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Health insurer data breaches

July 29th, 2010 admin Comments off

switched.com is having trouble understanding the attack vector of a data breach.  They apparently believe that  software vulnerabilities can be mitigated by consumers “actively protecting their information”.

Hackers recently attacked WellPoint, a health insurer which reportedly covers 34 million people. As a result of the breach, the company notified 470,000 individual customers that confidential information, including medical records and credit card numbers, may have been compromised. It’s imperative that consumers actively protect their information (sic), because cyber-criminals have accessed at least 358,400,000 records belonging to U.S. citizens over the past five years. [From: CBS News]

I recommend treating passwords like  cash, but give me a break. If over 350 million credit card records have been breached, then active protection measures are useless since your credit card is already disclosed.

Together with gems of  security naiveté in the American press,  we can add another round of US-European political infighting over who has a bigger schlong.

The Solvency II European insurance supervision directive is “not as comprehensive and transparent” as US regulation, according to New York’s state insurance regulator. Jim Wrynn, superintendent of the New York State Insurance Department, also criticised efforts by stakeholders in the process of the European regulatory overhaul to deny equivalence status to the US while its state-based regulation remains in place…Wrynn was critical of (the Solvency II) approach, and described the current US model as “a well-tested and comprehensive regime”. [From: risk.net]

I suppose that AIG and Wellpoint don’t count.

Operational risk management – what we really need

July 29th, 2010 admin 2 comments

Operational risk management has been the buzz word du-jour in recent years, due to the Basel II initiative in the banking industry and Solvency II in the insurance industry.

The Basel II definition of operational risk is “the risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events.”

It seems that in the middle of the great financial crisis, TARP, unmet calls for transparency and trillions being sunk into the US financial services industry (instead of encouraging innovation, manufacturing and creation of free cash flow…), Basel II deserves to be judged and found wanting.

Perhaps we need to update the Basel II definition of operational risk and bring it into line with a modern set of threats. For example, we might say, let’s add to the Basel II definition, “… and risks due to networking with other businesses”. This is a reasonable addition, since in my experience in data security projects and according to the Verizon security breach reports,  over 70% of data loss incidents involve outsourcing and sub-contractors.

External business partnerships are indeed, a source of risk for financial institutions that do business process outsourcing (especially if one considers data loss) but it appears to me that the Basel II and Solvency II definitions  are  less appropriate for the technology and manufacturing industries, where  innovation and product development are performed by relatively small engineering teams and key assets are product quality and customer safety and not credit cards in database servers.

Let’s take the example of a company that makes a robot to assist in micro-surgery.

For the medical device company, the biggest operational risk  is a flawed product that might damage a patient. The FDA sees this as a regulatory issue and addresses it with the 510(K) but my gut feeling is that most small (4-6 people)  software development teams don’t really have a “process”.  After an audit by a regulatory affairs consultant, they can comply and still fall hard on a software defect or design flaw.

It’s amazing to me that the Basel II definition of does not consider customer safety as an  operational risk, and yet, the lack of customer safety and networked-business risks in the Basel II definition only serves to illustrate the futility of a check list approach to operational risk management.

Since regulatory compliance is not a substitute for analyzing particular threats to a particular business unit,  I would propose a different definition of op risk:

“Any combination of one or more threats that exploits vulnerabilities to damage company assets as measured in dollars (or euro or yen ….)”

This definition is universally applicable to financial services, IP developers, manufacturing, distribution, health care, bio med etc…The definition does not limit business management to risk analysis inside the company but enables a company to consider threats due to product quality, compliance, extended business relationships, PHI, PII and a whole slew of new risks that don’t even exist yet on their current threat surface.

It’s a definition that forces the company executives to ask themselves what are their key threats and assets and vulnerabilities and how much of the company value is at stake.

Threat models are not a silver bullet solution to prevent a crisis like AIG on one hand or Toyota on the other. A threat model is only a tool to implement a risk strategy by the business management. Threat modeling  needs to be used in the proper way, measured in dollar values and must be reviewed regularly – at least once/year.

The beauty of the above definition is that it links operational risks to business operations.

Any business in any vertical, must define their own threat landscape, define their control/security countermeasure strategy, run their own risk assessment regularly and  insure that their data security and regulatory compliance policies, procedures and systems are aligned with the latest version of their threat model.

Read more about threat modeling and operational risk management on this blog.

Are you still using Excel for risk assessment?

June 18th, 2010 admin Comments off

There is a school of thought that says that you can take any complex problem and break it down like swiss cheese. Risk assessment data collection and analysis with Excel is one of those problems that can’t be swiss-cheesed.  A collection of brittle, unwieldy, two dimensional worksheets is a really bad way of doing multi-dimensional modelling.

Consider that a typical risk assessment exercise will have a minimum of 4 dimensions (assets, threats, vulnerabilities and controls) and I think you will agree with me that Excel is a poor fit for risk assessment.

Here is where PTA (Practical Threat Analysis) comes to the rescue. You can download the free risk assessment software and try it yourself.

Any risk assessment process can be automated using Practical Threat Analysis and the PTA threat modeling database.  PTA is a threat modelling methodology and software tool that has been downloaded over 15,000 times and has thousands of active security analyst users on a daily basis.

PTA (Practical Threat Analysis) was first introduced in a paper by Ygor Goldberg titled “Practical Threat Analysis for the Software Industry” published online at Security Docs in October 2005. PTA provides a number of meaningful benefits for security and compliance risk assessments:

  • Quantitative: enables business decision makers to state asset values, risk profile and controls in familiar monetary values. This takes security decisions out of the realm of qualitative risk discussion and into the realm of business justification.
  • Robust: enables analysts to preserve data integrity of complex multi-dimensional risk models versus Excel spreadsheets that tend to be unwieldy, unstable and difficult to maintain.
  • Versatile: enables organizations to reuse existing threat libraries in new business situations and perform continuous risk assessment and what-if analysis on control scenarios without jeopardizing the integrity of the data.
  • Effective: recommends the most effective security countermeasures and their order of implementation. In our experience, PTA can help a firm mitigate 80% of the risk at 20% of the total control cost.

The PTA calculative model is implemented in a user-friendly Windows desktop application available as a freeware at the PTA Technologies web site. A PTA ISO 27001 library is available as a free download and is licensed under the Creative Commons Attribution License.

The need for cost effective risk reduction

Despite the importance of privacy and governance regulation, compliance is actually a minimum but not sufficient requirement for risk management.

The question is: What security controls should a firm implement after a risk assessment?

Taking ISO 27001 as a baseline security standard with a comprehensive set of controls, the ISO 27001 certification process can be as simple or as involved as an organization wants but there are always far more available controls than threats. As a result, organizations, large and small, find themselves coping with a long and confusing shopping list of controls. You can implement the entire checklist of controls (if you have deep pockets), you can do nothing or you can try and achieve the most effective purchase and risk control policy (i.e. get the most for your security investment dollar) with a set of controls optimized for your business situation.

However, implementing additional controls does not necessarily reduce risk.

For example, beefing up network security (like firewalls and proxies) and installing advanced application security products is never a free lunch and tends to increase the total system risk and cost of ownership as a result of the interaction between the elements and an inflation in the number of firewall and content filtering rules.

Firms often view data asset protection as an exercise in Access Control (Section 11 of ISO 27001) that requires better permissions and identity management (IDM). However, further examination of IDM systems reveals that (a) IDM does not mitigate the threat of a trusted insider with appropriate privileges and (b) the majority of IDM systems are notorious for requiring large amounts of customization (as much as 90% in a large enterprise network) and may actually contribute additional vulnerabilities instead of lowering overall system risk.

The result of providing inappropriate countermeasures to threats is that the cost of attacks and security ownership goes up, instead of risk exposure going down.

How to choose cost-effective controls

A PTA threat model enables a risk analyst to discuss risk in business terms with her client and construct an economically justified set of security controls that reduces risk in a specific customer business environment. A company can execute an implementation plan for security controls consistent with its budget instead of using an  all-or-nothing checklist designed by a committee of experts who all work for companies 100x the size of your operation.

Brainwashed by propaganda?

June 3rd, 2010 admin Comments off

I normally blog about data security issues – I specialize in helping technology companies prevent trusted insider data leakage, protect intellectual property, reputation and trade secrets and mitigate attacks on sensitive data by malicious software.

However – the recent terror flotilla to Israel, the double moral standard of the UN Human Rights Council condemning Israel 25 times in the past 3 years without condemning once human rights violations in Iran and Darfur – makes one pause to think.

In Israel there is a general feeling that Israelis are to blame for the world hating Israelis.

There are at least six versions to this way of thinking – first is anti-semitism (people hate Israelis because they are Jewish), a second version is that extreme left university professors have provided the political rhetoric and ammunition for our enemies,  a third version is that our political leaders are weak and or corrupt (Bibi and Barak),  a fourth version is that the occupation has corrupted Israeli morals, making Israelis despicable in the eyes of the world, a fifth version is that if we would only get our public relations sorted out and speak with a British accent – then the world would accept Jewish presence and a sixth version says that the Palestinians, Iranians and Syrians really want peace – and that if Israel would only stop the occupation and down-size, then we would have peace and the world would accept the Jewish nation – once it had been reduced to an acceptably small, bite-sized portion.

I believe that all versions rest on one question which has not been fundamentally tested – which is what do our neighbors really want?

Brainwashed by propaganda?
Deborah Fink from the organisation Jews for Boycotting Israeli Goods (J-BIG), said it was “disgusting” that so many children were present to support the Israeli state.
They’ve been brainwashed. We wouldn’t bring loads of children out to things like this. They go to schools where they’re brainwashed with Israeli propaganda.
Ms Fink is one of many British Jews who campaign for an end to the occupation of Gaza and the West Bank.

Apparently Ms. Fink is mind-controlled by Palestinian propaganda and has conveniently forgot that Israel does not occupy Gaza, having left that area almost 5 years ago. Read more at BBC News – Gaza Crisis. I recommend that Ms. Fink read about the unilateral disengagement from Gaza in August 2005.

Unfortunately, we – Israelis are mind-controlled as well and have forgotten our primary mission – which is the development of the state of Israel – not down-sizing, not outsourcing nor appeasing terrorists.

There is I believe, a fundamental misunderstanding of what makes terrorists tick.

In order to test the assumption behind the various Middle East peace plans of the past 30 years – it is important to test an important hypothesis – “Israel’s neighbors want peace”.

Let’s conduct  a “gedanken experiment”  using 2 assumptions, which I believe are accepted by most politicians today – and consistent with US, Russian and European foreign policy:

  1. Peace is a valuable product.
  2. Israel holds the keys to regional peace

Since there is wide agreement in Israel, the US, Europe and Muslim countries, that Israel holds the keys to regional peace – then it becomes a question of price – how much are the other parties (Syria, Palestine, Iran, Turkey …) willing to pay to acquire that product – i.e. peace.

The price might be – how much land Syria is willing to give us in return for peace or how much water Turkey is willing to give us in exchange or how much land Palestine is willing to pay in return for peace or how badly Iran wants Israeli  technology for clean power generation.

Once we have agreed on the price – it’s just a question of agreeing terms of payment and issuing the PO.

If the thought experiment is correct then, the current Israeli strategy of paying the buyer to take our product seems ludicrous.

If the thought experiment is incorrect – then one or more of our assumptions must be false – either our neighbors don’t want peace, peace is not a valuable commodity or – Israel doesn’t hold the keys to acquiring peace in the Middle East.

Reading past the political vitriol of Iran and Abu Maazen,  it’s therefore important to examine our assumptions, starting with the question – “What do terrorists really want?”  and understand why Israel is losing the war against terror.

Worst executive behavior of the month award

November 24th, 2009 admin 1 comment

For my Israeli readers – הדבר היחיד שיותר גרוע מלהיות לא רציני זה לצאת פרייר.

I’m collecting data for a couple of articles on data security in social networks and ad-hoc mobile networks so I’ve been a little slow on blogging lately – so I’m down to general management and risk management stuff.

I think that cutting and running as soon as possible from unreliable business partners is an exercise in sound risk management.  Let me know if you agree after reading the following story.

I have an acquaintance, Eran Lasser who is co-founder and joint GM of John Bryce Training.  Back when I ran Bynet Software (a Microsoft distributor and ACS – Authorized Support Center), we did some training projects with Eran as we were launching Windows NT and later Microsoft Backoffice.

I reached out to Eran last week with some ideas for management level training courses in areas where I have some personal expertise – data security and more recently using social software for B2B sales. He asked their VP Business development, Ori Lapid to meet with me – and within a day or two a secretary made an appointment.  The morning of the appointment – the secretary called to confirm – I came in a few minutes early and waited patiently for Ori to start the meeting.

After 5, 10 and 15 minutes went by with the secretary giving me the usual disclaimer of “he will be with you in a few minutes” – I told the secretary that Ori’s 15 minute academic grace period had expired and I left.  I thought it was significant and also a vindication of my decision to walk out that neither the secretary nor Ori Lapid bothered to contact me and apologize for wasting my time.

This is  the epitome of what Israelis call “not being serious” or as they say in Israel.

הדבר היחיד שיותר גרוע מלהיות לא רציני זה לצאת פרייר.

Return on security investment

September 1st, 2009 admin Comments off

The Control Policy Group is presenting a series of 6 free online workshops starting Sep 3, 2009 at 15:00GMT. The first workshop, “Using data security metrics and a value-based approach”,  will teach measurement of how well  security tools reduce Value at Risk in dollars (or in Euro) and how well they will do 3 years from now.

The Control Policy Group is providing these workshops as a free service to the security and risk professionals community after having identified a gap between the security practioner and the management board.

The gap is this: the management speaks the language of money and security practioners speak the language of technical security countermeasures like DLP, database security and messaging security.

From a management board perspective, budgets for security projects like DLP are a capital cost in a down GFC economy – Control Policy Group clients in Europe and the Middle East have slashed down security and risk budgets about 50% since the beginning of the year.

From a security and risk practioner perspective, data breaches went up almost 50% in 2008, there is more phishing, more web defacing, more Web applications to secure and yet – less head-count and capital budget to do the job.

In order to close the gap – the Control Policy Group have built a model that helps an organization measure how well a new security product reduces Value at Risk in dollars (or in Euro) and how well it will do 3 years after you buy the technology.

Modern security tools are good at discovering exploitable vulnerabilities in the network, Web servers and applications.  However – since these tools have no notion of your business context and how much you value your information assets,  it is likely that a company’s security spending is misdirected.

This series of workshops is designed to help the security and risk team  take a  leadership role in the board room instead of waiting for vendor proposals. Through specific Business Threat Modeling(TM) tactical methods, you will learn how to quantify threats, valuate your risk and choose the most cost-effective security technologies to protect your data.

The role of DLP in IP protection

July 5th, 2009 admin Comments off

A common conversation I have with my technology clients  touches on patent protection as a  security countermeasure against abuse of intellectual property. The short answer is that if you’re not DuPont or Roche, then patent protection is not going to help you very much. If you develop software , you are probably infringing  someone’s patents as we speak.

Outside the chemical and pharmaceutical industries, the cost of litigation far exceeds the benefits of patent protection. (See “Patent Failure, How judges, bureaucrats and lawyers put innovators at risk”, Bessen and Maurer, Princeton University Press, 2008 pages 130-156, “The cost of dispute”)

Read more…

Reducing risk of major data loss events

June 18th, 2009 admin Comments off

Martin Hellman (of Diffie Hellman) fame maintains the Nuclear Risk web site and has written a very insightful piece on risk analysis of nuclear war entitled Soaring, cryptography and nuclear weapons

Hellman proposes that we need a  third state scenario (instead current state – > nuclear war) where the risk of nuclear holocaust has been reduced by several orders of magnitude from today to an acceptable level.

This makes sense and it’s an intriguing idea as an exercise in risk analysis of information security and data protection to see if there is a third state of reduced risk that where the risk of data breach and major data loss events is reduced to acceptable levels.

That’s one thing that got me thinking.

The second thing is the quote from Fyodr Burlatsky, one of Khrushchev’s speechwriters and close advisors, as well as a man who was in the forefront of the Soviet reform movement:

In Krushchev’s eyes [America insisting on getting its way on certain issues] was not only an example of Americans’ traditional strong arm policy, but also an underestimation of Soviet might. … Khrushchev was infuriated by the Americans’ … continuing to behave as if the Soviet Union was still trailing far behind.

So here we are – 2009 and President Obama is insisting on getting his way on certain issues with the  Iranians, who pose a serious nuclear threat to the world.  But no only Ahmadenijad – the Russians and the North Koreans are also  infuriated by the Americans’ … continuing to behave as if they are still trailing far behind.

Exploiting a wireless mesh network for utilities

June 11th, 2009 admin Comments off

Greentech

I think it’s only a matter of time before someone exploits a wireless mesh network that controls and reads home utility meters to get free water and electricity.

Until then, there is a problem of range and coverage.

Greentech media reports that Trilliant ( a smart meter neighborhood networking startup) has bought SkyPilot for it’s long range, WiFi-based communications. Skypilot (with over 500 customers in 50 countries – utilities, wireless Internet service providers (WISPs), and municipal agencies – deployments exceeding 50,000 devices) will help Trilliant get to the next stage. Read more…

Less regulation, increased data security

May 27th, 2009 admin Comments off

Data security compliance regulation such as PCI DSS 1.2 is a double-edged sword – as a security checklist it’s an important step for the payment card industry but too much regulation, especially for small to mid-sized businesses is too much of a good thing.

As my maternal grandmother, who spoke fluent Yiddish would yell at us – you have ” grosse augen” when we would pile too much food on our plates. ” Grosse augen”  is literally “big eyes” – having eyes that are bigger than your capacity.

Read more…