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Posts Tagged ‘PCI DSS’

The top 2 responses to data security threats

April 23rd, 2010 admin Comments off

How does your company mitigate the risk of data security threats?

Is your company management adopting a policy of “It’s other peoples money”?

In a recent thread on LinkedIn - Jody Keyser shared some quotes from David Vose’s book on risk, reliability and computerized risk modeling:  Risk Analysis a quantitative guide.

The responses to correctly identified and evaluated risks are many but generally fall into one of the following categories:

- Cancel Project
- Eliminate ( do it another way)
- Transfer (insure back to back contract)
- Share (with partner or contractor )
- Reduce (take a less risky approach)
- Add a contingency (increase budget, deadline etc.,to allow for possibility of risk)
- Collect more data to better understand risk
- Do nothing (cost is just too dang high)
- Increase ( maybe the plan is too cautious )

In my experience – when it comes to data security, data loss prevention, DLP projects – the top 2 responses to data security threats are “accept the risk” followed by “cancel the project” in a close second place.

The other alternatives are almost all non-starters. The question is – why?

Eliminating risk by changing the business process is often not an option or too much trouble for employees. For example – consider the process of transferring documents to external contractors – even though it’s trivial to encrypt documents inside a Zip file and share the password – most companies don’t make it part of their security procedure and those that do require encryption of documents sent to external business partners, don’t deploy DLP monitoring to ensure compliance with the encryption policy.

There are multiple reasons for data security risk being accepted by business managers.  Most are related to cost, complexity, changing business requirements and a tacit disbelief in effectiveness of technology in preventing data theft and fraud.

The reasons for accepting data security risk are related to  the difference between being secure and feeling secure.  Since most companies don’t monitor data flows, they don’t know how many sensitive digital assets are being leaked to the competition – ergo they don’t have the empirical data to analyze their data security threats and measure data security risks in terms of dollar threat to the business.  This would lead to enable a business to deploy data security countermeasures and be secure at an acceptable cost. It would also enable them to measure the cost effectiveness of their data security technology and challenge their innate beliefs and skepticism.

However – the company management already feel secure because they have delegated that part of  the business to the information security folks and reading the papers tells them that customers (not the business management) pay the cost of a data security breach.

As a kid growing up in South Jersey – when there was the occasional report of an urban boondoggle or million dollar NASA toilets – my Dad (who worked for RCA on defense projects and knew about these things) would always use the expression – “Other peoples money” or if it was closer to home – “Pa’s rich and Ma don’t care”…which is really close to home this year for Americans as President Obama takes the US to an unprecedented $1.35 trillion budget deficit in  2010.

Choosing endpoint DLP agents

March 21st, 2010 admin Comments off
There is a lot to be said for preventing data loss at the point of use but if you are considering endpoint DLP (data loss prevention), I recommend against buying and deploying an integrated DLP/Anti-virus end-point security agent.  This is for 4 reasons:
  • Bloatware/system resource consumption – if you’re concerned with anti-virus system resource usage, imagine layering another 100MB of software, another 20MB of data security rules and loads of network traffic for management just for the luxury of getting a good deal from Symantec on a piece of integrated software that IT doesn’t know how to manage anyhow.
  • Software vulnerabilities – if you have issues with the anti-virus – you don’t want them affecting your data flows via the DLP agent. Imagine a user uninstalling  the anti-virus and impacting the DLP agent.
  • Diversity – the strong anti-virus products have weak DLP agents – which means that the advantage of a single management platform is spurious. Having strong anti-virus software on your Windows PCs from a vendor like McAfee complements having strong data loss prevention from a company like Verdasys.
  • Not a good fit for the organization – IT manage the Anti-virus,   Security manage the data security and never the twain shall meet.

Learning about change and changing your security

March 11th, 2010 admin Comments off

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.

Toxic assets

October 13th, 2009 admin Comments off

Forrester just started calling lost credit card numbers “toxic asset”. Since when is data that is publicly available toxic?

Sharing security information

September 2nd, 2009 admin Comments off

fragmentationI think fragmentation of knowledge is a root cause of data breaches.

It’s almost a cliche to say that the  security and compliance industry has done a poor job in preventing data breaches of over 245 million personal records in the past 5 years.

It is apparent that government regulation is  ineffective in preventing identity theft and major data loss events.

Given: direct data security countermeasures go a long way;  data loss prevention and network surveillance work well inside a  feedback loop to improve security of systems, increase employee awareness and support management accountability.

However: I believe that even if every business deployed Fidelis XPS Extrusion Prevention system or Verdays Digital Guardian or Websense Data Security suite – we would still have major data loss events.

This is because a major data loss event has three characteristics:

1.Appears as a complete surprise to the organization
2.Has a major impact to the point of maiming or destroying the company
3.Event, after it has appeared, is ‘explained’ by human hindsight.

The root cause of the surprise is, in most cases, a lack of knowledge – not knowing what is the current range of data security threat scenarios in the wild or not even knowing what are the top 10 in your type of business.

The root cause of the lack of knowledge is fragmentation of knowledge.

Every business from SME to Global 2000 deals with security issues and amass their own best practices and knowledge base of how to protect their information.  But, the knowledge is fragmented, since business organizations don’t share their loss data, and the dozens or maybe hundreds of vendor web sites that do disclose and categorize attacks don’t provide the business context of a loss event.

Fragmentation leads to waste and duplication, as well as frustrating, expensive and sometimes dangerous experiences for companies facing a data loss event.

So what’s the solution?

With our clients, we see growing evidence that the more organized a company is with their security operation – having a single security organization responsible for digital assets, physical security, permissions management and compliance – the better security they deliver. What’s more, they may be able to reduce value at risk at lower costs due to higher levels of competence, knowledge and economy of scale.

The concept of sharing best practices  and  aggregating support so that companies of all sizes can access knowledge and support resources is not new, it’s a common theme in  industrial safety and Free Open Source worlds – to name two. I imagine that there are a few more examples I am not familiar with.

But what’s in it for security professionals? In addition to the satisfaction and prestige in helping colleagues, how about learning from the biggest and best practioners in the world; having access to resources to improve your own systems and procedures and having the ability to analyze the history of a data loss event from disclosure to analysis to remediation? How about having peers with a common goal of providing the best security for customers?

It’s time for policymakers and large commercial organizations to support organized security knowledge sharing systems, starting with compensation to employees and independent consultants that rewards high-quality, coordinated, customer-centric security  across the full continuum of security, not just point technology solutions or professional regulatory services. And it’s time for firms to recognize that sharing some data may be worth the benefits to them and their customers.

That’s my opinion. I’m Danny Lieberman.

Simplicity and technical superiority

July 14th, 2009 admin Comments off

In today’s environment of financial crisis, the tradeoff managers  usually make is coverage against cost.   IT and corporate management are more concerned with reducing outsourcing  costs and cutting back on  professional services instead of achieving and sustaining technical excellence in security and compliance.   Technical superiority in  IT security will not enlarge your market share or improve profitability.

I started thinking about different kind of tradeoffs after stumbling on MilkyMist today: tradeoffs between compliance and  simplicity/ technical excellence. The Milkymist project is an Open source hardware project developing a stand-alone device in a small form factor that is capable of rendering MilkDrop-esque visuals effects in real time, with a high level of interaction with many sensors and using live audio and video streams as a base.

While a lot of system-on-chip (SoC) designs put a strong emphasis on compliance with established standards, Milkymist favors simplicity and technical superiority over compliance

Is privacy and payment card compliance an effective data security countermeasure? The short answer is no. PCI DSS 1.3 compliance, whether SAQ (self-compliance) or with an external auditor (QAS) is not an effective data loss prevention system, as empirical evidence of data breach events like Hannaford Supermarkets shows.

But – I think the good news is that simplicity and technical superiority are cheaper in the long run than process compliance.

PCI DSS emphasizes that there is only one asset (a payment card + mag strip) and that if you don’t store payment card data – you are compliant to the card association requirements. With simplicity – no payment cards in the database,  you’re compliant. For the rest of system security, we need the technical superiority part – locking down servers, enforcing strong passwords, patch management and a data loss prevention system to keep the “good stuff inside” and an IPS to keep “the bad guys out”.

See   the OpenCores project for more about simplicity and technical superiority.