught during the design or development phases.

Robust Governance: The Foundation of Security


Technical controls are vital, but without a strong governance framework, API security efforts can quickly unravel. Without governance, APIs become a “wild west” of inconsistent standards, duplicated efforts, and accidental exposure. Governance provides the policies, processes, and oversight necessary to maintain a secure API ecosystem at scale. Effective Governance includes:

  • API Security Policy & Standards: Establish clear, comprehensive security policies and coding standards that all API developers must adhere to. This includes guidelines for authentication, authorization, input validation, error handling, logging, and data encryption.
  • Centralized API Gateway: Implement an API Gateway as a single entry point for all API traffic. Gateways can enforce security policies (e.g., authentication, rate limiting, IP whitelisting), perform threat protection, and provide centralized logging and monitoring capabilities.
  • Access Control & Least Privilege: Implement robust Role-Based Access Control (RBAC) to ensure users and applications only have access to the specific API resources and actions they need to perform their functions. Adhere to the principle of least privilege.
  • Regular Security Audits & Reviews: Conduct periodic security audits of your API infrastructure, code, and configurations. Regular reviews help identify deviations from policy, outdated security measures, and new vulnerabilities.
  • Threat Modeling: Before developing new APIs, conduct threat modeling exercises to identify potential threats, vulnerabilities, and attack vectors. This proactive approach helps embed security into the design phase rather than trying to patch it on later.
  • Incident Response Plan: Develop a comprehensive incident response plan specifically for API security incidents. This plan should outline steps for detection, containment, eradication, recovery, and post-incident analysis.
  • Developer Training & Awareness: Educate your development teams on secure coding practices, common API vulnerabilities, and your organization's security policies. Continuous training is essential to keep developers informed about the latest threats and mitigation techniques.
  • Version Control & Deprecation Strategy: Securely manage API versions and have a clear strategy for deprecating older, less secure API versions. Attackers often target older endpoints with known vulnerabilities.
  • Continuous Monitoring & Alerting: Implement robust monitoring solutions to track API traffic, identify unusual patterns, detect potential attacks, and trigger alerts in real-time. This includes monitoring for authentication failures, unusually high request volumes, and suspicious data access patterns.

Conclusion 


Securing APIs at scale is an ongoing journey, not a destination and it is not just a technical challenge—it’s a strategic imperative. It requires a multifaceted approach that combines advanced technical testing with a strong governance framework and a culture of security awareness. By understanding the evolving threat landscape, implementing proactive testing methodologies, and establishing robust governance, organizations can build resilient API ecosystems that empower innovation while protecting sensitive data and critical business functions. The investment in API security today will undoubtedly pay dividends in preventing costly breaches and maintaining trust in an increasingly API-driven world.

Sunday, March 20, 2016

Big Data for Governance - Implications for Policy, Practice and Research

A recent IDC forecast shows that the Big Data technology and services market will grow at a 26.4% compound annual growth rate to $41.5 billion through 2018, or about six times the growth rate of the overall information technology market. Additionally, by 2020 IDC believes that line of business buyers will help drive analytics beyond its historical sweet spot of relational (performance management) to the double-digit growth rates of real-time intelligence and exploration/discovery of the unstructured worlds.

This predicted growth is expected to have significant impact on all organizations, be it small, medium or large, which include exchanges, banks, brokers, insurers, data vendors and technology and services suppliers. This also extends beyond the organization with the increasing focus on rules and regulations designed to protect a firm’s employees, customers and shareholders as well as the economic wellbeing of the state in which the organization resides. This pervasive use and commercialization of big data analytical technologies is likey to have far reaching implications in meeting regulatory obligations and governance related activities. 

Certain disruptive technologies such as complex event processing (CEP) engines, machine learning, and predictive analytics using emerging big-data technologies such as Hadoop, in-memory, or NoSQL illustrate a trend in how firms are approaching technology selection to meet regulatory compliance requirements. A distinguishing factor between big data analytics and regular analytics is the performative nature of Big Data and how it goes beyond merely representing the world but actively shapes it.


Analytics and Performativity


Regulators are staying on top of the big data tools and technologies and are leveraging the tools and technologies to search through the vast amount of organizational data both structured and unstructured to prove a negative. This forces the organizations to use the latest and most effective forms of analytics and thus avoid regulatory sanctions and stay compliant.  Analytical outputs may provide a basis for strategic decision making by regulators, who may refine and adapt regulatory obligations accordingly and then require firms to use related forms of analytics to test for compliance. Compliance analytics are not simply reporting on practices but also shaping them through accelerated decision making changing strategic planning from a long term top down exercise to a bottom up reflexive exercise. Due to the 'automation bias' or the underlying privileged nature of the visualization algorithms, compliance analytics may not be neutral in the data and information they provide and the responses they elicit.

Technologies which implement surveillance and monitoring capabilities may also create self-disciplined behaviours through a pervasive suspicion that individuals are being currently observed or may have to account for their actions in the future. The complexity and heterogeneity of underlying data and related analytics provides a further layer of technical complexity to banking matters and so adds further opacity to understanding controls, behaviours and misdeeds. 

 Design decisions are embedded within technologies shaped by underlying analytics and further underpinned by data. Thus, changes to part of the systems may cause a cascading effect on the outcome. Data accuracy may also act to unduly influence outcomes. This underscores the need to understand big data analytics at the level of micro practice and from the bottom up. 


Information Control and Privacy


The collection and storage of Big Data, raises concerns over privacy. In some cases, the uses of Big Data can run afoul of existing privacy laws. In all cases, organizations risk backlash from customers and others who object to how their personal data is collected and used. This can present a challenge for organizations seeking to tap into Big Data’s extraordinary potential, especially in industries with rigorous privacy laws such as financial services and healthcare. Some wonder if these laws, which were not developed with Big Data in mind, sufficiently address both privacy concerns and the need to access large quantities of data to reach the full potential of the new technologies.

The challenges to privacy arise because technologies collect so much data and analyze them so efficiently that it is possible to learn far more than most people had predicted or can predict . These challenges are compounded by limitations on traditional technologies used to protect privacy. The degree of awareness and control can determine information privacy concerns; however, the degree may depend on personal privacy risk tolerance. In order to be perceived as being ethical, an organization must ensure that individuals are aware that their data is being collected, and they have control of how their data is used. As data privacy regulations impose increasing levels of administration and sanctions, we expect policy makers at the global level to be placed under increased pressure to mitigate regulatory conflicts and multijurisdictional tensions between data privacy and financial services’ regulations.

Technologies such as social media or cloud computing facilitate data sharing across borders, yet legislative frameworks are moving in the opposite direction towards greater controls designed to prevent movement of data under the banner of protecting privacy. This creates a tension which could be somewhat mediated through policy makers’ deeper understanding of data and analytics at a more micro level and thereby appreciate how technical architectures and analytics are entangled with laws and regulations. 

The imminent introduction of data protection laws will further require organizations to account for how they manage information, requiring much more responsibility from data controllers. Firms are likely to be required to understand the privacy impact of new projects and correspondingly assess and document perceived levels of intrusiveness. 


Implementing an Information Governance Strategy


The believability of analytical results when there is limited visibility into trustworthiness of the data sources is one of the foremost concern that an end user will have.  A common challenge associated with adoption of any new technology is walking the fine line between speculative application development, assessing pilot projects as successful, and transitioning those successful pilots into the mainstream. The enormous speeds and amount of data processed with Big Data technologies can cause the slightest discrepancy between expectation and performance to exacerbate quality issues. This may be further compounded by Metadata complications when conceiving of definitions for unstructured and semi-structured data.  

This necessitates the organizations to work towards developing an enterprise wide information governance strategy with related policies. The governance strategy shall encompass continued development & maturation of processes and tools for data quality assurance, data standardization, and data cleansing. The management of meta-data and its preservation, so that it can be evidenced to regulators and courts, should lso be considered when formulating strategies and tactics. The policies should be high-level enough to be relevant across the organization while allowing each function to interpret them according to their own circumstances. 

Outside of regulations expressly for Big Data, lifecycle management concerns for Big Data are fairly similar to those for conventional data. One of the biggest differences, of course, is in providing needed resources for data storage considering the rate at which the data grows. Different departments will have various lengths of time in which they will need access to data, which factors into how long data is kept. Lifecycle principles are inherently related to data quality issues as well, since such data is only truly accurate once it has been cleaned and tested for quality. As with conventional data, lifecycle management for Big Data is also industry specific and must adhere to external regulations as such.

Security issues must be part of an Information Governance strategy whichwill require current awareness of regulatory and legal data securityobligations so that a data security approach can be developed based on repeatable and defensible best practices. 

Thursday, November 6, 2014

Enterprise Architecture Practice - Capabilities

Enterprise Architecture (EA) function now have an unprecedented chance to lead the way in identifying new business opportunities, thanks to the innovations in the web and mobile technologies and businesses realizing the business advantages of such advancements. EA serves a strategic business purpose by enabling business capabilities to be implemented via IT architecture and related IT delivery processes.

Though Enterprise Architecture is not a very new practice, the maturity level is still not the optimal in most enterprises. Seeing the benefits that the EA function can bring to the table,  many enterprises are attempting to setup the EA practice within, but are in fact struggling to get it right. EA not just science and not just art as well. It is a combination of art and science. Successful EA practice has been found to being able to demonstrate certain key capabilities. In the EA world, there is no such thing as 'one size fits all', as it is highly dependent on the enterprises' business, its objectives, goals, strategies and priorities, which is never the same across enterprises.

While the objective of this blog is to discuss about the key capabilities that the EA function should be able to demonstrate, it is also good to highlight out what EA is not.

What EA is not:
  • EA is NOT a project
  • EA is NOT about review 
  • EA is NOT a one-time activity
  • EA is NOT for IT
  • EA is NOT a strategy
  • EA is NOT all about cost-reduction
  • EA is NOT one-man show

A successful EA practice should consider practicing and demonstrating the following key capabilities:

Staying Relevant

As we all know, it is highly unlikely that an architectural solution that works well for one enterprise will work well for another in the same industry domain. This is because each enterprise has its own vision and mission to win over the competition and constantly wish to stand alone in the crowd in certain key areas. Staying relevant helps the EA function in aligning strategic and operational views of business with the underlying technology and service delivery processes. For this reason, the EA practice should strive to understand the vision, mission and strategies of the enterprise and continue to stay aligned to the same, so that the architectural solutions continue to stay relevant for the enterprise.

Technology & Architecture Vision

No doubt that modern enterprise largely depend on technology and in certain cases, the business in fact is driven by technology. Irrespective of whether technology drives the business or not, technology is a key enabler of the business. So, it becomes essential to have a technology vision, which is aligned to the business vision. It is needless to mention that having a vision will not be just enough, and the same shall be driven down to the operational processes and practices. Every architecture and governance process should derive the technology vision as envisaged and so the solutions continue to stay relevant and yield the intended results. The technology vision and strategy shall be such that leverages both new tech innovations and existing capabilities that will enable the business to achieve the target state. 

The goal of the architecture vision is to articulate how the proposed architecture will enable the business goals, respond to the strategic drivers, conform to the principles, and addresses the stakeholder concerns and objectives.

Transforming and automating operations

While leveraging the existing knowledge and resources is key in saving costs, it is important for the EA function to stay on top of the technology and business innovations and explore opportunities of leveraging the same so that the enterprise stays on course of achieving its target mission and vision. This is where the EA teams should consider leveraging Agile approaches, so that the target reference architecture also stays dynamic and relevant. The EA framework shall have an evolution cycle, so as to improve the framework itself and similarly the architecture solutions should also be continually evolved based on feedback and availability of enabling technologies and innovations.

It is needless to mention here that the EA function shall equally consider the 'Business As Usual' as any transformational initiative should not derail the enterprise from achieving its intended mission and vision.

Being the Change Leader

EA is all about bringing change for the good. i.e. EA programs is all about driving the enterprise from its current state to the target reference state, which is nothing but identifying and driving changes to various resources at various levels, so that the target state is achieved. This is yet another key capability that come down to the old adage of building “better, faster, cheaper” systems that provide agility to change or expand capabilities, in response to ever-changing business requirements. EA function leads the planning for these new system and technology capabilities, ensuring the best solutions to the business requirements by providing blueprints and implementation road maps to the design and delivery teams. They also provide a service to the other organizational functions by ensuring compliance of these solutions at critical design and delivery milestones.

Mitigating risk

As the emphasis shifts from cleaning up the legacy of systems and technologies to better planning and governance of new IS and IT initiatives, we see a corresponding shift in the role of the EA practice. The focus shifts from driving out costs to reducing risks associated with new programs, while ensuring timely delivery of new capabilities. 

Every architectural initiatives shall be subject to a risk review and decisions shall be made based on the business value expected out of it. The changing business and regulatory conditions might also impact the solutions and at times could end up the enterprises not being able to realize the intended value out of it. This where the "Fail Fast" approach would help in making the right decisions. Periodic reviews of the change or transformational projects should be conducted with a view to ascertain whether the intended value is not impacted with the current conditions. Thus being able to manage and mitigate the risks well is a key capability that the EA practice should demonstrate.

Overseeing investments

It is natural for enterprises to look for Return on Investments (RoI), as the capital has a cost. The EA practice shall consider the cost of capital and the investment requirements for various change initiatives and work with the related other functions to ensure that the benefits are quantified so as to ensure the investments yield desired returns. In cases where the benefits are not directly quantifiable, the EA team shall identify such indirect benefits derived out of such investments and shall ascertain the monetary value in a best possible manner. 

Governing the architecture

As said earlier, EA function is not a project and it is a continuous function. EA function shall put in place necessary framework to monitor and manage the architectural activities in a constant basis. Business architects in the EA function monitor the project portfolio, while IT architects govern technology solutions, leveraging reference architectures to build the future state in alignment with strategic road maps. The governance principles shall be applied to various architecture activities with an objective to ensure the strategy alignment, risk management, measuring & monitoring, optimal resource utilization.

Integrating people, processes, and technology
Considering the innovation around the areas of web, mobile, big data powered by social media, modern enterprises are looking forward to leverage these to derive maximum business value. In this direction, to stay competitive and relevant to the customer business, most successful organizations are rapidly moving towards the system of engagement architecture supported by digital collaboration platforms and social strategies devised by EA where EA would create an effective social governance model and an overall enterprise strategy. It necessitates a pervasive social layer that spans many different system of records and departments within an organization. Discussion would also enlighten more focus on expanding social footprint by delivering consistent digital experience and utilizing social content and online communities to increase collaboration with customers and other stakeholders.

Saturday, September 13, 2014

Principles of Information Governance

With the evolution of tools and technologies around big data, the variety and volume of customer information collected has increased many fold. This also requires the responsible use of such information by the organization. Many countries have promulgated legislations to regulate the use and protection of such information in every organization.

The set of multi-disciplinary structures, policies, processes and controls that are used to manage the customer information and thereby supporting the current and future reglatory, legal and operational requirements make up the Information Governance framework of the organization. Information governance goes beyond retention and disposition to include privacy, access controls, and other compliance issues. It is interesting to note that big data innovators recognize the importance of governance to the success of their projects.

The Principles identify the critical hallmarks of information governance and provide both a standard of conduct for governing information and metrics by which to judge that conduct. In doing so, they give assurance to the public and society at large that organizations of every kind are meeting their responsibilities with respect to the governance of information.

Transmational organizations looking forward to demonstrate the highest level of maturity in the Information Governance design their Governance framework based on the following key principles:


Accountability:

Accountability to is key for the success of any program and on the same lines, for the Information Governance, to be successfull shall have an accountable senior leader, who shall oversee the governance practices and should require regular reporting for monitoring purposes. The organization should adopt policies and procedures to guide its workforce and agents and ensure its program can be audited and continually improved to support the organization’s goals.

An information governance program should at the minimum:
  • Establish an information governance structure for program development and implementation
  • Designate a qualified accountable person to develop and implement the program
  • Document and approve policies and procedures to guide its implementation
  • Remediate identified issues
  • Enable auditing as a means of demonstrating the organization is meeting its obligations to both internal and external parties

A high maturity organization would demonstrate the following:
  • The organization’s senior management and its governing board place great emphasis on the importance of information governance. 
  • The records manager directs the records management program and reports to an individual in the senior level of management. 
  • The chief information governance officer and the records manager are essential members of the organization’s governing body. 
  • The organization’s initial goals related to accountability have been met, and it has an established process to ensure its goals for accountability are routinely reviewed and revised. 

Transparency

An organization’s processes and activities relating to information governance shall be documented in an open and verifiable manner. Documentation shall be available to the organization’s workforce and other appropriate interested parties within any legal or regulatory limitations, and consistent with the organization’s business needs. Transparency of the organization’s governance practices must extend to definitions of appropriate information uses and the processes for ensuring compliance with policies on appropriate information use.

An information governance program includes its information management and information control policies and procedures. To ensure the confidence of interested parties, records documenting the information governance program must themselves adhere to the fundamentals of information management.

At the highest maturity level, an organization should practice and demonstrate the following:
  • The organization’s senior management considers transparency as a key component of information governance. 
  • The software tools that are in place assist in transparency. 
  • Requestors, courts, and other legitimately interested parties are consistently satisfied with the transparency of the processes and the organization’s responses. 
  • The organization’s initial goals related to transparency have been met, and it has an established process to ensure its goals for transparency are routinely reviewed and revised. 

Integrity

An information governance program shall be constructed so the information generated by or managed for the organization has a reasonable and suitable guarantee of authenticity and reliability. Integrity of information, which is expected by patients, consumers, stakeholders, and other interested parties such as investors and regulatory agencies, is directly related to the organization’s ability to prove that information is authentic, timely, accurate, and complete. For the healthcare industry, these dimensions of integrity are essential to ensuring trust in information.

For safety, quality of care, and compliance with applicable voluntary, regulatory and legal requirements, integrity of information should include at least the following considerations:
  • Adherence to the organization’s policies and procedures
  • Appropriate workforce training on information management and governance
  • Reliability of information
  • Admissibility of records for litigation purposes
  • Acceptable audit trails
  • Reliability of systems that control information
Transformational organizations, which are at the highest maturity level should demonstrate the following abilities:
  • There is a formal, defined process for introducing new record-generating systems, capturing their metadata, and meeting other authenticity requirements, including chain of custody. 
  • Integrity controls of records and information are reliably and systematically audited. 
  • The organization’s initial goals related to integrity have been met, and it has an established process to ensure its goals for integrity are routinely reviewed and revised. 

Protection
An information governance program shall be constructed to ensure a reasonable level of protection to records and information that are private, confidential, privileged, secret, classified, essential to business continuity, or that otherwise require protection.

Information protection takes multiple forms. First, each system must enable management of security access controls. Only members of the workforce and other authorized parties with the appropriate levels of access or security clearance may access information relevant to their roles or duties. Reliably protecting electronic and physical assets requires use of tools such as user authentication, key card access restrictions, and other relevant measures. This also requires that as the workforce and other authorized parties transition in status or job function, respective level of access is changed immediately to a level appropriate to the new role and duties.

The highly matured organizations would practice and demonstrate the following:
  • Executives and/or senior management and other governing bodies (e.g., board of directors) place great value in the protection of information. 
  • Audit information is regularly examined, and continuous improvement is undertaken. 
  • Inappropriate or inadvertent information disclosure or loss incidents are rare. 
  • The organization’s initial goals related to protection have been met, and it has an established process to ensure its goals for protection are routinely reviewed and revised. 

Compliance

An information governance program shall be constructed to comply with applicable laws and other
binding authorities, as well as with the organization’s policies. Every organization should:
Know what information should be entered into its records to demonstrate its activities are being conducted in a lawful manner.
Enter that information into its records in a manner consistent with laws and regulations.
Maintain its information in the manner and for the time prescribed by law or organizational policy.
Develop internal controls to monitor adherence to rules, regulations, and program requirements, thus assessing and ensuring compliance.

The following capabilities when demonstrated will mark the highest maturity level:
  • The importance of compliance and the role of records and information in it are clearly recognized at the senior management and governing body levels.
  • Auditing and continuous improvement processes are well-established and monitored by senior management. 
  • The roles and processes for information management and discovery are integrated, and those processes are well-developed and effective. 
  • The organization suffers few or no adverse consequences based on information governance and compliance failures. 
  • The organization’s initial goals related to compliance have been met, and it has an established process to ensure its goals for compliance are routinely reviewed and revised. 

Availability
An organization shall maintain records and information in a manner that ensures timely, efficient, and accurate retrieval of needed information.

A successful and responsible organization must have the ability to identify, locate, and retrieve the information required to support its ongoing activities. This information may be used by:
  • The healthcare team, patients, and other caregivers Authorized members of the workforce and others authorized consistent with regulations 
  • Legal and compliance authorities for discovery and regulatory review purposes
  • Internal and external reviewers for purposes including but not limited to: payer audit, financial audit, case management, and quality assurance.
High maturity organizations practice and demonstrate the following:
  • The senior management and governing body provide support to continually upgrade the processes that affect records and information availability. 
  • There is an organized training and continuous improvement program across the organization. 
  • There is a measurable return on investment to the organization as a result of records and information availability. 
  • The organization’s initial goals related to availability have been met, and it has an established process to ensure its goals for availability are routinely reviewed and revised. 

Retention
An organization shall maintain its records and information for an appropriate time, taking into account its legal, regulatory, fiscal, operational, and historical requirements.

As part of its retention program, an organization must develop an information retention schedule, which specifies what information must be retained and for what length of time. Retention decisions are based on the type of information, and the organization’s legal, regulatory, fiscal, operational, clinical, role/mission, and historical requirements. Information retention schedules should be reviewed periodically and revised regularly. Some internal changes in the organization such as mergers and acquisitions or lines of business changes, or types of records generated, as well as external events such as legal, regulatory, or fiscal changes, may require revisions.

High maturity organizations consider practising the following:
  • Retention is an important item at the senior management and governing body level.
  • Retention is looked at holistically and is applied to all information in an organization, not just to official records. 
  • Information is consistently retained for appropriate periods of time. 
  • The organization’s initial goals related to retention have been met, and it has an established process to ensure its goals for retention are routinely reviewed and revised. 

Disposition
An organization shall provide secure and appropriate disposition for records and information that are no longer required to be maintained by applicable laws and the organization’s policies.

Disposition includes not only destruction, but also any permanent change in custodianship of the information, such as when it is transferred to another party due to a merger or acquisition of another hospital, clinic, or physician practice or when a organization discontinues a practice, service, or other business. In many cases, the appropriate disposition is the destruction of information, in which case the organization should ensure the information is transported and destroyed in a secure and environmentally responsible manner. The organization should document or certify that the information has been destroyed completely and irreversibly when required.

The processes of a high maturity organization should address the following:
  • The disposition process covers all records and information in all media. 
  • Disposition is assisted by technology and is integrated into all applications, data warehouses, and repositories. 
  • Disposition processes are consistently applied and effective. 
  • Processes for disposition are regularly evaluated and improved. 
  • The organization’s initial goals related to disposition have been met, and it has an established process to ensure its goals for disposition are routinely reviewed and revised.

Reference:

Sunday, August 24, 2014

Perspectives of Business Reference Model

We are all witnessing the steady progress of the Enterprise Architecture(EA) discipline and it is now well understood that the EA is not just about IT infrastructure and the Business Architecture(BA) forms an integral part of EA. Unlike in the past, when Business Architecture was used for the purpose of eliciting the requirements for the IT systems, BA is used to develop and describe the targe business model and work on a road map that will get the business towards the target. The Open Group, as part of its "World Class EA" series, has published a White Paper on the Buiness Reference with an objective of providing the need help to organizations in developing BA assets and plan for the future.


The Open Group has developed the Business Reference Model to facilitate description of a business model through the five perspectives. The following diagram provides an overview of the structure and content of the BRM:

Image Source: The Open Group's World Class EA: Business Reference Model white paper.


Environment Perspective:

The Environment perspective addresses the context within which an organization must operate. It describes the external factors, such as the competitors and customers for an organization, in addition to the pre-established strategy defined by the organization for market positioning. This perspective is intended to describe why an organization is motivated to undertake particular courses of action.

The goal of understanding the business environment is to provide a good contextual knowledge base that informs the creation of effective architectures in the Value Proposition, Operating Model, and Risk perspectives.

The business challenge is to gain and exploit insights into the market, competition, and customer base that allow the organization to position itself optimally (described through strategy).


Value Proposition Perspective:

The Value Proposition perspective describes the offering produced by the organization in terms of products, services, brand, and shareholder value. It creates a belief from the existing customer, prospective costumer, stakeholder, or other constituent groups within or outside the organization where the value will be experienced – usually in exchange for economic value or some form of compensation.

The goal of understanding the value proposition is that it defines the customer experience and sets shareholder expectations. The value proposition also provides a baseline set of needs that need to be fulfilled by the Operating Model perspective. 

The business challenge is to develop a value proposition that is able to attract a suitable customer base, fulfil the needs of the customer base effectively, and generate sufficient benefit to satisfy shareholder expectations. All this needs to be achieved in a way that is consistent with, and reinforces, brand image and brand values.


The Operating Model Perspective:

The Operating Model perspective describes the resources at the disposal of the organization that will be deployed to generate the value proposition. This perspective is intended to describe how an organization will be able to deliver on its value proposition. Capabilities are the core enablers to operate the business from the perspectives of people, process, technology, and information.

The goal of operating model design is to allow executives and planners to evaluate the business through a wide variety of lenses and viewpoints in order to identify desired and enhanced states of the organization.

The business challenge is to identify the correct alignment of resources that will deliver the necessary customer and shareholder experience. Typical trade-offs to evaluate when structuring capabilities include centralization versus federation, matrix organization structures versus vertical integration, core versus context analysis, and process alignment versus competency alignment. The results of these trade-offs will produce different levels of efficiency versus agility versus stakeholder experience across different areas of the business.

The Risk Perspective

The Risk perspective identifies the uncertainties that may surround an organization in its delivery of the value proposition. This perspective is intended to describe the threats that face an organization from within and without. Typically, organizations model their architecture around the known, repeatable aspects of business operations. However, within a complex and volatile environment, unforeseen circumstances frequently occur in ways that may be extremely damaging to the business.

The goal of risk analysis is to gain a full understanding of potential scenarios that may adversely impact the business and then to prepare appropriately to address those risks in the event that they occur.
The business challenge of risk modelling is to ensure that risks are adequately understood (it is a great challenge to test for completeness in an exercise of identifying unlikely or unforeseeable scenarios), the impact of risk is appropriately quantified (again, challenging to accurately determine when there is limited precedent), and the mitigation steps for risks are appropriate to the risk level (in many organizations, over-compensation for risk can be as damaging as under-compensation, as valuable business activities are curtailed due to risk concerns).


The Compliance Perspective

The Compliance perspective represents activities that the organization must carry out in order to assure that the value proposition is delivered using an acceptable standard of business practice. This perspective is intended to describe the constraints that prevent an organization from acting in negative, destructive, or inappropriate ways. In many cases, compliance can offer opportunities for organizations to differentiate, by being first to access new markets by being compliant with new legislation.

The Compliance perspective acts in a similar manner to the Environment perspective in that it influences across value proposition, operating model, and risk, constraining all activities of the business to be in compliance with standards of acceptability.

The goal of the compliance architecture is to adequately understand the compliance requirements that exist and to ensure that appropriate mechanisms are in place to ensure they are met.

The business challenge of compliance is to appropriately translate commercial, quality, ethical, legal, and regulatory constraints (which tend to be complex and open to interpretation) into a set of clear, unambiguous operational policies that can be followed consistently and at scale within a large organization. Interpretations that are too risk-seeking in nature will tend to generate compliance breaches, with associated financial and reputational penalties. Interpretations that are too risk-averse will tend to stifle business activities and reduce the ability of the business to change quickly to meet new environmental circumstances.


This blogs contains excerpts from the white paper "World Class EA: Business Reference Model" published by The Open Group and this white paper is available for download.

Sunday, June 29, 2014

Governance of Agile Delivery

Introduction

The Agile methodology brings in alternate approach to traditional project management, where success was hard to get. Typically used in software development, Agile methodology help businesses respond to unpredictability. By focusing on the repetition of smaller work cycles as well as the deliverables, agile methodology is described as “iterative” and “incremental”. In waterfall, development teams only have one chance to get each aspect of a project right. In an agile paradigm, every aspect of development viz. requirements, design, etc. is continually revisited. When a team stops and re-evaluates the direction of a project every two weeks, there’s time to change course. Because teams can develop software at the same time they’re gathering requirements, “analysis paralysis” is less likely to impede a team from making progress. Agile development preserves a product’s critical market relevance and ensures a team’s work doesn’t wind up on a shelf, never released. Considering the value delivery that the Agile methodology promises, its adoption has been on the rise and today most organizations, including Government are embracing Agile approaches.


Governance of Agile Delivery


Critics say that Agile methodology is all about working in an unstructured way and for that reason, they believe that governing agile practices is always a challenge. While some of the Agile principles appear to support such criticism, there are many cases where organizations have successfully implemented processes and frameworks towards governance of Agile practices. Agile practitioners believe that because the agile methods are designed to be self-assuring, when practiced right, there exists built-in governance and accountability.


More so, the agile practices are more collaborative and operates continuously, requiring the stakeholders to review and test the deliverables on a continuous basis and helps the team to take alternate course of action as may be needed. Collaborative culture helps resolution of problems quicker and makes decisions are made on time. This helps to have a continuous focus on the value forecast with respect to the business case and manage the risks that may potentially impact on the expected value.


Principles of Governance

The following are the key governance principles for a successful governance of Agile Delivery:

Focus on the value delivery - only do a task if it brings value to the business. This principle also recognizes the timely delivery of a task as the value derived is more likely to deteriorate with the delayed delivery. In case of Agile deliveries, the governance is continuous and at a work unit level. It should also focus on what activity is taking place and the value such task delivers.

Embrace Change - This another principle of Agile and the Governance framework should take this into consideration. This would mean that the decisions or work flows should be flexible enough to change course based on the feedback received. Given that all stakeholders collaborate, decisions should be taken across the table, without putting things on hold and for the purpose, all needed specialists should take part in the reviews.

Decide on the performance metrics - Another key principle of Agile methodology is to 'fail fast and learn quiuckly'. Given that the overall objective is to improve the certainty that the team will deliver a usable product or service of good quality, the teams should be able to identify and implement the right metrics that will accurately indicate the quality of the deliverables and the performance of the team. For example they measure tasks completed; rework they had to perform; the backlog list and the value of the product or service to the business at the end of each iteration. Teams display this information visually, updating it frequently. This makes progress transparent to business users and management. If senior managers require performance information to oversee projects, they define what the ‘must have’ data are. Performance reports for senior management become a task in each iteration and an output of the delivery team.

Collaboration - All stakeholders, including senior management, external assessors, business users and the development team should be partners in quality, and this collaborative approach is an essential change in mindset. The business owner and delivery team defines what ‘quality’ tests they will use and what results are acceptable at the outset of each iteration – the definition of ‘done’. Regular user feedback identifies whether the product or service is providing the expected business value at each stage. External assessors are not gatekeepers; rather they are an integral part of the team. The iterative approach ensures continual reviews and feedback on progress, so external assessors are not just involved at critical points as defined in a traditional project life cycle.

Focus on behaviours and not just processes and documentation - More specifically, the external reviews or assessments will be more effective in providing critical challenge if the assessors have high-end skills, including technical and Agile delivery experience. In addition, they provide better value if they continually review how the team is performing, using observation as their main method of evidence collection. The focus of such external review or assessment shall be on the following:
  • the skills and experience of the team;
  • the team dynamics – frequency and nature of communication inside and outside of the delivery team, and the level of input to the delivery team from the business;
  • the organisational culture – the level of commitment and openness;
  • the timing and nature of quality control by the delivery team – the testing and release framework;
  • the order in which the team tackled the tasks – prioritisation of actions and deliverables, the amount of actions in the backlog list;
  • the way the team changes its activity in response to the results achieved in each iteration; and
  • the value of outputs to the business.

IBM's Disciplined Agile Delivery Methodology


IBM believes Agile delivery allows it to continually issue new capabilities that meet user needs. It usually introduces software as part of a wider business change project so, to keep both in step, it has developed several Agile project methodologies. Disciplined Agile Delivery is a hybrid method that can be applied by a large number of teams working on the same project at the same time. The image below shows the Disciplined Agile Delivery life cycle. It starts with a few short iterations that allow the team and its stakeholders to identify the initial requirements, develop the architecture and agree a release plan. IBM also uses this to determine the system level properties and characteristics – the non-functional requirements. There are iterations after the business owner has decided that the system has sufficient functionality. These additional iterations are necessary for IBM to support the operation and maintenance of the solution once it is in service.



In contrast to the traditional approach of looking at outputs, plans, resourcing and how a project is organised, external assessors should focus on outcomes, prioritisation of work and team dynamics. The most useful indicators of success are how the teams are organising the delivery of an operational service or capability and what Agile behaviours and practices are used. Areas for assessment include whether:
system level issues (security, availability) are addressed within the iterations;
  • short- and longer-term planning exists;
  • the stakeholders have a shared vision;
  • there is continuous integration; and
  • the team has the right people


Reference:

National Audit Office's Review on Governance of Agile Delivery

Saturday, April 5, 2014

IT Procurement - The Pricing Woes

Most IT products (both hardware and software) targeted for home or individual end customers usually carry a standard rate card. Some large resellers, considering their sales volume may offer a discounted price and that may be about 5 to 10 percent. While this seem to be a fair game, on the enterprise products side, things are totally different. The buyer, reseller (be it integrator or just a distributor) and the principal vendors play a game of negotiation. The end result of this game mostly is that one or more players lose. This is in contrast to the win-win theory where it is expected that all the players win.

The principals offering such enterprise products don't seem to have a standard pricing policy. Instead, they price the product or service for the specific enterprise customer based on the deal volume, the strategic importance of the deal and the indirect values that can be derived out of a specific deal. The indirect benefits could range from an increased reach to the associates of the customer, a consent to publish case study which might improve the market ranking of the product or increased revenue figures which again is used to determine the market share of the product or service.

The discounts the enterprise customers get range from 40 to even 90 percent. Large enterprises manage to negotiate and get substantial discounts on such products and services. Neither the principals nor the resellers can expect any margin out of such deals, but look for indirect benefits. This could potentially lead to a situation, where the principals don't see the intended indirect benefits being realized, they tend to take a 'no-frills' approach and thus not actively contributing towards the business goals of the customer.

This kind of pricing approach also result in the smaller businesses end up compensating the benefits that the larger enterprises get. That is, the discounts that the large enterprises get is out of the gains that the principals and resellers make out of deals with smaller business entities. This is in a way like taxing the poor for the benefit of the rich and could very well be termed as corporate corruption.

Knowing this, customers try their best to engage into a hard negotiation and get the maximum discount. When it is good to get the price advantage, are they aware of the hidden perils that could get in their way? Here are some such things that could happen:


  • The principals are likely to cut corners to ensure that they maximise their gain out of the deal or minimize the loss out of the deal. This could mean anything like trimming down the features which were not explicitly demanded by the customer and charge the customer when such features are required by the customer.
  • Vendors take the tendency to tone down post sale service levels. This could be the reason for a contrasting experience or feedback from different customers for the same product or service.
  • Principals and / or resellers take the no-frills approach. That is customer cannot expect a 'Customer Delight' kind of offering. The principals and vendors would stick to deliver what has been committed and not a bit more.
  • Unduly longer time and efforts is lost in the process of negotiation, which can have an impact on the time to market advantages for the customer.


While the above could impact the value delivery, these should not come in way in the negotiation process and thus ending up agreeing for an unreasonably higher cost.  This is where a win-win approach is recommended. A win-win outcome is one that gets all parties more than what no agreement would have guaranteed them. Win-win agreements do no promise all sides equal or similar gains. They only promise that all sides get is an outcome that is better than their most realistic estimate of what they would have ended up with had they walked away with no agreement.


Sunday, February 9, 2014

The Principles of Effective Risk Management

Enterprise Risk Management is one of the core domain of Governance. In some business sectors, the success depends on an intelligent and effective risk management principles, framework and practices. The advancement in technology, like big data and analytics also plays a key role in making the risk management effective and adding value to the business. Other factors that necessitate a well architected ERM in an organization include, regulatory & compliance needs, security and privacy expectations, disasters and business continuity needs, etc. As the risk management practices evolved further, adoption of principle based approaches have been found to be more effective.


Here the some of the common principles to model the Risk Management framework around:

  • Create and protect value - Any framework should be able to add value and also protect the values that the assets of the organization is expected to deliver. This would also involve identifying the specific business needs, appropriately assess the risk measure and in turn facilitate deciding on the best risk mitigation or avoidance plan. Risk management must have demonstrable effect on achievement of objectives and improvement of performance of the enterprise.
  • Integrated approach - Risk management cannot be practiced effectively in silos. Today's organizations face the challenges of many different frameworks for meeting different goals. For instance, ISO27001 for security, ITIL for IT infrastructure management, COBIT for Governance, etc. Integrated risk management promotes a continuous, proactive and systematic process to understand, manage and communicate risk from an organization-wide perspective in a cohesive and consistent manner. To be effective, the Risk Management framework should be capable of being integrated into the existing process framework.
  • Recognise & manage complexity - Organisations are very complex environments in which to deliver concrete solutions. There are many challenges that need to be overcome when planning and implementing information management projects. In practice, however, there is no way of avoiding the inherent complexities within organisations. New approaches to information management must therefore be found that recognise (and manage) this complexity.
  • Flexible and adaptable - There is no "one-size-fits-all" approach to risk management and organizations should consider their own context when determining an appropriate approach. Organizations today face a considerable change management challenge for information management projects. In practice, it means that projects must be carefully designed from the outset to ensure that sufficient adoption is gained. The framework shall be tailored and responsive to the organization's external and internal context including its mandate, priorities, organizational risk culture, risk management capacity, and partner and stakeholder interests.
  • Highly usable - In general, the risk management practices should allow for the identification of risk information throughout the organization that can be used to support enterprise wide decision-making, and should also be flexible enough to evolve with changing priorities. This requires that every employee of the organization has a role to play in an effective Risk Management program. This calls for the structures and the associated processes should be simple enough to understand and also usable or executable. 
  • Dynamic and responsive to change - The process of managing risk needs to be flexible. The challenging environment we operate in requires agencies to consider the context for managing risk as well as continuing to identify new risks that emerge, and make allowances for those risks that no longer exist. Risk Management shall be deployed in a systematic, structured and timely manner to enable cost-effective embedding and focused generation of consistent, comparable and reliable results. 
  • Leverage tools & technology - An effective risk management calls for the ability to consider and make use of large volume of data and should leverage the statistical techniques to predict and prioritise the risks. Coming up with a right mitigation or contingency plan also calls for processing of large volume of data. The framework should provide for leveraging latest technology as it emerges to facilitate such high volume information handling and statistical analysis.
  • Considerate to human and cultural factors - The success of the risk management program largely depends on its employees in implementing it as part of their every day business activities. This calls for the structure and the processes to be considerate of the organization's cultural values and should not lead to creating conflicts. 
  • Communicate extensively - Communication is the key for success of any project or program. The framework shall provide for seamless communication amongst all stakeholders, so that the information is exchanged at the right time without losing its value.
  • Continuous Improvement - The big bang approach is unlikely to yield the expected outcome for obvious reasons. Instead, an evolutionary approach will work better and thus the ERM should be capable of evolving. Deployment should be complemented with mechanisms to assess and continually improve enterprise risk management maturity and be aligned with approaches driving the organization’s overall excellence and maturity agenda. 
  • Governance - Oversight and accountability for the risk management process is critical to ensure that the necessary commitment and resources are secured, the risk assessment occurs at the right level in the organization, the full range of relevant risks is considered, these risks are evaluated through a rigorous and ongoing process, and requisite actions are taken, as appropriate.

The above list is not an exhaustive list of principles that readily suits an organization. The right set of principles shall be identified based on the priorities of the business. These principles when adopted help the organizations to practice an improved risk management and thus giving the following benefits to the enterprise.
  • Enhance the coverage of risks in all areas including mission,strategy, planning, operations, finance.
  • Consider the causes of various risks and the resulting impacts.
  • Develop a culture in which employees manage risks as part of their daily routines.
  • Optimized risk appetite, so that the business functions can take take calculated risks.
  • Facilitate enterprise wide risk aware decision making.

Saturday, September 28, 2013

Strategies for Information Governance

No, we are not discussing about IT governance or Data Governance either. It is about Information Governance. Information is fast becoming the currency of the business organizations and it is an important asset that need to be protected, managed and governed. Physical records are giving way in favor of digital information and it is growing and moving beyond the boundaries of the enterprise. This opens up a new set of challenges in realizing the business value and managing the associated risks. To add to that a whole set of new and evolving regulatory requirements escalate the risks of privacy, security and retention. Now to understand what is Information Governance let us look at how Gartner defines it:

“The specification of decision rights and an accountability framework to encourage desirable behavior in the valuation, creation, storage, use, archival and deletion of information. It includes the processes, roles, standards and metrics that ensure the effective and efficient use of information in enabling an organization to achieve its goals.”

Looking at the above definition, we can say that the Information Governance is a framework for managing information life cycle from its creation through its deletion and defining accountability, retention, protection and quality aspects around the same. Obviously the framework should comprise of processes, standards, roles & responsibilities, metrics and tools and technology for effective and efficient use of the information. The framework should be in line with the strategies of the organization for Information Governance. So it is important to establish the strategies first and then build the framework around it.

Obviously the Information Governance Strategies shall be formed with due consideration to the following aspects of Information:

Classification: Information classification is one of the most crucial elements of an effective information governance process and yet it’s also the one that many organizations fail to implement well. In its simplest terms, Information classification is the process of categorizing information based on its level of sensitivity, perceived business value and its retention needs. While information classification based on sensitivity is mostly prevalent as most of the Information Security frameworks demand, for an effective and efficient information governance, the classification should represent the retention needs and the business value in addition to sensitivity. When done properly, the classification of information helps an organization determine the most appropriate level of safeguards, controls and usage guidelines that need to be in place. Organizations should be aware that data classification may change throughout the life cycle. It's important for data stewards to re-evaluate the classification of information on a regular basis, based on changes to regulations and contractual obligations, as well as changes in the use of the data or its value to the company.

Protection: Protection of data is an important Element of the information governance framework. Data security breaches now appear to be headline news almost on a weekly basis. The consequences can be
disastrous as organisations’ bottom line and reputation are impacted. Information management and protection is undoubtedly moving in keeping with organisational changes. A planned governance structure
for information allows organisations to support business expansion, while meeting regulatory and personal data protection laws. 

Retention: Organizations are obligated to respond to various information requests, be it litigation, audit or investigation. There are numerous legislations in various countries requiring retention of information for a certain period to be used as evidences. Certain countries have legislations that require non persistence of information, i.e. certain class of information not to be persisted for privacy reasons. Effectively balancing such complex retention requirements depends on proper identification and classification of the information and use of appropriate tools and technology.

Roles & Accountability: Historically, establishing robust information management was considered an IT challenge. The CIOs were expected to deliver the appropriate technology to support critical information reporting and management, and the CISOs, who are mostly aligned with IT functions, were expected to protect the information assets. This does not absolve the business functionaries from the accountability of the information that they create and manage. IT is just a facilitator and it is the business who owns and be responsible for the information throughout its life cycle. The overall requirements of any information asset must be specified, ultimately, by the business people who define, understand and own the process that handles its usage. 

Collaboration: The people who staff the functions that produce and use the information are the people who know its value, can point out the current version of documents, should know how long a given document or set of data is going to be useful from a business continuity perspective. Thus it is very important that their knowledge on these aspects of information is considered while formulating the information governance strategies. Committed involvement from every employee and an effective communication amongst all of them is the key in building a successful information governance framework. Continued collaboration of all the business and IT functions is also essential in sustaining the information governance program in the organization, so that various attributes that determine the information classification, its usage and its business value are constantly aligned to the changing landscape of regulatory and business needs.

Quality & Integrity: As the information is becoming a key asset of an organization and that many decisions are based on the information at hand, it is important that the quality and integrity of the information to be at the highest level, so that such decisions do not go against the organization. Appropriate processes or techniques to validate the quality and integrity of the information shall be put in place and those involved in the creation or discovery of the information shall ensure that appropriate checks are performed and ensure that the information so created is reliable.


Information Governance is a combination of business practices, technology and human capital for meeting the compliance, legal, regulatory, security requirements, and organizational goals of an entity. Information governance provides a means to protect, access, and otherwise manage data and transform it into useful information. While applying best practices such as physical and electronic security measures as well as creating policies for the disposition of data are critical to implementing an information governance strategy, available technology solutions and services can play a key role in several areas.

Wednesday, August 14, 2013

Agile in Fixed Price Fixed Scope projects - Hybrid Contracts

It is well known that the traditional methods are not yielding to a better success rate of a project and thus there is a tendency to lean on Agile Methodologies. At the same time, clients feel secure with Fixed Price and Fixed Scope project as their financial outlay is limited and there is no ambiguity. What they miss however in this process is the value delivery. The traditional project management methodologies focus on the Scope, Time and Resources where all three are constraints. Ideally the focus should be on the Value and Quality delivered, given the constraints there by guaranteeing a better success rate of the project.

The software vendors are doing business and they work to earn profits. As such, with Fixed Price projects, the vendors tend to limit their efforts to deliver the agreed scope. With the pace at which changes are happening around any business, freezing scope for a project early on is nearly impossible as software delivered to such scope frozen early on is often less usable. With change is the key driver in optimizing the value delivery, clients and vendors have conflicting views on the change.

Agile methodology has evolved over these years and offers a solution to the problem of optimized value delivery. However, clients still feel that Agile approach does not secure their interests in terms of a definite price and time. Of course, their concern is genuine as they cannot afford to sign a project contract where the cost and time are elastic. While the basic premise of Agile is to embrace the changes, to succeed, it depends on a very high level of trust between the vendors and the clients, where both should work for a common goal and the contract should be profitable to both.

Having said that the Fixed Price (FP) Fixed Scope (FS) contracts offer very limited opportunity for vendors to practice Agile methodology. Making either FP or FS elastic will give some room for practicing Agile methodology. Let us explore how this can be accomplished in the contracts. Both the above contracting models requires a high level of trust between both the vendors and the clients.

Fixed Price Elastic Scope (FPES) contract: In this model, while the price is fixed, the scope can be variable. This model can practice a hybrid Agile approach, the scope is broken down to features and the development happens feature by feature. Depending the time taken to implement a feature, more features are added or removed. For instance, if a feature estimated to take 30 days is implemented in 20 days, one or more new features can be added to fill the time saved. Similarly if the implementation takes 45 days, then one or more features will be removed.

To bring in incentive for both vendors and clients, a discount factor can be agreed upon, which is applied while adding or removing features. For instance, in a case where the vendor has saved 10 days for a feature, the client instead of adding a feature that needs 10 days to fill the gap, will only add a feature with 5 days of effort, where the discount factor would be 50%. The same discount factor is applied on the converse (where implementation exceeds the planned effort).

Elastic Price Fixed Scope (EPFS) contract: In this model, the Scope is fixed, but the pricing is variable. The idea behind this approach to is arrive at a base rate and a profit factor. While the base rate and the profit factor, along with the generic terms and conditions are covered in the Master Services Agreement, the actual project scope can be covered in multiple Statement of Works (SoW). Requirement elicitation and scoping can be the first SoW. This way, the project can be split into smaller working software modules and the work items can be scoped in stages / phases. This approach will help the clients in handling changes with ease.

Here again, an approach like 60:40:20 can be adopted to prioritize the work items. This approach requires the work items to be grouped into Must have features, Good to have features and Fixes. Every SoW can comprise of 60% of Must Haves, 40% of Good to haves and 20% of fixes emerged out of previous deliveries.

The incentives for both vendors and clients can be based on categorization of the work items as New feature, Clarification, Fixes. New features are the scope items as elaborated during elicitation. Clarifications are such items that emerge out of elicited requirements during the design or build phase. Fixes are incorrect implementations by the vendors, basically design and build defects. Costs for each SoW can be computed by applying the profit factor on the base rate. For instance, the New features will be charged at base rate + profit, clarifications will be charged at base rate and fixes will be charged at base rate - profit.

With the above, we are not concluding that Agile cannot be practiced in an FPFS project. There are still ways and means that a hybrid agile approach can be thought of and practiced so that value delivery is the primary focus for all the parties. Do share your thoughts in the form of comments on the subject, and I will cover those in my next blog.

Saturday, December 15, 2012

Effective vs Ineffective Security Governance

Continuing with my earlier blog on Measuring the Performance of EA, I was looking for methods and measures that can be used for measuring the effectiveness of the security program in an enterprise. I happened to read a CERT article titled as Characteristics of Effective Security Governance which contains a good comparision of what is effective and what is ineffective. I have reproduced it here in this blog for a quick reference. The original article of CERT though out dated is worth reading.

EffectiveIneffective or Absent
Board members understand that information security is critical to the organization and demand to be updated quarterly on security performance and breaches.

The board establishes a board risk committee (BRC) that understands security’s role in achieving compliance with applicable laws and regulations, and in mitigating organization risk.

The BRC conducts regular reviews of the ESP.

The board’s audit committee (BAC) ensures that annual internal and external audits of the security program are conducted and reported.
Board members do not understand that information security is in their realm of responsibility, and focus solely on corporate governance and profits.

Security is addressed adhoc, if at all.

Reviews are conducted following a major incident, if at all.

The BAC defers to internal and external auditors on the need for reviews. There is no audit plan to guide this selection.
The BRC and executive management team set an acceptable risk level. This is based on comprehensive and periodic risk assessments that take into account reasonably foreseeable internal and external security risks and magnitude of harm.

The resulting risk management plan is aligned with the entity’s strategic goals, forming the basis for the company's security policies and program.
The CISO locates boilerplate security policies, inserts the organization's name, and has the CEO sign them.

If a documented security plan exists, it does not map to the organization’s risk management or strategic plan, and does not capture security requirements for systems and other digital assets.
A cross-organizational security team comprised of senior management, general counsel, CFO, CIO, CSO and/or CRO, CPO, HR, internal communication/public relations, and procurement personnel meet regularly to discuss the effectiveness of the security program, new issues, and to coordinate the resolution of problems.CEO, CFO, general counsel, HR, procurement personnel, and business unit managers view information security as the responsibility of the CIO, CISO, and IT department and do not get involved.

The CSO handles physical and personnel security and rarely interacts with the CISO.
The general counsel rarely communicates particular compliance requirements or contractual security provisions to managers and technical staff, or communicates on an ad-hoc basis.
The CSO/CRO reports to the COO or CEO of the organization with a clear delineation of responsibilities and rights separate from the CIO.

Operational policies and procedures enforce segregation of duties (SOD) and provide checks and balances and audit trails against abuses.
The CISO reports to the CIO. The CISO is responsible for all activities associated with system and information ownership.

The CRO does not interact with the CISO or consider security to be a key risk for the organization.
Risks (including security) inherent at critical steps and decision points throughout business processes are documented and regularly reviewed.

Executive management holds business leaders responsible for carrying out risk management activities (including security) for their specific business units.

Business leaders accept the risks for their systems and authorize or deny their operation.
All security activity takes place within the security department, thus security works within a silo and is not integrated throughout the organization.

Business leaders are not aware of the risks associated with their systems or take no responsibility for their security.
Critical systems and digital assets are documented and have designated owners and defined security requirements.Systems and digital assets are not documented and not analyzed for potential security risks that can affect operations, productivity, and profitability. System and asset ownership are not clearly established.
There are documented policies and procedures for change management at both the operational and technical levels, with appropriate segregation of duties.

There is zero tolerance6 for unauthorized changes with identified consequences if these are intentional.
The change management process is absent or ineffective. It is not documented or controlled.

The CIO (instead of the CISO) ensures that all necessary changes are made to security controls. In effect, SOD is absent.
Employees are held accountable for complying with security policies and procedures. This includes reporting any malicious security breaches, intentional compromises, or suspected internal violations of policies and procedures.Policies and procedures are developed but no enforcement or accountability practices are envisioned or deployed. Monitoring of employees and checks on controls are not routinely performed.
The ESP implements sound, proven security practices and standards necessary to support business operations.No or minimal security standards and sound practices are implemented. Using these is not viewed as a business imperative.
Security products, tools, managed services, and consultants are purchased and deployed in a consistent and informed manner, using an established, documented process.

They are periodically reviewed to ensure they continue to meet security requirements and are cost effective.
Security products, tools, managed services, and consultants are purchased and deployed without any real research or performance metrics to be able to determine their ROI or effectiveness.

The organization has a false sense of security because it is using products, tools, managed services, and consultants.
The organization reviews its enterprise security program, security processes, and security’s role in business processes.

The goal of the ESP is continuous improvement.
The organization does not have an enterprise security program and does not analyze its security processes for improvement.

The organization addresses security in an ad-hoc fashion, responding to the latest threat or attack, often repeating the same mistakes.
Independent audits are conducted by the BAC. Independent reviews are conducted by the BRC. Results are discussed with leaders and the Board. Corrective actions are taken in a timely manner, and reviewed.Audits and reviews are conducted after major security incidents, if at all.


The article also lists eleven characteristics of effective security governance in addition to listing the Ten challenges to implementing an effective security governance. I would highly recommend you to read the full article.


References:
CERT’s resources on Governing for Enterprise Security


CERT and CERT Coordination Center are registered in the U.S. Patent and Trademark Office by Carnegie Mellon University

Thursday, December 13, 2012

Implementing IT Balanced Scorecard

Source: ISACA, Board Briefing on IT Governance 2nd edition

With IT increasingly becoming an enabler of business, more and more organizations are looking for effective and efficient management of IT, so that the investment in IT fetches optimum value. On the same lines, the need for better IT Governance is being felt by the Board of increasing number of organizations. One of the key domain of IT Governance is Performance Measurement. Going by "what is not measured cannot be managed", there need to be plans and processes in place for measuring the performance of IT so that it can be better governed.

Much of the value returned by IT are intangible. While it is easy to measure the tangible benefits, measuring intangible benefits is difficult. Business Scorecard (BSC) which evolved in the early 1990s has evolved into an very useful tool for measuring both tangible and intangible benefits segmented into four perspectives - Financial, Customer, Internal Process and Learning. IT BSC as derived from the Business Scorecards were found to be a a very effective measurement system addressing the concerns of reporting the intangible benefits to the Board.
The Balanced Scorecard as it has evolved over a period of time is being looked at not just as a performance measurement tool, but as a strategic planning and management system. This is because, the Balanced Scorecards can be cascaded down smaller business units including IT and aggregated upwards to the higher-level. IT BSC, which is cascaded from the Business Scorecard can be further subdivided into one for each of the technology domains, for instance one for managing the IT Operations and another to manage the IT Development areas. While doing so, it is important to maintain the linkages between each such cascaded Scorecards and this way the Balanced Scorecard can facilitate Strategy Mapping, thereby improving the Alignment of the objectives of the smaller business and IT units into the business strategy.


The perspective of the IT BSC may be redefined to better represent the IT organization. For instance, the following four perspectives may be used in IT BSC:

  • Corporate Contribution - Equivalent to the Finance perspective of the Balanced Scorecard, this represents the view of business executives on the IT department. 
  • Customer Orientation - Equivalent to the Customer perspective of the Balanced Scorecard, this represents the view of the end users on the IT department. 
  • Operational Excellence - Equivalent to Process perspective of the Balanced Scorecard, this represents the effectiveness and efficiency of various standards, processes and policies followed by the IT department. 
  • Future Orientation - Equivalent to Learning and Growth perspective of the Balanced scorecard, this represent a view of how well IT is prepared to meet the future needs of the business.

To be effective, the following three principles need to be built into the balanced scorecards:

  • Cause-and-effect relationships - the identified performance measures have a cause and effect relationships amongst them, for instance a measure on Improved developer skills (Future Orientation perspective) as a cause will result in improved quality in the applications delivered(Operational Excellence perspective), which in turn should contribute for user statisfaction (User Orientation perspective) 
  • Sufficient performance drivers - While it is common to measure all the possible outcomes (measuring what you have done), it is also important to identify and include suufficient performance drivers(how you are doing). A good mix of both outcome measures and performance drivers are essential for the Scorecard to be effective. 
  • Linkage to financial measures - IT Scorecard, being cascaded from the Enterprise Business Scorecard, the measures in the IT Scorecard should link up to a corresponding measure in the top-level business scorecard. 

To have the Balanced Scorecard implemented as part of the IT Governance initiative, the following steps are recommended:

  • Obtain commitment - Make a presentation to the board and executives explaining the concepts, benefits and cost of implementing it and get a commitment to go ahead. 
  • Kick-off - Kick off the Balanced Scorecard initiative as a project and as part of this activity, train the staff and identify the project team members. 
  • Strategy map - Get an understanding of the corporate business strategy and the sub unit level strategies and then establish a strategy map. 
  • Metrics selection - Understand the existing metrics if any and identify the required metrics, which should be a good mix of both outcome measures and performance drivers 
  • Metrics definition - With respect to each identified metric, create a standard definition, related processes to collect and manage the data. As part of this, the cause and effect relationships should also be clarified and the linkage with higher level scorecards should also be established. 
  • Assign ownership - Assign owners for each metric. 
  • Define Targets - With respect to each metric, set targets (may be a range) for the function heads to achieve and devise strategic initiatives to achieve these targets. 
  • Act on the results - Have the appropriate executive management or board as may be required to review the resulting measures and then act on the results. 
  • Review periodically - The metric definitions, the linkages and the cause-effect relationships may require revision based on experience and this achieved through periodic reviews. 

Successful execution of strategy requires the successful alignment of four components: the strategy, the organization, the employees and the management systems. As Kaplan and Norton put it, “Strategy execution is not a matter of luck. It is the result of conscious attention, combining both leadership and management processes to describe and measure the strategy, to align internal and external organizational units with the strategy, to align employees with the strategy through intrinsic and extrinsic motivation and targeted competency development programs and finally, to align existing management processes, reports and review meetings, with the execution, monitoring and adapting of the strategy.”