What the Securities and Exchange Commission (SEC) Division of Corporate Finance and Investment Management Staff thinks of the Year 2000 (Y2K) problem may help you convince your management to take this matter seriously. Staff Legal Bulletins generally foreshadow the future rulings of the agency. If your organization has an external audit firm that opines on the financial statements of your enterprise, then it should already have advised your senior management on this matter. The accounting implications, however, may not lead management to a greater understanding of the security issues. Financial audits may not require an understanding of your access control environment — at least not in depth. You may then face several challenges: • Access control software (system, network, and application layers) may have Y2K issues. • Audit logs and historical records on which you rely for incident investigations may have Y2K issues (and some of the measures used to correct the first bullet may cause the new logs to be incompatible with your historical logs making reconstruction difficult; in some cases, the new product deletes, and even overwrites, old log files). • The process followed for correcting Y2K issues may bypass controls because time is short. This surrender to expedience opens a host of opportunities for abuse. Regaining control in the year 2000 may pose its own challenges. • What will either be, or appear to be, Y2K-related failures will provide a smokescreen for unauthorized activities. • Heavy reliance on outside consultants, contractors, outsourcers, and vendors of replacement or upgraded products will further burden your security administrators. Administrators will face increased user-identifier maintenance, resource access rules changes, and possibly, architectural changes affecting the security products themselves. Few organizations have properly budgeted for additional help here.
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