Author: David Froud

On January 13th, 2018 the Payment Services Directive 2 (PSD2) becomes national law across the EU.

Depending on whom you ask – and to a large degree what their vested interests are – PSD2 will either have little effect, or be a FinTech game changer that will kill banking as we know it.

From the bank’s perspective, they clearly don’t want change. They have been front and centre for generations when it comes to consumer interaction, and the data they have collected is a major source of their power. Start-ups on the other hand, need a way in, and access to that data is a very good place to start. Whoever controls the consumer directly, will have the best chance of controlling the consumer’s financial choices.

PSD2 itself is supposed to promote 2 things:

  1. Make it easier and safer to use internet payment services by better protecting consumers against fraud, abuse, and payment problems as well as strengthen consumer rights; and
  2. Promote innovative mobile and internet payment services. [competition in other words].

The first applies no matter who you are, bank, service provider, or merchant. Combine this with General Data Protection Regulation (GDPR) and everyone needs to protect personal data.

The second however, is supposed to create a so-called ‘level playing field’, but can start-ups truly compete against the big banks who already have the direct consumer relationship?

Innovation is not the problem, FinTech is busting at the seams with new ideas, but none of them mean much unless they are adopted by the masses. What do they have to do to displace a bank, when the chances are they will not actually be providing banking services as we understand them? And what exactly are “innovative mobile and internet payment services” in this context – and to the point of this blog [finally] – how are mobile devices going to make all the difference?

Counterintuitively, mobile phones will actually improve security. You only have to look at the sheer number of each authentication factor of which the modern smartphone is capable to realise that traditional banking apps just don’t cut it. From passwords / passphrases, to fingerprints, to geo-fencing, to whatever comes next, your phone gets as close to true identity management as any device can.

That’s not to say mobile phones are secure, they are not, and this is one of the biggest hurdles to overcome. A bad guy ‘hacking’ into one of your banks accounts is bad enough, now imagine them hacking into an app that controls access to all of your finances. Money management apps is one of the greatest potential benefits of PSD2, and one of its scariest.

As for how mobile devices will aid PSD2 adoption, you only have to look at the trends. According to Statista for the UK:

  • By the end of 2017 66% of the UK’s population will be using a smartphone – That’s 43 million people, and given the demographic, they control the lion’s share of the UK’s wealth.
  • In 2015, 58% of all smartphone owners used banking apps

It follows therefore that a good chunk of that 43 million will be using their devices for a lot more than Facebook.

The only statistic that does not back this up, is adoption of mobile payments. Despite the Apple Pays/ Samsung Pays, and the plethora of digital wallets, mobile payments have in no way realised their potential. This is not the fault of the smartphone, this has to do with the inability of the payment apps to provide any sort of value-add. From loyalty point, to instant coupons, to ratings and reviews, payment apps are not improving the BUYING experience, just adding a payment option.

PSD2 will change all of that. When you have an app that can not only help you find the best price for something, but give you the best purchase choices based on your combined financial history, now you’re providing true benefit. It’s not about how you pay, it’s about how you buy.

Yes, you can do all of this through a PC / laptop, but on what device do you spend the majority of your time online?

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In the vast majority of organisations for whom I’ve provided guidance, the security departments are seen as something to work around, not alongside. In not one of those organisations was security actually seen the critical and intrinsic-to-the-business asset is can, and should be.

While I have written incessantly about this all being the CEO’s fault for not creating the necessary culture, the fact remains that most security professionals do themselves no favours. However good intentioned our actions may be, most of us completely miss the point. Like it or not, our entire existence is predicated on achieving the following:

“To provide the business with all the information, and as much context, as we can to enable them to make the best decision they can.”

Yes, that may include decisions that we in security would consider completely unacceptable, and would likely never make ourselves. It also may even include decisions that turn out to be really bad ones, but that’s just as much our failure as theirs.

The bottom line is that if we cannot speak the business’s language, if we are unable to convince them of the risks, we have failed them. There is no room for towering egos or hubris in security, it does not matter what we want, it only what the business needs. This will never be our decision, and we should never expect the business to speak our language.

I’m not saying that if you’re a cybersecurity professional that you have to say yes all the time, but you should avoid saying no whenever possible. Frankly, it’s not your job to do so. And as much as we would love to believe that as security experts we’re here to help, and that we have the best interests of our clients at heart, we will never be anything more than enablers. What’s more, if we’re anything less than that, there’s little point in having us around.

In the movie Office Space, one of the most cringe-worthy moments was when Bill Lumber reveals the “Is this good for the Company” banner. I remember laughing at the ridiculousness of the message, and laughing again when our hero tears it down. Almost 18 years later, here I am expounding the exact same message as that banner.

Why?

Because in security, we rarely have enough knowledge of the company’s big picture to put our guidance and recommendations into the right context. Even if we know that the company’s long-term goals are, unless we sit on the board we are in no position to appropriately address the risk appetite. A Sword of Damocles scenario to us, may well be a necessary gamble to keep the business competitive.

That leaves us only 2 things to do:

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  1. Explain risk in the format they respond to best; detail the impact of not doing what we suggest; provide suitable alternatives; and
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  2. Cover your arse by having THEM sign-off on the residual risk.

The business does not need our approval to proceed with even the most egregious risks, but that does not mean we have to like it. Legal have far more power than we’ll ever have, but even they have to compromise. That said, we are fully entitled to document our objections as part of the final sign-off, but we should never take this personally.

As a corollary to the last paragraph, never, EVER say “I told you so”! Given that it’s likely partially your fault that senior leadership didn’t make the right decision, your only focus should be to help mitigate the negative impact. Take the high road, you’ll be employed longer.

In the simplest terms, map everything on your Risk Register to the business’s goals, and only worry about the things that impact them. Doing the right thing in security is rarely, if ever, measured by security metrics, it’s measured by the company’s success.

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This time last year I wrote Froud on Fraud: Top 5 Predictions for 2016. Unsurprisingly, none of these things has transpired. At least not yet anyway [embarrassed silence].

So why do this again, when it’s fairly clear that any insight I have – if any – is aimed more towards potential long-term trends than to short-term results?

The reason I’m taking another stab is I can’t help feeling that 2017 is going to something of a watershed year for cybersecurity. At least I hope so, because there is so much hype, scaremongering and dross out there that something needs to change. And it must change soon, before cybersecurity professionals get lumped into the same category as the better known examples of sleaze; used car salesmen, estate agents, and lawyers (no offence Sis).

The last few years has been bad for the cybersecurity/privacy profession. From Snowden, to the Snooper’s Charter, from Target to Yahoo there has been no good news. Forget that the press will not print good news if they can possibly help it, things actually are getting worse. State sponsored attacks, organised crime, numerous vulnerabilities in Android and iOS, irresponsible Internet of Things manufacturers, there is little to smile about.

But instead of coming to the rescue, the cybersecurity industry seems Hell-bent on making it worse by cashing in on the confusion. From biometrics vendors disgracefully overstating their worth, to consulting practices doing everything in their power to cross-sell and upsell their wares, it’s becoming increasingly difficult to know where to turn.

The only bright side? Legislation.

Yes, legislation. The Payments Service Directive (PSD2) and the General Data Protection Regulation (GDPR) – for example – are both designed to start putting things right in payments and data privacy respectively. No one with a vested interest in keeping things the same was ever going to do anything themselves, so now they’ll have to. Banks, large retail, you name it, there will now be a price to pay for how you treat the consumer.

And let’s face it, it’s all about the consumer.

So with the above in mind, these are my predictions for 2017:

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  1. ISO 27001 certification will be increasingly important: Unlike PCI which is entirely prescriptive, no other regulation that I have ever seen requires anything other than ‘appropriate‘ or ‘reasonable‘ security measures. Appropriate and reasonably to whom is always the first question. ISO 27001, and other frameworks like it, perform one overarching function; to provide demonstrable evidence that an organisation is taking security seriously. Whether the organisation is actually taking security seriously is another matter, but it is hard to fake certification. Not impossible mind you, just difficult. ‘Compliance’ with GDPR, and other data privacy regulations globally will look to ISO for help.
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  2. Biometrics vendors will keep pushing their wares, and fail: OK, so this one is more of a wish than a prediction, but I am so sick of the hype around biometrics that I need to vent. Yes, biometrics if very important, yes, it’s better than a password in most scenarios, but it is NOT an answer by itself. Biometrics will not replace the password, nor will it ever be a solution all by itself. It will do what every other form of authentication should do; take its rightful place in the arsenal of identity management systems.
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  3. Amazon GO will be the new model for brick & mortar: Any brick and mortar retailer not terrified by the opening of the Amazon GO store in Seattle is completely missing the point. The point is that consumers don’t care how they PAY, they care how they BUY. Cash, credit cards, even the Apple Pays and their ilk are just forms of payment, they are not relevant to how we choose the products and services we actually BUY. We demand a lot more from our merchants than a glorified cash register. In Invisible Payments, Are They Real? (Aug ’15) I went a little further than Amazon did, and will go even further in a week or so. And while I don’t expect 2017 to see a sharp increase in GO-esque stores, it’s definitely a glimpse of the near future.
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  4. Containerised Security Services: Anyone who has looked to Amazon Web Services or Azure for hosting their e-commerce systems often do so in order to outsource security as well. The fact that neither of these services provide much is often a nasty surprise. Yes, the merchants asked the wrong questions (or none at all), but it is incomprehensible to me that vendors like AWM DON’T provide comprehensive security wrappers. 2017 will see an increase in modular and full-service security programs (at least to PCI minimums) from all of the major providers. Hopefully these will be easily understandable and transparent to non-experts, because even the better service providers do a piss-poor job of getting their point across.
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  5. Automated Governance, Risk & Compliance: GRC is a fantastic concept, implemented poorly. However, with the ever increasing regulatory landscape, larger organisations simply can’t keep up with the audit  ommitments. GRC tools have traditionally been mostly manual in nature, which explains their lack of adoption. More and more GRC vendors are looking to automate compliance baseline input by providing APIs to end-point vendors (A/V, SIEM, vulnerability scanning etc) for automated input of production system data. 2017 will see GRC vendors finally focusing on the only thing that makes sense; asset management and automated baseline comparisons of known-good profiles.

OK, so 5. is a bit of a stretch, but there’s no way my OCD would allow for only 4 predictions.

What are your predictions?

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In previous blogs I expanded upon two main reasons why CISOs seem to have such a limited lifespan, and why the role is currently one of the most difficult senior leadership roles to both fulfil, and stay in long-term.

In Make the CSO Role a Board Appointment, or Don’t Bother Having One I touched upon the fact that so few CSOs; 1) are hired by the right people or for the right reasons, 2) report to the correct hierarchy, and 3) have the necessary support from the people from whom they need it most.

In The 3 Types of CISO: Know Which You Need I tried to explain why there is effectively no such thing as an ‘all-rounder’ CISO, so expectations are already completely out of line with reality.

I’ve now come up with a 3rd; Expecting the CISO alone to fix everything.

While this may be a byproduct of the first two, it is nevertheless important enough to be addressed by itself. And for once, I can’t actually blame the CEO entirely for this issue, the CISO is every bit as culpable.

Consider this scenario; An organisation, for whatever reason, decides it needs a security expert in senior management. Even if the BoD does get involved from the beginning, the organisation will end up writing a job description of some sort. This is no different from going to the Doctor’s, diagnosing yourself, and writing your own prescription.

This description will then be advertised in some fashion, guaranteeing that the only people who respond are the ones wholly unqualified to fill it. In the same way that anyone who wants to be in politics should be stopped from doing so, anyone who responds to a CISO role that they didn’t draft themselves has no idea what they are doing.

There is only one exception to this, and that’s if the organisation has already put the basics of a security program in place and need someone to optimise it. Everything before this is a series of consulting gigs, the aim of which is to prepare the organisation’s security program to the point a CISO can come in and run with it.

So, whether you’re an organisation looking for a long-term CISO, or a CISO looking for a long-term gig, what do you do?

A Security Program in 10 Difficult-as-Hell Steps

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Clearly there are many steps in between these, as none of this appropriately addresses two of the most important aspects of any security program; 1) Senior Leadership’s role in changing the corporate culture, and 2) a Knowledge Management program personified by documented processes and procedures.

But in no way do I wish to downplay the CISO role to one of a babysitter, it is still one of the most difficult roles imaginable. However, I have never met a CISO who joined an organisation at Step 1, and was still the CISO a year or so later. Because the CISO role is perceived by many security professionals as the pinnacle of their career, too few ask the hard questions before committing;

  1. Has the organisation followed the 10 steps? – If no, where are they in the process?. If yes;
  2. Am I right for the job? – If no, can I help them find someone who is. If yes;
  3. Do I really want the job? – Go in with your eyes wide open, or again, walk away.

As long as both the organisation and the prospective CISO are fully aware of these issues, there is no reason a CISO can’t go the distance. That said, there is no reason a security program can’t be put on track without one…

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Like almost everything else in my life (e.g. marriage, fatherhood), I became a cybersecurity professional with little to no planning. I was happily plodding along with zero direction, and even less qualifications, when an employer required me to get an MCSE in Windows NT.

In a very short time I realised that if I was looking at a computer my boss thought I was working, so being lazy, IT was the career for me! However, I did get bored, so when I received a call about my resume on Monster.com from a start-up cybersecurity company, I jumped at the chance. A little homework showed that security was the place to be in IT, even then, especially when the company consisted almost entirely of incredibly smart ex-NSA types.

This was in 2000.

In the 16 subsequent years I have gone from firewall admin, to managed service manager, to consultant, to manager of consultants, to self-employed. I have loved [almost] every minute of it. The funny thing is though, I have no passion for security per se, I just love helping others fix broken stuff. Especially processes.

There is a LOT of work out there.

So my first piece of advice; decide why you want to be a cybersecurity professional in the first place. If it’s just for the money, move on to something else, you’re not welcome here. Having performed the Keirsey Temperament test on 30-odd security consultants across the globe, it was clear that certain characteristics are dominant in their type (ESTJ). Bottom line; they actually care, and they are:

  • Highly social and community minded;
  • Generous with their time and energy;
  • Hard working; and
  • Friendly and talk easily to others.

That’s not to say others can’t do well (I’m an INTJ for example), but you have to know yourself before you know what aspect of security would suit you best. Follow the money, or choose something for which you are not suited, and you will likely fail.

Then Bear These Things in Mind…

  1. Qualifications: A degree in cybersecurity should not be seen as a pre-requisite, as certifications are almost as much good, and neither of these things can trump experience. Regardless of your qualifications, you will start at the bottom, and there is no better place to learn. Make the most of it.
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  2. Specialise or Generalise: You’ll need to decide very quickly which you’re going to be; Specialist, or Generalist. You cannot be both, there are just too many aspects of cybersecurity. Medicine, law, engineering, and a whole host of other careers are the same, you must find what suits you best.
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  3. Learn the Basics: Jumping straight into a career in User and Entity Behavior Analytics (UEBA) or Intelligence-Driven Security Operations Center Orchestration Solutions (whatever the hell that is) may be tempting, but you are not doing your career, or more importantly, your clients, any favours. From Confidentiality, Integrity & Availability, to Risk Assessment, Asset Management, to Policy & Procedure, the basics have never, and will never change. Whenever you find yourself stuck, only the basics can give you a clear way forward.
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  4. Choose a Camp: Unfortunately most cybersecurity professionals tend to fall into one of two camps; 1) those focused primarily on Technology, and 2) those focused primarily on People and Process. These are two distinct skill-sets, so know which you are, and make sure you pair up with a counterpart.
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  5. Ask for Help: I got where I am without a mentor as such, but I most certainly didn’t get here without a LOT of help. Nor would I be able to stay here without the constant support of my peers. If there’s one thing I love about cybersecurity professionals it’s their generosity and desire to help. So join your local chapter of ISC2, ISACA and / or ISSA and start talking to people.
    Use mentors too if you can, as while I have few regrets in my career path, not having mentor is one of them.

Without question, a career in cybersecurity can be very rewarding, both in personal achievement and financial terms. It can also chew you up and spit you out if you’re not careful.

In the end, cybersecurity will give as much back as you put in, there are no shortcuts.

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