PII: Achieving a Defensible Standard of Care...

A data security breach of "Personal Identifiable Information" (PII) will impact your organization in the future. This incident is no different than other Operational Risk loss events to your global enterprise this year, such as occupational fraud or the settlement of a lawsuit.

Correct?

This time however, the difference is that now your own employees or your customers are the victim. Their PII has been lost or stolen and your organization has been the safeguarding entity of that valuable data until now. Your response is vital and the way you legally and ethically behave is a significant risk factor in itself.

Your brand reputation in the marketplace is on the line and the potential churn in lost customers or employees is at stake. Like many post 9/11 companies, your crisis response protocol is already in place for incidents that require your senior executives and the establishment of an immediate Incident Response Team (IRT).

So why is lost or stolen PII such an important executive issue for any organization?

In privacy, PII is less restrictive than in Information security and one definition can be found in the EU directive 95/46/EC:^[1]

"Article 2a: 'personal data' shall mean any information relating to an identified or identifiable natural person ('data subject'); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;"

Although the concept of PII is ancient, it has become much more important as information technology and the AI-powered Internet have made it easier to collect PII, leading to a profitable market in collecting and reselling PII.

PII can also be exploited by criminals to stalk or steal the identity of a person, or to plan a person's murder or robbery, among other crimes. As a response to these threats, many web site privacy policies specifically address the collection of PII, and lawmakers have enacted for decades a series of legislation to limit the distribution and accessibility of PII.

As your General Counsel and Chief Privacy Officer begin to assess the magnitude and breadth of your recent PII exposure, so too does the plaintiff lawyers. Now the clock starts ticking and each tick gets louder and louder, as different litigation strategies are discussed. In Board Rooms and judges court chambers across the United States, the Federal Rules of Civil Procedure (FRCP) and the admissibility of "Electronically Stored Information" (ESI) is being discussed as a legitimate component of evidence and it's relevance in the case.

What if you could now "Rewind" this scenario and find yourself in a "legal safe zone" to adequately prepare, prevent and even preempt a "Data Security Breach" in your organization. This "legal safe zone" is available today and is as close as your corporate executive conference room, with several "Subject Matter Experts" working side-by-side. It's a professional service solution from a data breach services leader.

The "Achieving a Defensible Standard of Care" Readiness workshop in your organization begins with a two day facilitated process for discovery and convergence with your fellow company executives.

You will be engaged in a proactive, preventive and preemptive tactical plan in preparation for the day of your next PII-involved Data Security Breach. Upon completion, this operational plan establishes the baseline framework for a complete team-based drill.

This outcome will then test the readiness of your key stakeholders internally and external to the company. More importantly, it provides the strategic insight on what vulnerabilities still exist in your particular organizations approach to remediation and legal compliance.

Each year, despite security efforts, millions of personal records are compromised as a result of corporate and public-sector data breaches. Breach response costs - mandated notification, PR, call handling, credit monitoring and legal fees - can add up, yet traditional approaches don't fully mitigate the risk to your business or your customers.

A data security breach of "Personal Identifiable Information" (PII) will impact your organization in the future. The next one will be different…

Virtual Truth: False Information Risk...

How does "False Information" impact the risk to your organization? 

Decisions based upon faulty or inaccurate information is the root of many of the systemic failures of catastrophic history. The Titanic, Challenger Shuttle and Three Mile Island nuclear incident can all be attributed to the integrity of vital information.

Fast forward to the financial crisis and the past decades of consumer credit expansion strategies. What data have you been collecting from US consumers or clients about their personal identifiable information attributes?

The Information Age has drawn us into a more dangerous business operating environment as these digital assets have become another commodity to be sold in an international market place, to the highest bidder. Are you ready when the federal "Suits" or the local LEO's (Law Enforcement Officer) knock on your door in pursuit of the truth:

The Fair Credit Reporting Act (FCRA) spells out rights for victims of identity theft, as well as responsibilities for businesses. Identity theft victims are entitled to ask businesses for a copy of transaction records — such as applications for credit — relating to the theft of their identity. Indeed, victims can authorize law enforcement officers to get the records or ask that the business send a copy of the records directly to a law enforcement officer. The businesses covered by the law must provide copies of these records, free of charge, within 30 days of receiving the request for them in writing. This means that the law enforcement officials who ask for these records in writing may get them from your business without a subpoena, as long as they have the victim’s authorization.

The financial integrity of your future as a business and as a consumer is at stake. Christopher Burns brings this to light in a dramatic fashion in his book; Deadly Decisions:

"First, it is often extremely difficult to validate, corroborate, or verify the information we are dealing with, except by comparing it to the other information we are dealing with. And often the whole system is contaminated by misunderstanding, bad data and false assumptions that are hard to spot. The truth test rarely works. And second, the real issue of truth is not whether you or I should believe this or that, it is what we believe together. The truth that matters is group truth, and where we get into trouble is when a whole organization--a company, a community, a nation--starts to act on information that has been gathered from many sources and processed by many people but has come to contain significant elements that are false.”

Trusted Information is at the core of current global trading, business transactions and the fabric of our own personal identities. False information and knowledge is what creates operational risk factors that can change a whole company or the integrity of a whole nation.

Systems that comprise vast databases of "so called" trusted information are at our fingertips being utilized to make coherent and effective decisions. Yet what may be the more catastrophic Operational Risk beyond the simple stealing of information is the potential opportunity for the destruction of vital information.

The vulnerability of our institutions and the critical infrastructure of the United States economy is ever more at risk of a systemic loss. While our stolen data will continue to be sold to the highest bidder on a global platform for trading, the 4GW "Non-State" actors will change their modus operandi. This is a given.

Trusted Information systems that have certified integrity and the oversight controls to ensure the highest level of virtual truth is the "Holy Grail.”

The degree to which these same systems include false knowledge is our most complex problem for business and government in the next decade…

Analytic Priorities: Crossing the Digital RubiCON...

The governance of information within the government enterprise or the private sector enterprise remains very much the same. Both are subjected to a myriad of laws to help protect the civil liberties and privacy of U.S. citizens. Yet the data leaks, breaches and lost laptops keep both private sector and government organizations scrambling to cover their mistakes and to keep their adversaries from getting the upper hand. Again, the governance of information is the core capability that must be addressed if we are to have effective homeland security intelligence sharing to defeat the threats to the homeland 100% of the time.

The stakeholders in the information sharing environments will say that they have all the laws they need to not only protect information and also to protect the privacy of and liberties of U.S. citizens. What they may not admit, is that they do not have the assets within the context of their own organizations to deter, detect, defend and document the threats related to too much information being shared or not enough. These assets are a combination of new technologies, new education and situational awareness training and the people to staff these respective duties within the enterprise architecture.

Operational Risk Management is a continuous process in the context of our rapidly expanding corporate environments. What is one example? People traveling to emerging markets to explore new business opportunities or new suppliers that will be connected by high speed Internet connections to the supply chain management system. These boundaries of managing operational risk, have not only expanded, they have become invisible.

Ru·bi·con

1. a river in N Italy flowing E into the Adriatic

—Idiom

2. Rubicon, to take a decisive, irrevocable step

This "Digital Rubicon" before us, to take on a more "Active Defense" in navigating the risk across international waters of e-commerce, privacy and legal jurisdictions will forever shape our future. The decisions made on what constitutes an adversarial attack in the cyber domain, will not be as easy as the dawn of the nuclear age. Policy makers today have to weave the potential implications into a sophisticated decision tree that crosses the complex areas of intelligence, diplomacy, defense, law, commerce, economics and technology.

The new digital "Rule Sets" are currently being defined by not only nation states but the "Non-State" actors who dominate a segment of the global digital domains. The same kinds of schemes, ploys, communication tactics and strategies are playing out online and what has worked in the physical world, may also work even better in the cyber-centric environment. Corporations are increasingly under estimating the magnitude of the risk or the speed that it is approaching their front or back door steps.

The private sector is under tremendous oversight by various regulators, government agencies and corporate risk management. Yet the "public-private" "tug-of-war" over information sharing, leaks to the public press and Wikileaks incidents has everyone on full alert. As the government has outsourced the jobs that will take too long to execute or that the private sector already is an expert, operational risks have begun to soar.

As the private sector tasks morph with the requirements of government you perpetuate the gap for effective risk mitigation and spectacular incidents of failure. Whether it is the failure of people, processes, systems or some other clandestine event doesn't matter. The public-private paradox will continue as long as the two seek some form of symbiosis. The symbiotic relationship between a government entity and a private sector supplier must be managed no differently than any other mission critical resource within an unpredictable environment.

Once an organization has determined the vital combination of assets it requires to operate on a daily basis, then it can begin it's quest for enabling enterprise resiliency. The problem is, most companies still do not understand these complex relationships within the matrix of their business and therefore remain vulnerable. The only path to gaining that resilient outcome, is to finally cross that "Digital Rubicon" and realize that you no longer can control it.

The first step in any remediation program, is first to admit the problem and to accept the fact that it exists. Corporate enterprises and governments across the globe are coming to the realization that the only way forward is to cooperate, coordinate and contemplate a new level of trust.

operational risk

Cyber Reality: Quest for the Digital Castle...

On this Saturday morning the prayers are silent. For family, friends and also for the subject matter experts in business and the U.S. government.

They have been waking us up again to the reality of the Operational Risks we now face, to our ubiquitous digital-based economic infrastructure.

The message is clear to those insiders, who have been trying to defend our "Digital Castles" against tremendous odds of these seemingly invisible threats. Is it really, game over?

The short answer is yes. The current mindset should be, that every major business of valuable interest in the eyes of the enemy has already been compromised or soon to be. It is already too late. The stealth digital code is currently waiting in the shadows of your organizations hundreds or thousands of digital assets.

Whether it is the aging Dell Tower Desk Tops still running on Windows XP somewhere or the latest Android PDA/Apple IOS devices tethered to the corporate network does not matter. Your adversary has control of when and where to begin the attack on you and your organization.

So if this is the reality of the global state-of-play, in both the business world and also to government, what should the risk management strategy consist of going forward? How could we ever get to a point of advantage over those who seek to do us harm?

So internally, the prudent corporate business strategy should be for your General Counsel and the CIO of your organization to be already preparing themselves for the day that they will step before the press conference microphone to disclose the material breach of the companies intellectual capital or theft of assets.

They should already know, that it is just a matter time and not a denial that it will ever happen on their watch. If you are a Board Director and you still have not had "The Talk" with management about this stark reality, then you too are complicit in the scheme to present your stockholders and stakeholders with a false sense of confidence that you are safe and secure.

The new normal for forward thinking organizations is already being implemented for adverse events. The Crisis Management Team has already exercised the "Data Breach" scenario numerous times.

Your General Counsel and Chief Information Officer have rehearsed and practiced their testimony before opposing and adversarial questioning of your organizations information security processes.

The company subject matter experts are more than prepared to submit evidence of their best practices, industry standards compliance and previous tests of due diligence. The stage is set for the court room battles ahead:

The quest for the "Digital Castle" has been going on for years. Are you awake now or still living in a dream of denial on your state of achieving a Defensible Standard of Care…

CyberCom: Real-time Situational Awareness...

The Operational Risks to your enterprise that are associated with your digital assets, networks and infrastructure are vast.

What is your organizations exposure today?

The amount of daily "Cyber Intelligence" flowing into the organization is growing exponentially and there are few hours in the day to analyze it. You have invested hundreds of thousands if not millions on cyber security to keep your corporate systems protected and ready for any significant business disruptions.

Electronic Stored Information (ESI) is continuously being discussed at the Board of Directors meetings. Data Breach Notification Laws are being amended and the congressional pipeline for privacy and cyber laws is in full swing in the United States.

The Fortune 500 is already paying for "White Hat" hackers to test their online and data security. The only way to continuously determine the effectiveness of risk management controls, is to continuously test them in a lab or scenario environment.

This "Red Cell" approach to attacking the corporate assets from the "inside out" or the "outside in" provides the intelligence necessary to close the gaps and vulnerabilities. These penetration or vulnerability tests are necessary and the ecosystem of companies of sources and methods is expansive.

A Fortune 500 organization may currently subscribe to annual services that provide the intelligence that gives them an alert of a "Red Flag" in their security landscape.

The company that provides the intelligence is paying a substantial fee to a network of sophisticated professionals to exploit the vulnerabilities in software coding. Namely, the design, configuration or implementation of a complex set of technologies to determine where and how these vulnerabilities may pose a threat to your assets.

The model for Enterprise OPS Risk Management in the most savvy and enlightened critical infrastructure dependent organizations realize that cyber security is not a department or a unit at the company.

It remains a horizontal platform on which all business units and the departments of the organization rest and it's pervasive mechanisms for the security and safety of people, processes, systems and external events must operate 24 X 7 X 365.

Our future is about "Defend Forward" or an "Real-Time Situational Awareness" strategy.

"The “defend forward” concept outlined in the DoD’s 2018 cyber strategy charges Cyber Command to get as close to adversaries in networks outside the United States before they reach the nation. The command uses its authorities to operate in networks abroad to discover malware and enemy tactics that could be used against the American people or election infrastructure.

The command can either share that with relevant partners — such as the Department of Homeland Security, the FBI or private companies — so they can take necessary measures, or the command can unilaterally take action thwart malicious activities before they impact American networks."

The public and the consumer are becoming used to the fact, that the challenge continues to be an iterative process and worthy of some levels of patience. 

"Operational Risk Management (ORM) is not about eliminating all threats to the enterprise. It is about the speed and accuracy of understanding the current levels and threat vectors so you can effectively deter, detect, defend and document."

This "4D" approach to risk management in the rapidly changing, digitally mobile organization of 2020 and beyond is a shift away from pure information security thinking that is housed within the Information Technology Department...

Red Zone: Behavioral Analysis Interviews...

Industrial Espionage and the theft of trade secrets is continuously on every Operational Risk Management (ORM) executives mind these days.  The names Chelsea Manning and Julian Assange have been headline news for years.

In addition, the 2009 conviction under the Economic Espionage Act of 1996 in the United States, is a stark reminder of the accelerated requirements for an "Insider Threat Program" (InTP), by the counter intelligence and OPSEC units of major public and private organizations.  Flashback to a decade ago:

"A former Rockwell and Boeing engineer from Orange County, CA was remanded into custody this morning after a federal judge convicted him of charges of economic espionage and acting as an agent of the People’s Republic of China, for whom he stole restricted technology and Boeing trade secrets, including information related to the Space Shuttle program and Delta IV rocket."

How 250,000 pages of classified, proprietary and otherwise sensitive information was found under this employees house is a good question? What might be an even more interesting question is pertaining to the controls for OPSEC and INFOSEC at Boeing in Orange County, CA a decade ago.

Information Operations (IO) or Information Security controls are only as good as the creativity and the will of the individual human being, that exploits the vulnerabilities in the design, configuration or implementation of your layers of defense.

This is why the counter intelligence and OPSEC capabilities within the enterprise must be ever vigilant and continuously adapting to the changing personnel within the organization.

In collaboratin with the Information Technology organization, the Digital Operational Risks that the OPSEC team is focused on these days, has to do with Data Loss Prevention (DLP)  software platforms and proactive data exfiltration detection capabilities.

As companies such as Boeing and other Defense Industrial Base (DIB) institutions utilize the latest software, hardware and other technology to assist in the "insider" detection and prevention of stealing, changing or deleting sensitive information, there still remains the risk of human factors and social engineering.

Sometimes the low tech or human designed detection systems that work on behavioral sciences, can be just as effective as the newest software running on the fastest computer box.

One example is "The Reid Technique" in the context of doing routine interviews and investigations with a set of "Red Zone" employees. Who are the red zone employees?

Those individuals who have certain access to systems or information, leave the organization for involuntary reasons or people that may be 3rd party suppliers to the key people in the red zone. So how does the Reid Technique help?

"The Reid Technique is a method of meeting, conferring with, and evaluating, the subjects of an investigation. It involves three different components — factual analysis, interviewing, and interrogation. While each of these are separate and distinct procedures, they are interrelated in the sense that each serves to help eliminate innocent suspects during an investigation."

The "Integrity Interview" is a highly structured interview with a job applicant. The purpose for the interview is to develop factual information about the applicant's past behavioral patterns.

The philosophy behind the interview is very straightforward. The most accurate indicator of an individual's future behavior, is their recent past behavior.

The same technique can be used on a departing employee with the emphasis on adherence to all "Acceptable Use" policies, regarding digital assets and cyberspace access to organizational data repositories.

Individuals who have the characteristics associated with deception, could be the target of a further investigation to determine whether any unauthorized information has been sent to an encrypted webmail account or if a 2 TB Thumb Drive happened to be plugged into a corporate laptop, the night before the last day on the job.

This low tech method may still be one of the most effective means for industrial espionage. Old school methods with 21st century technologies. All of the detection hardware and software, CCTV cameras, tagged files or RFID countermeasure, will not be able to thwart a diligent, patient and trusted insider.

Utilizing "Behavioral Interview Analysis" can make the difference between early detection or late reaction.

And while the OPSEC group is working on the "Lone Wolf" insider, there are swarms of non-state attackers initiating their asymmetric information operations strategy on the corporations and governments worldwide.

Economic espionage and attacks on nations states critical infrastructures, requires a substantial shift in policy and taxonomy, if we are ever going to be effective in protecting our IP and trade secrets.

While the CEO's and the General's are being briefed on the latest facets of "Weaponizing Malware," we can only hope that OPSEC is still conducting the behavioral analysis exit interview.

A face to face encounter, with someone who may just be that one person, who has your most valuable intellectual property or trade secrets in the purse or backpack at their feet...

Cyber Risk: Human Factors vs. Automation...

Operational Risk Management (ORM) is a growing multi-faceted mosaic comprised of people, processes, systems and external events. The risks to the enterprise are increasing at a dynamic speed and trajectory that requires the use of automated tools.

This is where risk to the enterprise may actually expand as executives and operational management rely on software to provide information assurance. The design and architecture of software needs a human-based fail-safe. It requires a human interface that allows and simultaneously requires human intervention. Has too much automation contributed to our increased levels of vulnerability?

Fortunately, the software designs have allowed for these opportunities and for a human-factor to ask "What if" questions. Those questions that may arise after an automated alert from the system tells us that something is outside the baseline parameters set for the system, the sensor or the alarm.

Now we go back to Operational Risk and the nature of thinking from a security and safety perspective. What is the continued reliance on automated systems doing to the human capital who have been charged with the over all "Standard of Care" for the enterprise?

We believe that they may have lost the ability to ask the right questions, at the right moment and with the correct contextual understanding.

What is the truth? Is it true? What evidence do we have that this is true? How do you know that the evidence is not spoiled or compromised? If we know the truth, then what do we do next? Is the software really telling us the truth?

The security and the safety of the enterprise is counting on you. And more importantly, the enterprise is asking you to question the software. The "rule-sets" that you have chosen as a result of the programmers and architects decisions can no longer be trusted.

Is our system learning? In what capacity is the system learning in context with the human interaction for judgement, intuition and ethical emotions? Are you with us? The next generation of "Cyber Security" Innovators are now at the edge of significant new breakthroughs and solutions.

"Active Defense" has been and is a controversial topic du jour, yet the next few years will be a new age of understanding, cultural bifurcations and significant global collaboration.

Our entire platform of digital trust is at stake and the conversation has finally made its way to the nation state policy levels.

Operational Risk Management (ORM) will remain a key factor in decision points for the enterprise, the consumer and the operators of critical infrastructure across the globe.

Lets work on keeping the human factor in the loop as automation continues to give us a false sense of security and safety...

New Vision: Security Operations Center and CIU...

Flashback over 8 years ago when there was a convergence of thinking about the topic of a "Defensible Standard of Care" going on in the industry.

The key Operational Risk Management news from the 2011 RSA Conference was coming in, yet there were inside sources who still needed to be interviewed. What did they think was the most brilliant presentation or idea(s) presented?

This particular release caught some eyes as it addressed much of the thinking on the latest evolution of the Security Operations Center (SOC).  How much of this is still relevant today:

New Vision for Security Operations: Six Core Elements

The vision includes six core elements and prescriptive guidance for how to incorporate these elements into existing security operations. These elements include:

• Risk planning: The new SOC will take a more information-centric approach to security risk planning and invest in understanding which organizational assets are highly valuable and essential to protect. With priorities based on GRC policies, security teams need to conduct risk assessments that focus on the “crown jewels” of the enterprise.
• Attack modeling: Understanding attack modeling in a complex environment requires determining which systems, people and processes have access to valuable information. Once the threat surface is modeled, organizations can then determine potential attack vectors and examine defense steps to isolate compromised access points efficiently and quickly. RSA® Laboratories has developed theoretical models based on known APT techniques and employed game theory principles to identify the most efficient means of severing an attack path and optimize defense costs.
• Virtualized environments: Virtualization will be a core capability of tomorrow's SOC – delivering a range of security benefits. For example, organizations can "sandbox" e-mail, attachments and URLs suspected of harboring malware. Anything suspicious can be launched in an isolated hypervisor and the virtual machine can be cut off from the rest of the system.
• Self- learning, predictive analysis: To remain relevant in tomorrow's IT environment, a SOC will need to truly integrate compliance monitoring and risk management. The system should continually monitor the environment to identify typical states which can then be applied to identify problematic patterns early. Statistic-based predictive modeling will be able to help correlate various alerts. Developing such a system will require real-time behavior analysis innovations, although some of these elements are available today.
• Automated, risk-based decision systems: A key differentiator of a more intelligent SOC will be its ability to assess risks instantly and vary responses accordingly. Similar to risk-based authentication, the SOC will employ predictive analytics to find high-risk events and then automatically initiate remediation activities. The prospect of dynamic typography is one of the most exciting areas of this type of systems automation for the cloud. To implement an APT, an attacker must understand network mapping and be able to model it. In response to this, organizations can remap their entire network infrastructure to disrupt an attacker’s reconnaissance efforts. This is akin to physically rearranging a city at frequent intervals – and the entire process can be automated so that links between systems stay intact and dependencies are handled without human intervention.
• Continual improvement through forensic analyses and community learning: Although forensic analysis can be resource-intensive, it is an imperative element of a SOC and key to mitigating the impact of subsequent attacks. Virtualized environments can provide snapshots of the IT environment at the time of the security event providing useful information if detection of the attack was delayed. Having a way to share information about attack patterns will be the future of the SOC. This concept should be embraced in order to exchange threat information within respective industries and better predict the path of the APT and thereby determine countermeasures.

The evolution of the SOC in your enterprise may start in some unconventional places. Who is it in your organization that is responsible for the loss of corporate assets?

Who in your company is the one who determines what items are counted as losses to the bottom line?

Who does the enterprise look to when the crisis hits and people are looking for answers in minutes, not hours, or days?

Who picks up the phone to answer the call from the local FBI Field Office?

These may not be the people you think of in the CIO's office or IT department. These people however need to be part of the combined Security Operations Center solution in the company.

The Advanced Persistent Threat (APT) now requires the intersection of prudent strategy from the business leadership, the accounting or finance leadership and the risk management leadership.

If the CIO is looked upon as the key executive running a "Utility" inside the enterprise, think again.

This blog has discussed the "Corporate Intelligence Unit" in years past :

Beyond the utilization of threat assessment or management teams, enterprises are going to the next level in creating a "Corporate Intelligence Unit" (CIU). The CIU is providing the "Strategic Insight" framework and assisting the organization in "Achieving a Defensible Standard of Care."

The framework elements that encompass policy, legal, privacy, governance, litigation, security, incidents and safety surround the CIU. It includes with effective processes and procedures that provides a push / pull of information flow. Application of the correct tools, software systems and controls adds to the overall milestone of what many corporate risk managers already understand.

The best way in most cases to defend against an insider attack and prevent an insider incident is to continuously help identify the source of the incident, the person(s) responsible and to correlate information on other peers that may have been impacted by the same incident or modus operandi of the subject. "Connecting The Dots" with others in the same company or with industry sector partners, increases the overall resilience factor and hardens the vulnerabilities that are all too often being exploited for months if not years.

In retrospect, you can be more effective investigating and collecting evidence in your company to gain a "DecisionAdvantage". To pursue civil or criminal recovery of losses from these insider incidents, you may not go to law enforcement, but it's likely they will come to you once they get a whistle blower report, catch the attacker and/or they have the evidence that you were a victim.

How your organization pulls together the right people to staff and operate your "CIU" is going to depend on your culture, funding and current state of the threat.

BALTIMORE—Sean Gallagher - 6/5/2019, 9:25 AM
It has been a month since the City of Baltimore's networks were brought to a standstill by ransomware. On Tuesday, Mayor Bernard "Jack" Young and his cabinet briefed press on the status of the cleanup, which the city's director of finance has estimated will cost Baltimore $10 million—not including $8 million lost because of deferred or lost revenue while the city was unable to process payments. The recovery remains in its early stages, with less than a third of city employees issued new log-in credentials thus far and many city business functions restricted to paper-based workarounds.

Here is another thought. A thorough review of the current funding, staffing and strategy of a SOC or CIU in the enterprise, may even become a priority at the next "Board of Directors" meeting.

Digital Trust: Transparency in a World of Cyber War...

"British police arrested Wikileaks founder Julian Assange on Thursday. He had been hiding in the Ecuadorian Embassy in London since 2012 and was arrested after the Ecuadorian government invited the Metropolitan Police Service into the embassy to remove him. Assange was initially arrested for jumping bail in 2012, but the Metropolitan Police Service subsequently announced that he had been "further arrested on behalf of the United States authorities."

After Assange's arrest, the US Justice Department unsealed its indictment against him. The indictment focuses on Assange's role in helping Chelsea Manning steal classified information from the US military."  Wikileaks — Julian Assange arrested, charged with conspiracy to hack US computers Assange had been holed up in the Ecuadorian Embassy in London since 2012.  Timothy B. Lee - 4/11/2019, 7:05 AM


Someday in the future, there will be a documentary on the timeline and journey of Julian Assange, beyond what has already been produced about his life and his behavior.

It is going to be years before the U.K. legal system finishes the process it has demonstrated in the past with people and issues such as this one.

Yet transparency remains an important topic here.  Whether you are arguing for greater disclosure on what is going on inside government or within the R&D practices of a Global Fortune 1000 public company, transparent communications to the public and shareholders is vital.

The justice systems will finally have the opportunity to produce the information, that will allow every world citizen, to read about the true facts in the Assange case.

Meanwhile, the use of sophisticated exploit tools by nation states and rogue non-state actors continues to disrupt our international e-commerce.  Many variations of these tools are now in the wild as a result of the actions of Wikileaks and are being utilized in nefarious ways.  Here is just one example:

Canadian Police Raid ‘Orcus RAT’ Author
"Canadian police last week raided the residence of a Toronto software developer behind “Orcus RAT,” a product that’s been marketed on underground forums and used in countless malware attacks since its creation in 2015. Its author maintains Orcus is a legitimate Remote Administration Tool that is merely being abused, but security experts say it includes multiple features more typically seen in malware known as a Remote Access Trojan." Krebs on Security

This latest phase of legal justice is about a digital world that exists underground and unknown to the naive "John Q. Citizen" on the street.  Brian Krebs own transition from journalism at the Washington Post to creating his own blog, is only part of this transparency topic.  The Dark Web and all that is comprised of it, is still growing exponentially.

Remember that only about 4-5% of the world wide web (WWW) is what you are seeing in the searchable "Google" Internet.  The other 95% of the Deep and Dark web, is indeed another virtual world.

The international entrepreneur today who has that new great idea, product or service will be operating on the Internet and the World Wide Web.  No different from years before the Internet when you set up your office/business on Mainstreet, in the skyscraper or in the Mall, yet now your reach is instantaneously global.  Your inventory display, banking, accounting, order entry, distribution and delivery is done with software and global communications networks.

Today and since the dawn of the Internet, every new online entrepreneur has a digital spectrum of Operational Risks that must be addressed as part of your daily business.  Those digital trust factors have created new dimensions of risk and resilience strategies, to counter the size and scope of the expanding cyber crime and terrorism enterprises.

So what?

There are several analogies that could be used here to illustrate the issues associated with selling cyber weapons online or the theft and distribution of those digital weapons in our modern society.  Yet the truth is, international commerce is here to stay and it will require new and more rapid action by business and governments.

Simultaneously, the future of our digital trust and the lack of manpower and enforcement resources is spelled out daily in the public press.  How many times have we heard, that there is a shortage of Cyber Security and Risk professionals in the commercial and government workforce?  There is a reason for this.

Transparency of reporting is vital for the public, so they can make more informed decisions.

Balancing the nightly television news with politics, business earnings reports, weather events and the reality of our expanding "Cyber World War," will soon become the new normal...

Operational Threat Matrix: The Mission Ready Many...

"Five years after the release of the Framework for Improving Critical Infrastructure Cybersecurity, organizations across all sectors of the economy are creatively deploying this voluntary approach to better management of cybersecurity-related risks. The U.S. Department of Commerce’s National Institute of Standards and Technology (NIST) issued what is now widely known simply as the “NIST Cybersecurity Framework” on February 12, 2014."

Measuring an incident first requires defining a taxonomy on what an "incident is" and what an "incident is not". In other words, how can you measure something that has not been sufficiently defined in your organization. How do you know when an incident has occurred?

Our corporate assets are under attack by a continuous barrage of new laws, new employees, new competitors and new exploits.

Business survival in the next decade will require a more effective and robust risk strategy to deter, detect and defend against a myriad of new threats to the organization.

Modern day attackers include hackers, spies, terrorists, corporate raiders, professional criminals, vandals and voyeurs. Simply said, these attackers use tools to exploit vulnerabilities. They create an action on a target that produces an unauthorized result. They do this to obtain their objective.

The Mission

The organization shall develop, implement, maintain and continually improve a documented operational risk management system:

• Identify a method of risk assessment that is suited for the organizations business assets to be protected, regulatory requirements and corporate governance guidelines. 
• Identify the assets and the owners of these assets. Identify the threats to those assets.
• Identify the vulnerabilities that might be exploited by the threats.
• Identify the impacts that losses of confidentiality, integrity and availability may have on the assets.

Assess the risks. Identify and evaluate options for the treatment of risks. Select control objectives and controls for treatment of risks. Implement and operate the system. Monitor and review the system. Maintain and improve the system.

The Take Away

While you were in the Board of Directors meeting, your Operational Risk Profile changed. When you were asleep last night it changed again. The people, processes, systems and external events are interacting to create a new and dynamic threat matrix for your organization.

Who is responsible for Operational Risk Management in your business? Everyone is. You see, if everyone in the organization was able to understand and perform the mission flawlessly, then the business could stay in constant control of how much incidents are costing the enterprise.

Only a guarded few understand the mission of operational risk management in your company. Only a guarded few can do it flawlessly.

If you want to protect your corporate assets better than you do today, then turn those guarded few into the mission ready many.

International Risk: Cyberwarfare Rules of Engagement...

When the financial private sector views the actions of government, in terms of regulation and compliance, it is often considered another risk to its operations. Why? More rules and the need to report on oversight, creates new obstacles to other more valuable revenue producing activities.

CDOs were a focus in the movie "The Big Short" and is an example of a financial product that explains why the government regulation mechanisms continue to exist. Yet the implementation of internal controls, to thwart the embezzlement of funds or the theft of proprietary intellectual secrets, is something that is encouraged and welcomed in the banking community. This paradox is something that continues to occur in the cyber risk management domain.

The dawn of Internet banking, spawned many of the Operational Risks associated with using public networks for our various banking transactions. The oversight of cyber risk management in the financial institution, is still a major challenge yet becoming more mature by the day.

Government is more effectively learning how to apply the right oversight with private sector institutions, through the use of International Standards such as ISO 27001 and NIST best practices to protect Critical Infrastructure.

The newest strategies for cyber risk management have been a robust topic of global conversation. New reports on the origin of state sponsored hacking and cyber crime data breach incidents, has produced some new theories on how to address these international Operational Risks:

"Deadly force against organized hackers could be justified under international law, according to a document created by a panel of legal and cyber warfare experts. Use of lethal force on those behind a cyberattack on a nation would be legal if the virtual attack meets criteria similar to those currently accepted for real-world warfare, said Michael N. Schmitt, chairman of the International Law Department at the U.S. Naval War College in Newport, R.I. Schmitt is the editor of the Tallinn Manual on the International Law Applicable to Cyber Warfare, a 300-page book put together by a score of experts at the request of NATO and published by Cambridge University Press."

Even the most knowledgeable cyber experts, are at odds over the topic of "Active Defense" and the use of asymmetric cyber force, to retaliate against a so called attack or denial of service. A kinetic response is much more clear, based upon the source or attribution evidence of the attack. In the cyber domain, the word "Attribute" has some very interesting ramifications.

The State-of-Play will remain the same and for good reason. The governments of the world do not have issue with each other performing reciprocal cyber espionage. This practice is just a new version of intelligence collection and the next manifestation of Tinker Tailor Soldier Spy. However, if there should be any visible or kinetic damage to infrastructure, then the Tallinn Manual will be a vital resource for all. The question remains, what is a cyberattack? Jim Lewis said over five years ago:

“Cyberattack” is one of the most misused terms in the discussion of Chinese hackers. With very few exceptions, China has not used force against the United States in cyberspace. What it has been doing is spying. And spying, cyber or otherwise, is not an attack or grounds for war, even if military units are the spies. Spying isn’t even a crime under international law, and it wouldn’t be in Washington’s interest to make it so."

  Cyberwarfare Rules of Engagement remains a significant international Operational Risk...

InTP: Insider Threat Via Critical Infrastructure...

The private sector organizations of the United States are vital to the protection and security of the Homeland.  The private sector owns a majority of our assets and Critical Infrastructure Protection (CIP) remains a priority as a result of the latest asymmetric threats.  Securing Critical Infrastructure sectors includes:

• Chemical:
• Commercial Facilities:
• Communications:
• Critical Manufacturing:
• Dams:
• Defense Industrial Base:
• Emergency Services:
• Energy:
• Financial Services:
• Food and Agriculture:
• Government Facilities:
• Healthcare and Public Health:
• Information Technology:
• Nuclear Reactors, Materials, and Waste:
• Transportation Systems:
• Water and Wastewater Systems:

The National Strategy to Secure Cyberspace, emphasizes the importance of public/private partnerships in securing these critical infrastructures and improving national cyber security.

Similarly, one focus of the Department of Homeland Security is enhancing protection for critical infrastructure and networks by promoting working relationships between the government and private industry.

The federal government has acknowledged that these relations are vital because most of America’s critical infrastructure is privately held.  Further, the networks of our global super-infrastructure are tightly “coupled”—so tightly interconnected, that is, that any change in one has a nearly instantaneous effect on the others.

Attacking one network is like knocking over the first domino in a series: it leads to cascades of failure through a variety of connected networks, faster than most human managers can respond.

We realize that there are many facets of CIP, yet where should we be allocating resources?  The vigilance within our organizations has not changed and is based upon previous studies done by CERT and the US Secret Service:

"A system administrator, angered by his diminished role in a thriving defense manufacturing firm whose computer network he alone had developed and managed, centralized the software that supported the company’s manufacturing processes on a single server, and then intimidated a coworker into giving him the only backup for that software. Following the system administrator’s termination for inappropriate and abusive treatment of his coworkers, a logic bomb previously planted by the insider detonated, deleting the only remaining copy of the critical software from the company’s server. The company estimated the cost of damage in excess of $10 million, which led to the layoff of some 80 employees." U.S Secret Service and CERT Coordination Center/SEI Insider Threat Study: Computer System Sabotage in Critical Infrastructure Sectors

Insider Characteristics

The majority of the insiders were former employees.

• At the time of the incident, 59% of the insiders were former employees or contractors of the affected organizations and 41% were current employees or contractors.

• The former employees or contractors left their positions for a variety of reasons. These included the insiders being fired (48%), resigning (38%), and being laid off (7%).

Most insiders were either previously or currently employed full-time in a technical position within the organization.

• Most of the insiders (77%) were full-time employees of the affected organizations, either before or during the incidents. Eight percent of the insiders worked part-time, and an additional 8% had been hired as contractors or consultants. Two (4%) of the insiders worked as temporary employees, and one (2%) was hired as a subcontractor.

• Eighty-six percent of the insiders were employed in technical positions, which included system administrators (38%), programmers (21%), engineers (14%), and IT specialists (14%). Of the insiders not holding technical positions, 10% were employed in a professional position, which included, among others, insiders employed as editors, managers, and auditors. An additional two insiders (4%) worked in service positions, both of whom worked as customer service representatives.

Making sure that you have a robust workplace awareness program is yet one key component in addressing the "Insider Threat" and our resilience.

More importantly, the timing may have been the perfect launch point for other malfeasance from non-state actors who lie in their "Lone Wolf" mode, waiting to strike.

And while the scenario could be well contained, the timing could create opportunities for the "Black Swan" outlier inside your enterprise.

It's never to early to plan for the unimaginable, all happening in the same geography and the same time frame.  Revisit your "Insider Threat Program" (InTP) and Critical Infrastructure Resilience today...

Unthinkable: Adapting in New World Disorder...

Will 2018 bring more data breaches, lost laptops and insider threats than 2017?  This is why CSO's, CPO's and corporate General Counsels have their teams working overtime.

When the enemy is increasing their attacks, utilizing new strategies and leveraging the existing base of compromised organizational intellectual and data assets, the future horizon becomes ever more clear. 

The statistics don't lie.  1579 documented Data Breaches occurred in 2017. Up 44.7% according to reports by the Identity Theft Resource Center (ITRC) compared to the previous year.  It is the new normal.

The Insider Threat Program (InTP) however, remains a key focus for Operational Risk Management (ORM) professionals because human behaviors are exaggerated during periods of stress, fear and uncertainty. This means that people who may have never considered doing something to jeopardize their reputations, may now be up against a wall.

When there is no obvious exit and no way out, people will do extraordinary things to get ahead, beat the odds and hedge their own risk portfolio of life.

In Joshua Cooper Ramo's book "The Age of the Unthinkable", "Why the New World Disorder Constantly Surprises Us and What We Can Do About It" the author discusses the concept of Deep Security. His analogy of how to think about "Deep Security" is the biological immune system:

"A reactive instinct for identifying dangers, adapting to deal with them, and then moving to control and contain the risk they present."

The key word in Ramo's writing is "Adapt".  Being Adaptive.  However, prior to this there are two other very vital words that we feel are even more imperative. Instinct. Identifying. In other words, Proactive Intuition.

Ask any savvy investigator on how she solved the case and you may hear just that, "I had a hunch."

Talk with a Chief Privacy Officer in any Global 500 company.  You might get them to admit they have a sense that their organization will be the target of an "Insider data breach" incident in the coming year or two.

Do you remember signing off on reading and your acceptance of the employee handbook?  When did your organization last make changes to the Corporate Employee policies?  We would start with the updates to the following sections:

• MEDIA CONTACT
• SOCIAL MEDIA POLICY
• REMOTE ACCESS POLICY
• E-MAIL, VOICE MAIL AND COMPUTER NETWORK SYSTEM PRIVACY
• (YOUR ORGANIZATION) RIGHT TO ACCESS INFORMATION
• SYSTEMS USE RESTRICTED TO COMPANY BUSINESS
• FORBIDDEN CONTENT
• PASSWORD SECURITY AND INTEGRITY
• INTERNET ACCEPTABLE USE POLICY
• POLICY ON USE OF SOFTWARE
• COMPANY PROPERTY
• PROTECTION OF TRADE SECRETS/NON-DISCLOSURE OF COMPANY INFORMATION 

Due to the increasing complexity of IT systems, cloud computing, data networks and the hundreds or thousands of laptops and mobile devices circling the globe with company executives and employees is enough to predict that a major breach will occur.

Being adaptive and having proactive intuition in the modern enterprise does not come natural. You have to work at it and it requires a substantial investment in time and resources to make it work effectively.  Proactive Intuition.

Once you realize that all of the controls, technology and physical security are not going to keep you out of harms way, you are well on your way to reaching the clairvoyance of "The Age of the Unthinkable."

Critical Infrastructure: "Known Vulnerabilities" in Your Enterprise...

What are the known vulnerabilities in your enterprise architecture?  We will come back to this question.

Asymmetric Warfare across the globe spans a digital Internetwork that has it's roots fostered in openness and with little regulation.  We are in many instances within real possibilities of significant digital systems failures.  Here is a just small window into that battlefield.

Operational Risk Management (ORM), is a mature discipline that you and your organization shall embrace, study, expand and continuously support.  One facet of Operational Risk, the Information Technology (IT) systems in your enterprise, is not part of an evolution any longer.  It has become a pervasive and mobile social revolution, that is now accelerating beyond your comprehension.

Let's put it another way.  Known but unmitigated vulnerabilities, will likely be the origin of your demise, failure, damage, ruin and loss of precious assets.  Why do you let it continue?

You and your organization are on the edge, operating each day with peoples lives, reputations and Personal Identifiable Information (PII) at stake and even the livelihood of the enterprise itself.

Whether that is your family, business, state or even your country, you can do something more to address your known vulnerabilities.  Do you know who, what and where they are in your enterprise?

When you hear the name "Equifax" today, what do you think?  Data security breach, correct?  What about these organizations:

• Whole Foods Market Services, Inc.
• Discover Financial Services
• Transamerica
• Hyatt Hotels
• Northwestern Mutual Life Insurance Company
• Wells Fargo Advisors
• Sprint
• Massachusetts Mutual Life Insurance Company
• Sharp Memorial Hospital
• Virgin America
• The Neiman Marcus Group
• Keller Williams Realty, Inc.
• Club Quarters Hotels
• Hard Rock International
• Four Seasons Hotels Limited
• BMO Harris Bank NA
• Bank of the West
• Gannett Company, Inc.

These are all well known companies, who have reported data security breaches by law, to the State of California, over the past 6 months.  There are dozens more of other organizations who are not large, well known brand names such as these.  Some are as a result of the Equifax breach and organizations who were using Equifax product solutions internally.  Now multiply this by 50 states.

So what?

Our Critical Infrastructure(s) in the United States are something we just take for granted.  Bank ATM's on every corner, bridges across bays and rivers, trains and planes departing from even small cities, trauma hospitals, massive hotels and supermarkets, fiber communications and LTE wireless network connectivity almost everywhere.

Let's come back to where we started.  What are the "Known Vulnerabilities" in your enterprise architecture?  Why are you so certain, that your adversaries are not currently inside your network?

The resilience modernization of your particular enterprise, is going to be expensive.  Mostly, because it has been patched and poorly integrated for a decade or more.  In some cases, simply because your adversaries and competition are more stealthy than you are.  Faster than you are.  Smarter than you are.  Laying in wait.

So what are you going to do about it?  In your home, business, city, state, or country and beyond?

"As a highly connected nation, the United States is especially dependent on a globally secure and resilient internet and must work with allies and other partners toward maintaining the policy set forth in this section. Within 45 days of the date of this order, (May 11, 2017) the Secretary of State, the Secretary of the Treasury, the Secretary of Defense, the Secretary of Commerce, and the Secretary of Homeland Security, in coordination with the Attorney General and the Director of the Federal Bureau of Investigation, shall submit reports to the President on their international cybersecurity priorities, including those concerning investigation, attribution, cyber threat information sharing, response, capacity building, and cooperation."   Presidential Executive Order on Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure 

You are going to find, repair and replace your known vulnerabilities.  Then repeat.  When you think you are finished, you can begin the next project, on your UNKNOWN vulnerabilities.

RSA 2017: In Search of the Truth...

The 2017 RSA Conference is set to launch this week in San Francisco.  What is true?  The state of asymmetric warfare across the globe is pervasive and nation states have been negotiating new rules of the game.

As you descend into the keynote sessions, absorb the content from your favorite track or walk the overwhelmed Expo halls, pause for a moment.  Stop, look around and look at what you see.  The ICT (Information, Communications & Technology) ecosystem is no longer a vertical.

The horizontal intrusion of smart devices, IoT and the rapid mobility sensor markets have created a juggernaut ecosystem.  The startup communities across just the United States landscape have entrepreneurs sharing and automating parts of your daily life once thought unthinkable.

The Techstars of the next generation of commerce, understand the platform better than ever.  Meanwhile, the same ambitious individuals with so much creativity are simultaneously in a battle for funding and market share.

It is a new generation of inventions that are AI-driven by Voice Recognition that are becoming the foundation for getting the information we need now; this second, not in a few minutes or even an hour from now.  We want it now and we trust that it will be true.

There are some major themes that you will see and pick-up on while attending RSA this year.  Some established companies with a tenured legacy in the industry are even making a pivot.  Look for how they are starting to craft the new narratives that will consume the marketing airwaves.

Expect plenty of talk about the ongoing ransomware scourge and threats against the Internet of Things (IoT) during RSA Conference 2017, which begins a week from today at the Moscone Center in San Francisco.

The conference will include 15 keynotes, including talks by RSA CTO Zulfikar Ramzan, Microsoft president Brad Smith, and Alphabet CEO Eric Schmidt. The popular cryptographers’ panel will feature Whitfield Diffie (of Diffie-Hellman-Merkle), Ronald Rivest and Adi Shamir (the R and S in RSA encryption), and Susan Landau (creator of Landau’s Algorithm). Paul Kocher, who figured out timing attacks against various RSA and DHM implementations, will moderate the panel.

With this in mind, now start to realize the places that have been behind the innovation curve.  The small and even mega markets, that have been slow to invent or work in such austere environments the tech has not reached it yet.  Start your new journey into these places to see how you can contribute, how you will be able to make a difference:

The Defense Innovation Initiative (DII)
Exploring Ideas to Better Identify the “Art of the Possible” for National Security

The Defense Innovation Initiative (DII) is a Department-wide initiative to pursue innovative ways to sustain and advance the capabilities of the “force of the future.” The U.S. changed the security landscape in the 1970s and 1980s with networked precision strike, stealth and surveillance for conventional forces. Through the DII, the Department will identify a third offset strategy that puts the competitive advantage firmly in the hands of American power projection over the coming decades.

The future of RSA and our way of life for our interconnected nations, economies and daily consumption of the truth is at stake.  We do have the ability to better cooperate, collaborate and communicate our paths forward.  Yet it begins with a conversation in person, face-to-face to establish the emotional and behavioral ties to trustworthiness.

Have a wonderful week in San Francisco...