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An analysis of IT policy transformation


An analysis of IT policy transformation

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The aim of this project is to evaluate the effectiveness of information security policy in the context of an organization, OSI Systems, Inc. With presence in Africa, Australia, Canada, England, Malaysia and the United States, OSI Systems, Inc. is a worldwide company based in California that develops and markets security and inspection systems such as airport security X-ray machines and metal detectors, medical monitoring anesthesia systems, and optoelectronic devices. The company is also represented by three subsidiary divisions in offices and plants dedicated to the brands, Rapiscan Systems, OSI Optoelectronics and SpaceLabs Healthcare.

In 2010, OSI, Inc. had sales of $595 million with net income of over $25 million. As of June 2010, the company was comprised of 2,460 personnel globally. The parent company provides oversight and fiscal control to the different divisions, and is connected through its virtual network world-wide intranet system; with external integration of other stakeholders involved in the channel of operations, mostly represented by third party vendors whom are connected to the company’s extranet. Key stakeholders involved in IT security decision and job responsibilities at OSI, Inc. are outlined in Table 1.

Table 1

3 Definitions

3.1 CIO — Chief Information Officer

3.2 VPN — Virtual Private Network which is used to connect to internal networks while outside of corporate locations or on wireless networks

3.3 IT Management Team — The CIO, Global Directors, and Global Managers in the IT department

3.4 Company — Refers to OSI Systems, Inc. And all subsidiaries

Table 1. OSI, Inc. IT Security Policy provision definitions of key stakeholders (2009).

In 2011, OSI, Inc. will implement changes to its IT security policies. Those changes are largely in response to national articulations in computer misuse laws. This especially pertains to extensive statutory provisions within UK employer related policy on internet privacy and propriety commercial information as will be discussed in review of the nation’s Computer Misuse Law (CMA), put into effect in 1990 with revision in accordance with technological innovation in 2006. Related legislation in the United States on telecommunications and internet use, and in accordance with post 9/11 provisions on web-based privacy infringement in part to anti-terrorist legislation on IT infrastructure, OSI, Inc. will improve its competency as a technology organization through heightened policy posture.

As with other global organizations, OSI, Inc. is constantly seeking solutions to its vulnerabilities to both internal and external forces of competition. For this reason, security policy amendments are strategic priorities: 1) Corporate and IT Organizational structure including rules and resources with respect to information security; 2) Stakeholders (users, managers, and designers) interacting with information security; 3) Security technology (technical platform); 4) Tasks associated with information security (goals and deliverables); 5) Information Security risks. Formidable to those actionable goals, is the vision of CIO, John Loo’s administrative oversight of the corporation’s IT informatics network. In an interview with Mr. Loo, I redeemed important insights into the transition of OSI, Inc. In this unit of business operations, illustrated in Table 2.

Table 2


IT Director, John Loo

1. Do you have a full Contingency plan (CP) in effect composed of BIA (Business Impact Analysis) included in this are an Incident Response (IR), Disaster Recovery (DR) Plan and a Business Continuity (BP) plan? Do you have a Security Incident Response Team (SIRT) as well?

JL: was that he did not have a not have such a large encompassing plan due to the relative smallness of the company as compared to a General Electric or IBM. In fact many contend that this type of security philosophy is penny wise and foolish (Whitman & Mattord, 2010. 171). He said he had just a Disaster recovery plan which did not include an SIRT team.

He said that he does not have a list of personnel that he calls from but basis his team on the immediate threat at hand. In the event of a vulnerability attack on the network, Mr. Loo would base the severity of the attack and that he himself would determine if it was just an incident or a major disaster. From there he would then determine the extra personnel that would be needed to take care of the threat. Again, no security team list is in place.

2. Do you classify, profile and describe any of the potential threats, vulnerabilities, and attacks, such denial-of-service, zombie attacks, etc., with a before, during, and after response description so that if any of these threats appear, you would have an adequate response against them?

JL: he did not put together such a listing profile because of the enormity and sheer number of different threats and vulnerabilities and the small size of his company. Mr. Loo also indicated that his primary fear or concern for security was simply having someone walk into an OSI facility, plant or office and plug their laptop into the network and be able to hack or password into the network and interrupt or steal company data.

3. If you Mr. Loo get sick, injured or die, who will follow into your place during an emergency?

JL: he has back-up managerial personnel from Global IT and Telecom management to fill-in in the case he is absent.

4. Do you do practice or test any vulnerability attack scenarios, such as a simple desk check, structured walk-through, simulation, or full-interruption scenario, so that you know what to expect and do in a real-life situation?

JL: indicated that he does not do any testing at all. It is all in his head.

5. Concerning a natural disaster within the business continuity and strategy plan, do you have a disaster recovery in place in case of a man-made or natural disaster that would destroy the corporate data center and it’s data?

JL: he does have a back-up – a warm back-up site facility in Issaquah Washington. It is not a hot site where the company can immediately turn things on and start operating. Although all of the applications are loaded in the servers, the back-up data tapes and disks are stored in Burbank, CA and that they would have to be carried and sent over to Issaquah and then loaded into the databases and tested before operation can begin. That would take anywhere from 10 hours to 2 days for completion. If the situation was not totally disabling, he would just send the disks and tapes to the Torrance California facility and restore the servers from there. That would take less than a day.

6. Are all of the third party vendors that do business with the company on-board with back-up computing resources and services if needed?

JL: indicated that he has agreements with all the vendors during an emergency or disaster but that he does not contact them frequently if at all and that he assumes that the facilities are on board with any disaster that may happen. This non-action can be very dangerous.

7. Concerning crisis management and the press, how would you handle it?

JL: he will be the main point of contact for the CEO and for newspaper and TV announcements to let the public know the situation of the disaster.

8. Since OSI has a risk assessment department, are they involved at all in the assessment of a disaster to the company?

JL: they were not involved in this area and that all planning and assessment was done in IT.

9. What is the relationship between the organizational structure of the IT department and its relationship with the CEO, as stipulated in the organizational hierarchy chart?

JL: indicated that although there is no Chief Information Security Officer (CISO) between him and the CIO, the CIO is firmly committed to obtaining the resources and expenses for fully implementing proper security within the company. Unfortunately, the CIO himself does not directly report to the CEO but to the non-technical CFO Mr. Edick and that sometimes it is very difficult to obtain additional money and resources to fully implement all of Global ITs plans for security since the company has never had an IT or security in a real emergency before.

Although it is quite common and natural for many companies, both small and large to place their security department or group within the IT organizational structure, this is not the best place for it. Given the seriousness for destructiveness due to loss data and networks, many organizations place their security group either within Legal or Insurance and Risk Management departments. Since OSI is small it is just within the IT department. Another factor is that the CIO and CEO are brothers and that can provide for a conflict of interest. This is why the CIO does not report directly to the CEO. This conflict imperils information security. Most experts agree that the CIO or CISO should report directly to the COO or President of the company. In case they do not.

10. What are the duties and responsibilities of the individual stakeholders (users, managers, designers, and vendors) interacting with information security and that of Critical Electronic Data?

JL: See the Critical Electronic Data Policy attachment.

What is OSI’s Global IT Security policy?

JL: Document

Do you provide for advanced IT and security training for your IT employees?

JL: Yes, we have extensive online and conventional training courses for our employees, including information security.

Are stakeholders (users, managers, and designers) interacting with information security?

JL: indicated that Business unit managers are responsible for enforcing IT security policy and that individual users are also responsible for the following IT policy concerning user accounts and proper use of the computer.

Is the policy part of an internal risk management protocol?

JL: As far as risk management is concerned and even though the company

As defined by the U.S. General Accounting Office, a stakeholder is “an individual or group with an interest in the success of an organization in delivering intended results and maintaining the viability of the organization’s products and services. Stakeholders influence programs, products, and services.” (Allen, 2005)

Information security planning should include the views of stakeholders, especially when you are planning for information security projects. The stakeholders buy-in is key to the success of information security in an organization. With the company’s success in mind, decisions are less likely to be made based on personal beliefs when stakeholders views are considered.

Table 2. Interview with OSI, Inc. IT Director, John Loo (2009).

OSI, Inc.’s general provisions mentioned in discussion with Mr. Loo are described in the Global IT Policy first three articles cited in Table 3.

Table 3

1. Purpose

The Global IT Policy establishes the authority of the Information Technology (“IT”) department regarding IT development, maintenance, purchase and distribution within all OSI Systems Companies. The IT department mission is to safeguard and enhance the confidentiality, integrity, and availability of IT systems while meeting business needs.

2. Scope

This policy applies to all OSI Systems Company corporate IT systems to include, hardware, software, networks and services.

3. Responsibility

3.1 It is the responsibility of the CIO to approve this document.

3.2 It is the primary responsibility of the IT department to ensure this Policy is adhered to by the Company.

3.3 It is the responsibility of the OSI Systems Company business unit management to ensure this policy is adhered to by the business unit.

Table 3. Global IT Policy, OSI, Inc. (2009).

Enforcement of new security provision to the Global IT Policy is part of the scope of Mr. Loo’s responsibility in strategic planning of system wide upgrades and risk management. Universal consideration of interface with employees is addressed in the interpretation of human user elements through mapping technologies. There is also the business development aspect of integrated systems as a mechanism for achieving higher productivity- cost, efficiency-cost, and competitive edge by way of streamlined logistics and reduced time to market. Loo’s role in this process is critical, as IT directives will address each department within each division and forge a viable plan for implementation.

This includes appropriate software applications (SAP) within the various architectural nodes in the flow of information supporting the company’s channel operations, and management of those processes on the back end once aligned, will mean change strategies for administration of new factors into the processes of the respective areas of the business. In addition to the IT Department, OSI, Inc. administrative structure involves departmental capacity in Finance, Human Resources, Internal Audit, Legal and Travel. Incremental in approach, the strategic development of OSI, Inc. IT security program is reliant upon consecutive changes to Company IT Policy, interpreted as the framework to decision on the project.

At present, each main corporate office and facility plant has as its information technology security framework which consists of a combination of dual firewalls with appropriate DMZ zones within the firewall routers for outside user access; along with numerous intrusion detection and protection hardware and software. OSI uses dual T1 lines for interconnection among its corporate entities. The companywide system is also secured with advanced virus protection and encryption technologies to ensure safe operation in applications, and transfer of data. OSI, Inc. current IT Security Policy offers guidelines to its IT program, and internal personnel user policy, and reference to the Company’s external stakeholders. The Purpose and Responsibility framework to the existing security policy is cited in Table 4.

Table 4

1 Purpose

1.1 This policy statement clarifies the responsibilities of information technology (“IT”) users and the steps they must take to help protect OSI Systems Company information and IT

1.2 Every worker at an OSI Systems Company must comply with the information security policies. This policy applies to all computer systems, networks and network devices, operating systems, and applications owned by or administered by an OSI Systems Company

2 Responsibility

2.1 It is the responsibility of the CIO to approve this document

2.2 It is the responsibility of the IT management team to ensure this document is adhered to Table 4. OSI, Inc. IT Security Policy (2009).

As systems architectures are designed for deeper integration in and between firms, optimization of security now means standardization like never before. Legacy systems which were the ‘standard’ in unique taxonomies are increasingly becoming a thing of the past as IT engineers base researched recommendations on the capacity of standardization to mitigate most effectively against risk. Combined technical and managerial security controls ensure integrity of information security policy.

To this end, companies also benefit from ‘universal’ models of IT policy, as global organizations seek competency in law and application to accommodate both statutory provisions, and real user applications. Policy is first and foremost an outline to protocol for, and a value added to control aspects in an organization. A legally binding contract between an organization and its stakeholders, internal policy that follows computer misuse laws, and implicates employees and other users into a relationship of agreement to designated access, evaluation of existing policies and their effectiveness at OSI, Inc. incorporates a four (4) point criteria index, illustrated in Table 5.

Table 5

1. Security technology

It involves different types of tools, methods, hardware and software platforms utilized to maintain security of a system

2. Security tasks

It signifies expected outcomes in terms of goals and deliverables

3. Security Structure

It involves systems of communication, authority and workflow related to information security

4. Stakeholders

These include organizational members including users, managers, developers and designers interacting with information security

Table 5 OSI, Inc. IT Security Policy four (4) point criteria index (2009).

Respective to incremental changes over time within IT systems management, one component in either policy or the network system itself will have an effect on other aspects of the program. Programmatic issues pertinent to the transformation of OSI, Inc. IT Policy will involve evaluation of problems occurring in the actual system where there may be: 1) misalignment between people and security technology; 2) the conflict and disparity between the implemented security technologies and the existing structure; and 3) fit of security technology to task. Knowledge of glitches within an IT network enables informed analysis of laws, and applicable protocol in alignment of policy with the actual security structure proposed as part of the organization’s global IT strategy.

Articulation to the current OSI, Inc. Global IT Security provision where security posture on employee authorized access and intrusion is outlined is discussed extensively in Section 4 (4.1-4.16) of the Policy, and circumscribes general accountability to those terms in 4.4, which states that “users are responsible for familiarizing themselves with and complying with all OSI Systems Company policies, procedures, and standards dealing with information security” (Appendix A). Where changes to the policy provision will be sought by OSI, Inc. In response to national legislation on computer misuse, the definition of quite a few of the articles within Section 4 may be altered to encompass the international scope of the Company’s position on misconduct. Clauses within the OSI, Inc. Global IT Security Policy are important in respect to organizational practice where the CMA and PJA 2006 are in effect at the Company’s UK locations, for example. Article 4.23 indicates,

” Users must not test or attempt to compromise computer or communication system security measures unless specifically approved in advance and in writing by the director of the Internal Audit department. Incidents involving unapproved system hacking, password guessing file decryption, bootleg software copying, or similar unauthorized attempts to compromise security measures may be unlawful, and will be considered serious violations of OSI Systems internal policy” (OSI, Inc., 2010).

The UK CMA and the subsequent Police and Justice Act (PJA) of 2006 make use of court rulings on employer-employee contractual relations, and access to secure information. In the case of R. v Bow Street Magistrates Court and Allison (AP) Ex-parte Government of the United States of America (Allison) [2002]2 AC 216, the House of Lords addresses ‘unauthorised access’ in cases where an employee could commit an offense by securing access to a computer contrary to section 1 CMA. In the case precedent, it was held that the employee’s misconduct had indeed come under UK provisions to section 1 CMA, substantiating alleged intent, and cause in fact related to data retrieval through unauthorized access. If this singular instance in national law in the UK is representative of the current within policy developments in the IT sector, OSI, Inc.’s John Loo still has much work ahead.


4. Policy

4.1 The Global IT organization is responsible for establishing and maintaining organization-wide information security policies, standards, guidelines, and procedures. Compliance checking to ensure that organizational units are operating in a manner consistent with these requirements is the responsibility of the Global IT Internal Audit department. Investigations of system intrusions and other information security incidents are the responsibility of the Global IT Infrastructure department. Disciplinary matters resulting from violations of information security requirements are handled by local business unit managers working in conjunction with the Human Resources department.

4.2 Production applications are computer programs that regularly provide reports in support of decision making and other business activities. All production application system information must have a designated owner — a manager or management delegate responsible for the acquisition, development, and maintenance of production applications that process OSI Systems Company information (“Owner”). For each type of information, owners designate the relevant sensitivity classification, designate the appropriate level of criticality, define which users will be granted access, and approve requests for various ways in which the information will be utilized.

4.3 Persons who possess OSI Systems Company information are responsible for safeguarding the information including implementing access control systems to prevent inappropriate disclosure, and making backups so that critical information will not be lost (“Custodian”). Custodians are also required to implement, operate, and maintain the security measures defined by information Owners.

4.4 Users are responsible for familiarizing themselves with and complying with all OSI Systems Company policies, procedures, and standards dealing with information security.

4.5 OSI Systems Company information must be protected in a manner commensurate with its sensitivity and criticality. Security measures must be employed regardless of the media on which information is stored, the systems that process it, or the methods by which it is moved.

4.6 OSI Systems requires that each user accessing information systems and applications have a unique user ID and a private password. These user Ids must be employed to restrict system privileges based on job duties, project responsibilities, and other business activities. Each user is personally responsible for the usage of his or her user ID and password. Passwords will be considered critical and follow the Password Policy.

4.7 Unless it has specifically been designated as public, all OSI Systems Company internal information must be protected from disclosure to third parties. Third parties may be given access to OSI Systems Company internal information only when a demonstrable need to know exists, when a OSI Systems non-disclosure agreement has been signed, and when such a disclosure has been expressly authorized by the relevant OSI Systems information Owner.

4.8 If sensitive information is lost, is disclosed to unauthorized parties, or is suspected of being lost or disclosed to unauthorized parties, the information Owner and the Global IT department must be notified immediately.

4.9 Access to every office, computer server room, and other OSI Systems work area containing sensitive information shall be physically restricted to those people with a legitimate need for access.

4.10 All OSI Systems computers that store sensitive information and that are permanently or intermittently connected to internal computer networks must have a password-based access control system. Regardless of the network connections, all stand-alone computers handling sensitive information must also employ an approved password-based access control system.

4.11 Users working with all other types of computers must employ a password protected screen saver, so that after a period of no activity the screen will go blank until the correct password is again entered.

4.12 All in-bound session connections to OSI Systems Company computers from external networks must be protected via encryption and be approved by the Global IT Network team. Users with laptop or remote computers connected to OSI Systems Company networks are prohibited from leaving unattended network sessions turned-on while VPN connection software is enabled. When using OSI Systems Company computers, users must not leave those computers unattended at anytime without locking the screen with a password protected screen locker.

4.13 At management’s discretion, certain qualified workers can work at home. Permission to telecommute must be granted by each worker’s immediate supervisor. Continued permission to telecommute is dependent on continued compliance with a number of information security policies and standards. Additional information on remote access to company networks is available in the Remote Access Policy

4.14 All computer users must keep the current versions of approved virus screening software enabled on their computers. Users must not abort automatic software processes that update virus signatures. Virus screening software must be used to scan all software and data files coming from either third parties or other OSI Systems groups. This scanning must take place before new data files are opened and before new software is executed. Workers must not bypass or turn off the scanning processes that could prevent the transmission of computer viruses. If workers suspect infection by a computer virus, they must immediately stop using the involved computer and contact the IT Global Helpdesk. USB or any other external data drives used with the infected computer must not be used with any other computer until the virus has been successfully eradicated. The infected computer must also be immediately isolated from internal networks. Users must not attempt to eradicate viruses themselves. Qualified OSI Systems staff must complete this task in a manner that minimizes both data destruction and system downtime. Additional information on virus protection is available in the Anti- Virus Policy.

4.15 OSI Systems computers and networks must not run software that comes from sources other than other OSI Systems departments, knowledgeable and trusted user groups, well-known systems security authorities, or established computer, network, or commercial software vendors. Software downloaded from the internet, shareware, public domain software, and other software from untrusted sources must not be used unless it has been approved by the Information Technology department.

4.16 Owners must make appropriate arrangements with software vendors for additional licensed copies, if and when additional copies are needed for business activities. All software must be purchased through Global IT purchasing. 4.17 Users must not copy software provided by OSI Systems to any storage media, transfer such software to another computer, or disclose such software to outside parties without advance permission from the Global IT Department.

4.18 Laptop and desktop computer users must regularly back up the information on their personal computers that are not stored on a network drive or server. If you are deployed in the field and use a laptop your information on the location system is NOT backed up by the Global IT Department and should be considered at risk at all times. If you store information on your local computer you must back that data up periodically. This can be done by the use of USB thumb drives or CD or DVD recorders that are standard on all laptop computing devices. If you do not know how to backup your data then please contact the Global IT Helpdesk. Examples of local data would be information stored in My Documents, C: Drive, D: Drive and your Desktop. If you are a user of a desktop or are connected to the OSI Systems network you may also copy your information to a shared drive. Shared personal drives are also available on request. Approved shared drives are backed up periodically by the Global IT Department.

4.19 OSI Systems management reserves the right to monitor, inspect, or search at any time all OSI Systems information systems, local laws providing. This examination may take place with or without the consent, presence, or knowledge the involved user. Because OSI Systems computers and networks are provided for business purposes only, workers must have no expectation of privacy associated with the information they store in or send through these information systems. OSI Systems management retains the right to remove from its information systems any material it views as offensive or potentially illegal.

4.20 OSI Systems information systems are intended to be used for business purposes only. Personal use is permissible if the use does not consume resources that could otherwise be used for business purposes, does not interfere with worker productivity, and does not preempt any business activity. Use of OSI Systems information systems for chain letters, charitable solicitations, political campaign material, religious work, transmission of objectionable material, or any other non-business use is prohibited.

4.21 OSI Systems management reserves the right to revoke the system privileges of any user at any time. Conduct that interferes with the normal and proper operation of OSI Systems information systems, which adversely affects the ability of others to use these information systems, or that is harmful or offensive to others is not permitted.

4.22 Unless specifically authorized by the Global IT department, OSI Systems workers must not acquire, possess, trade, or use hardware or software tools that could be employed to evaluate or compromise information systems security or monitor computer or network activity. Examples of such tools include those that defeat software copy protection, discover secret passwords, identify security vulnerabilities, compromise network encryption or decrypt encrypted files.

4.23 Users must not test or attempt to compromise computer or communication system security measures unless specifically approved in advance and in writing by the director of the Internal Audit department. Incidents involving unapproved system hacking, password guessing file decryption, bootleg software copying, or similar unauthorized attempts to compromise security measures may be unlawful, and will be considered serious violations of OSI Systems internal policy.

4.24 All suspected policy violations, system intrusions, virus infestations, and other conditions that might jeopardize

OSI Systems Company information or OSI Systems information systems must be immediately reported to the Global IT Helpdesk.

4.25 Application level security will be managed by specific application security policies.

4.26 IT will apply user account and access procedures in connection with employee termination, new hire and transfer process.

OSI, Inc. Global IT Security Policy (2009).


Allen, J. (2005). Governing for Security: Project Stakeholders Interests. News at SEI. Retrieved on 5SEPT10 from

Computer Misuse Law, 2006. Parliament UK. Retrieved from:

Diver, S. (2006). Information Security Policy — A Development Guide for Large and Small Companies. SANS Institute InfoSec Reading Room. Retrieved on 30 Sept 10 from

Global IT Policy (2009) OSI, Inc.

Global IT Security Policy (2009). OSI, Inc.

Maiwald, Eric & Sieglein, William (2002). Security Planning and Disaster Recovery. New York, NY: McGraw-Hill Professional.

Police and Justice Act (c. 48) 2006. Office of Public Sector Information (OPSI). Retrieved from:

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