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Risk is Agencywide, But What About Risk Management?

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Recent news that the Modernizing Government Technology Act has cleared the House Oversight and Government Reform Committee represents promise for federal transformation. But as agencies look to update their bloated stock of legacy infrastructure, their risk profiles will transform as well. All organizational levels, from the C suite to the mailroom, will be affected.

Among the areas most impacted by the digital evolution will be records and information management (RIM). Those who carry out the policies and practices of securing and managing information assets and their lifecycles will need to prepare for the risks.

The definition of a government record has evolved beyond paper records to encompass digital documents, emails, social media and even worker knowledge. However, the government has not yet adequately updated its overall risk framework to reflect this. The most telling evidence of this assertion is the 2015 data breach at the Office of Personnel Management.

In a recently released House Oversight and Government Reform Committee report on the OPM data breach, lawmakers stated that, “the longstanding failure of OPM’s leadership to implement basic cyber hygiene . . . represents a failure of culture and leadership, not technology.” So what can be done? Changing the entire culture of an agency is a daunting task that requires a significant amount of training and education. One of the report’s 13 recommendations was to “Improve Federal Recruitment, Training and Retention of Cyber Security Specialists.” While this recommendation is a step in the right direction, it does not do enough to address the core underlying causes of OPM’s (or any agency’s) cultural shortcomings.

Any agency attempting a cultural shift in information security and management must recognize that the problem is systemic, affecting every employee from top-tier leadership down to end-users. Although agency leadership, CIOs and cyber specialists obviously need to be well versed in their agency’s cyber capabilities and risks, improving these stores of specialized knowledge is not enough to guarantee an agencywide culture shift. That is because you can’t rely on education and training to simply trickle down throughout an organization—you need to also educate from the bottom up. This is especially true when it comes to protecting government records, because virtually every federal employee will create or handle government records as part of their job. Therefore, agencies that foster an understanding of records and risk will be in a much more secure position than agencies that keep their risk mitigation skills and knowledge siloed among top leadership.

This conclusion is corroborated by a recent survey conducted by Government Business Council, the research arm of Government Executive Media Group, which found that “while 16 percent consider risk management training of employees to be the greatest challenge, only 4 percent rank technical expertise as their agency’s top challenge in risk management. This finding may indicate that while departments have the specialized personnel to handle information risks, they are more concerned about the challenge of relaying this level of risk awareness to employees elsewhere in the organization.”

This is troubling information, as risk management is an agency- and governmentwide requirement and challenge. The understanding of what comprises a record is constantly evolving, and all agency employees need to understand when they are creating, or accessing, government records and the responsibilities that accompany those actions.

But what can agencies do to remedy the situation?

One core recommendation is to increase training for all agency employees. Although agencies do frequently offer training, especially internal training, they should be considering how increasing their offerings can help improve employees’ risk knowledge and confidence. If they do not already, agencies should consider a combination of in-office training, and professional external options from third-party experts. Agencies should also promote the knowledge and mentoring skills of experienced staff that already have a firm understanding of agency-specific risk requirements.

Importantly, agencies should establish and follow a comprehensive risk assessment framework. This is an operational self-assessment tool that provides records and information managers with the ability to diagnose their own performance against a set of given controls. This process enables an agency to proactively address any holes or issues negatively affecting their information management practices, as well as quantify and demonstrate compliance through a continuous, systematic approach.

Currently, only specialized segments of the government are prepared to deal with the next generation of information risks. As the definition of a government record continues to expand and evolve, most, if not all, agency employees will at some point be responsible for creating a government record. It is the responsibility of the agency to ensure that all employees are trained to deal with the risks associated with the creation of any record.

By increasing training and doing more to identify and involve experts within the organization, agencies can begin making more risk-aware decisions. That said, training is just one of several critical facets to creating a lasting cultural shift. To be prepared for the next generation requirements, agencies need to expand training in conjunction with other focused initiatives such as adhering to a formal risk framework, ensuring senior-level sponsorship, advancing technical expertise, as well as improving systems and processes. Ultimately, that is what the next generation of effective information management is going to require.

April Chen is the Senior Product Manager at Iron Mountain.

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