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« HIPAA: Advisory Workgroup Proposes PHI Security and Privacy Requirements Should Apply to All Organizations | Main | Information Security and Privacy Professionals Must Partner on Over 15 Different Enterprise Issues »

SOX Compliance: Fraudsters Posing as Officials Selling "Compliance Solutions;" *NO* vendor Product Can Make an Organization 100% Compliant With ANY Regulation

Something that has irritated me for a very long time are vendors who see a chance to make a quick buck off of worried organizations, afraid they are not going to be in compliance with new laws, and create junk products to sell to them using fear, uncertainty and doubt (FUD). FUD products.

I saw a lot of HIPAA FUD back when that regulation went into effect, and saw way too many people spending way too much money for so-called HIPAA security and privacy certifications offered by vendors who did not even have anyone on staff with any type of healthcare provider, payer or clearinghouse practitioner experience. Not to mention HIPAA compliance solutions.

On April 16, 2007, the Financial Accounting Standards Board (FASB) warned its constituents to on the alert for people and organizations falsely claiming to be members of the Financial Accounting Board staff and promoting the sale of Sarbanes-Oxley Act compliance materials.

"The Financial Accounting Foundation (FAF) has been informed that some of its constituents have been contacted by parties falsely claiming to be members of the Financial Accounting Standards Board staff and promoting the sale of certain Sarbanes Oxley compliance materials. The FAF has brought the matter to the attention of the U.S. Securities Exchange Commission and law enforcement and strongly urges constituents who are subjected to this scheme to contact their local authorities."

FASB operates under the oversight of the Financial Accounting Foundation (FAF), which is responsible for funding the activities of both FASB and its counterpart for state and local government, the Governmental Accounting Standards Board.

Folks, please beware of slick talking sales folks who promise you quick and easy, complete compliance, with their new and dandy automated technology solution. I've seen way too many products promise to make organizations 100% compliant with various, and sometimes all, laws and regulations just by installing it on a network and then sitting back and doing nothing else.

Legal and regulatory compliance generally requires a great amount human work...training, ongoing awareness, creating policies and procedures that are tailored for *YOUR* organization and not just cookie cutter statements that any organization can use, assessing risk within your organization, and so on. Yes, much compliance activity can be automated, but a significant amount must be done through thoughtful planning, analysis, and human interaction.

Don't let any vendor convince you that his or her product will make your organization 100% compliant with SOX, HIPAA, GLBA, or any other regulation; you would just be buying magic beans and snake oil if you believed the sales pitch.

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Rebecca Herold's Bio:

Rebecca Herold,CISSP, CIPP, CISM, CISA, FLMI, has been providing information security, privacy and regulatory assistance and services to organizations from a wide range of industries for over 18 years. Rebecca was instrumental in building the information security and privacy program while at Principal Financial Group, which was awarded the CSI Information Security Program of the Year Award in 1998. IT Security ranked Rebecca as one of the top 59 IT security influencers, and Computerworld put Rebecca their list of the 25 top privacy experts and on their list of the 9 best privacy consulting firms. Rebecca has been CPO for two consulting organizations, and has had her own information privacy, security and compliance business since 2004. Rebecca has written chapters for several books, dozens of articles, and has been writing a monthly privacy column for the CSI Alert newsletter since the beginning of 2001, and is working on her 11th book. Some of her other books include The Privacy Papers, Managing an Information Security and Privacy Awareness and Training Program, The Definitive Guide to Security Inside the Perimeter (Realtime Publishers), The Shortcut Guide to Improving IT Service Support through ITIL (Realtime Publishers), and The Practical Guide to HIPAA Privacy and Security Compliance. In addition, Rebecca is the leader of The Realtime IT Compliance Community where she posts to her IT Compliance weblog. You can contact Rebecca at: rebecca_herold@realtimepublishers.net.