Name of Tier | Tier Criteria | Required Diligence | Required Controls |
Critical Risk Vendors | Shared IIP that allows duplication of products or differentiator features or R&D; ANY outage of the vendor’s IT operations would harm JIT delivery or line manufacturing | Any required regulatory document gathering (SAS70, PCI DSS, HIPAA, etc.); Monthly MSI passive assessment – MEDIUM or HIGH risk issues trigger FULL risk assessment & review of their security audits; MSI monitors vendor list for Targeted Threat Intelligence and if triggered, formal incident response process is required from the vendor |
As determined by your firm…
All controls required – NO VARIANCE ALLOWED
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High Risk Vendors | Shared non-critical IIP that allows feature replication, long term damage to product/brand strategy or R&D; Protracted outage of the vendor’s IT operations could impact production | Any required regulatory document gathering (SAS70, PCI DSS, HIPAA, etc.); Quarterly MSI passive assessment – HIGH risk issues trigger FULL risk assessment & review of their security audits |
As determined by your firm…
All controls required – NO VARIANCE ALLOWED
|
Routine Risk Vendors | IIP shared at this level represents a potential for reputational or regulatory impacts; Normal vendor level where data sharing occurs | Any required regulatory document gathering (SAS70, PCI DSS, HIPAA, etc.); Yearly MSI passive assessment – HIGH risk issues trigger deeper risk assessment |
As determined by your firm…
Variance allowed by signed acceptance from steering committee or executive team
|
Low Risk Vendors | Data is not shared with this vendor and compromise of the vendor’s IT operations is unlikely to have any impact | Peer review to validate tier eligibility; Contract language review; Financial fraud team validation | Only contractual controls and/or SLA required |
Category Archives: How To
Mapping Control Requirements to Vendor Tiers
- Low Risk Vendors– What are the minimum steps we should perform for each vendor in this tier?
- Controls Required: Scoping peer review to ensure that the criteria for this tier are met; contract and, when applicable, SLA review by the security team against established guidance & regulatory requirements, approval of financial due diligence team to avert fraud, etc.
- Comments: Since there are only isolated potentials for digital risk in this tier, we don’t need to perform cyber-security reviews and the like, or accumulate data we don’t need (which wastes time & resources, etc.). If, for example, this is a commodity or non-impactful application provider, we might review their contract for language around malware free deliverables, code security, patch/fix turnaround times, etc., as appropriate for each vendor and the service or good they provide.
- Controls Required: Scoping peer review to ensure that the criteria for this tier are met; contract and, when applicable, SLA review by the security team against established guidance & regulatory requirements, approval of financial due diligence team to avert fraud, etc.
- Routine Risk Vendors – At this level, I try and think of the controls that I would want for just about any vendor that can impact us or our operations, but that aren’t capable of doing much beyond reputational or regulatory damage.
- Controls Required: All of the controls of the lower level apply and are required. Any control reviews that are required for regulatory compliance over PII that we share (SAS70, PCI-DSS compliance statements, etc.). Plus, at this stage, I would really like some form of cyber-security assessment, which in this case is MSI’s passive assessment tool (that can be run without the vendor’s knowledge or permission) run against them on a yearly basis with NO HIGH RISK issues identified. If a HIGH RISK issue is found, then they would be flagged and would need to have a formal technical review of their security controls performed or even our traditional risk assessment process. Any deviance from the accepted controls would require a signed risk acceptance variance from a management team or steering committee, as an example.
- Comments: Here, we are defining the basics. What do we need for most vendors that could hurt us? We try to keep the process as simple as possible, so that we can focus on the vendors that have higher risk of actually hurting us and our business. The use of passive assessments here is a powerful new approach to reduce the number of full fledged risk assessments that we need to perform, and the overhead created by dealing with the paperwork and interactions to complete the traditional risk assessment process.
- Controls Required: All of the controls of the lower level apply and are required. Any control reviews that are required for regulatory compliance over PII that we share (SAS70, PCI-DSS compliance statements, etc.). Plus, at this stage, I would really like some form of cyber-security assessment, which in this case is MSI’s passive assessment tool (that can be run without the vendor’s knowledge or permission) run against them on a yearly basis with NO HIGH RISK issues identified. If a HIGH RISK issue is found, then they would be flagged and would need to have a formal technical review of their security controls performed or even our traditional risk assessment process. Any deviance from the accepted controls would require a signed risk acceptance variance from a management team or steering committee, as an example.
- High Risk Vendors – Here we build on the controls below for normal vendors to try and achieve a balance between work load and information security needs. We define a level that exceeds best practices and serves to give us more confidence in the vendors that could hurt us at a significant level.
- Controls Required: All of the controls of the lower levels apply and are now definitely required(no variances accepted at this level for the basic controls defined for lower risk levels). In addition, we need to provide ongoing assessment of the vendor’s security controls, so a passive run is now required without any HIGH RISK findings on a quarterly basis. This is to help us combat control drift and control entropy in the vendor’s security posture. If at any time, a HIGH RISK issue is identified, then a FULL and COMPREHENSIVE risk assessment is required as soon as possible. This risk assessment should include the review of the vendor’s third party risk assessments, vulnerability assessments & penetration tests (these should be provided to us by the vendor, within 3 business days of the request). Failure to pass this risk assessment, respond properly or any significant issues identified that are not mitigated in a timely manner should result in financial and legal consequences for the vendor and their contract with our organization.
- Comments: Again, we are trying to reduce the incidence of full risk assessments, so that we can focus our attention and limited resources on the vendors that can hurt us significantly and are in the worst security postures. Further, we create an incentive at this level for them to comply and respond rapidly.
- Controls Required: All of the controls of the lower levels apply and are now definitely required(no variances accepted at this level for the basic controls defined for lower risk levels). In addition, we need to provide ongoing assessment of the vendor’s security controls, so a passive run is now required without any HIGH RISK findings on a quarterly basis. This is to help us combat control drift and control entropy in the vendor’s security posture. If at any time, a HIGH RISK issue is identified, then a FULL and COMPREHENSIVE risk assessment is required as soon as possible. This risk assessment should include the review of the vendor’s third party risk assessments, vulnerability assessments & penetration tests (these should be provided to us by the vendor, within 3 business days of the request). Failure to pass this risk assessment, respond properly or any significant issues identified that are not mitigated in a timely manner should result in financial and legal consequences for the vendor and their contract with our organization.
- Critical Risk Vendors – These are the vendors that can REALLY hurt us, so we spend a majority of our attention and resources here.
- Controls Required: All of the controls of the lower levels apply and are now definitely required(no variances accepted at this level for the basic controls defined for lower risk levels). Additionally, passive assessments are now monthly in frequency (or maybe even weekly, depending on your paranoia/risk tolerance). Ongoing monitoring of target threat intelligence data is also required – so we are having MSI monitor social media/public web/deep web/dark web for any events or indicators of compromise that might emerge and be related to our vendors in this tier. At this level, we are performing the full comprehensive risk assessment process on a yearly basis, in addition to the passive work of MSI. While this is tedious, we want to ensure that we have provided the utmost effort on these vendors that can truly hurt us at the most damaging of levels. We can now do this easily without taxing our resources, thanks to the tiering architecture and the use of the focus points provided by MSI through our passive assessment and other services. Any identified MEDIUM or HIGH RISK issue flagged by MSI results in the immediate triggering of an update to the risk assessment process, notification of the vendor for the required response of their security team leadership, and the potential requirement for a formal incident response process for the vendor – which we manage by requiring the delivery of an incident response report and/or attestation by a third party security firm that the situation was mitigated and that our IIP was protected. Failure to pass this risk assessment, respond properly or any significant issues identified that are not mitigated in a timely manner should result in SIGNIFICANT financial and legal consequences for the vendor and their contract with our organization.
- Comments: Here we leverage ongoing monitoring and take the lead on watching for potential compromises for ourselves and our vendors. Given the large percentage of breaches reported by third parties, we no longer believe that the detection and response capabilities of any partner organization are strong enough, alone, to protect our IIP. Thus the increased due diligence and oversight for the vendors that can hurt us the worst.
- Controls Required: All of the controls of the lower levels apply and are now definitely required(no variances accepted at this level for the basic controls defined for lower risk levels). Additionally, passive assessments are now monthly in frequency (or maybe even weekly, depending on your paranoia/risk tolerance). Ongoing monitoring of target threat intelligence data is also required – so we are having MSI monitor social media/public web/deep web/dark web for any events or indicators of compromise that might emerge and be related to our vendors in this tier. At this level, we are performing the full comprehensive risk assessment process on a yearly basis, in addition to the passive work of MSI. While this is tedious, we want to ensure that we have provided the utmost effort on these vendors that can truly hurt us at the most damaging of levels. We can now do this easily without taxing our resources, thanks to the tiering architecture and the use of the focus points provided by MSI through our passive assessment and other services. Any identified MEDIUM or HIGH RISK issue flagged by MSI results in the immediate triggering of an update to the risk assessment process, notification of the vendor for the required response of their security team leadership, and the potential requirement for a formal incident response process for the vendor – which we manage by requiring the delivery of an incident response report and/or attestation by a third party security firm that the situation was mitigated and that our IIP was protected. Failure to pass this risk assessment, respond properly or any significant issues identified that are not mitigated in a timely manner should result in SIGNIFICANT financial and legal consequences for the vendor and their contract with our organization.
Sorting Vendors into Tiers
- Critical Risk Vendors
- Criteria: Mission critical “information intellectual property” (IIP) assets are shared with this vendor, where the assets represent a significant portion of the market differentiator or research and development of a product line OR the vendor’s IT operations are critical to our just in time manufacturing or delivery model – that is – ANY outage of the vendor’s IT operations would cause an outage for us that would impact our capability to deliver our products to our customers
- Examples: Compromise of the IIP data would allow duplication of our product(s) or significant replication of our research; Outages or tampering with the vendor IT operations would impact manufacturing line operations, etc.
- Criteria: Mission critical “information intellectual property” (IIP) assets are shared with this vendor, where the assets represent a significant portion of the market differentiator or research and development of a product line OR the vendor’s IT operations are critical to our just in time manufacturing or delivery model – that is – ANY outage of the vendor’s IT operations would cause an outage for us that would impact our capability to deliver our products to our customers
- High Risk Vendors
- Criteria: Non-critical IIP assets are shared with this vendor such that if said assets were compromised, they would represent damage to our long term product & brand strategies or research and development. Actual product replication would not be enabled, but feature replication might be possible. Outages of vendor’s IT operations at this level, if protracted, could impact our research and development or ability to deliver our products to our customers.
- Examples: Breach of this vendors network could expose the design specs for a specific part of the product. Compromise of the vendor could expose our future marketing plan for a product and some of the differentiating features that we plan to leverage. If the vendor’s IT operations were disabled for a protracted time, (greater than /48, 72 or 96/ hours), our capability to deliver products could be impacted.
- Criteria: Non-critical IIP assets are shared with this vendor such that if said assets were compromised, they would represent damage to our long term product & brand strategies or research and development. Actual product replication would not be enabled, but feature replication might be possible. Outages of vendor’s IT operations at this level, if protracted, could impact our research and development or ability to deliver our products to our customers.
- Routine Risk Vendors
- Criteria: Non-critical IIP assets may be shared with this vendor tier, and compromise of that IIP may be damaging to our reputation. The IIP, if compromised, would not allow duplication of our product lines, research or differentiators of our products. In addition to reputational impacts, share of data that could impact our sales pipeline/process and/or other secondary systems or processes may be expected if breaches occur at this level. Regulatory or legally protected IIP also resides at this level.
- Examples: Organizations where customer data, sales & marketing data, employee identification information, etc. are shared (outsourced payment, outsourced HR, etc.) are good examples here. This is the level of risk for any vendor that you share IIP with, in any form, that does NOT immediately empower delivery of your products or impact your longer term R&D efforts or market differentiators…
- Criteria: Non-critical IIP assets may be shared with this vendor tier, and compromise of that IIP may be damaging to our reputation. The IIP, if compromised, would not allow duplication of our product lines, research or differentiators of our products. In addition to reputational impacts, share of data that could impact our sales pipeline/process and/or other secondary systems or processes may be expected if breaches occur at this level. Regulatory or legally protected IIP also resides at this level.
- Low Risk Vendors
- Criteria: This tier is for vendors that we share NO IIPwith, in any form, and vendors that could not directly impact our product delivery via an IT operations outage in any way. These vendors, should they experience a breach, would result in little to no impact on the reputation or capabilities of our firm to operate.
- Examples: Caterers, business supply companies, temporary employment agencies, hardware and software vendors for not manufacturing systems, commodity product or component dealers, packaging material suppliers, transport companies, etc.
- Criteria: This tier is for vendors that we share NO IIPwith, in any form, and vendors that could not directly impact our product delivery via an IT operations outage in any way. These vendors, should they experience a breach, would result in little to no impact on the reputation or capabilities of our firm to operate.
Comparing 2 Models for DMZ Implementations
- The “3 Legged Model” or “single firewall” – where the DMZ segment(s) are connected via a dedicated interface (or interfaces) and a single firewall implements traffic control rules between all of the network segments (the firewall could be a traditional firewall simply enforcing interface to interface rules or a “next generation” firewall implementing virtualized “zones” or other logical object groupings)
- The “Layered Model” or “dual firewall”- where the DMZ segment(s) are connected between two sets of firewalls, like a sandwich
Old School Google Hacking Still Works…
Did some old school Google hacking last night.
“Filetype:xls & terms” still finds too much bad stuff.
Check for it lately for your organization?
Try other file types too. (doc/ppt/pdf/rtf, etc.)
Information leakage happens today, as it always has. Keeping an eye on it should be a part of your security program.
How to Use Risk Assessment to Secure Your Own Home
Risk assessment and treatment is something we all do, consciously or unconsciously, every day. For example, when you look out the window in the morning before you leave for work, see the sky is gray and decide to take your umbrella with you, you have just assessed and treated the risk of getting wet in the rain. In effect, you have identified a threat (rain) and a vulnerability (you are subject to getting wet), you have analyzed the possibility of occurrence (likely) and the impact of threat realization (having to sit soggy at your desk), and you have decided to treat that risk (taking your umbrella) – risk assessment.
However, this kind of risk assessment is what is called “ad hoc”. All of the analysis and decision making you just made was informal and done on the fly. Pertinent information wasn’t gathered and factored in, other consequences such as the bother of carrying the umbrella around wasn’t properly considered, other treatment options weren’t considered, etc. What business concerns and government agencies have learned from long experience is that if you investigate, write down and consider such factors rationally and holistically, you end up with a more realistic idea of what you are really letting yourself in for, and therefore you are making better risk decisions – formal risk assessment.
So why not apply this more formal risk assessment technique to important matters in your own life such as securing your home? It’s not really difficult, but you do have to know how to go about it. Here are the steps:
1. System characterization: For home security, the system you are considering is your house, its contents, the people who live there, the activities that take place there, etc. Although, you know these things intimately it never hurts to write them down. Something about viewing information on the written page helps clarify it in our minds.
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Threat identification: In this step you imagine all the things that could threaten the security of your home and family. These would be such things as fire, bad weather, intruders, broken pipes, etc. For this (and other steps in the process), you can go beyond your own experience and see what threats other people have identified (i.e. google inquiries, insurance publications).
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Vulnerability identification: This is where you pair up the threats you have just identified with weaknesses in your home and its use. For example, perhaps your house is located on low ground that is subject to flooding, or you live in a neighborhood where burglaries may occur, or you have old ungrounded electrical wiring that may short and cause a fire. These are all vulnerabilities.
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Controls analysis: Controls analysis is simply listing the security mechanisms you already have in place. For example, security controls used around your home would be such things as locks on the doors and windows, alarm systems, motion-detecting lighting, etc.
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Likelihood determination: In this step you decide how likely it is that the threat/vulnerability will actually occur. There are really two ways you can make this determination. One is to make your best guess based on knowledge and experience (qualitative judgement). The second is to do some research and calculation and try to come up with actual percentage numbers (quantitative judgement). For home purposes I definitely recommend qualitative judgement. You can simply rate the likelihood of occurrence as high, medium or low risk.
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Impact analysis: In this step you decide what the consequences of threat/vulnerability realization will be. As with likelihood determination, this can be judged quantitatively or qualitatively, but for home purposes I recommend looking at worst-case scenarios. For example, if someone broke into your home, it could result in something as low impact as minor theft or vandalism, or it could result in very high impact such as serious injury or death. You should keep these more dire extremes in mind when you decide how you are going to treat the risks you find.
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Risk determination: Risk is determined by factoring in how likely threat/vulnerability realizations is with the magnitude of the impact that could occur and the effectiveness of the controls you already have in place. For example you could rate the possibility of home invasion occurring as low, and the impact of the occurrence as high. This would make your initial risk rating a medium. Then you factor in the fact that you have an alarm system and un- pickable door locks in place, which would lower your final risk rating to low. That final rating is known as residual risk.
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Risk treatment: That’s it! Once you have determined the level of residual risk, it is time to decide how to proceed from there. Is the risk of home invasion low enough that you think you don’t need to apply any other controls? That is called accepting risk. Is the risk high enough that you feel you need to add more security controls to bring it down? That is called risk limitation or remediation. Do you think that the overall risk of home invasion is just so great that you have to move away? That is called risk avoidance. Do you not want to treat the risk yourself at all, and so you get extra insurance and hire a security company? That is called risk transference.
So, next time you have to make a serious decision in your life such as changing jobs or buying a new house, why not apply the risk assessment process? It will allow you to make a more rational and informed decision, and you will have the comfort of knowing you did your best in making the decision.
Thanks to John Davis for this post.
How to Avoid Getting Phished
Mergers and Acquisitions: Look Before You Leap!
Mergers and acquisitions are taking place constantly. Companies combine with other companies (either amicably or forcibly) to fill some perceived strategic business need or to gain a foothold in a new market. M&As are most often driven by individual high ranking company executives, not by the company as a whole. If successful, such deals can be the highpoint in a CEO’s career. If unsuccessful, they can lead to ignominy and professional doom.
Of course this level of risk/reward is irresistible to many at the top, and executives are constantly on the lookout for companies to take over or merge with. And the competition is fierce! So when they do spot a likely candidate, these individuals are naturally loath to hesitate or over question. They want to pull the trigger right away before conditions change or someone else beats them to the draw. Because of this, deal-drivers often limit their research of the target company to surface information that lacks depth and scope, but that can be gathered relatively quickly.
However, it is an unfortunate fact that just over half of all M&As fail. And one of the reasons this is true is that companies fail to gain adequate information about their acquisitions, the people that are really responsible for their successes and the current state of the marketplace they operate in before they negotiate terms and complete deals. Today more than ever, knowledge truly is power; power that can spell the difference between success and failure.
Fortunately, technology and innovation continues to march forward. MSI’s TigerTraxTM intelligence engine can provide the information and analysis you need to make informed decisions, and they can get it to you fast. TigerTraxTM can quickly sift through and analyze multiple sources and billions of records to provide insights into the security posture and intellectual property integrity of the company in question. It can also be used to provide restricted individual tracing, supply chain analysis, key stakeholder profiling, history of compromise research and a myriad of other services. So why not take advantage of this boon and “look” before you leap into your next M&A?
This post courtesy of John Davis.
Tips for Writing Good Security Policies
Almost all organizations dread writing security policies. When I ask people why this process is so intimidating, the answer I get most often is that the task just seems overwhelming and they don’t know where to start. But this chore does not have to be as onerous or difficult as most people think. The key is pre-planning and taking one step at a time.
First you should outline all the policies you are going to need for your particular organization. Now this step itself is what I think intimidates people most. How are they supposed to ensure that they have all the policies they should have without going overboard and burdening the organization with too many and too restrictive policies? There are a few steps you can take to answer these questions:
- Examine existing information security policies used by other, similar organizations and open source information security policy templates such as those available at SANS. You can find these easily online. However, you should resist simply copying such policies and adopting them as your own. Just use them for ideas. Every organization is unique and security policies should always reflect the culture of the organization and be pertinent, usable and enforceable across the board.
- In reality, you should have information security policies for all of the business processes, facilities and equipment used by the organization. A good way to find out what these are is to look at the organizations business impact analysis (BIA). This most valuable of risk management studies will include all essential business processes and equipment needed to maintain business continuity. If the organization does not have a current BIA, you may have to interview personnel from all of the different business departments to get this information.
- If the organization is subject to information security or privacy regulation, such as financial institutions or health care concerns, you can easily download all of the information security policies mandated by these regulations and ensure that you include them in the organization’s security policy.
- You should also familiarize yourself with the available information security guidance such as ISO 27002, NIST 800-35, the Critical Security Controls for Effective Cyber Defense, etc. This guidance will give you a pool of available security controls that you can apply to fit your particular security needs and organizational culture.
Once you have the outline of your security needs in front of you it is time to start writing. You should begin with broad brush stroke, high level policies first and then add detail as you go along. Remember information security “policy” really includes policies, standards, guidelines and procedures. I’ve found it a very good idea to write “policy” in just that order.
Remember to constantly refer back to your outline and to consult with the business departments and users as you go along. It will take some adjustments and rewrites to make your policy complete and useable. Once you reach that stage, however, it is just a matter of keeping your policy current. Review and amend your security policy regularly to ensure it remains useable and enforceable. That way you won’t have to go through the whole process again!
Thanks to John Davis for this post.
Three Danger Signs I Look for when Scoping Risk Assessments
Scoping an enterprise-level risk assessment can be a real guessing game. One of the main problems is that it’s much more difficult and time consuming to do competent risk assessments of organizations with shoddy, disorganized information security programs than it is organizations with complete, well organized information security programs. There are many reasons why this is true, but generally it is because attaining accurate information is more difficult and because one must dig more deeply to ascertain the truth. So when I want to quickly judge the state of an organization’s information security program, I look for “danger” signs in three areas.
First, I’ll find out what kinds of network security assessments the organization undertakes. Is external network security assessment limited to vulnerability studies, or are penetration testing and social engineering exercises also performed on occasion? Does the organization also perform regular vulnerability assessments of the internal network? Is internal penetration testing also done? How about software application security testing? Are configuration and network architecture security reviews ever done?
Second, I look to see how complete and well maintained their written information security program is. Does the organization have a complete set of written information security policies that cover all of the business processes, IT processes and equipment used by the organization? Are there detailed network diagrams, inventories and data flow maps in place? Does the organization have written vendor management, incident response and business continuity plans? Are there written procedures in place for all of the above? Are all of these documents updated and refined on a regular basis?
Third, I’ll look at the organization’s security awareness and training program. Does the organization provide security training to all personnel on a recurring basis? Is this training “real world”? Are security awareness reminders generously provided throughout the year? If asked, will general employees be able to tell you what their information security responsibilities are? Do they know how to keep their work areas, laptops and passwords safe? Do they know how to recognize and resist social engineering tricks like phishing emails? Do they know how to recognize and report a security incident, and do they know their responsibilities in case a disaster of some kind occurs?
I’ve found that if the answer to all of these questions is “yes”, you will have a pretty easy time conducting a thorough risk assessment of the organization in question. All of the information you need will be readily available and employees will be knowledgeable and cooperative. Conversely I’ve found that if the answer to most (or even some) of these questions is “no” you are going to have more problems and delays to deal with. And if the answers to all of these questions is “no”, you should really build in plenty of extra time for the assessment. You will need it!
Thanks to John Davis for this post.