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.

And – here, we have not even solved the problem of trusted insiders.

The letter of the law is always operative and the common denominator of the regulators (HIPAA, PCI etc..) is not to store or transmit personal information at all in the application software systems.

We are correct in identifying cloud providers as a potential vulnerability – however, storing data in the ‘cloud’ is no different from storing data in an outsourced data center and it’s subsequent exposure to employees, outsourcing contractors etc..If you have a medical file application,  ecommerce or an online application – your best data security countermeasure is NOT to store PII at all in your application.

I personally don’t buy into technology silver bullets and data obfuscation as effective security countermeasures.   They have their utility but even if the data is obfuscated in the cloud it still traverses some interface between the data provider and the cloud provider.

In my experience, since almost all data breaches occur on the interface – adding an additional technology layer will serve to increase your value at risk not reduce it – since more complexity and more third party software only adds additional vulnerabilities and increases your threat surface.

As far as I know, there have been no documented events of PII being leaked from an infrastructure cloud provider like Rackspace or IBM. Their standards of operation and security are far better than the average business.

Notwithstanding legal definitions, regulatory standards like HIPAA and SOX tell us to do a top down risk analysis and demonstrate why the risk of leaking PII is acceptably low.

If you are developing and maintaining an online application with patient or customer data, your best bet is good application engineering and resolving your data privacy exposure issues by simply removing ePHI and PII from your systems.

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.

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.

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:

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.

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.

Now let’s look at three steps for developing a business justification for spending on information security.

1. Choose a business unit strategy

• Take a break from the daily firefighting and choose a competitive strategy for infosec operations. Is it low-cost? Is it single-vendor? Is it Linux desktops?
• Start by implementing a consistent set of activities, for example, standardizing on diskless thin clients, remote desktops and Windows Terminal services.
• Then think how activities can reinforce each other, such as installing personal firewall software that reports on intrusion attempts to a central server so that you can plan your response to future attacks.
• The most productive strategy identifies sets of activities that optimize your efforts. Perhaps you have a flat spaghetti network of servers and workstations. Segment the network into virtual LANs, put the application servers on one segment, the data servers on another and client workstations on departmental segments and so forth. Performance and security will improve, and you’ll be able to monitor content effectively. You’ll spend less time firefighting and more time thinking how to optimize the operation.

2. Add business value and measure your results

There are widely practiced models and metrics that work for all kinds of business units. For instance, if you want to evaluate cash flow, then measure cash flow from operations or free cash flow (FCF), which is cash from operations minus capital expenditures. FCF omits the cost of debt, but it is an objective indicator that can be measured every day.

• Set up indicators and publish them once a week on the company intranet for everyone to see. Start with three indicators: the number of network anomalies your intrusion-detection system found that week, the current patch cycle time and how much overtime the team worked.
• Do continuous security audits. Purchase a tool for network auditing and run it once a week on a different part of the network. The guys over in the warehouse stopped doing full physical counts once a year 15 years ago. They count a little bit of inventory every day with bar-code terminals. Have a consultant help you set it up and run audit yourself.
• Run security awareness programs. Make training hours an indicator.
• Build a threat model and maintain a database of assets, threats and vulnerabilities. Start today. Check out the SANS Institute for tools.

3. Drive the message home

Send out your CTO to install your company’s products himself, follow customers back to their offices, observe howthey do the install and take notes. Update the threat model with the CTO’s findings. He’ll sign your next purchase request for software security tools in a flash. Trust me.

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.”

A new bribery and corruption legislation will be put before the UK parliament. Doing business using bribery would mean jail for a decade under the bill.

“The new Bribery Bill will make it far easier for companies and senior management to be prosecuted where bribes have been offered, paid or received. The new legislation will be even wider than the US Foreign Corrupt Practices Act, because it covers business-to-business transactions as well as business transactions with government or state-owned bodies,” says Neill Blundell, partner and head of the fraud group at law firm Eversheds”

This article – Unsupervised Retrieval of Attack Profiles in Collaborative Recommender Systems casts this problem as a problem of detecting anomalous structure in network analysis and proposes a novel mechanism for detecting this anomalous structure.

Like the warnings on cigarette packets – whistle blowing may be hazardous to your health.

HBOS chief risk officer Paul Moore blew the whistle on the bank’s risk exposure and lost his job. Last week, the UK Treasury Select committee heard allegations from  Moore ( who was sacked by Sir James Crosby in 2005) – that senior executives ignored repeated warnings about excessive risk-taking.

Following the political firestorm – Sir James Crosby has left his position as deputy chairman of the UK Financial Services Authority. Crosby was a close adviser to prime minister Gordon Brown, and former HBOS CEO – leading HBOS during a period of high-rolling profits.

Are there sins of hubris at your company – let me know!

It appears that chief executives at the big banking institutions like Lehman Brothers and AIG were totally out of touch with the realities of risk management.  Out of touch to the point where out of hubris – they were probably not even listening to the Cassandras in their organizations.  When your’e flying a private jet, taking home $10M in bonuses and staying at the premium class hotels – it’s tough to relate to bearers of bad news and it’s even harder for a middle manager to gain access to the big guys and sell a case that toxic assets, data breaches and and internal fraud that could kill the $10M bonus.