Tag Archives: process

SOC2 Type 2 Compliance Through the Cynefin Lens

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Achieving and maintaining SOC2 Type 2 compliance is crucial for organizations handling sensitive data. This post explores the intersection of SOC2 Type 2 controls and the Cynefin framework, offering a unique perspective on navigating the complexities of compliance.

The Cynefin framework, developed by Dave Snowden, is a sense-making model that helps leaders determine the prevailing operative context so that they can make appropriate choices. It defines five domains: Clear (formerly known as Obvious), Complicated, Complex, Chaotic, and Disorder. By mapping SOC2 Type 2 controls to these domains, we can better understand the nature of each control and the best approaches for implementation.

SOC2 (Service Organization Control 2) is a framework developed by the American Institute of Certified Public Accountants (AICPA) to ensure that service organizations securely manage data to protect the interests and privacy of their clients. SOC2 Type 2 reports on the effectiveness of these controls over a period of time, typically 6-12 months.

Control Mapping

Clear (Obvious) Domain

Controls in this domain have clear cause-and-effect relationships and established best practices.

Examples:
– Access control policies (Security)
– Regular system backups (Availability)
– Data encryption at rest and in transit (Confidentiality)

These controls are straightforward to implement and maintain. Best practices are well-documented, and solutions are often standardized across industries.

Risks and Challenges:
– Complacency due to perceived simplicity
– Overlooking context-specific nuances

Best Practices:
– Regular review and updates of policies
– Employee training on basic security practices
– Automation of routine tasks

Complicated Domain

Controls in this domain require expert knowledge but have predictable outcomes when implemented correctly.

Examples:
– Intrusion detection systems (Security)
– Load balancing and failover mechanisms (Availability)
– Data classification and handling procedures (Confidentiality)
– Privacy impact assessments (Privacy)

These controls often require specialized expertise to design and implement but follow logical, analyzable patterns.

Risks and Challenges:
– Overreliance on external experts
– Difficulty in maintaining in-house expertise

Best Practices:
– Engage with specialized consultants
– Develop internal expertise through training and knowledge transfer
– Document complex processes thoroughly

Complex Domain

Controls in this domain involve many interacting elements, making cause-and-effect relationships difficult to determine in advance.

Examples:
– Incident response planning (Security)
– Continuous monitoring and adaptive security measures (Security)
– Dynamic resource allocation (Availability)
– AI-driven anomaly detection (Processing Integrity)

These controls require constant monitoring, learning, and adaptation. Outcomes are often unpredictable and emerge over time.

Risks and Challenges:
– Difficulty in predicting outcomes
– Potential for unexpected consequences
– Resistance to change within the organization

Best Practices:
– Implement robust feedback mechanisms
– Encourage experimentation and learning
– Foster a culture of adaptability and continuous improvement

Chaotic Domain

Controls in this domain deal with rapidly evolving threats or crisis situations where immediate action is necessary.

Examples:
– Zero-day vulnerability responses (Security)
– Data breach containment procedures (Confidentiality)
– Rapid scalability during unexpected traffic spikes (Availability)

These controls often involve crisis management and require quick decision-making with limited information.

Risks and Challenges:
– Pressure to act without sufficient information
– Potential for panic-driven decisions
– Difficulty in planning for all possible scenarios

Best Practices:
– Develop and regularly test crisis management plans
– Foster decision-making skills under pressure
– Establish clear chains of command for emergency situations

Challenges in SOC2 Compliance

Achieving and maintaining SOC2 Type 2 compliance presents several challenges:

1. Complexity of Controls: As seen in the Cynefin mapping, SOC2 controls span from clear to chaotic domains. Organizations must be prepared to handle this spectrum of complexity.

2. Continuous Monitoring: SOC2 Type 2 requires ongoing compliance, necessitating robust monitoring and reporting systems.

3. Evolving Threat Landscape: The rapid pace of technological change and emerging threats means that controls, especially in the complex and chaotic domains, must be continually reassessed and updated.

4. Resource Intensity: Implementing and maintaining SOC2 compliance requires significant time, expertise, and financial resources.

5. Organizational Culture: Embedding compliance into the organizational culture can be challenging, particularly for controls in the complex domain that require adaptability and continuous learning.

6. Vendor Management: Many organizations rely on third-party vendors, adding another layer of complexity to compliance efforts.

MicroSolved’s Expertise

MicroSolved, Inc. brings a wealth of experience and expertise to help organizations navigate the complexities of SOC2 Type 2 compliance:

1. Comprehensive Assessment: We conduct thorough evaluations of your current controls, mapping them to the Cynefin framework to identify areas of strength and improvement.

2. Tailored Solutions: Recognizing that each organization is unique, we develop customized compliance strategies that align with your specific business context and risk profile.

3. Expert Guidance: Our team of seasoned professionals provides expert advice on implementing and maintaining controls across all Cynefin domains.

4. Continuous Monitoring Solutions: We offer advanced tools and methodologies for ongoing compliance monitoring, particularly crucial for controls in the complex and chaotic domains.

5. Training and Culture Development: We help foster a culture of compliance within your organization, ensuring that all employees understand their role in maintaining SOC2 standards.

6. Crisis Preparedness: Our expertise in handling chaotic domain controls helps prepare your organization for rapid response to emerging threats and crises.

7. Vendor Management Support: We assist in evaluating and managing third-party vendors to ensure they meet your compliance requirements.

Need Help or More Information?

Navigating the complexities of SOC2 Type 2 compliance doesn’t have to be a daunting task. MicroSolved, Inc. is here to guide you through every step of the process. We invite you to:

1. Schedule a Consultation: Let our experts assess your current compliance posture and identify areas for improvement.

2. Attend Our Workshops: Schedule an educational session on SOC2 compliance and the Cynefin framework to better understand how they apply to your organization.

3. Explore Our Services: From initial assessment to ongoing advisory oversight, we offer a full suite of services tailored to your needs.

4. Request a Demo: See firsthand how our tools and methodologies can simplify your compliance journey.

Don’t let the complexities of SOC2 compliance hinder your business growth. Partner with MicroSolved, Inc. to transform compliance from a challenge into a competitive advantage. Contact us today to begin your journey towards robust, efficient, and effective SOC2 Type 2 compliance. Give us a call at 614.351.1237 or drop us an email at info@microsolved.com for a no hassle discussion. 

 

 

 

* AI tools were used as a research assistant for this content.

Use Cases for AI in Vendor Risk Management

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Today, managing vendor relationships has never been more critical. With increasing reliance on third-party vendors, organizations face heightened risks that can affect their operations and reputation. Vendor risk management (VRM) ensures that companies can identify, assess, and mitigate risks associated with their vendor partnerships, particularly as new challenges emerge. Traditional VRM methods often struggle to keep pace with the complexities of modern supply chains, which is where the application of artificial intelligence (AI) comes into play.

This article explores the various use cases for AI in vendor risk management, highlighting how it enhances risk assessment processes, addresses the limitations of conventional models, and discusses best practices for effectively implementing AI solutions.

VendorRiskAI

The Importance of Vendor Risk Management

In the intricate web of modern business, vendor risk management plays a pivotal role in safeguarding supply chain resilience and maintaining uninterrupted operations. With third-party relationships climbing in complexity and volume, the potential risks burgeon. Third-party risk management has therefore escalated to a critical business discipline.

AI-driven solutions transform how organizations evaluate and mitigate third-party risks. Real-time updates to vendor data, courtesy of Artificial Intelligence, diminish the dependence on stale reports, ensuring procurement teams wield current insights for informed decisions. Dynamic assessments of vendor performance and compliance, propelled by AI, augment abilities to pinpoint risks instantaneously.

How AI Enhances Vendor Risk Management

Artificial Intelligence is revolutionizing Third-Party Risk Management by introducing efficiency, accuracy, and agility into the process. By automating the collection and analysis of risk data from various sources, AI not only enhances efficiency but also significantly improves the accuracy of the risk assessments.

Real-World Example: Financial Services Industry

A leading global bank implemented an AI-driven vendor risk management system to monitor its vast network of over 10,000 third-party vendors. The AI system continuously analyzes financial data, news feeds, and regulatory updates to provide real-time risk scores for each vendor. This implementation resulted in:

  • A 40% reduction in time spent on vendor assessments
  • Early detection of potential risks in 15% of vendors, allowing for proactive mitigation
  • An estimated cost saving of $2 million annually due to improved efficiency and risk prevention

Automating Vendor Classification

AI has a profound impact on the way organizations classify their vendors. Replacing once time-intensive manual tasks, AI systems process unstructured evidence and analyze vendor certification data at remarkable speeds. It can sift through thousands of vendor profiles, pinpoint the most relevant risks, and classify vendors according to their firmographics.

Predictive Analytics for Proactive Risk Management

At the cornerstone of proactive risk management lies predictive analytics powered by AI. These models constantly monitor an array of factors, including market conditions, suppliers’ financial health, and geopolitical events, to foresee potential supply chain disruptions or vendor stability issues before they arise.

Challenges with Traditional Vendor Risk Management Models

Traditional models of vendor risk management often encounter significant hurdles, particularly in the dynamic landscape of today’s cyber-threat environment. Here’s a comparison of traditional methods versus AI-driven approaches:

Aspect Traditional Method AI-Driven Approach
Data Currency Often relies on outdated information Real-time data analysis and updates
Assessment Speed Time-consuming manual processes Rapid automated assessments
Risk Detection Limited to known, historical risks Predictive analytics for emerging risks
Scalability Struggles with large vendor networks Easily scales to manage thousands of vendors
Consistency Prone to human error and bias Consistent, data-driven assessments

Best Practices for Implementing AI in Vendor Risk Management

In the sphere of vendor risk management, integrating artificial intelligence (AI) can catalyze a transformation in managing and mitigating risks associated with third-party vendors. Best practices when implementing AI into such critical operations involve a holistic approach that spans dynamic risk assessments, automation of risk analysis, and enhancement of operational resilience.

Integrating AI with Existing Processes

A seamless integration of AI with existing supplier management systems ensures not only a cohesive workflow but also eases the adoption process for security teams. Organizations benefit from starting with a pilot program to gauge the impact of AI systems with real-world data before moving to a comprehensive deployment.

Training Staff on AI Tools

A successful AI integration in vendor risk management is contingent not just on technology itself, but also on the proficiency of the human intelligence behind it. Consequently, equipping the procurement team with essential skills and knowledge pertaining to AI technologies becomes paramount.

Establishing Clear Governance Frameworks

AI-powered tools have the potential to significantly bolster governance structures by enhancing transparency and offering traceable, auditable insights into business transactions and decision-making processes. By leveraging AI, organizations can actively maintain compliance with regulations, effectively mitigating risk exposure and promoting a culture of accountability.

Ethical Considerations in AI-Driven Vendor Risk Management

While AI offers significant benefits in vendor risk management, it’s crucial to consider the ethical implications of its use:

  • Data Privacy: Ensure that AI systems comply with data protection regulations and respect vendor privacy.
  • Algorithmic Bias: Regularly audit AI algorithms to detect and mitigate potential biases that could unfairly assess certain vendors.
  • Transparency: Maintain clear communication with vendors about how AI is used in risk assessments and decision-making processes.
  • Human Oversight: While AI can automate many processes, maintain human oversight to ensure ethical decision-making and accountability.

Future Trends in AI-Driven Vendor Risk Management

Artificial intelligence has rapidly evolved from a novel innovation to a cornerstone of vendor risk management, and its trajectory points to even more sophisticated and strategic uses in the future.

Emerging Technologies in AI

Several breakthrough AI technologies are coming to the fore within vendor risk management paradigms:

  • Machine Learning (ML): ML algorithms have become a staple for enhancing predictive analytics, allowing for more rapid and accurate risk assessments based on an ever-growing data pool from vendors.
  • Natural Language Processing (NLP): NLP technologies are vital for analyzing the plethora of unstructured data that vendors generate, converting nuanced textual information into actionable insights.
  • Robotic Process Automation (RPA): RPA is applied to automate repetitive and time-consuming tasks such as data collection and risk report generation.
  • Quantum Computing: The potential marriage of AI with quantum computing suggests a future where risk predictions and insights attain unprecedented accuracy.
  • Blockchain: Integration of blockchain technology with AI could enhance transparency and security in vendor transactions and data sharing.

Evolving Regulatory Standards

The burgeoning use of AI in vendor risk management introduces intricate regulatory and compliance challenges. As organizations strive to comply with these myriad regulations, a shift is necessary from a static assessment model to continuous, internal governance that actively keeps pace with regulatory evolution.

Conclusion

AI-driven vendor risk management represents a significant leap forward in how organizations approach third-party risks. By leveraging advanced technologies like machine learning, natural language processing, and predictive analytics, businesses can achieve more accurate, efficient, and proactive risk management strategies. As AI continues to evolve, it will undoubtedly play an increasingly crucial role in safeguarding supply chains, ensuring compliance, and driving strategic decision-making in vendor relationships.

However, the successful implementation of AI in vendor risk management requires careful planning, continuous learning, and a commitment to ethical practices. Organizations must balance the power of AI with human oversight and judgment to create a robust, effective, and responsible vendor risk management framework.

Take Your Vendor Risk Management to the Next Level with MicroSolved, Inc.

Ready to harness the power of AI for your vendor risk management? MicroSolved, Inc. is at the forefront of AI-driven security solutions, offering cutting-edge tools and expertise to help organizations like yours transform their approach to vendor risk.

Our team of experts can help you:

  • Assess your current vendor risk management processes
  • Design and implement tailored AI solutions
  • Train your staff on best practices in AI-driven risk management
  • Ensure compliance with evolving regulatory standards

Don’t let vendor risks compromise your business. Contact MicroSolved, Inc. (info@microsolved.com) today for a free consultation and discover how AI can revolutionize your vendor risk management strategy.

 

 

* AI tools were used as a research assistant for this content.

 

Ransomware-Proof Your Credit Union: A Checklist of NCUA Guidance

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In today’s digital landscape, credit unions face numerous cybersecurity threats, including the rising risk of ransomware attacks and vulnerabilities in their information and communications technology supply chain. To help credit unions protect themselves against these risks, the National Credit Union Administration (NCUA) has compiled an FAQ. This checklist covers the essential steps to safeguard against ransomware attacks, additional resources for cybersecurity, understanding supply chain risk management, developing effective practices, mitigating risks associated with using a Managed Service Provider (MSP), and other insights based on their FAQ. By following this checklist, credit unions can enhance their overall security posture and minimize the potential impact of cyber threats.

1. Protect against ransomware attacks:
– Update software and operating systems regularly with the latest patches.
– Avoid clicking on links or opening attachments in unsolicited emails.
– Follow safe browsing practices.
– Replace equipment running older unsupported operating systems.
– Verify the security practices of vendors and third-party service providers.
– Maintain complete and tested backups of critical systems and data.

2. Additional resources for cybersecurity:
– Use the Ransomware Self-Assessment Tool (R-SAT) from the Conference of State Bank Supervisors.
– Read the Center for Internet Security white paper on ransomware.
– Visit the cybersecurity pages of the National Security Agency Central Security Service and the Cybersecurity & Infrastructure Security Agency. (CISA)
– Refer to the Treasury Department’s advisory on potential sanctions risks for facilitating ransomware payments.

3. Understand Technology Supply Chain Risk Management (SCRM):
– Recognize that technology supply chain vulnerabilities can pose risks to the entire institution.
– Consider the risks associated with third-party vendors and the entire technology supply chain.
– Identify vulnerabilities in all phases of the product life cycle.

4. Develop an effective Technology Supply Chain Risk Management Practice:
– Build a team with representatives from various roles and functions.
– Document policies and procedures based on industry standards and best practices.
– Create a list of technology components and understand their criticality and remote access capability.
– Identify suppliers and verify their security practices.
– Assess and evaluate the SCRM program regularly.

5. Risks associated with using a Managed Service Provider (MSP):
– APT actors actively attempt to infiltrate IT service provider networks.
– Conduct proper due diligence and ongoing monitoring of MSPs.
– Understand the risks of centralizing information with an MSP.
– Recognize that compromises in an MSP’s network can have cascading effects.

6. Mitigate the risk of using an MSP:
– Manage supply chain risk by working with the MSP to address security concerns.
– Implement architecture measures to restrict access and protect networks.
– Use dedicated VPNs for MSP connections and restrict VPN traffic.
– Ensure proper authentication, authorization, and accounting practices.
– Implement operational controls, such as continuous monitoring and software updates.

7. Additional references for Information and Communications Technology Supply Chain Risk Management:
– Refer to guidance from the NCUA, NIST, and CISA.
– Evaluate third-party relationships and outsourcing technology services.
– Learn about supply chain threats and cyber supply chain risk management.

Note: This checklist is a summary of the information provided. For more detailed guidance, refer to the full content on the NCUA website.

 

* We used some AI tools to gather the information for this article.

First Step After Breach

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Discovering an information security breach can be a shock! Picture it: you are enjoying a regular work day and WHAM! Suddenly you are at the center of an incident that could possibly affect the future of the company and perhaps your own future as well. It’s easy to panic. You know if you don’t do the right thing, right now, bad things are sure to rain down on you. So, what is the very first thing that you should do?

Go immediately to your incident response plan, of course! After all, that is the reason your company has put together an IR plan and team in the first place; to plan for contingencies so that personnel don’t go off half-cocked and lose vital data and evidence. 

But is your plan clear enough that regular system users or even help desk personnel know what to do first without having to thumb through a hundred pages of plan? If not, perhaps a simple little trick we use in our incident response plans will work for you. 

The very first thing you see when you open one of our incident response plans are employee and incident response team Quick Response Guides (see the example of an employee guide below-the IRT guide is similar, but more complex). 

I know from my military experience that having checklists such as the Quick Response Guides in place truly cuts down on mistakes and helps calm personnel during difficult situations. Why not see if they can also improve your response quality?

 

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You can download the pocket guide here. 

Thanks to John Davis for this post.

State Of Security Podcast Episode 4

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We are proud to announce the release of State Of Security, the podcast, Episode 4. This time around I am hosting John Davis, who riffs on policy development for modern users, crowdsourcing policy and process management, rational risk assessment and a bit of history.

Give it a listen and let us know what you think!

Thanks for supporting the podcast!

Tips for Writing Good Security Policies

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Almost all organizations dread writing security policies. When I ask people why this process is so intimidating, the answer I get most often is that the task just seems overwhelming and they don’t know where to start. But this chore does not have to be as onerous or difficult as most people think. The key is pre-planning and taking one step at a time.

First you should outline all the policies you are going to need for your particular organization. Now this step itself is what I think intimidates people most. How are they supposed to ensure that they have all the policies they should have without going overboard and burdening the organization with too many and too restrictive policies? There are a few steps you can take to answer these questions:

  • Examine existing information security policies used by other, similar organizations and open source information security policy templates such as those available at SANS. You can find these easily online. However, you should resist simply copying such policies and adopting them as your own. Just use them for ideas. Every organization is unique and security policies should always reflect the culture of the organization and be pertinent, usable and enforceable across the board.
  • In reality, you should have information security policies for all of the business processes, facilities and equipment used by the organization. A good way to find out what these are is to look at the organizations business impact analysis (BIA). This most valuable of risk management studies will include all essential business processes and equipment needed to maintain business continuity. If the organization does not have a current BIA, you may have to interview personnel from all of the different business departments to get this information. 
  • If the organization is subject to information security or privacy regulation, such as financial institutions or health care concerns, you can easily download all of the information security policies mandated by these regulations and ensure that you include them in the organization’s security policy. 
  • You should also familiarize yourself with the available information security guidance such as ISO 27002, NIST 800-35, the Critical Security Controls for Effective Cyber Defense, etc. This guidance will give you a pool of available security controls that you can apply to fit your particular security needs and organizational culture.

Once you have the outline of your security needs in front of you it is time to start writing. You should begin with broad brush stroke, high level policies first and then add detail as you go along. Remember information security “policy” really includes policies, standards, guidelines and procedures. I’ve found it a very good idea to write “policy” in just that order.

Remember to constantly refer back to your outline and to consult with the business departments and users as you go along. It will take some adjustments and rewrites to make your policy complete and useable. Once you reach that stage, however, it is just a matter of keeping your policy current. Review and amend your security policy regularly to ensure it remains useable and enforceable. That way you won’t have to go through the whole process again!

Thanks to John Davis for this post.

Touchdown Task for August – Change Management Audit

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This month, we urge all infosec teams to engage in a quick 30 minute audit of your change management processes.

Here are some quick win questions to ask of the change management team:

  • How often does the change management team meet & what is the time frame for turning around a change order?
  • What percentage of actual changes to the environment went through the change process in the last 12 months?
  • Where can we locate the documents that specifically describe the change management process and when were they last revised?
  • Please describe how exceptions to the change management process are handled.
  • How are changes to the environment audited against what was provided to the change management team?
  • What happens if a change is identified that did NOT go through the change management process?

There are plenty of online guidance sources for additional questions and audit processes, but these quick wins will get you started. As always, thanks for reading and keep working on your monthly touchdown tasks. Be sure to touch base with us on Twitter (@microsolved) should you have any questions about the work plans.

The Big Three

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Information security techniques certainly are improving. The SANS Top Twenty Critical Controls, for example, are constantly improving and are being adopted by more and more organizations. Also, security hardware devices and software applications are getting better at a steady rate. But the question we have to ask ourselves is: are these improvements outpacing or even keeping up with the competition? I think a strong argument can be made that the answer to that question is NO! Last year there were plenty of high profile data loss incidents such as the Target debacle. Over 800 million records were compromised that we know of, and who knows how many other unreported security breaches of various types occurred?

So how are we going to get on top of this situation? I think the starkly realistic answer to that question is that we aren’t going to get on top it. The problem is the age old dilemma of defense versus attack; attackers will always have the advantage over entrenched defenders. The attackers know where you are, what you have and how you defend it. All they have to do is figure out one way to get over, under or around your defenses and they are successful. We, on the other hand, don’t know who the attackers are, where they’re at or exactly how they will come at us. We have to figure out a way to stop them each and every time – a daunting task to say the least! Sure, we as defenders can turn the tables on the information thieves and go on the attack; that is one way we can actually win the fight. But I don’t think the current ethical and legal environment will allow that strategy to be broadly implemented.

Despite this gloomy prognosis, I don’t think we should just sit on our hands and keep going along as we have been. I think we should start looking at the situation more realistically and shift the focus of our efforts into strategies that have a real chance of improving the situation. And to me those security capabilities that are most likely to bear fruit are incident detection, incident response and user education and awareness; the Big Three. Over the next several months I intend to expand upon these ideas in a series of blog posts that will delve tactics and means, so stay tuned if this piques your interest! 

Thanks to John Davis for writing this entry.

September TouchDown Task: Policy Quick Review

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This month’s touchdown task is to review your information security related policies and procedures. Whether you, your team, or human resources are responsible for updating and maintaining information security policies, we suggest you review these documents every quarter, or at least every six months to ensure your policies keep pace with legislation, pertinent guidance and ever-changing technology. Even if your organization utilizes a company wide revision process, we suggest you carve out a few hours this month to begin to review the infosec policies.

Start by reading all the policies related to information security. Note those that require significant updates.
Next, research changes in legislation or technology that might affect your policies. Note the pertinent changes.
Seek feedback from your colleagues and managers.
Using the information gained, revise the necessary policies or document your suggestions for the company-wide revision process.
Either obtain necessary approvals for your updates or provide your draft revisions to those responsible for maintaining updated policies and procedures.
Until next month, stay safe out there!

Special Thanks to Teresa West for the help on this one! — Brent

How Cloud Computing Will Leak Into Your Enterprise

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“Consumer use of the cloud”; in a phrase, is how the cloud will leak into your enterprise, whether you like it or not. Already, IT is struggling with how to manage the consumer use of devices and services in the enterprise. Skype/VoIP and WIFI were the warning shots, but the BlackBerry, iPhone, iPad and other consumer devices are the death nail for centralized IT (and IS) control.

Consumer electronics, backed by a wide array of free or low cost cloud services, are a new frontier for your organization. Services like MobileMe, DropBox, various file sharing tools and remote access services like GoToMyPC, et al. have arrived. Likely, they are in use in your environment today. Consumers use and leverage these services as a part of their increasingly de-centralized online life. Even with sites like Twitter and FaceBook growing in capability and attention, consumers grow their use, both personally and professionally of services “in the cloud”. Make no mistake, despite your controls at the corporate firewalls, consumers are using their mobile and pocket devices and a variety of these services. Unless you are searching them at the door and blocking cell phone use in your business, they are there.

This might not be “the cloud” that your server admins are worrying about. It might not represent all of the off-site system, database and other hosting tools they are focused on right now, but make no mistake, this consumer version of the cloud has all, if not more, of the same issues and concerns. Questions about your data is managed, secured and maintained all abound.

Given the “gadget posture” of most organizations and their user communities, this is not likely to be something that technical controls can adequately respond to. The consumer cloud services are too dynamic and widespread for black listing approaches to contain them. Plus, they obviously lack centralized choke points like in the old days of “network perimeter security”. The new solution, however, is familiar. Organizations must embrace policies and processes to cover these technologies and their issues. They also have to embrace education and awareness training around these topics with their user base. Those who think that denial and black listing can solve this problem are gravely mistaken. The backdoor cloud consumer movement into your organization is already present, strong and embedded. Teaching users to be focused on safe use of these services will hopefully reduce your risk, and theirs.