It is with some surprise (and frankly, confusion) that I now realise not all security professionals think information security policies (ISPs) should [must!] be aspirational in nature.

By ‘aspirational’, I mean that at least some aspects of your ISPs require a greater degree of control / implementation / assurance etc. than you are currently capable of achieving in reality.

The ‘accurate policy’ proponents feel that if the policies do not reflect exactly what you are doing, then what you are doing is in violation of your own policies, thereby effectively rendering those policies useless. I assume, by extension, that they consider compliance with any regulatory regime is also nullified.

Continue reading “If Your Policies Aren’t Aspirational, Why Bother Having Any?” →

It is with thanks to Chad Loder that I write this blog. His post on LinkedIn made me laugh out loud and is what inspired me to propose the CEO Cybersecurity Challenge (#ceocybersecuritychallenge). The very simple post was:

From: Security Team
To: All Employees
Subject: Security Awareness Training

To opt out of this year’s security training, click here.

Security experts will instantly see the simple genius of this social engineering tactic. In just 10 words you get:

Continue reading “The CEO Cybersecurity Challenge” →

The title should be; Why YOUR Information Security Policies (ISP) are Pointless, but I figured this title was far more contentious/click-worthy.

If you’ve come this far, you’re in one of two groups:

  1. You’re horrified at my ignorance and want to rip me a new one (good for you by the way); or
  2. You’re thinking the equivalent of “I knew it!”, in which case you need this more than anyone.

When I say that your ISPs are pointless, it’s because in all likelihood they are. Assuming you even have a policy set (policies, standards and procedures), ~20 years of consulting experience has shown that they invariably:

  1. are not sponsored/supported/signed-off by the highest levels within and organisation – does anyone really care about something their bosses don’t visibly to care about?;
  2. are not managed by a governance function to ensure adherence to business goals / regulatory compliance / corporate responsibility etc – who else is going to do this? The CEO? A CXO by him/herself?;
  3. include no overarching framework policy that 1) spells out a commitment to security, 2) breaks down the responsibilities for everyone from the CEO to the interns, or 3) details the consequences for non-conformance – how well do buildings stand up without foundations?;
  4. are generic templates with zero attempt to fit them to the prevailing culture – sometimes the phrase “That’s not how we do things here!” is perfectly acceptable;
  5. are non-aspirational – it’s actually a good practice to set your policies above your current security capability, IF you have a comprehensive exception/variance process linked to a risk register / risk treatment plan as part of the framework;
  6. are not DIRECTLY linked to robust risk management processes to ensure full policy coverage and continuing suitability to the business – how do you know they’re right?, now and in the event of significant change?;
  7. are not part of an [annual] internal audit process to measure adherence – few companies even have an internal audit function, let alone one capable of assessing IT/IS policies;
  8. are not part of employee on-boarding and ongoing security awareness training programs – every role should have relevant policies assigned to it, and appropriate training should be continuous;
  9. are not maintained appropriately/consistently – you don’t need a librarian to do document management well, you just have to be organised; and
  10. are not distributed or made available to everyone whom they impact – “Policies, what policies?”

Bottom line is that I have never seen a policy set done well, and it’s not a coincidence that I’ve never seen security done well either. These two things go hand-in-hand and you absolutely cannot have one without the other.

Yes a decent policy set is ‘paperwork’, yes it’s bloody difficult and time consuming, and no, it’s not even remotely sexy, but don’t bother trying to get a security program in place without them. Seriously, don’t even bother, because it will fail.

Lego don’t send out a 4,000+ piece Death Star set without detailed build instructions, and that’s exactly what your policies, standards and procedures are; instructions on how to do security appropriately within your organisation.

So why don’t all security folks take this more seriously? Two main reasons; 1) they are so focused on technology that the processes fall to the wayside, and 2) they have tried over and over and finally gave up, electing to do what they can, knowing full well it will never be enough.

Sad, huh?

Security is about People, Process and Technology, in that order, because without a policy set you will have:

  • no understanding of the technology[ies] you will need – risk assessment;
  • no processes to run the technology properly – procedures;
  • no way to sustain the technologies moving forward – vulnerability management;
  • no understanding of what to do with technology output – incident response;
  • no-one who could perform the incident response even if you did – security awareness training.

A decent set of information security policies ties all of this together into a sustainable program, and if you still don’t think they are that important, you are simply not paying attention.

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You could almost be forgiven in thinking that words/phrases like; ‘pseudonymised’, ‘anonymised’, ‘access control’ or ‘encrypted’ are all that is required when reporting your technical and organisational security measures for Article 30 – Records of Processing Activities.

Almost.

Continue reading “GDPR: Reporting Your “Technical and Organisational Security Measures”” →

Fact #1: There is no effective incident response without logging and monitoring;

Fact #2: There is no effective disaster recovery without incident response; and

Fact #3: There is no effective business continuity without disaster recovery.

Therefore logging and monitoring should be a fundamental aspect of every security program, regardless of organisation size. So why is it performed so universally poorly? Don’t organisations want to stay in business?!

It’s not like EVERY STANDARD ON THE PLANET has it as a prerequisite! Well, except for these obscure ones:

  • ISO 27001 – A.12.4 Logging and monitoring
  • COBIT – F.10 Monitoring and Alert Services for Security-related Events
  • NIST – Anomalies and Events (DE.AE)
  • PCI DSS – Requirement 10: Track and monitor all access to network resources and cardholder data
  • …and so on

So you can imagine my surprise and delight when OWASP – more commonly known for coding vulnerabilities – singled this out as one of their Top 10 for 2017. Yes, it barely snuck in at number 10, but there it is, finally in the light of day.

Unfortunately, OWASP isn’t exactly up there with the NISTs of the world, so the importance of this is probably lost on most. I mean, the DSS uses [loosely] the OWASP Top 10 as one of its “industry accepted best practice” providers, which is actually why a lot of people have even heard of OWASP in the first place.

So now what? What difference is this going to make?

Well, very little probably, if you don’t understand now just how important centralised logging and monitoring is, you probably never will. If you’re in a position where this makes a difference (you’re in technology or cybersecurity) then the only time your organisation will care is when your business suffers a loss. Then I’m sure you’ll start to care as you’re updating your CV/resume.

Honestly, I really don’t know where I’m going with blog. It was either write about this or the bloody GDPR again. But it’s really the privacy regulations that are beginning to drive things like this forward. Record keeping, data breach notifications, accountability and so on all have an enormous impact in how we will be running our businesses and logging is intrinsic to them all.

In my consulting practice I very rarely use the word ‘recommend’, and I try never to mention the names of security control vendors except as examples. So while the due diligence is yours in terms of finding the right logging solution for your organisation’s needs, I HIGHLY recommend that you start looking.

I’m sure there’s some out there, but I’ve yet to see one argument for not performing logging and monitoring, and I’m willing to bet there are no valid ones. The problem, like most things in security these days is that the name is just not sexy enough. Perhaps if we include in a brand new acronym like ‘Episode Reply & Adversity Restoration (ERAR)’ as I did in Froud on Fraud’s Top 10 Cybersecurity Technologies to Implement in 2017 it would get more attention?

Whatever it takes…

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