12 steps to building a top-notch vulnerability management program

Along with my peer CISOs, I recently added my $0.02 to a CSO Online article on how to get the best results out of an enterprise vulnerability management program.

I particularly wanted to zoom in on key performance indicators (KPIs), given this is an area where many security professionals don’t focus enough of their attention.

“He says organizations could use any of the commonly used key performance indicators—such as percentage of critical vulnerabilities remediated on time and percentage of critical vulnerabilities not remediated on time—to measure current state and track improvement over time.

Other KPIs to use could include percentage of assets inventoried, time to detect, mean time to repair, number of incidents due to vulnerabilities, vulnerability re-open rate and number of exceptions granted.”

What are some of your key focus areas?

Don’t get your wires crossed – The evolution of cyber risk and why more companies are considering captives

A captive is a licensed insurance company fully owned and controlled by the insured parties – a type of “self-insurance.”

Captives are essentially an alternative for organizations to retain and finance cyber risk via actuarial-determined premiums to be paid from the parent company to the captive. They’re becoming more popular due to an increasingly tough cyber insurance market.

Many thanks to Captive Insurance Times and to the amazing Rebecca Delaney for featuring me alongside other industry professionals on discussing this important topic.

The feature can be found on pages 18-22, and is now available to read in the latest online issue at this link: https://bit.ly/3KMnX8j

Ransomware has “changed the game” of cyber insurance

I recently made a presentation on ransomware and cyber insurance at the Barbados Risk and Insurance Management (BRIM) conference.

Many thanks to the Captive Insurance Times’ reporter Rebecca Delaney for so excellently capturing my session. In the intro section, she wrote:

“Cyber insurance is not an exhaustive replacement for robust security capabilities, warns Niel Harper […] He explained that ransomware is so disruptive because of the extensive network of paid services it has spawned, such as access brokers, malware packing, phishing kits, hosting and infrastructure, anonymity and encryption, and hardware for sale… In addition, distribution networks include social network spam, instant messaging spam, exploit kit development, spam email distribution, and traffic distribution systems.”

The full article can be found at: https://bit.ly/3MMs71t

12 CISO Resolutions for 2022

At the beginning of January, my peers and I shared our security and privacy resolutions for 2022 with CSO Online. The full article can be found here on their website.

However, I wanted to further elaborate here on my plans for privacy and security across the enterprise this year.

I have a couple of resolutions for the upcoming year. Firstly, I want to focus more energy and resources on privacy and data. My second resolution is to refine and enhance the control framework around third-party risk management. In third place, but definitely not of lesser importance, is improving my enterprise’s protection against ransomware. The next resolution on my list is continuing to advocate the importance of email security to every business leader I meet; I am specifically referring to Domain-based Message Authentication, Reporting and Conformance (DMARC), DomainKeys Identified Mail (DKIM), and Sender Policy Framework (SPF). Finally, I want to gain more control over ‘shadow IT.’

With regards to privacy and data, it’s not only about responding to growing demands from GDPR and other national and regional privacy regulations. It’s just good practice to get a solid handle on where business-critical data assets reside and how this data moves inside and outside of your organization, ensuring that you have adequate and effective controls to prevent data leakage and privacy rights violations (and of course avoid fines). Over 55% of data breaches are now caused by a third-party, so ensuring that I have an efficient, standardized approach for assessing third party risk will most definitely reduce privacy and security exposures from vendors, services providers and even contractors. Ransomware continues to increase in terms of prevalence and severity, so a strong prevention and response strategy is key to operational, financial, and reputation risk reduction. Email security in some form has been around since the early 2000s, and yet less than 35% of companies have implemented DMARC, DKIM and SPF. The value of these technologies in combating brand impersonation, reputation damage, and phishing attacks can’t be emphasized enough. Shadow IT in basic terms means that you’ve lost control and visibility into your IT environment, and if you can’t account for IT assets, you can’t protect them.

My approach to privacy and data governance is premised on user/cultural awareness, end-to-end risk assessment, detailed records of processing activities, effective incident response, strong security controls, and building capabilities to integrate ‘privacy by design’into the CI/CD. I plan to move away from using spreadsheets and manual processes to manage third-party risks, and instead leverage best-of-breed software tools that analyze, track, and minimize risks arising from supply chain exposures. With ransomware, my objective is to incorporate identity and access governance, multi-factor authentication (MFA), advanced honeypots, endpoint detection and response (EDR), and multi-tiered backups (3-2-1 strategy) into a cohesive ransomware prevention strategy. As it pertains to email security, my focus is less about my own shop (we’re already there) and more about assisting my peers and small to medium enterprises (SMEs) in properly setting up DMARC, DKIM, and SPF. Preventing shadow IT begins with enhancing usability and eliminating risky workarounds by removing the hindrances that foster them (i.e., being more agile in addressing discrete stakeholder requirements in close collaboration with the IT function).

The UK seeks to enforce tougher standards on MSPs

The UK government is proposing new regulations to strengthen cyber resilience in the private sector. Their intention is to expand cybersecurity rules for critical infrastructure (CI) operators to include managed service providers (MSPs), more stringent breach notification requirements, and legislation to establish the UK Cyber Security Council as the standards development organization for the cybersecurity profession. This is a welcomed development, but more details about implementation and enforcement are needed.

MSPs are deeply integrated into the supply chains of several businesses, especially those organisations categorised as CI providers. They not only have privileged access to their customer’s infrastructure and applications, but also to the personal data of millions of citizens. A single breach of a MSP can potentially allow threat actors to compromise hundreds, even thousands of organisations. Additionally, the accompanying fallout from personal data leakage would have a serious impact in terms of impersonation, fraud, and other identity-based crimes. Poor risk management practises and weak security controls in MSPs can have dire consequences to national security and the economic prosperity of the UK.

Better cyber incident reporting, especially where mandated by law, has several positive effects. For one, it ensures that regulations keep pace with the evolving threat landscape to better protect consumers by allowing them to respond quicker to leaks of their information. It also provides certain guarantees that law enforcement agencies (LEAs) receive timely information to better model threats, mitigate the risks, prevent or lessen harm from breaches, and take action to reduce the likelihood of future attacks.

At a macro level, the new regulations are focused on strengthening the country’s cyber-resilience in response to growing supply chain and critical infrastructure attacks – this is essentially a public safety matter. It can provide security to UK citizens against the negative impacts of attacks on critical infrastructure providers such as financial services, telecoms, energy, food & agriculture, defence, manufacturing, and others. It also protects businesses in these key industries where the incapacitation or destruction of their assets, networks and systems would have a paralysing effect on the UK’s national security, economic security, national public health or safety, or any combination thereof.

Cybersecurity is a risk management discipline, and improvements in the overall assessment of risks and development of effective risk responses leads to better security posture. For example, ransomware attacks are very much preventable, yet many businesses don’t invest the time or resources to understand their risks/exposures and implement relevant controls such as data recovery processes, isolated backups, encryption at rest, and routine backup testing. I believe these new regulations can most definitely enhance risk management capabilities in MSPs and other CI operators to counteract a broad range of cyber attacks, including ransomware.

It is imperative that companies develop stronger capabilities around risk management. For one, they need to view cyber risks as business risks and recognise that the impacts range from financial (loss of revenue or drop in share price) to operational (business disruption) to reputation (loss of customer and shareholder confidence) and ultimately regulatory (fines or other penalties). Consequently, they will need to embed a risk culture and build risk management capacity across their enterprises, or face punitive regulatory measures.

A shocking percentage of businesses routinely ignore growing cyber threats, thinking that “it won’t happen to them.” And this isn’t just small to medium enterprises (SMEs), but also large businesses across critical sectors. Several of these organisations don’t have a dedicated cybersecurity leader or functional information security department, refuse to invest in much needed controls and capabilities, and regularly hide breaches from staff, customers, and investors. Without specifically calling out any companies, there are more than enough examples of massive breaches at major businesses to validate my points. The price of failing to act is way too high, and the government would be negligent to not introduce these new regulations.

Why the humanitarian sector needs to make cybersecurity a priority

“In the not-too-distant past, international organizations (IOs) and non-governmental organizations (NGOs) working on humanitarian initiatives largely depended on landlines and fax machines to communicate and convey data back to their regional hubs or headquarters.

Now, like most businesses, NGOs and IOs have invested significant funds in information and communication technologies to enhance their crisis management capabilities. For example, better and faster decision-making is achieved through capturing and analysing demographic data to identify vulnerable groups, online surveys have proven critical for water, sanitation, and hygiene teams in the delivery of population health services, and biometric-enabled digital vouchers have been instrumental in reducing errors and fraud in the payment of traders.

These changes make humanitarian aid faster and more efficient. Picking up these digital tools helps save lives. However, digital transformation has also made IOs and NGOs enticing targets for cyber attacks by criminals, terrorists, and authoritarian regimes. The reasons for this range from the purely financial – people in crisis make easy targets for scams and theft – to the political – digital is becoming another avenue to attack a regime’s perceived enemies.”

I recently joined with the World Economic Forum’s Centre for Cybersecurity to author this piece for the Davos Agenda.

This article examines the cybersecurity threats being faced by international organizations (IOs) and non-governmental organizations (NGOs), outlines some key steps they should take to counteract these threats, and touches on what the private sector can do to support IOs and NGOs in responding to these risks & challenges.

You can read the full article on the World Economic Forum website.

Cloud Security Trends: What Is Cybersecurity Mesh?

“Have you heard of cybersecurity mesh?

Some are calling it one of the more notable trends for cloud security and today’s other cyber concerns. So, what is it, and how does it work? The technology stack is breaking down as more people use architectures based on micro-services.

They’re also using blockchain and other trust models to embrace an information-centric security model that works with distributed services (key to cloud security).”

I recently shared my perspectives on cybersecurity mesh with IBM Security Intelligence.

Check it out and let me know what you think!

Pandemic Democracy: COVID-19 And Election Management

Elections are large, social gatherings that involve masses of individuals and galvanise entire societies. No other national operation presents a similar degree of operational magnitude, legal and procedural complexity, and broad-based participation.

The COVID-19 pandemic has quickly disrupted elections, creating new pressures and challenges on how they are managed. The key public health threat associated with elections stems from the need for voters to cast their ballots in person, at a polling stations, most often on a single day. Caribbean nations are particularly impacted as they don’t generally support absentee voting, provisional balloting, early voting, or e-voting (in-person or online).

On January 9th, I participated in a Town Hall discussion hosted by the University of the West Indies – Cave Hill Campus.

The panel was predominantly made up of very experienced and highly capable election management professionals, with myself being the sole expert focusing on leveraging technology to guarantee the representativity and legitimacy of the democratic process. My contributions were specifically around the following areas:

  • Guaranteeing access to the voter registration list in a secure and privacy enabling manner
  • Ensuring speed and transparency in counting votes by moving to secure, electronic systems
  • Emergency planning in response to situations like national disasters and pandemics
  • Accommodation for hospitalised voters
  • Staffing electoral commissions with key IT and information security resources
  • The need for government investment in the digitalisation of elections

It was a very stimulating discussion, and I want to express my gratitude to the University of the West Indies for inviting me. Additionally, I want to thank the panelists and the moderators (Professor Cynthia Barrow-Giles and Dr. Dalano DaSouza) for sharing their ideas and insights.

Why the Barbados Election List Data Leak is Problematic – And How it Could Have Been Prevented

On 27 December 2021, the Prime Minister of Barbados Mia Amor Mottley scheduled a snap election for 19 January 2022.

On 29 December 2021, a full data dump of all eligible voters in the country was published by the Government of Barbados on the open Internet. This occurred largely because the Representation of the People Act 13(1) states “The [Electoral] Commission shall cause to be prepared and shall publish not later than the 31st day of January in every year a register of electors for each constituency and a register of foreign service electors entitled to vote at any election.” 

In the past, this list was made available in somewhat controlled environments to be queried by election officials, candidates, voters, etc. to ensure that elections accurately reflected the will of the people (in most all cases it was usually printed and held at libraries, constituency offices, polling stations, etc. to be reviewed by interested parties). To limit congregation of individuals in the previously mentioned locations during COVID-19 times, it was decided to publish the full voters list on the Internet to ensure access for all.

The 5250-page list contains approximately 250,000 individual records with the below personally identifiable information (PII). *

  • Last Name
  • First Name
  • National Registration Number (similar to a Social Security Number in the United States)
  • Gender
  • Date of Birth
  • Residential Status
  • Constituency (Voting District)
  • Home Address

* The total population of Barbados currently hovers around 290,000 persons.

Instead of this data being restricted to a few thousand persons in Barbados, it was now accessible by all 4.6 billion Internet users, exposing 250,000 Barbadians to increased risks of data misuse and abuse, fraud, identity theft, and other financial and reputation risks. The information was quickly downloaded and posted on Reddit and a number of hacker/fraudster sites on the Dark Web, making it perpetually available to malicious actors. There is also a high physical risk to individuals with regards to stalking, home invasions, robberies, rape, etc.

PII, also referred to as personal data, covers a wide variety of information that can identify a living individual. If a piece of information is unique to that person, it can lead back to them in several ways, and it is private and needs to be protected with the greatest care.

Why Does Personal Data Need to be Kept Safe?

The reason this type of information requires protection is that it can be used to commit fraud or to steal an individual’s identity.

Depending on what a thief is trying to accomplish, he will need different types of information. To open specific accounts all that is needed is an email address, while in other cases an individual’s name, address, date of birth, a national registration number, and other information may be required.

It’s also critical to note that accounts of all types can be opened over the phone or via the internet without having to physically visit a location for your identity to be verified. This provides opportunities for criminals with appropriate stolen information to open bank accounts, enter into contractual agreements, or make claims using someone else’s information or identity.

If a criminal is fraudulently using your information, you might not even know it. They may not use the credit card you already own to make purchases (in which case you might catch them by looking at your purchase history). Most often, criminals open up new, separate accounts using the victim’s information, leaving the victim unaware of the damage that is being done until years after the fact. In that time criminals can rack up a lot of debt using your identity.

How Can Identity Thieves Use Your Personal Data?

There are several ways which identity thieves can use your personal data, including but not limited to the following:

  • Open a new credit card account.
  • Create fake social media accounts with your identity (e.g., Facebook, Twitter, Instagram, etc.).
  • Take out a commercial bank loan.
  • Obtain and use your debit card to withdraw funds.
  • Change your billing address so your bills will no longer be delivered.
  • Obtain expensive medical care or procedures.
  • Open new utilities accounts in your name (e.g. electricity, water, natural gas, etc.).
  • Obtain a mobile phone service.
  • Open a bank account, obtain a cheque book, and write bad checks.
  • Obtain a new driver’s license or national ID.
  • Use your information when arrested or in a court action.
  • Engage in bullying, stalking, harassment or otherwise cause fear.
  • Inflict severe reputation damage.
  • Combine it with additional data gathered from the Internet (e.g., Google search, Facebook, Instagram, LinkedIn, etc.) to create even more detailed profiles of individuals.

How Long Does It Take Fraudsters to Use Stolen Personal Data?

In 2017, the Federal Trade Commission (FTC) in the United States demonstrated how criminals can use your personal information within minutes. The FTC developed fake personal data and posted it on a website that hackers use to make stolen information available. It took a mere nine (9) minutes for the fraudsters to access the information, and over 1,200 attempts were made to access email, credit card and payment accounts. The research confirms how valuable personal information is to identity thieves, and if they can gain access to it, they will most definitely use it.

What Should the Government Have Done Instead?

While it’s not an exhaustive list, below are some of the key steps the government should have taken.

From a technology perspective, a searchable database should have been published on the Government Information Service (GIS) portal, where individuals could use personal data which they already knew to confirm that they were on the voters list. The full database could have been provided to election officials and campaign managers using a digital rights management (DRM) solution to control access and distribution of the document. 

The Data Protection Act was approved by Parliament in July 2019 and came into force in March 2021. This statute introduces a strong privacy and data protection regime in Barbados, and its wide-reaching impact on overall data governance across sectors and industries should have triggered key updates to existing legislation, processes and operational guidelines (including the Representation of the People Act and any other legislation involving personal data processing). And this doesn’t even address the urgent need for broader legislative reforms in the country. There are way too many outdated pieces of legislation which are incompatible with progressive changes in technology, changing community awareness, changing community values, and changing expectations of the legal system.

Appropriate funding should be allocated to the Office of the Data Protection Commissioner to better equip them in investigating and monitoring data breaches and providing other types of regulation involving the public sector. Additionally, these financial resources can be used to deliver privacy awareness training to educate government personnel on how to protect individual privacy in their daily work. Simultaneously, a public campaign should be started to achieve broad public awareness on all issues related to the Data Protection Act and the new legal framework created. The Office of the Data Protection Commission is severely under-resourced at present, making it virtually impossible to implement and enforce the Data Protection Act, which focuses largely on preventing exactly these types of data leakages. For example, adhering to the principle of data minimisation would have significantly reduced the risk and impact of publishing the entire voters list. By this I mean the narrowing of data collection and processing to strictly what is needed – In this case, there is absolutely no reason to publicly release the National Registration Number (NRN) and Date of Birth of all eligible voters.

Why the Electoral and Boundaries Commission (EBC) is Dead Wrong

The Electoral and Boundaries Commission (EBC) has strongly (and wrongly might I add) defended its decision to publish the voters list online. Their position is that “We are obligated to publish the list now electronically so that more people can have access to it.” Chairman of the EBC Queen’s Counsel Leslie Haynes also maintains that “ID numbers are not private” and made reference to them “being published before the introduction of the digital age in public libraries, rum shops, the electoral office and other spaces.” Because a law states that you must publish information electronically doesn’t mean you should make it accessible to 4.6 billion Internet users (including hackers, fraudsters and other cyber criminals). There are numerous laws in Barbados that are outdated, poorly drafted, contradictory to other laws, and incompatible with existing technology – Should we follow them all to the letter or do we comprehensively update them to be more fit for purpose? Moreover, there are numerous technology solutions available for publishing said data online in a controlled manner to reduce the overall risk and exposure. And if they are not at fault, why did government officials remove the voters list from the public websites?

Finally, national registration number (NRN), date of birth (DOB) and home address are all private information, and there are established technical standards, privacy principles, and national laws or treaties around the globe that assert as much. From a data minimisation perspective, the requirements of the law could have been satisfied without including NRN and DOB.

Where online can you find the social security numbers (SSNs) for all eligible voting Americans? What about the passport numbers or driver’s license numbers for all voting Canadians? What about the national ID numbers for all voters in France, Denmark, Switzerland, Germany, etc.? The answer is NOWHERE!

[UPDATE] Sunday, 2 January 2022 – I have amended the original blog post in response to the EBC’s staunch defence of their decision to publish the voters list on the open Internet.

The UK’s National Cyber Strategy signals a more ‘proactive’ approach to cyber power

The UK government unveiled its long-awaited National Cyber Strategy yesterday, outlining how it plans to improve the resilience of UK institutions and businesses while protecting the country’s interests in ‘cyberspace’. The strategy signals a more interventionist stance from the government, experts told Tech Monitor, which has previously looked to the private sector for leadership. Its commitment to a ‘whole of society’ approach, meanwhile, risks overlooking the need for more diverse perspectives in the cybersecurity workforce.”

I added my quick two cents to a Tech Monitor article on the UK National Cyber Strategy 2022, which can be found here.

Then I provided a more detailed breakdown of the strategy for CircleID…

The 2016 UK Cyber Security Strategy was largely focused on deeper involvement by the government across a broad range of activities, including building cyber offensive capabilities, skills development across key sectors, enhancing coordination and incident response (including the creation of the National Cyber Security Center), promoting innovation, and incubating the UK cyber commercial sector. The 2022 strategy seeks to sustain and build upon the progress from 2016, but taking a ‘cyber ecosystem’ approach that integrates a broader range of stakeholder groups across society in developing cyber risk responses. Think of it as an acknowledgment that cyber security issues are so broad, complex and interlinked that they need to be knitted into the very fabric of national policymaking, including education strategy, regulatory/legal reform, foreign policy, and industrial policy, among others.

The government has come to terms with the fact that it doesn’t have the resources or the depth of skills to tackle all the UK’s cyber-related problems on its own and that private-sector leadership won’t necessarily achieve the desired outcomes. The 2022 Cyber Security Strategy signals the government’s intention to carve out key roles—coordinator, convener, and enabler—in the UK’s cyber ecosystem. The 2016 National Cyber Security Strategy received heavy criticism from the Public Accounts Committee, which maintained there was a lack of evidence and no solid business case to justify the £1.9 billion funding it received—making it nearly impossible to measure success. The ‘whole of society’ approach outlined in the 2022 document illustrates a deeper understanding of cyber issues and brings together the full range of cyber activities domestically and internationally into a seemingly cohesive vision with more measurable outcomes and outputs […]

Feel free to view the entire blog article on the CircleID website.