It occurred to me that after 15 years of consulting, 10 years of public speaking, 3 years of blogging, and saying things like; “All regulatory compliance falls out the back-end of a security program done well.” and; “If you fail to develop an appropriate security program, it’s the CEO’s fault and no-one else’s.” that I have never actually defined what I consider to be a good security program.

In my defence, a good (i.e. appropriate) security program is as unique as the organisation trying to implement one. However, like any other discipline, there are basics that ALL security programs must have to be successful.

All of the best security experts on the planet pretty much agree on these basics. But just try looking for something you can apply to your business and you’ll soon be as confused as I am when trying to read anything written by a lawyer. Regulatory compliance, greedy product vendors, incompetent consultants and a whole host of other factors conspire to take security out of the hands of those who need it most.

Nothing I am about to write has not be said by me many times over, or by a thousand others much smarter than me, but for some reason it never seems to stick. As much as I hate the concept of rebrand-it-to-sell (e.g. a ‘service on the Internet’ is now called The Cloud), I can see the attraction. If we could make security ‘sexy and new’, perhaps we’d have an easier time bringing back the basics. 99% of security lives and breathes in the basics.

For example, everyone knows that there is no security program without senior leadership support (i.e. CEO). This is free, takes a fraction of a percent of the CEO’s time per calendar year, and has benefits well beyond anything you can imagine. But try getting it.

Anyway, on with the program detail, but first; If you don’t believe that a security program is a balance of People, Process, and Technology, stop reading, this will all be lost on you.

8 Steps to an Appropriate Security Program

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  1. Senior Management Support – Been over this a million times. If you don’t have it, stop here, you’re wasting your time. Can you have some security without it? Yes, but guess who will be blamed when things go wrong.
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  2. Governance Committee – Senior stakeholders who will run the program with the full and visible support from senior leadership. Governance runs everything from risk assessments to change control, and without this centralised function your security program will collapse like a flan in a cupboard.
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  3. Policies & Procedures – Again, if you don’t know by now how important this one is, don’t bother reading the rest, you’ll never understand.
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  4. Risk Management – The primary function of the risk management is to ensure that all security controls meet the organisation’s risk appetite. Risk Assessment, Business Impact Analysis, Risk Treatment, and the Risk Register all sit here.
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  5. Appropriate Security Controls – No, I do NOT mean technology! Technology supports security, it does not define it. Your controls will be a direct result of the risks determined by Governance, and the requirements as defined in your policies (requirement for hardening guides for example). Technology purchases are the last resort.
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  6. Vulnerability Management / Change Control – I don’t lump these together very often, but from a program perspective, they have similar results. i.e Don’t make things easy for the attacker by a) ignoring the evolving threat landscape, and b) introducing potential vulnerabilities without due diligence respectively.
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  7. Testing Program – Test everything, then when you’re done, go back and test it again. Repeat. You simply have no idea whether or not your security program is working until you test it. Test results feed back into everything done before it in order to make the necessary adjustments.
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  8. Security Awareness & Training – Again, if this makes no sense, you’re reading the wrong blog. None of the above works unless EVERYONE knows what part they play.

That’s it. Finished. there is nothing more to do for any organisation to develop an appropriate security program. Nothing here is complicated, perhaps that’s why people ignore it, it’s just not dramatic enough.

However, making this process simple can be extremely difficult, as is getting the program in place, and these difficulties should not be underestimated. It’s the difficulty, not the complexity that ruins most security programs, especially when you don’t have the support you need.

FWIW, done well, a security program based on the above will not only make you more secure than most of your competition, but give you demonstrable compliance with every regulation out there. How’s that for an ROI?

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On June 15th, Gartner released it’s Top 10 Technologies for Information Security in 2016. As a security ‘professional’ with over 15 years front-line experience, it has taken me this long to find out what half of these things are even trying to achieve. My initial impression was that this was just an attempt to corner the market on acronyms.

Now that I’ve had a little more time to look at them, it’s not just about acronyms, it’s about selling things. Things the vast majority of businesses don’t need. Things that if you DID introduce them into your current environment it would be like building a castle on a swamp (hope you got the Monty Python reference);

Utterly useless, expensive, and completely missing the point.

The breakdown:

  1. Cloud Access Security Brokers (CASBs), provide a “…critical control point for the secure and compliant use of cloud services across multiple cloud providers.” – In the real world this is called performing proper due diligence, before you outsource to a cloud provider. The right reporting should be built into the SLAs. Good God, even the PCI DSS makes this a requirement!
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  2. Endpoint Detection and Response (EDR), “EDR tools typically record numerous endpoint and network events, and store this information either locally on the endpoint or in a centralized database.” then compare the output to “known indicators of compromise (IOC)“. [Ed. note the 2-for-1 on the acronym front] – Why the Hell would you wait for a ‘known indicator of compromise’ instead of trying to fix the problem pro-actively first?!  Hardening guides, vulnerability management, system baselining, FIM et al are all designed to produce baselines of known-good configs thereby minimising exposure. This is nothing more than a rebranding of basic security tenet in order to sell a technology.
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  3. Non-Signature Approaches for Endpoint Prevention, uses “machine learning-based malware prevention using mathematical models as an alternative to signatures for malware identification and blocking.” – Seriously (see 2. above)? Once you have your system at a known-good config, stop anything NOT that. Are you seriously going to spend God-knows how much on a new technology instead of doing what you SHOULD have doing all along …for free(ish)?
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  4. User and Entity Behavioral Analytics (EUBA), “…provides user-centric analytics around user behavior, but also around other entities such as endpoints, networks and applications.” – This one just pisses me off, and I can only assume Gartner were paid a ton of money by EUBA vendors to add this to the list. This is the THIRD nod to baselining and I’m only at number 4 on the list.
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  5. Microsegmentation and Flow Visibility, which is basically more granular segmentation (think system-to-system instead of the usual network-to-network). – So let’s see; most organisations have horrible segmentation at the network level, so to combat this, buy a technology that puts the ‘firewalls’ on each endpoint and maps your traffic flows at that level. I have an idea, why don’t you just do segmentation properly with the infrastructure you have and THEN decide if you need more. I seriously doubt you will unless you’re an IaaS/PaaS provider.
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  6. Security Testing for DevOps (DevSecOps) – In other words; building security and security testing into every step of the development process. This is new? I have to assume this was just padding to avoid a Top 9 scenario.
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  7. Intelligence-Driven Security Operations Center Orchestration Solutions, “an intelligence-driven SOC [ISOC] also needs to move beyond traditional defenses, with an adaptive architecture and context-aware components.” – So what you’re saying is; Let me know if something happens that’s not normal? Errr, isn’t that reporting events outside of a KNOWN-GOOD BASELINE!?!
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  8. Remote Browser solutions “…remotely present the browser session from a “browser server” (typically Linux based) running on-premises or delivered as a cloud-based service.” – This one kinda makes sense, but haven’t we had jump-servers for decades that could do something very similar?
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  9. Deception “technologies are defined by the use of deceits and/or tricks designed to thwart, or throw off, an attacker’s cognitive processes, disrupt an attacker’s automation tools, delay an attacker’s activities or disrupt breach progression.” – Anyone who uses this technology deserves to be hacked. This is perhaps the stupidest concept I have ever seen and I cannot believe it’s on anyone’s list. Gartner should actually be ashamed of themselves.
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  10. Pervasive Trust Services, “As enterprise security departments are asked to extend their protection capabilities to operational technology and the Internet of Things, new security models must emerge to provision and manage trust at scale.” – Finally we agree on something; centralised management of end-points based on known-good configs.

As far as I am concerned, 99.9% of organisations can effectively ignore this Top 10 list. You will NEVER find a technology that fixes stupid. Just do security properly and you’ll achieve what every organisation is looking for; appropriate, value-for-money, security.

It’s a shame Gartner can’t monitise a ‘Top 10 Information Security Back to Basics’, that would actually be worth a read.

 

No idea.

But let’s be honest, everyone will be making wild speculations at this point, just as ‘experts’ in every other field will be. The only thing for certain, is that the UNcertainty will be used by security vendors to try to scare UK companies into buying something.

This one is unrelated, but is actually very good and you should read it first; Brexit: The Implications for the Insurance Industry.

Two of the pending EU laws in the pipeline that will be most cited are the Payment Services Directive 2 (PSD2) and the General Data Protection Regulation (GDPR). While both of these do not relate to information security per se, security is an enormously important component of each, and penalties will be commensurate with the egregiousness of the data misuse/loss.

The UK would have had to make these law within the next 2 -3 years, but now what? If we’re not IN the EU, do we have to follow the EU rules? Can’t we just do our own thing, like the US?

Well yes, we could, all we’d have to do is adopt something like Safe Harbor and all EU countries would be more than happy to do business with us. Right?

I don’t think so somehow.

Clearly the UK would never put itself in that position [praying silently], and seeing as both PSD2 and GDPR are fully supported by the UK, I would very much doubt any UK-only law would be markedly different. But ANY difference will still complicate things for UK businesses. It will likely require UK organisations to be far more pro-active in the demonstration of their compliance than would otherwise be necessary.

And if there’s one thing that no organisation I have ever come across is good at, it’s the demonstration of good security practices.

Not one.

Luckily for us, there is absolutely nothing in ANY regulation of which I am aware that requires anything more than ‘appropriate’ controls. From the GDPR for example; “Personal data should be processed in a manner that ensures appropriate security and confidentiality of the personal data, including for preventing unauthorised access to or use of personal data and the equipment used for the processing.

This is the greatest thing about my chosen career; Information security cares nothing for law, regulation, compliance, geography, or politics, it’s about a piece of data, on a computer, that someone wants to steal. Everything else is just reporting.

However, getting to the point where the demonstration of compliance is business as usual, is extremely difficult. Not complicated, just difficult. It’s actually very simple, all you have to do is get the CEO/BoD to care about it and it will happen. Easy, right?

UK organisations had 2 years from May 25th to demonstrate compliance with the GDPR, now [potentially] they have to demonstrate their equivalent compliance to every EU business with whom they want to transact. And you thought answering RFPs was bad now!

Nothing will change anytime soon, but in the meantime, just do what you know you should have doing all along, but start now.

Don’t know how, ask.

If you’re a security professional and there’s a new phrase or product going around with which you are unfamiliar, there’s a better than even chance you won’t need that thing. Ever.

The reasons are myriad, but the major offenders are:

  1. It’s something that product vendors invented to scare you into thinking you’ve missed something; [e.g. Advanced Persistent Threats]
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  2. It’s something Gartner was paid to promote into a magic quadrant of some sort, [e.g. most of Gartner’s output]
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  3. It sells column inches, or;
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  4. It’s something you already have but now it has a sexier name. [e.g. Logging and Monitoring is now Security Incident and Event Management (SIEM)]

For me, this pet peeve started with ‘The Cloud’. Suddenly everything had to be “In The Cloud”, that adoption of Cloud-based services was the only way to stay up with your competition …blah blah blah. Basically The Cloud was the only way you were going to stay in business in the digital age.

“But wait David!” I hear you gasp; “Isn’t The Cloud just an application on the Internet? Haven’t we had this capability for, I don’t know, DECADES!?!” Why yes Dear Reader, we HAVE had this capability for decades, but clearly you didn’t know you needed it until it had a fancy name and had vendors shoving the concept down your throat!

I know of organisations who quite literally renamed their ‘Managed Security Services’ to ‘Cloud Security Services’ without changing a SINGLE piece of infrastructure or a single process. And yes, this hid all manner of sins, but for some reason the new name stopped clients asking difficult questions like; “Can you tell me how it works?”

By sheer coincidence, I gave a webinar last week titled “Ignore Future Attacks, Fix Your Broken Security Program First”, it could just as easily be called “Ignore Buzzwords, Fix Your Broken Security Program First” and the content would be almost identical. We need to stop focusing on the new when we usually don’t even know what assets we’re trying to protect, who has access to what, or what any given system should look like from a normalised perspective.

Business needs information in context in order to compete, and the data that makes up that information is stored somewhere on a physical system. I don’t care if it’s virtualised, containerised or whatever-ised, it’s still a piece of hardware running an operating system sitting in a room somewhere (yes, I know it can be distributed). Nevertheless, there is NOTHING you need outside of an established good security practice to protect this data from what’s out there now, and what will be out there in the future. REGARDLESS of its name!

Segmentation, configuration standards, access control, logging and monitoring and a host of other old fashioned and boring names all boil down to one thing; baseline. What should a system look like all day every day, and how do I report anything different. No innovation in security capability (i.e buzzword) will be of any use whatsoever if you don’t have the basics right, because you’ll have no idea what you have, let alone how it should normally behave.

Ignore the hype, ignore the press, ignore Gartner and their ilk, focus on the stuff that you’ve likely relegated to a ‘previous generation’s problems’. They are still your problems too.

Not feeling very creative today, but luckily the Payment Card Industry can always be relied upon to dish out plenty of blodder.

With a stunning twist, the SCC announced the potential release of the DSS v3.2 as early as March. It was greeted by the industry with a resounding; “Meh”. And quite rightly, have you read the potential changes? They are;

…evaluating additional multi-factor authentication for administrators within a Cardholder Data Environment (CDE); incorporating some of the Designated Entities Supplemental Validation (DESV) criteria for service providers; clarifying masking criteria for primary account numbers (PAN) when displayed; and including the updated migration dates for SSL/early TLS that were published in December 2015.

While I understand this is part of their new program to; “…[move] towards a system of smaller, more incremental modifications to address things like the EMV roll-out in the US, rather than larger, wholesale updates.“, when was the last time you saw a large update? You could point to the change from v2.0 to v3.0, but you would only be showing your ignorance of the ‘ROC Reporting Instructions for PCI DSS v2.0’, the incorporation of which accounted for 95% of the difference between the 2 versions (take a look at this if you don’t believe me; PCI DSS v3.0 – Mapping to v2.0_v07NOV13).

But let’s handle each of these ‘changes’ in turn:

  1. Evaluating additional multi-factor – Note the use of the word ‘evaluating’, meaning nothing will actually change for some time. Is multi-factor auth a good idea for all privileged access? Yes, so let’s hope they actually enforce this one properly.
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  2. Incorporating some of the Designated Entities Supplemental Validation (DESV) – For ALL service providers, or just the ones to whom the DESV already applies? If the former, great, but the DESV is mostly a paperwork and process requirement, not additional controls. Not necessarily a terrible thing, but it depends on which requirements.
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  3.  Clarifying masking criteria – This one stumps me, how do you clarify the exposure of ‘first 6 and last 4’ only?
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  4. Migration for SSL and early TLS –  For to new date of 2018 to make ANY sense they should have left the requirement for offering TLS 1.2 by 2016, but allowing backwards compatibility until the later date. The way it’s written, merchants don’t even have to offer v1.2 of TLS until 2018 which is absolute nonsense.

The PCI DSS has always been, and will always be entirely inadequate to protect critical data assets, but frankly, what choice do the card brands have? They are fully aware of the inadequacy of their plastic in the face of current payment innovations, and the only saving grace delaying their rapid decline is the ignorance of the end consumer themselves. Henry Ford is often attributed the best phrase that sums this up perfectly; “If I had asked people what they wanted, they would have said faster horses.” The average consumer simply has no idea what could replace plastic, but when they do, the changes will be incredibly fast, and permanent.

The PCI DSS can never change dramatically, or the multi-billions spent on compliance to date would all be thrown away. Every organisation on the planet who is currently compliant (or reporting as such to be more accurate) would have to spend countless more billions to bring themselves up to the new standard. There is no way the card brands would survive the backlash. They have painted themselves into a compliance corner that cannot protect their 50 year old technology from the current threat landscape.

Yes of course implementing the PCI DSS controls on all forms of data is better than doing nothing, but barely, and can never and will never represent real security.