Tag Archives: Intel

Information Security Best Practices

What is more important – patient safety or hospital IT?

What is more important – patient safety or the health of the enterprise hospital Windows network?  What is more important – writing secure code or installing an anti-virus?

A threat analysis was performed on a medical device used in intensive care units.  The threat analysis used the PTA (Practical threat analysis) methodology.

Our analysis considered threats to three assets: medical device availability, the hospital enterprise network and patient confidentiality/HIPAA compliance. Following the threat analysis, a prioritized plan of security countermeasures was built and implemented including the issue of propagation of viruses and malware into the hospital network (See Section III below).

Installing anti-virus software on a medical device is less effective than implementing other security countermeasures that mitigate more severe threats – ePHI leakage, software defects and USB access.

A novel benefit of our approach is derived by providing the analytical results as a standard threat model database, which can be used by medical device vendors and customers to model changes in risk profile as technology and operating environment evolve. The threat modelling software can be downloaded here.

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Compliance, security and Wikileaks

This is an essay I wrote in 2004.  There is nothing here that doesn’t still ring true, especially with the latest round of Wikileaks disclosures. I wrote then and I still hold that  compliance and and data security technology cannot protect an organization from a data breach. The best security countermeasures  for protecting a company’s digital assets and individuals’ private information are uncompromising ethics and honest management.

On security and compliance

It’s impossible to ignore the fact that compliance (like it or not) is a driver for companies to invest in improving their software and data security past running a firewalls and anti-virus. While compliance drives companies into taking action, do compliance activities actually result in implementing and sustaining strong data security  management and technology countermeasures?  We will see that the answer is generally no.

There is plethora of compliance regulations. There is regulation for  Privacy(HIPAA/HHS), for Children: (Children’s Online Privacy Protection Act (COPPA) for Credit Card holders: (FCRA), for merchants (PCI DSS), for Public entities (Sarbanes-Oxley), for Insurance (State laws) , for Securities trading (SEC), for Telecom (New York State Public Service Commission rulings) and many many more.

Looking at the wide variety of regulations and standards we can see that compliance really comes in only 3 flavors:

  1. Governance regulation such as HIPAA and SOX.  Government compliance regulation is focussed on customer protection and requires a top down risk analysis process.
  2. Industry compliance regulation such as PCI DSS that focuses on protecting the card association supply chain, doesn’t require risk analysis and mandates a fixed control set (if you think that best-practice security control sets are a good idea, then stop and consider the abysmal failure of the Maginot line in WWII and the Bar Lev line in the Yom Kippur war in 1973).
  3. Vendor-neutral standards such as ISO 27001 that focuses on data and system protection, doesn’t require risk analysis nor consider asset values although it does provide what is arguable the most comprehensive set of controls.

Well-meaning as the regulators may be, there are two fundamental flaws in the security-by-compliance model:

  1. You can comply without being secure and use compliance as a fig-leaf for lack of data security
  2. You can invest in software and data security without being compliant

…We don’t invest in data loss prevention technology because it’s a criminal offense when one of our employee breaches critical filings. We feel the legal deterrent is sufficient.
IT Manager – Securities and Exchange Commission in a Middle East country

Privacy regulation trends in the US and Europe

Government-regulated privacy-protection of information is a natural response rooted in the field of telecommunications, since countries either own the telecom business outright or tightly regulate their industry. This has largely led to a view of electronic privacy as an issue of citizen rights versus state legislation and monopoly.

In the information age, privacy has two dimensions – intrusion and data breach:

  • Protection against intrusion by unwanted information or criminals; similar to the constitutional protection to be secure in one’s home.
  • Protection against data breach by controlling information flows about an individual’s or a business’s activities; for example preventing identify theft or protecting a company’s trade secrets.

Regulation has moved in two major directions–centralized general protection and decentralized ad-hoc protection. The EEC (European Economic Community ) has pursued the former, and passed comprehensive data protection laws with coordination on information collection and data flows. The United States, in contrast, has dealt with issues on a case-by-case basis (health-care, credit cards, corporate governance etc…) resulting in a variety of ad hoc federal and state legislation.

A synthesis of the European and the American approaches is to formulate a set of broad rules for vertical industry. This was the direction taken by the New York Public Service Commission on the issue of telecommunications privacy. However, U.S. privacy legislation remains considerably less strict than European law in the regulation of private databases. Two Representatives in the House Select Committee on Homeland Security are calling for a Privacy Czar. The Privacy Czar would be responsible for privacy policies throughout the federal government as well as ensuring private technology does not erode public privacy.

“Right now, there’s no one at home at the White House when it comes to privacy. There’s no political official in the White House who has privacy in their title or as part of their job description. Congress should take the lead here because this administration has not,” says Peter Swire, an Ohio State University law professor and former chief privacy officer in the Clinton administration in an interview with Wired back in 2006 – and in the Obama administration has anything changed?
(http://www.wired.com/news/privacy/0,1848,63542,00.html )

Horizontal applications

Sarbanes Oxley: enforcing corporate governance

The Sarbanes-Oxley Act (SOX) has had a major impact on US corporate governance SOX was a response to the accounting scandals and senior management excesses at some public companies in recent years. It requires compliance with a comprehensive reform of accounting procedures for public corporations to promote and improve the quality and transparency of financial reporting by both internal and external independent auditors. SOX regulation is enforced by the Public Company Accounting Oversight Board (“the Board”).

SOX Section 404 – “Management Assessment Of Internal Controls ” is indirectly relevant to data breach. It requires an “internal control” report in the annual report which states management responsibility and assesses effectiveness of internal controls. Companies are also required to disclose whether they have adopted a code of ethics for senior financial officers and the contents of that code.

SOX Section 409 – “Real Time Disclosure” implies that a significant data breach event be disclosed on “a rapid and current basis”. SOX also increases the penalties for mail and wire fraud increased from 5 to 10 years and creates a crime for tampering with a record or otherwise impeding any official proceeding.

HSS/HIPAA: enforcing patient privacy

Each time a patient sees a doctor, is admitted to a hospital, goes to a pharmacist or sends a claim to a health plan, a record is made of their confidential health information. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) gave Congress 3 years to pass health privacy legislation. In May 2003 – the HHS (Dept of Health and Human services implemented federal protections for the privacy of individual health information under the Privacy Rule, pursuant to HIPAA. Because of limitations of HIPPA, the rule is far from seamless and will require a lot more work in the US Congress by both parties to ensure privacy of personal health information.

My conclusion on all of this is:

  • SOX has been a strong driver for sales of  IT  products and services, but it’s totally unclear that the billions spent by corporate America on compliance has actually done much to improve customer protection.

Vertical Industries

Securities: Did we leave the cat guarding the cream?

Annette L. Nazareth, market regulation director at the U.S. Securities and Exchange Commission, outlined proposals at a securities industry conference in New York on May 21 calling for stock exchanges, as the Associated Press put it, “to abide by most of the requirements they set for companies they list.”
(http://www.sec.gov./news/speech/spch052104aln.htm )

Wow.

Insurance Industry: Federal versus free market

October 2003, witnesses before the Senate Commerce committee testified regarding insurance industry regulations. The committee analyzed the current US system, which relies on state law, and examined proposals for improving industry regulation. One of the central issues was whether or not the federal government should play a larger role in insurance industry regulation. Also discussed was the need to provide protection for consumers without forcing unnecessary regulations on insurance companies. Some senators expressed concerns about high insurance rates.

Conclusion

If you’re a vendor of IT products and services, it has become increasingly difficult to sell security with rising complexity of attacks and countermeasures and decision makers who find it difficult to understand what works and what doesn’t.

What will happen to the B2C security industry is hard to say. Perhaps the Intel McAfee acquisition is a sign of things to come where security becomes a  B2B  industry  like safety manufacturers for the aerospace and automotive industries.

Until security becomes built-into the cloud, my best suggestion for a business is don’t leave your ethics at home and don’t wait for the government to tell you what you learned from your parents at age 5 – put your toys away and don’t steal from the other kids.

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Teachers Matter More Than PCs

Just as I was wondering how pumping trillions into banks will solve the GFC (great financial crisis) – along comes Craig Barrett (former CEO of Intel) and tells us that Teachers Matter More Than PCs

“We’re bailing out Wall Street, we’ll be bailing out Detroit soon, we’re bailing out the agricultural sector with high subsidies at a time of record crop prices,” Mr. Barrett said. “Where is the public outrage that the U.S. education system is failing our kids?”

This is a particularly cogent point for someone like me who lives in Israel. The Israeli Ministry of Education has been installing massive quantities of PCs in classrooms from kindergarden to 12th grade high school.  The lip-service to PC and Microsoft Windows usage in the classroom has reached new levels of absurdity when I heard from my niece, who is a  first grade teacher, that they teach computer literacy and how to use Microsoft Paint.  It is no accident that achievements of Israeli High School students in international math tests have fallen from the top 10 to the bottom 50 in less than 20 years.

Schools should take a lesson from best practice risk management of large software engineering projects:  increasing the number of programmers in the middle of a failing project is a very bad idea.  Less is more in programming and less PCs are more in the classroom.

Give the classroom back to the teachers.   Invest all that money in better salaries.   Our kids live and breathe Internet and computers – its part of their life and just as there is no reason to teach children how to use a phone, there is no reason for a first grade class to learn how to use Paint.

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Ex-Intel worker charged with $1B data theft

Big time data theft event, this time by an employee leaving Intel to go to work for AMD. A Worcester, Mass. man has been charged with stealing trade secrets worth more than $1 billion.

Biswamohan Pani, 33, was indicted for allegedly stealing trade secrets from Intel’s Hudson, Mass. facility and downloading confidential documents from Intel offices in California.

According to the indictment, Pani gave notice to leave Intel and told his superiors he was using up about a week of vacation while looking for a job at a hedge fund.

In reality, according to the indictment, he had taken a job at Intel rival AMD and, while using up vacation time at Intel, was downloading documents marked by Intel as confidential. Without going into the entire discussion of Intel’s management of intellectual property, there are some interesting  questions:

Why was an employee, who had announced he was leaving, and was running down vacation at home – even allowed to have access to Intel file servers?

How did Intel discover that confidential documents were being downloaded? Does Intel use data loss prevention technology? were they tipped off by another employee? or did the investigation start once Intel discovered that the employee was going to work for a competitor and then they started checking download logs?

Full article on the Sacremento Business Journal

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