Category Archives: Regulation

Utility Tabletop Cybersecurity Exercises

Posted on by
Reply

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

Posted on by
Reply

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

Posted on by
Reply

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

Posted on by
Reply

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. 

About the Ohio Data Protection Act

Posted on by

The Ohio Data Protection Act differs from others in the country in that it offers the “carrot” without threat of the “stick.” Although companies are rewarded for implementing a cyber-security program that meets any of a variety of security standards, having a non-compliant program carries no penalty under this act.

The theory is that Ohio companies will be more willing to put resources into their information security programs proactively if a tangible return on their investment is available; like investing in insurance to hedge risk. Alternatively, if there is no threat of penalty for non-compliance, why wouldn’t a business simply adopt a wait and see attitude? After all, most companies do not have big data breaches, and developing and documenting a compliant information security program is expensive.

Continue reading →