Do you use any data loss prevention products as part of your compliance/security program?

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Regulated and sensitive information can leave your environment quicker than you realize. Data loss prevention (DLP) systems can prevent this information from leaving your control in unauthorized manners. Whether that’s from an employee copying the information to take it so they can work from home or an adversary that has managed to infiltrate and embed in your environment – we’re talking about the insider threat.  The ability to identify this information leaving your environment is crucial.  This is being driven from a variety of regulatory and contractual requirements and you are on the hook to ensure the information you’ve been entrusted with is protected. It doesn’t matter if you’re talking about the information that has been provided by your customers, shared by your business partners or your own intellectual property – you must protect it.  Being able to detect and respond plays a major role in supporting your claims of conforming with the relevant regulatory drivers, but also in the midst of responding to an incident where you have to know and get to ground truth on what data that you’re accountable for, left your organization.

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What are you doing regarding threat intelligence?

Another Question to Consider: How do you get your actionable cyber threat intelligence?

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Understanding the threats you face is the first step (identification) of a Risk Management program and ultimately how the organization manages risks.  The organization’s ability to collect, process and analyze cyber threats goes a long way in protecting the organization and reducing its risk.  

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What are you doing regarding Identity and Access Management?

Another Question to Consider: What is the central authority that governs your active directory domains?

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Identity (and by extension access) is at the center of not only security, but compliance as well.  The way your organization manages users is critical, now more than ever.   The way your organization protects authorized identities, ensures policy compliance, and provisions access to sensitive/regulated data all drives toward the overall organizational risk posture.  

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Are you doing Full-Packet Captures or collecting and analyzing NetFlow data?

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Full Packet Captures (FPCs) and NetFlow are probably the most important data you will need during an incident.  FPCs contain all of the data, think of them like a DVR.  FPCs record all communications over a network.  FPCs allow you to reconstruct network activity between systems, allowing you to “re-play the conversation between two systems”, which you will need (note need, not want) when an incident occurs.

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How do you define and manage your perimeter?

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Just like the first step of avoiding a trap is knowing of its existence; the first step in protecting against something is knowing it’s there.  Knowing the variety of ways in and out of your organization’s network environment is equally important.  Those points of entry and exit NEED TO BE MANAGED AND PROTECTED TOO. While your firewall is normally the first line of defense when employing a Defense in Depth model, it should not be your only line of defense.  You should be including not only your perimeter firewall, but also applications that allow data exchanges (including APIs), X-as-a-Service providers, Wireless Access Points, mobile devices, as well as Shadow IT (i.e., Gramarly, OneDrive, DropBox).  When networks are poorly designed and architected, they will degrade other security capabilities.   Make sure the perimeter is documented (inventoried, if you will) and that it is centrally managed.  Ensure you know what data is flowing where, how it’s being exchanged, what the classification is (e.g., public, private, secret), when it’s being shared and how it gets from point A to point B. 

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How do you manage remote access?

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Single factor authentication is like locking a screen door.  Sure, you’ll keep out the small pests, but the neighbor’s German shepherd is going to get in. When an adversary gets into a network (or gets credentials from any number of data dumps), they’re going to capture credentials via any number of relatively easy methods (passive monitoring is second only to reviewing freely accessible anonymous file share).  This allows an adversary the ability to move, largely undetected, throughout the network.  If an organization is using single-factor authentication on their VPN or email, it’s not difficult to find weak passwords through password spraying.  When done properly, you’ll never see it coming. Once the adversary finds those credentials, they’re now the insider – same permissions, levels of access, read/writes on shares, databases, etc. Because compromised credentials look like, well valid credentials.

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How do you manage network traffic to and from your network?

Another question to consider: Do you allow anything in your network to talk directly to the Internet?

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Systems that can communicate directly to the Internet in 2020 are just asking for problems.  This means that those systems can bypass all the safeguards and countermeasures (you know, the controls management has invested in to prevent attacks?) that would otherwise provide and enforce proper monitoring in addition to the ability to effectively identify and respond should a system be compromised.  This also opens the organization with additional liability if they fail to screen out harassing content.  So, in addition to the added liability, what else? Well, as it turns out adversaries LOVE this type of setup.  It’s like finding that $100 bill in your winter coat that you forgot about or finding that scratch off ticket you thought was for a $100 really was really for $10K.   Why do they like it you ask?  Well remember when we said, “this means that those systems can bypass all the safeguards and countermeasures”?  We’ll wait for you to finish processing that thought, because while you’re thinking about all those systems that may be able to connect directly to the Internet, just keep in mind the adversary isn’t having to deal with all those pesky defenses.

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How will your organization respond when sensitive or regulated data is lost/stolen/ransomed?

Another question to consider: Is there a clear plan for response, including incident and crisis communication?

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Incidents are going to happen, it’s not a matter of if but when.  Whether it’s a result of you being placed in the crosshairs by a sophisticated adversary or an employee who has a laptop with personal information stolen out of their locker while at the gym, the organization’s leadership must be engaged.  Understand, this is not an IT function, this is a joint effort and means having the appropriate authoritative representatives available and ready.  Ensure general counsel is engaged to address any regulatory or privacy implications, the corporate communications lead is effectively communicating with the media and identified staff are sufficiently trained to answer questions from concerned customers. Engage with the appropriate team members from IT Operations, Information & Cybersecurity to understand what happened from the technical aspect; as well as internal audit teams to understand what control weakness allowed the incident to occur in the first place.   Based on the type of breach, you may have to notify third parties such as Attorney Generals, specific payment card brands (e.g., Visa, MasterCard) or a federal agency (i.e., Department of Health and Human Services).

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Who has access to our systems?

Other questions to consider: How do we identify who has access? After third parties have access, how quickly can we sever access to our systems and data?

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This expands on the previous question from the last post, adding additional granularity to the matter.  Specifically, which third parties have access to regulated/sensitive data your organization has been entrusted with?  This includes everything from cloud applications to service providers (e.g., HRIS, ERP, CRM systems).  It doesn’t matter if the system is onsite managed by a third party (i.e., HVAC system) or hosted offsite (i.e., Amazon Web Services), you need to know who has access to your data (and why?). Accept that an adversary will consider all available attack vectors, to include your providers, business partners and vendors. These are common attack vectors used to gain access to systems as they advance on their objectives.

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How are you protecting and handling sensitive or regulated data? Are you protecting data on devices that can be lost or stolen?

The Driver Behind This

The fines and penalties, as well as brand impact for data violations (e.g., PII, PHI, Credit Card) can be severe as well as being very, very public. Legal requirements frequently differ greatly between states, and considering most now operate with our global marketplace, it is important to understand that this is especially true when operating between countries. In 2020, most employees rely on a variety of methods and means to support routine operations, systems which are comprised of components such as smartphones, laptops and tablets, all of which carry an inherent risk of being either lost or stolen.  To not be prepared on addressing this threat is sheer folly. 

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