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CMMC: Is it time for your cybersecurity program to grow up?

09.29.23

Read this if you are involved in cybersecurity at your organization.

The cyber threat landscape is growing

Over the years, the cyber threat landscape has experienced a steady increase in cyberattacks, with more data breaches, targeted social engineering attacks, and crippling ransomware attacks taking place. The increase in cyberattacks is affecting all industries, including government supply chain vendors, higher education and research institutions, and many others. 

The US government is particularly aware of the risks involved with the increase in cyberattacks and understands it must continue to strengthen its cybersecurity program to protect intellectual property and national security. This means not only strengthening cybersecurity controls and processes for the government, but also for contractors who work directly and indirectly with the government. In this case, “contractors” include businesses that enter into contracts with the US government and any supplier, distributor, vendor, or firm that provides products or services to contractors and other subcontractors. 

What is the Cybersecurity Maturity Model Certification (CMMC) framework?

The CMMC framework provides a foundation for establishing a strong cybersecurity program to effectively manage cyber threats. The framework was developed by the Department of Defense (DoD) and is designed to help ensure that cybersecurity controls and processes adequately protect sensitive information that is shared among entities across various industries. Broadly speaking, contractors and subcontractors that work with the DoD will be required to comply with CMMC guidelines. 

Prior to the enforcement of CMMC, contractors were responsible for implementing and monitoring their own cybersecurity controls and processes and could self-attest to their level of security. In other words, the DoD did not audit or verify the level of security maintained by contractors. But now with cyber criminals frequently targeting the weakest link in supply chains, the DoD has responded by moving to a trust-but-verify approach, meaning organizations working with the DoD may be required to have a third party (also called a C3PAO) assess cybersecurity controls and processes and verify CMMC compliance. 

CMMC industry standards and cybersecurity best practices

Although the framework is evolving and requirements are still being finalized, CMMC currently mandates NIST 800-171 compliance and adds additional requirements coming from other cybersecurity frameworks, including the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF), Center for Internet Security (CIS) Controls, and the Computer Emergency Response Team (CERT) Resilience Management Model (RMM). CMMC uses these industry standards and cybersecurity best practices to establish a benchmark against which assessors can measure an organization’s cybersecurity posture. Following the assessment, the organization will better understand the maturity of their controls and processes and where gaps may exist. 

CMMC compliance benefits beyond the DoD

CMMC compliance will soon become a prerequisite for DoD contract awards and is expected to impact over 300,000 contractors and subcontractors. The purpose of CMMC is to provide a uniform set of security standards that every contractor working with the DoD must use to protect sensitive information. Without compliance, organizations could be excluded from bidding on DoD contracts. By 2025, every organization doing business with the DoD must be CMMC compliant, including those entities conducting research using federal grant funds. 

Outside of helping companies with DoD contract prerequisites, CMMC compliance is important for several other reasons. First, the framework helps ensure that organizations have implemented the proper controls and processes to protect themselves from cyber threats. It also helps ensure compliance with other laws and regulations. Additionally, by following the CMMC set of standards and best practices, organizations can maintain a high trust relationship with partners and customers. 

Who should be CMMC compliant?

All contractors and subcontractors that work with the DoD should be CMMC certified. The required maturity level will depend on the DoD contract and the sensitivity of information the organization receives or uses. Today, only organizations that directly provide products and services to the DoD, known as prime contractors, must meet NIST 800-171 and additional requirements of CMMC compliance. Prime contractors must also verify that subcontractors further down the supply chain also meet requirements. By 2025, CMMC compliance obligations will extend to all organizations bidding on defense contracts. At that point, all organizations working with the DoD, no matter what service or services they provide, will need at least Level 1 CMMC compliance to win or maintain a DoD contract (more information on maturity levels below). 

If an organization is planning to contract with the DoD, they should plan to be CMMC certified and should preemptively attain Level 1 CMMC compliance. Again, the maturity level required by an organization will be stipulated on a case-by-case basis in the contract. Fortunately, if an organization is already compliant with NIST 800-53 or FedRAMP (the security standard for all government contractors generally), they are not far from becoming certified. Likewise, if an organization is compliant with NIST 800-171, they may already fulfill many of the requirements of CMMC. 

A breakdown of CMMC maturity levels

In September 2020, the DoD established CMMC 1.0. The original framework organized security maturity levels into five tiers, but in November 2021, the DoD announced the most recent version, CMMC 2.0, which introduces several key changes, including a more streamlined model that should reduce costs, particularly for smaller organizations. Additionally, CMMC 2.0 organizes maturity levels into three tiers—instead of five.

  1. Foundational
    The first tier includes basic cybersecurity hygiene appropriate for small organizations utilizing a subset of universally accepted best practices. This tier only requires an annual self-assessment and attestation by company leadership.
  2. Advanced
    The second tier includes coverage of all 110 NIST SP 800-171 controls. This tier will require a CMMC third-party Assessment Organization (C3PAO) to perform a triennial assessment of their CMMC implementation.
  3. Expert
    The final tier includes implementing highly advanced cybersecurity controls and processes. The processes involved at this level include continuous improvement across the organization and timely incident response capabilities. The details of this tier are still being defined, but it is expected that it will incorporate a subset of controls from NIST 800-172. Additionally, the organization would be assessed by the DoD and not by a C3PAO. 

Challenges and considerations of CMMC compliance 

CMMC compliance can be challenging for several reasons. The first challenge refers to the extent of CMMC compliance for the organization, whether you are starting from scratch or modifying another cybersecurity framework. The CMMC’s core is comprised of the 14 cybersecurity domains outlined in NIST 800-171. The domains include areas such as access control, awareness and training, and incident response. Within the 14 domains there are 110 controls. These controls include topics like limiting unsuccessful login attempts, ensuring that personnel are trained to carry out their assigned information security-related duties and responsibilities, and testing organizational incident response capabilities. Mapping all these security requirements is not easy and implementing them without a clear idea of what they entail is almost impossible.

Another common challenge with CMMC compliance is cost, and organizations should begin to build budgets to upgrade cybersecurity controls and processes to the levels needed. The costs associated with CMMC compliance depend on several factors:

  • Organization size
    The size of the organization may have an impact on project costs; however, the number of employees accessing sensitive information is the more significant driver in determining overall costs of compliance. Thus, organizations should limit the number of employees receiving and using sensitive information. 
  • Maturity
    The journey to CMMC compliance will likely cost more and take longer for organizations starting from scratch. For organizations further along in the process, it will be important to consider the current maturity level of documentation development, technology implementation, and what processes and procedures are already documented and in use. 
  • Technology implementation
    Achieving compliance will require a combination of policy and technology. The more technologies the organization must implement, the greater the costs. Some of the more expensive technologies include a security incident and event management (SIEM) system and vulnerability scanner.
  • Consultants
    Consulting costs should be considered when setting out for CMMC compliance. Organizations often have consultants perform a gap analysis to analyze how well their current cybersecurity program meets—or does not meet—the demands of NIST 800-171. This helps an organization determine whether it complies with the CMMC, or what steps will be necessary to achieve compliance. In other words, a gap analysis can keep the organization’s CMMC compliance strategy on track.

It is important that organizations understand that CMMC compliance is not a one-time expense. Compliance can have an impact on IT support teams, forcing units to spend time on regulated data environments at the cost of supporting broader organizational needs. Ongoing training is necessary to keep stakeholders up to date on the evolving threat landscape. Requirements are also not easy to implement and may have an impact on the organization. Finally, noncompliance carries its own risks, such as not qualifying for new awards or the potential loss of current projects. 

The last challenge to completing CMMC compliance is getting the official certification. Contrary to many other frameworks, the organization must obtain the certification from a C3PAO that has been granted accreditation by the CMMC Accreditation Body/The Cyber AB.

Preparing for CMMC compliance

Before achieving CMMC compliance, organizations should understand their current state of security and determine what level of compliance is necessary. Organizations should perform a gap analysis to analyze how their current cybersecurity program meets—or does not meet—compliance requirements. Following the analysis, organizations should develop a security roadmap that outlines how they will implement requirements to prepare for a CMMC assessment. It will also be important for the organization to determine the scope of the assessment. 

For organizations that are ready to attain CMMC compliance, the next step is to perform the assessment. A CMMC assessment is the process of assessing an organization’s cybersecurity maturity, and it is required to demonstrate an organization’s compliance with the desired CMMC level before being certified. For organizations looking to achieve Level 1 CMMC compliance, an assessment can be performed through a self-assessment. Any organizations that intend to attain Level 2 or 3 compliance need to pass a third-party assessment.

CMMC assessments examine the cybersecurity policies, procedures, controls, and processes to determine compliance with NIST 800-171, NIST 800-172, and any other requirements. The extent of the assessment will depend on the maturity level an organization wants to achieve. The assessor will request information to evaluate the controls and processes protecting sensitive information, which may include previous risk assessments, network diagrams, vulnerability scans, and other relevant documentation. 

Conclusion

In today’s rapidly evolving environment, the DoD is focused on protecting sensitive information from malicious cyberattacks, particularly throughout the supply chain. CMMC offers a structured framework for organizations to strengthen their cybersecurity posture. For organizations doing business or looking to do business with the DoD, CMMC compliance will soon be required to help ensure that contractors are meeting minimum industry standards and cybersecurity best practices. 

While the road to compliance presents challenges like resource allocation and technological adaptation, the journey toward compliance is an ongoing process. To help ensure compliance, organizations should establish transparent ownership and consistent expectations across their enterprise and partnerships.

Topics: cybersecurity

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More and more emphasis is being put on cybersecurity by companies of all sizes. Whether it’s the news headlines of notable IT incidents, greater emphasis on the value of data, or the monetization of certain types of attacks, an increasing amount of energy and money is going towards security. Security has the attention of leadership and the board and it is not going away. One of the biggest risks to and vulnerabilities of any organization’s security continues to be its people. Innovative approaches and new technology can reduce risk but they still don’t prevent the damage that can be inflicted by an employee simply opening an attachment or following a link. This is more likely to happen than you may think.

Technology also doesn’t prepare a management team for how to handle the IT response, communication effort, and workforce management required during and after an event. Technology doesn’t lessen the operational impact that your organization will feel when, not if, you experience an event.

So let’s examine the human and operational side of cybersecurity. Below are three factors you should address to reduce risk and prepare your organization for an event:

  1. People: Create and maintain a vigilant workforce
    Ask yourself, “How prepared is our workforce when it comes to security threats and protecting our data? How likely would it be for one of our team members to click on a link or open an attachment that appear to be from our CFO? Would our team members look closely enough at the email address and notice that the organization name is different by one letter?”
     

    According to the 2016 Verizon Data Breach Report, 30% of phishing messages were opened by the target across all campaigns and 12% went on to click on the attachment or link.

    Phishing email attacks directed at your company through your team range from very obvious to extremely believable. Some attempts are sent widely and are looking for just one person to click, while others are extremely targeted and deliberate. In either case, it is vital that each employee takes enough time to realize that the email request is unusual. Perhaps there are strange typos in the request or it is odd the CFO is emailing while on vacation. That moment your employees take to pause and decide whether to click on the link/attachment could mean the difference between experiencing an event or not.

    So how do you create and cultivate this type of thought process in your workforce? Lots of education and awareness efforts. This goes beyond just an annual in-service training on HIPAA. It may include education sessions, emails with tips and tricks, posters describing the risk, and also exercises to test your workforce against phishing and security exploits. It also takes leadership embracing security as a strategic imperative and leading the organization to take it seriously. Once you have these efforts in place, you can create culture change to build and maintain an environment where an employee is not embarrassed to check with the CFO’s office to see if they really did send an email from Bora Bora.
  1. Plan: Implement a disaster recovery and incident response plan 
    Through the years, disaster recovery plans have been the usual response. Mostly, the emphasis has been on recovering data after a non-security IT event, often discussed in context of a fire, power loss, or hardware failure. Increasingly, cyber-attacks are creeping into the forefront of planning efforts. The challenge with cyber-events is that they are murkier to understand – and harder for leadership – to assist with.

    It’s easier to understand the concept of a fire destroying your server room and the plan entailing acquiring new equipment, recovering data from backup, restoring operations, having good downtime procedures, and communicating the restoration efforts along the way. What is much more challenging is if the event begins with a suspicion by employees, customers, or vendors who believe their data has been stolen without any conclusive information that your company is the originating point of the data loss. How do you take action if you know very little about the situation? What do you communicate if you are not sure what to say? It is this level of uncertainty that makes it so difficult. Do you have a plan in place for how to respond to an incident? Here are some questions to consider:
     
    1. How will we communicate internally with our staff about the incident?
    2. How will we communicate with our clients? Our patients? Our community?
    3. When should we call our insurance company? Our attorney?
    4. Is reception prepared to describe what is going on if someone visits our office?
    5. Do we have the technical expertise to diagnose the issue?
    6. Do we have set protocols in place for when to bring our systems off-line and are our downtime procedures ready to use?
    7. When the press gets wind of the situation, who will communicate with them and what will we share?
    8. If our telephone system and network is taken offline, how we will we communicate with our leadership team and workforce?

By starting to ask these questions, you can ascertain how ready you may, or may not be, for a cyber-attack when it comes.

  1. Practice: Prepare your team with table top exercises  
    Given the complexity and diversity of the threats people are encountering today, no single written plan can account for all of the possible combinations of cyber-attacks. A plan can give guidance, set communication protocols, and structure your approach to your response. But by conducting exercises against hypothetical situations, you can test your plan, identify weaknesses in the plan, and also provide your leadership team with insight and experience – before it counts.

    A table top exercise entails one team member (perhaps from IT or from an outside firm) coming up with a hypothetical situation and a series of facts and clues about the situation that are given to your leadership team over time. Your team then implements the existing plans to respond to the incident and make decisions. There are no right or wrong answers in this scenario. Rather, the goal is to practice the decision-making and response process to determine where improvements are needed.

    Maybe you run an exercise and realize that you have not communicated to your staff that no mention of the event should be shared by employees on social media. Maybe the exercise makes you realize that the network administrator who is on vacation at the time is the only one who knows how to log onto the firewall. You might identify specific gaps that are lacking in your cybersecurity coverage. There is much to learn that can help you prepare for the real thing.

As you know, there are many different threats and risks facing organizations. Some are from inside an organization while others come from outside. Simply throwing additional technology at the problem will not sufficiently address the risks. While your people continue to be one of the biggest threats, they can also be one of your biggest assets, in both preventing issues from occurring and then responding quickly and appropriately when they do. Remember focus on your People, Your Plan, and Your Practice.

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In light of the recent cyberattacks in higher education across the US, more and more institutions are finding themselves no longer immune to these activities. Security by obscurity is no longer an effective approach—all  institutions are potential targets. Colleges and universities must take action to ensure processes and documentation are in place to prepare for and respond appropriately to a potential cybersecurity incident.

What are some examples of incidents that managers need to prepare for?

Examples range from external breaches and insider threats to instances of malfeasance or incompetence. Different types of incidents lead to the same types of results—yet you can’t have a broad view of incidents. Managers should work with their teams to create incident response plans that reflect the threats associated with higher education institutions. A handful of general incident response plans isn’t going to cut it.

Managers need to work with their teams to develop a specific incident response plan for each specific type of incident. Why? Well, think of it this way: Your response to a careless employee should be different from your response to a malicious employee, for a whole host of legal reasons. Incident response is not a cookie-cutter process. In fact, it is quite the opposite. This is one of the reasons I highly suggest security teams include staff members outside of IT. When you’re responding to incidents, you want people who can look at a problem or situation from an external perspective, not just a technical or operational perspective within IT. These team members can help answer questions such as, what does the world see when they look at our institution? What institutional information might be valuable to, or targeted by, malicious actors? You’ll get some valuable fresh perspectives.

How short or long should the typical incident response plan be?

I often see good incident response plans no more than three or four pages in length. However, it is important that incident response plans are task oriented, so that it is clear who does what next. And when people follow an incident response plan, they should physically or digitally check off each activity, then record each activity.

What system or software do you recommend for recording incidents and responses?

There are all types of help desk software you can use, including free and open source software. I recommend using help desk software with workflow capabilities, so your team can assign and track tasks.

Any other tips for developing incident response plans?

First, managers should work with, and solicit feedback from across the academic and administrative areas within the institution when developing incident response plans. If you create these documents in a vacuum, they will be useless.

Second, managers and their teams should take their time and develop the most “solid” incident response plans possible. Don’t rush the process. The effectiveness of your incident response plans will be critical in assessing your institution’s ability to survive a breach. Because of this, you should be measuring your response plans through periodic testing, like conducting tabletop exercises.

Third, keep your students and external stakeholders in mind when developing these plans. You want to make sure external communications are consistent, accurate, and within the legal requirements for your institution. The last thing you want is students and stakeholders receiving conflicting messages about the incident. 

Are there any decent incident response plans in the public domain that managers and their teams can adapt for their own purposes?

Yes. My default reference is the National Institute of Standards and Technology (NIST). NIST has many special publications that describe the incident response process, how to develop a solid plan, and how to test your plan.

Should institutions have dedicated incident response teams?

Definitely. Institutions should identify and staff teams using internal resources. Some institutions may want to consider hiring a reputable third party to act as an incident response team. The key with hiring a third party? Don’t wait until an incident occurs! If you wait, you’re going to panic, and make panic-based decisions. Be proactive and hire a third party on retainer.

That said, institutions should consider hiring a third party on an annual basis to review incident response plans and processes. Why? Because every institution can grow complacent, and complacency kills. A third party can help gauge the strengths and weaknesses of your internal incident response teams, and provide suggestions for general or specific training. A third party can also educate your institution about the latest and greatest cyber threats.

Should managers empower their teams to conduct internal “hackathons” in order to test incident response?

Sure! It’s good practice, and it can be a lot of fun for team members. There are a few caveats. First, don’t call it a hackathon. The word can elicit negative or concerned reactions. Call it “active testing” or “continuous improvement exercises.” These activities allow team members to think creatively, and are opportunities for them to boost their cybersecurity knowledge. Second, be prepared for pushback. Some managers worry if team members gain more cybersecurity skills, then they’ll eventually leave the institution for another, higher-paying job. I think you should be committed to the growth of your team members―it’ll only make your institution more secure.

What are some best practices managers should follow when reporting incidents to their leadership?

Keep the update quick, brief, and to the point. Leave all the technical jargon out, and keep everything in an institutional context. This way leadership can grasp the ramifications of the event and understand what matters. Be prepared to outline how you’re responding and what actions leadership can take to support the incident response team and protect the institution. In the last chapter, I mentioned what I call the General Colin Powell method of reporting, and I suggest using that method when informing leadership. Tell them what you know, what you don’t know, what you think, and what you recommend. Have answers, or at least a plan.

How much institution-wide communication should there be about incidents?

That’s a great question, but a tough one to answer. Transparency is good, but it can also unintentionally lead to further incidents. Do you really want to let your whole institution know about an exploitable weakness? Also, employees can spread information about incidents on social media, which can actually lead to the spread of misinformation. If you are in doubt about whether or not to inform the entire institution about an incident, refer to your Legal Department. In general, institution-wide communication should be direct: We’ve had an incident; these are the facts; this is what you are allowed to say on social media; and this is what you’re not allowed to say on social media.

Another great but tough question: When do you tell the public about an incident? For this type of communication, you’re going to need buy-in from various sources: senior leadership, Legal, HR, and your PR team or external PR partners. You have to make sure the public messaging is consistent. Otherwise, citizens and the media will try to poke holes in your official story. And that can lead to even more issues.

What are the key takeaways for higher education leaders?

Here are key takeaways to help higher education leaders prepare for and respond appropriately to cybersecurity incidents:

  1. Understand your institution’s current cybersecurity environment. 
    Questions to consider: Do you have Chief Information Security Officer (CISO) and/or a dedicated cybersecurity team at your institution? Have you conducted the appropriate audits and assessments to understand your institution’s vulnerabilities and risks?
  2. Ensure you are prepared for cybersecurity incidents. 
    Questions to consider: Do you have a cybersecurity plan with the appropriate response, communication, and recovery plans/processes? Are you practicing your plan by walking through tabletop exercises? Do you have incident response teams?

Higher education continues to face growing threats of cybersecurity attacks – and it’s no longer a matter of if, but when. Leaders can help mitigate the risk to their institutions by proactively planning with incident response plans, communication plans, and table-top exercises. If you need help creating an incident response plan or wish to speak to us regarding preparing for cybersecurity threats, please reach out to us.
 

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Cyberattacks in higher education—How prepared are you?

Read this if you are an Institutional Research (IR) Director, a Registrar, or are in the C-Suite.

In my last blog, I defined the what and the why of data governance, and outlined the value of data governance in higher education environments. I also asserted data isn’t the problem―the real culprit is our handling of the data (or rather, our deferral of data responsibility to others).

While I remain convinced that data isn’t the problem, recent experiences in the field have confirmed the fact that data governance is problematic. So much, in fact, that I believe data governance defies a “solid,” point-in-time solution. Discouraged? Don’t be. Just recalibrate your expectations, and pursue an adaptive strategy.

This starts with developing data governance guiding principles, with three initial points to consider: 

  1. Key stakeholders should develop your institution’s guiding principles. The team should include representatives from areas such as the office of the Registrar, Human Resources, Institutional Research, and other significant producers and consumers of institutional data. 
  2. The focus of your guiding principles must be on the strategic outcomes your institution is trying to achieve, and the information needed for data-driven decision-making.
  3. Specific guiding principles will vary from institution to institution; effective data governance requires both structure and flexibility.

Here are some baseline principles your institution may want to adopt and modify to suit your particular needs.

  • Data governance entails iterative processes, attention to measures and metrics, and ongoing effort. The institution’s governance framework should be transparent, practical, and agile. This ensures that governance is seen as beneficial to data management and not an impediment.
  • Governance is an enabler. The institution’s work should help accomplish objectives and solve problems aligned with strategic priorities.
  • Work with the big picture in mind. Start from the vantage point that data is an institutional asset. Without an institutional asset mentality it’s difficult to break down the silos that make data valuable to the organization.
  • The institution should identify data trustees and stewards that will lead the data governance efforts at your institution
    • Data trustees should have responsibility over data, and have the highest level of responsibility for custodianship of data.
    • Data stewards should act on behalf of data trustees, and be accountable for managing and maintaining data.
  • Data quality needs to be baked into the governance process. The institution should build data quality into every step of capture and entry. This will increase user confidence that there is data integrity. The institution should develop working agreements for sharing and accessing data across organizational lines. The institution should strive for processes and documentation that is consistent, manageable, and effective. This helps projects run smoothly, with consistent results every time.
  • The institution should pay attention to building security into the data usage cycle. An institution’s security measures and practices need to be inherent in the day-to-day management of data, and balanced with the working agreements mentioned above. This keeps data secure and protected for the entire organization.
  •  Agreed upon rules and guidelines should be developed to support a data governance structure and decision-making. The institution should define and use pragmatic approaches and practical plans that reward sustainability and collaboration, building a successful roadmap for the future. 

Next Steps

Are you curious about additional guiding principles? Contact me. In the meantime, keep your eyes peeled for a future blog that digs deeper into the roles of data trustees and stewards.
 

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Focus on the people: How higher ed institutions can successfully make an ERP system change

The enterprise resource planning (ERP) system is the heart of an institution’s business, maintaining all aspects of day-to-day operations, from student registration to staff payroll. Many institutions have used the same ERP systems for decades and face challenges to meet the changing demands of staff and students. As new ERP vendors enter the marketplace with new features and functionality, institutions are considering a change. Some things to consider:

  1. Don’t just focus on the technology and make change management an afterthought. Transitioning to a new ERP system takes considerable effort, and has the potential to go horribly wrong if sponsorship, good planning, and communication channels are not in place. The new technology is the easy part of a transition—the primary challenge is often rooted in people’s natural resistance to change.  
  2. Overcoming resistance to change requires a thoughtful and intentional approach that focuses on change at the individual level. Understanding this helps leadership focus their attention and energy to best raise awareness and desire for the change.
  3. One effective tool that provides a good framework for successful change is the Prosci ADKAR® model. This framework has five distinct phases that align with ERP change:

These phases provide an approach for developing activities for change management, preparing leadership to lead and sponsor change and supporting employees through the implementation of the change.

The three essential steps to leveraging this framework:

  1. Perform a baseline assessment to establish an understanding of how ready the organization is for an ERP change
  2. Provide sponsorship, training, and communication to drive employee adoption
  3. Prepare and support activities to implement, celebrate, and sustain participation throughout the ERP transition

Following this approach with a change management framework such as the Prosci ADKAR® model can help an organization prepare, guide, and adopt ERP change more easily and successfully. 

If you’re considering a change, but need to prepare your institution for a healthy ERP transition using change management, chart yourself on this ADKAR framework—what is your organization’s change readiness? Do you have appropriate buy-in? What problems will you face?

You now know that this framework can help your changes stick, and have an idea of where you might face resistance. We’re certified Prosci ADKAR® practitioners and have experience guiding Higher Ed leaders like you through these steps. Get in touch—we’re happy to help and have the experience and training to back it up. Please contact the team with any questions you may have.

1Prosci ADKAR®from http://www.prosci.com

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Perspectives of an Ex-CIO

“The world is one big data problem,” says MIT scientist and visionary Andrew McAfee.

That’s a daunting (though hardly surprising) quote for many in data-rich sectors, including higher education. Yet blaming data is like blaming air for a malfunctioning wind turbine. Data is a valuable asset that can make your institution move.

To many of us, however, data remains a four-letter word. The real culprit behind the perceived data problem is our handling and perception of data and the role it can play in our success—that is, the relegating of data to a select, responsible few, who are usually separated into hardened silos. For example, a common assumption in higher education is that the IT team can handle it. Not so. Data needs to be viewed as an institutional asset, consumed by many and used by the institution for the strategic purposes of student success, scholarship, and more.

The first step in addressing your “big” data problem? Data governance.

What is data governance?

There are various definitions, but the one we use with our clients is “the ongoing and evolutionary process driven by leaders to establish principles, policies, business rules, and metrics for data sharing.”

Please note that the phrase “IT” does not appear anywhere in this definition.

Why is data governance necessary? For many reasons, including:

  1. Data governance enables analytics. Without data governance, it’s difficult to gain value from analytics initiatives which will produce inconsistent results. A critical first step in any data analytics initiative is to make sure that definitions are widely accepted and standards have been established. This step allows decision makers to have confidence in the data being analyzed to describe, predict, and improve operations.
     
  2. Data governance strengthens privacy, security, and compliance. Compliance requirements for both public and private institutions constantly evolve. The more data-reliant your world becomes, the more protected your data needs to be. If an organization does not implement security practices as part of its data governance framework, it becomes easier to fall out of compliance. 
     
  3. Data governance supports agility. How many times have reports for basic information (part-time faculty or student FTEs per semester, for example) been requested, reviewed, and returned for further clarification or correction? And that’s just within your department! Now add multiple requests from the perspective of different departments, and you’re surely going through multiple iterations to create that report. That takes time and effort. By strengthening your data governance framework, you can streamline reporting processes by increasing the level of trust you have in the information you are seeking. Understanding the value of data governance is the easy part/ The real trick is implementing a sustainable data governance framework that recognizes that data is an institutional asset and not just a four-letter word.

Stay tuned for part two of this blog series: The how of data governance in higher education. In the meantime, reach out to me if you would like to discuss additional data governance benefits for your institution.

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Data is a four-letter word. Governance is not.

Best Practices for Educating Your Financial Institution’s Board of Directors on Cybersecurity

According to Cybersecurity Ventures, cybercrime will account for $6 trillion annually by 2021—that’s more than the global trade of all major illegal drugs combined. Data breaches and other information security events adversely impact organizations through significant losses in revenue, erosion of customer trust, substantial remediation costs, increased insurance premiums, and more.

The financial services industry has always led the way with internal controls, vendor management, and now with cybersecurity for one simple reason—you are in the business of money and it is critical to protect it.

That said, cybersecurity controls require more than just a strong IT department—an effective cybersecurity program, much like ethical behavior, depends on culture. Since your organization’s leadership plays a key role in driving your cybersecurity culture, boards of directors and senior management need a solid understanding of cybersecurity risks and impacts.

According to a 2018 Technology Survey of bank directors by Bank Director, 79% say they need to enhance their level of technology expertise. Many board members come from non-technology backgrounds and careers, and though they are able to support their institution’s mission and drive growth, they may not be able to provide direction in the areas of information technology and security. They may also not recognize what attractive targets they make for phishing and other cybercrimes due to their high level of access to valuable information, their ability to send and receive data from financial institution personnel, and their potential exemption from certain employee policies.

Keeping board members up-to-date on the evolving landscape of cybersecurity risks can present a serious challenge due to board members’ time constraints. To help, here are some best practices you can follow to make educating your institution’s board and senior management a relatively simple and sustainable process.

Leverage Existing Cybersecurity Training Resources

In most cases, you already provide and require cybersecurity training for employees, typically through internal IT experts, third-party vendors, or self-paced courses available online. Board members should complete the same training at least annually.

Require Board Members to Comply with Information Security Policies

Despite their high-risk profile, board members are often exempted from policies applicable to employees, including password requirements and other critical information security policies. Given the sensitive information and levels of access board members have, it is imperative that they fully comply with all information security policies.

Facilitate Regular Review of Information Security Audits and Assessments

Information security audits and assessments provide valuable insights into areas for improvement. Keep your board members aware of any findings, recommendations, or potential risks noted in recent audits and assessments. Provide a regular status report to the board of ongoing efforts and progress to resolve or mitigate findings and risks. Use these regular communications as an opportunity to provide cybersecurity education to the board, and don’t hesitate to speak up about any specific areas and emerging risks you may be concerned about.

Regular Cybersecurity Updates and Discussions

Keep the board and senior management updated on cybersecurity threats, incidents, and any changes to the bank’s cybersecurity program. Provide this information on a quarterly basis and include the cause of and any remediation for such events, as well as any trends in incidents. Regular updates to the board and senior management provide guidance for budgets, goals, and overall strategic direction. With more awareness of security incidents and events, trends in occurrences, and potential risks, the board and senior management are more likely to support greater investments in the bank’s security efforts.

Annual Board Approval of Information Security Plans and Policies

The board should review and approve all information security policies and relevant procedures on an annual basis, as these board-approved policies will establish the financial institution’s directive for effective internal control and cybersecurity programs. Important examples include Information Security and Acceptable Use Policies, Cybersecurity Policy, Incident Response Plan, Business Continuity Plan, and Disaster Recovery Plan.

Knowing your current position and having a plan are key. Through continuous assessment of your board’s fluency with cybersecurity and establishing a process of ongoing education that’s both effective and manageable, your financial institution can improve its culture of cybersecurity awareness—helping reduce the likelihood of future security incidents and events that could adversely impact your board, your financial institution’s employees, and your customers.

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Creating a culture of cybersecurity awareness

As a new year is upon us, many people think about “out with the old and in with the new”. For those of us who think about technology, and in particular, blockchain technology, the new year brings with it the realization that blockchain is here to stay (at least in some form). Therefore, higher education leaders need to familiarize themselves with some of the technology’s possible uses, even if they don’t need to grasp the day-to-day operational requirements. Here’s a high-level perspective of blockchain to help you answer some basic questions.

Are blockchain and bitcoin interchangeable terms?

No they aren’t. Bitcoin is an electronic currency that uses blockchain technology, (first developed circa 2008 to record bitcoin transactions). Since 2008, many companies and organizations utilize blockchain technology for a multitude of purposes.

What is a blockchain?

In its simplest terms, a blockchain is a decentralized, digital list (“chain”) of timestamped records (“blocks”) that are connected, secured by cryptography, and updated by participant consensus.

What is cryptography?

Cryptography refers to converting unencrypted information into encrypted information—and vice versa—to both protect data and authenticate users.

What are the pros of using blockchain?

Because blockchain technology is inherently decentralized, you can reduce the need for “middleman” entities (e.g., financial institutions or student clearinghouses). This, in turn, can lower transactional costs and other expenses, and cybersecurity risks—as hackers often like to target large, info-rich, centralized databases.

Decentralization removes central points of failure. In addition, blockchain transactions are generally more secure than other types of transactions, irreversible, and verifiable by the participants. These transaction qualities help prevent fraud, malware attacks, and other risks and issues prevalent today.

What are the cons of using blockchain technology?

Each blockchain transaction requires signature verification and processing, which can be resource-intensive. Furthermore, blockchain technology currently faces strong opposition from certain financial institutions for a variety of reasons. Finally, although blockchains offer a secure platform, they are not impervious to cyberattacks. Blockchain does not guarantee a hacker-proof environment.

How can blockchain benefit higher education institutions?

Blockchain technology can provide higher education institutions with a more secure way of making and recording financial transactions. You can use blockchains to verify and transfer academic credits and certifications, protect student personal identifiable information (PII) while simultaneously allowing students to access and transport their PII, decentralize academic content, and customize learning experiences. At its core, blockchain provides a fresh alternative to traditional methods of identity verification, an ongoing challenge for higher education administration.

As blockchain becomes less of a buzzword and begins to expand beyond the realm of digital currency, colleges and universities need to consider it for common challenges such as identity management, application processing, and student credentialing. If you’d like to discuss the potential benefits blockchain technology provides, please contact me.

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Higher education and blockchain 101: It's not just for bitcoin anymore

The late science fiction writer (and college professor) Isaac Asimov once said: “I do not fear computers. I fear the lack of them.” Had Asimov worked in higher ed IT management, he might have added: “but above all else, I fear the lack of computer staff.”

Indeed, it can be a challenge for higher education institutions to recruit and retain IT professionals. Private companies often pay more in a good economy, and in certain areas of the nation, open IT positions at colleges and universities outnumber available, qualified IT workers. According to one study from 2016, almost half of higher education IT workers are at risk of leaving the institutions they serve, largely for better opportunities and more supportive workplaces. Understandably, IT leadership fears an uncertain future of vacant roles—yet there are simple tactics that can help you improve the chances of filling open positions.

Emphasize the whole package

You need to leverage your institution’s strengths when recruiting IT talent. A focus on innovation, project leadership, and responsibility for supporting the mission of the institution are important attributes to promote when recruiting. Your institution should sell quality of life, which can be much more attractive than corporate culture. Many candidates are attracted to the energy and activity of college campuses, in addition to the numerous social and recreational outlets colleges provide.

Benefit packages are another strong asset for recruiting top talent. Schools need to ensure potential candidates know the amount of paid leave, retirement, and educational assistance for employees and employee family members. These added perks will pique the interest of many candidates who might otherwise have only looked at salary during the process.

Use the right job title

Some current school vacancies have very specific job titles, such as “Portal Administrator” or “Learning Multimedia Developer.” However, this specificity can limit visibility on popular job posting sites, reducing the number of qualified applicants. Job titles, such as “Web Developer” and “Java Developer,” can yield better search results. Furthermore, some current vacancies include a number or level after the job title (e.g., “System Administrator 2”), which also limits visibility on these sites. By removing these indicators, you can significantly increase the applicant pool.

Focus on service, not just technology

Each year, institutions deploy an increasing number of Software as a Service (SaaS) and hosted applications. As higher education institutions invest more in these applications, they need fewer personnel for day-to-day technology maintenance support. In turn, this allows IT organizations to focus limited resources on services that identify and analyze technology solutions, provide guidance to optimize technology investments, and manage vendor relationships. IT staff with soft skills will become even more valuable to your institution as they engage in more people- and process-centric efforts.

Fill in the future

It may seem like science fiction, but by revising your recruiting and retention tactics, your higher education institution can improve its chances of filling IT positions in a competitive job market. In a future blog, I’ll provide ideas for cultivating staff from your institution via student workers and upcoming graduates. If you’d like to discuss additional staffing tactics, send me an email.

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No science fiction: Tactics for recruiting and retaining higher education IT positions