CISO Sacrifice

How to Hire a CISO

In my experience, the hiring of a CISO is one of the last things on the minds of the overwhelming majority of Board of Directors (BoD). Well, maybe more accurately; it’s the last role they want to hire. Who wants to spend money on security? Where’s the ROI? While there is often significant kudos for corporate responsibility, its effects on the bottom line are invariably lost in translation.

I’ve written more than enough blogs on why cybersecurity is so essential to every organisation. Even tried to spell out some of its many benefits, but 180 subscribers will hardly change the course of a multi-billion £/€/$/¥ industry.

However, I will count this blog a HUGE success if I succeed in one, and especially both of the following:

  1. An organisation hires the exact right person for their cybersecurity needs; and/or
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  2. A prospective CISO asks all the right questions and gets the right job for them.

By far the biggest challenge for organisations in hiring a CISO is doing it for the right reason(s). Unfortunately the reason, 99 times out of 100, is necessity. From landing a big contract, to regulatory compliance, to post-breach PR, the CISO role is often nothing more than an empty suit. Compound this with the BoD having no idea of the right questions to ask the prospective candidates, the whole thing likely started out with little idea of what they were actually trying to achieve.

Security is not about technical requirements, it is a business process, and until the BoD see it as such no CISO job description (JD) will ever land the right candidates. In security, if you’re not an expert, never ask for what you want, find someone  who can fully detail the things you need. You’d be amazed how often these things are very different.

Steps to Hiring the Perfect CISO

But first, we need to stop thinking about the CISO as a person, CISO is a function. Or rather, a series of projects that culminates in a function. Security begins with a plan, then evolves through several phases into a coherent cycle of business enabling processes. I’ve never met a single individual with either the skill-set, or even the interest, to perform all of these phases. I for one would rather chew tinfoil than babysit something that does not require fixing.

Second, I am going to assume that the hiring of the CISO is going to be managed by the BoD, if not, none of these steps make sense.

Finally, I am going to use the types of CISO I defined in The 3 Types of CISO: Know Which You Need to illustrate my point.

Step 1: BoD must finalise three things: 1) their Mission Statement, 2) their Value Statement(s), and 3) their short / medium / long-term business goals.

Step 2: BoD uses all resources at their disposal to find the right resource(s) to turn the Mission/Values/Goals into an appropriate security strategy.

Step 3: Hire a p-CISO (Planner) for Phase 1 – skill-set prerequisites must include:

  • drafting Governance charters and policy sets;
  • standardising and performing initial risk assessments;
  • controls gap analysis;
  • developing business impact analyses (BIA);
  • defining a basic set of minimum security controls; and
  • chairing a Governance Committee meeting (this is a requirement across all 3 CISO types).

[Once Phase 1 tasking is roughly 75% complete, Phase 2 can begin. the p-CISO will be expected to fine-tune the draft JD for the e-CISO and hand over all relevant knowledge / duties.]

Step 4: Hire an e-CISO (Executor) for Phase 2 – skill-set prerequisites must include:

  • matching Policy Set with both business goals and the prevailing corporate culture;
  • socialisation and distribution of procedure and standard document coordination to relevant SMEs;
  • integration and centralisation of security control output into a unified incident response capability;
  • assignment and formalisation of all security responsibilities; and
  • implementation of disaster recovery (DR) and business continuity planning (BCP).

[Once Phase 2 tasking is roughly 75% complete, Phase 2 can begin. the o-CISO will be expected to fine-tune the draft JD for the o-CISO and hand over all relevant knowledge / duties.]

Step 5: Hire an o-CISO (Optimiser) for Phase 3 – skill-set prerequisites must include:

  • performing an objective review of all security controls including policies (with Internal Audit if available);
  • maintain their aspect of the company-wide Risk Register in-line with the security strategy and business goals;
  • formalise management information and security/risk metrics into a BoD-level reporting process; and
  • implement a cyclical program for continuous improvement.

Sample Phased Approach

That’s it, 5 simple steps. Very difficult and potentially expensive steps, yes, but simple nonetheless. Clearly these steps are VERY high level, and there is a lot more detail involved than that. This process could also take many months or even years. But the hiring of a CISO is not about finding people, it’s about committing to an idea and doing whatever it takes to bring that idea to life.

For that to happen, the BoD must stay involved. For the CISO roles as defined above to succeed the BoD needs to use as much of its influence as necessary to fully support them. A dotted line reporting structure directly to the BoD works best.

In my experience, if you’re looking to hire a CISO to sort out your security, you’ve already started down the wrong path. It’s the CISO who usually ends up paying the price.

If you’ve made it this far, you are probably thinking that the title of the blog should have been: How to Implement a Security Program. And you’d be right, it should, but the people wanting to hire a CISO probably wouldn’t have read it.

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Disruptive Innovation

Enough With the Disruptive Innovation. Collaborate or Fail.

[This is taken in large part from from an earlier blog, but I feel it needs updating to include more than just payments.]

‘Disruptive Innovation’ has become a common cry for anyone wanting to displace the existing players. It is defined as; “an innovation that helps create a new market and value network, and eventually disrupts an existing market and value network (over a few years or decades), displacing an earlier technology.

Unfortunately the original concept is now grossly misapplied. But like how ‘irony’ now has several meanings, I guess disruptive innovation will have different meaning based on its context.

However, I’ve never heard anyone using the phrase ‘Sustaining Innovation’, which; “does not create new markets or value networks but rather only evolves existing ones with better value, allowing the firms within to compete against each other’s sustaining improvements.

So why is everyone so interesting in disrupting the existing ecosystems? And by “everyone” I of course mean those who are trying to either break into market, or those trying to wrest even more control for themselves. In payments – as my example -, non-cash payments work [mostly], and you have a large degree of faith in your bank’s ability to protect your monetary assets. Do you really want the whole thing to change? Do you even know what it is that you want that’s different?

But do things even need to change? Well yes actually, they do. And are there innovations available NOW that make the payments process easier, cheaper, and more secure for the consumer? Yes, there are. However, can we expect the entire payment industry to throw out everything they have spent billions on over the last few decades, are used BY billions, just to make room for every start-up with a good idea? No, we can’t, and that’s the real issue here.

In the last 10 years there have only been 2 true [potential] disruptors in the payments industry; the mobile phone, and block chains (Bitcoin et al), neither of which has achieved anywhere near its full potential. Yet. Not because the technologies are flawed [necessarily], but because the introduction OF the technologies was done poorly. For mobile devices, the payments challenges included the ‘fight’ between NFC and BlueTooth, the numerous options for security on the device (Secure Elements, Trusted Execution Environments and so on), and the presumed insecurity of the technology overall. For block chains is was, and still is, the almost complete lack of understanding of how they even work in the first place. I’ve looked into them and I still find the concept nearly incomprehensible.

But even these disruptors need current context, and they represent a fundamental shift from our overly complicated view of payments back to its basics; I go to work to earn value (money), the value gets stored somewhere (a bank), and I access the value when I want it regardless of time or location (mobile payment). This would suggest that the only disruption we really need is the disintermediation of some of the players. There are simply too many middle-men whose only input to the new world of payments will be value erosion. Thank God the Mobile Network Operators (MNOs) are too busy bickering amongst themselves or this would be even more complicated!

As a consumer who has a very good idea of what he want to see change, I know that only those who help the payments industry evolve will have a lasting positive impact, and this will only be through collaboration and fair competition.

I’ve used payments as an example, because that’s what I know the best, but the same can be said for almost every other industry sector. The drive to take away what others have, instead of providing a better service for the common good, is capitalism at its worst. And no, I’m not proposing some sort of socialism, it’s just logic; What’s easier? Completely replacing something, or improving what we have in collaboration with multiple players?

It’s not like there isn’t enough to go around.

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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;
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  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
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  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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Peerlyst: Essentials of Cybersecurity

PEERLYST e-book: “Essentials of Cybersecurity”

In almost 4 years, and over 250 blogs, I have only promoted something  – other than myself of course – once: The Analogies Project.

I find myself doing the same thing for PEERLYST for much the same reasons; 1) it’s purpose is to educate, not sell, 2) it’s members are incredibly generous with their time, and 3) it’s free. I recommend that anyone already in, or WANTS to be in the field of cybersecurity, to not only join, but actively participate.

To me, an important measure of any of these forums is the output. I’m not looking to promote myself or my business – that’s LinkedIn, I’m not looking to vent – that’s Facebook, and I’m not looking to be as pointless as Donald Trump – that’s Twitter. Therefore, a forum that allows me to share my knowledge to anyone desperate enough to listen, as well as support me in the countless instances where I need guidance, will get my attention.

As for output, PEERLYST recently published a new e-book – their second – free to all members; “Essentials of Cybersecurity[The link will only work if you’re already a member]. It consisted of 10 Chapters, the first of which I was given the honour of writing:

  1. Starting at the Beginning: Why You Should Have a Security Program by me
  2. Understanding the Underlying Theories of Cybersecurity by Dean Webb
  3. Driving Effective Security with Metrics by Anthony Noblett
  4. A Security Compromise Lexicon by Nicole Lamoureux
  5. Building a Corporate Security Culture by Dawid Balut
  6. Why People Are Your Most Important Security Asset by Darrell Drystek
  7. Basic Security Hygiene Controls and Mitigations by Joe Gray
  8. Understanding Central Areas of Enterprise Defense by Brad Voris
  9. Telecom Security 101: What You Need to Know by Eric Klein
  10. Strengthen Your Security Arsenal by Fine-Tuning Enterprise Tools by Puneet Mehta

Some of these folks not only donated significant amounts of their time on this e-book, but have already signed themselves up for one of the THREE new e-books already in the works! THIS is the kind of forum with which I want to be associated.

Go take a look, hope to see you there.

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PCI L1 Service Provider

From FinTech Concept to PCI Compliant in 6 Months?

Anyone wanting to start a new business in FinTech/payments – digital wallets for example – has to address PCI. Like it not, payment cards are still the dominant form of non-cash payment on the planet. By far.

So what if you have a great idea in this amazing world of opportunity, but your skill-set is in payments and innovation, and not IT or cybersecurity. How do you get your service to market, AND play by the rules? Can you do this in time to be ahead of game given the incredibly short timeframe of today’s competitive advantage?

Well, you could just self assess, but you are restricting yourself to a maximum of 300,000 transaction annually.  But more importantly, would you trust your money to a service provider who self assesses? No, neither would I.

However, I’m talking about full Level 1 Service Provider compliance through a reputable QSA (yes, there are some out there). How can you set up the infrastructure, get all the documentation in place, AND get all the way through a PCI DSS Level 1 assessment in 6 months? And if you do, have you really done it properly?

The answer is yes, you can, but there are MANY caveats, and if you deviate from these steps you will not get there. I am only interested in helping organisations get compliant properly, I have no interest in adding more crap service providers to the ecosystem.

First, you have to completely ignore the PCI DSS. Any plans you make to design both your physical infrastructure and your security program from scratch must be with real security in mind. Never compliance alone. For that, many organisations turn to the ISO 27001 standard. There are others, but try finding affordable consultants who can help you implement them. As long as you realise they are all just frameworks, not step-by-step instructions, then you’re ready to start asking questions.

So What Are the Steps to Compliance?

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  1. Get Help – This should be no surprise. I don’t perform emergency appendectomies, I’m not remotely qualified, why would you try to achieve compliance when that’s not your experience or skill-set. Yes, is can be expensive, but nowhere near as expensive as any of the alternatives. There are some very good consultants out there, do your homework and find the best one for you.
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  2. Outsource the Infrastructure – Unless you’re an expert in everything from hardened operating systems, to logging and monitoring, to firewall management, you will want to outsource as much of the platform as you possibly can. Unfortunately, finding a single provider who can take on anything more than physical hosting and some networking stuff is still ridiculously difficult. Amazon Web Services (AWS) for example is about as bad as you can get. Unless of course you want a dozen or so independent service providers to manage along with Amazon.
    You MUST ask the right questions, and this is where your  consultant comes into play. S/he will write your RFP, interview providers, and eventually produce a responsibility mapping of services against the PCI DSS. This will match their Attestation of Compliance, as YOU should only do business with L1 PCI compliant service providers.
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    You are welcome to use my mapping if you don’t have one: PCI DSS v3.2 SP Responsibility Mapping
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  3. Policies, Standards & Procedures – You have to start somewhere, so you will likely want to buy a Policy Set. Once again, you have to be very careful as there are dozens of options but few will be fit for purpose. In this case, ‘fit for purpose’ means the service must 1) get you through compliance, 2) provide a platform for your unique culture, and 3) be self-sustainable for the long-term.
    If you buy a Policy Set with ‘PCI’ in the title, you have already failed. Buy one that your consultant can customise on your behalf, and then teach you to manage yourself. Get one that; 1) Is already mapped to both the PCI DSS and your chosen framework (usually ISO 27001), 2) has document management built in (numbering, content standards, assigned coordination etc.), and 3) is easily distributed to the subject matter experts best placed to maintain them.
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    I have written a quasi-white paper on how to choose the right the right service, you use the questions as an RFP: ‘Selecting the Right Policy Set
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  4. Hire a Completely Independent QSA – While it may be very tempting to have your consultant take care of all the ‘PCI stuff’, bite the bullet and keep these separate. No, you don’t have to be an expert in this stuff, but if you are relying completely on your consultant you are building in a single source of failure. By all means have your consultant run with the assessment, but be involved. If you don’t, you’ll have no idea what you paid for in the first place. In fact, you may even want to build in some SLAs regarding how much remediation is required from by QSA. There will always be some, but if it involves significant scope creep or capital cost, your consultant has failed you. Remember, you have outsourced almost the entire function of PCI to your platform provider, validation of compliance should be a formality.

Of course this is oversimplified, but I’m already way over my self-imposed word limit. However, while I haven’t included any of the inevitable challenges, the process is a simple as security itself, it’s up to you to find someone who can make it simple.

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