August 1st, 2018
Adam Stone, Principal and Chief Privacy Officer
Just as business leaders started acclimating to the data privacy requirements in the EU’s General Data Protection Regulation (GDPR), along comes a new and equally robust privacy law from the Golden State. Passed with impressive velocity and approved by Governor Jerry Brown on June 28, the California Consumer Privacy Act of 2018 (CaCPA, or “kak-pah“) raises the data privacy bar for businesses that profit from or otherwise collect, use and share personal data about California residents. In a borderless digital economy, where a business is domiciled no longer matters. The extrajurisdictional reach of CaCPA means that businesses of all sizes may fall under the statute if they provide goods or services to Californians. And who doesn’t nowadays?
Long the policy vanguard for data privacy, California generally sets the tone for the rest of the country. Once effective, many privacy experts believe that CaCPA will move organizations (especially tech-focused firms) towards a data protection regime similar to GDPR. Operating from the constitutional position that Californians enjoy an inalienable right to privacy, CaCPA enshrines many of the same rights that GDPR does for those in the EU. These include a right to be informed; to block the sale of personal information; to access, rectify and request erasure of personal information; and a right to exercise these privileges without prejudice.
If history is a guide, the state will take an aggressive stance on enforcement after the law’s January 1, 2020 effective date.
Though CaCPA covers the activities of a significant number of organizations across the US, some businesses can count themselves out of the statute’s scope. To do this, business leaders should conduct a scoping test based on the carve-outs defined in CaCPA. Here is a helpful decision-flow chart for this purpose.
In plain language, the decision flow above points to businesses that collect, process, use, share, and retain personal information about California consumers. To fall within scope, the business must meet certain thresholds for annual revenue and the breadth of processing of personal information. If the answer to one of the three questions below are “yes,” organizational leaders may assume that the business is in scope of CaCPA.
Do we have annual gross revenues in excess of $25 million dollars?
Do we alone or in combination, annually buy or receive, for the business’ commercial purposes, sells, or shares for commercial purposes, alone or in combination, the personal information of 50,000 or more consumers, households, or devices?
Do we derive ≥50% of our annual revenues from selling consumers’ personal information?
With an affirmative answer to the decision flow above, business leaders should begin reviewing their business processes to ensure compliance with CaCPA on or before the effective date. As the date draws near, expect to find numerous articles and resources for deciphering CaCPA and implementing its requirements. For business leaders seeking an early edge on the competition, hire an outside expert who can help efficiently operationalize a CaCPA-compliant data privacy program.
Adam Stone is Principal Consultant and Chief Privacy Officer for Minneapolis,MN based Secure Digital Solutions (SDS). With a focus in data protection, SDS provides expert guidance in building and maintaining programs that align with the needs of the business. Our team of seasoned professionals offers a rigorous approach to improving privacy and security management processes. We seek opportunities to improve performance and demonstrate meaningful results. Contact our professionals today at (952) 544-0234 or firstname.lastname@example.org.
(originally posted November 2015 – revised June 2018)
By Chad Boeckmann, (CEO, Secure Digital Solutions)
In my previous blog, “Controls are for Auditors” I wrote about how we as security leaders need to move away from managing security controls in the weeds like an auditor. This article describes a “processes are for managers” approach. It aims to align security management with the business in order to communicate and manage information security effectively.
CISOs are tasked to achieve challenging outcomes and need to also communicate the state of their progress and the state of information security program – related risks – to other executives and board of directors. Our team partners with CISO’s from Fortune 500 companies and many mid-market businesses. They are all challenged with the same dilemma: Presenting effectively to an audience that does not necessarily understand the complexities of information security.
To address this challenge consider looking at the information security program as a business process. Frameworks and legal or industry data protection requirements often overlap and these requirements can be combined to establish a core process as a requirement of the security program. For example ISO27002, HIPAA Security Rule and GLBA all require Access Control. If we look at access control for a moment:
Let’s say we want to measure the referenced process above. Access Control is a requirement of many data protection laws and is also highlighted in both ISO27001 and NIST Cyber Security Framework. Instead of managing control verbiage from a regulation or framework we can measure the effectiveness of Access Control Management generally from a process perspective but do so specifically using maturity attributes. Looking at Access Control Management we want to understand the level of performance (maturity) of this process across the six major attributes using a standard maturity scale of 1 through 5.
What is our level of maturity of Awareness for Access Control Management across our environment?
What is our level of maturity for Policy & Procedures for Access Control Management across our environment?
What is our level of maturity of Expertise for Access Control Management across our environment?
What is our level of maturity of Accountability for Access Control Management across our environment?
What is our level of maturity of Automation for Access Control Management across our environment?
What is our level of maturity of Measurability for Access Control Management across our environment?
If the business is performing well in Awareness, Policy and Procedure and Accountability (relative to our process in question) then understand clearly where our resources and investment should be applied. In this example, improvement can be applied to Automation (tools) and Metrics for Access Control Management. This approach provides a much more holistic method to repeatedly understand attributes of a control process that applies to internal policies and external regulations.Then taking core business objectives, such as improving customer retention, and associating a core process like “access management” to that objective, one can correlate how information security is supporting key business outcomes.
This approach described is proven to establish alignment with business leadership, while still meeting control objectives and focusing resources on the areas of greatest impact. Let your internal and external auditors measure the effectiveness of the control in place, you will know the answer before the audit starts by measuring and improving upon attributes of each process. Therefore we can leave controls to auditors and adopt a “process for managers” approach to manage security programs and related risks. To see this methodology in action, take a look at a 2-minute video demonstrating TrustMAPP, a platform we developed to holistically manage information security.
Does the GDPR "due date" remind us of Y2K? What will really happen on May 25th? No one really knows for sure the answer to this question but likely there will be a lot of work to continue to do in the months (and perhaps years) to follow May 25th, 2018.
Just for fun here is a timer you can refer to for the GDPR deadline.
#1 Data Portability #2 Accountability Principle #3 Extraterritorial applicability of the GDPR #4 Maintaining records of processing activities #5 New Data Subject Rights #6 Privacy by Design and by default #7 Data Protection Authority enforcement methods #8 Pseudonymization and its use in profiling #9 Security and breach notification #10 One stop shop
Stop Panicking and Start Your GDPR Readiness Journey Today
The time to act is now. Firms of all sizes must determine how GDPR will impact their business and act accordingly. For business executives who do not have the time or expertise needed to meet GDPR’s stringent requirements, our seasoned consultants will help you identify GDPR readiness gaps and define common-sense strategies for meeting compliance obligations. We leverage the in-the-trenches experience of past compliance initiatives to provide maximum value for today’s clients. Start your GDPR-focused compliance journey today with an affordable Readiness Assessment. Contact us at 952-544-0234 or visit our privacy services page for more information.
A security program, as it evolves and matures, will typically experience four types of leader personalities. These personalities may even occur within the same individual if that individual adapts to the maturation of the business and molds the security program simultaneously.
I believe these leaders can be categorized into four types:
The first type of leader is the auditor. The role of the auditor is purposefully designed to be tactical. The security leader in the auditor role is primarily focused on control measurement and compliance. The resulting security program is typically built and managed based on complying with regulatory requirements. Budget and resource decisions are made with the purpose of meeting these regulatory requirements. This approach isn’t surprising considering the history of Information Security throughout its long tenure. Countermeasures were frequently driven by the need for controls to protect information. As such, many security programs begin with compliance as the initial driver for building and maturing information security, making them tactically effective but strategically immature due the fact that some never move beyond this stage.
The next type of security leader personalities – the one that we most commonly see – is the technologist. The security leader in the technologist role has a keen focus on technical testing, monitoring and response, and primary focus on tools to automate controls. Typically the security leader as a technologist takes pride in building out operational security capabilities and leveraging leading edge products and services. Every modern security program must have a strong security technologist leader. However caution should be placed in emphasizing the majority of time in this single discipline. Implementation of leading automation technology must also be accompanied by well-defined processes and plans. Oftentimes, these processes are defined after tools are selected. Instead, the reverse should be achieved. Processes and plans that meet the business objectives and inform technology decisions to automate key processes must be defined before technology is selected and applied.
The next type of security leader personality is the hero. The hero is generally the type of leader who will focus on response and detection based on the company having recently experienced a negative cyber security event. Oftentimes the hero approaches the role with the mindset “they hired me to build it” which can have both positive and negative effects on the organization. The positive implications this personality displays is pride and ownership for achieving outcomes. The flipside of this trait could be spending countless hours of staff time to build tools that already exist within the marketplace.
The fourth security leader personality is business leader. The business leader personality has only recently benefitted from discussion in the community. A security leader fulfills this type of role when they focus on managing the security program like a business within the business. Being a modern-day security leader is challenging as they need to understand technology and controls while simultaneously having the right team (staff and partnerships) in place to respond adequately in the event of a negative cyber event. The business-minded security leader understands to be successful, they must rely on others within the business and have strategic partnerships with firms outside of their business. Additionally, business-minded security leaders measure performance and do not rely on the less-effective approach of FUD (fear, uncertainty and doubt) to communicate the performance of their security initiatives with executives. Instead, they focus on aligning and enabling the business objectives while raising caution when situations require it.
No matter what type of security leader you have (or you are), we can help you measure the things that matter most to the business and improve the alignment of security strategy. I encourage you to reach out for more information and further discussion.
January 16th, 2018 Adam Stone, Principal Consultant
Are you falling into the rut known as the great GDPR compliance panic of 2018? Stop worrying. Many data security and privacy leaders have successfully addressed the challenges of new regulatory compliance obligations before.
Several years ago, I entered the data security and privacy world just as new business challenges emerged from two separate congressional reform bills intended to solve certain problems in the US healthcare and financial services sectors. The Health Insurance Portability and Accountability Act of 1996 (HIPAA), followed by the Gramm-Leach-Bliley Act of 1999 (GLBA), triggered federal regulation focused on – among many other areas – data privacy and security. At the time, organizations of all sizes struggled to prepare for the new federal requirements.
The first hurdle for some organizations was to simply acknowledge the fact that HIPAA and GLBA applied to their operations. For those who moved past the acknowledgement phase, preparatory scope creeped, and unplanned business disruptions followed. In an environment where executives were unclear about the applicability and impact of HIPAA and GLBA regulations, data security and privacy professionals found little support to implement new controls structures. The result: compliance programs poorly-aligned to corporate mission, values and objectives.
Though data security and privacy professionals emerged wiser from the HIPAA/GLBA compliance experience of the early aughts, evidence suggests that many firms now struggle with the emerging challenges of the EU General Data Protection Regulation (GDPR). As principal consultant with Secure Digital Solutions (SDS), I hear from lots of panicked leaders who need help understanding the impact of GDPR ahead of its May 2018 effective date. We find that firms can avoid some of the setbacks of the past by adopting an effective, scalable process for GDPR compliance preparations today. Whether preparing for GDPR with in-house resources or hiring an experienced consultant, firms should adopt a GDPR Readiness process like the one in the image below.
Stop Panicking and Start Your GDPR Readiness Journey Today
The time to act is now. Firms of all sizes must determine how GDPR will impact their business and act accordingly. For business executives who do not have the time or expertise needed to meet GDPR’s stringent requirements, our seasoned consultants will help you identify GDPR readiness gaps and define common-sense strategies for meeting compliance obligations. We leverage the in-the-trenches experience of past compliance initiatives to provide maximum value for today’s clients. Start your GDPR-focused compliance journey today with an affordable Readiness Assessment. Contact us at 952-544-0234 or visit our Web site for more information.
Original: October 19th, 2016 Updated: December 11th, 2017
Mike Edlund, Solutions Manager
Cyber Security Service Catalog Enables Strategy
Creating a Security Services Catalog for a security team begins to drive value across the business by establishing accountability and scope of services. A security service catalog enables strategy by clearly articulating to the business customer services provided by information security teams while providing a level of service and responsible parties for each area identified. This case study was inspired by a more formal representation of provided by NIST 800-35 "Guide to IT Security Services". In short NIST 800-35 provides guidance using a lifecycle consisting of six phases:
Phase 1: Initiation—the need to initiate the services life cycle is recognized. Section 4.1 discusses potential triggers for this phase. Phase 2: Assessment—before decision makers can implement a service and select a service provider, an accurate portrait of the current environment must be developed. Section 4.2 discusses Phase 2 and the importance of creating and gathering appropriate metrics. Phase 3: Solution—decision makers choose the appropriate solution from the viable options identified during the assessment phase. Section 4.3 discusses the business cases and implementation plans. Phase 4: Implementation—the service and service provider are implemented during the implementation phase. Section 4.4 guides decision makers through service agreement development and service implementation. 4-1 NIST Special Publication 800-35 Phase 5: Operations—the service is operational, the service provider is fully installed, and constant assessment of the service level and performance is made. Section 4.5 discusses the importance of metrics in monitoring service level and performance. Phase 6: Closeout—the environment changes, the need for the service diminishes, or performance deficiencies are noted necessitating a replacement or termination of the IT security service. Section 4.6 discusses the closeout and retirement of a service and/or service provider using the exit strategies developed in Phase 3. (source: NIST 800-35 - http://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-35.pdf)
A customer requested Secure Digital Solutions (SDS) to develop security plans and procedures to consistently manage their information security program. SDS collaborated with the customer's security team to document and improve the current and desired security capabilities and plans. Our customer had two key challenges:
Procedures and plans to deliver the security program activities were not formally documented, leading to poorly-defined program actions and responsibilities.
Roles and responsibilities defined in newly minted procedures and plans were not aligned with the team set up to do these activities and the associated controls supported by the new activities.
The customer engaged SDS to collaboratively develop cyber security plans and procedures for the cyber security program and supporting team members. Along the way, SDS discovered a gap in roles and responsibilities that led to a further surprise benefit to aid the customer's security program.
Over a period of months, SDS partnered with customer security leadership to define desired security program strategy, objectives and goals. The service areas in-scope include a number of processes such as threat and vulnerability management, training and awareness, risk management as well as policy and standards management.
SDS began creating a number of documents that defined areas within the security program including a RACI chart designed specifically for the customer's cyber security team. Plans to define how these areas would be strategically delivered were designed and offered for further feedback, input and iteration from the security team and executive leadership to reach a final cyber security service catalog framework. The SDS team developed the content leveraging both industry best practice, SDS experience and and feedback from the customer's security team.
Plans and procedures included sections to define roles and responsibilities as to who is responsible to deliver the security program processes and related service levels (RACI). SDS also noted areas missing formal responsibilities for the security team that lead to more reactive response and "firefighting" in turn draining current resources. The existing approach used by the customer, prior to the final adoption of the SDS service catalog, was far less strategic and not optimized. With the presentation of our findings conversation with leadership and it was clear to all parties involved for the need to coalesce security team processes/controls into a centralized service catalog.
Consulting with customer's security team lead to the creation of a services catalog that defined the required activities and assigned team personnel responsibilities to these activities. As a result not only did the security team have a clear understanding of priorities and responsibilities, the business customers also understood the scope of the internal security services team. Business teams now understand how to engage and who to speak with regarding various projects and customer engagements to meeting both internal and external security requirements.
Impact on the Customer's Business
Along the way, leadership of the security team changed. The security catalog took on a whole new meaning with a surprising additional benefit. With the catalog’s estimates for FTEs required for duties to properly cover the entire security program, the new security leadership leveraged the security service catalog as the means to forecast and request additional resources to executive stakeholders.
With the change in security program leadership, the plans and procedures also offered insights and a standard approach from which the new leadership could understand how the program is managed to meet business expectations while aligning existing security team personnel.
To learn more about automating a cyber security services catalog reach out to our team at: email@example.com or visit the TrustMAPP website.
Virtually everyone wants to be healthier. Good health and fitness provide a multitude of benefits. Better quality of life, increased energy, sharper mental focus and lower risk of malady are but a few. But it takes work to enjoy the benefits. A four-hour marathoner won’t suddenly become a three-hour marathoner simply by acquiring the newest running shoe. It takes planning, discipline and execution, and there are countless obstacles lurking to derail you in your attainment of your goal — both known and unknown.
Ironically, this scenario also applies to an organization’s information security program. A mature and effective program empowers staff, allows for more effective enablement of the business, increases threat awareness and response, and lowers the risk of negative front-page exposure. However, like the marathoner example, simply purchasing the latest security technology won’t guarantee good security health and fitness. It takes the same planning, discipline and execution, as well as the same willingness and ability to overcome obstacles.
Here are eight steps to create an effective information security protocol in the form of a health and fitness plan:
Take inventory. Regardless of where you want to be, a good fitness plan starts with where you are today and an honest assessment of current capabilities. Perhaps it’s a body fat measurement or a VO2 test. A mile time or a max bench press. An evaluation of eating and sleeping habits. Whatever the assessment type, diligence and candor are critical. The same goes for the state of a security program. What are the program’s current capabilities, its level of expertise, the usable technologies available today? Honesty is the key. If a security program’s third-party management capability may not be where it should be, then it’s a baseline of current capability.
Set goals. This could be anything from dropping a few pounds to completing a full Ironman. Goals should be multifaceted. Along with determining the desired outcome brings the analysis of what it will take to get there based on the results of the initial inventory. Shaving an hour off a marathon time, for instance, will require a training plan with a schedule and a certain level of effort. So too will reducing vulnerabilities in a company’s critical infrastructure, lowering the time to respond to a security incident and complying with the newest data privacy regulations. Determining what an organization needs to accomplish from a security perspective should be the focus.
Execute. The fitness plan may call for a 1,000-meter swim on Monday, but there’s an errand to run, a call to make or it’s simply been a long day. There are countless roadblocks that could derail a detailed plan, and some truly can’t be avoided. However, most can. It’s oftentimes an attractive proposition to get security “quick wins” by acquiring a new tool or by making a short-term change in direction. In some cases, these actions are mandatory. But not in most. Plan the work and, more importantly, work the plan. It’s consistency that produces results.
Monitor progress. This is straightforward. As the work on a plan progresses, health and fitness increase as demonstrated by the metrics. Mile times get better, pounds come off and performance improves. Similarly, success on the security front will bring progress, too. The clusters on the risk heat map transition from red to yellow to green, malware infections decrease, code quality gets better, significant compliance deficiencies are remediated, etc.
Adjust. At this point, there should be enough data to track alignment to goals. For a triathlete, it may be time to adjust the cycling schedule because that appears to be the weakest area — more hill training or longer distances. Some areas in the security plan may need adjustment as well. Perhaps risk management is improving and with it, security’s visibility of an enterprise. Because of this, more focus may be required on data loss prevention, for example, to reach security performance milestones.
Accomplish the first goal. Run the first 10k, shoot the first sub-90 round of golf, drop the first five pounds. For a security program, it may be achieving compliance, reduction of significant risk in an area or reducing online fraud by a certain percentage. Whatever the first goal is — accomplish it.
Celebrate. Enjoy the fruits of labor and appreciate all who contributed.
Maturity is an interesting word. We’ve heard it throughout our lives and it’s had different meanings in different contexts. As a child, we heard it from our parents regarding “growing up” or “being more mature”. We may not have entirely understood it then, but our parents knew that developing maturity would be important for friends, colleagues and peers to take us seriously.
As we grew older, we began to understand the concept of maturity and that it could be compared closely to wisdom. We began using what we learned through experience and started applying that knowledge to our decision-making process.
Today we hear the word maturity frequently in the workplace. We see it used in processes, methodologies, rating scales, etc., and from a technology and process standpoint, maturity can be applied to cybersecurity as well, although its applicability and benefit isn’t always readily apparent.
Case in point. Recently, over lunch, I was attempting to explain the purpose and benefit of cybersecurity maturity to a business colleague. Based on his skeptical expression, it was clear to me that I wasn’t succeeding. He fully understood compliance and the implications of non-compliance, but wasn’t grasping the value of maturity and how it was relevant in the security space.
I thought about what was personally important for me to secure, and the answer was easy – my family. I then thought about an area where compliance comes into play and how it is typically used to determine effectiveness – home fire safety. Using that as an example, I asked him to rate his family’s level of home fire safety on a scale of 1-5. “4-5,” was his response. “I have the best smoke alarms money can buy. I have one on each floor and in each bedroom, as I’m required to by code. In addition, I have a fire extinguisher in the house and one in the garage.”
From a compliance standpoint, we both agreed that his score of 4-5 was likely accurate, and one could say that he had gone above and beyond the minimum standard. I then challenged him to look at it from a maturity perspective, using a series of ad-hoc questions as a baseline:
Do you test your smoke alarms?
Do you have a regular schedule for replacing the batteries or do you replace them only when the alarm tells you to?
Do you have a family communication and logistics plan that you can put into action if an alarm sounds in the middle of the night?
Do you practice the plan?
Does everyone in your family know where the fire extinguishers are?
Does everyone in your family know how to use the fire extinguishers?
Is there a pre-determined family assembly area outside?
As he considered each question, I then asked, now that he’d added a maturity measurement to compliance, what would he rate his family’s level of fire safety? “Probably a 1-2,” was his concerned reply.
While this may be a simple example, it begs a question. Traditional compliance and operational data is important, but does it provide adequate context to truly evaluate capability? Using the fire safety example above, it doesn’t appear to. My colleague had all the required detection mechanisms in place, including some additional preventative measures, but any significant capability for his family to respond effectively to a fire simply wasn’t there.
The same question can be asked of a cybersecurity organization, and a growing number of security leaders are adopting maturity as a metric to analyze and determine their team’s strategic capabilities because the hundreds of individual controls, while critical, only represent a point in time.
Cybersecurity maturity, used as a performance metric, offers additional insight into how the security organization is operating. It can be used to analyze compliance and operational data at the process or function level. Trends can be discovered, monitored and adjusted for. An enterprise security training program may have all the right features in place, for instance, but the open rate of phishing emails by employees isn’t decreasing over time. Do the components of the training program need to be adjusted or does the content? Or, does the challenge lie within another function or process outside of the training program? The use of maturity to analyze the capabilities of those processes can likely answer those questions.
In today’s evolving threat landscape, effective metrics are critical to security success. Controls and operational data are required to run the organization today. Strategic KPIs, such as maturity, are also required to measure, profile and plan the security organization’s capabilities for both today and tomorrow. Performing a cybersecurity maturity assessment on the security organization will likely yield valuable insights. There are excellent sources available that show where to begin and how to demonstrate the value of measuring cybersecurity capabilities and effectiveness. (An example can be found here).
Ultimately, the best smoke alarms money can buy are powerful tools in the event of a fire, but only if everyone has the capability and maturity to respond effectively.
Chances are you’ve seen a similar image over the past several months. Either on internal systems (hopefully not) or within the countless blogs, news stories and industry journals that bombard us every day with ominous warnings and dire consequences. It is, of course, ransomware. And while it (and media coverage of it) has dominated the cybersecurity world for the last several years, it’s not new. Also, not new are the fundamental security building-blocks necessary to mitigate its impact or the fact that it represents a cyber risk.
What does seem new is the incredible amount of singular focus on these incidents around the ‘cyber watercooler’ that drowned out the broader discussion of the underlying principles comprising a solid cyber security program. In addition, the tenor of the cyber risk discussion has seemingly changed as well, from an enterprise-level conversation to a single-point conversation. Neither of these trends are positive.
The first significant ransomware instance occurred in 1989. It was coined the AIDS trojan and was released on 5.25” floppy disk. Similar to today’s modus operandi, it attempted to extort currency from victims by encrypting their hard drive and demanding payment for decryption. It was ultimately unsuccessful due to several factors, despite the lack of security in place at the time, but set a precedent with regard to criminal motivation and intent. As most companies had yet to adopt personal computing and the internet was still in its infancy – used primarily by academia and scientists – the risk and potential of malware wasn’t well understood or communicated.
Throughout the 90’s the use of personal computing and the internet grew exponentially along with the creation of standardized operating systems and associated applications. The adoption of personal computers and enterprise-level functionality increased within corporations as well, becoming the table stakes necessary to keep up with an increasingly connected marketplace.
It was during this time that a need emerged for organizations to create processes to manage and maintain their technology stack along with the need to hire internal [or external] experts to manage and refine those processes. Building blocks emerged that formed the basis for how IT and cybersecurity is run today. Identity and access management, anti-virus, firewalls, enterprise email, instant messaging, VPN, cryptography – all were developed rapidly during the technology boom of the 1990s. While security was becoming more relevant and the notion of IT security risk was beginning to emerge, the major focus from an IT risk perspective centered primarily on availability and emerging IT processes reflected the focus on that aspect.
The late 1990s (and early 2000s) brought with them a new development in cybercrime. The first significant uses of malware for financial gain began to manifest themselves within online banking applications. As waves of consumers adopted the convenience of managing their money without having to leave home or work, the criminal acquisition of credentials became both highly sought-after and increasingly more profitable. The ability to transfer funds internationally had also advanced significantly, allowing cybercriminals to exploit this threat vector quickly and without a high likelihood of being apprehended. As a result, the concept of cyber risk truly began to take shape. Losses could now be measured in hard numbers that directly affected an organization’s bottom line and the realization emerged that steps had to be taken to address these new threats.
Financial institutions and regulators responded to this realization by producing several significant requirements designed to directly address IT security and cyber risk. GLBA, SOX, NIST and BASEL, to name a few, all intended to provide some semblance of best practice requirements while allowing institutions flexibility to implement the requirements in alignment with business goals. While this didn’t specifically address the malware threat, it did begin to form the basic building blocks of a sound security program, complete with increasing consequences for not adopting some form of security process.
The mid-2000s and early 2010s brought the first ‘modern’ ransomware and the precursors to today’s crypto-ransomware. Gpcoder, Winlock and so-called Police ransomware utilized a ‘locker’ approach, requiring victims to pay a fee to unlock files or perform some money-generating action to remove malicious functionality. Police ransomware (locking the peripherals and displaying a warning screen from a supposed law enforcement agency) began to show the emerging effectiveness of social engineering. In many cases, the user’s IP address was displayed, the screens were generated in a victim’s native language and a local or regional law enforcement logo was used, adding perceived legitimacy to the attack. While these early variants were impactful, they were easily mitigated (compared to today’s efforts) due to their weak encryption and relatively basic infection methods.
Standards continued to emerge and evolve simultaneously to address these threats. In 2004, for example, the 5 largest payment card brands combined their individual security requirements into the PCI DSS, establishing 12 standards sections for accomplishing 6 objectives. While opinions vary on the effectiveness and necessity of the PCI DSS, many of the key requirements and processes in the standard outlined ways to address the threats. Encryption standards, network segmentation, vulnerability management, file integrity monitoring, training and awareness, perimeter security, etc., all could be applied in varying degrees of strength and effectiveness throughout the corporate infrastructure (not only within the cardholder data environment) to make organizations more secure.
Today’s modern ransomware emerged in 2013 and has been dominant since. Crypto-ransomware and its progressively more automated infection methods are straightforward and effective, encrypting the victim’s files using strong encryption and demanding payment using various means – most frequently today, cyber currency. Recovery from these outbreaks is much more difficult and some organizations have had to resort to reformatting their entire hard drive population to remove the infection.
This standard and threat progression has produced two additional trends. First, it made security more challenging to design and implement. Transforming enterprise architecture, for example, from a flat network to a segmented network and creating processes to deploy, manage and maintain encryption keys, were not small efforts. They required focus on people, process and technology to be effective.
Secondly, as security became more complex, effective enterprise implementation required knowledge, awareness and support from the business units within the organization. Security leaders who recognized this, and could demonstrate and communicate the necessity of security being a critical part of doing business, typically received the funding and support required to build world-class programs.
The moral of the story is that, while there’s no such thing as 100 percent secure, the processes, tools and expertise to combat the threat has been around almost as long as the threat itself. The two most recent outbreaks – WannaCry and Petya, for instance, likely could have been greatly minimized or potentially avoided altogether by focusing on the fundamentals. The fixes were there well in advance of the outbreaks. It simply took awareness and execution to address them before something bad happened.
No one can predict the future. There will be bona fide threats that emerge without warning that the industry will have to collaborate on to address. In the meantime, let’s cut through the ‘noise’, recognize today’s (ransomware) threats for what they are and how they compromise the organizations we’re responsible for protecting. Let’s focus on ensuring the foundational building blocks are in place (patching, backups, vulnerability management, etc.) and be as ready as we can be to respond to future security news that’s new.
Understanding GDPR: The Security Leader’s (Really Concise) Primer
July 11th, 2017
Adam Stone, Chief Privacy Officer and Principal
As the effective date for the GDPR nears, the team at Secure Digital Solutions (SDS) are experiencing a significant uptick in calls from information security leaders seeking guidance about this new regulation. Though there’s much to discuss when it comes to GDPR compliance, we would like to provide a short primer to answer some of your most basic questions.
Strengthens protections for individuals via enhanced requirements for data privacy risk assessments, notice, choice, consent, data portability, right-to-be-forgotten and breach notification, among others;
Adapts to technological developments that emerged in years past the enactment of the Data Protection Directive;
Enacts a new penalty structure that includes administrative fines of up to 4% worldwide revenue for certain violators.
2. Why is everyone talking about GDPR now?
The effective date for GDPR is 25 May 2018, less than a year away. Many organizations recognize that implementation activities must begin today to be compliance with GDPR mandates.
3. Isn’t GDPR a legal thing? Why can’t the lawyers handle this?
Legal professionals play a critical role by helping interpret GDPR compliance obligations, establishing policy and defending our organizations in the event of GDPR-related enforcement actions. Attorneys may not however, be called upon to assist organizations with the implementation of controls and processes in support of GDPR compliance. Many key functions have a role to play in deploying GDPR controls and processes, including of course, information security.
4. Who typically leads GDPR readiness efforts?
For organizations that have a Data Privacy Officer (DPO) in place, this person will often be tapped to lead GDPR readiness efforts. Otherwise, organizations choose a leader that reflects the culture of the organization. Firms that view GDPR as chiefly a legal liability are likely to appoint General Counsel or the Chief Compliance Officer (CCO) to lead GDPR implementation efforts. For those who see GDPR as material factor in marketing and sales initiatives, the Chief Operating Officer (COO) or Chief Marketing Officer (CMO) will lead. Some firms see GDPR as an issue closely aligned to IT, and thus will appoint the Chief Information Officer (CIO) or Chief Information Security Officer (CISO) to lead readiness efforts. Since GDPR crosses many organizational functions, whoever leads GDPR readiness efforts must have the authority to affect change throughout the firm.
5. Does GDPR define specific things that security leaders need to do?
Like most laws and regulations, the GDPR does not go into many specifics about the types of information security solutions required for compliance. Luckily for organizations with a security leader in place, there is a strong possibility that the firm already has many of the basic information security controls requirements in place. In these scenarios, security leaders should, at a minimum, conduct a gap assessment to ensure that existing controls meet GDPR standards.
It may be helpful to parse the sections of GDPR into logical chunks to identify potential areas where information security is involved. For the benefit of our readers, we provide a worksheet to get you started.
6. Where should I start in my GDPR preparations?
First and foremost, organizations should seek an understanding of whether GDPR applies to their business operations. For most, this is when a lawyer comes in handy. S/he can provide the legal advice needed to decide whether to move forward on GDPR readiness.
Assuming that GDPR does apply, we suggest that organizations begin by identifying the scope of GDPR within their operations. Doing so should minimize the disruptions created when implementing new controls and processes. Part of this scoping work includes identification of the personal data and sensitive personal data that fall into regulatory purview. Following this stage, the firm should conduct a comprehensive gap or risk assessment, aligned with the requirements of GDPR. Only after completing these first two stages should an organization develop a strategy for addressing potential gaps in GDPR compliance.
SDS’ experienced professionals stand ready to assist your organization as you prepare for GDPR. Choosing a knowledgeable advisor will help ensure that your efforts have maximum impact, even limited budgets and resources. Contact Secure Digital Solutions today to learn more!