Brrrr! A Winter Word Bank
Brrrrrr! Here’s an icy blast of words that will give your young writers a leg up when they’re crafting stories and poems about winter. Remember—using a word bank isn’t cheating! It’s simply another great tool to slip into your children’s tool belt of writing aids.
Try the activities below, and stay tuned for more winter writing ideas and prompts!
Winter Word Bank
winter, season, weather, December, January, February, scarf, hat, cap, beanie, mittens, gloves, sweater, jacket, coat, vest, shawl, leggings, boots, pajamas, robe, slippers, socks, booties, wool, fleece, heavy, wrap, bundle, blanket, comforter, quilt, patchwork, skiing, sledding, skating, jingle, shiver, chill, breath, snowstorm, blizzard, rain, sleet, snow, snowflakes, snow bank, snowball, powder, drift, crust, ice, icicles, crystals, frost, cold, bitter, windy, nippy, gusting, frozen, frigid, sparkling, slippery, icy, crunchy, lacy, delicate, soft, fluffy, knee-deep, powdery, freezing, melting, blustery, cloudy, dreary, drippy, slushy, rainy, snowman, shovel, bells, sled, sleigh, skis, ice skates, snowboard, toboggan, hill, mountain, pond, rink, forest, woods, creek, river, lane, road, holly, pine, cedar, fir, balsam, scent, boughs, wreath, trees, branches, bare, dark, silvery, blue, white, gray, brown, clear, piney, bird feeder, cardinal, suet, berries, hibernate, knit, sew, snuggle, read, book, stories, hearth, smoke, chimney, coals, flames, fire, fireplace, blazing, crackling, glowing, warm, cozy, toasty, spiced, spicy, tea, cider, cocoa, mug, popcorn, sugar, vanilla, spice, ginger, cinnamon, nutmeg, baking, aroma, waft
Word Bank Activities
Categories. Here’s a fun pre-writing activity! Copy the list of winter words to a Word document or Notepad. Then have your child copy/paste words into different categories. Alternatively, she can write the words by hand, crossing them off the list as she transfers them to her paper.
The older the child, the more detailed or specific the categories can be. This is not an exact science, so allow freedom and flexibility. Here are some ideas:
- Indoor winter words
- Outdoor winter words
- Activities and outdoor-fun words
- Weather words
- Clothing words
- Baking or food words
- Comfort words
- Warm and cozy words
- Cold words
- Other ____________________
Synonyms. Older students can add to their Winter Word Bank and build up their writing vocabulary by looking up some of the words in a thesaurus and adding a few interesting synonyms to the list. If you need a good thesaurus, I highly recommend The Synonym Finder. It’s my all-time fave!
DID YOU KNOW? The Winter Word Bank is now available as a full-color e-book download from WriteShop. In addition to organized, categorized winter word lists, the e-book contains over 100 printable vocabulary cards and ideas for using them to build writing skills. Only $2.50!
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Share a comment: What are five of your favorite or most descriptive winter words? Or, What new winter words would you like to add to this word bank?
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Development of information security systems. Changes to STO BR IBBS-1.0-2014 and personal data protection assessment
November 19, 2014
Dmitry Tretyakov , Andek Company
On June 1, 2014, a new edition of STO BR IBBS-1. 0-2014 was put into effect. The previous version of the Bank of Russia standard gave banks a number of significant advantages in terms of compliance with legal requirements in the field of personal data processing and protection. The question remained open whether these advantages were preserved in the new edition of STO BR IBBS-1.0-2014.
Since the introduction of the Standard of the Bank of Russia STO BR IBBS-1.0-2014 (hereinafter referred to as the Standard), enough time has passed for various reviews of changes to the new edition of the Standard to be published. The purpose of this article is to analyze the changes in STO BR IBBS-1.0-2014 from the point of view of the positive and negative aspects of the application of the Standard as a measure to comply with the requirements of legislation in the field of personal data.
IMPLEMENTATION No. 152-FZ THROUGH STO BR IBBS-1.0-2014
The “Letter of the Six” is still published on the official website of the Bank of Russia along with the new standard STO BR IBBS-1. 0-2014, however, the letter itself refers to the fourth edition of STO BR IBBS-1.0-2010, i.e. the letter is outdated. The question is — why publish it if it applies to previous editions of the Standard, which are officially cancelled? Perhaps because there is still no new letter, and the old letter has not been formally cancelled. But, one way or another, using the published letter for the same purposes with the new Standard will not work.
The only found reference to the application of the Standard as a tool for meeting the requirements of legislation in the field of personal data is the text of the Information Message of the Bank of Russia dated May 30, 2014, published in the Bulletin of the Bank of Russia No. 48-49 (1526-1527) dated May 30, 2014 year, which states that the documents of the BR IBBS Complex are recommended for the implementation of organizations of the banking system of the Russian Federation requirements of the legislation of the Russian Federation in the field of personal data .
Also in this issue, in Order of the Bank of Russia dated May 17, 2014 No. R-399, it is indicated that the documents of the BR IBBS Complex were to be sent “for review to the Federal Security Service of the Russian Federation, the Federal Service for Technical and Export Control, the Federal Service for Supervision of Communications, Information Technology and Mass Communications, the Association of Russian Banks and the Association of Regional Banks of Russia”. At the same time, neither Roskomnadzor, nor the FSTEC of Russia, nor the FSB of Russia, nor the Bank of Russia itself has yet published any information in open sources about the results of consideration of these documents.
Thus, as of today, RF BS organizations that have adopted the Standard must still comply with the direct requirements of personal data protection legislation set out in Order No. 21 of the Federal Service for Technical and Export Control dated 18 February 2013 “On Approval of the Composition and Content organizational and technical measures to ensure the security of personal data during their processing in personal data information systems” (hereinafter — Order of the FSTEC of Russia No. 21).
And also — in the Order of the Federal Security Service of Russia dated July 10, 2014 No. 378 “On approval of the Composition and content of organizational and technical measures to ensure the security of personal data when they are processed in personal data information systems using cryptographic information protection tools necessary to perform the requirements for the protection of personal data established by the Government of the Russian Federation for each of the levels of security «(Further — Order of the FSB No. 378).
Considering the above, the question arises as to whether it is appropriate for RF BS organizations to adopt the documents of the IBBS BR Complex as mandatory. Prior to the amendments to the legislation of the Russian Federation in the field of protection and processing of personal data, STO BR IBBS-1.0-2010 could be used as a measure to replace the requirements of regulators, but now, unfortunately, this possibility has disappeared.
ARGUMENTS TO PAY ATTENTION TO
The change in the Standard in clause 7. 11.4 deserves special attention, in which the Bank of Russia directly states: “Taking into account the specifics of processing and ensuring the security of personal data in RF BS organizations, the threat of personal data leakage through technical channels, as well as threats associated with the presence of undocumented (undeclared) capabilities (hereinafter referred to as the NDV threats) in the system and application software used in ISPD, , it is recommended that be considered irrelevant for RF BS organizations.” In accordance with paragraph 6 of Decree of the Government of the Russian Federation of November 1, 2012 No. 1119 «On approval of requirements for the protection of personal data when they are processed in personal data information systems» (hereinafter — PP No. 1119), such threats include threats of the 1st and 2nd type .
In addition, in accordance with clause 7.11.5 of the Standard, the Personal Data Security Threat Model is formed based on the results of risk assessment, and only those threats for which the corresponding information security risks turned out to be above an acceptable level are included in it. At the same time, for risk assessment, it is possible to use the already familiar methodology of the Central Bank — RS BR IBBS-2.2-2009″Methodology for assessing the risks of information security violations». This approach can allow organizations of the banking system of the Russian Federation to quite easily justify the irrelevance of threats of the 1st and 2nd types.
Of course, even without using the documents of the BR IBBS Complex, banks can recognize threats of the 1st and 2nd types as irrelevant — in accordance with paragraph 6 of PP No. 1119, they have the same right as personal data operators. Nevertheless, those banks that recognize the Standard as mandatory for themselves receive several additional arguments that increase the likelihood of successfully defending their position in dialogue with the regulator during scheduled or unscheduled verifications of compliance with the requirements of the law on personal data.
Now let’s remember how the types of threats affect the determination of personal data security levels, for which we turn to Table 1, already known to all, prepared on the basis of PP No. 1119.
Table 1. Definition of security levels
Information system processing special categories of personal data of subjects who are not employees of the operator;
|ISPDn-S-SO||Information system processing special categories of personal data of subjects who are employees of the operator;|
|ISPDn-B||Information system processing biometric categories of personal data of subjects who are not employees of the operator;|
Information system processing biometric categories of personal data of subjects who are employees of the operator;
Information system processing other categories of personal data of subjects who are not employees of the operator;
Information system processing other categories of personal data of subjects who are employees of the operator;
Information system processing public categories of personal data of subjects who are not employees of the operator;
Information system processing public categories of personal data of subjects who are employees of the operator
As can be seen from the table, if type 1 and type 2 threats are deemed irrelevant, RF BS organizations must ensure that personal data is protected according to the requirements for security level 4 or 3. The same levels will be relevant even if the bank maintains processing of biometric personal data. To meet these requirements, the Bank of Russia recommends implementing the provisions of the Standard set out in sections 7 and 8.
Only in cases where a bank processes a significant amount (more than 100,000) of special categories of personal data of subjects who are not employees of the Bank, it becomes necessary to protect personal data on the 2nd level of security. For example, in the West there is a practice when a bank’s credit strategy or scoring cards require the collection of information about the health status or nationality of the borrower in order to make a decision on issuing a loan to a certain category of citizens. But I have not yet seen such a practice in Russian banks. In other words, if the 2nd level of security in Russian banks will occur, then only in strictly exceptional cases.
However, let me remind you that in order to ensure the 2nd level of personal data security, it is necessary to fulfill the additional requirements of the Standard set out in paragraph 7. 11.6, most of which, of course, coincide with the similar requirements of FSTEC Order No. 21. The most essential requirements are: the use of intrusion detection systems, provision of trusted loading of computer equipment, integrity control, segmentation of the information system. But, despite the fact that the requirements of the Standard and the requirements of FSTEC Order No. 21 for the 2nd level of security mostly coincide, there are certain differences. For example, FSTEC Order No. 21 contains more stringent requirements for protecting the virtualization environment.
Let’s consider one more significant circumstance: regarding the use of certified information security tools, the Standard (see clause 7.11.8) does not put forward its own requirements or recommendations, but directly refers to FSTEC Order No. 21, which allows the use of non-certified information security tools to ensure 3 -th and 4th levels of security, if the threats of NDV are irrelevant.
Thus, the only advantage that STO BR IBBS-1. 0-2014 gives in terms of freedom to use non-certified means of protection is additional reasoning for the position of the Bank, which recognized threats of the 1st and 2nd types as irrelevant.
STO BR IBBS-1.0-2014 AND CIPF
It should be noted that the requirements of the Central Bank of the Russian Federation for the CIPF classes used to protect personal data are more stringent than the requirements of FSB Order No. 378. Thus, RF BS organizations that have chosen to comply with the requirements of the Bank of Russia in terms of personal data protection must always use CIPF of a class of at least KS2 . However, for RF BS organizations that have decided to adhere only to the requirements of the legislation in the field of PD, in order to ensure the 4th, 3rd and 2nd levels of security (provided that only type 3 threats are relevant) in accordance with subparagraph «c» paragraph 9, paragraph 18 and paragraph 21 of the Order of the FSB No. 378, the use of cryptographic information protection tools of class KS1 and higher is allowed.
Let me remind you that the main differences between KS2 and KS1 are that when using cryptographic information protection of the KS2 class, it is necessary to use trusted boot tools, such as PAK Sobol, Accord-AMDZ, etc., which are not always compatible with some technologies, such as blade servers, virtual infrastructure, or mobile devices. In other words, in a number of cases, the use of CIPF class KS2 is impossible or is associated with a number of serious problems.
On the other hand, although this requirement of the Standard is mandatory and more stringent, it is assessed by only one particular indicator (out of sixteen included in the M6 group indicator). Thus, non-compliance with this requirement cannot drastically affect the final level of compliance. Moreover, as mentioned above, according to the requirements of the legislation, the use of CIPF class KS1 is permissible. Thus, when using CIPF of class KS1 or partial use of CIPF of class KS2 along with class KS1 and properly fulfilling the other requirements and recommendations of the Standard, RF BS organizations in any case do not violate the mandatory requirements of the law and, at the same time, have every chance of obtaining the recommended final level of compliance according to requirements of the Bank of Russia.
SIGNIFICANCE OF DOCUMENTATION
The importance of documenting IS maintenance and management procedures has noticeably changed in the Standard. So, if earlier, without having an appropriate regulatory document, the Bank nevertheless put into practice one or another process of ensuring security in accordance with the requirements of the Standard, it could get a score of 0.5 for the corresponding particular information security indicator.
Now, even if the requirement is actually perfectly met, but the normative document is not developed, the Bank will not be able to score more than 0 for this partial indicator. This applies to category 1 partial indicators, where both the degree of documentation and the degree of implementation are assessed. For private indicators of IS category 2, where only the degree of documentation of IS requirements is assessed, the situation is, of course, the same — a requirement partially established in the documents will lead to a score of 0.
If we talk about the number of documents required to comply with the requirements of the legislation on the processing and protection of personal data, and to comply with the requirements of the Standard relating to the same area, then the key difference between these two approaches is that the Bank of Russia approach uses a process character. If we compare the requirements of the legislation and STO BR IBBS-1.0-2014, we can see that in order to comply with the Standard, it is not enough just to have any document.
It is necessary to define, implement, record and control the procedure associated with such a document. For example, in accordance with PP-1119, subparagraph «c» of paragraph 13, the head of the document defining the list of persons having access to personal data must be approved, and in accordance with paragraph 7.10.7 of the Standard, a RF BS organization must define, implement, register and control procedures for accounting for persons with access to personal data. As can be seen from the above example, the requirement is essentially the same, but the number and composition of documents will be different.
Taking into account the above, the fulfillment of the requirements of the Standard for the processing and protection of personal data, in terms of documenting the protection and processing of PD, seems to be more time-consuming than the fulfillment of direct legal requirements.
ABS AS ISDN
I would like to draw attention to one more significant change. For example, in the past, RF BS organizations could not classify their core banking systems that implement bank payment processes as ISPDs, since this was explicitly stated in the previous edition of the Standard. Thus, RF BS organizations were able to exempt such ABSs from the scope of personal data legislation and, thereby, significantly reduce their resources for bringing ABSs in line with the requirements of Federal Law No. 152-FZ “On Personal Data”.
The situation has changed somewhat in the new version of the Standard. The Bank of Russia did not make direct demands on the inclusion or exclusion of the ABS from the ISPD, but vaguely wrote in clause 7.10.3 of the Standard that criteria for classifying the ABS as a ISPD should be established in RF BS organizations, i.e. The Bank of Russia leaves the choice directly to the banks themselves.
Of course, in the event of an erroneous decision to exclude ABS from the list of their PDIS, RF BS organizations will not be able to appeal to the requirements or recommendations of the Bank of Russia, and, of course, will be liable to the regulator in the field of PD protection on their own.
So, the BR IBBS Complex can give banks additional arguments to justify the irrelevance of threats of the 1st and 2nd type before the regulator for the protection of the rights of PD subjects.
The consequence of recognizing the threats of the 1st and 2nd types as irrelevant is the possibility of actually fulfilling the requirements only for security levels 3 or 4, and the possibility of using a wider range of information protection tools.
The negative features of the adoption of the Standard include more stringent requirements for the use of CIPF for RF BS organizations that comply with the requirements of the Standard than for organizations that comply with direct legal requirements. But, given the current Methodology for assessing compliance with the requirements of the Standard, such a feature can only be called conditionally negative.
In addition, it is worth paying attention to the disappearance of the past clear advantages of the Standard:
- the disappearance of the clear possibility of exclusion of core banking systems that implement banking payment technology processes from the composition of ISPD;
- , as of today, there is no possibility of using the Standard to replace the direct requirements of regulators for the protection of personal data, as it was before.
Of course, the Standard is advisory in nature, and to accept (or not to accept) the documents of the BR IBBS Complex as mandatory, each bank decides for itself, weighing all the pros and cons.
But in conclusion, it should be noted that the Standard was developed specifically for Banks and takes into account their industry specifics. To date, there are a large number of all kinds of legislative and industry requirements for the protection of information that banks are required to comply with. In addition to the Federal Law No. 152-FZ “On Personal Data” discussed in this article, there is, for example, Federal Law No. 161-FZ “On the National Payment System”.
Both federal laws impose a number of requirements for information protection, which overlap somewhere, somewhere they have certain nuances of joint application. During the development of the new version of the Standard, the Bank of Russia tried to take these requirements into account and harmonize them with the already familiar text of STO BR IBBS-1. 0-2010. And regardless of whether a bank accepts the IBBS BR Complex as mandatory or not, proper implementation of the requirements and recommendations of the Standard may allow RF BS organizations to meet various requirements of various regulators within one information security system.
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disciplines that I studied at the university (+ even in college before that) and took exams on them, there were also such subjects as Human Resources Management, Forecasting the development of the industry, Cost management in a service sector enterprise, Organizational, economic and regulatory support for activities, Business -planning, Project management, Anti-crisis management at the enterprise, Psychology and pedagogy, etc.
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From my childhood (at different moments) and before being drafted into the army, I was engaged in the following — swimming, karate, theater, pop vocals and hand-to-hand combat.
At the moment I’m interested in playing badminton actively, playing billiards, cycling (etc.).
Intellectual games are interesting to me — «Checkers», an interesting game where my intuition and strategy is needed, analysis — «Battleship», the game «Balda» is a kind of word game.
For some time I was engaged in small-scale wholesale business in the city of Vladimir.
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