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Sarbanes Oxley: Article

Assuring Compliance with Content Security

Lessons from the trenches

Employees aren't only clever at figuring out new methods for private communication, but also at figuring out more creative ways to do it. Many companies, for example, have figured out that cell phone cameras are a potential security risk and have banned them from the premises. And yet, the combination of instant messaging and low-cost Web cameras is every bit as lethal, but many AUPs have yet to catch up.

Web Browsing - Get Real
Companies have discovered that just as too lenient an AUP can lead to trouble so can a policy that's too rigid - because it can't be enforced. In most situations, for example, it's simply not realistic to ban any correspondence that is not 100% business-related. Human nature being what it is, even crusty security guys can spend a few minutes browsing ESPN.com. Here's the trap: once you have known violations, if you don't prosecute, then the policy becomes null and void, giving you no legal standing to enforce it. The better course is to create a policy that seeks a realistic balance. For example, you might specify that personnel are allowed to use the Internet for personal use (within the bounds of a company's anti-harassment policy) six hours a month, or only during a lunch break, or for 10% of their time. That gives employees the ability to check their bank accounts and eBay bids, and gives your AUP the flexibility it needs to pass muster.

You may find it also makes sense to have different AUPs, depending on the circumstance. To cite one extreme example, one customer, an energy company, had an AUP for the crew on an oilrig that essentially said: "Anything goes." The isolated environment and lengthy stays justify what, in a different setting, would be an irresponsible AUP. But note that when drilling crews return to the mainland, that policy stays back on the rig. While this approach may make logical sense, without automated tools to assist you in enforciong these different AUPs, putting this approach into practice is nearly impossible.

An Ongoing Process
It might sound like a cliché, but compliance turns out to be a process, not a goal. One of the biggest issues facing IT is convincing management to fund additional compliance projects, as well as maintaining the existing ones. When the regulations were first introduced, their visibility in the press, particularly with Sarbanes-Oxley, alerted executive teams to the need for funding. What IT departments are now discovering is that sustainable funding for ongoing compliance is much more difficult to secure. In some companies, the finance department expected that the budget would return to prior levels when in fact, compliance is an ongoing, never ending process. The people in the trenches know that, and the challenge is in communicating that message above.

Compliance regulations are here to stay. They will be tested in the field, refined by the courts, and, no doubt, augmented by further legislation down the line. The biggest lesson learned is one any Boy Scout can relate to: be prepared.

More Stories By Kimber Spradlin

Kimber Spradlin is a senior compliance architect at NetIQ corporation with eight years of experience in the information security field. She is a security subject matter expert currently focusing on understanding the needs of, and communicating with, the regulatory and policy compliance market.

More Stories By Skip Dostine

Skip Dostine is the product marketing manager for NetIQ's Marshal Content Security Solutions. With more than 25 years of international technology experience, Skip's background includes sales, product planning, project management and engineering, as well marketing and operations.

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