Cybersecurity Collage

Without 3rd Party Security ‘Vendor Brokers’, AWS and Azure May Not Be For You

…at least for PCI anyway. It’s just too damned difficult to get all the security wrappers PCI requires without Vendor Brokers.

Cybersecurity has now be made too complex – by security vendors – to be able to mix-and-match with individual vendors from the AWS/Azure marketplaces. I don’t know of any single vendor who can cover even a majority of the PCI requirements related to platforms.

i.e.

  1. Firewall Management;
  2. Configuration Standard(s);
  3. Anti-Virus;
  4. Vulnerability Management;
  5. Patching;
  6. Access Control;
  7. Authentication Mechanism(s);
  8. Logging & Monitoring;
  9. Web Application Firewall; and
  10. File Integrity Monitoring

There are many reasons for this, one of which is that ever since security became a multi-billion £/$/€ a year industry, hundreds of companies have started up to try bring us the ‘silver bullet’ appliances.  Not only do silver bullets not exist in cybersecurity – and you should be shot for using the phrase in any way that’s non-derogatory – but where are the overwhelming majority of those companies now?

They either failed, or have been ‘collected’ by larger companies who have tried to duct-tape the disparate products into silver-bullet solutions.

Which have also failed.

It’s not that the original products didn’t work, some of them actually did, it’s that;

  1. Organisations threw technology at business problems without knowing why they were doing it;
  2. The big companies that collected the smaller ones tried to integrate the individual products together under one GUI, instead of unifying the functionality under a single code base; and
  3. There has never been, and there never will be, a one-size-fits-all solution to security.

But the market is still ripe for innovation, and there will continue to be companies starting up with the goal of bringing a single product to market that will catch the latest security hype/wave/buzz and make them their fortunes (UEBA for example).  They may even succeed, but only if they make their impact in the first year or two, otherwise the market will have moved on.

And if they’re VERY lucky, the larger companies will be naive / ignorant enough to buy them and save them the trouble.

Don’t get me wrong, I am not against combining single products into a larger solutions. In fact it’s the only way to go, but only if it’s done correctly.  Single product companies have 100% focus, which gives them drive, short-term goals, and a dedication to making their one product the best. The second you absorb that company however, every one of those attributes that put them on (or near) the top, are lost in the larger mix.  The functionality is diluted, innovation ceases, and the the whole thing quickly becomes obsolete.

True integration of functionality can only be accomplished with a single code base, and a single platform, which means that any organisation that absorbed the smaller companies better have a plan in mind to migrate not only the applications over to their growing solution, but they will need to consider all of the clients who bought the product prior to the M&A.  These guys often suffer from a total lack of customer service and support, and there’s no way they’ll buy into the larger program.

In my experience, the due diligence necessary to combine product companies is not overly abundant, and until it is, we should all be VERY careful when we look to resolve our security issues with multi-function solutions.

I call these Vendor Brokers ‘collage companies’, as the picture might be pretty, but it’s in no way whole.

Here are a few questions you might want to ask your potential providers;

  1. Can your solution replace some / most of my current functionality?
  2. Do you provide a consultancy ‘wrapper’ around these solutions to help us manage them against our business goals?
  3. Will the output from your solution feed into my current collection mechanism, or can my current output feed into yours?
  4. Are the various aspects / functions of your solution ‘home grown’, or obtained through acquisition?  If acquisition, how have you unified the back end code and platforms?
  5. How do you ensure that the different functions of the solution receive a similar attention to what the single product vendors provide?
  6. Do you have a single customer support process to handle all functionality questions?

Regardless of the shenanigans going on in the security product market, your choice of Vendor Broker should only be driven by what your risk assessment and gap analysis said you need, and your due diligence should cover any requirements you may have regarding integration and ongoing maintenance.

If is doesn’t, don’t expect Vendor Brokers to help, they have enough problems keeping their own houses in order. 

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GDPR Fines

GDPR and Cybersecurity, a Very Limited Partnership

If a security vendor has ever told you that the GDPR is imposing fines of up to 4% of annual global revenue for data breaches, they are either:

  1. ignorant of the standard; and/or
  2. lying to you.

Being generous, they may not actually know they are lying, the General Data Protection Regulation (GDPR) isn’t exactly easy to decipher, but even a cursory review tells a rather obvious story. I will attempt to address the following assumptions in the course of this blog:

  1. The GDPR is >95% related to enforcing the RIGHT to privacy, not the LOSS of privacy through data breach;
    o
  2. The maximum fines for ANY organisation are 2% of ‘annual turnover’ for even the most egregious loss of data through breach, not 4%; and
    o
  3. Fines are entirely discretionary, and an appropriate security program will significantly reduce any fines levied.

Wait, there are 2 types of privacy!?

Ask a lawyer in the EU what privacy is and s/he’ll likely quote Article 12 of the Universal Declaration of Human Rights: “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.

From a GDPR perspective, this equates to two of its three fundamental aspects. Grossly simplified these are:

  1. Explicit consent; and
  2. Legitimacy of processing.

In other words, the vast majority of the GDPR is concerned with obtaining explicit consent for the personal data collected, and then ONLY using that data for legitimate purposes in-line with the consent received.

Even when GDPR refers to ‘security’, it is more concerned with these two fundamentals than it is with security of the data itself. That is what they mean by “security of processing“.

However, from a cybersecurity professional’s perspective – and the third fundamental aspect of the GDPR – privacy also involves loss. i.e. The data was stolen during a breach, or somehow manipulated towards nefarious ends. This is a very important part of the GDPR, Hell, it’s a very important part of being in business, but it should never be used to sell you something you don’t need.

Maximum fines?

Of the 778 numbered or lettered lines of text in the GDPR Articles section, there are only 26 that relate directly to data security (or 3.34%). These are contained within Articles 5, 25, 32, 33 and 34.

Per Article 83(4)(a) (a.k.a. ‘2% fines’) – “(a) the obligations of the controller and the processor pursuant to Articles 8, 11, 25 to 39 and 42 and 43;

While Article 5 is contained within Article 83(5)(a) (a.k.a. ‘4% fines’), all but one line refers to security of processing, not the security of the data.

So, if it can be assumed that if the maximum fine for ANY data breach, no matter how egregious, is 2% of the annual revenue from the previous year (in the case of an undertaking), that 2% is what the EU considers the maximum for a fine to qualify as “effective, proportionate and dissuasive” (per Article 83(1)). Therefore, a fine of €10,000,000 would be reserved for any organisation with revenue over €500,000,000 annually. Fines are never there to put you OUT of business!

It must follow that if 2% is the maximum, then fines will go down the less egregious is your offence. Everything you need to determine the level of ‘egregiousness’ is contained in the 11 lines of Article 83(2)(a) – (k). Words like ‘intentional’, ‘negligent’, ‘degree’, and ‘manner’ are bandied around, all of which can be answered by you.

In this spreadsheet, I have taken a stab at adding specific questions to each of the (a) – (k) line items. Answer them all truthfully and you’ll get an indication of what I consider to be an appropriate fine based on your annual revenue: GDPR Fine Worksheet. Caveat: I am NOT a lawyer, and this is based entirely on my own experience, not anything resembling known fact.

Finally, bear in mind that as per Article 58(2), there are many ‘corrective powers’ that a supervisory authority can resort to long before levying a fine, including simple warnings (Article 58(2)(a)). Fines should be considered as a worst case scenario in their own right, let alone the amount.

Appropriate security program?

There is no such thing as 100% security, so the more you can demonstrate that your security program is appropriate to the levels of risk, fines should be the least of your problems. As long as you have everything from senior leadership buy-in, to incident response, to disaster recovery and breach notification – you know, the basics! – it is not a foregone conclusion that fines will even be considered.

Go here for more on what a security program should look like: What is a Security Program?

In conclusion…

In the UK, if you are an organisation that processes personal data and you were already a) complying with the Data Protection Act (DPA), and b) doing security properly, GDPR compliance would require only relatively minor adjustments. For those that weren’t, you have a lot of work to do now once the supervisory authority has the powers that GDPR bring to bear, and not much time to do it in (May 25, 2018).

That said, don’t do anything for compliance alone. Do it for the business, do it properly, and compliance will fall out the back end. So while it is reprehensible that security vendors are trying to exploit the GDPR for profit, if you fall for it it’s entirely your fault.

By the way, if you’re a business that is predominantly centered around the processing of personal data, the Article 58(2)(f) – “to impose a temporary or definitive limitation including a ban on processing;” can take you offline indefinitely. And yes, you can be fined on top of that.

I hate to say it, but don’t do anything until you’ve spoken to a lawyer.

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Virtual CISO

Are ‘Virtual CISOs’ a Good Idea?

Type “virtual CISO” into Google and you’ll get ~240,000 hits, with the top 10 being mostly vendors who offer this as a service. I have no doubt much of the remaining pages are the same.

In other words, just about every security vendor out there is seeing a need, and they want to be the ones to fill it. As a corollary, if organisations weren’t crying out for the service, no-one would be offering it.

I am no different, in that I too see a massive gap in senior leadership security expertise that no one in-house can fill. Due to price constraints, it is quite often inappropriate to fill such a senior and specialised role on a full-time basis. Where I differ is the length and function of the v-CISO, as I cannot see how an indefinite ‘outsourcing’ is in my client’s best interest.

Let’s face it, once you outsource the function of something, it is a very small step to try and outsource the responsibility for it too. And finally, if you got away with that, an attempt at shirking the accountability is never far behind. This is where both organisations asking for help, and v-CISOs alike, make their biggest mistake.

The v-CISO should never be a long-term proposition, which is why I call my service an ‘Interim Security Chief’. While this may seem like semantics, it’s the difference between doing the work for you, and enabling you to do it for yourselves.

First and foremost, a v-CISO should be a teacher and a mentor, not [necessarily] a ‘doer’. Yes, they can design big-picture processes, from secure architecture to governance charters, but they had better not be expected to own them. A good v-CISO is nothing more than an consultant at the senior management level, and any deliverables must be sustainable long after they have moved on.

That said, I see nothing wrong with a v-CISO remaining part of ‘steering committees’, providing ongoing security awareness training, or even taking part in incident response testing. But, once the CISO functions have been absorbed internally, the v-CISO becomes part of the cycle for continuous improvement only. They stay around to provide strategic input on industry trends and the changing threat landscape, they don’t dictate the enterprise goals.

What You Should  Expect From a v-CISO

These are the three main things you should expect from a v-CISO, take particular note of the transience of each deliverable.

  1. Governance Charter Development – There is no security program without Governance, and there is no better platform onto which the v-CISO can pass on their operational function. This committee can in fact replace the v-CISO in due course, but may bring them back in as a trusted advisor or SME. The members of the governance committee will share the CISO function amongst themselves based on individual capability, and their meetings will bring it all together.
    o
  2. Policies & Security Awareness Training – Along with governance, policies are intrinsic to a security program, and along with the formation of that committee, represent the most important part of a v-CISO’s role. Unless the polices are in place, and all employees appropriately trained, nothing else they try to do will work effectively.
    o
  3. Process Development – Security programs consist of a number of critical processes, all of which must be developed, tested, tested again, and take their place in the never-ending cycle of improvement and business as usual. These are the big ones:o
    • Risk Management – Includes the enterprise-wide risk assessment and risk treatment procedures.
    • Vulnerability Management – Keeping up with the threat landscape.
    • Vendor Due Diligence & RFPs – Significant aspects of the security program will likely be outsourced to skilled providers, so the right questions must be asked.
    • Event Management & Incident Response – Bringing all the controls together into a business saving process.
    • Disaster Recovery & Business Continuity – What to do if everything goes completely pear-shaped.

Anything else the v-CISO does will depend on the organisation’s needs and the v-CISO’s skill-set.

But what about Strategic Advice, Board Level Interface, Regulatory Compliance Lead and a whole host of other fancy names / clichés? Yes, these are all important, but are utterly meaningless until the basics are in place.

Any security program put in place by a v-CISO must be in-line with the business’s goals, appropriate to their needs, and sustainable in their absence. So if you’re on the market for a v-CISO, you had better know what you need, or you’ll get what a salesperson thinks you asked for.

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o

Change Your QSA

Too Scared to Change Your QSA?

Or perhaps the question should be; “Can’t be bothered to change your QSA?

Or an even worse scenario; you know you can’t change your QSA because the new one might discover things you’ve been hiding from the last one!

I can almost empathise with the first two, but if it’s the third scenario you deserve the bad things that will happen when you get breached.

The fact is, if you have been working with a good QSA, not one of the challenges I list below will apply to you, Changing QSAs, or even QSA companies will not be an issue. You will have been doing security properly, and not just faking compliance.

Challenges:

A significant number of organisations are faced with at least 1 of these 5 main challenges;

  1. Lack of Continuity – Employee attrition is inevitable. QSAs have historically bounced from one QSA company to the next following the money. Which has been abundant for almost a decade now. This has left many clients in the unfortunate position of having to start all over again with another QSA. Often one who has received little to no hand-over.
    o
  2. Lack of Guidance – This is the QSA’s only real job. Other than writing the second half of the Report on Compliance, ALL of the remediation work belongs to the client. The role of the QSA is to ensure that the client NEVER hits a roadblock. QSAs are supposed to have ‘been-there-done-that’, so “What’s next?” should never be a question the client has to ask.
    o
  3. Inconsistent Opinions – Every security consultant has a different skill-set. Some are network wizards, others know encryption, most should be very familiar with policies and procedures. What happens when your last QSA agreed something that your current QSA won’t accept? Who is accountable for the loss of resource and/or capital cost?
    o
  4. Starting Over Again Every Year – Too many  QSAs are ‘just QSAs‘, with little experience or capability in fitting PCI into sustainable security processes. If your PCI compliance looks like an annual project, it is. Validation of compliance should be a simple process that should fit neatly into your BAU program. If it doesn’t, there’s a very good chance your QSA is at least partially to blame.
    o
  5. Black-Hole Communications – If you expect your QSA to be a project manager, you have completely misunderstood the dynamic. But if you expect them to respond to emails requesting guidance in a timely fashion, you should. A QSA is there to tell you everything you have to do to achieve compliance, that’s their job, they must be readily available.

Mitigation:

OK, so those are all the bad things, how do you fix them? Easy, choose the right QSA in the first place!

Facetious yes, and likely a moot point, but it’s never too late to change:

  1. For Lack of Continuity – All good QSAs have a methodology; Have you seen it? Does you QSA even have one? If the answer is no, you don’t have a good QSA. Continuity is simple, it just requires discipline, and a plan.
    o
  2. For Lack of Guidance – As stated above, this is the QSA’s only purpose, if they can’t provide it, find someone who can. Interview your QSA(s) before letting them onsite, but have your questions prepared. Insist on having access to QSAs suitably qualified in ALL 12 DSS Requirements. You’ll never find this in a single QSA, unless it’s one of the 3 that I know that come close (I’m not one of them).
    o
  3. For Inconsistent Opinions – Agree a process whereby the QSA company accepts mitigation plans or compensating controls, not individual QSAs. Agree, in writing, that ALL QSAs they send will accept a company approved option.
    o
  4. For Starting All Over Again – This is as much your fault as the theirs. If you had a security program in place that appropriately covered your business, PCI would fit into it, not the other way around.
    o
  5. Black-Hole Communications – Vendor Due Diligence + Service Level Agreements + Vendor Management. Period / Full Stop.

Changing QSAs every few years is a best practice, you should ALWAYS want fresh eyes on such a critical process. If changing your QSA is too difficult or inconvenient, it says a lot about both your current QSA, and your organisation’s attitude toward security;

They both leave a lot to be desired.

Here’s some old guidance I threw together a while back; Selecting the Right QSA for Your Business

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All About the Data

Forget Cyber, Forget Cloud, It’s ALL About the Data!

Ever wonder why data breaches are now called cyber attacks, or an application on the Internet is now called The Cloud? It’s for the same reason that Coca Cola is constantly changing it’s ‘look’, adding ‘new’ flavours of what is basically the same sugary mess. And why they’ve changed their slogan FORTY SEVEN times in their 125 year history;

To keep things fresh, to keep you thinking about them, and of course, to help you spend money.

So is this necessarily a bad thing for the field of information security? The answer is clearly no if these marketing ‘tricks’ actually help keep you secure though valid awareness programs and good services. But a resounding YES if it’s just a new buzz-phrase used to sell the same services with less due diligence.

Too many vendors and self-interested lobby groups are frighteningly good at demand generation. From new buzz-phrases, the invention of perceived needs, and playing on an organisation’s fear of losing a competitive edge, these have all been the cause of many bad purchasing decisions. This is especially frustrating when the tools for making good decisions have been around for decades. Literally.

For example; ISO 27001 – probably the best known and de facto security framework – has it’s roots in BS 7799 first published in 1995, ISACA’s COBIT was released in 1996, and even PCI (which is just a controls based standard for the protection of cardholder data) has some merit in its 10th year in existence. If these aren’t enough, the ages-old – but still VERY much alive – concept of Confidentiality, Integrity and Availability has been around for so long that no-one seems to know when it started.

And these are just the overarching frameworks for the security of data, beneath them you have equally well known, mature, and readily available tools for the protection of your data assets:

1. Governance – The Business side and the IT side having meaningful conversations;

2. Risk Assessment – An examination of the business needs applied to the current ability to achieve those goals;

3. Vendor Due Diligence – a THOROUGH review of the external help you’ll likely need;

4. Asset Management – You can’t manage what you don’t even know you have; and

5. Vulnerability Management and Change Control – If you have absolute control over the changes you make internally, the only things that can increase risk are from the outside. These two tools work hand-in-hand.

All of these tools are covered to a varying degree in the above frameworks, and represent standard good security practices established for longer than most of us have been alive. Without these processes in place, you don’t have data security. Full stop.

So if they are that established, why are they not as well known and pervasive as they should be? Simple, and for the same reason no-one likes paying for insurance; there is no obvious positive impact on the bottom line. Where’s the ROI for spending money on security? But this assumes that an ROI involves making MORE money, but is not LOSING money just as impactful? Fines, damages / reparations, and the inevitable loss of reputation all have significant negative impact.

Instituting an appropriate level of data security for your business is actually quite simple, keeping it in place requires much more effort but is equally simple; follow the decades-old advice of the existing frameworks.

[Ed. Written in collaboration with Voodoo Technology, Ltd.]

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