Top 10

Froud on Fraud’s Top 10 Cybersecurity Technologies to Implement in 2017

In direct response to a certain organisation’s ‘Top 10 Cyber Security Technologies to Watch in 2017’, [cough, Gartner, cough], I have come up my own list of bleeding edge security technologies that every organisation should spend millions of $/£/€/¥ on.

Yes, even if you don’t MAKE millions, you should borrow the money and buy them anyway.

Being honest, my fight to bring security ‘back to basics’ has failed – despite my enormous 210 person following – so I have decided to sell-out and promote nothing except buzz-phrases and acronyms. You know, like everyone else.

However, I am convinced that if you buy, implement, and actually take these technologies seriously, you can forget the security basics. The combination of these 10, never-seen-before, shiny new objects will provide the silver bullet you’re looking for:

  1. Directorate Approbation Paradigm (DAP) – Historically, achieving ‘management buy-in‘ was the ultimate goal for anyone attempting to implement a security program. Quite rightly, caring about the future of an organisation was considered naive, and proponents of this stone-aged technology were left begging for work on LinkedIn. Some of these poor souls even became CISOs. Now, with DAP technology, every single person in an organisation will take security seriously, even if their bosses don’t!
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  2. Command & Control Commission (CCC) – While not strictly a technology the CCC is responsible taking the output from the EIC below, combining it with the DAP above and obtaining the budget to buy everything else on this list. This is the spider in the middle of the web, making sure that all technologies work together. Called ‘governance‘ in the old days, the new CCC is clearly superior given that you’ve never heard of it, and it’s an acronym.
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  3. Protocol, Method, & Archetype Orchestrator (PMAO) – Much as leeches were seen as the go-to technology in medieval medicine, ‘policies, procedures and standards‘ were seen as a foundation for every security program. While clearly nothing more than a quaint superstition, they nevertheless laid the groundwork for the PMAO revolution. Imagine it; a series of artefacts designed to record not only an organisation’s entire security culture, but their process knowledge and system baselines as well! No way just policies, procedures and standards could do all of that!
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  4. Exposure Investigation & Computation (EIC) – I almost feel sorry for the poor saps who only had the ‘risk assessment‘ process to measure their risk profile. Can you imagine basing you risk treatment and technology purchasing decisions only on expert opinion and business goals!? Instead, EIC, in combination with AI, big data, The Cloud, and fairy dust, can tell you exactly how many millions to spend on technology! No more embarrassing moments when you try to explain to your boss how you tried to save them money by fixing the actual problem! Like people and process could ever be the problem!
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  5. Intelligence Preservation Administration Schema (IPAS) – Can you imagine the nerve of the International Standards Organisation when they came up with the Information Security Management System (ISMS)? A so-called ‘framework’ designed for “systematically managing an organization’s sensitive data” with – and you won’t believe this- “a set of policies and procedures”! How naive! Instead, with IPAS, you can basically ignore the hard work and common sense approach to doing security properly and hide behind an expensive appliance with flashing green lights! Blinking green, you know it’s working!
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  6. Transformation Regulation Authority (TAR) – Before the advent of TAR technology, organisations across the globe relied on a ‘change control board’ to ensure that unmeasured risk was not introduced into an environment. As yes, once again, actual humans – apparently those with ‘expert’ knowledge – were allowed to determine what was right for the business. A clearer case could not be made to put this in the safe ‘hands’ of technology written by someone else.
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  7. Episode Reply & Adversity Restoration (ERAR) – We’ve all seen those commercials from the 50’s where attractive actors extolled the virtues of smoking? Well, ‘incident response & disaster recovery‘ were just as misleading, and just as dangerous! Like anything involving people and process could possibly help you stay in business! ERAR on the other hand, will not only detect bad things happening, it will keep your business up and running! Surely THAT’S worth a few million all by itself!!
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  8. Capital Durability Projection (CDP) – The future of any organisation should never be placed in the hands of those who care. The experiment called corporate social responsibility failed because it was assumed that it’s the people who are the most important aspect of a business. At least now we know it’s money that’s most important, so the old concept of ‘business continuity planning’ can be replaced by EDC and those making the world better with technology. Finally the people can be safely ignored.
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  9. Asset Management (AM) – This is one aspect of security where technology is actually sadly lacking. Asset management is the centre of everything, and without it, no other aspect can be truly be done well. Spreadsheets just don’t cut it, and no GRC that I’ve seen gives asset management its due. This much change, even in The Cloud.
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  10. Continuous Compliance Validation (CCV) – This is an idea whose time has come, it’s about time technology provides a REAL solution to overly manual processes.

All facetiousness aside, I am a huge fan of technology. Or more accurately, I am a huge fan of the appropriate application of technology. If you buy something based on anything other than 1) the results of your risk assessment, and 2) answers to the RIGHT questions, you have no business being in charge of a budget.

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GDPR Vulture

Want on the GDPR Bandwagon? Be Qualified, or Stay the Hell Off!

First, what do I mean by ‘qualified’? – I mean that the only people truly qualified to lead a GDPR project are lawyers specialising in privacy. That’s it.

EVERYONE else only has a part to play. Often a very significant part, but that’s it for them as well. A part.

I’m NOT saying that every single organisation has to make the significant investment in a privacy lawyer to meet the intent of GDPR. I’m saying that the only ones qualified to determine ‘intent’ in your organisation’s specific context, are privacy lawyers. No-one who is an expert in information technology, or cybersecurity, or any other subject is qualified …unless they are also a privacy lawyer.

To even further labour the point, a qualified person is neverCertified EU General Data Protection Regulation Practitioner …unless – you guessed it – they are also a privacy lawyer.

I’ve seen every type of vendor from Cyber Insurance providers, cybersecurity consultants, to single-function technology vendors, make the most ridiculous claims as to their suitability to ‘help’ with GDPR. All to make a bit more money while the GDPR bandwagon is on the roll.

The prize so far goes to a consultant who maintains that the entire GDPR can be ‘operationalized’ under the ISO 27001 standard. Unfortunately this attitude is pervasive, as no organisation seems to want to share the opportunity with appropriate partners. The attitude of ‘land-the-gig-and-we’ll-work-out-how-to-deliver-it-later’ cannot apply here. GDPR is a law, one with significant penalties attached, so unless you really know what you’re doing, stick to what you know. And ONLY what you know.

For example, I can be [very] loosely categorised as a ‘cybersecurity expert’, so that limits my ability to help with GDPR to:

  1. Data Security – As I’ve said a few times now, of the 778 individual lines of the GDPR Articles, only 26 of them are related directly to data security. That’s only 3.34%. Yes, I can help you implement ISO 27001 to cover that 3.34% (a.k.a. “appropriate security and confidentiality”), but if GDPR is the only reason you have to implement ISO, don’t bother, you’ve missed the point;
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  2. Secure Technology Implementation – GDPR is not about technology, but the implementation of GDPR will have significant technology implications. From collection of consent (Recital 32), to age identification (Recital 38), to the rights to erasure and rectification (Recital 39), technology will play a big role. All of this technology will require appropriate security wrappers in-line with demonstrable good security practices; and
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  3. Governance Design and Implementation – Any organisation that has a Governance function already has a GDPR Implementation Team in place. Since there can be no true Governance without full departmental representation (Technology, Security, Legal, PMO, Sales, Marketing and so on), it follows that the Security team will have full understanding of GDPR’s impact from the Legal team. In turn, Technology and Security will have significant input to Legal’s decisioning, and it’s this ‘negotiation’ under the Governance umbrella that gives GDPR its ‘organisation specific context’.

This should be more than enough for any security consultant, but apparently it’s not enough for some consultants who want to replace Governance all by themselves. But, what’s wrong with partnering up with others to do the parts you absolutely should not touch? Is it not better to be really good at the one thing you do for a living and be part of a team of experts who can cover the other bases?

To put this another way, do you really want to ruin your reputation by lying to your clients now, or be the resource they come to to solve every similar problem from this point forward? Do you want to sell used cars or be a trusted advisor?

GDPR, like security, is not complicated. It’s actually very simple, just BLOODY difficult to implement. There is not one individual who can simplify this for you, not even a privacy lawyer. So if you’re looking to implement GDPR, you can rest assured that anyone who is a) not a privacy layer, AND 2) not part of a team of experts with collaborative skill-sets, AND 3) trying to sell you something, should be listened to with caution.

As always, I am not going to lay the blame entirely at vendor’s feet, they too have a business to run. In the end, the only people who get the answers they need on GDPR are the ones asking the right questions.

You MUST do your homework!

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Human Resources

Human Resources, the Missing Piece From Every Security Program

Like a ‘service on the Internet’ – which we’ve had for decades – is now called The Cloud, Human Resources is now known by more touchy-feely names. Talent, People, Employee Success, all sound great, but they don’t represent a fundamental shift in the functions they perform. Or even HOW they perform those function from what I’ve seen.

Regardless of what the department is called, I’ve never seen one take an active part in their organisation’s security program. Not one, in the better part of 20 years, and as I hope to demonstrate, this a significant loss to everyone concerned.

HR are usually the very first people in an organisation that you talk to, often even before the interview process begins. They are first ones who can instill the security culture in new candidates from the get-go. Anyone who has tried to implement a security awareness program knows that the loss of this ‘first impression’ makes the task exceedingly difficult. Unnecessarily so. If the joiners had just been told how important security is, AND received appropriate training, they would just accept it as a fact of life. Try and force it on them after they have already learned the bad behaviours and your impact is enormously reduced.

But there are 5 fundamental areas in security, that with HR’s help, would be significantly more effective:

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  1. Onboarding – As I have already stated above, HR are the first people with whom new employees have interaction. The onboarding process is the perfect time to get everything out on the table. From Acceptable Use Policy / Code of Conduct, to security awareness training, security can be instilled from the very beginning. Now imagine if the CEO had a welcome letter prepared that emphasised the importance of data protection / privacy. Imagine further that this letter detailed what is expected them, and to take this aspect of their jobs seriously. There is ZERO cost associated with any of this, yet the positive impact of the security culture is immeasurable.
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  2. Role Based Access Control – The hint is in the title; ROLE based. If HR broke the org chart into specific roles, granting appropriate access to all joiners, movers , and leavers would be that much simpler. In theory, everyone gets what I call ‘base access’, usually consisting of email address and domain access. A role could then receive everything they need to perform their basic job functions automatically. Then, an individual could apply for any additional access they require. Everything is now recorded appropriately, allowing for not only a demonstrable access control process, but the raw material for all access reviews. Especially those with elevated privileges.
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  3. Policies, Standards, and Procedures – If you accept that policies represent the distillation of the corporate culture, standards are the baselines of ‘known good’ configurations, and procedures are the sum of all corporate knowledge, why aren’t these distributed at the beginning? First, most organisations don’t even HAVE these documents in place, at least not in a condition to meet the above criteria anyway. Second, even if they did exist, HR take no part in their distribution. Why not? If they assisted with RBAC per 2. above, surely it’s a simple step to have the relevant department heads which documents should be attributed to a specific role? Can you imagine it, every new employee knows 1) what they should and should not do, 2) how to do it, and 3) what to do it with!
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  4. Security Awareness Training – OK, so HR are not security experts and will take very little part in developing the SAT content, but they should be involved in HOW it’s delivered. HR are the people experts, IT and IS professions are usually quite the opposite. Training written by me would suit technical people, who’s going to write it for everyone else? After all, it’s usually the ‘everyone else’ who are the cause of most of the issues. HR should also be tracking the annual SAT program and flagging any issues to the employee’s supervisor etc.
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  5. Role Specific Procedures – This one is a bit of a stretch, but I can’t just have 4 bullet points. The concept is that part of everyone’s job description is to document every one of their repeatable tasks. If the procedure already exists, they could be challenged to improve it. In almost every job I’ve had there was a 3 month probation period. This review, and every performance review from that point forward could include a procedure section where failure to develop appropriate content has negative repercussions. Or, for the glass-half-full folks, great documentation has rewards attached to it. Imagine how nice it would be is every new starter just moved forward and didn’t have to waste time re-inventing the wheel.

The fact is most HR departments are not geared to perform any of the above functions. They are simply not trained to do so. I can’t help thinking this is a terrible waste.

I’d actually love to hear from some HR folks, even if you’re gonna tell me I’m way out of line! 🙂

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PCI to GDPR

Going From PCI to GDPR? You Are Starting from Square One

To be very clear from the outset, if you think the PCI DSS is a good ‘stepping stone’ to GDPR, you need to do a lot more homework. Data security represents less than 5% of the entire GDPR, and the PCI DSS is – in my admittedly biased estimation – no more than 33% of a true security program.

I have, for years, railed against the PCI DSS as an inadequate baseline for security, and even the card brands and the SSC have never claimed it be more than what it is; a set of MINIMUM security control related to the protection of cardholder data. Well, except for this ill-advised and rather naive quote perhaps;

People come to me and say, ‘How do I achieve GDPR compliance?’… Start with PCI DSS.

The PCI DSS was written for ONE very specific purpose, and it’s only ego, desperation, or vested interest that would lead people to think it’s anything more.

The reason for this particular blog is reading articles like the two samples below. It’s articles like these that lead organisations who don’t know better [yet] into making bad decisions. They also give cybersecurity professionals a bad name. Well, worse name, unscrupulous QSA companies and greedy product vendors have already caused significant damage.

Article 1, and by far the most egregiously overstated quote [so far] is from an article in SecurityWeek (PCI 3.2 Compliant Organizations Are Likely GDPR Compliant); “Any company that fully and successfully implements PCI DSS 3.2 is likely to be fully GDPR compliant — it’s a case of buy one and get one free.” Given the author’s apparent credentials, he should know better. Since when does the PCI DSS deal with explicit consent, or children’s data, or the right to erasure/correction/objection/portability and so on.

Then, in the very recent article 2; How the PCI DSS can help you meet the requirements of the GDPR – the author states that; “Failure to report breaches attracts fines of up to €10 million or 2% of annual turnover, whichever is higher. Breaches or failure to uphold the sixth data protection principle (maintaining confidentiality and integrity of personal data) can attract fines of up to €20 million or 4% of annual turnover (whichever is higher).

No part of the above statement is factually correct:

  1. Just because Article 33 – Notification of a personal data breach to the supervisory authority is included in Article 83(4)(a) – General conditions for imposing administrative fines, it does NOT mean that failure to respond in 72 hours will attract a fine. There are many caveats; e.g. Recital 85 states ; “the controller should notify the personal data breach to the supervisory authority without undue delay and, where feasible, not later than 72 hours after having become aware of it (Recital 85)”‘
  2. sixth data protection principle“? – Nothing to do with confidentiality and integrity, assume author meant the seventh principle (security).
  3. Maximum fines for data breaches are 2% (for an undertaking, a.k.a. a group of companies), not 4%.

The author then goes on to say; “The ICO is also likely to treat inadequate or non-implementation of the PCI DSS as a failure to implement appropriate “technical and organisational measures” to protect personal data…” which is clearly not the case. The ICO has always left loss of cardholder data / PCI up to the card schemes, and have already mentioned ISO 27001 in their “The Guide to Data Protection“.

Every article I have read on how PCI helps with GDPR, is at best, hugely overstated, and at worst, full of self-serving lies. I can fully appreciate the desire for cybersecurity companies (especially QSAs) to branch out from the massively price compressed and ultimately doomed PCI space, but to do so in this manner is unconscionable.

Unfortunately if you are falling for this advice, I can safely assume that you:

  1. have little idea of how limited the PCI DSS is, even as protection for the only form of data to which it’s relevant;
  2. have little idea what the GDPR is trying to achieve if you think a bunch of security controls are that significant a component; and
  3. don’t actually know what an ‘appropriate’ security program should look like.

This is actually not meant as a criticism, these things may not be your job, but if you have any responsibility for GDPR, you absolutely must learn to ask the right questions.  I will finish with some reasoning below, but leave to up to you work out whose guidance to take.

PCI and GDPR are very far removed from each other.

  1. Data protection Articles are only 3.34% of the Regulation – yes, I actually worked this out on a spreadsheet. That means the GDPR is 96.66% NOT security control relevant. Of course IT and IT security are important and intrinsic to GDPR, but PCI does not cover anything else other than than those things.;
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  2. PCI DSS makes no mention of the need for Governance – PCI compliance is almost invariably an IT project, and while this is obviously wrong, does not prevent organisations from achieving compliance. In GDPR, the IT folks have absolutely no idea where to start. Nor should they, IT/IS people aren’t lawyers and they do not control the organisation’s direction, they are business enablers who do as bid by senior management. GDPR requires a team effort from every department, which is exactly what Governance is.;
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  3. PCI DSS is about compliance to an already defined standard of security controls, the GDPR requires a demonstration of ‘appropriate security’ measures – For example, what if your annual risk assessment showed that the PCI controls were actually excessive? Could you scale some of them back? No, you can’t. Alternatively, what if your risk assessment showed that they weren’t enough, could your QSA insist that you went above and beyond? Again, no, so what the hell is the point of the risk assessment in PCI?
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  4. Only QSAs that started out as security consultants [not the other way around] have the skill-set to provide any help at all. If they were experts in ISO 27001, CoBIT, NIST etc., then yes, they can help you both define and implement ‘appropriate security’. If all they did was pass the QSA exam, the only guarantee you have is that they can read.
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  5. The PCI DSS can never keep pace with the threat landscape – It’s already way behind, and with its complete inability to change significantly, the DSS can never represent appropriate security. If the DSS did change significantly, both the card brands and the SSC would be lynched. Millions of organisations have spent BILLIONS on PCI, they will simply refuse to start all over again. GDPR on the other hand has no defined controls, it’s up to YOU to show that your controls meet the measured risk.

In the end, the only way PCI can help with GDPR is to use the assigned budget to do security properly. You will never reach GDPR ‘compliance‘ using PCI, but you will achieve both PCI and GDPR compliance on the way to real security.

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GDPR

GDPR: Focus on the WHY First, Not the HOW

By far the most common answers to the questions; “Are you worried about GDPR?” and “If yes, why?”, are, in this order:

  1. The fines;
  2. Possible loss of reputation;
  3. What’s GDPR again? (no, unfortunately I’m not joking)
  4. The cost / complexity; and
  5. Board-level accountability (a.k.a. it’s a law now).

While from a business perspective I can empathise with most of these, I have zero empathy for 3. That’s not really the point though, which is that not one person I have ever spoken to about GDPR got anywhere near touching on the actual reason GDPR is here in the first place;

It protects a human right.o.

If you haven’t read the Universal Declaration of Human Rights, and surprisingly few seem to have done so, it forms what I will call a code of conduct for what the United Nations calls the ‘human family’. So while it’s not a global law (per se), and somewhat impractical taken in its entirety, you have to be something of a sociopath not to recognise its basic goodness. It just fits. For example, and most relevant to this blog:

UDHR Article 12

“No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks.”

Fair enough, right?

Therefore, the GDPR starts out of the gate with:

GDPR Recital 1

The protection of natural persons in relation to the processing of personal data is a fundamental right. Article 8(1) of the Charter of Fundamental Rights of the European Union (the ‘Charter’) and Article 16(1) of the Treaty on the Functioning of the European Union (TFEU) provide that everyone has the right to the protection of personal data concerning him or her.

And while the GDPR does go on to say things like; “The right to the protection of personal data is not an absolute right because it must be considered in relation to its function in society and be balanced against other fundamental rights... (Recital 4)”, it’s meaning and intent remain both clear and unwavering.

So if you want to know why fines are in place, why loss of reputation is such a big deal, and why infringements will be breaking the law, look no further. Compliance should go way beyond being just another consideration in your effort to demonstrate corporate social responsibility. This is not just some PR exercise you can fake your way through.

On the other hand, why is this so one sided against businesses? Why do they have to do all the work? I have made no secret of my disdain for people who don’t take responsibility for their own lives and actions. People who blame retailers for using personal data in ways they resent when they were the ones who gave it away without question. Even people who blame criminals for stealing their identity when it’s the victim themselves who made it possible by posting their entire life on social media.

When was the last time you read Google’s T&Cs? Or iTunes? Or anyones? No, I haven’t either.

I have long contended that your privacy is a currency that you spend for the conveniences you crave. GDPR is there to make the risks of spending it far more transparent. Or as Angela Boswell (a privacy lawyer, DPO, and GDPR implementation lead for her organisation) puts it; “What GDPR intends is to put the choice of ‘if’ and ‘to what extent’ back in the hands of the data subject.

So while organisations will have a lot more responsibility moving forward, you should still do your homework before sharing personal data.

But in the end, the main reasons it’s the businesses who are now [mostly] responsible for protecting people from themselves are clear. For years, many businesses who should have been guarding your privacy, weren’t. And those businesses who were supposed to protect the data they had, weren’t. Not even close. This will all change under GDPR.

In theory however, the businesses who were already doing the right thing are [for all intents and purposes] GDPR compliant, it’s only those described in the paragraph above who now have a really tough time ahead. GDPR is and extension of, and replaces the Data Protection Directive (Directive 95/46/EC) which has been out for 22 years! You really should not be starting from scratch here.

Depending on your business, GDPR might get tricky as you progress through it, but every organisation starts out the exact same way: By mapping your business processes (at both the individual asset and ‘asset interdependency’ level). This does not require a lawyer, and isn’t something you should not already be doing. If you don’t even have this in place, you will likely never be able to demonstrate the appropriateness of the ‘extent and proportionality’ of your data processing should things go wrong.

If I was a supervisory authority (e.g. the ICO here in the UK) I would reserve my biggest penalties not for those who aren’t compliant, or even necessarily those guilty of a minor infringement, it would be for those who have done nothing.

If that’s you, you’ve already wasted ~13 months of the 2 year run-up to GDPR’s application. There will be no ‘grace period’ after May 25th 2018, you’re IN the final stage. So you only have ~11 months left before the penalties can be applied. You must start asking the right questions of the right people now, and if you don’t know what and who they are, I suggest that’s where you start.

This is very basic, but it’s a beginning; Preparing for the General Data Protection Regulation (GDPR) 12 Steps to Take Now

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