Israeli Software

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.

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:

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.

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

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…

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.

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.”

At a meeting with one of our clients last week – the question of business case for data loss prevention came up quite strongly.   It started with the client saying that they were hearing that while vendors like Symantec and Websense were getting a lot of customers to buy their DLP products – many of these customers were failing at their attempt to implement DLP.

The detailed reasons why people fail at DLP implementations merits a separate post –  but it’s a lot like why over 50% of the content management implementation from vendors like Vignette never made it to production in the 90s – the root cause was that there was no real business case for the technology.

I want to talk about why  building a business case for Data security is critical to the success of your data security/data loss prevention/fraud prevention project.

If you run a business or business unit – you must ask yourself two questions

Is data security a major operational risk for your business?

Could be.

Unlike a computer virus – internally launched attacks on data  that result in data leaks, breach of  integrity, loss of data availability and non-compliance are your problem, not someone elses.

Unlike business processes – data risk cannot be outsourced.

Unlike balance sheet assets – companies don’t know their current financial exposure to data security threats.

The next question is should you invest in DLP technologies? Any one with only a nickel in their pocket (and in this market – that’s a lot of companies…) will say “Why should we when we don’t know the return on investment?  In order to answer your questions, you must measure your value at risk using a data security based risk assessment This is a simple, almost obvious notion – you measure risk of asbestos poisoning by checking your building insulation and you measure risk of fire damage by checking the building itself and various policies, procedures and equipment related to fire prevention.

Think about smoke detectors. You can’t put up an office building without smoke detectors (in Israel – the regulator has set a minimum density per square meter and the prices are low enough that the contractors will basically put in as many as you want). Why would you think of managing your data without the comparable data breach security monitoring equipment?

Data security based risk assessment uses DLP technology (the test equipment) and a best practices analytical risk model to measure the value of your data and your value at risk. Within a couple weeks, you should be able to get a picture of your current data security events, know your data value at risk in Euro and build a prioritized program for cost-effective data security controls in the people, process and technology planes. What you do then – is up to you.

Most companies I know in Europe and Israel are not at a sufficient level of security maturity to do this kind of thing themselves – and will need an independent consultant – one with specific domain expertise in their industry vertical,  specific data security expertise and ability to do analytical threat modeling – installing Checkpoint firewalls doesn’t count and you really want someone who is vendor neutral.

I love how this Cisco video clip on Blip TV starts with examples of DDOS attacks and then uses shots of incoming content filtering and then dramatizes with a cop not allowing a visitor into the booth -  what is going on here?  Cisco didn’t have budget for an editor who knows the difference between incoming and outbound traffic? (funny stuff around 1 minute 35 seconds)

At the DLP Expert 2009 conference in Moscow 2 weeks ago I heard the following insight from Bill Nagel from Forrester:

American companies are rule-based. 40% of US companies state that they have implemented some form of DLP technology.
European companies are principles-based. In EMEA, 80% of chief security officers do not have plans to implement DLP in 2010.