Close the barn door… the horse is out!

It never fails. Information security controls are immediately put into place AFTER a significant security incident has happened.  This is true even when these controls are reasonable to have in place and could have prevented the incident from happening at all.   Often, decisions made after an incident are knee-jerk reactions rather than business-minded protections.

As a case in point, the Department of Defense issued a new ban on removable media being used on classified machines in response to the WikiLeaks release of diplomatic cables.  Completely reactive.  The point here isn’t the effectiveness of the control but the timing.

For those who haven’t followed the WikiLeaks drama, here is a tidbit taken from a December 10, 2010 CNN article that can be applied to many organizations.

“Pfc. Bradley Manning says he downloaded hundreds of thousands of files from SIPRNET to a CD marked “Lady Gaga” before giving the files to WikiLeaks.”

Do you have a Private Manning in your organization who has access to sensitive information?  Can he easily take that information out of your environment and sell it to the highest bidder?  Why not consider that risk and address it before it becomes an issue?

The culprit often lies in the attitude of executive leadership.   How often have you heard the following?

  • “We’ve been doing things this way for years and haven’t had a breach.”  (that you know of)
  • “Show me the hard dollar return on investment before I sign off on these security thingies.”  (BTW, since most security implementations aren’t revenue generating, a ROI will always be zero.)
  • “It’s not convenient.”

These excuses need to be replaced with a desire to take ownership of information you have.  The focus needs to be on protecting your intellectual property and maintaining competitive advantage.  It should examine the risks to information and appropriate measures to reduce risk without impacting the functions of the business.

Controls don’t have to be expensive or fancy.  They just need to be effective.  Understand and take control of your information before an incident forces rushed decisions that impact your ability to conduct business.

Fail to plan, plan to fail… incident response preparation

Consider this:  A review of an application or database that processes and stores customer information, including personally identifiable information, has been compromised.  What are you going to do?

Many organizations fail to plan for a compromise and unfortunately, often exacerbate the damage while attempting an “on the fly” response to an incident.  The absolute worst time to figure out what you should be doing is in the middle of an incident.  Having a plan and preparation is key.

Plans often fail to include:

  • Explicit authority for the primary incident handler to take decisive action to “stop the bleeding” and prevent further escalation of the incident.   Decision-by-committee with endless debate often leads to delayed action that increases financial and reputation damage.
  • A backup (or more) for the primary incident handler in case they are not available.  The backup should fully understand the role and be capable of making decisions in critical situations.
  • The inclusion of more than technical resources for the incident response team.  HR, Legal, and the PIO are often left out but essential.
  • Templates for press releases and notifications.  Writing your first draft during an incident is a mistake.
  • A communication plan for the team.  If your e-mail system is compromised, sending e-mail to your team about your response may not be the best option.
  • Checklists to help keep a response on track when the heat is on.

When developing the plan, consider the potential scenarios you may face and plan for them.  Different scenarios may require different responses so it’s best to have thought some of these through before they happen.  Malware outbreak; denial of service; illegal material on an employee PC; lost or stolen laptop; compromised system; or accidental disclosure to name a few.

Last, the first time you try out the plan shouldn’t be during an actual incident.  Practice builds confidence for the incident response team and shines a light on gaps in your plan that may need to be addressed.  A calm response to an incident is more likely when you can say “yeah, we’ve practiced this… let’s get to work” versus “oh man… what do we do now”.

Prior Proper Planning Prevents Piss Poor Performance.

Be prepared and hope you never need to use your plan.

Lawsuit, breaches and bashing… oh my!

Though it seems obvious that corporations have an obligation to protect the sensitive information they use for business it still amazes me that corporate behavior in this regard is still quite dismissive.  Lawsuits and public embarrassment seem to be the only catalyst for action for many organizations.  That is kind of sad.  Not only is information not being adequately protected by companies are ill-prepared for dealing with crisis.

As a recent example, in Connecticut, the Attorney General is suing Health Net for failure to protect medical records of over 450,000 patients.  The information was stored on a portable disk drive that “disappeared” from an office.   The information on that drive wasn’t encrypted.  Add to this the fact that the organization took six months to send notification to Connecticut residents whose information may have been compromised.  This is a failure on many levels but certainly a failure in leadership and crisis management.

What should we be asking ourselves?

  1. We need to understand the information that we use and how we use it.  How is information accessed, transmitted and stored?  What is our legal (and moral) obligation to protect this information?
  2. There is no such thing as 100% security.  If/when there is a breach, are we prepared to act swiftly and appropriately to mitigate the damage for our customers and ourselves?
  3. Do we have a communication plan in place so that we can effectively provide notification internally and externally?
  4. When examining other breaches, do we practice the same way?  Are we at risk of compromise?  How do we change this?

Part of information security isn’t just applying best practices and being vigilent.  Unfortunately, there is a need to be prepared for an incident or crisis.  I believe that one of the best recoveries from a crisis has to be credited to Tylenol in 1982.  Another example would be the handling of a Southwest airlines crash at Midway airport in 2005.  Neither one of these are information security incidents but certainly the lessons learned from their handling of a major crisis can be applied.  Just do a search and look at the response from a corporate point of view.  It’s really quite educational.

I hope we reach a time when breaches, lawsuits and embarrassment are not the motivators for applying sound information security practices and incident response plans.  I’m afraid I may be waiting for awhile.