Category Archives: Policy and Process

FAQ on Audit Log Best Practices

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Q: What are audit logs?

A: Audit logs are records of all events and security-related information that occur within a system. This information is crucial for incident response, threat detection, and compliance monitoring.

Q: Why is audit log management important?

A: Audit log management is essential for every organization that wants to ensure its data security. Without audit logs, organizations would have no way of knowing who accessed what information when or how the incident happened or whether unauthorized users or suspicious activity occurred. Moreover, audit log management supports compliance with industry regulations and guidelines.

Q: What are the best practices for audit log management?

A: To ensure that your audit log management practices meet the CIS CSC version 8 guidelines and safeguard requirements, consider implementing the following best practices:

1. Define the audit log requirements based on industry regulations, guidelines, and best practices.

2. Establish audit policies and procedures that align with your organization’s requirements and implement them consistently across all systems and devices.
3. Secure audit logs by collecting, storing, and protecting them securely to prevent unauthorized access or tampering.
4. Monitor and review audit logs regularly for anomalies, suspicious activity, and security violations, such as unauthorized access attempts, changes to access rights, and software installations.
5. Configure audit logging settings to generate records of critical security controls, including attempts to gain unauthorized access or make unauthorized changes to the network.
6. Generate alerts in real-time for critical events, including security violations, unauthorized access attempts, changes to access rights, and software installations.
7. Regularly test audit log management controls to ensure their effectiveness and meet your organization’s audit log requirements.

Q: What are the benefits of following audit log management best practices?

A: Following audit log management best practices can establish a strong framework for incident response, threat detection, and compliance monitoring. This, in turn, can help safeguard against unauthorized access, malicious activity, and other security breaches, prevent legal and financial penalties, and maintain trust levels with clients and partners.

Q: How long should audit logs be kept?

A: As a general rule, storage of audit logs should include 90 days hot (meaning actively available for immediate review or alerting), 6 months warm (meaning they can be restored within hours), and two years cold (meaning they can be restored within days). However, organizations should define retention periods based on their audit log requirements and compliance regulations. [1] [2]

*This article was written with the help of AI tools and Grammarly.

3 Key Tips for Rapid and Effective Incident Response in Information Security

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Incident response is a critical component of any successful information security program. An effective incident response process can help organizations detect, investigate, and respond to threats in a timely manner. This blog post will discuss three key tips to ensure rapid and effective incident response during an information security incident.

  1. Develop a well-structured incident response plan:

    A comprehensive incident response plan serves as the foundation for effective incident response. The plan should outline each process phase’s roles, responsibilities, and procedures. Key elements include clear communication channels, escalation paths, and predefined actions to be taken during an incident. Regularly review, update, and test the plan to ensure it remains relevant and practical.

  2. Implement proactive detection and monitoring tools:

    The rapid response starts with early detection. Invest in advanced detection and monitoring tools, such as intrusion detection systems (IDS), security information and event management (SIEM) solutions, and endpoint detection and response (EDR) technologies. These tools enable organizations to identify potential security incidents in real time and respond quickly to minimize their impact.

  3. Train and empower your Incident Response Team (IRT):

    An experienced and well-equipped IRT is crucial for effective incident response. Provide regular training, including tabletop exercises and simulations, to ensure team members are familiar with the incident response plan and can execute it efficiently during an actual incident. Ensure the IRT has access to the necessary resources and tools, and maintain a culture of open communication to encourage swift reporting of potential incidents.

 

*This article was written with the help of AI tools and Grammarly.

High-Level FAQ for Incident Response

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  1. Q: What is an incident response process in information security?

A: The incident response process in information security is a systematic approach to identifying, containing, analyzing, and resolving security incidents that may compromise the confidentiality, integrity, or availability of an organization’s information systems and data. It involves a set of predefined policies, procedures, and tools designed to minimize the impact of security incidents and facilitate a swift recovery.

  1. Q: Why is the incident response process necessary?

A: The incident response process is crucial for organizations because it helps to minimize the damage caused by security incidents, protect sensitive data, maintain business continuity, and comply with regulatory requirements. A well-defined incident response process can also help organizations learn from security incidents and improve their overall security posture.

  1. Q: What are the critical phases of an incident response process?

A: The incident response process typically includes six key phases:

  • i. Preparation: Developing and maintaining an incident response plan, training staff, and setting up necessary tools and resources.
  • ii. Detection and Analysis: Identifying potential security incidents through monitoring, reporting, and analyzing security events.
  • iii. Containment: Limiting the spread and impact of an identified security incident by isolating affected systems or networks.
  • iv. Eradication: Removing the cause of the security incident, such as malware or unauthorized access, and restoring affected systems to a secure state.
  • v. Recovery: Restoring affected systems and networks to regular operation and verifying their security.
  • vi. Post-Incident Activity: Reviewing the incident response process, identifying lessons learned, and implementing improvements to prevent future incidents.

  1. Q: Who should be involved in the incident response process?

A: An effective incident response process involves a cross-functional team, typically called the Incident Response Team (IRT), which may include members from IT, information security, legal, human resources, public relations, and management. External stakeholders, such as law enforcement, third-party vendors, or cyber insurance providers, may also be involved, depending on the nature and severity of the incident.

  1. Q: How can organizations prepare for incident response?

A: Organizations can prepare for incident response by:

  • Developing a comprehensive incident response plan that outlines roles, responsibilities, and procedures for each process phase.
  • Regularly updating and testing the incident response plan to ensure its effectiveness and relevance.
  • Training employees on their roles and responsibilities during an incident, including reporting procedures and essential security awareness.
  • Establishing a well-equipped IRT with clear communication channels and access to necessary resources.
  • Implementing continuous monitoring and detection tools to identify potential security incidents early.

  1. Q: How can organizations improve their incident response process?

A: Organizations can improve their incident response process by:

  • Regularly reviewing and updating the incident response plan to reflect changes in the organization’s infrastructure, personnel, and threat landscape.
  • Conducting periodic tests and simulations, such as tabletop exercises or red team exercises, to evaluate the plan’s effectiveness and identify improvement areas.
  • Implement a continuous improvement cycle incorporating lessons learned from past incidents and industry best practices.
  • Investing in advanced detection and monitoring tools to enhance the organization’s ability to identify and respond to security incidents.
  • Providing ongoing training and support to the IRT and other stakeholders to ensure they remain up-to-date with the latest threats and best practices.

 

*This article was written with the help of AI tools and Grammarly.

How Do I Know If My Company Needs a Risk Management Policy?

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Risk management policies protect companies against financial losses due to various risks. These risks include legal issues, employee misconduct, environmental hazards, etc.

A company may implement a risk management policy to minimize these risks. However, several questions should be asked before implementing such a policy.

What Are the Risks That Could Lead to Financial Losses?

Many types of risks can lead to financial losses. Some examples include:

• Legal issues

• Employee misconduct

• Environmental hazards

• Product liability

• Cybersecurity threats

• Data breaches

• Other

It is important to understand what type of risk your company faces. For example, if your company sells products online, you will face cyber security risks.

Are There Any Existing Policies?

Before deciding whether or not to adopt a risk management policy, it is important to determine whether any existing policies cover the risks your company faces.

For example, if your company has an insurance policy, then you may not need to implement a separate risk management policy.

However, if your company does not have an insurance policy, then it is necessary to consider implementing a risk management policy.

Is Implementing a New Policy Worth It?

Once you know what type of risks your company faces, it is time to decide whether or not to implement a risk management plan.

Some companies feel that they do not need a risk management plan because their current policies already address their risks. However, this decision should be made carefully.

If your company does not have a formal risk management policy, then it is possible that some of the risks your company faces could go unaddressed. This means that the risks could become more significant problems down the line.

In addition, if your company decides to implement a risk management program, it is crucial to ensure that the program covers all the risks your company faces, including those currently unaddressed.

Do Your Employees Understand What Is Being Done?

When implementing a risk management plan, it is vital to ensure employees understand what is being done.

This includes explaining why the risk management plan was implemented, how the plan works, and what steps must be taken to comply.

The goal here is to ensure that employees understand your company’s risks and how the risk management plan helps mitigate them.

Will the Plan Be Cost-Effective?

Finally, it is essential to evaluate whether or not the risk management plan will be cost-effective.

Cost-effectiveness refers to the amount of money saved compared to the costs incurred.

For example, suppose your company spends $1 million per year to insure its assets. In addition, suppose that the risk management plan saves $500,000 per year. Then, the risk management plan would be considered cost-effective if it saves $500,000 annually.

In this case, the risk management plan is cost-effective because it saves $500,00 annually.

However, if the risk management plan only saves $100,000 per year, then the plan is not cost-effective.

In Conclusion

As discussed above, there are many reasons to implement a risk management strategy.

These strategies can help your company avoid potential financial losses caused by certain risks.

In addition, implementing a risk management plan can make your company more efficient and productive.

 

Preparing for the End of SMS Authentication

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Over the last several years, wealth management/asset management firms have been integrating their systems with banking, trading and other financial platforms. One of the largest challenges wealth management firms face, from a technology standpoint, is managing multi-factor authentication when connecting to the accounts of their clients. In the coming year to eighteen months, this is likely to get even more challenging as SMS-based authentication is phased out. 

Today, many financial web sites, applications and phone apps require the use of SMS one-time security verification codes to be sent via text to the user. This usually happens once the user has entered their login and password to the system, after which it triggers the credential to be sent to their mobile phone number on record. The user then inputs this code into a form on the system and it is verified, and if correct, allows the user to proceed to access the application. This is called two factor authentication/multi-factor authentication (“MFA”) and is one of the most common mechanisms for performing this type of user authorization.

The problem with this mechanism for regulating sign ins to applications is that the method of sending the code is insecure. Attackers have a variety of means of intercepting SMS text messages and thus defeating this type of authentication. Just do some quick Google searches and you’ll find plenty of examples of this attack being successful. You’ll also find regulatory guidance about ending SMS authentication from a variety of sources like NIST and various financial regulators around the world. 

The likely successor to SMS text message authentication is the authenticator app on user mobile devices and smartphones. These authenticator apps reside in encrypted storage on the user’s phone and when prompted, provide a one-time password (“OTP”) just like the code sent in the text message. The difference is, through a variety of cryptographic techniques, once the application is setup and  the settings configured, it doesn’t need to communicate with the financial platform, and thus is significantly more difficult for attackers to compromise. Indeed, they must actually have the user’s device, or at the very least, access to the data that resides on it. This greatly reduces the risk of interception and mis-use of the codes in question, and increases the security of the user’s account with the financial institution.

This presents a significant problem, and opportunity, for wealth management firms. Transitioning their business processes from integrating with SMS-based authentication to authenticator apps can be a challenge on the technical level. Updates to the user interaction processes, for those firms that handle it manually, usually by calling the user and asking for the code, are also going to be needed. It is especially important, for these manual interactions, that some passphrase or the like is used, as banks, trading platforms and other financial institutions will be training their users to NEVER provide an authenticator app secret to anyone over the phone. Attackers leveraging social engineering are going to be the most prevalent form of danger to this authentication model, so wealth management firms must create controls to help assure their clients that they are who they say they are and train them to resist attackers pretending to be the wealth management firm. 

Technical and manual implementations of this form of authentication will prove to be an ongoing challenge for wealth management firms. We are already working with a variety of our clients, helping them update their processes, policies and controls for these changes. If your organization has been traditionally using SMS message authentication with your own clients, there is even more impetus to get moving on changes to your own processes. 

Let us know if we can be of service. You can reach out and have a no stress, no hassle discussion with our team by completing this web form. You can also give us a call anytime at 614-351-1237. We’d love to help! 

Utility Tabletop Cybersecurity Exercises

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Recently, a group of federal partners, comprised of the Federal Energy Regulatory Commission (FERC), North American Reliability Corporation (NERC) and it’s regional entities released their Cyber Planning for Response and Recovery Study (CYPRES). The report was based on a review and analysis of the incident response and recovery capabilities of a set of their member’s cyber security units, and is a great example of some of the information sharing that is increasing in the industry. The report included reviews of eight utility companies’ incident response plans for critical infrastructure environments, and the programs reviewed varied in their size, complexity and maturity, though all were public utilities.

Though the specific tactics suggested in the report’s findings have come under fire and criticism, a few items emerged that were of broad agreement. The first is that most successful programs are based on NIST 800-61, which is a fantastic framework for incident response plans. Secondly, the report discusses how useful tabletop exercises are for practicing responses to cybersecurity threats and re-enforcing the lessons learned feedback loop to improve capabilities. As a result, each public utility should strongly consider implementing periodic tabletop exercises as a part of their cyber security and risk management programs.

Tabletop Exercises from MSI

At MicroSolved, we have been running cyber security tabletop exercises for our clients for more than a decade. We have a proprietary methodology for building out the role playing scenarios and using real-world threat intelligence and results from the client’s vulnerability management tools in the simulation. Our scenarios are developed into simulation modules, pre-approved by the client, and also include a variety of randomized events and nuances to more precisely simulate real life. During the tabletop exercise, we also leverage a custom written gaming management system to handle all event details, track game time and handle the randomization nuances.

Our tabletop exercise process is performed by two MSI team members. The first acts as the simulation moderator and “game master”, presenting the scenarios and tracking the various open threads as the simulation progresses. The second team member is an “observer” and they are skilled risk management team members who pre-review your incident response policies, procedures and documentation so that they can then prepare a gap analysis after the simulation. The gap analysis compares your performance during the game to the process and procedure requirements described and notes any differences, weaknesses or suggestions for improvement.

Target scenarios can be created to test any division of the organization, wide scale attacks or deeply nuanced compromises of specific lines of business. Various utility systems can be impacted in the simulation, including business networks, payment processing, EDI/supply chain, metering/AMI/smart grid, ICS/SCADA or other mission critical systems.Combination and cascading failures, disaster recovery and business continuity can also be modeled. In short, just about any cyber risks can be a part of the exercise.

Tabletop Exercise Outcomes and Deliverables

Our tabletop exercises result in a variety of detailed reports and a knowledge transfer session, if desired. The reports include the results of the policy/procedure review and gap analysis, a description of the simulated incident and an action plan for future improvements. If desired, a board level executive summary can also be included, suitable for presentation to boards, management teams, direct oversight groups, Public Utility Commission and Homeland Security auditors as well.

These reports will discuss the security measures tested, and provide advice on proactive controls that can be implemented, enhanced, matured or practiced in order to display capabilities in future incidents that reflect the ability to perform more rapid and efficient recovery.

The knowledge transfer session is your team’s chance to ask questions about the process, learn more about the gaps observed in their performance and discuss the lessons learned, suggestions and controls that call for improvement. Of course the session can include discussions of related initiatives and provide for contact information exchange with our team members, in the event that they can assist your team in the future. The knowledge transfer session can also be performed after your team has a chance to perform a major review of the reports and findings.

How to Get Started on Tabletop Exercises from MSI

Tabletop exercises are available from our team for cyber security incidents, disaster preparedness and response or business continuity functions. Exercises are available on an ad-hoc, 1 year, 2 year or 3 year subscription packages with frequencies ranging from quarterly to twice per year or yearly. Our team’s experience is applicable to all utility cyber programs and can include any required government partners, government agencies or regulators as appropriate.

Our team can help develop the scope of threats, cyber attacks or emergency events to be simulated. Common current examples include ransomware, phishing-based account compromises, cyber attacks that coincide with catastrophic events or service disruptions, physical attacks against substations or natural gas pipelines, data breach and compromise of various parts of the ICS/SCADA infrastructure. Our team will work with you to ensure that the scenario meets all of your important points and concerns.

Once the scenario is approved, we will schedule the simulation (which can be easily performed via web-conference to reduce travel costs and facilitate easy team attendance) and build the nuances to create the effects of a real event. Once completed, the reporting and knowledge transfer sessions can follow each instance.

Tabletop exercises can go a long way to increasing cybersecurity preparedness and re-enforcing the cybersecurity mindset of your team. It can also be a great opportunity for increasing IT/OT cooperation and strengthening relationships between those team members.

To get started, simply contact us via this web form or give us a call at (614) 351-1237. We would love to discuss tabletop exercises with you and help you leverage them to increase your security posture.

 

Closing the CUSO Security Loop Hole

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The CUSO Security Loop Hole

The NCUA Inspector General (IG) suggested this week that the agency have regulatory oversight of Credit Union Service Organizations (CUSOs) to reduce the overall risk to the system. CUSOs have long been seen as a separate firm from the credit unions, though they may have an ownership stake in them. To date, many of these organizations have been outside the regulatory and oversight controls that are applied to the very credit unions they serve. In terms of information security, that often means they aren’t held to the same level of security and risk management controls as required by NCUA 748 and other guidance.

DigitalMoneyCUSO Security Oversight Challenges

The NCUA IG suggests that NCUA guidance and regulatory oversight be directly applied to CUSOs, instead of through vendor or partner risk management programs of the CUSO customers. This would provide for more direct regulation of the security controls and risk management processes in use at the CUSOs themselves. However, this introduces several challenges for some CUSOs, who may be more focused on agility, market speeds and innovation – areas where regulatory guidance can be especially impactful and can create significant budgetary challenges. This gets even more complicated when regulatory guidance is vague, or can be inflexible – the very opposite of the needs of organizations focused on innovation and market speed adaptation. An excellent example of this is CUSOs working on financial technologies, crypto currencies, blockchain and other exciting new areas. Regulatory guidance lags or lacks in most of those areas and hasn’t caught up to these new, and in some cases, experimental technologies.

One Approach – Best Practices CUSO Security and Third Party Attestation

One approach that might work, is for CUSOs to work with independent third-party assessors who could then measure the CUSO against industry standard best practices that apply to their specific lines of business, research or innovation. These vendors could then help the CUSO build a relevant and respectable CUSO security and risk management program – which they could attest to the NCUA. If this attestation were required on a yearly basis, along with some basic guidance, like ongoing risk management reviews, ongoing vulnerability management, etc – this could go a long way to mitigating the risks that concern the NCUA IG, while still maintaining independence and control by the CUSOs – thus, empowering their mission. Programs like these have been very successful in other industries and don’t have to add the overhead and bureaucracy of full regulatory compliance or programs like PCI-DSS. 

If you’d like to build such a program for your CUSO, please get in touch with us. We’d love to work on creating this process with a handful of CUSOs around the US, and are more than capable of applying our 30 years of experience in information security to each organization’s independent needs. Drop us a line or give us a call at (614) 351-1237 and let’s work together to close the CUSO Security loop hole in a way that reduces risk but doesn’t destroy the power and flexibility of the CUSO ecosystem.

A Quick Expert Conversation About Gap Assessment

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Gap Assessment Interview with John Davis

What follows is a quick interview session with John Davis, who leads the risk assessment/policy/process team at MicroSolved. We completed the interview in January of 2020, and below are the relevant parts of our conversation.

Brent Huston: “Thanks for joining me today, John. Let’s start with what a gap assessment is in terms of HIPAA or other regulatory guidance.”

John Davis: “Thanks for the chance to talk about gap assessment. I have run into several HIPAA concerns such as hospitals and health systems who do HIPAA gap analysis / gap assessment in lieu of HIPAA risk assessment. Admittedly, gap assessment is the bulk of risk assessment, however, a gap assessment does not go to the point of assigning a risk rating to the gaps found. It also doesn’t go to the extent of addressing other risks to PHI that aren’t covered in HIPAA/HITECH guidance.”

BH: “So, in some ways, the gap assessment is more of an exploratory exercise – certainly providing guidance on existing gaps, but faster and more affordable than a full risk assessment? Like the 80/20 approach to a risk assessment?”

John Davis: “I suppose so, yes. The price is likely less than a full blown risk assessment, given that there is less analysis and reporting work for the assessment team. It’s also a bit faster of an engagement, since the deep details of performing risk analysis aren’t a part of it.”

BH: “Should folks interested in a gap assessment consider adding any technical components to the work plan? Does that combination ever occur?”

JD: “I can envision a gap assessment that also includes vulnerability assessment of their networks / applications. Don’t get me wrong, I think there is immense value in this approach. I think that to be more effective, you can always add a vulnerability assessment to gauge how well the policies and processes they have in place are working in the context of the day-to-day real-world operations.”

BH: “Can you tie this back up with what a full risk assessment contains, in addition to the gap assessment portion of the work plan?”

JD: “Sure! Real risk assessment includes controls and vulnerability analysis as regular parts of the engagement. But more than that, a complete risk assessment also examines threats and possibilities of occurrence. So, in addition to the statement of the gaps and a roadmap for improvement, you also get a much more significant and accurate view of the data you need to prioritize and scope many of the changes and control improvements needed. In my mind, it also gets you a much greater view of potential issues and threats against PHI than what may be directly referenced in the guidance.” 

BH: “Thanks for clarifying that, John. As always, we appreciate your expert insights and experience.”

JD: “Anytime, always happy to help.”

If you’d like to learn more about a gap assessment, vulnerability assessment or a full blown risk assessment against HIPAA, HITECH or any other regulatory guidance or framework, please just give us a call at (614) 351-1237 or you can click here to contact us via a webform. We look forward to hearing from you. Get in touch today! 

MicroSolved vCISO for Credit Unions

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I recently asked MicroSolved COO, Dave Rose, to share his thoughts with all of us about the vCISO program. He has been leading the effort this last year across several credit unions and regional banks around the US. I asked him for the 3 biggest benefits an organization can expect and here is what he said:

“MicroSolved has been providing vCISO services to Credit Unions for over 20 years. Whether you are a corporate or a natural person CU, hiring MSI for vCISO Services will allow you to:

  • Obtain CISO expertise without having to incur the expense of finding and hiring a CISO. This is an affordable solution that will help keep the risk budget under control.
  • MSI vCISO program comes with the benefit of a focus towards financial expertise and compliance. MSI has had extensive experience working with banks and credit unions on their risk programs, and have spent time educating regulators on risk events and controls.
  • MSI is in the business of mitigating risk. We live it everyday and our clients benefit from that experience. Our clients get to pick the risk work they want resolved and the issues they want remediated. 

You will be hard pressed to find a more efficient and cost effective way to address risk issues and move the regulatory needle. Don’t bear the burden of mitigating risk alone, let MSI be a partner to help you solve your risk needs!”

—Dave Rose

For more information, give us a call at 614-351-1237 or email us at info@microsolved.com. 

Zelle…quick, easy, and…problematic?

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With the increasing adoption of PayPal, Venmo, and other instant payment services…it’s no surprise that the financial services industry entered the arena. The concept is simple – P2P payments via phone or email. At least one entity – sender or recipient – needs to have a bank account with a bank that supports Zelle. The other entity can simply link a supported debit card to enable the exchange.

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