Israeli Software

Now it’s some lazy journalist at Information Week aiding and abetting the pseudo-statistics of of the Ponemon Institute – screaming headlines of  the cost of data breaches of PHI – protected healthcare information

According to Information Week; Analysis: Healthcare Breach Costs May Reach $800 Million

Since the Health Information Technology for Economic and Clinical Health Act or HITECH Act of 2009 came to being, a number of new privacy, security and reporting and non-compliance penalty provisions went into effect. And as summarized by this report from HITRUST, there have been 108 entities who have reported security breaches since September of last year.

Those breaches comprise about 4 million people and records.

In the analysis, Chris Hourihan Manager, CSF Development and Operations, HITRUST used the 2009 Ponemon Institute Cost of a Data Breach Study [.pdf], which found the average cost for each record within a data breach to be $204. That’s $144 of indirect costs and $60 of direct costs. An overview of the Ponemon study is available here.

What is the connection between the Ponemon studies (sponsored by data security vendors) and the PHI leakages.

Nothing.

Why is a PII leak and a meaningless plug number of $60 relevant to PHI (which requires a combination of medical data and personal identifiers?

Why can’t someone make a phone call and ask how much the companies actually paid in fines and then make a few more phone calls and start estimating ancillary costs and direct costs such as legal.

Why not just multiply by the average cost of an iPhone?

After all you can steal data with your mobile easily enough can’t you.

Aug 7, 2010 WASHINGTON, D.D.—U.S. Senators Mark Pryor (D-AR) and John D. (Jay) Rockefeller IV (D-WV) today introduced legislation to require businesses and nonprofit organizations that store consumers’ personal information to put in place strong security features to safeguard sensitive data, alert consumers when this data has been breached, and provide affected individuals with the tools they need to protect their credit and finances. Currently, there is no single federal standard for guarding many types of consumer information.

I cannot believe my eyes – “no single federal standard”??

I am at a loss to understand why the US needs another data security bill – when there are already a plethora of regulations regarding personal information – Graham Leach Bliley (financial services), PCI DSS (credit cards), HIPAA (health care) and the state data security bills (CA SB 1386, Mass Data privacy etc.. ).  This is without even mentioning FISMA and the NIST security requirements for implementing HIPAA. With Obamacare in effect – it seems to me that the gold standard for PII protection will soon become HIPAA and since health care appears to becoming nationalized in the US – NIST will soon be the king of data security control frameworks.

Looking at data security  as an exercise in providing cost effect security countermeasures, it appears to me that the bill is most likely either a public relations play  or congressional logrolling. The interesting item is the requirement to provide credit card monitoring services after a breach for a year – perhaps the bill is intended to help stimulate the business of companies like Experian, Symantec, RSA and Mcafee.

The US does not need more data security regulation (requiring “strong security features” whatever that means) because with over 350 million US credit cards breached – the data is already out there. This bill is equivalent to closing the barn door after the horses have already fled.

What I would recommend to the esteemed Senators is a totally different approach – one adopted by Poland. Poland, which is a member of the EU and subject to the EU Privacy Law decided a few years back to make data security breaches expensive. If a firm in Poland breaches personal data – they are liable to up to a 2.5% fine of their annual gross revenue.

None of this hokey – “provide monitoring services and notify within 60 days” nonsense. Make US data breachers pay for their security vulnerabilities and even the playing field with the consumers – who are indeed paying the price for poor data security at American retailers and banks.

It seems that with amorphous and rapidly evolving trend of storing data in cloud providers and social media like Twitter and Facebook, that social media and cloud computing is the next frontier of data security breaches.

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.

Are the security lights on, but no  one is home at your company?

Question No. 1 – Does your organization have a formalized risk analysis process? … 90 percent of the respondents, said that their organizations have such a formalized risk analysis process.

Question No 2 – Does your organization have an executive with a mandate to manage enterprise risk ? … only about 40 percent of the respondents had an executive with such a mandate.

Enterprise Security Risk Management Benchmarking Survey - April 2010

“That’s hard to believe, given that extreme events and risk management are making headlines almost every other day.”

In order  to understand why large enterprises invest in risk analysis process but not in risk management we need to take a closer look at Western (US and EU for the sake of argument) corporate value systems.

For a manager of a company on the verge of bankruptcy, equity compensation is a one-sided bet with upside only. For example, say the CEO  bets on a bridge loan at usurious terms in order to buy time to close an acquisition deal. If the bet pays off, his equity compensation pays off, but if he loses the bet (and the company goes bankrupt or is sold for a pittance), his personal compensation exposure is zero, but the stockholders, bond holders, customers and business partners will be left holding the bag.  Since it’s a one-sided bet with no downside, executives may also be tempted to adopt borderline business practice in order to proactively optimize their compensation.

Risk analysis provides invaluable input to improve business practice and reduce security breach exposure but you have to execute on the implementation of the security countermeasures and be prepared to hold them up to scrutiny of your peers on a regular basis.  That requires a strong work ethic, transparency and accountability.

Since executives are generally not held personally accountable for security breaches  - it is not surprising at all that most enterprises have  formal risk analysis processes but few firms have managers with  the personal responsibility to execute on security risk management.

Let’s return to our original question – ‘Is IT equipped to deal with clear and present danger?’

We now see that IT and their information security colleagues may indeed have the formal risk analysis processes and even the latest in data security technology countermeasures to reduce the impact of security breaches but they don’t function inside a corporate value system that rewards them for cost-effective security.

And that my friends – is already an ethical question, not a process management nor a compensation question.

Best practices for data security are still evolving – as there are no industry-standard data security metrics and a confusing array of regulatory compliance and industry standards – PCI DSS 1.2, Sarbanes-Oxley, FISMA, ISO2700x – just to name a few.

Organizations (government included) currently use a combination of tactics – penetration testing, vulnerability analysis (usually at the network and sometimes at the application software layer), “fire and forget” compliance exercises and technology countermeasures such as IPS/IDS, network DLP, agent DLP, database firewalls, encryption on demand, Web application firewalls.

The one countermeasure I have never seen is standardized screening.  Borrowing an approach from health-care, consider the following:

Standardized screening for suicide risk in primary care can detect adolescents with suicidal ideation, allowing referral to a behavioral healthcare center before a fatal or serious suicide attempt is made, according to the results of a study reported online April 12 and published in the May print issue of Pediatrics.

“Several associations and federal agencies have called for depression screening in pediatric primary care,” writes Matthew B. Wintersteen, PhD, from Thomas Jefferson University in Philadelphia, Pennsylvania. “Screening for suicide risk is a natural adjunct to this call….To our knowledge, this is the first study to prospectively examine the impact of standardized screening for suicide risk on detection and referral rates in pediatric primary care.”

The goals of the study were to evaluate whether brief standardized screening for suicide risk in pediatric primary care practices could improve detection of youth with suicidal ideation, maintain improved rates of detection and referral, and be duplicated in other practices.

It seems to me that duplicating brief standardized screening to data security practice is eminently possible.   A possible approach would involve using a standard threat model based on a comprehensive set of security controls – (ISO 27001 would work fine for this purpose).  The process would start with a pre-screening preparation exercise that an organization could do in the office in 1-2 hours.   After the preparation exercise, a group of 3-5 people from a business unit would meet with a data security specialist for the standardized screening that would walk through the threat model and gauge probability of occurrence of vulnerabilities and  percent damage to assets by threats.  Based on my experience, this sort of walk-through would take 2-3 hours using the structured threat model.  The result of the threat analysis would be a level of value at risk to the organization for data security and indeed a 1/2 day qualifies as brief enough.

Apache is the world’ most popular Web server for Linux and Windows platforms, and with such a large attack surface, it’s no surprise that attackers are looking to exploit Apache software vulnerabilities. The approach used by XerXeS is somewhat novel in that it is based on a DoS (not DDos) attack and apparentlyrequires relatively modest computing resources to execute.

The object of such an attack goes beyond denial of service where a more interesting and potentially valuable attack would gain access to the back end database (typically MySQL) generally used by Apache web servers.  The trick of course is identifying – who has valuable data assets – since the vast majority of LAMP installations are small content/blogging Web sites.

Courtesy of my colleague Anthony Freed -

Infosec Island has once again gained exclusive access to a video demonstration of the XerXeS DoS attack recently developed by the infamous patriot-hacker known only as The Jester (th3j35t3r).

This new video shows a little more of the XerXeS dashboard, and reveals even more about the attack technique – watch the text box on the left as Jester mentions “Apache” for the first time outside of our private conversations…

See the video on the enhanced DoS exploit of Apache vulnerabilties

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….

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.

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.

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, Mcafee, nexTier, ANBsys 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