What the Government of Barbados Needs to Do to Get Fintech Right

There’s a common misconception that IT governance, risk and control (GRC) professionals like myself impose unreasonable demands on those trying to innovate and deliver human, social and economic benefits to society. But this is the furthest thing from the truth – our role is to ensure that those who are delivering technological solutions understand the risks and impacts associated with their IT platforms, and mitigate them in an adequate, effective, and sustainable manner.

The aforementioned point is key as I will go on to explore the privacy, security, and socio-economic implications of two recent announcements by the Government of Barbados pertaining to the implementation of Blockchain-related technology in the country. In a September 19th article titled ‘E-currency pilot coming’, it was stated that Prime Minister Mia Mottley “did not give details of the planned mobile wallet pilot project or when it would begin but gave the assurance that it would not be done in a reckless manner.” Barbados Today published an article on September 25th which stated ‘BSE to begin crypto-trading’, essentially heralding the decision of the Barbados Stock Exchange to trade in security tokens or crypto assets.

Given my intimate knowledge of privacy and security weaknesses in both the public and private sectors, the PM’s words do not instill in me any great confidence around the robustness of the security controls that will accompany these projects. The implementation of e-currency is a complex undertaking, that if not done correctly, can have a material impact on the country’s already weakened economic position. Security tokens are an extremely nascent solution with a lot of potential, but that doesn’t exempt them from security and privacy deficiencies. As such, I want to delve into some of the key areas that must be addressed before these solutions are widely deployed across our beloved nation.

Contract management and due diligence

Before any contracts are signed to commence these projects, the government must understand where personal data of Barbadian citizens will be stored. To provision users onto these platforms, personal data will need to be collected for AML and KYC purposes such as name, address, phone number, driver’s license, passport details, etc.

If the data is stored outside of Barbados, the privacy of Bajans may not be safeguarded as it will be subject to the laws and regulations of the jurisdiction in which the data resides (meaning that the legislation of a foreign country could permit them access to any and all data kept on Barbadian citizens). This is particularly concerning given the absence of data protection legislation in Barbados that would force any fintech company to ensure that transnational data flows must only occur where the destination country has an adequate legal framework in place to protect the rights of data subjects.

The lack of data protection legislation presents another problem in terms of imposing strict obligations on fintech providers to uphold the rights of data subjects. This includes setting requirements and fines for both data controllers and data processors as it pertains to protecting personal and sensitive data, obtaining consent to share personal/sensitive data, reporting data breaches to government and data subjects, among other rules. Hence, it would be in the best interests of Barbados citizens and foreign nationals if the 2018 Data Protection Bill was enacted into law before the launch of the new platforms.

In an ideal situation, the government should obtain 2-3 references from previous instances where the contracted parties have deployed solutions of this kind for other customers. However, it appears that Barbados will be the first country where the vendor will be deploying a ‘true’ e-currency platform, thus making the need for strong controls even more critical. As it pertains to tokenized securities, similar due diligence must be undertaken to protect our citizens.

The government must ensure that a qualified and independent security professional conducts a site visit to the vendors’ IT facilities to undertake a thorough assessment of their security controls. If this cannot be done, the vendor should be required to furnish government with a signed attestation from an independent and qualified third party that the IT facilities meet all the necessary best practice security requirements (e.g. physical security, grounding and lightning protection, environment monitoring, generators, etc.). Additionally, there should be a “right to audit” clause in the contract that allows the government to turn up at the vendors’ IT facilities at any time to conduct a security assessment.

The vendors’ financial statements should be reviewed by an independent auditing firm such as PwC, EY or Deloitte to ensure that they are in good standing and that they are able to remain going concerns for the foreseeable future. The viability of their business models should also be assessed as ‘feasible’. This would protect the country and its citizens from being left at the mercy of fintech service providers whose platforms enjoy massive uptake and integration into the socio-economic fabric of the country, and then they are quickly no longer in business.

With regards to PwC, EY, Deloitte, and other accounting firms (or any qualified professional services firm as a matter of fact), government should enlist one of them to have experienced IT auditors assigned full-time to both projects. This would ensure that IT governance, risk and control processes are embedded throughout the project lifecycles and don’t become an afterthought.

Another area of due diligence is assessment of the team who will be delivering and supporting the solutions. The government must obtain assurance that the right mix of skills is available to deliver and provide ongoing support for high performance, scalable and secure fintech platforms. Along with the technical positions, key roles that should be in place are Internal Audit (assurance), Privacy (compliance) and Information Security (availability, integrity and confidentiality).

Finally, a software escrow agreement that allows government access to the vendor’s proprietary code in the event they go out of business should be put into place […]

To view the remaining guidance on Technical Architecture, Deployment & Support, and Monitoring & Evaluation, you can read the entire blog here.

Should it be mandatory for CISOs to be part of the Board of Directors?

More and more boards are scrutinizing the impact of security and privacy issues on their businesses. However, taken action to being CISOs on to the board has been way too slow. The main challenge is that they don’t grasp that information security issues are not simply IT issues. For clarity, take a look at my article on ‘8 Reasons Why Cybersecurity Strategy and Business Operations are Inseparable‘.

The urgency now being seen from many boards is more so a knee-jerk response to government pressures and increased regulations in lieu of several high profile breaches that have shaken public trust. The former head of the Securities and Exchange Commission (SEC) Luis Agulilar made the following comment back in 2014:

“Board oversight of cyber risk management is critical to ensuring that companies are taking adequate steps to prevent, and prepare for, the harms that can result from such attacks.” He also issued a clear warning that “boards that choose to ignore or minimize the importance of cybersecurity oversight responsibility do so at their own peril.”

Regulators across the globe are making it clear that organizations must have robust privacy and security controls in place to manage the risks associated with technology-enabled commerce. As such, it is critically important that boards regardless of their companies’ industries have a security expert among them to expertly lead the organization in such matters. It is clear that government regulators will hold the Board of Directors accountable and liable for not discharging their duty to prevent harm to the corporation, including damage occurring from cyber attacks and data breaches. Individual directors themselves can be subject to derivative shareholder lawsuits and class-action suits from the company’s banks, business partners, vendors, customers and their own employees.

That being said, not many CISOs have the knowledge and experience; the executive capabilities required to translate into meaningful business terms the impact a cyber incident has on the organization and the activities undertaken to mitigate such events. Many members of the board are not engineers or IT professionals, let alone possess an understanding of technology governance, risk and control. The average board is comprised of approximately nine individuals but some can be as many as 30 persons, so it is imperative that the CISO familiarize himself with his audience to effectively deliver a solid presentation that resonates with them. It is helpful to go into the details of presentations one-to-one with individual board members, as many of them love going into depth and that is an ideal approach to influence the board on an individual basis. For actual board meetings, there is a firm agenda and time limitations that can lessen the strength and impact of CISO presentations.

One of the most effective presentations is the use of risk metrics as most board members in a formal session do not want to be inundated with techno-jargon (do this and watch their eyes glaze over). They want a helicopter perspective of the issues and with clear impact on how the organization as a whole is affected. Board members want visual quantification of risks with the most relevant data in simple language. Using benchmarks designating the past, present and future allows the audience to clearly see how the situation has changed, see the progress and efforts necessary to achieve a benchmark goal.

It is an uphill journey for a CISO to acquire a seat on the board. It is not for the faint-hearted as one is burdened with enormous responsibilities and the board members are the apex of the organization tasked with guiding its ultimate success or failure. Consequently, board membership is a delicate process as much is at stake in terms of the organization remaining a going concern.

CISOs are a necessity to have on the board but they must be savvy, experienced and strategic-minded executive to serve in that capacity. They must have the vision, thought leadership, relationship building skills, and grit to demonstrate value to the organization in this role.

The Impact of the GDPR on the Hospitality Sector

Today I held a General Data Protection Regulations (GDPR) awareness seminar for members of the Barbados Hotel and Tourism Association (BHTA).

With regards to data security, there are few sectors more vulnerable to data-related threats than the hospitality sector. The volume of processed personal and credit card information being handed over to hotels, restaurants, etc. on a daily basis makes the sector extremely vulnerable. With the enforcement deadline having passed on 25 May, several companies in the sector have not updated their data protection processes, and are at risk for large financial penalties.

The seminar touched on key areas such as the following:

  1. Major Differences between the Data Protection Directive 95/46/EC and the GDPR
  2. Overall readiness across the hospitality sector
  3. Capturing and using personal data going forward
  4. Consent and contextual use of personal data
  5. How the GDPR affects repeat business and email marketing
  6. How the GDPR affects third-party data processors
  7. The rights of data subjects under the GDPR
  8. The difference between ‘personal data’ and ‘sensitive data’, and how they should be treated
  9. Other key aspects of the GDPR such as the Data Protection Officer (DPO), Data Protection Impact Assessments (DPIA) and ‘privacy by design’
  10. How to update strategies for websites, data governance, and marketing to become GDPR compliant

My takeaway from this session was that many businesses — small to large — have not made any steps to align their operations and processes with the requirements of the GDPR. Several others are defiantly refusing to address privacy and data protection within their organizations. However, what was gratifying is that I received a torrent of emails in the hours and days after from hoteliers, many of them eager to engage subject matter experts (SMEs) to assist in improving their control framework to meet the rigorous demands of the GDPR. Hopefully, this interest and willingness to improve is sustainable. There’s a lot of work to be done!

 

 

ICT PULSE: Cyber threats and security in the Caribbean 2018 update – Interview with Niel Harper

ICT Pulse:  Niel, thank you again for taking the time to share your insights with us. To start, give us a quick recap of what have been the most prevalent types of incidents in the Barbados and/or in the wider Caribbean region over the past year or so?

Niel Harper:  Over the past year, there has been a substantive increase in ransomware attacks in Barbados and across the Caribbean. This is pretty much in line with the global trend, where we saw massive ransomware attacks such as NotPetya and WannaCry that impacted over 500,000 organizations and resulted in damages and losses in excess of USD$400 million. Barbados and the rest of the Caribbean were not spared from the wrath of these attacks.

ICTP:  Has the threat landscape changed over the past year? Are there any particular areas of concern that you have for Caribbean organizations, or the region as a whole?

NH:  Yes, most definitely the threat landscape has changed over the last year. Firstly, there has been a shift towards attacks on the underlying Internet infrastructure. Hence, Caribbean service providers need to implement protections in their networks to address core routing and DNS security, among others. Additionally, we are seeing hackers using social media platforms as an attack vector, and such attacks are routinely compromising mobile phones. Last but perhaps most significant, state-sponsored threat actors have become more and more active. We are seeing increasing attacks against critical infrastructure and supply chains. For example, cyberwar actors will seek to attack targets that result in maximum disruption, economic upheaval, and even public safety issues (e.g. airports, public transit, power grids, nuclear facilities, smart cities, etc.). There will be continued attacks targeting democratic processes such as electronic voting machines, online voter registration, party or politician websites, and other such platforms. Sadly, Caribbean (and global) enterprises will get caught up in state-led or state-sponsored attacks, and with far-reaching economic impacts.

ICTP:  Over the past year, ransomware incidents still appeared to be occurring across the region. Are they still as huge a threat?

NH:  As stated in my earlier comment, ransomware is most definitely still a threat, and there are a couple of reasons for this. For one, there are numerous techniques available to hackers for initiating ransomware attacks such as spam, phishing, rootkits on legitimate website, traffic redirection, and others. Ransomware also remains a lucrative business for hackers. There’s also no shortage of targets for ransomware attackers, specifically when you consider that many healthcare providers, government agencies and educational institutions simply don’t have the resources to adequately respond to cyber threats […]

The entire interview can be found on the ICT Pulse website at: https://bit.ly/2JzAFce

What is a virtual CISO? When and why should you hire one?

Chief information security officers (CISOs) are increasingly in-demand, and the very good ones are expensive and difficult to lock down. As more and more organizations who are without CISOs suffer breaches, how should they go about bringing such talent into their businesses?

Could an on-demand virtual CISO (vCISO) be the appropriate solution for them? A vCISO is essentially a security practitioner who provides their advice and insights to an organization on an outsourced and ongoing basis, usually part-time and remotely.

But why would a business engage a vCISO when they can hire a full-time CISO? The answer to this is not a simple one. Firstly, a vCISO is not a good fit for all organizations. Secondly, highly-regarded, experienced CISOs are not easily found, generally stay in a role for 2-3 years, and most importantly, come with a salary that is prohibitive for small to medium enterprises (SMEs).

vCISOs usually cost around 40% – 60% of what you would pay a full-time CISO, and their services can be delivered on-demand. Their benefits usually way exceed their costs. Virtual CISOs are highly experienced, knowledgeable, don’t have learning curve challenges, can integrate easily into a business, and won’t see the need to tiptoe or play nice when it comes to corporate politics. With this approach, it is strictly about outcomes, and a top-tier vCISO will provide critical board and executive engagement, metrics, and high-level reporting.

While different vCISOs come with varying skillsets, most should be able to deal with a plethora of activities from strategic to tactical. They can develop your information risk assessment methodology. They can create a robust framework of policies, procedures, standards, and guidelines. They can help your organization come to terms with GDPR, PCI-DSS and other compliance issues. They can address outsourced vendor risks, for example around cloud computing and IoT services. They can also assist with recruitment and establishing a high-performance team, devising the security vision and strategy, leading the RFP process for security solutions, refining incident response processes, and implementing COBIT 5.0 and ISO/IEC 27000. They might also support the coaching and training needs of newly hired CISOs and conduct awareness training and reporting to the Board of Directors.

Virtual CISOs are best suited to startups and growing companies, and are an ideal approach for bolstering the already in-place management team or basically leveraged as a short-term solution. The best vCISOs must be good communicators – vertically and horizontally, and especially at the board level. They must be able to work with companies across diverse industries and with varying risk profiles and backgrounds. They must be capable of communicating clearly what business risks companies are exposed to as it relates to cybersecurity. An effective vCISO must also be adaptable and quickly learn about the unique business environment their customer operates in. And once these things are known, the vCISO needs to bring their knowledge and skills to bear in terms of aligning the cybersecurity strategy with the business’ strategic objectives.

As they generally operate without budgets or responsibility for implementation, it is best if vCISOs are viewed as advisors and not as auditors or change managers. Cybersecurity is largely a business of relationship management, and traditional CISOs must win the hearts and minds of the executives and organizational leaders if they’re to move the enterprise forward. vCISOs don’t necessarily need to do this, as they are not visible and likely won’t be around for the long-term.

Why Bitcoin Will Not Solve the Caribbean’s Financial Inclusion Woes

What is Bitcoin? Is it electronic money?

There’s a deluge of hype around Bitcoin and blockchain technologies right now, and policymakers and regulators in the Caribbean are doing their best to wrap their heads around the advantages and disadvantages of this virtual currency. Similar questions are being contemplated in the ICTs for development (ICT4D) community, taking into account that electronic money (e-money) platforms such as Safaricom’s M-PESA have essentially solved the financial inclusion quandary for millions of people in Kenya. The service has now even expanded to Eastern Europe, Afghanistan, and India.

Besides sharing the characteristic of being digital, how do Bitcoin and e-money compare, especially with regards to reaching individuals who have previously been unable to access traditional financial services? Presently, there appear to be more differences than similarities between the two, and it’s critical not to confuse virtual currency with e-money.

Blockchain, in brief, is a record of digital events, distributed across multiple participants. It can only be updated by consensus between participants in the system, and when new data is entered, it can never be erased. The blockchain contains a true and verifiable record of each and every transaction ever made in the system. Launched in 2009, Bitcoin is a virtual, private currency that uses blockchain as an underlying, immutable public ledger. Bitcoins are ‘mined’ using distributed processing power across a global network of volunteer software enthusiasts. The supply mechanism is designed to grow slowly and has an upper limit of 21 million units as determined by a built-in algorithm. There is no central authority that controls blockchain or Bitcoin. There are no central banks that can be politically manipulated; and no way to inflate the value of a national currency by simply printing more money. Economic libertarians are ecstatic at the very thought of this. However, competing virtual currencies can be created that could have the net effect of devaluing the original.

Contrastingly, e-money is not a separate currency and is overseen by the same national regulatory authority that governs the printing of fiat money – as is the case with M-PESA and the Central Bank of Kenya. It’s an extension of a national currency like Jamaican dollars or Netherland Antilles guilders for use over digital networks to reduce the costs associated with handling physical cash. More specifically, it’s a one-to-one electronic store of value pegged to the cash receipt of the equivalent amount. To mitigate against risks like money laundering, terrorist financing, consumer protection, etc., the cash against which e-money is issued most often has to be deposited with fully regulated financial institutions.

The issue of financial exclusion

The issue of financial exclusion can be summarized into 2 categories: unbanked and underbanked. Unbanked individuals do not have an account at a regulated financial institution, while underbanked individuals have accounts, but frequently use alternative or unregulated financial services.

Before elaborating on the key factors behind financial exclusion, it is important to detail the effects of being unbanked to illustrate the severity of the problem. Unbanked individuals are faced with a heavy economic burden […]

The full article can be found on the CircleID website at: https://goo.gl/zn7Yg9

The State of Cybersecurity 2017 – Simplicity 2.0 Podcast

“Cybersecurity is a constant challenge for businesses. Niel Harper, Managing Director of Octave Consulting Group, shares tips to protect your company’s infrastructure from security threats, and offers ways to stay a step ahead of malware, hacking, and other attacks.”

I recently sat down with the Economist Group and Laserfiche (Simplicity 2.0 Podcast) to discuss the management of cybersecurity risks. These types of interviews tend to get very abstract, so I purposely wanted to touch on topics that would resonate with both corporations and end users.

The podcast in its entirety can be found here.

Internet Infrastructure Security Guidelines for Africa

To facilitate implementation of the Convention, the African Union Commission (AUC) asked the Internet Society (ISOC) to jointly develop the Internet Infrastructure Security Guidelines for Africa. The Guidelines were created with contributions from regional and global Internet infrastructure security experts, government and CERT representatives, and network and ccTLD DNS operators. As one of the cybersecurity experts involved in the development of these Guidelines, I am proud and deeply humbled to have made a contribution.

The Guidelines emphasize the importance of the multistakeholder model and a collaborative security approach in protecting Internet infrastructure. The Guidelines put forward four essential principles of Internet infrastructure security: Awareness, Responsibility, Cooperation, and adherence to Fundamental Rights and Internet Properties.

These critical actions are tailored to the African cybersecurity environment’s unique features: a shortage of skilled human resources; limited resources (including financial) for governments and organizations to allocate for cyber security; limited levels of awareness of cyber security issues among stakeholders; and a general lack of awareness of the risks involved in the use of information and communication technologies (ICTs).

Only with ongoing multistakeholder efforts from the African Internet community can the continent overcome its challenges, embrace its opportunities, and become an Internet world leader.

6 Tips for Protecting Against Ransomware

The Internet Society has been closely monitoring the ransomware cyber-attacks that have been occurring over the last couple of days. The malware, which has gone by multiple names, including WannaCry, WannaDecryptor, and WannaCrypt, exploits a flaw in Microsoft Windows that was first reportedly discovered by the National Security Agency (NSA). A group of hackers leaked the code for exploiting this vulnerability earlier this year, and a fix or patch was available as far back as March 2017. Since Friday, 200,000 computers in 150 countries have been compromised using this exploit. The numbers are expected to grow exponentially as people settle back into their work routines and regular use of computer systems this week. As part of our continuing work in online trust and security, there are some key takeaways from this incident that we want to leave with our community.

Firstly, we want to highlight the extremely negative effects which government stockpiling of vulnerabilities and zero day attacks has on the overall security of the Internet. With over 60 countries known to be developing growing arsenals of cyber weapons, and with many of these exploits leaking into the public domain, the potential for widespread damage is a massive cause for concern. The impact is not only economic in terms of financial loss, but social in terms of how it impacts end user trust, and most importantly human in terms of loss of life (especially given that ransomware attacks have been focusing on hospitals). And with critical infrastructure like power plants, dams, and transportation systems being targeted in nation state cyber offensives, the threat to human life increases exponentially.

Secondly, it would appear that some hospitals are easy targets for ransomware attackers. Their systems house data that is critical to patient care and management, and many of these institutions don’t have the IT resources to support critical process areas like vulnerability management, patch management, business continuity management, etc. In general, hospitals are also now adapting to digital realities and a number of them are playing catchup with regards to cyber readiness. However, the aforementioned challenges are not unique to hospitals, and are faced by many small and medium enterprises (SMEs), and in several instances, large corporations. Individual users are also targeted based on their generally poor Internet hygiene or lack of security awareness.

We want to take this opportunity to emphasize the importance of good online security practices when accessing the Internet. So here are 6 basic tips for protecting against ransomware:

1. Employ strong, multi-layered endpoint security – Using endpoint security that can protect web browsing, control outbound traffic, protect system settings, proactively stop phishing attacks and continuously monitor for anomalous system behavior will allow for better protection of servers, laptops, tablets, and mobile devices.

2. Maintain regular backups of your critical data – Backups can help you to protect your data from more than just ransomware. Other risk events such as malware, theft, fire, flood or accidental deletion can all render your data unavailable. Be certain to encrypt your backed-up data so it can be effectively restored. Backups should also be stored at an offsite location isolated from the local network.

3. Do not open unsolicited emails or messages from unknown senders – Many ransomware variants are distributed through phishing attacks or email attachments. Increased mindfulness when handling ‘suspect’ emails can be effective in combating ransomware.

4. Patch your systems regularly – Patching your systems for vulnerabilities reduces the opportunities for hackers to infect you with ransomware. The fact that a patch was available for the WannaCrypt vulnerability since March highlights the somewhat lax attitude by organizations and individuals to keeping their system patches up to date. That being said, patch management is a complex activity and can impact the availability of key systems. Hence, thorough testing must be conducted to avoid unplanned downtime.

5. Disable macros if possible – Many forms of ransomware are distributed in Microsoft Office documents that attempt to trick users into enabling macros. There are a number of tools available that can limit to functionality of macros my preventing them from being enabled on files downloaded from the Internet.

6. Be aware and vigilant – For individuals, don’t assume that only techies need to know about all the recent malware and trends in online attacks. Subscribe to mailing lists that provide information on common vulnerabilities and exposures. In the case of organizations, developing an information security awareness program is an integral part of improving overall security posture.

Finally, we want to touch on the important work being done by the Online Trust Alliance (OTA), the Internet Society’s newest initiative. The OTA’s mission is to enhance online trust, user empowerment and innovation through convening multi-stakeholder initiatives, developing and promoting best practices, ethical privacy practices and data stewardship. With regards to preventing ransomware attacks, OTA has developed a number of industry best practices that address key threat areas such as email authentication and incident response. These are as follows:

Email Authentication: https://otalliance.org/resources/email-security

Domain-based Message Authentication, Reporting & Conformance (DMARC):https://otalliance.org/dmarc

Cyber Incident & Breach Response: https://otalliance.org/resources/cyber-incident-breach-response

Additional OTA best practices, resources and guidance to help enhance online safety, data security, privacy and brand protection can be found here.

The Spam Toolkit developed by the Internet Society also provides some guidance on addressing online threats.

The Internet Society is committed to the enhancement of online trust, and our work along this vein spans multiple areas. Our goal is to continue to provide our individual members, organizational members, chapters, partners, and other constituents with timely and relevant information and resources that equip and empower them to act.

My original blog article was published on the Internet Society website at: http://bit.ly/2qMuQ4U