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The effectiveness of access controls

March 11th, 2010 admin No comments

With all due respect to Varonis and access controls in general (Just the area of Sharepoint is a fertile market for data security), the problem of internally-launched attacks is that they are all done by the “right” people and / or by software agents who have the “right” access rights.

There are 3 general classes of internal attacks that are never going to be mitigated by access controls:

Trusted insider theft

A trivial example is a director of new technology development at a small high-tech startup who would have access to the entire company’s IP, the competitive analyses, patent applications and minutes of conversations with all the people who ever stopped in to talk about the startup’s technology. That same person has access by definition but when he takes his data and sucks it out the network using a back-door, a proxy, an HTTP GET or just a plain USB or Gmail account – there is no way an Active Directory access control will be able to detect that as “anomalous behavior”.

Social engineering

Collusion between insiders, gaming the system, taking advantage of friends and DHL messengers who go in and out of the office all the time with their bags.

Side channel attacks

Detecting data at a distance with acoustic or Tempest attacks – for example. or watching parking lot traffic patterns….

Cultural factors in DLP

March 11th, 2010 admin No comments

What is interesting and generally overlooked – is the cultural differences between the US and the rest of the world.  The Europeans prefer a more nuanced approach stressing discipline and procedures,The Americans are compliance driven and IT top heavy, I imagine if you look at DLP sales – 98% are in the US, being (right or wrong) compliance driven.

Last September, Forrester did a seminar in Amsterdam on data security – only 10% of the CTOs/CIOs that attended the meeting had plans to implement DLP in 2010.

The Europeans have a point – but, policies and procedures are only as good as the monitoring and enforcement behind them. This is where DLP comes into play- collecting data in several realms – data channels, content and organizational anomalies (downloads, uploads etc…).

In addition – there is a strong and well-known link between the social health of employees in an organization and the company’s economic/business health.  In a successful business unit – people are happy, and happy people contribute to the success of the business.   Unhappy people don’t identify, have problems contributing and leave or cross the line to malicious behavior.

For my money (and this is my experience in a dozen DLP deployments in EMEA) – the key value add of DLP technology is not the prevention part but the monitoring part and it’s role in a feedback / educational loop with the organization.

If you only do one thing this year – you should start measuring data security events and using those measurements to improve your policies, procedures and systems – and user education.

Facebook disclosure cancels raid on terrorists

March 11th, 2010 admin No comments

I want to challenge the effectiveness of top-down, monolithic security frameworks (ISO 27001/PCI DSS) – I submit that rapidly changing threats – social networking, cyberstalking, social engineering, cyber-stalking and custom spyware are threats that exploit people and system vulnerabilities but are not readily mitigated by a top down set of security countermeasures.

The recent case of the Opsec security violation on Facebook in Israel reported by the Jerusalem Post, is a good example of how a hierarchical organization (Army) is threatened by a flat social network. The good news was that the security countermeasure was found the social network itself – herein lies the lesson.

The IDF was forced to cancel a recent arrest operation in the West Bank after a soldier posted information about the upcoming raid on his Facebook page.The operation was scheduled to take place several weeks ago in the Binyamin region. The soldier, from an elite unit of the Artillery Corps, posted on his Facebook page: “On Wednesday, we are cleaning out [the name of the village] – today an arrest operation, tomorrow an arrest operation and then, please God, home by Thursday.”

The status update on the soldier’s page was revealed by other members of the soldier’s unit. His commanders then updated Judea and Samaria Division commander Brig.-Gen. Nitzan Alon, who decided to cancel the operation out of concern that the mission had been compromised.

Organizations need to leave the static top down control frameworks a few times a year and look outside the organization for links and interdependencies – and talk to the soldiers in the trenches in customer service, field sales and field service.

The information you will get from people outside your firm and from people with dirty hands is far more valuable than rehashing the ISO27001 check list in an audit.

The most valuable data is from questions you haven’t asked yet – not from a checklist in an Excel spreadsheet in the hands of a junior auditor from KPMG.

Learning about change and changing your security

March 11th, 2010 admin No comments

Reading through the trade press, DLP vendor marketing collateral and various forums on information security,  the conventional wisdom is that the key threat to an organization is trusted insiders. This is arguable – since it depends on your organization, the size of the business and type of operation.   However -

This is certainly true at a national security level where trusted insiders that committed espionage have caused considerable damage.  MITRE Corporation – Detecting Insider Threat Behavior

There are three core and interrelated problem in modern data security:

  1. Systems are focussed on rule-breaking (IDS, DLP, firewalls, procedures) – yet malicious insider can engage in data theft and espionage without breaking one of the IDS/IPS/DLP rules.
  2. The rules are static (standards such as ISO 27001 or PCI DSS 1.x) or slow-moving at best (yearly IT Governance audit)
  3. Ignore collusion between insiders and malicious outsiders whether for espionage purposes (a handler who manipulates an employee) or for criminal purposes (stealing customer data for resale).

You may say – fine, let’s spend more time observing employee behavior and educate supervisors for tell-tale signs of change that may indicate impending involvement in a crime.

However – malicious outsiders (criminals, competitors, terrorists…) that may exploit employees in order to obtain confidential data is just another vulnerability in a whole line of business vulnerabilities.  Any vulnerability must be considered within the context of a threat model – the organization has assets that are damaged by threats that exploit vulnerabilities that are mitigated by countermeasures.   The organization needs to think literally  outside the box and at least attempt to identify new threats and vulnerabilities.

The issue is not that employees can be bought or manipulated, the issue is that government and other hierarchical organizations use a fixed system of security controls.  In reducing the organization’s security to passive executives of defense rules in their procedures and firewalls, we ignore the extreme ways in which attack patterns change over time. Any control policy that is presumed optimal today is likely to be obsolete tomorrow.  It is a fair assumption that an organization that doesn’t change data security procedures frequently – will provide an insider with  enough means, opportunity and social connectivity to game the system and once he or she has motivation – you have a crime.

Learning about change and changing your security systems must be at the heart of day-to-day security management.

Content protection and plagiarism

February 25th, 2010 admin 1 comment

Most people tend to view content protection as a recording industry or corporate espionage  issue.   We have forgotten that people who plagiarize original content are also violating content security – someone else’s security in this case.

My colleague Anthony Freed (who runs Information Security Resources) recently got an email from computer scientist and mathematician, Aaron Krowne.  Aaron got plagiarized by no less than the the NY Times. The original story that Aaron reported is here – NY Times Caught Lifting Implode-O-Meter, Other Online Pubs’ Material

With Aaron’s kind permission, I’ve decided to republish  the original article verbatim as a public service to my data security clients in the tech, bio-pharma and telecom industries – because it could happen to you also. Paraphrasing and proper citations are the kind of thing they teach you in elementary school and this is a blunt reminder to remember what Ms. Bates, your third grade teacher taught you.

We knew it was happening, but it looks like it was more extensive and systematic than we first thought:

How long did New York Times editors know of Kouwe’s story copying?

On Dec. 26, 2008, an online publication covering the housing market, Mortgage Implode-O-Meter, published an exclusive news report that a group of financial services firms, led by Steven Mnuchin of Dune Capital, would be buying failed IndyMac Bank from the FDIC. IndyMac was one of the first large thrift banks to be seized by the FDIC at the start of the financial crisis.

A day later, Kouwe reported for the NYT’s Dealbook that Dune Capital was expected to buy IndyMac and added two other names of buyers, JC Flowers and John Paulson, to the story. Kouwe’s report did not credit Mortgage Implode-O-Meter for first breaking the fact that 1) a private equity group was buying IndyMac 2) Dune Capital was involved.

Wire services picked up the NYT’s story and the rest of the business press ended up sourcing Kouwe for breaking the news on the sale of IndyMac to a private equity group.

Shockingly, Kouwe wrote the below, justifying his plagiarism and failures to attribute (my bold, and comments in italics):

I don’t know what to tell you. Things move so quickly on the Web that citing who had it first is something that is likely going away, especially in the age of blogs [except of course amongst blogs themselves, which give attribution religiously.]
Read more…

Data discovery and DLP

February 23rd, 2010 admin No comments
A number of DLP vendors like Symantec and Websense have been touting the advantages of data discovery – data at rest and data  in motion. Discovery of data in motion is an important part of continuous improvement of data security policies.  However – there are downsides to data discovery.
Discovery is a form of voyeurism – it’s titillating but the fun wears off quickly.

Automated discovery of data at rest is  an unsurmountable  challenge for institution with large quantities of PCs, data and thousands of document formats, most of which are not well-documented and all the application and database server technologies that were ever invented. Smaller companies may find it either unnecessary or not cost-effective.

Discovery of data at rest is also  a double-edged sword.  From a compliance perspective, it’s not only not required by PCI DSS 1.x but it can create exposure issues that no business in their right mind would want to deal with.  Also – why would a business want to buy products and services from a technology vendor vendor and allow them to “discover” their data?

Love to hear your comments and what you think.

Do you have a business need for DLP?

February 19th, 2010 admin 1 comment

To be able to do something before it exists,
sense before it becomes active,
and see before it sprouts.


The Book of Balance and Harmony

(Chung-ho chi).
A medieval Taoist book

Will security vendors, large to small  (Symantec, McafeenexTierANBsys and others..) succeed in restoring balance and harmony to their customers by relabeling their product suites as unified content security (Websense) or enterprise information protection (Verdasys)?

I don’t think so.

Unfortunately – data security is not an enterprise suite kind of problem like ERP. You don’t have harmony, synergy and control over business process; you have orthogonal attack vectors:

  • Human error – cc’ing a supplier by mistake on a classified RFP document
  • System vulnerabilities – Production servers with anonymous file transfer protocol (FTP) turned on
  • Criminal activity – Break-ins, bribes and double agents (workers who spy for other groups or companies)
  • Industrial competition/breach of non-disclosure agreements – the actuary who went to work for the competition

After 5 years of hype, most  customers have a high awareness of DLP products but fewer (especially outside the US) are buying DLP technologies  and even fewer are succeeding with their DLP implementations. This stems from the customer and vendors’ inability to answer two simple questions:

  1. Who is the buyer?
  2. What is her motivation to protect information?

A common question I hear from my clients, is, “Who should ‘own’ data security technology?” Is it the vice president, internal auditor, chief financial officer, CIO or CSO, our security consultants or our IT outsourcing vendor; IBM Global Services?

If there is no clear business need for information protection (the kind that a CEO can enunciate in a  sentence) – the company is not going to buy DLP technology.

The business need for data security derives directly from  the CEO and his management team. In firms with outsourced IT infrastructure, the need for data security becomes more acute as more people are involved with less allegiance to the firm.

To help qualify an organization’s business need for DLP technology, let’s examine the decision drivers, or what compels companies to buy data security products, and the decision-makers, or those who sign off on the products. Let’s look at seven industries: banking, credit card issuing, insurance, pharmaceuticals, telecommunications, health care and technology.

INDUSTRY TYPICAL DATA SECURITY DRIVERS DECISION – MAKERS
BANKING A real event, such as theft of confidential customer account information by trusted insiders

Privacy regulations such as the Gramm-Leach-Bliley Act, HIPAA

The Sarbanes-Oxley Act, for transparency and timeliness in reporting of significant events

CSO or CIO
CREDIT CARD ISSUERS Ongoing theft of customer transactional information by customer service reps

Data breach threat to credit card numbers that haven’t yet been printed on plastic cards and issued to card holders

Privacy regulations, Sarbanes-Oxley , nondisclosure agreements with business partners

The security officer or information security officer (many issuers have separate functions for physical and information security)
INSURANCE A real event, such as theft of customer lists by competitors

Fear of losing actuarial data

Exposure to data leakage of credit card numbers in online systems

General counsel, VP of internal audit, CFO
PHARMACEUTICALS Theft of chemistry, manufacturing and control information, product formulation and genome data by trusted insiders

Difficulty in preserving secrecy of sensitive intellectual property prior to patent filings

Sensitivity of company records during due diligence processes

General counsel, CFO, chief compliance officer
TELECOM/ONLINE BUSINESS
(Telecom service providers and large online operations such as Yahoo collect and aggregate huge quantities of data, and the higher up the value chain you go with data aggregation, the more valuable and vulnerable the asset.)
Prepaid code files

Pricing data

Strategic marketing plans

Call detail records (analogous to credit card transaction records, these are extrusions by customer service representatives to private investigators and difficult to detect)

Customer credit card records

VP of internal audit, VP of technologies
HEALTH CARE Privacy regulations/HIPAA

Need to protect pricing data of drugs and supplies purchased by the health care organization

CSO, VP of internal audit
TECHNOLOGY COMPANIES Theft of:

Source code

Designs, pictures and plans of proprietary equipment

Strategic marketing plans

CEO, CTO

Business unit strategy for data security

February 17th, 2010 admin No comments

At a recent seminar on information security management, I heard that FUD (fear, uncertainty and doubt) is dead, that ROI is dead and that the insurance model is dead. Information security needs to give business value. Hmm.

This sounds like a terrific idea, but the lecturer was unable to provide a concrete example similar to purchasing justifications that companies use like: “Yes, we will buy this machine because it makes twice as many diamond rings per hour and we’ll be able corner the Valentine’s Day market in North America.”

The seminar left me with a feeling of frustration of a reality far removed from management theory. Intel co-founder Andy Grove said, “A little fear in an organization is a good thing.” So FUD apparently isn’t dead.

This post will help guide readers from a current state of reaction and acquisition to a target state of business value and justification for information security, providing both food for thought and practical ideas for implementation.

Most companies don’t run their data security operation like a business unit with a tightly focused strategy on customers, market and competitors. Most security professionals and software developers don’t have quotas and compensation for making their numbers.

Information security works on a cycle of threat, reaction and acquisition. It needs to operate continuously and proactively within a well-defined, standards-based threat model that can be benchmarked against the best players in your industry, just like companies benchmark earnings per share.

In his classic Harvard Business Review article, What Is Strategy?, Michael Porter writes how “the essence of strategy is what not to choose … a strong completive position requires clear tradeoffs and choices and a system of interlocking business activities that fit well and sustain the business.” The security of your business information also requires a strategy.

Improvement requires a well-defined strategy and performance measures, and improvement is what our customers want. With measurable improvement, we’ll be able to prove the business value of spending on security.

Ask yourself these questions:

  1. Is your information asset protection spending driven by regulation?
  2. Are Gartner white papers your main input for purchasing decisions?
  3. Does the information security group work without security win/loss scores?
  4. Does your chief security officer meet three to five vendors each day?
  5. Is your purchasing cycle for a new product longer than six months?
  6. Is your team short on head count, and not implementing new technologies?
  7. Has the chief technology officer never personally sold or installed any of the company’s products?

If you answered yes to four of the seven questions, then you definitely need a business strategy with operational metrics for your information security operation.

Read more…

How can we convince our VP that a network-based DLP makes sense?

February 17th, 2010 admin No comments

My colleague, Michel Godet – sent me a link to an article that Mike Rothman recently wrote.

Michel  (rightly) thinks that it supports the approach that we have been pushing in Europe for over a year now, to justify data security technology investments by using Value at Risk calculations.

Mike’s article – building a business case for security is good. I agree with most of what he writes (I would have commented but searchsecurity doesn’t allow commenting on their Ask The Security Expert: Questions & Answers articles.

So – I will use my own blog to post a couple of my comments (I should probably ping Mogull on this too but I lost  his email)

1) I agree that if you can’t get past the first energy barrier of concern with information protection than you are a non-starter for DLP ( or any data security technology for that matter – it must fit the business needs – otherwise it’s like trying to sell a trombone to a violinist.  Total waste of time

However – once you get past the first road block, the business problem for security investment is:

What is your value at risk, what are the right security countermeasures and are they cost-effective.? Not – what are the vendors selling this quarter.

There is no reason in the world why data security should be any different than any other IT investment.

2) I totally disagree that looking only at a network-based DLP product is inherently limiting. Just because a few vendors like Websense and Symantec, have integrated end point and gateway products doesn’t  makes them cost-effective data security countermeasures, ensure success of the project or prevent the next data breach.

Let me submit  two counter-examples:

A) Suppose all your sensitive data is in the cloud – then maybe network DLP is a good fit

B) Suppose all your endpoints are in the cloud – then maybe endpoint DLP is a good fit

C) Suppose all your sensitive data is on notebooks – then maybe encryption is the right countermeasure to data loss.

The answer is that you have to measure stuff – measure your people, process and system vulnerabilities and where your assets are headed. After that you need to estimate your  VaR and only THEN start thinking about the people, process and technology countermeasures

BTW – I’ve been saying this for years

October 28, 2004 –  A guide to buying extrusion prevention products

March 17, 2005 - How to justify Information security spending

Now if only we could find a way to monetize being right.

Data security and compliance – Best practices

January 28th, 2010 admin Comments off

Compliance is about enforcing business process – for example, PCI DSS is about getting the transaction authorized without getting the data stolen. SOX is about sufficiency of internal controls for financial reporting and HIPAA is about being able to disclose PHI to patients without leaks to unauthorized parties.

So where and how does DLP fit into the compliance equation?

Let’s start with COSO recommendations for internal controls:

“If the internal control system is implemented only to prevent fraud and comply with laws and regulations, then an important opportunity is missed…The same internal controls can also be used to systematically improve businesses, particularly in regard to effectiveness and efficiency.”
In the attached presentation – we review data security requirements in compliance regulation, we discuss provable security and show how DLP can serve both as an invaluable measurement tool of security metrics of inbound and outbound business transactions and when required – as a last line of defense for personal account numbers.