Category: Security Good Practices

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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For the last decade, ISO 27001 certification has been the de facto standard for security programs across the globe. The only problem is, few organisations can be bothered with it. In the years of its existence, I have been asked about implementing a total of twice.

Why?

The reasons are numerous, and vary from organisation to organisation. However, they most often fall within these categories. The client has:

  1. never actually heard of it;
  2. doesn’t care about cybersecurity;
  3. thinks it’s too difficult;
  4. thinks it’s too expensive; and
  5. cannot see a return on investment (ROI).

But the biggest reason I have not been involved in ISO that much?… The Payment Card Industry Data Security Standard (PCI DSS). Which coincidentally, began at almost the same time.

All by itself, PCI has sucked the security budgets out of enough organisations that there was little left for anything else. And if I’m honest, because of PCI, I haven’t had to go looking for any other work.

Think about that for just a minute…

A very basic, controls-only standard, related to a single form of data, that’s not even a law has driven enough business my way that I have not had to worry about diversifying.

And frankly, I still don’t, but with what’s going on here in the EU, we are all going to need something better. From the General Data Protection Regulation (GDPR) to the Payment Services Directive (PSD2), the regulatory landscape is finally making real security a necessity.

It follows therefore that organisations will begin looking to ISO for options.

And that’s really the point, can the ISO standards actually help, or is the 2700X series just a bunch of meaningless paperwork? At first glance, it certainly looks that way, and few organisations choose to go any further. And the ones that do, get so lost in the paperwork that they forget why they are doing it. It’s only when the framework is fully customised and implemented, that you see its true and significant benefits.

However, before you look to ISO, you absolutely MUST do your homework! You have to know exactly what an Information Security Management System (ISMS) is, why you’re doing it, and how you’re going to keep it going. If you can’t answer those questions, don’t start, because you will never cross the finish line.

The biggest killers of ISO certification projects, are, in this order:

  1. Grossly underestimating the level of effort;
  2. Doing it just to land a big contract (or for marketing purposes);
  3. Tying the certification to an overly aggressive deadline;
  4. Ignoring the expert help; and
  5. Having no business goals in mind.

These are usually exacerbated by not getting senior leadership support, and then failing to tailor ISO to your needs. So what organisations end up with 99 times out of 100 is a stalled project and an external consultant taking all the blame.

ISO 27001 certification is bloody difficult…

…just accept that from the beginning. It requires commitment from every aspect of your organisation, and will only be effective if you enable the culture shift necessary to embrace it properly.

Strangely enough though, it actually looks fairly simple, as the ISO 27001 standard itself is only 30-odd pages long and only 114 controls. However, for every 1 of those controls, there are an average of 4 additional aspect to consider from the NINETY-odd page ISO 27002. Then, if that’s not enough, you must show some kind of evidence that you actually doing what you say you are!

For example, the very first ISO 27001 control is “A.5.1.1 – Policies for information security – A set of policies for information security shall be defined and approved“. Sounds simple enough until you realise that there are a minimum of 19 suggested ‘Implementation Guidance’ factors behind it.

From requiring that Information Security Policies address; “business strategy” and “regulation, legislation and contract“, to the suggested ‘examples’ of “policy topics”, A.5.1.1 becomes a project all by itself. Then, assuming you get all this paperwork together, you have to ensure that the policies are; “communicated to employees and relevant external parties in a form that is relevant, accessible and understandable to the intended reader, e.g. in the context of an “information security awareness, education and training programme” (see 7.2.2).” Finally, you then need to provide some ‘record’ that this is all implemented , or that you have a risk treatment plan in place that shows you’re going to get it implemented …how …and when.

There are 114 of these, and even if you decide a few of them are not relevant to you, you must fully justify their EXclusion.

Not trying to put you off, the implementation of an appropriate ISMS is one of the best things you can do for your business as a whole. Just make sure you start out the project for the right reasons, with the right support, and the right goals in mind. And for GOD’S sake, get an expert in for a day FIRST to show all major stakeholders what to expect BEFORE you commit to the full project!

I see ISO 27001 certification becoming a must-have for almost any business, but only if it’s done properly.

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I have never hidden my disdain for the PCI DSS, and have written numerous blogs as to why. Not just whinging mind you, I have always included a stab at providing solutions or alternatives. But every now and again, I have to remind myself why the DSS even exists in the first place. And who needs to accept a sizeable chunk of the responsibility for it.

It’s you Mr. Retail, and you Mr. E-Commerce, and especially you Mr. Service Provider. You are every bit as culpable as the Card Brands.

Yes, the payment card technology is 50+ years old, and hopelessly outdated. Yes it’s a ridiculous way of paying now that there are so many better ways. And yes, it’s very difficult to protect cardholder data, but it’s really not complicated. All it took was effort.

But organisations didn’t make any effort. For decades on end. From stand-alone terminals, to integrated points of sale, to e-commerce, and now to mobile, the threat landscape has changed beyond measure. The corresponding risk management programs have done next to nothing.

Let’s take a quick look at the causes of 3 of the worst card data breaches to date:

  1. T.J. Maxx (2007 – 45.7M Primary Account Numbers (PANs) compromised) – I know this one’s going back a bit, but it’s one of those rare examples of where the PCI DSS was [mostly] up to speed with the prevailing threat landscape. The breach was caused by weak encryption on their wireless access points. Although Wired Equivalent Privacy (WEP) was:
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    i)   known to be vulnerable way back in 2001;
    ii)  replaced by WPA in 2003;
    iii) deprecated by the IEEE in 2004, and;
    iv) addressed specifically in the DSS from as early as v1.0 – “4.1.1 For wireless networks transmitting cardholder data, encrypt the transmissions by using Wi-Fi Protected Access (WPA) technology if WPA capable, or VPN or SSL at 128-bit. Never rely exclusively on WEP to protect confidentiality and access to a wireless LAN.”
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    …T.J.Maxx still had WEP as its standard. This vulnerability (plus horrifically poor network segmentation) lead to the compromise. It also took T.J.Maxx 18 MONTHS to find out.
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  2. Target (2013 – 40M PANs compromised) – Network access credentials stolen from a 3rd party and used to remotely log in to systems in-scope for PCI. An HVAC provider at that! Where to even begin on where Target went wrong?! But we can assume:
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    i)   vendor due diligence and management was sub-standard (addressed in Requirements 12.8.x);
    ii)  vendor access standards and monitoring were not in place (addressed in Requirements 8.1.5.a, 8.1.5.b, and 8.3.2.a);
    iii) change detection mechanisms were either not in place, or ineffective (addressed in Requirements 6.4.x);
    iv)  logging and monitoring mechanisms were either not in place, or ineffective (addressed in Requirements 10.x), and;
    v)   network segmentation was inadequate.
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  3. Home Depot (2014 – 56M PANs compromised) – Similar to Target, which makes this one even more embarrassing and unforgivable.

If we were to look at the thousands of other breaches that have occurred we would find little difference. It’s not so much concerted attacks from dedicated and skilled hackers that’s the problem, it’s the complete disregard for basic security practices by the vast majority of organisations. Organisations who KNOW better, but have chosen instead to just roll the dice.

I’m not saying that these three examples were not perpetrated by skilled hackers, but the level of skill required was significantly less than it should have been. In fact, if these organisations only had DSS levels of security controls in place, the attacks would have significantly more difficult. REAL security would have made these targets of last resort.

What Are You Going to Do About It?

As the South Africans say; If you want security, build your fence higher than your neighbour’s.” The reason the PCI DSS exists is because no one was building any fences!

The right things to do for security have, quite literally, been written down for generations. Ignore these basics and the upcoming regulations related to privacy will make PCI look like a walk in the park by comparison.

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Perform research on IT Governance models and you’ll eventually come across the concept of People, Process, & Technology (The Golden Triangle). Yet another concept whose origination has been lost in time (it was not Bruce Schneirer), but one whose evolution has polarised the security industry.

On the one side you have the technology-first advocates. Even a security icon like Bruce Schneier says; “We rely far too much on policy and people, neither of which are reliable, especially when dealing with fast-changing, large scale infrastructures.“. Oddly enough you’ll find most of the security product vendors in this camp too. I know, weird huh?

Then you have the side that I’m on, that says all the technology in the world can’t fix stupid. The enormous benefits that can be derived from technology are only achievable if the people put the processes in place to make the technologies effective.

In cybersecurity, technology can only enhance, it cannot fix.

Yes, of course technology is critical, why do you think I rage against PCI’s ‘daily review’ of logfiles so much? No, I do not believe that an organisation can ever achieve good security without the automation that only technology can bring, but putting technology first is the definitive cart before the horse.

In cybersecurity, technology can only enhance something that already works, it cannot replace it entirely.

So, to me, the job of the CISO is to get the three aspect of the golden triangle into line with the only things that matters; the business goals. In the digital age, technology is the ultimate enabler, and the CSO/CISOs the ultimate facilitators of that technology. The IT security function gets involved in everything from M&A to compliance, from incident response to internal audit, it’s the CISO’s role to bring it all together into a sustainable program. One that that is only ever appropriate to the business’s needs and no more.

But none of this is possible without Governance. The CISO, as a facilitator, is only a bridge between the business goals and the means to get there. It’s the Governance function that gets the job done.

Also, not every organisation can afford a CISO, and frankly nor should they even contemplate one if there is no discernible return on investment. This is where the Virtual CISO can come into play, and from my perspective, the only reason to consider one. It’s the v-CISO’s job to train the governance committee (or whatever it’s called) to do what CISOs do.

Too many organisations are instantly turned off by the word ‘Governance’. At best it’s seen as unnecessary bureaucracy, at worst it’s perceived as some kind of dystopian ‘Big Brother’. Nothing could be further from the truth; it’s not a department, it’s not an institution, it’s a function, one designed to help keep a business IN business.

EVERY organisation needs governance, regardless of size, region, or industry sector. The governance charter, membership, responsibilities, and operation will vary considerably, but all need to be appropriate, and of measurable benefit.

Only someone with the skill-set of a true CISO can put this in place in such a way as to be sustainable without them. But only a Governance function can keep it going.

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One of the goals of this blog, as well as the ultimate goal of my career, is to simplify all aspects of cybersecurity. Well, maybe not all. I have no idea how to simplify a penetration test (or even perform one), or encryption mechanisms, but I’ve got the high-level stuff covered! 🙂

From my perspective, cybersecurity is already simple. You would hope so, it’s what I do, but that’s not actually what I meant. Which is that every aspect of cybersecurity must be simple for it to even be effective security in the first place. There is no room for complicated. It must also be accessible to everyone who needs it, regardless of their current role or previous experience.

It is therefore the job of every cybersecurity professional to make this stuff easy, but clearly we are not doing a very good job. In fact, I would go as far as to say that there are certain elements that seem to go out of their way to make things difficult!

What / who are these elements, and why are they doing it?

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  1. No offence, but Element 1 is You; While you may not be a security expert, you are every bit as responsible for security as those who are the experts. Ignorance of your responsibilities is no excuse, and if your organisation does not provide you the necessary training, demand that they do so. Unless you’ve lived in a hole for the last 10 years, you have seen the headlines related to data breaches. You really don’t want to be the cause of one.
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  2. Which is the ideal segue into the Element 2, which is; Senior Management. If they don’t care about security, there’s a very chance you don’t care (see element 1.). If cybersecurity is not in the Top 5 priorities of your BoD / CEO, then you likely have an entirely ineffectual security program. If you even have one at all. There is nothing more difficult and seemingly complicated than starting something from the very beginning, but start you must.
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  3. Element 3 is of course, Lawyers / Regulators. Not that they do this on purpose, it’s that they just can’t help themselves. The language of the law is practically incomprehensible to the rest of us, yet it has to be lawyers that write every contract, regulation, and [of course] law out there. Combine their legal-ese with something you already don’t understand [cybersecurity], and you’re left scratching your head in frustration. Or worse, avoiding it altogether.
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  4.  And the worst of the bunch, Element 4; Security Vendors. This is the one that is truly reprehensible. How many of you, for example, know what Cloud Access Security Brokers (CASBs) are? Or User and Entity Behavioral Analytics (UEBA)? What about Intelligence-Driven Security Operations Center Orchestration Solutions? No, me either. What I DO know is that you don’t need ANY of these things until such times as your risk assessment TELLS you need them! You have that process well oiled, right?

Of all the horrendous clichés out there, my favourite is ‘Back to Basics’. Cybersecurity is simple, bloody difficult, but simple. Anything that complicates it can be effectively ignored until such times as you’re ready for it. You will never get there by buying technology, and you will never get there until you get the basics right.

Luckily the basics are the cheapest things to fix. All you have to do is get your CEO to care, formalise your Governance, and get all of your policies and procedures in place.

Simple, right?

OK, that was facetious, but if you think any of these things is complicated you’re just not asking the right people the right questions.

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