Welcome to the World of Public Cloud Collaboration Allowing Enhanced Security

Size: px
Start display at page:

Download "Welcome to the World of Public Cloud Collaboration Allowing Enhanced Security"

Transcription

1 Whitepaper Welcome to the World of Public Cloud Collaboration Allowing Enhanced Security A New, More Secure, and More Efficient Approach to Storage, Management and Collaboration for ITAR-defined Technical Data Through the Use of Cloud Solutions

2 The ITAR Rules Are Undergoing a 21st Century Facelift Regulations and practices governing the storage and processing of technical data defined in the ITAR are evolving. For many years management and collaboration have not been available for the ITAR-defined technical data. Regulations and practices governing the storage and processing of technical data defined in the International Traffic in Arms Regulations (the ITAR) are evolving. For example, in 2014, the Directorate of Defense Trade Controls (DDTC) within the U.S. State Department, the administrating agency for the ITAR 1, issued an advisory opinion pertaining to internet transmission of ITAR technical data. The new guideline, reflecting ongoing efforts to bring the ITAR in alignment with advancements in cloud computing over the last 15 years, for the first time formally recognized ITAR technical data might be shared and stored using cloud computing applications. The flexibility reflected in that guideline was conditioned on specific encryption strategies designed to address the traditional concerns of the DDTC that accidental or unintended exports of specified data be avoided. Other handling and recipient protocols beyond encryption, some again of a customary nature, also would be required, but it is clear from the DDTC s policy statement that change was in the wind. Thus, we see that in mid-2015, the DDTC has again visited the subject of cloud storage by proposing for comments certain revisions to the ITAR that, if adopted, would appear to permit cloud storage of technical data outside of the United States. Generally, these proposed rules changes, published in the Federal Register on June 3, 2015, would allow the electronic storage abroad of the ITAR-defined technical data that has been encrypted under the FIPS 140-2, so long as it is not stored in various prohibited countries. 2 For many years, aerospace and defense industry organizations have been unable to collaborate via common cloud computing practices that are widely recognized at the enterprise-level as best-in-class to foster high productivity and performance. Thus, the implementation of public cloud tools for document storage, management and collaboration have not been available for the ITAR-defined technical data. Even Robert Gates, former Secretary of Defense, recognized the detriment to development created by these types of restrictions when in 2010 he called the U.S. export control system a byzantine amalgam of authorities, roles, and missions scattered around different parts of the federal government. 3 1 See https://www.pmddtc.state.gov/index.html, accessed June 10, See https://www.pmddtc.state.gov/fr/2015/ _80fr31525.pdf, accessed June 10, As explained in the proposed rule change, [t]his will allow for cloud storage of encrypted data in foreign countries, so long as the technical data remains continuously encrypted while outside the United States. The effect of this proposed change would only add more risk to the concept of deemed exports unless the cloud solution itself can prevent export to one of those prohibited country. Moreover there may be less change here than might be immediately imagined. Technical data that must al ways be encrypted when outside the United States will always be useless for reference or production purposes when outside the country and, therefore, inaccessible in a usable form. 3 See (accessed on June 10, 2015) Whitepaper - ITAR Technical Data 2 6

3 Stringent Guidelines The ITAR dictates control over the export and import of defenserelated articles and services on the United States Munitions List (USML) and all listed and related technical data. This includes information within blueprints, technical drawings, photographs, mechanical plans, instructions, software and other sensitive defense-related documentation. The ITAR dictates control over the export and import of defense-related articles and services. Under the ITAR, at least to the present and unless an exemption exists, generally such information must be stored in a U.S.- located environment physically and logistically accessible only to U.S. citizens or permanent residents (U.S. persons). For a public cloud solution to meet these rigorous demands, all installation, support, ongoing maintenance and system upgrade activities must be supported exclusively by U.S. persons, employed by U.S. employers and supervised by other U.S. persons. Additional security features not mandated specifically by the ITAR but certainly part of a comprehensive and reasonably effective cybersecurity approach are full encryption, tamper-proof audit trails, two-factor authentication and operators, administrator and provider shielding, granular user permissioning, and document handling and dissemination restrictions, unless extra-territorial sharing (exporting) is going to occur. To be sure, ITAR-compliant solutions are not, and cannot be, available to the general public. Those wishing to utilize the ITAR-compliant solutions must guarantee that users are limited to U.S. persons or others who are appropriately licensed and, ideally, such organizations would maintain a valid DDTC exporter registration with full, unsanctioned U.S. export privileges, among other requirements. ITAR-compliant solutions are not, and cannot be, available to the general public. Moreover, any third party provider of cloud-based document storage, management and collaboration solution likely come within the ITAR s definition of manufacturers, exporters and brokers of defense article, related technical data and defense services as defined in the USML and therefore are required to register with the Defense Trade Controls as a precondition for the issuance of any license or other approval of export based on such services. 4 Organizations wishing to turn to a public cloud provider should ensure such registration has been approved and remains current. 4 The underlying regulations may be accessed at https://www.pmddtc.state.gov/registration/index.html (both accessed June 10, 2015). Whitepaper - ITAR Technical Data 3 6

4 Encryption and Tokenization More sophisticated and complete solutions to cloud security solutions to avoid deemed exports are required. Complex requirements and lagging use of technology solutions have led many to move quicker than it appears the DDTC would wish. The U.S. State Department has already cautioned at least one cloud security services provider for overstating the benefits of encryption and tokenization to meet the ITAR s high standards. While the provider apparently sought to market its token-based encryption technology as solving certain deemed export restrictions, according to a June 9, 2014 article published in the Wall Street Journal on the issue, a State Department official is quoted as stating, Tokenization is almost irrelevant to the exemption. We did not in any shape or form endorse tokenization as means [of meeting the ITAR standards]. Thus, more sophisticated and complete solutions to cloud security solutions to avoid deemed exports are required. Risky Business: The Cost of Non-Compliance Aerospace and defense contractors have been sanctioned for failing to comply with the ITAR. What is the importance of all this? Since 2010, there have been at least nine cases where aerospace and defense contractors have been sanctioned for failing to comply with the ITAR. In 2014, there were two fines issued, totaling approximately $30 million. In 2013, there were three fines issued for the ITAR violations, for a total of $41 million. Year Number of Fines Issued $30 million $41 million $55 million $79 million Total Amount of Assessed and Contingent Fines Moreover the possibility of fines is not the totality of sanctions. Remedial and punitive measures extend to additional civil and administrative remedies, including debarment as an exporter or even a government contractor. Consequences also could extend into criminal sanctions for egregious non-compliance. Whitepaper - ITAR Technical Data 4 6

5 Risky Business: What is to be Done? A better alternative is provided by newer offerings that have sophisticated functionality. Organizations wishing or having to use the collaborative and efficient cloud solutions that are coming to define best practices for ITAR-defined technical data, therefore, do have choices that go beyond the too often applied, and too often inadequate, default of telling employees to be careful and then hoping for the best. One alternative is to develop an expensive private, dark cloud to provide secure storage and sharing of sensitive documents. A better alternative, however, is provided by newer offerings that are entering the market and have sophisticated functionality that achieve important efficiencies and cost savings. These offerings have systemic monitoring tools to track who has viewed information, if it has been copied to an unsecure platform or if it has been exported. They can prevent the careless, clueless and malicious recipients of ITAR technical data from violating the ITAR despite best efforts at training and cautioning. The second choice relies on a conscious, automated and persistent effort, enabled by sophisticated document management tools, to avoid breaches of the ITAR through the deployment of proven enterprise tools that substantially reduce the risk of not meeting security guidelines. Not only do these tools employ safeguards to prevent non-u.s. persons or unlicensed individuals from viewing information, potentially causing the unintended or accidental export of the ITAR-defined technical data, they also implement definitive functions and processes to prevent copying and sharing outside of the solution. These solutions track access and sharing to allow for tamper-proof auditing for the future, as well as required reporting on an ongoing basis. Priceless Peace of Mind There is no need for businesses to take unnecessary risks. Although the monetary penalties for the ITAR violations are stiff -- often times, up to tens of millions of dollars in fines levied upon a company -- additional outcomes can be even more damaging including future bids that are challenged when an organization becomes known for a history of not complying with the ITAR. However, with the U.S. government opening the door for organizations that handle the ITAR-related technical data to now leverage secure public cloud collaboration tools, there is no need for businesses to take unnecessary risks. Whitepaper - ITAR Technical Data 5 6

6 These solutions, such as the ITAR-compliant Brainloop Secure Dataroom, are available for relatively affordable costs, particularly when compared to the consequences of the ITAR violations. In order to attain priceless peace of mind when handling the ITAR technical data, companies must ensure that collaboration solutions being considered for deployment are covered by endto-end the ITAR compliance. These solutions must assure the non-intended exports of the ITAR technical data are possible. They must be implemented and supported exclusively by U.S. persons at U.S. companies. They must include tamper proof audit trails to demonstrate uninterrupted ITAR compliance based on a document s specific history. They must be, or match, the ITARcompliant Brainloop solution. These solutions are available for relatively affordable costs, particularly when compared to the consequences of the ITAR violations. To learn more about the rules and regulations pertaining to the storage and collaboration of the ITAR-related documents in the ITAR compliant public cloud solutions, visit ITAR.com. About Brainloop Inc. Operating since 2007, Brainloop Inc., the Secure Enterprise Information Company, is a market-leading provider of highly intuitive SaaS (Software-as-a-Service) solution enabling customers to securely manage and collaborate on confidential documents and information, whether inside or outside of their IT environments. Our enterprise customers, comprising of numerous industries, count on our software s regulatory and corporate compliance, collaboration and process capabilities as well as its complete portfolio of security features. Brainloop s secure solutions look at the entire information protection issue in a holistic and integrated way to better protect the way businesses operate today. We go beyond common security measures to provide full 256-bit encryption, audit trail, two-factor authentication and provider and administrator shielding, all through an easy to use interface. Our customers count on our software s regulatory and corporate compliance, collaboration and process capabilities as well as its complete portfolio of security features. Brainloop Inc. holds a registration under part 122, Registration of Manufacturers and Exporters, section through 122.5, of the United States Munitions List for the purpose of providing its ITARcompliant, cloud based storage, management and collaboration solutions for documents containing technical data. Copyright 2015 Brainloop WP Whitepaper - Whitepaper - ITAR Technical Data 6 6

ITAR: Welcome to Public Cloud Collaboration

ITAR: Welcome to Public Cloud Collaboration Whitepaper ITAR: Welcome to Public Cloud Collaboration Updated Guidelines Create New Avenues for Aerospace and Defense Contractors to Share and Store Technical Data www.brainloop.com ITAR Rules Undergo

More information

Stringent Guidelines. ITAR dictates control over the export and import of. defense-related articles and services on the United States

Stringent Guidelines. ITAR dictates control over the export and import of. defense-related articles and services on the United States ITAR Rules Undergo 2l't Century Facelift Regulations and practices governing the storage and processing of International Traffic in Arms Regulations (ITAR) technical data are evolving. For example,in2or4,

More information

EXPORT CONTROLS COMPLIANCE

EXPORT CONTROLS COMPLIANCE Responsible University Official: Vice President for Research Responsible Office: Office for Export Controls Compliance Origination Date: May 1, 2014 EXPORT CONTROLS COMPLIANCE Policy Statement Northwestern

More information

Middle Tennessee State University. Office of Research Services

Middle Tennessee State University. Office of Research Services Middle Tennessee State University Office of Research Services Procedure No.: ORS 007: Export Control Date Approved: December 08, 2011 1. INTRODUCTION: It is the intent of Middle Tennessee State University

More information

ITAR Compliance Best Practices Guide

ITAR Compliance Best Practices Guide ITAR Compliance Best Practices Guide 1 Table of Contents Executive Summary & Overview 3 Data Security Best Practices 4 About Aurora 10 2 Executive Summary & Overview: International Traffic in Arms Regulations

More information

Key Elements of International Trade Compliance. Presented by:

Key Elements of International Trade Compliance. Presented by: Key Elements of International Trade Compliance Presented by: International Business Transactions International Civil Litigation 2 I. Introduction Every international shipment implicates at least TWO legal

More information

Using Technology Control Plans in Export Compliance. Mary Beran, Georgia Tech David Brady, Virginia Tech

Using Technology Control Plans in Export Compliance. Mary Beran, Georgia Tech David Brady, Virginia Tech Using Technology Control Plans in Export Compliance Mary Beran, Georgia Tech David Brady, Virginia Tech What is a Technology Control Plan (TCP)? The purpose of a TCP is to control the access and dissemination

More information

PROTECTING YOUR VOICE SYSTEM IN THE CLOUD

PROTECTING YOUR VOICE SYSTEM IN THE CLOUD PROTECTING YOUR VOICE SYSTEM IN THE CLOUD Every enterprise deserves to know what its vendors are doing to protect the data and systems entrusted to them. Leading IVR vendors in the cloud, like Angel, consider

More information

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls Westlaw Journal COMPUTER & INTERNET Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 31, ISSUE 1 / JUNE 13, 2013 Expert Analysis Software Development and U.S. Export Controls

More information

Brainloop Cloud Security

Brainloop Cloud Security Whitepaper Brainloop Cloud Security Guide to secure collaboration in the cloud www.brainloop.com Sharing information over the internet The internet is the ideal platform for sharing data globally and communicating

More information

University of Louisiana System

University of Louisiana System Policy Number: M-(16) University of Louisiana System Title: EXPORT CONTROL Effective Date: October 26, 2009 Cancellation: None Chapter: Miscellaneous Policy and Procedures Memorandum The University of

More information

Research Information Security Guideline

Research Information Security Guideline Research Information Security Guideline Introduction This document provides general information security guidelines when working with research data. The items in this guideline are divided into two different

More information

Second Annual Impact of Export Controls on Higher Education & Scientific Institutions

Second Annual Impact of Export Controls on Higher Education & Scientific Institutions The following presentation was presented at the Second Annual Impact of Export Controls on Higher Education & Scientific Institutions Hosted by Georgia Institute of Technology In cooperation with Association

More information

Enterprise Cloud Backup of Cloud-Based Applications/Platforms

Enterprise Cloud Backup of Cloud-Based Applications/Platforms EXECUTIVE SUMMARY Enterprise Cloud Backup of Cloud-Based Applications/Platforms Gartner predicts that more than 50% of enterprises will have some form of SaaS-based application strategy by 2015. As enterprises

More information

Addressing ITAR compliance with Teamcenter

Addressing ITAR compliance with Teamcenter Addressing ITAR compliance with Teamcenter White Paper Providing a framework for managing export control Teamcenter software enables companies to securely manage sensitive information and other highly

More information

Export Controls and Cloud Computing: Legal Risks

Export Controls and Cloud Computing: Legal Risks Presenting a live 90-minute webinar with interactive Q&A Export Controls and Cloud Computing: Legal Risks Complying with ITAR, EAR and Sanctions Laws When Using Cloud Storage and Services TUESDAY, APRIL

More information

DATA SECURITY AGREEMENT. Addendum # to Contract #

DATA SECURITY AGREEMENT. Addendum # to Contract # DATA SECURITY AGREEMENT Addendum # to Contract # This Data Security Agreement (Agreement) is incorporated in and attached to that certain Agreement titled/numbered and dated (Contract) by and between the

More information

ProtectV. Securing Sensitive Data in Virtual and Cloud Environments. Executive Summary

ProtectV. Securing Sensitive Data in Virtual and Cloud Environments. Executive Summary VISIBILITY DATA GOVERNANCE SYSTEM OS PARTITION UNIFIED MANAGEMENT CENTRAL AUDIT POINT ACCESS MONITORING ENCRYPTION STORAGE VOLUME POLICY ENFORCEMENT ProtectV SECURITY SNAPSHOT (backup) DATA PROTECTION

More information

Using Data Encryption to Achieve HIPAA Safe Harbor in the Cloud

Using Data Encryption to Achieve HIPAA Safe Harbor in the Cloud Using Data Encryption to Achieve HIPAA Safe Harbor in the Cloud 1 Contents The Obligation to Protect Patient Data in the Cloud................................................... Complying with the HIPAA

More information

HIPAA Security Alert

HIPAA Security Alert Shipman & Goodwin LLP HIPAA Security Alert July 2008 EXECUTIVE GUIDANCE HIPAA SECURITY COMPLIANCE How would your organization s senior management respond to CMS or OIG inquiries about health information

More information

Global Compliance Audit

Global Compliance Audit WHITE PAPER Global Compliance Audit Understanding the Critical Importance of FCPA and Export Management Compliance 333 Route 46 West Suite 200 Mountain Lakes, NJ 07046 1.866.611.7874 973.808.3366 fax 973.227.1873

More information

Bridging the HIPAA/HITECH Compliance Gap

Bridging the HIPAA/HITECH Compliance Gap CyberSheath Healthcare Compliance Paper www.cybersheath.com -65 Bridging the HIPAA/HITECH Compliance Gap Security insights that help covered entities and business associates achieve compliance According

More information

You Can Survive a PCI-DSS Assessment

You Can Survive a PCI-DSS Assessment WHITE PAPER You Can Survive a PCI-DSS Assessment A QSA Primer on Best Practices for Overcoming Challenges and Achieving Compliance The Payment Card Industry Data Security Standard or PCI-DSS ensures the

More information

International Trade Compliance Alert

International Trade Compliance Alert M A Y 2 0 1 1 International Trade Compliance Alert Proposed Change to the ITAR s Definition of Defense Services: Critical Analysis and Related Concerns Recently, the U.S. Department of State, Directorate

More information

WHITEPAPER. HIPAA/HITECH Compliance and SharePoint

WHITEPAPER. HIPAA/HITECH Compliance and SharePoint WHITEPAPER HIPAA/HITECH Compliance and SharePoint Executive Summary The United States Congress passed the Health Insurance Portability and Accountability Act (HIPAA) into law in 1996. Most people in the

More information

HIPAA Security Rule Compliance and Health Care Information Protection

HIPAA Security Rule Compliance and Health Care Information Protection HIPAA Security Rule Compliance and Health Care Information Protection How SEA s Solution Suite Ensures HIPAA Security Rule Compliance Legal Notice: This document reflects the understanding of Software

More information

Securing Data in the Virtual Data Center and Cloud: Requirements for Effective Encryption

Securing Data in the Virtual Data Center and Cloud: Requirements for Effective Encryption THE DATA PROTECTIO TIO N COMPANY Securing Data in the Virtual Data Center and Cloud: Requirements for Effective Encryption whitepaper Executive Summary Long an important security measure, encryption has

More information

Supplier Awareness. Export Control/ ITAR

Supplier Awareness. Export Control/ ITAR Export Control & ITAR Supplier Awareness Export Control/ ITAR THIS INFORMATION IS PROVIDED BY PAR SYSTEMS, INC. ("PAR"). PAR IS NOT A LAW FIRM, AND THE INFORMATION CONTAINED HEREIN IS NOT INTENDED TO BE

More information

Why You Should Consider Cloud- Based Email Archiving. A whitepaper by The Radicati Group, Inc.

Why You Should Consider Cloud- Based Email Archiving. A whitepaper by The Radicati Group, Inc. . The Radicati Group, Inc. 1900 Embarcadero Road, Suite 206 Palo Alto, CA 94303 Phone 650-322-8059 Fax 650-322-8061 http://www.radicati.com THE RADICATI GROUP, INC. Why You Should Consider Cloud- Based

More information

Page 1. Copyright 2009. MFA - Moody, Famiglietti & Andronico, LLP. All Rights Reserved.

Page 1. Copyright 2009. MFA - Moody, Famiglietti & Andronico, LLP. All Rights Reserved. Page 1 Page 2 Page 3 Agenda Defining the Massachusetts Personal Data Security Law Becoming Compliant Page 4 Massachusetts Privacy Law Defining the Massachusetts Personal Data Security Law - 201 CMR 17.00

More information

Security in Fax: Minimizing Breaches and Compliance Risks

Security in Fax: Minimizing Breaches and Compliance Risks Security in Fax: Minimizing Breaches and Compliance Risks Maintaining regulatory compliance is a major business issue facing organizations around the world. The need to secure, track and store information

More information

HIPAA and HITECH Compliance for Cloud Applications

HIPAA and HITECH Compliance for Cloud Applications What Is HIPAA? The healthcare industry is rapidly moving towards increasing use of electronic information systems - including public and private cloud services - to provide electronic protected health

More information

PCI Compliance for Cloud Applications

PCI Compliance for Cloud Applications What Is It? The Payment Card Industry Data Security Standard (PCIDSS), in particular v3.0, aims to reduce credit card fraud by minimizing the risks associated with the transmission, processing, and storage

More information

Bossier Parish Community College

Bossier Parish Community College Bossier Parish Community College Department of Cyber Information Technology Welcome to the Program! Network Security & Networking Tracks Code of Conduct This marks the beginning of your journey through

More information

Head of Information & Communications Technology Responsible work team: ICT Security. Key point summary... 2

Head of Information & Communications Technology Responsible work team: ICT Security. Key point summary... 2 Policy Procedure Information security policy Policy number: 442 Old instruction number: MAN:F005:a1 Issue date: 24 August 2006 Reviewed as current: 11 July 2014 Owner: Head of Information & Communications

More information

The Brave. New World of Healthcare Correspondence. Harnessing the Power of SaaS to Safeguard Patient Data. White paper

The Brave. New World of Healthcare Correspondence. Harnessing the Power of SaaS to Safeguard Patient Data. White paper The Brave New World of Healthcare Correspondence Harnessing the Power of SaaS to Safeguard Patient Data Background The passage of HIPAA in 1996 introduced seismic changes to the way healthcare providers

More information

Department of Defense DIRECTIVE

Department of Defense DIRECTIVE Department of Defense DIRECTIVE NUMBER 5400.11 October 29, 2014 DCMO SUBJECT: DoD Privacy Program References: See Enclosure 1 1. PURPOSE. This directive: a. Reissues DoD Directive (DoDD) 5400.11 (Reference

More information

Harvard Export Control Compliance Policy Statement

Harvard Export Control Compliance Policy Statement Harvard Export Control Compliance Policy Statement Harvard University investigators engage in a broad range of innovative and important research both in the United States and overseas. These activities

More information

Using Automated, Detailed Configuration and Change Reporting to Achieve and Maintain PCI Compliance Part 4

Using Automated, Detailed Configuration and Change Reporting to Achieve and Maintain PCI Compliance Part 4 WHITEPAPER Using Automated, Detailed Configuration and Change Reporting to Achieve and Maintain PCI Compliance Part 4 An in-depth look at Payment Card Industry Data Security Standard Requirements 10, 11,

More information

Five PCI Security Deficiencies of Retail Merchants and Restaurants

Five PCI Security Deficiencies of Retail Merchants and Restaurants Whitepaper January 2010 Five PCI Security Deficiencies of Retail Merchants and Restaurants The Most Common PCI Compliance Mistakes of Brick-and-Mortar Locations by Brad Cyprus, SSCP - Senior Security Architect,

More information

SOLUTION BRIEF. HIPAA and HITECH Compliance for SharePoint. Introduction

SOLUTION BRIEF. HIPAA and HITECH Compliance for SharePoint. Introduction SOLUTION BRIEF HIPAA and HITECH Compliance for SharePoint Introduction The United States Congress passed the Health Insurance Portability and Accountability Act (HIPAA) into law in 1996. Most people in

More information

JOINT EXPLANATORY STATEMENT TO ACCOMPANY THE CYBERSECURITY ACT OF 2015

JOINT EXPLANATORY STATEMENT TO ACCOMPANY THE CYBERSECURITY ACT OF 2015 JOINT EXPLANATORY STATEMENT TO ACCOMPANY THE CYBERSECURITY ACT OF 2015 The following consists of the joint explanatory statement to accompany the Cybersecurity Act of 2015. This joint explanatory statement

More information

Introduction to The Privacy Act

Introduction to The Privacy Act Introduction to The Privacy Act Defense Privacy and Civil Liberties Office dpclo.defense.gov 1 Introduction The Privacy Act (5 U.S.C. 552a, as amended) can generally be characterized as an omnibus Code

More information

Compliance in the Corporate World

Compliance in the Corporate World Compliance in the Corporate World How Fax Server Technology Minimizes Compliance Risks Fax and Document Distribution Group November 2009 Abstract Maintaining regulatory compliance is a major business issue

More information

Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health Act (HITECH)

Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health Act (HITECH) Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health Act (HITECH) Table of Contents Introduction... 1 1. Administrative Safeguards...

More information

Safeguarding the cloud with IBM Dynamic Cloud Security

Safeguarding the cloud with IBM Dynamic Cloud Security Safeguarding the cloud with IBM Dynamic Cloud Security Maintain visibility and control with proven security solutions for public, private and hybrid clouds Highlights Extend enterprise-class security from

More information

Securing the Service Desk in the Cloud

Securing the Service Desk in the Cloud TECHNICAL WHITE PAPER Securing the Service Desk in the Cloud BMC s Security Strategy for ITSM in the SaaS Environment Introduction Faced with a growing number of regulatory, corporate, and industry requirements,

More information

The Story of Non-admitted Insurance in California

The Story of Non-admitted Insurance in California The Surplus Line Association Of California CA The Story of Non-admitted Insurance in California The Story of Non-Admitted Insurance in California It is vital an innovative and imaginative insurance marketplace

More information

HIPAA Compliance: Are you prepared for the new regulatory changes?

HIPAA Compliance: Are you prepared for the new regulatory changes? HIPAA Compliance: Are you prepared for the new regulatory changes? Baker Tilly CARIS Innovation, Inc. April 30, 2013 Baker Tilly refers to Baker Tilly Virchow Krause, LLP, an independently owned and managed

More information

Information Security Handbook

Information Security Handbook Information Security Handbook Adopted 6/4/14 Page 0 Page 1 1. Introduction... 5 1.1. Executive Summary... 5 1.2. Governance... 5 1.3. Scope and Application... 5 1.4. Biennial Review... 5 2. Definitions...

More information

Export Control Basics

Export Control Basics Export Control Basics Updated on May 15, 2014 What are Export Controls? U.S. laws and regulations that restrict the distribution to foreign nationals and foreign countries of strategically important products,

More information

ADDING STRONGER AUTHENTICATION for VPN Access Control

ADDING STRONGER AUTHENTICATION for VPN Access Control ADDING STRONGER AUTHENTICATION for VPN Access Control Adding Stronger Authentication for VPN Access Control 1 ADDING STRONGER AUTHENTICATION for VPN Access Control A VIRTUAL PRIVATE NETWORK (VPN) allows

More information

Information Security Program Management Standard

Information Security Program Management Standard State of California California Information Security Office Information Security Program Management Standard SIMM 5305-A September 2013 REVISION HISTORY REVISION DATE OF RELEASE OWNER SUMMARY OF CHANGES

More information

Accelerating Insurance Legacy Modernization

Accelerating Insurance Legacy Modernization White Paper Accelerating Insurance Legacy Modernization Avoiding Data Breach During Application Retirement with the Informatica Solution for Test Data Management This document contains Confidential, Proprietary

More information

Strengthen security with intelligent identity and access management

Strengthen security with intelligent identity and access management Strengthen security with intelligent identity and access management IBM Security solutions help safeguard user access, boost compliance and mitigate insider threats Highlights Enable business managers

More information

Healthcare Compliance Solutions

Healthcare Compliance Solutions Privacy Compliance Healthcare Compliance Solutions Trust and privacy are essential for building meaningful human relationships. Let Protected Trust be your Safe Harbor The U.S. Department of Health and

More information

Protection. Code of Practice. of Personal Data RPC001147_EN_WB_L_1

Protection. Code of Practice. of Personal Data RPC001147_EN_WB_L_1 Protection of Personal Data RPC001147_EN_WB_L_1 Table of Contents Data Protection Rules Foreword From the Data Protection Commissioner Introduction From the Chairman Data Protection Responsibility of Employees

More information

NATIONAL CREDIT UNION ADMINISTRATION OFFICE OF INSPECTOR GENERAL

NATIONAL CREDIT UNION ADMINISTRATION OFFICE OF INSPECTOR GENERAL NATIONAL CREDIT UNION ADMINISTRATION OFFICE OF INSPECTOR GENERAL INDEPENDENT EVALUATION OF THE NATIONAL CREDIT UNION ADMINISTRATION S COMPLIANCE WITH THE FEDERAL INFORMATION SECURITY MANAGEMENT ACT (FISMA)

More information

Evolving Employment Authorization Enforcement

Evolving Employment Authorization Enforcement Portfolio Media, Inc. 648 Broadway, Suite 200 New York, NY 10012 www.law360.com Phone: +1 212 537 6331 Fax: +1 212 537 6371 customerservice@portfoliomedia.com Evolving Employment Authorization Enforcement

More information

HIPAA Compliance and the Protection of Patient Health Information

HIPAA Compliance and the Protection of Patient Health Information HIPAA Compliance and the Protection of Patient Health Information WHITE PAPER By Swift Systems Inc. April 2015 Swift Systems Inc. 7340 Executive Way, Ste M Frederick MD 21704 1 Contents HIPAA Compliance

More information

Banking Supervision Policy Statement No.18. Agent Banking Guideline

Banking Supervision Policy Statement No.18. Agent Banking Guideline Banking Supervision Policy Statement No.18 Agent Banking Guideline NOTICE TO COMMERCIAL BANKS LICENSED UNDER THE BANKING ACT 1995 PART I: PRELIMINARY 1. Introduction 1.1. This Notice, issued under section

More information

Policy and Procedures Date: 08-24-11

Policy and Procedures Date: 08-24-11 Virginia Polytechnic Institute and State University Policy and Procedures Date: 08-24-11 Subject: Export and Sanctions Compliance Policy Definitions 1.0 Policy 2.0 Oversight 3.0 Responsibilities of Faculty,

More information

HIPAA Omnibus Compliance How A Data Loss Prevention Solution Can Help

HIPAA Omnibus Compliance How A Data Loss Prevention Solution Can Help HIPAA Omnibus Compliance How A Data Loss Prevention Solution Can Help The Health Information Portability and Accountability Act (HIPAA) Omnibus Rule which will begin to be enforced September 23, 2013,

More information

Whitepaper. Simple and secure. Business requirements for Enterprise File Sync and Share solutions. www.brainloop.com

Whitepaper. Simple and secure. Business requirements for Enterprise File Sync and Share solutions. www.brainloop.com Whitepaper Simple and secure Business requirements for Enterprise File Sync and Share solutions www.brainloop.com Simplicity and security: business requirements for enterprise file sync and share solutions

More information

1. Not Subject to the EAR and Defense Article. (1) Reserved. (2) Reserved

1. Not Subject to the EAR and Defense Article. (1) Reserved. (2) Reserved 1. Not Subject to the EAR and Defense Article 734.3 (a) (NO REVISION) (b) The following are not subject to the EAR: (1) (NO REVISION) (2) (NO REVISION) (3) Information and software that: (i) Are published,

More information

Understanding HIPAA Privacy and Security Helping Your Practice Select a HIPAA- Compliant IT Provider A White Paper by CMIT Solutions

Understanding HIPAA Privacy and Security Helping Your Practice Select a HIPAA- Compliant IT Provider A White Paper by CMIT Solutions Understanding HIPAA Privacy and Security Helping Your Practice Select a HIPAA- Compliant IT Provider A White Paper by CMIT Solutions Table of Contents Understanding HIPAA Privacy and Security... 1 What

More information

Adopt a unified, holistic approach to a broad range of data security challenges with IBM Data Security Services.

Adopt a unified, holistic approach to a broad range of data security challenges with IBM Data Security Services. Security solutions To support your IT objectives Adopt a unified, holistic approach to a broad range of data security challenges with IBM Data Security Services. Highlights Balance effective security with

More information

2016 OCR AUDIT E-BOOK

2016 OCR AUDIT E-BOOK !! 2016 OCR AUDIT E-BOOK About BlueOrange Compliance: We specialize in healthcare information privacy and security solutions. We understand that each organization is busy running its business and that

More information

white paper Mitigate Risk in Handling ediscovery Data Subject to the U.S. Export Control Laws and Regulations

white paper Mitigate Risk in Handling ediscovery Data Subject to the U.S. Export Control Laws and Regulations white paper Mitigate Risk in Handling ediscovery Data Subject to the U.S. Export Control Laws and Regulations WWW.EPIQSYSTEMS.COM 800 314 5550 Mitigate Risk in Handling ediscovery Data Subject to the U.S.

More information

Securing the Financial Services Firm With Essential Taceo

Securing the Financial Services Firm With Essential Taceo You, In Control www.essentialsecurity.com Essential Security Software TM presents Securing the Financial Services Firm With Essential Taceo 2. Financial Services Firm: Overview 3. In Compliance with SOX,

More information

White Paper. HIPAA-Regulated Enterprises. Paper Title Here

White Paper. HIPAA-Regulated Enterprises. Paper Title Here White Paper White Endpoint Paper Backup Title Compliance Here Additional Considerations Title for Line HIPAA-Regulated Enterprises A guide for White IT professionals Paper Title Here in healthcare, pharma,

More information

TARTISAN RESOURCES CORP. INSIDER TRADING AND BLACK-OUT POLICY

TARTISAN RESOURCES CORP. INSIDER TRADING AND BLACK-OUT POLICY TARTISAN RESOURCES CORP. INSIDER TRADING AND BLACK-OUT POLICY DECEMBER 21, 2010 Table of Contents EXECUTIVE SUMMARY... 3 INTRODUCTION... 3 MATERIAL INFORMATION... 4 PERSONS IN A SPECIAL RELATIONSHIP WITH

More information

Evolution from FTP to Secure File Transfer

Evolution from FTP to Secure File Transfer IPSWITCH FILE TRANSFER WHITE PAPER Evolution from FTP to Secure File Transfer www.ipswitchft.com Do you know where your organization s confidential and sensitive files were transferred today? Are you sure

More information

Cloud Computing: A Question of Trust Maintaining Control and Compliance with Data-centric Information Security

Cloud Computing: A Question of Trust Maintaining Control and Compliance with Data-centric Information Security Russ Dietz Vice President & Chief Technology Officer Cloud Computing: A Question of Trust Maintaining Control and Compliance with Data-centric Information Security By Russ Dietz Vice President & Chief

More information

Encryption, Key Management, and Consolidation in Today s Data Center

Encryption, Key Management, and Consolidation in Today s Data Center Encryption, Key Management, and Consolidation in Today s Data Center Unlocking the Potential of Data Center Consolidation whitepaper Executive Summary Today, organizations leadership teams are striving

More information

MANAGED FILE TRANSFER: 10 STEPS TO HIPAA/HITECH COMPLIANCE

MANAGED FILE TRANSFER: 10 STEPS TO HIPAA/HITECH COMPLIANCE WHITE PAPER MANAGED FILE TRANSFER: 10 STEPS TO HIPAA/HITECH COMPLIANCE 1. OVERVIEW Do you want to design a file transfer process that is secure? Or one that is compliant? Of course, the answer is both.

More information

Compliance Management, made easy

Compliance Management, made easy Compliance Management, made easy LOGPOINT SECURING BUSINESS ASSETS SECURING BUSINESS ASSETS LogPoint 5.1: Protecting your data, intellectual property and your company Log and Compliance Management in one

More information

Infor CloudSuite. Defense-in-depth. Table of Contents. Technical Paper Plain talk about Infor CloudSuite security

Infor CloudSuite. Defense-in-depth. Table of Contents. Technical Paper Plain talk about Infor CloudSuite security Technical Paper Plain talk about security When it comes to Cloud deployment, security is top of mind for all concerned. The Infor CloudSuite team uses best-practice protocols and a thorough, continuous

More information

HIPAA DATA SECURITY & PRIVACY COMPLIANCE

HIPAA DATA SECURITY & PRIVACY COMPLIANCE HIPAA DATA SECURITY & PRIVACY COMPLIANCE This paper explores how isheriff Cloud Security enables organizations to meet HIPAA compliance requirements with technology and real-time data identification. Learn

More information

Enterprise Data Protection

Enterprise Data Protection PGP White Paper June 2007 Enterprise Data Protection Version 1.0 PGP White Paper Enterprise Data Protection 2 Table of Contents EXECUTIVE SUMMARY...3 PROTECTING DATA EVERYWHERE IT GOES...4 THE EVOLUTION

More information

EXPORT CONTROL GUIDELINES FOR STAFF

EXPORT CONTROL GUIDELINES FOR STAFF EXPORT CONTROL GUIDELINES FOR STAFF Created: June 2010 Reviewed: September 2013 Reviewed: April 2015 Maintained by the Office of Sponsored Programs 1 List of Commonly Used Acronyms BIS CCL CJ DDTC EAR

More information

REGULATORY CHANGES DEMAND AN ENTERPRISE-WIDE APPROACH TO DISCLOSURE MANAGEMENT OF PHI

REGULATORY CHANGES DEMAND AN ENTERPRISE-WIDE APPROACH TO DISCLOSURE MANAGEMENT OF PHI REGULATORY CHANGES DEMAND AN ENTERPRISE-WIDE APPROACH TO DISCLOSURE MANAGEMENT OF PHI Healthcare Organizations Can Adopt Enterprise-Wide Disclosure Management Systems To Standardize Disclosure Processes,

More information

A Primer on U.S. Export Controls

A Primer on U.S. Export Controls A Primer on U.S. Export Controls Presentation for the Pacific Northwest Defense Coalition By Akana K.J. Ma Partner, Ater Wynne LLP 16 July 2013 (503) 226-8489/akm@aterwynne.com Akana K.J. Ma 2013 All Rights

More information

TERRITORY RECORDS OFFICE BUSINESS SYSTEMS AND DIGITAL RECORDKEEPING FUNCTIONALITY ASSESSMENT TOOL

TERRITORY RECORDS OFFICE BUSINESS SYSTEMS AND DIGITAL RECORDKEEPING FUNCTIONALITY ASSESSMENT TOOL TERRITORY RECORDS OFFICE BUSINESS SYSTEMS AND DIGITAL RECORDKEEPING FUNCTIONALITY ASSESSMENT TOOL INTRODUCTION WHAT IS A RECORD? AS ISO 15489-2002 Records Management defines a record as information created,

More information

Sarbanes-Oxley Compliance for Cloud Applications

Sarbanes-Oxley Compliance for Cloud Applications Sarbanes-Oxley Compliance for Cloud Applications What Is Sarbanes-Oxley? Sarbanes-Oxley Act (SOX) aims to protect investors and the general public from accounting errors and fraudulent practices. For this

More information

White Paper. Document Security and Compliance. April 2013. Enterprise Challenges and Opportunities. Comments or Questions?

White Paper. Document Security and Compliance. April 2013. Enterprise Challenges and Opportunities. Comments or Questions? White Paper April 2013 Document Security and Compliance Enterprise Challenges and Opportunities Comments or Questions? Table of Contents Introduction... 3 Prevalence of Document-Related Security Breaches...

More information

5 Cornerstones of Compliance

5 Cornerstones of Compliance 5 Cornerstones of Compliance DATTO S INFORMATION SECURITY CONTROLS by Feisal Nanji, Datto Chief Security Officer For backup and disaster recovery (BDR) solution providers Security Compliance can be a multi-tiered,

More information

Cloud security architecture

Cloud security architecture ericsson White paper Uen 284 23-3244 January 2015 Cloud security architecture from process to deployment The Trust Engine concept and logical cloud security architecture presented in this paper provide

More information

PCI Data Security Standards (DSS)

PCI Data Security Standards (DSS) ENTERPRISE APPLICATION WHITELISTING SOLUTION Achieving PCI Compliance at the Point of Sale Using Bit9 Parity TM to Protect Cardholder Data PCI: Protecting Cardholder Data As the technology used by merchants

More information

Is Your Vendor CJIS-Certified?

Is Your Vendor CJIS-Certified? A Thought Leadership Profile Symantec SHUTTERSTOCK.COM Is Your Vendor CJIS-Certified? How to identify a vendor partner that can help your agency comply with new federal security standards for accessing

More information

Protection. Code of Practice. of Personal Data RPC001147_EN_D_19

Protection. Code of Practice. of Personal Data RPC001147_EN_D_19 Protection of Personal Data RPC001147_EN_D_19 Table of Contents Data Protection Rules Foreword From the Data Protection Commissioner Introduction From the Chairman Data Protection Rules Responsibility

More information

SAS 70 Type II Audits

SAS 70 Type II Audits Thinking from IntraLinks SAS 70 Type II Audits SAS 70 Type II Audits Ensuring Data Security, Reliability and Integrity If your organization shares sensitive data over the Internet, you need rigorous controls

More information

CENTER FOR INSTRUCTION TECHNOLOGY AND INNOVATION (CiTi) MEDICAID BILLING COMPLIANCE PROGRAM

CENTER FOR INSTRUCTION TECHNOLOGY AND INNOVATION (CiTi) MEDICAID BILLING COMPLIANCE PROGRAM CENTER FOR INSTRUCTION TECHNOLOGY AND INNOVATION (CiTi) MEDICAID BILLING COMPLIANCE PROGRAM INTRODUCTION This Program is an integral part of the CiTi s ongoing efforts to achieve compliance with federal

More information

A Comprehensive FATCA Solution

A Comprehensive FATCA Solution in collaboration with A Comprehensive FATCA Solution End-to-end automated legal, technology and software solution facilitates global compliance with U.S. Foreign Account Tax Compliance Act requirements

More information

Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance

Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance Arm Stakeholders with Critical Information to Assess 3rd Party Relationships and Comply with the Foreign Corrupt Practices Act

More information

Please note this policy is mandatory and staff are required to adhere to the content

Please note this policy is mandatory and staff are required to adhere to the content Policy ICT Security Please note this policy is mandatory and staff are required to adhere to the content Summary DECD is committed to ensuring its information is appropriately managed according to the

More information

COMPUTER SOFTWARE AS A SERVICE LICENSE AGREEMENT

COMPUTER SOFTWARE AS A SERVICE LICENSE AGREEMENT COMPUTER SOFTWARE AS A SERVICE LICENSE AGREEMENT This Agreement is binding on the individual and the company, or other organization or entity, on whose behalf such individual accepts this Agreement, that

More information

HIPAA, PHI and Email. How to Ensure your Email and Other ephi are HIPAA Compliant. www.fusemail.com

HIPAA, PHI and Email. How to Ensure your Email and Other ephi are HIPAA Compliant. www.fusemail.com How to Ensure your Email and Other ephi are HIPAA Compliant How to Ensure Your Email and Other ephi Are HIPAA Compliant Do you know if the patient appointments your staff makes by email are compliant with

More information