It Is Too Hard Or Impossible…

July 15, 2014

** Admitting that you don’t know how to make the sausage will always cast doubt on the quality of the sausage you do produce. **

One of my personal risk management aggravations relates to risk management professionals that claim it is too hard or impossible to quantify the frequency or severity of loss. First, there is the irony that we operate in a problem space of uncertainty and then make absolute statements that something cannot be done. When I witness this type of uttering, I will often challenge the person on the spot – keeping in mind the audience – in an effort to pull that person off the edge of mental failure. And make no mistake, I struggle with quantification as well – but to what degree I share that with stakeholders or peers is an aspect of professional perception that I intentionally manage. Reflecting on my own experiences and interactions with others, I want to share some quick litmus tests I use when addressing the “it is too hard or impossible” challenges.

1. Problem Scoping. Have I scoped the problem or challenge too broadly? Sometimes we take these super-big, gnarly problem spaces and become fascinated with them without trying to deconstruct the problem into more manageable chunks. Often, once you begin reducing your scope, the variables that drive frequency or severity will emerge.

2. Subject Matter Experts. This is one litmus test that I have to attribute to Jack Jones and the FAIR methodology. Often, we are not the best person to be making subject matter estimates for the variables that factor into the overall risk. The closer you get to the true experts and extract their knowledge for your analysis, the more robust and meaningful your analysis will become. In addition, leveraging subject matter experts fosters collaboration and in some cases innovation where leaders of unrelated value chains realize there is opportunity to reduce risk across one or more chains.

3. Extremes and Calibration. Once again, I have Jack Jones to thank for this litmus test and Doug Hubbard as well. Recently, a co-worker declared something was impossible to measure (workforce, increased expense related). After his “too hard” declaration, I simply asked: “Will it cost us more than $1BN?” The question stunned my co-worker, which resulted in a “Of course not!” to which I replied “It looks like it is greater than zero and less than 1 billion, we are making progress!” Here is the point, we can tease extremes and leverage calibration techniques to narrow down our uncertainty and define variable ranges versus anchoring in on a single, discreet value.

4. Am I Trying Hard Enough. This is a no-brainer but unfortunately I feel too many of us do not try hard enough. A simple phone call, email or even well crafted Google query can quickly provide useful information that in turn reduces our uncertainty.

These are just a few “litmus tests” you can use to evaluate if an estimation or scenario is too hard to quantify. But here is the deal, as risk professionals it is expected that we deal with tough things so our decision makers don’t have too.

Wonder Twin Powers Activate…

March 7, 2013

…form of risk professional. I really miss blogging. The last year or so has been a complete gaggle from a relocation and time-management perspective. So naturally, discretionary activities – like blogging – take a back seat. I want to share a few quick thoughts around the topic of transitioning from a pure information technology / information security mindset to a risk management professional mindset.

1. Embrace the Gray Space. Information technology is all about bits, bytes, ones and zeros. Things either work or don’t work; it is either black or white, it is either good or bad – you get the point. In the discipline of risk management we are interested in everything between the two extremes. It is within this space where there is information to allow decision makers to make more well informed decisions.

2. Embrace Uncertainty. Intuitively, the concept of uncertainty is contrary to a lot of information technology concepts. Foundational risk concepts revolve around understanding and managing uncertainty and infusing it into our analysis / conversation with decision makers. There is no reason why this cannot be done within information risk management programs as well.  At first, it may feel awkward as an IT professional to admit to a leader that there is uncertainty inherent within some of the variables included in your analysis. However, what you will find – assuming you can clearly articulate your analysis – is that infusing the topic of uncertainty in your conversations and analysis has indirect benefits. Such an approach implies rigor, maturity and builds confidence with the decision maker.

3. Find New Friends. Notice I did not type find different friends. There is an old adage that goes something to the effect of “you are who you surround yourself with”. Let me change this up: “you are who you are learning from”. You want to learn risk management? Indulge yourself in non-IT risk management knowledge sources, learn centuries old principles of risk management and then begin applying what you have learned to the information technology / information security problem space. Here are just a few places to begin:

b. Risk Management Magazine
c. The Risk Management Society
d. Property & Casualty  – Enterprise Risk Management

4. Change Your Thinking. This is going to sound heretical but bear with me. Stop thinking like an IT professional and begin thinking like a business and a risk management professional. Identify and follow the money trails for the various risk management problem spaces you are dealing with. Think like a commercial insurer. An entire industry exists to reduce the uncertainty associated with technology-related, operational risk – when bad things happen. Thus, learn how commercial insurers think so you can manage risk more effectively without having to overspend on third party risk financing products – as well as manage risk in such a way that can tie back to the financials – feelings and emotions. This is why I am so on-board with the AICPCU’s Associate in Risk Management (ARM) professional designation. You can also check out the FAIR risk measurement methodology which is also very useful for associating loss forms to adverse events which can also help tell the story around financial consequences.

5. Don’t Die On That Hill. I have to thank my new boss for this advice. Choose your risk management battles wisely and in the heat of the conversation ask yourself if you need to die on this hill. Not all of our conversations with decision makers, leaders or even between ourselves – as dear colleagues – is easy. It is way too easy for passion to get in the way of progress and influencing. Often, if you find yourself “on the hill” asking if you need to die – something has gone terribly wrong. Instead of dying and ruining a long term relationship – take a few steps back, get more information that will help in the situation, regroup and attack again. This is an example of being a quiet professional.

That is all for now. Take care.

The AICPCU ‘Associate in Risk Management’ (ARM)

September 14, 2012

A year or so ago I stumbled upon the ARM designation that is administered through the AICPCU or ‘the Institutes’ for short. What attracted me then to the designation was that it appeared to be a comprehensive approach to performing a risk assessment for scenarios that result in some form of business liability. Unfortunately, I did not start pursuing the designation until July 2012. The base designation consists of passing three tests on the topics of ‘risk assessment’, ‘risk control’ and ‘risk financing’. In addition, there are a few other tests which allows one to extend their designation to include disciplines such as ‘risk management for public entities’ and ‘enterprise risk management’.

I am about two months into my ARM journey and just passed the ARM-54 ‘Risk Assessment’ test. I wanted to share some perspective on the curriculum itself and some differentiators when compared to some other ‘risk assessment’ and ‘risk analysis / risk measurement’ frameworks.

1. Proven Approach. Insurance and risk management practices have been around for centuries. Insurance carriers especially those who write commercial insurance products are very skilled at identifying and understanding the various loss exposures businesses face. Within the information risk management and operational risk management space, many of the loss exposures we care about and look for are the same that insurance carriers may look for when they assess a business for business risk and hazard risk; so they can create a business insurance policy. In other words, the ‘so what’ associated with the bad things we and insurance carriers care about is essentially a business liability that we want to manage. Our problem space / skills and risk treatment options may be slightly different but the goal of our efforts is the same: risk management.

2. Comprehensive. The ARM-54 course alone covers an enormous amount of information. The material easily encompasses the high level learning objectives of six college undergraduate courses I have taken in the last few years:

- Insurance and Risk Management
- Commercial Insurance
- Statistics
- Business Law
- Calculus (Business / Finance Problem Analysis / Calculations)
- Business Finance

The test for ARM-54 was no walk in the park. Even though I passed on the first attempt, I short-changed myself on some of the objectives which caused a little bit of panic on my part. The questions were well written and quite a few of them forced you to understand problem context so you could choose the best answer.

3. ‘Risk Management Value Chain’. Some of the following thoughts are the largest selling points of this designation compared to other IT risk assessment frameworks, IT risk analysis frameworks and IT risk certifications / designations. The ARM curriculum connects the dots between risk assessment activities, risk management decisions and the financial implications of those decisions at various levels of abstraction. This is where existing IT-centric risk assessment / analysis frameworks fall short – they are either to narrow in focus, do not incorporate business context, are not practical to execute or in some cases, not useful at all in helping someone or a business manage risk.

4. Cost Effective. For between $300-$500 per ARM course – one can get some amazing reference material and pay for the test. Compare that to the cost of six university courses (between $6K – $9K) or the cost of one formal risk measurement course (~$1k). I am convinced that any risk management professional can begin applying learned concepts from the ARM-54 text within hours after having been introduced to the text. So just the cost of the text books alone (~$100 give or take) is justified even if you do not take the test(s).

5. Learn How To Fish. Finally, I think it is worth noting that there is nothing proprietary to the objectives and concepts presented in the ARM-54 ‘Risk Assessment’ curriculum. Any statistical probability calculations or mathematical finance problems are exactly that – good ole math and probability calculations. In addition, there is nothing proprietary about the methods or definitions presented as they relate to risk assessments or risk management proper. This is an important selling point to me because there are many information risk management practitioners that are begging for curricula or training such as ARM where they can begin applying what they are learning and not be dependent on proprietary tools, proprietary calculations or pay for the license to use a proprietary framework.

In closing, the ARM-54 curriculum is a very comprehensive risk management curriculum that establishes business context, introduces proven risk assessment methods, and reinforces sound risk management principals. In my opinion, it is very practical for the information / operational risk management professional – especially those that are new to risk management or looking for a non-IT or non-security biased approach to risk management – regardless of the industry you work in.

So there you have it. I am really psyched about this designation and the benefits I am already realizing in my job as a Sr. Risk Advisor for a Fortune 200 financial services firm. I wish I would have pursued this designation two years ago but I am optimistic that I will make for lost time and tangible business value very quickly.

Assurance vs. Risk Management

August 29, 2012

One of my current hot button is the over-emphasis of assurance with regards to risk management. I recently was given visibility to a risk management framework where ‘management assurance’ was listed as the goal of the framework. However, the framework did not allow for management to actually manage risk.

Recently at BSidesLA I attempted to reduce the definitions of risk and ‘risk management’ down to fundamental attributes because there are so many different – and in a lot of cases contextually valid – definitions of risk.

Risk: Something that can happen that can result in loss. It is about the frequency of events that can have an adverse impact to our time, resources and of course our money.

Risk Management: Activities that allow us to reduce our uncertainty about risk(s) so we can make good trade off decisions.

So how does this tie into assurance? The shortcoming with an assurance-centric approach to risk management is that assurance IMPLIES 100% certainty that all risks are known and that all identified controls are comprehensive and effective. An assurance-centric approach also implies that a control gap, control failure or some other issue HAS to be mitigated so management can have FULL assurance regarding their risk management posture.

Where risk management comes into play is when management does not require with having 100% assurance because there may not be adequate benefit to their span of control or the organization proper. Thus, robust risk management frameworks need to have a management response process – i.e. risk treatment decisions – when issues or gaps are identified. A management response and risk treatment decision process has a few benefits:

1. It promotes transparency and accountability of management’s decisions regarding their risk management mindset (tolerance, appetite, etc.).

2. It empowers management to make the best business decision (think trade-off) given the information (containing elements of uncertainty) provided to them.

3. It potentially allows organizations to better understand the ‘total cost of risk’ (TCoR) relative to other operational costs associated with the business.

So here are the take-aways:

1. Assurance does always not equate to effective risk management.

2. Effective risk management can facilitate levels of assurance, confidence as well one’s understanding of uncertainty regarding loss exposures they are faced with.

3. Empowering and enabling management to make effective risk treatment decisions can provide management a level of assurance that they are running their business they way they deem fit.

Heat Map Love – R Style

January 20, 2012

Over the last several years not a month has gone by where I have not heard someone mention R – with regards to risk analysis or risk modeling – either in discussion or on a mailing list. If you do not know what R is, take a few minutes to read about it at the project’s main site. Simply put, R is a free software environment for statistical computing and graphics. Most of my quantitative modeling and analysis has been strictly Excel-based, which to date has been more then sufficient for my needs. However, Excel is not the ‘end-all-be-all’ tool. Excel does not contain every statistical distribution that risk practitioners may need to work with, there is no native Monte Carlo engine and it does have graphing limitations short of purchasing third party add-ons (advanced charts, granular configuration of graphs, etc…).

Thanks to some industry peer prodding (Jay Jacobs of Verizon’s Risk Intelligence team and Alex Hutton suggesting that ‘Numbers’ is a superior tool for visualizations). I finally bit the bullet, downloaded and then installed R.  For those completely new to R you have to realize that R is a platform to build amazing things upon. It is very command-line like in nature. You type in instructions and it executes. I like this approach because you are forced to learn the R language and syntax. Thus, in the end you will probably understand your data and resulting analysis much better.

One of the first graphics I wanted to explore with R was heat maps. At first, as I was thinking a standard risk management heat map; a 5×5 matrix with issues plotted on the matrix relative to frequency and magnitude. However, when I started searching Google for ‘R heat map’, a similar yet different style of heat map – referred to as a cluster heat map – was first returned in the search results. A cluster heat map is useful for comparing data elements in a matrix against each other depending on how your data is laid out. It is very visual in nature and allows the reader to quickly zero in on data elements or visual information of importance. From an information risk management perspective, if we have quantitative risk information and some metadata, we can begin a discussion with management by leveraging a heat map visualization. If additional information is needed as to why there are dark areas, then we can have the discussion about the underlying quantitative data. Thus, I decided to build a cluster heat map in R.

I referenced three blogs to guide my efforts – they can be found here, here and here. What I am writing here is in no way a complete copy and paste of their content because I provide some additional details on some steps that generated errors for me that in some cases took hours to figure out. This is not unexpected given the difference in data sets.

Let’s do it.

1.    Download and install R. After installation, start an R session. The version of R used for this post is 2.14.0. You can check your version by typing version at the command prompt and pressing ENTER.

2.    You will need to download and install the ggplot2 package / library. Do this through the R gui by referencing an online CRAN repository (packages -> install packages …). This method seems to be cleaner then downloading a package to your hard disk and then telling R to install it. In addition, if you reference an online repository, it will also grab any dependent packages at the same time. You can learn more about ggplot2 here.

3.    Once you have installed the ggplot2 package, we have to load it into our current R workspace.

> library(ggplot2)

4.    Next, we are going to import data to work with in R. Download ‘risktical_csv1.csv’ to your hard disk and execute the following command. Change the file path to match the file path for where you saved the file to.

risk <- read.csv(“C:/temph/risktical_csv1.csv”, sep=”,”, check.names= FALSE)

a.    We are telling R to import a Comma Separated Value file and assign it to a variable called ‘risk’.
b.    Read.csv is the method or function type of import.
c.    Notice that the slashes in the file name are opposite of what they normally would be when working with other common Windows-based applications.
d.    ‘sep=”,”’ tells R what character is used to separate values within the data set.
e.    ‘check.names=FALSE’ tells R not to check the column headers for correctness. R expects to see only letters, if it sees numbers, it will prepend an X to the column headers – we don’t want that based off the data set we are using.
f.    Once you hit enter, you can type ‘risk’ and hit enter again. The data from the file will be displayed on the screen.

5.    Now we need to ‘shape’ the data. The ggplot graphing function we want to use cannot consume the data as it currently is, so we are going to reformat the data first. The ‘melt’ function helps us accomplish this.

risk.m <- melt(risk)

a.    We are telling R to use the melt function against the ‘risk’ variable. Then we are going to take the output from melt and create a new variable called risk.m.
b.    Melt rearranges the data elements. Type ‘help(melt)’ for more information.
c.    After you hit enter, you can type ‘risk.m’ and hit enter again. Notice the way the data is displayed compared to the data prior to ‘melting’ (variable ‘risk’).

6.    Next, we have to rescale our numerical values so we can know how to shade any given section of our heat map. The higher the numerical value within a series of data, the darker the color or shade that tile of the heat map should be. The ‘ddply’ function helps us accomplish the rescaling; type ‘help(ddply)’ for more information.

risk.m <- ddply(risk.m, .(variable), transform, rescale = rescale(value), reorder=FALSE)

a.    We are telling R to execute the ‘ddply’ function against the risk.m variable.
b.    We are also passing some arguments to ‘ddply’ telling it to transform and reshape the numerical values. The result of this command produces a new column of values between 0 and 1.
c.    Finally, we pass an argument to ‘ddply’ not to reorder any rows.
d.    After you hit enter, you can type ‘risk.m’ and hit enter again and observe changes to the data elements; there should be two new columns of data.

7.    We are now ready to plot our heat map.

(p <- ggplot(risk.m, aes(variable, BU.Name)) + geom_tile(aes(fill = rescale), colour = “grey20″) + scale_fill_gradient(low = “white”, high = “red”))

a.    This command will produce a very crude looking heat map plot.
b.    The plot itself is assigned to a variable called p
c.    ‘scale_fill_gradient’ is the argument that associates color shading to the numerical values we rescaled in step 6. The higher the rescaling value – the darker the shading.
d.    The ‘aes’ function of ggplot is related to aesthetics. You can type in ‘help(aes)’ to learn about the various ‘aes’ arguments.

8.    Before we tidy up the plot, let’s set a variable that we will use in formatting axis values in step 9.

base_size <- 9

9.    Now we are going to tidy up the plot. There is a lot going on here.

p + theme_grey(base_size = base_size) + labs(x = “”, y = “”) + scale_x_discrete(expand = c(0, 0)) + scale_y_discrete(expand = c(0, 0)) + opts(legend.position = “none”, axis.ticks = theme_blank(), axis.text.x = theme_text(size = base_size * 0.8, angle = -90, hjust = 0, colour = “black”), axis.text.y = theme_text(size = base_size * 0.8, angle = 0, hjust = 0, colour = “black”))

a.    ‘labs(x = “”, y = “”)’ removes the axis labels.
b.    ‘opts(legend.position = “none”’ gets rid of the scaling legend.
c.    ‘axis.text.x = theme_text(size = base_size * 0.8, angle = -90’ sets the X axis text size as well as orientation.
d.    The heat map should look like the image below.

A few final notes:

1.    The color shading is performed within series of data, vertically. Thus, in the heat map we have generated, the color for any given tile is relative to the tile above and below it –IN THE SAME COLUMN – or in our case for a given ISO 2700X policy section.

2.    If we transposed our original data set – risktical_cvs2 – and applied the same commands with the exception of replacing BU.Name with Policy in our initial ggplot command (step 7), you should get a heat map that looks like the one below.

3.    In this heat map, we can quickly determine key areas of exposure for all 36 of our fictional business units relative to ISO 2700X. For example, most of BU3’s exposure is related to Compliance, followed by Organizational Security Policy and Access Control. If the executive in that business unit wanted more granular information in terms of dollar value exposure, we could share that information with them.

So there you have it! A quick R tutorial on developing a cluster heat map for information risk management purposes. I look forward to learning more about R and leveraging it to analyze and visualize data in unique and thought-provoking ways. As always, feel free to leave comments!

Metricon 6 Wrap-Up

August 10, 2011

Metricon 6 was held in San Francisco, CA on August 9th, 2011. A few months ago, I and a few others were asked by the conference chair – Mr. Alex Hutton (@alexhutton) – to assist in the planning and organization of the conference. One of the goals established early-on was that this Metricon needed to be different then previous Metricon events. Having attended Metricon 5, I witnessed firsthand the inquisitive and skeptical nature of the conference attendees towards speakers and towards each other. So, one of our goals for Metricon 6 was to change the culture of the conference. In my opinion, we succeeded in doing that by establishing topics that would draw new speakers and strike a happy balance between metrics, security and information risk management.

Following are a few Metricon 6 after-thoughts…

Venue: This was my first non-military trip to San Francisco. I loved the city! The vibe was awesome! The sheer number of people made for great people-watching entertainment and so many countries / cultures were represented everywhere I went. It gave a whole new meaning to America being a melting pot of the world.

Speakers: We had some great speakers at Metricon. Every speaker did well, the audience was engaged, and while questions were limited due to time – they took some tough questions and dealt with them appropriately.

Full list of speakers and presentations…

Favorite Sessions: Three of the 11 sessions stood out to me:

Jake Kouns – Cyber Insurance. I enjoyed this talk for a few reasons: a. it is an area of interest I have and b. the talk was easy to understand. I would characterize it as an overview of what cyber insurance is [should be] as well as some of the some of the nuances. Keeping in mind it was an overview – commercial insurance policies can be very complex – especially for large organizations. Some organizations do not buy separate “cyber insurance” policies – but utilize their existing policies to cover potential claims / liability arising from operational information technology failures or other scenarios. Overall – Jake is offering a unique product and while I would like to know more details – he appears to be well positioned in the cyber insurance product space.

Allison Miller / Itai Zukerman – Operationalizing Analytics. Alli and Itai went from 0 to 60 in about 5 seconds. They presented some work that brought together data collection, modeling and analysis- in less then 30 minutes. Itai was asked a question about the underlying analytical engine used – and he just nonchalantly replied ‘I wrote it in Java myself’ – like it was no big deal. That was hot.

Richard Lippman – Metrics for Continuous Network Monitoring. Richard gave us a glimpse of a real-time monitoring application; specifically, tracking un-trusted devices on protected subnets. The demo was very impressive and probably gave a few in the room some ‘metrigasms’ (I heard this phrase from @mrmeritology).

People: All the attendees and speakers were cordial and professional. By the end of the day – the sense of community was stronger then what we started with. A few quick shout-outs:

Behind-the-scenes contributors / organizers. The Usenix staff helped us out a lot over the last few months. We also had some help from Richard Baker who performed some site reconnaissance in an effort to determine video recording / video streaming capabilities – thank you sir. There were a few others that helped in selecting conference topics – you know who you are – thank you!

@chort0 and his lovely fiancé Meredith. They pointed some of us to some great establishments around Union Square. Good luck to the two of you as you go on this journey together.

@joshcorman. I had some great discussion with Josh. While we have only known each other for a few months – he has challenged me to think about questions [scenarios] that no one else is addressing.

+Wendy Nather. Consummate professional. Wendy and I have known of each other for a few years but never met in person prior to Metricon6. We had some great conversation; both professional and personal. She values human relationships and that is more important in my book then just the social networking aspect.

@alexhutton & @jayjacobs – yep – it rocked. Next… ?

All the attendees. Without attendance, there is no Metricon. The information sharing, hallway collaboration and presentation questions contributed greatly to the event. Thank you!


So there you go everyone! It was a great event! Keep your eyes and ears open for information about the next Metricon. Consider reanalyzing your favorite conferences and if you are looking for small, intimate and stimulating conferences – filled with thought leadership and progressive mindsets – give Metricon a chance!

Risk Vernacular Update

August 2, 2011

It has been a few years since I updated the “risk vernacular” portion of this blog. Based off some college-level  insurance and risk management courses as well as some work I am doing in the operational risk management space – there are some new terms I wanted to share as well as update some existing terms based off new information / knowledge. If it has been a while since you reviewed the page – take a few minutes to look at the page. Enjoy!

BTW, I will be in San Francisco on August 9th and 10th for Metricon 6.

What’s Your Target?

May 19, 2011

Been awhile since I publicly blogged. Between family, work, school, podcasting, helping run the Society of Information Risk Analysts (SIRA) and some public speaking – time has been limited. I want to briefly write about targets today.

I have had the privilege to speak twice in the month of May. The first engagement was at Secure360, an awesome regional information security conference based out of St. Paul, Minnesota. Mr. Jack Jones and I partnered up to give a talk about having a ‘seat at the table’. Specifically, speaking in a language that our IT and business leaders understand, establishing perspective, gaining influence, and providing value to our leaders so they can effectively manage risk. The talk appeared to be well received and there have been a few follow-up conversations with some information security professionals that want to up their game – which was the point to begin with.

Earlier this week I had the privilege to speak about IT risk management – specifically IT risk quantification – as part of the ‘CIO Practicum’ series at the University of Kentucky. The theme of this particular event was “Security for Grown-Ups”. I found myself in a room of IT and business executives who came to get a glimpse of how information risk management functions can begin adding value to the business or organization. My take-away from the event was that IT and business executives are craving value-add from information risk management functions (security, continuity management, compliance, etc.). Let me repeat in bold capital letters: IT AND BUSINESS EXECUTIVES ARE CRAVING VALUE FROM INFORMATION RISK MANAGEMENT FUNCTIONS.

So here is the dilemma. Information risk management professionals want to add value and our IT and business executives want [expect] value. How can we achieve goodness?

In order to achieve goodness, you and your leadership have to define it for your organization – you have to have a vision or a target to direct your efforts toward. It requires relationship building with your leadership and executives to develop a sense of mutual trust, perspective and shared understanding about why the organization exists, how the information risk management function fits into the organization as well as how the information risk management function contributes to helping the organization reach its goals and fulfill its strategy.

If you are an information risk practitioner, security, continuity management or compliance professional – what is the target that the outcomes of your efforts are directed towards? If you don’t know – figure it out quickly. Better yet – if your manager or other leaders cannot tell you then be proactive and work with your leadership to help define it.

If you are an IT or business executive that happened to stumble on this blog post – let me ask you a question. Have you established a vision or target for your information risk management function(s) to direct their efforts toward? If so – how is it working out? Is value being added? If a vision or target has not been established, why not?


Deconstructing Some HITECH Hype

February 23, 2011

A few days ago I began analyzing some model output and noticed that the amount of loss exposure for ISO 27002 section “Communications and Operations Management” had increased by 600% in a five week time frame. It only took a few seconds to zero-in on an issue that was responsible for the increase.

The issue was related to a gap with a 3rd party of which there was some Health Information Technology for Economic and Clinical Health Act (HITECH) fine exposure. The estimated HITECH fines were really LARGE. Large in the sense that the estimates:

a.    Did not pass the sniff test
b.    Could not be justified based off any documented fines / or statutes.
c.    From a simulation perspective were completely skewing the average simulated expected loss value for the scenario itself.

I reached out to better understand the rationale of the practitioner who performed the analysis and after some discussion we were in agreement that some additional analysis was warranted to accurately represent assumptions as well as refine loss magnitude estimates – especially for potential HITECH fines. About 10 minutes of additional information gathering yielded valuable information.

In a nutshell, the HITECH penalty structure is a tiered system that takes into consideration the nature of the data breach, the fine per violation and maximum amounts of fines for a given year. See below (the tier summary is from link # 2 at the bottom of this post; supported by links # 1 and 3):

Tier A is for violations in which the offender didn’t realize he or she violated the Act and would have handled the matter differently if he or she had. This results in a $100 fine for each violation, and the total imposed for such violations cannot exceed $25,000 for the calendar year.

Tier B is for violations due to reasonable cause, but not “willful neglect.” The result is a $1,000 fine for each violation, and the fines cannot exceed $100,000 for the calendar year.

Tier C is for violations due to willful neglect that the organization ultimately corrected. The result is a $10,000 fine for each violation, and the fines cannot exceed $250,000 for the calendar year.

Tier D is for violations of willful neglect that the organization did not correct. The result is a $50,000 fine for each violation, and the fines cannot exceed $1,500,000 for the calendar year.

Given this information and the nature of the control gap – one can quickly determine the penalty tier as well as estimate fine amounts. The opportunity cost to gather this additional information was minimal and the benefits of the additional analysis will result  in not only more accurate and defendable analysis – but also spare the risk practitioner from what would have been certain scrutiny from other IT risk leaders and possibly business partner allegations of IT Risk Management once again “crying wolf”.

Key Take-Away(s)

1.    Perform sniff tests on your analysis; have others review your analysis.
2.    There is probably more information then you realize about the problem space you are dealing with.
3.    Be able to defend assumptions and estimates that you make.
4.    Become the “expert” about the problem space not the repeater of information that may not be valid to begin with.

Links / References associated with this post:

1.    HIPAA Enforcement Rule ref. HITECH <- lots of legalese
2.    HITECH Summary <- less legalese
3.    HITECH Act scroll down to section 13410 for fine information <-lots of legalese
4.    Actual instance of a HITECH-related fine
5.    Interesting Record Loss Threshold Observation; Is 500 records the magic number?

Simple Risk Model (Part 4 of 5): Simulating both Loss Frequency & Loss Magnitude

February 5, 2011

Part 1 – Simulate Loss Frequency Method 1
Part 2 – Simulate Loss Frequency Method 2
Part 3 – Simulate Loss Frequency Method 3

In this post we want to combine the techniques demonstrated in parts two and three into a single simulation. To accomplish this simulation we will:

1.    Define input parameters
2.    Introduce VBA code – via a macro – that consumes the input parameters
3.    Perform functions within the VBA code
4.    Take the output from functions and store them in the spreadsheet
5.    Create a histogram of the simulation output.

Steps 3 & 4 will be performed many times; depending on the number of iterations we want to perform in our simulation.

You can download this spreadsheet to use as a reference throughout the post. The spreadsheet should be used in Excel only. The worksheets we are concerned with are:

test – This worksheet contains code that will step through each part of the loss magnitude potion of the simulation. By displaying this information, it allows you to validate that both the code and calculations are functioning as coded. This tab is also useful for testing code in small iterations. Thus, the number of iterations should be kept fairly low (“test”; B1).

prod – Unlike the “test” tab, this tab does not display the result of each loss magnitude calculation per iteration. This is the tab that you would want to run the full simulation on; thousands of iterations.

Here we go…and referencing the “prod” worksheet…

Input Parameters.
Expected Loss Frequency. It is assumed for this post that you have estimated or derived a most likely or average loss frequency value. Cell B2 contains this value. The value in this cell will be one of the input parameters into a POISSON probability distribution to return an inverse cumulative value (Part 2 of this Series).

Average Loss Magnitude. It is assumed for this post that you have estimated or derived a most likely or average loss magnitude value. Cell B3 contains this value. The value in this cell will be one of the input parameters into a NORMAL probability distribution to return an inverse cumulative value (Part 3 of this Series).

Loss Magnitude Standard Deviation. It is assumed for this post that you have estimated or derived the standard deviation for loss magnitude. Cell B4 contains this value. The value in this cell will be one of the input parameters into a NORMAL probability distribution to return an inverse cumulative value (Part 3 of this Series).

The Simulation.
On the “prod” tab, when you click the button labeled “Prod” – this will execute a macro composed of VBA code. I will let you explore the code on your own – it is fairly intuitive. I also left a few comments in the VBA so I remember what certain sections of the code are doing. There are four columns of simulation output that the macro will generate.

Iter# (B10). This is the iteration number. In cell B1 we set the number of iterations to be 5000. Thus, the VBA will cycle through a section of its code 5000 times.

LEF Random (C10). For each iteration, we will generate a random value between 0 and 1 to be used in generating a loss frequency value. Displaying the random value in the simulation is not necessary, but I prefer to see it so I can informally analyze the random values themselves and gauge the relationship between the random value and the inverse cumulative value in the next cell.

LEF Value (D10). For each iteration, we will use the random value we generated in the adjacent cell (column c), combine it with the Expected Loss Frequency value declared in B2 and input these values as parameters into a POISSON probability distribution that returns an inverse cumulative value. The value returned will be an integer – a whole number. Why a whole number? Because you can’t have half a loss event – just like a woman cannot be half pregnant ( <- one of my favorite analogies). This is a fairly important concept to realize from a loss event modeling perspective.

Loss Magnitude (E10). For each iteration, we will consume the value in the adjacent cell (column D) and apply logical rules to it.

a.    If the LEF Value = 0, then the loss magnitude is zero.
b.    If the LEF Value > 0, then for each instance of loss we will:
1.    Generate a random value
2.    Consume the average loss magnitude value in cell B3
3.    Consume the loss magnitude standard deviation in cell B4
4.    Use the values referenced in 1-3 as input parameters into a Normal probability distribution and return an inverse cumulative value. In other words, given a normal distribution with mean $2000 and standard deviation of $1000 – what is the value of that distribution point given a random value between 0 and 1.
5.    We will add all the instances of loss for that iteration and record the sum in column E.

Note: Steps 4 and 5 can be observed on the “test” worksheet by clicking the button labeled “test”.

The code will continue to loop until we have completed the number of iterations we specified in cell B1.

The Results. Now that the simulation is complete we can begin to analyze the output.

# of Iterations With No Loss (B5). This is the number of iterations where the returned inverse cumulative value was zero.

# of Iterations With Loss (B6). This is the number of iterations where the returned inverse cumulative value was greater than zero.

# of Loss Events (B7). This is the sum of loss events for all the iterations. There was some iteration where there was more then one loss event.

Max. # of Loss Events for an iteration (B8). This is the maximum number of loss events for any given iteration.

Next, let’s look at some of the simulation output in the context of loss severity; $.

Min. Loss (K6). This is minimum loss value returned from the simulation. I round the results to the nearest hundred in the worksheet.

Max. Loss (K7). This is maximum loss value returned from the simulation. I round the results to the nearest hundred in the worksheet.

Median (G5). This is the 50th percentile of the simulation results. In other words, 50% of the simulations results were equal to or less then this value.

Average (G6). This is the average loss value for the simulation. This is the quotient of summing all the loss magnitude values and dividing by the number of iterations. This value can quickly be compared to the median to make inferences about the skew of the simulation output.

80th % (G7). This is the 80th percentile of the simulation results. In other words, 80% of the simulations results were equal to or less then this value. In some industries, this is often referred to as the 1-in-5 loss.

90th % (G8). This is the 90th percentile of the simulation results. In other words, 90% of the simulations results were equal to or less then this value. In some industries, this is often referred to as the 1-in-10 loss.

95th % (G9). This is the 95th percentile of the simulation results. In other words, 95% of the simulations results were equal to or less then this value. In some industries, this is often referred to as the 1-in-20 loss.

99th % (G10). This is the 99th percentile of the simulation results. In other words, 99% of the simulations results were equal to or less then this value. In some industries, this is often referred to as the 1-in-100 loss.

Note 2: Generally speaking, the 95th, 99th and greater percentiles are often considered as being part of the tail of the loss distribution. I consider all the points in cells G5:G10 to be useful. For some loss exposures, the median and average values are more than enough to make informed decisions. For some loss exposures; the 80th, 90th, 95th, 99th and even larger percentiles are necessary.

Simulated Loss Magnitude Histogram. A histogram is a graphical representation showing the distribution of data. The histogram in the “prod” worksheet represents the distribution of data for all iterations where the loss was greater than zero.

Wrap Up. What I have presented in this post is a very simple model for a single loss exposure using randomness and probability distributions. Depending on your comfort level with VBA and creativity, one can easily build out more complex models; whether it is hundreds of loss exposures you want to model for or just a few dependent loss exposures.


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