Corporate custodians of confidential medical data should be closely monitoring events connected to a nightmarish computer security breach in the St. Louis region.

Express Scripts is one of the nation’s largest pharmacy benefits managers. The company, with headquarters in St. Louis County, handles approximately 500 million prescriptions per year for 50 million workers at 1,600 American companies. Early in October, it received an extortion letter, the details of which it released on Nov. 6.

The letter included personal information on about 75 Express Scripts clients — Social Security numbers, dates of birth and, in some cases, information about prescription medications. Whoever sent the letter demanded money from the company — the amount has not been disclosed — and threatened to use the Internet to reveal personal and medical information about millions of people if the demands were not met.

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Beyond the scale of the problem for Express Scripts — and the potential impact on the company is enormous — the issue extends well beyond the mounting concerns about identity theft, a phenomenon with which most people have become at least somewhat familiar.

The greater problem is the unique nature of personal medical records, the importance of moving to computerization of such records to improve health safety and reduce costs and the irreversibility of the damage people can suffer if confidential medical information becomes public. The stakes are so high that a federal law establishes strict standards for maintaining the privacy of medical information and stiff fines for failing to do so.

Medical records of all kinds — paper and, especially, electronic — must be protected with the most sophisticated kinds of security systems available, including backup protections and automatic alerts of security violations. Yet Express Scripts learned of this breach in the “worst way,” as InformationWeek.com security correspondent George Hulme put it in an online report: “via an extortion letter.”

The Express Scripts breach raises many questions for all elements of the health industry: hospitals, clinics and doctors’ practices, benefits management firms, insurance companies, pharmacies, employers and government agencies:
Are they using the most advanced information security technology possible? Do they minimize the amount of data they collect and keep it only as long as necessary? Do they have strict protocols governing access to personal and medical data — and systems to enforce those protocols? If criminals were to hack into their systems, how would the companies know? How soon? And are the systems capable of instantly cutting off illegal access as soon as a breach is discovered?

Confronted with a grave breach of electronic security, Express Scripts has responded by contacting law enforcement, establishing an informational website, offering a substantial reward and hiring a private consulting firm to help clients who have privacy concerns and investigate situations that “appear to be tied to identity theft” and provide “identity restoration services.” There is no question that the company is taking the situation extremely seriously.
Given the ongoing criminal situation, information about how Express Scripts’ data systems were compromised — and whether it could have been avoided — has yet to be disclosed. But the American people have the right to expect that their sensitive personal and medical information is zealously protected and kept secure — not only by Express Scripts but also by every person or company entrusted with it.

"Customers and customer relationships...have tangible measurable value to businesses, and their value is much easier to communicate to those who fund projects. So in an enterprise risk management scenartio, their vlaue informs the risk management process...[For example, consider] a farmer deciding which crop to grow. A farmer interested in short term profits may grow the same high yield crop every year, but over time this would burn the fields out. The long term focused farmer would rotate the crops and invest in things that build the value of the farm and soil over time. Investing in security on behalf of your customers is like this. The investment made in securing your customer's data build current and future value for them. Measuring the value of the customer and relationships helps to target where to allocate security resources."

Blogger: Dan Blum

With the crisis in financial markets still unfolding, it is important to draw what lessons we can from the experience. Since the roots of the crisis lie in a monumental failure of risk management, it’s important to understand more about what happened, and then draw some parallels to our business risk management and  IT risk management situations.

The risk management failure in the housing market and on Wall Street had multiple interdependent dimensions:

• Mortgage lenders abandoned long standing prudent loan practices. They made too many loans that buyers might not be able to repay. Exotic instruments like ARMs, option ARMs, and interest only loans proliferated. In many cases, all pretense of lending standards were abandoned, so-called “liar loans” approved.
• Capital was grossly over-leveraged. Mortgage lenders and other financial services packaged loans into securities, which they sold to raise capital to support more lending. Real capital reserve requirements to back loans were reduced. Of course, if borrowers could not repay loans, all or parts of the derivative securities would become worthless.
• Risk was aggregated at Fannie Mae, Freddie Mac, and mortgage loan insurance companies. These companies bought or insured some mortgage loans, providing something of a backstop should loans fail. Government sponsored enterprises (GSEs) Fannie and Freddie in turn became over-leveraged and securities that they sold were in turn repackaged in the murky brew of mortgage-backed securities called collateralized debt obligations (CDOs) and other exotic instruments returning generous yields.
• Non-Caveat Emptor. Institutional wealth funds and financial services firms who should have known better bought securities that had been deliberately structured to obfuscate risk. They bought securities they didn’t understand with buried tranches of toxic subprime loans..

It was a great Ponzi scheme – one that kept working as long as housing prices were going up; the recipients of subprime loans could always flip that house to the next buyer. Everyone made money. As Chuck Prince of Citigroup famously put it during a July, 2007 interview: “So long as the music is playing, you’ve got to keep dancing. We’re still dancing.” But one month later, the music stopped. Since then, Citigroup and other financial institutions have taken massive writeoffs with more to come. Wall Street titans like Bear Sterns, Lehman Brothers, Merrill Lynch, and AIG have fallen or been bought out.

What can we learn from this risk management debacle?

As business risk managers and investors, we should ask questions like these:

• Does the executive incentive structure of the company encourage managers to dance around risk? Many Wall Street firms paid senior managers 5 times their salary in bonuses tied to annual growth alone.
• Is the company over-leveraged? Is it borrowing too much money and betting it on ventures with uncertain outcomes?
• Are financial models used for risk management realistic? Earlier, I described the mortgage market of the past few years as a Ponzi scheme, where risk management models must have assumed prices would keep rising. Unlike the dotcom boom whose demise many predicted, very few in the industry foresaw the sharp declines to come in housing prices and sales volumes. Historically, the U.S. housing market has been a steadily rising one, but on the other hand the 2000s saw unprecedented rates of price increases. In reality, what goes up must come down.
• Has your company’s risk council ever performed worst case scenario analysis and built adequate reserves? In the days before economics emerged as a would-be “hard” deterministic science, business leaders may have been more cautious, more aware of and more accepting of uncertainty. Events like the Great Tulip Bubble came once in decades or centuries – not every few years. Note that legendary investor George Soros has proposed a Theory of Reflexivity that, if true, helps explain the recent extremes of boom and bust cycles. This theory holds that market participants model market behaviors based on self-interest, and for a time, their manipulations change the reality of the market – until gravitational forces bring it back to earth. Has the music of ephemeral success played to the backbeat of deterministic-sounding economic models gone to your heads and infected your risk management models?
• Are cost cutting efforts pursued blindly? Outsourcing and other forays into treacherous global waters may be giving away the crown jewels. Smart companies cut costs, but they do it in smart ways. Smart companies think like intelligence agencies as they parcel out work to different partners with varying levels of dependability, and they check on those partners.

Risk management failures can also occur at the more technical level of IT security. As IT risk managers, we might ask questions like these:

• Are the accounting and financial systems your IT department supports under adequate control? As Fred Cohen wrote in one of our documents: “Many companies use computers to manage financial systems, and despite the Sarbanes-Oxley Act (SOX) claims about accounts being properly kept, there are many attacks on financial systems that remain. For example, most of the largest financial systems in the world running on common financial databases do not use double-entry bookkeeping and are thus susceptible to all manner of frauds by insiders.” We find it troubling that a prudent control dating back to the 12th century is going out of style in the name of convenience and cost cutting. Kind of like credit checking became anachronistic during the housing bubble, eh?
• Is the “separation” in your “separation of duty” (SoD) for real? Sure the SOX auditors are looking for SoD, and maybe you have different administrators with different accounts maintaining different systems or functions. But when they say Western civilization may be but one weak password from collapse they’re not lying. Look what happened to Sarah Palin’s email account! Weak and straggly SoD is a problem across all critical IT systems where deperimiterization and server consolidation may be bringing down protective barriers, identity management is weak, and strong process controls (e.g., where two people must sign on, one perform a critical operation such as backbone router reconfiguration, and the second observe) abandoned in the name of expediency.
• Are risks being aggregated to unacceptable levels in centralized control systems? There are many ways that risks aggregate within enterprise IT infrastructures as we pursue automation and cost cutting. Network risks aggregate when centralized domain name system control is implemented. Application risks aggregate when common infrastructure is shared among applications. And enterprises aggregate platform risks when they use low-assurance endpoints, authentication, and directory systems with single sign-on to access large numbers of resources and don’t separate high consequence systems.
• Non-caveat emptor: Has IT security really done the worst case consequence analysis, attack graphs, and vulnerability analysis to know when putting more eggs in a supposedly stronger basket aggregates risks to an unacceptable level? Or are you depending only on vendor claims about some black box appliance equivalent of a risk-obfuscated CDO security? Caveat emptor (buyer beware) again! (The good news is we’ll keep talking about promoting vendor and product rating systems so you don’t have to do all the detailed product analysis yourself, but that’s another post.)

There are many parallels between the monumental risk management failure in the financial markets, and the probable weaknesses in our day to day business risk management and IT risk management. Abandonment of prudent practices for profit; excessive leverage and centralization; ill-constructed risk analysis models; risk obfuscation; and a failure of caveat emptor seem to be common problems. Please take this as a wakeup call to sharpen up the risk management thinking, process, and execution.

If you look at the news, you’ll see layoffs, buyouts, bankruptcy, going-out-of-business– there are a lot of companies in trouble right now

Ebay — laying off around 1500 workers.

Corbis — Cutting 170 Jobs, as its start-up rival Photoshelter closes its doors.

Washington Mutual in trouble

HP cutting 24,600 jobs

B of A – stocks tumble as the bank buys Merrill Lync

Fannie Mae and Freddie Mac taken over by the Feds a couple weeks back

I’ve read in many places that even though the economy is headed under, tech is still going strong. But with fewer jobs overall and less confidence, tech is sure to take a tumble as well. These are tough times that aren’t going to be solved by going out and buying buttons for your favorite political candidate.

It's not just terrorism; it's any rare risk in the news. The big fear in Canada right now, following a particularly gruesome incident, is random decapitations on intercity buses. In the US, fears of school shootings are much greater than the actual risks. In the UK, it's child predators. And people all over the world mistakenly fear flying more than driving. But the very definition of news is something that hardly ever happens. If an incident is in the news, we shouldn't worry about it. It's when something is so common that its no longer news - car crashes, domestic violence - that we should worry. But that's not the way people think.

Psychologically, this makes sense. We are a species of storytellers. We have good imaginations and we respond more emotionally to stories than to data. We also judge the probability of something by how easy it is to imagine, so stories that are in the news feel more probable - and ominous - than stories that are not. As a result, we overreact to the rare risks we hear stories about, and fear specific plots more than general threats.

The problem with building security around specific targets and tactics is that its only effective if we happen to guess the plot correctly. If we spend billions defending the Underground and terrorists bomb a school instead, we've wasted our money. If we focus on the World Cup and terrorists attack Wimbledon, we've wasted our money.

It's this fetish-like focus on tactics that results in the security follies at airports. We ban guns and knives, and terrorists use box-cutters. We take away box-cutters and corkscrews, so they put explosives in their shoes. We screen shoes, so they use liquids. We take away liquids, and they're going to do something else. Or they'll ignore airplanes entirely and attack a school, church, theatre, stadium, shopping mall, airport terminal outside the security area, or any of the other places where people pack together tightly.

These are stupid games, so let's stop playing. Some high-profile targets deserve special attention and some tactics are worse than others. Airplanes are particularly important targets because they are national symbols and because a small bomb can kill everyone aboard. Seats of government are also symbolic, and therefore attractive, targets. But targets and tactics are interchangeable.

The following three things are true about terrorism. One, the number of potential terrorist targets is infinite. Two, the odds of the terrorists going after any one target is zero. And three, the cost to the terrorist of switching targets is zero.

We need to defend against the broad threat of terrorism, not against specific movie plots. Security is most effective when it doesn't require us to guess. We need to focus resources on intelligence and investigation: identifying terrorists, cutting off their funding and stopping them regardless of what their plans are. We need to focus resources on emergency response: lessening the impact of a terrorist attack, regardless of what it is. And we need to face the geopolitical consequences of our foreign policy.

In 2006, UK police arrested the liquid bombers not through diligent airport security, but through intelligence and investigation. It didn't matter what the bombers' target was. It didn't matter what their tactic was. They would have been arrested regardless. That's smart security. Now we confiscate liquids at airports, just in case another group happens to attack the exact same target in exactly the same way. That's just illogical.

This essay originally appeared in The Guardian. Nothing I haven't already said elsewhere.