Fraud/White Collar Crime

 

 

https://sm.asisonline.org/Pages/The-Unique-Threat-of-Insiders.aspxThe Unique Threat of InsidersGP0|#28ae3eb9-d865-484b-ac9f-3dfacb4ce997;L0|#028ae3eb9-d865-484b-ac9f-3dfacb4ce997|Strategic Security;GTSet|#8accba12-4830-47cd-9299-2b34a43444652017-10-01T04:00:00Zhttps://adminsm.asisonline.org/pages/megan-gates.aspx, Megan Gates<p>​It’s perhaps the most infamous incident of an insider threat in modern times. During the spring and summer of 2013, then-National Security Agency (NSA) contractor and Sharepoint administrator Edward Snowden downloaded thousands of documents about the NSA’s telephone metadata mass surveillance program onto USB drives, booked a flight to Hong Kong, and leaked those documents to the media.</p><p>An international manhunt was launched, Snowden fled to Moscow, hearings were held in the U.S. Congress, and new policies were created to prevent another insider breach. The damage a trusted insider can do to an organization became painfully obvious.</p><p>“If you’d asked me in the spring of 2013…what’s the state of your defense of the business proposition as it validates the technology, people, and procedures? I would have said, ‘Good. Not perfect,’” said Chris Inglis, former deputy director and senior civilian leader of the NSA during the Snowden leaks, in a presentation at the 2017 RSA Conference in San Francisco.</p><p>“I would have said that ‘we believe, given our origins and foundations, and folks from information assurance, that that’s a necessary accommodation,” he explained. “We make it such that this architecture—people, procedure, and technology—is defensible.”</p><p>Inglis also would have said that the NSA vetted insiders to ensure trustworthiness, gave them authority to conduct their jobs, and followed up with them if they exceeded that authority—intentionally or unintentionally—to remediate it. </p><p>“We made a critical mistake. We assumed that outsider external threats were different in kind than insider threats,” Inglis said. “My view today is they are exactly the same. All of those are the exercise of privilege.”</p><p>Inglis’ perspective mirrors similar findings from the recent SANS survey Defending Against the Wrong Enemy: 2017 Sans Insider Threat Survey by Eric Cole, SANS faculty fellow and former CTO of McAfee and chief scientist at Lockheed Martin.</p><p>The SANS survey of organizations with 100 to 100,000 employees found that it can be easy to conclude that external attacks should be the main focus for organizations. </p><p>“This conclusion would be wrong. The critical element is not the source of a threat, but its potential for damage,” Cole wrote. “Evaluating threats from that perspective, it becomes obvious that although most attacks might come from outside the organization, the most serious damage is done with help from the inside.”​</p><h4>Insider Threat Programs</h4><p>Incidents like the Snowden leaks and the more recent case of Harold Thomas Martin III, an NSA contractor accused of taking top secret information home with him, along with other incidents of economic espionage have raised awareness of the impact insider threats can have. However, many organizations have not adjusted their security posture to mitigate those threats.</p><p>In its survey, SANS found that organizations recognize insider threat as the “most potentially damaging component of their individual threat environments,” according to the survey. “Interestingly, there is little indication that most organizations have realigned budgets and staff to coincide with that recognition.”</p><p>Of the organizations surveyed, 49 percent said they are in the process of creating an insider threat program, but 31 percent still do not have a plan and are not addressing insider threats through such a plan. </p><p>“Unfortunately, organizations that lack effective insider threat programs are also unable to detect attacks in a timely manner, which makes the connection difficult to quantify,” SANS found. “From experience, however, there is a direct correlation between entities that ignore the problem and those that have major incidents.”</p><p>Additionally, because many are not monitoring for insider threats, most organizations claim that they have never experienced an insider threat. “More than 60 percent of the respondents claim they have never experienced an insider threat attack,” Cole wrote. “This result is very misleading. It is important to note that 38 percent of the respondents said they do not have effective ways to detect insider attacks, meaning the real problem may be that organizations are not properly detecting insider threats, not that they are not happening.”</p><p>The survey also found that the losses from insider threats are relatively unknown because they are not monitored or detected. Due to this, organizations cannot put losses from insider threats into financial terms and may not devote resources to addressing the issue, making it difficult or impossible to determine the cost of an insider attack.</p><p>For instance, an insider could steal intellectual property and product plans and sell them to a competitor without being detected.</p><p>“Subsequent failure of that product might be attributed to market conditions or other factors, rather than someone ‘stealing it,’” Cole wrote. “Many organizations, in my experience, are likely to blame external factors and only discover after detailed investigation that the true cause is linked back to an insider.”</p><p>And when organizations do discover that an insider attack has occurred, most have no formal internal incident response plan to address it.</p><p>“Despite recognition of insiders as a common and vulnerable point of attack, fewer than 20 percent of respondents reported having a formal incident response plan that deals with insider threat,” according to the SANS survey. </p><p>Instead, most incident response plans are focused on external threats, Cole wrote, which may explain why companies struggle to respond to insider threats.</p><p>Organizations are also struggling to deal with both malicious and accidental insider threats—a legitimate user whose credentials were stolen or who has been manipulated into giving an external attacker access to the organization. “Unintentional insider involvement can pose a greater risk, and considerably more damage, by allowing adversaries to sneak into a network undetected,” the survey found. “Lack of visibility and monitoring capability are possible explanations for the emphasis on malicious insiders.</p><p>To begin to address these vulnerabilities, SANS recommends that organizations identify their most critical data, determine who has access to that data, and restrict access to only those who need it. Then, organizations should focus on increasing visibility into users’ behavior to be proactive about insider threats. </p><p>“We were surprised to see 60 percent of respondents say they had not experienced an insider attack,” said Cole in a press release. “While the confidence is great, the rest of our survey data illustrates organizations are still not quite effective at proactively detecting insider threats, and that increased focus on individuals’ behaviors will result in better early detection and remediation.”​</p><h4>Trusted People</h4><p>When the NSA recruits and hires people, it vets them thoroughly to ensure their trustworthiness, according to Inglis.</p><p>“We ultimately want to bring some­body into the enterprise who we can trust, give them some authority to operate within an envelope that doesn’t monitor their tests item by item,” he explained. “Why? Because it’s within that envelope that they can exceed your expectations and the adversary’s expectations, your competitors’ expectations, and hope­fully the customers’ expectations. </p><p>You want them to be agile, creative, and innovative.”</p><p>To do this, the NSA would go to great lengths to find people with technical ability and possible trustworthiness. Then it or a third party would vet them, looking at their finances and their background, conducting interviews with people who knew them, and requiring polygraph examinations.</p><p>After the Snowden leaks, the U.S. federal government examined the work of its contract background screening firm—United States Investigations Services (USIS). USIS had cleared both Snowden and the Washington Navy Yard shooter Aaron Alexis. The government decided to reduce its contracted work with the company.</p><p>USIS later agreed to pay $30 million to settle U.S. federal fraud charges, forgoing payments that it was owed by the U.S. Office of Personnel Management for conducting background checks. The charges included carrying out a plot to “flush” or “dump” individual cases that it deemed to be low level to meet internal USIS goals, according to The Hill’s coverage of the case.</p><p>“Shortcuts taken by any company that we have entrusted to conduct background investigations of future and current federal employees are unacceptable,” said Benjamin Mizer, then head of the U.S. Department of Justice’s Civil Division, in a statement. “The Justice Department will ensure that those who do business with the government provide all of the services for which we bargained.”</p><p>This part of the process—vetting potential employees and conducting background checks—is where many private companies go wrong, according to Sandra Stibbards, owner and president of Camelot Investigations and chair of the ASIS International Investigations Council.</p><p>“What I’ve come across many times is companies are not doing thorough backgrounds, even if they think they are doing a background check—they are not doing it properly,” she says. </p><p>For instance, many companies will hire a background screening agency to do a check on a prospective employee. The agency, Stibbards says, will often say it’s doing a national criminal search when really it’s just running a name through a database that has access to U.S. state and county criminal and court records that are online.</p><p>“But the majority of counties and states don’t have their criminal records accessible online,” she adds. “To really be aware of the people that you’re getting and the problem with the human element, you need to have somebody who specializes and you need to…invest the money in doing proper background checks.”</p><p>To do this, a company should have prospective employees sign a waiver that informs them that it will be conducting a background check on them. This check, Stibbards says, should involve looking at criminal records in every county and state the individual has lived in, many of which will need to be visited in person.</p><p>She also recommends looking into any excessive federal court filings the prospective employee may have made.</p><p>“I’ll look for civil litigation, especially in the federal court because you get people that are listed as a plaintiff and they are filing suits against companies for civil rights discrimination, or something like that, so they can burn the company and get money out of it,” Stibbards adds.</p><p>Additionally, Stibbards suggests looking for judgments, tax liens, and bankruptcies, because that gives her perspective on whether a person is reliable and dependable.</p><p>“It’s not necessarily a case break­er, but you want to have the full perspect­ive of if this person is capable of managing themselves, because if they are not capable of managing themselves, they may not make the greatest employee,” she says.</p><p>Companies should ensure that their background screenings also investigate the publicly available social media presence of potential employees. Companies can include information about this part of the process in the waiver that applicants sign agreeing to a background check to avoid legal complications later on. </p><p>“I’m going to be going online to see if I see chatter about them, or if they chat a lot, make comments on posts that maybe are inappropriate, if they maintain Facebook, LinkedIn, and Twitter,” Stibbards says. </p><p>Posting frequently to social media might be a red flag. “If you find somebody on Facebook that’s posting seven, eight, nine, or 10 times a day, this is a trigger point because social media is more important to them than anything else they are doing,” Stibbards adds.</p><p>And just because a prospective employee is hired doesn’t mean that the company should discontinue monitoring his or her social media. While ongoing review is typically a routine measure, it can lead to disciplinary action for an employee who made it through the initial vetting process. For instance, Stibbards was hired by a firm to investigate an employee after the company had some misgivings about certain behaviors.</p><p>“Not only did we find criminal records that weren’t reported, but we then found social media that indicated that the employee was basically a gang member—pictures of guns and the whole bit,” Stibbards says.</p><p>It’s also critical, once a new employee has been brought on board, to introduce him or her to the culture of the organization—an aspect that was missing in Snowden’s onboarding process, Inglis said. This is because, as a contractor working for the NSA, regulations prohibited the U.S. government from training him. </p><p>“You show up as a commodity on whatever day you show up, and you’re supposed to sit down, do your work—sit down, shut up, and color within the lines,” Inglis explained.</p><p>So on Snowden’s first day at the NSA, he was not taken to the NSA Museum like other employees and taught about the agency’s history, the meaning of the oath new employees take, and the contributions the NSA makes to the United States.</p><p>“Hopefully there are no dry eyes at that moment in time, having had a history lesson laying out the sense of the vitality and importance of this organization going forward,” Inglis explained. “We don’t do that with contractors. We just assume that they already got that lesson.”</p><p>If companies fail to introduce contractors and other employees to the mission of the organization and its culture, those employees will not feel that they are part of the organization.​</p><h4>Trusted Technology</h4><p>Once trusted people are onboarded, companies need to evaluate their data—who has access to it, what controls are placed on it to prevent unwarranted access, and how that access is monitored across the network.</p><p>“The one thing I always recommend to any company is to have a monitoring system for all of their networks; that is one of the biggest ways to avoid having issues,” Stibbards says. “Whether it’s five people working for you or 100, if you let everybody know and they are aware when they are hired that all systems—whether they are laptops or whatever on the network—are all monitored by the company, then you have a much better chance of them not doing anything inappropriate or…taking information.”</p><p>These systems can be set up to flag when certain data is accessed or if an unusual file type is emailed out of the network to another address. </p><p>Simon Gibson, fellow security architect at Gigamon and former CISO at Bloomberg LP, had a system like this set up at Bloomberg, which alerted security staff to an email sent out with an Adobe PDF of an executive’s signature.</p><p>“He’s a guy who could write a check for a few billion dollars,” Gibson explains. “His signature was detected in an email being sent in an Adobe PDF, and it was just his signature…of course the only reason you would do that is to forge it, right?”</p><p>So, the security team alerted the business unit to the potential fraud. But after a quick discussion, the team found that the executive’s signature was being sent by a contractor to create welcome letters for new employees.</p><p>“From an insider perspective, we didn’t know if this was good or bad,” Gibson says. “We just knew that this guy’s signature probably ought not be flying in an email unless there’s a really good reason for it.”</p><p>Thankfully, Bloomberg had a system designed to detect when that kind of activity was taking place in its network and was able to quickly determine whether it was malicious. Not all companies are in the same position, says Brian Vecci, technical evangelist at Varonis, an enterprise data security provider.</p><p>In his role as a security advocate, Vecci goes out to companies and conducts risk assessments to look at what kinds of sensitive data they have. Forty-seven percent of companies he’s looked at have had more than 1,000 sensitive data files that were open to everyone on their network. “I think 22 percent had more than 10,000 or 12,000 files that were open to everybody,” Vecci explains. “The controls are just broken because there’s so much data and it’s so complex.”</p><p>To begin to address the problem, companies need to identify what their most sensitive data is and do a risk assessment to understand what level of risk the organization is exposed to. “You can’t put a plan into place for reducing risk unless you know what you’ve got, where it is, and start to put some metrics or get your arms around what is the risk associated to this data,” Vecci says. </p><p>Then, companies need to evaluate who should have access to what kinds of data, and create controls to enforce that level of access. </p><p>This is one area that allowed Snowden to gain access to the thousands of documents that he was then able to leak. Snowden was a Sharepoint administrator who populated a server so thousands of analysts could use that information to chase threats. His job was to understand how the NSA collects, processes, stores, queries, and produces information.</p><p>“That’s a pretty rich, dangerous set of information, which we now know,” Inglis said. “And the controls were relatively low on that—not missing—but low because we wanted that crowd to run at that speed, to exceed their expectations.”</p><p>Following the leaks, the NSA realized that it needed to place more controls on data access because, while a major leak like Snowden’s had a low probability of happening, when it did happen the consequences were extremely high. </p><p>“Is performance less sufficient than it was before these maneuvers? Absolutely,” Inglis explained. “But is it a necessary alignment of those two great goods—trust and capability? Absolutely.”</p><p>Additionally, companies should have a system in place to monitor employees’ physical access at work to detect anomalies in behavior. For instance, if a system administrator who normally comes to work at 8:00 a.m. and leaves at 5:00 p.m. every day, suddenly comes into the office at 2:00 a.m. or shows up at a workplace with a data storage unit that’s not in his normal rotation, his activity should be a red flag.</p><p>“That ought to be a clue, but if you’re not connecting the dots, you’re going to miss that,” Inglis said.  ​</p><h4>Trusted Processes</h4><p>To truly enable the technology in place to monitor network traffic, however, companies need to have processes to respond to anomalies. This is especially critical because often the security team is not completely aware of what business units in the company are doing, Gibson says.</p><p>While at Bloomberg, his team would occasionally get alerts that someone had sent software—such as a document marked confidential—to a private email address. “When the alert would fire, it would hit the security team’s office and my team would be the first people to open it and look at it and try analyze it,” Gibson explains. “The problem is, the security team has no way of knowing what’s proprietary and valuable, and what isn’t.”</p><p>To gather this information, the security team needs to have a healthy relationship with the rest of the organization, so it can reach out to others in the company—when necessary—to quickly determine if an alert is a true threat or legitimate business, like the signature email. </p><p>Companies also need to have a process in place to determine when an employee uses his or her credentials to inappropriately access data on the network, or whether those credentials were compromised and used by a malicious actor. </p><p>Gibson says this is one of the main threats he examines at Gigamon from an insider threat perspective because most attacks are carried out using people’s credentials. “For the most part, on the network, everything looks like an insider threat,” he adds. “Take our IT administrator—someone used his username and password to login to a domain controller and steal some data…I’m not looking at the action taken on the network, which may or may not be a bad thing, I’m actually looking to decide, are these credentials being used properly?”</p><p>The security team also needs to work with the human resources department to be aware of potential problem employees who might have exceptional access to corporate data, such as a system administrator like Snowden.</p><p>For instance, Inglis said that Snowden was involved in a workplace incident that might have changed the way he felt about his work at the NSA. As a systems administrator with incredible access to the NSA’s systems, Inglis said it would have made sense to put a closer watch on him after that incident in 2012, because the consequences if Snowden attacked the NSA’s network were high.</p><p>“You cannot treat HR, information technology, and physical systems as three discrete domains that are not somehow connected,” Inglis said.</p><p>Taking all of these actions to ensure that companies are hiring trusted people, using network monitoring technology, and using procedures to respond to alerts, can help prevent insider threats. But, as Inglis knows, there is no guarantee.</p><p>“Hindsight is 20/20. You have to look and say, ‘Would I theoretically catch the nuances from this?’”   ​</p>

Fraud/White Collar Crime

 

 

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https://sm.asisonline.org/Pages/Teller-Trouble.aspx2017-03-01T05:00:00ZTeller Trouble
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https://sm.asisonline.org/Pages/Playing-Clean.aspx2016-12-01T05:00:00ZPlaying Clean
https://sm.asisonline.org/Pages/Book-Review---Anti-Fraud-Program-Design.aspx2016-06-01T04:00:00ZBook Review: Anti-Fraud Program Design
https://sm.asisonline.org/Pages/Book-Review---Fraud-Identification-and-Prevention.aspx2016-06-01T04:00:00ZBook Review: Fraud Identification and Prevention
https://sm.asisonline.org/Pages/Upping-the-Ante-on-Corruption.aspx2016-03-01T05:00:00ZUpping the Ante on Corruption
https://sm.asisonline.org/Pages/Shrink-Expands.aspx2016-02-12T05:00:00ZShrink Expands
https://sm.asisonline.org/Pages/Defense-Corruption.aspx2016-02-03T05:00:00ZDefense Corruption
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https://sm.asisonline.org/Pages/Book-Review---White-Collar-Crime.aspx2015-09-01T04:00:00ZBook Review: White Collar Crime
https://sm.asisonline.org/Pages/Fuga-de-Información-Médica.aspx2015-06-10T04:00:00ZFuga de Información Médica
https://sm.asisonline.org/Pages/Swiping-Medical-Data.aspx2015-06-01T04:00:00ZSwiping Medical Data

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https://sm.asisonline.org/Pages/Access-Under-Control.aspxAccess Under Control<p>​<span style="line-height:1.5em;">Companies spend significant resources on access control equipment. Estimates of the size of the global market range from about $6 billion to around $22 billion, and a recent ASIS survey indicates that 57 percent of U.S. businesses will be increasing access control spending through 2016. </span></p><p>Upfront costs are just the start. Security professionals take time to determine which doors need to be locked and when.  They decide where to install readers and decide how to pro­cess visitors. Despite the effort spent on the access control equipment layout and maintenance, over time the access control database can become mismanaged. Requests for tweaks to reader groupings and access levels are continuous. One group may want time restrictions for the janitorial crew; another group may need access to one door but want to restrict others. If these accommodations are made without regard for the overall system, over time a complicated tangle of access control levels is created. The next thing you know, security no longer controls access; access control takes charge of the organization’s security, resulting in a chaotic mess.</p><p>BB&T, a large financial services institution headquartered in Winston-Salem, North Carolina, has protocols in place that ensure appropriate and accurate administration of access control systems at its corporate locations. The Fortune 500 company has more than 1,800 financial centers in 12 states.  In addition, it has approximately 120 corporate buildings–data centers, operations centers, call centers, corporate and regional headquarters–that have access control systems. ​</p><h4>Challenges</h4><p>Regulatory developments over the last decade make it necessary to closely maintain access control data. The Health Insurance Portability and Accountability Act of 1996 and Gramm-Leach-Bliley Act of 1999 require health­care and financial organizations, respectively, to keep strict watch over sensitive and personal information. The Sarbanes-Oxley Act of 2002 forced a strengthening of internal controls within corporations. More recently, the Payment Card Industry Data Security Standard requires that companies keep tight control over credit and debit card data. </p><p>These regulations, as well as others that affect specific industries, have brought more scrutiny to the administration of access control data. Most large organizations, especially those in regulated industries, have experienced an increase in audit activity as it relates to physical access controls. This means that regular reviews of access reports are required in many cases. For this reason, it is critical that the data in a company’s access control database be clean and accurate.  </p><p>Numerous challenges can arise from failing to properly maintain an access control system. Maintenance lapses can result in thefts when, for example, terminated employees get into a facility. What good is an access control system if, due to negligence in maintaining the system, people can enter places they shouldn’t? If your access control database has been around for years and has turned into a Byzantine web of access permissions, what steps can be taken to get control over the data? </p><p>Access control database administrators must have an ongoing process of maintaining the accuracy of the data. A standards-based approach must be taken to manage any effective access control program. Standards include defining the types of users in the system–employees, vendors, visitors, temporary card users– and establishing credentials for which each of these user categories will be managed and reviewed. Once the user categories are defined, space definitions and ongoing maintenance procedures must be established. ​</p><h4>Database management</h4><p>BB&T categorizes its cardholders into three groups based on the users’ network login ID. There are employees and contractors with a company network login ID; vendors, tenants, and others without a company network login ID; and temporary users. BB&T uses the network login ID for employers and contractors because the network ID is also used in the IT security database. This allows security to match the IT access records to the physical access records. Human resource data was considered for this match, but the bank determined that many vendors, temporary employees, and contractors who have a BB&T network login ID are not included in its human resource system. Matching the network login ID covers a majority of the organization’s users. If the records do not match, the user’s access is terminated.   </p><p>For cards not involved in the matching process, BB&T identifies a company employee who can serve as a sponsor for each vendor and tenant. The company conducts quarterly reviews of those cards, during which the company sponsor ascertains whether the vendor or tenant employee still works for the third-party company and still needs the BB&T card.</p><p>All temporary cards in the system are assigned to the individuals who have the cards in their possession. The temporary cards may be used by visitors, trainees, vendors, and employees who forgot their badge at home. Information on the cardholder is housed within the access control database. Quarterly reports for all temporary cards are sent to one person who is responsible for ensuring that their temporary cards are accounted for.  ​</p><h4>Space</h4><p>BB&T has established criteria and definitions of the physical space in its environment and categorizes space into three categories: critical, restricted, and general. Criteria are established for each category of space. The critical category is reserved for high-risk, critical infrastructure areas, such as server rooms or HVAC sites. Restricted space is office space for departments that the company deems restricted. All critical and restricted space is assigned a space owner. The space owner is then responsible for approving or denying people’s access to that area. General access areas are common doors and hallways.</p><p>For each category of space, standards are established on how access is governed. For example, the data center standards might state that janitors or nonessential personnel are not granted access without an escort. Standards also dictate who can approve access to that space and how often access reports should be reviewed. For example, critical and restricted space reports are reviewed monthly or quarterly.</p><p>Access devices are grouped together based on the categories of space and the users that access the space. This streamlines the access request process and makes it easier for the requestors to understand what access they are selecting. Grouping as many readers together as possible minimizes the number of possible groupings meaning that there are fewer choices for those requesting access. It also makes it easier to ensure that access reports are accurate, and it simplifies the process of approving access and access report reviews. If all readers for critical space to a building are grouped together, only one approval would be required for critical space and only one report would need to be reviewed.  </p><p>However, in some cases, minimizing groupings may not possible. For example, one group of users may be allowed into the IT area but only a subset of that group has access to the server room that resides within the lab. In this case, groups would be categorized by the users rather than the readers.</p><p>It’s also important to make sure that access levels and device groupings don’t overlap. This can complicate the request process and the report reviews and could cause access reports to reflect an incomplete list of users who have access to a space. For example, in a building with three readers, grouping one may include the front and back doors, and grouping two may include the communications room. If, in addition to these two groupings, there is an overarching grouping three that includes all three readers, this could create a problem since each of the three individual readers belong to two different groupings. In this scenario, if a request is made to determine who has access to the communications room, rather than producing a report of the communications room reader group, an additional report of the group of all three readers would need to be provided. In many organizations, this second step is missed, causing an inaccurate representation of those with access to a specific area. This can be a major issue if discovered during an audit.</p><p>Another way to remedy this issue would be to run reader reports on individual doors, in this example, a reader report on the communications room only. Most access control systems allow for this type of report. However, in companies with a large number of individual card readers, this would require many more reports. The same users often need access to multiple doors, so combining them into groupings that don’t overlap makes more sense than running individual reader reports. As a rule, BB&T does not allow a reader that has been deemed critical or restricted to belong to more than one reader grouping. This ensures that access reports are accurate and complete.  It does, however, require that a user who needs access to a full building, such as a janitor or security officer, request access to each area of the building rather than requesting overarching access to the entire building. This is beneficial, not only for reporting reasons, but also because it requires that space owners approve all users who have access to their space and holds the space owners responsible for knowing who is entering their space. Controls in the report review process can be set up to ensure that a space owner does not remove access for a janitor or security officer. Some systems allow cards to be flagged and would require a higher level of scrutiny before access is removed. Nonetheless, this is a cleaner way to set up access levels and ensures that space owners will review a report of all users that have access to their space, which is what most auditors are looking for.   ​</p><h4>Clean-Up</h4><p>If an access control system has become muddled over time, a database clean-up is recommended. A good place to start is to deactivate all cards that have not been used in a specific timeframe, such as the previous six months. Thus there will be fewer cards to review. Then, security can find a common piece of data with another database in the company that provides a match of current employees. Human resource or information security data is best to determine whether active cardholders in the system still work for the company. Of the remaining cards for nonemployees, visitors, tenants, and contractors, security should research whether the card users can be associated with a manager or employee within the company. Security can work with these internal partners to implement an ongoing review of access cards. ​</p><h4>Maintenance</h4><p>Performing a regular match of human resource or information security data ensures that cards are deactivated for users whose information does not match that on the card. If a user is not captured in the match, that person should be assigned to a sponsor for quarterly review to determine whether any credentials need to be terminated. Access reports should be reviewed for all nongeneral space to ensure that users still need access to the designated areas. Such reviews should take place at regular intervals–not more than quarterly. An important piece of the access request process is to ensure that all necessary information is captured to support the new standards and to support the report review. For example, if the request is for a visitor, security should capture the name of the person who will have that card in their possession during the request.   ​</p><h4>Automation</h4><p>BB&T is working to upgrade the auto­mation of its access control request and audit reporting system by the end of 2015. It is considering software that automates the entire access control database management process from the onboarding human resource system to the access control system. This would include a software interface that would be fully integrated with the information security credentialing system. The ideal software would fully integrate with the access control system where approved access is automatically provisioned with no human intervention.</p><p>Cost is a major factor in implementing such automation. Some companies choose to automate pieces of the process. Some use a simple Web portal form that sends e-mails to approvers and ultimately e-mails the request to the team that provisions access or provides a dashboard for the access control team to view requests. Many companies have integrated with human resource or information security data to update their access control system, which allows for the automatic deactivation of cards for terminated employees, vendors, or contractors. Others have found a way to automate the report reviews. Few access control manufacturers provide these additional software tools in combination with their access control software. Some will work with or direct their customers to third-party solutions, while others are beginning to see the need for automation and are incorporating pieces into their standard software package, such as more robust reporting capabilities.  </p><p>These efforts may seem daunting, but once the standards are set and the database is cleaned up, ongoing maintenance is initiated, and some level of automation is implemented, the system will be under control. It is imperative that security professionals see beyond the equipment and installation and not rely solely on these for protection. A sound maintenance program ensures that, should access control processes be called into question, security can be confident that the company’s program is under control.  </p><p>--</p><p><em><strong>Briggette Jimenez, CPP,</strong> is physical security manager at BB&T where she manages the company’s security command center, security operations, and workplace violence prevention programs.</em></p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://sm.asisonline.org/Pages/Training-Your-Team.aspxTraining Your Team<p>​</p><p>Whether the action is on the battlefield or the basketball court, you can be certain that the winning team owes its success in large measure to extensive training. Recognizing the importance of training to any team’s performance, the Cincinnati Children’s Hospital Medical Center set out to makes its own training program better. </p><p>The existing training program, which the director of protective services felt lacked specificity, consisted of one of the shifts’ veteran officers sitting with the new security employees and covering several department and hospital-specific policies along with administrative topics. Additionally, the new officers would be given several commercially produced security training videotapes to view, after which they were required to complete the associated tests. Following the completion of the tapes and review of the policies and administrative procedures, officers would go through brief hands-on training for certain subjects such as the use of force and pepper spray.</p><p>Once they completed these tests and training sessions, the officers would then begin their on-the-job training. Officers have historically stayed in the on-the-job phase of training between three and five weeks, depending on how quickly the officers learned and were comfortable with command center operations. When the officers completed their training program, they had to pass the protective services cadet training test as well as a test on command center procedures.</p><p>Training council. To help devise a better training program, the security director chose several members of the staff to sit on a training council. The group, which included the director, three shift managers, and the shift sergeants, met to discuss the current training program and what could be done to enhance it.</p><p><br>Through discussions with new employees, the council learned that the existing program was boring. The council wanted to revitalize the training to make it more interesting and more operationally oriented. The intent was to emphasize hands-on, performance-oriented training. The council also wanted to improve the testing phase so that the program results could be captured quantitatively to show the extent to which officers had increased their knowledge and acquired skills. <br> <br>Phases. The council reorganized training into four phases: orientation, site-specific (including on-the-job), ongoing, and advanced. Under the new program, the officers now take a test both before training, to show their baseline knowledge, and after the training, to verify that they have acquired the subject matter knowledge; they must also successfully demonstrate the proper techniques to the instructors.</p><p>Orientation training. The orientation training phase begins with the new employees attending the hospital’s orientation during their first day at the facility. The security department’s training officer then sits down with the new officers beginning on their second day of employment. This training covers all of the basic administrative issues, including what the proper clock-in and clock-out procedures are, when shift-change briefings occur, and how the shift schedules and mandatory overtime procedures function.   </p><p>The training officer also administers a preliminary test to the new officers that covers 12 basic security subjects including legal issues, human and public relations, patrolling, report writing, fire prevention, and emergency situations. New employees who have prior security experience normally score well on the test and do not need to view security training tapes on the subjects. The officers must receive a minimum score of 80 percent to receive credit for this portion of the training. If an officer receives an 80 percent in most topics but is weak in one or two subjects, that officer is required to view just the relevant tapes, followed by associated tests.</p><p>All officers, regardless of the amount of experience, review the healthcare-specific tapes and take the related tests for the specific subjects including use of force and restraint, workplace violence, disaster response, bloodborne pathogens, assertiveness without being rude, and hazardous materials. Also included in the orientation training phase are classes covering subjects such as pepper spray, patient restraint, defensive driving, and the hospital’s protective services policies.</p><p>Site-specific training. During site-specific training, officers learn what is entailed in handling specific security reports. The shift manager, shift officer-in-charge, or the training officer explains each of the reports and has the new employee fill out an example of each. Examples of reports covered in site-specific training include incident reports, accident reports, field interrogation reports, fire reports, motorist-assist forms, ticket books, safety-violation books, broken-key reports, work orders, bomb-threat reports, and evidence reports.</p><p>On-the-job training is also part of the site-specific training phase. The new employee works with a qualified security officer for a period of two to three weeks following the first week of orientation training with the departmental training officer. The new employee works through all of the various posts during this time. At least one week is spent in the command center. The site-specific phase of training culminates with both the security officer cadet training exam and the command center exam, which were also given in the original program.</p><p>Ongoing training. The ongoing training includes refresher training in which shift managers have their officers review selected films covering healthcare security and safety subjects. The training occurs during shift hours. The officers also receive annual refresher training covering topics such as using pepper spray and employing patient-restraint methods.</p><p>Another type of ongoing training, shift training, is conducted at least weekly. Managers conduct five-to ten-minute meetings during duty hours to refresh the security staff on certain subjects, such as customer service. These sessions are not designed to deal with complex topics. Managers can tie these sessions to issues that have come up on the shift.</p><p>Advanced training. Advanced training includes seminars, management courses, and sessions leading to professional designations and certifications. Qualified personnel are urged to attend seminars sponsored by several professional societies and groups such as ASIS International, the International Healthcare Association for Security and Safety, and Crime Prevention Specialists. Staff members are also encouraged to attain the Crime Prevention Specialist (CPS) certification, the Certified Protection Professional (CPP) designation, and the Certified Healthcare Protection Administrator (CHPA) certification.</p><p>Staff members are urged to pursue special interests by obtaining instructor certification such as in the use of pepper spray or the use of force. This encouragement has already paid off for the hospital. For example, the department’s security systems administrator has trained officers on each shift in how to exchange door lock cylinders, a task that would previously have required a contractor. Officers are currently being trained to troubleshoot and repair CCTV, access control systems, and fire alarm equipment problems.</p><p>Training methods. A special computer-based training program was developed to help quantify and track the success in each of the training modules. Additionally, a program was developed to present training subjects during shift changes.</p><p>Computer training. Security used off-the-shelf software to create computer-based training modules and included them in the site-specific training and ongoing training phases, both of which occur during shift hours. The training council tasked each shift with creating computer-based training modules for the various security officer assignments on the hospital’s main campus and off-campus sites. These training modules cover life safety, the research desk, the emergency department, exterior patrols, foot and vehicle patrols, and the command center.</p><p>The training council asked officers to participate in the creation of the computer-based training modules. The officers produced the training modules during their respective shifts when it did not interfere with other responsibilities.  </p><p>The group participation paid off. For example, the officers who created the command center and the emergency-department training modules not only spent several hours discussing what information should be included in the modules, but then allowed their creativity to flow by using the software to make these modules interactive. These particular modules include test questions of the material, and the program will respond appropriately to the employees as they answer the questions correctly or incorrectly. The volunteers also created tests for before and after an officer goes through each of the computer modules to track the effectiveness of the training.</p><p>Shift-change training. A major question with ongoing training is how to fit it into the officer’s routine. For most industries using shift work, difficulties arise when trying to carve out enough training time without creating overtime. The training council decided to take advantage of downtime that occurs as officers come to work ready for their shift to begin. They are required to show up six minutes before the shift. This time is now used for training.</p><p>The shift-change training is used to cover specific topics—already covered in some of the training phases—that can be easily encapsulated into a six-minute program. For example, some topics include departmental policies, radio communication procedures, command center refresher sessions, self-defense subjects, confronting hostile people, proper report writing, and temporary restraint training. By implementing the shift-change training sessions on a weekly basis, the department created an additional five hours of training per year for each officer.</p><p>One of the security supervisors created a six-minute training binder to house all of the lesson plans. Each shift supervisor uses the same lesson plan so that the training is consistent across the shifts. As with all other training, the before-and-after tests are given to quantitatively document changes in subject knowledge or skills.</p><p>Results. After implementing the training program, the training council wanted to check the initial results to see whether the training was effective. There were numerous quantifiable measurements that the council could use to evaluate the new training program, such as tracking the rate of disciplinary actions from the previous year to the current year. However, since the council desired to have a quick assessment of the training program changes, it decided to compare the after-training test scores to the before-training test scores for the computer-based training modules as well as the scores of the six-minute training tests. </p><p>To the council’s surprise, the initial tabulated scores resulted in an average before-training test score of 93 percent and an after-training test score of 95 percent. The council also found in many of the officers’ tests that they missed the same questions on both the before and after tests.</p><p>Based on these results, the council decided to make several changes. First, the test questions were reviewed and tougher questions were added. Based on the preliminary test score, the council felt that the questions were not challenging enough and might not indicate how competent the officers were with the subject matter. </p><p>The training council assigned each shift the task of revising the tests for their computer-based training modules as well as the six-minute training tests. The goal was to make the tests more challenging and to obtain more accurate assessments of the effectiveness of the training program. </p><p>The training council also reviewed how the different shifts were conducting the six-minute lessons. Managers noted that the shifts initially followed the schedule of the six-minute subjects from week to week, but then they began to conduct their own lessons without an accepted lesson plan or to forgo training altogether. </p><p>To avoid this problem, the training council determined that the training program needed to be more structured. The group created a schedule to indicate which class would be covered each week. One of the shift supervisors volunteered to take over the six-minute training program and formally structure it so that each shift would conduct training in a consistent manner.</p><p>The training council has plans to further hone the training program in the near future. The council plans to analyze the program us­ing other quantitative evaluative instruments such as an employee survey and a comparison of disciplinary action data from previous years. </p><p>In battle, it is said that an army fights as it has trained. Thus, commanders know the value of training. In the businessworld, though the stakes are different, training is no less critical to the success of the mission.</p><p>Ronald J. Morris, CPP, is senior director of protective services at Cincinnati Children’s Hospital Medical Center. Dan Yaross, CPP, is manager of protective services. Colleen McGuire, CPS (crime prevention specialist), is sergeant of protective services. Both Morris and Yaross are members of ASIS International.</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465