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Posts Tagged ‘Risk management’

The valley of death between IT and information security

August 2nd, 2010 admin Comments off

Not so long ago – when a company ( business unit, department or manager) wanted to develop a line of business software application, they would do a system analysis starting with business requirements and then proceed to develop an application and deploy it.

Things have changed.

Packaged software and Web applications that the CEO’s niece can whip together in a week, have replaced structured systems development. There are of course,  good things about not having a design (like not coming down with an advanced case of analysis paralysis) and iterating quickly to a better product, but the downside of not developing software according to a structured systems design methodology is insecure software. So called security development methodologies are band-aids on deep cuts, that cannot replace a serious look at business requirements followed by a structured process of implementation.

There is a fundamental divide, a metaphorical valley of death of  mentality and skill sets between IT and security professionals.  IT is about executing predictable business processes. Security is about reducing the impact of unpredictable events.

IT’s “best practice” security in 2010 is  firewall/IPS/AV.  Faced with unconventional threats  (for example a combination of trusted contractors exploiting defective software applications), IT staffers  tend to seek a vendor-proposed, one-size-fits-all “solution” instead of performing a first principles threat analysis and discovering  that the problem has nothing to do with malware on the network and everything to do with software defects that may kill customers.

Threat modelling is a lot of hard work, hard data collection and hard analysis.  It’s not a sexy, fun to use, feel-good application like Windows Media Player.   Risk analysis  may yield results that are not career enhancing, and as  the threats  get deeper and wider  with  bigger and more complex systems – so the IT security valley of death deepens and gets more untraversable.

There is a joke about systems programmers – they have heard that there are real users out there, actually running applications on their systems – but they know it’s only an urban legend. Like any joke, it has a grain of truth. IT and security are primarily systems and procedures-oriented instead of  customer-safety oriented.

Truly – the essence of security is protecting the people who use a company’s products and services. What utility is there in running 24×7 systems that leak 4 million credit cards or developing embedded medical devices that may kill patients?

Clearly – the challenge of running a profitable company that values customer protection must be shouldered by IT and security teams alike.

Around this common challenge, I  propose that IT and security adopt a common goal and a common language – a language  of customer-centric threat modelling - threats, vulnerabilities, attackers, entry points, assets and security countermeasures.  This may be the best or even only way for IT and security  to traverse the valley of death successfully.

Professional skill sets

July 30th, 2010 admin 1 comment

We spent the past week in Tzfat  (Safed) – situated in the northern part of Israel and with a 900meter elevation, the weather is cool and dry and a welcome relief from the humidity and heat of Tel Aviv.

We met a couple at dinner one evening – the husband is a retired aerospace software engineer that had done cutting edge work in his career, including the embedded software for one of the first unmanned aerial vehicles (UAV).  He took early retirement 15 years ago and today is hustling real estate and odd jobs.   At age 62, he’s overweight, after a triple bypass, technology-obsolete and convinced he will never get back into the tech game.

For sure – this recession is helping us understand the importance of family and friends and the difference between needing something (really) and wanting something.  This is a natural inward-looking reaction. However, in order to really take something of value out of the recession you need to look outward and challenge a lot of your base assumptions – it doesn’t really matter if you are (or soon will be) a self-employed consultant or a salaried (or soon to be ) sales professional. I submit that there are several important takeways that most people miss:

1) Invest in knowledge – spend 1 hour a day in constant learning, if you’re a tech person then work on keeping your edge and learning some new tools and technologies. If you are a sales professional – remember that sales skills are like basketball – practice your shooting 1 hour/day and your stats will go up.

2) Remember that what counts in your business is free cash flow – adding value and having some cash left at the end of the transaction. It’s not definitely not about  leveraging credit cards, mortgages and derivatives.

3) Invest in your health – spend 4-5 hours a week in physical activity. There is no point reaching 60 with a heart condition and proficiency in a programming language that was obsolete in the 70s.

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.

Security is in the cracks

June 11th, 2010 admin Comments off

I just finished a software security assessment of an innovative patient monitoring device. The bedside monitor also sends data and alerts to a central nursing station.  The developers chose to use Windows XP and did an excellent job writing secure code with a view to ensuring high availability of the device and highly reliable and meaningful monitoring data.

Although most software security assessments focus on system security, one of the key security concerns when operating a networked, Windows-based system like a medical device in a hospital is not the software  vulnerabilities of the device itself, but  whether new entry points for viruses and malware are created in the enterprise network that hosts the device. In the course of a threat analysis  this question can be sub-divided into 3 specific threat scenarios:

  1. Can  system units be infected from the enterprise network?
  2. Can  system units be infected via removable media?
  3. Can infected system units propagate malicious software back into the enterprise network?

This particular case is a reminder that most system vulnerabilities live in the cracks of system integration of components in the  implementations.

The next generation of risk analysis

June 7th, 2010 admin Comments off

“What me worry – I’ve got a regulatory check list and an enterprise risk management system to manage the process”.

I want to talk about under-thinking the risk analysis and over-spending on the solution.

I believe that there is a fundamental flaw in  enterprise risk management systems –  they don’t really tell the organization something it doesn’t already know and if  we don’t bring some fresh input and new risk intelligence to the board room,we are not going to be very effective at mitigating new threats.

The  problem with  enterprise risk management systems starts with a   focus on managing internal business processes, as if mitigating threats to intellectual property is like producing a purchase requisition.

Systems like Oracle ERM help “assess risk for a portfolio across multiple parameters” and provide a powerful way of collecting data from users by asking them how ‘risky’ is their part of a business process and then roll up the total risk in the business process. This approach of self-assessments may actually be a very bad idea for an effective risk mitigation program, since users can answer  self-guided questionnaires any way they feel like. It’s called GIGO, garbage in garbage out – i.e. a system that rolls up a bunch of arbitrary answers will give an arbitrary result which might help the auditor rack up billable hours but may not help the management anticipate and mitigate threats in a cost-effective way.

Most of these systems seem to try to satisfy one kind of compliance regulation or another. Asking a bunch of people how risky their part of the business process whether they care about it or not is not a good way of ensuring quality data collection.  This sort of risk assessment doesn’t  help people do their job better and doesn’t help a business protect customer data more effectively.

Another vulnerability of enterprise risk management stems from a standardized check list approach which encourages under-thinking the analysis and over-spending on the solution.  Check lists like PCI DSS 1.2 were outdated the moment they were publicized and comprehensive checklists like ISO27001 are lacking security metrics and prioritization of control implementation – although, I will grant that ISO is moving in that direction.

While checklist applications are important for the customer and the auditor in order to prove compliance – sticking blindly to a checklist doesn’t help an organization find cost-effective security controls, respond to new threats or sustain a consistent level of security.

There are a few things that I’d like to see in a next generation risk management system that might help organizations get out from under their rock and discover new threats and new ways of implementing countermeasures:

  • Believe it or not – a totally different user interface – like maybe Facebook for risk assessment. If risk assessment was a must-have business resource like general ledger, then the user interface might not matter but I suspect that a social-networking application of  risk data collection and collaboration between analysts, attackers, vendors and managers might go a long way. SMS and email, for example, were hard to use when they were first introduced, but the network connectivity value that users got out of it was so high that people used it anyway and then the  applications took off like sky rockets.
  • Global catalog of risk model classes & entities – like a Wikipedia of risk
  • Multiple language support (let’s face it, most of  the world doesn’t speak English)
  • Open source plugin  risk models and model inheritance – that would enable a threat analyst in India to build a risk model base class and have an analyst in San Francisco be able to inherit the model and add new functionality
  • Risk model authoring and entitlement – this would help risk analysts monetize their efforts.

Facebook disclosure cancels raid on terrorists

March 11th, 2010 admin Comments off

I want to challenge the effectiveness of top-down, monolithic security frameworks (ISO 27001/PCI DSS) – I submit that rapidly changing threats – social networking, cyberstalking, social engineering, cyber-stalking and custom spyware are threats that exploit people and system vulnerabilities but are not readily mitigated by a top down set of security countermeasures.

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.

Content protection and plagiarism

February 25th, 2010 admin 1 comment

Most people tend to view content protection as a recording industry or corporate espionage  issue.   We have forgotten that people who plagiarize original content are also violating content security – someone else’s security in this case.

My colleague Anthony Freed (who runs Information Security Resources) recently got an email from computer scientist and mathematician, Aaron Krowne.  Aaron got plagiarized by no less than the the NY Times. The original story that Aaron reported is here – NY Times Caught Lifting Implode-O-Meter, Other Online Pubs’ Material

With Aaron’s kind permission, I’ve decided to republish  the original article verbatim as a public service to my data security clients in the tech, bio-pharma and telecom industries – because it could happen to you also. Paraphrasing and proper citations are the kind of thing they teach you in elementary school and this is a blunt reminder to remember what Ms. Bates, your third grade teacher taught you.

We knew it was happening, but it looks like it was more extensive and systematic than we first thought:

How long did New York Times editors know of Kouwe’s story copying?

On Dec. 26, 2008, an online publication covering the housing market, Mortgage Implode-O-Meter, published an exclusive news report that a group of financial services firms, led by Steven Mnuchin of Dune Capital, would be buying failed IndyMac Bank from the FDIC. IndyMac was one of the first large thrift banks to be seized by the FDIC at the start of the financial crisis.

A day later, Kouwe reported for the NYT’s Dealbook that Dune Capital was expected to buy IndyMac and added two other names of buyers, JC Flowers and John Paulson, to the story. Kouwe’s report did not credit Mortgage Implode-O-Meter for first breaking the fact that 1) a private equity group was buying IndyMac 2) Dune Capital was involved.

Wire services picked up the NYT’s story and the rest of the business press ended up sourcing Kouwe for breaking the news on the sale of IndyMac to a private equity group.

Shockingly, Kouwe wrote the below, justifying his plagiarism and failures to attribute (my bold, and comments in italics):

I don’t know what to tell you. Things move so quickly on the Web that citing who had it first is something that is likely going away, especially in the age of blogs [except of course amongst blogs themselves, which give attribution religiously.]
Read more…

Business unit strategy for data security

February 17th, 2010 admin Comments off

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…

Dissonance is bad for business

October 28th, 2009 admin 1 comment

In music, dissonance is  sound quality which seems “unstable”, and has an aural “need” to “resolve” to a “stable” consonance.

Leading up to the Al Quaeda attack on the US in 9/11, the FBI investigated, the CIA analyzed but no one bothered to discuss the impact of Saudis learning to fly but not land airplanes.

Dissonance in organizations is often resolved  by building separate silos of roles and responsibilities.

However, it is impossible to take wise decisions on risk management in the business when the risk intelligence is in separate silos.

Resolving dissonance in your business is key to getting actionable intelligence in order to reduce risk and improve compliance Why should I care? After all – for this we have security, risk and compliance specialists.


According to the Verizon Business Report, 285 million records were breached in 2008;  32% of the cases implicated business partners.

Information assurance of third parties that have access to your business assets is crucial for contract due diligence, complying with best practices, internal and external audit and regulation.

Due diligence of third parties that work with your business requires actionable intelligence.

Remember Madoff?

Actionable risk and compliance intelligence requires breaking down silos and recycling commonalities instead of fragmenting activities and duplicating resources.

Learn how to make that happen at our next  online workshop on security management coming this Thursday October 29, 2009,
10:00 Eastern 14:00 GMT, 16:00  in Israel and Central Europe 17:00 MT.

Go green by recycling policies and controls.

Don’t make any of the 10 data security mistakes

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Through specific Business Threat Modeling(TM) tactical methods we teach you how to quantify threats, valuate your risk and choose the most cost-effective security technologies to protect your data. Data security is a war – when the attackers win, you lose.  We will help you win more.

We help protect customer data and intellectual property from fraud and breaches of confidentiality.  We’re always looking for interesting projects – call or text me at  +972 54 447 1114 at  any time.