Angry BossIt’s 4:20 p.m. on Friday.  You’re looking forward to meeting your friends soon for happy hour at the local bar.  Your boss is on vacation, and you’re caught up for the week.  All is well.  As you take one last look at your e-mail, you see a message has just arrived from one of your suppliers – marked URGENT.  The supplier is ranting about why you didn’t send payment for last month’s invoice to the right bank account.  They’ve contacted your boss, who they say was irate at being disturbed while in Madrid on vacation, and who told them to contact you personally for immediate resolution.  They helpfully provide the correct bank routing information and demand the payment be made today.  Your authority for wire transfers ($1M) will easily cover the request for $250,000, with change.   The invoice amount sounds about right, you know the supplier, your boss is already upset, it’s Friday, and so you wire the funds.

Of course, you—the reader—already know the ending of this story.  The email was fraudulent, the company is now out a quarter of a million dollars, and you may be out of a job.  Yet this and similar scenarios play out every day, representing a 2,370% increase in the last 18 months in identified exposed losses resulting from business e-mail compromise targeting small, medium, and large businesses. Continue Reading It’s time to annoy your boss

EquifaxThe aftermath of the Equifax breach continues.  First, the Ugly:

Music Major?  Really?

The hoi palloi apparently find it offensive that Equifax’s Chief Security Officer, fired in the breach’s wake, had a music degree. The implication is that someone formally trained long ago in music is clearly incompetent to have a career in IT or Infosec, much less to be a CSO. That must be a surprise to Jennifer Widom (data management researcher, computer science professor, and Dean of Stanford University’s School of Engineering), who somehow, despite her undergraduate music degree, managed to help lay the foundations for active database systems architecture, crucial for such uses as security monitoring.  Or to countless others who came to Infosec after formal education in other disciplines – check out #unqualifiedfortech on Twitter.

Yesterday’s thoughtful Washington Post piece was well-titled: Equifax’s security chief had some big problems. Being a music major wasn’t one of them. And if your ironic sensibility remains unsated, see the 10/20/2016 article Musicians May Be the Key to the Cybersecurity Talent Shortage.

Next, the Bad: Continue Reading Equifax breach – the good, the bad, and the ugly

Worried couple checking credit account onlineThe grousing began within 24 hours of Equifax’s announcement, last Thursday, of its massive data breach that compromised personal data of over 140 million U.S. consumers.  I’m generally unsympathetic about such complaints (“We’re shocked – SHOCKED – that in a breach affecting 140+ million people, we’re having trouble immediately reaching a live person at the phone bank!  And the breach website is not operating smoothly!”). Usually only Louis CK’s masterpiece “Everything’s Amazing – and Nobody’s Happy” can coax me out of my grumpy place.

But as post-announcement events have unfolded, some of the initial criticism appears to have legs: Continue Reading Equifax breach – hot mess, or simply the world we live in?

Young woman who's forgot her passwordAt last!!!  A good reason not to create dozens of hard-to-remember passwords!  The updated National Institute for Standards and Technology guidance on creating passwords has been out for a while now, but the word has been slow in trickling down to end users.  It’s time to pay attention, because the recommendations represent a huge departure from standard practice.  First, the good news:

The good

NIST is part of the US Department of Commerce and an authoritative standards-making body.  It is the entity that wrote the primer on how to create all those complex and hard-to-remember passwords in the first place. You know, passwords like *Pa$$w)rd3!  NIST now acknowledges through this publication that the old rules affected usability negatively. It also turns out that passwords composed of a few common words strung together are far stronger than upper-lower-numbers-characters passwords, so the old way was less secure than we thought.

It’s big news then that NIST has seen the error of its ways and now recommends creating passwords we can remember.  Even more important, it also now recommends that a password not be changed unless there is an indicator it has been compromised or forgotten by the user.  Of course, being the government, calling a password a password is just too hard.  The term in NIST SP800-63B 2017 is “Memorized Secret Authenticator.”  Whatever you choose to call it, user guidance is simple: Continue Reading dyktthctgohtcp?

White WalkerA swarm of zombies, led by Byte Walkers, surges inexorably onward to penetrate a massive perimeter wall by force and stealth.  Sounds like Game of Thrones, right?  Instead, this is our cyberthreat reality. And in an ironic twist that would make George R. R. Martin blush under his beard, it’s now painfully real for HBO, which recently acknowledged suffering a massive cyber intrusion through which hackers claim to have stolen up to 1.5 terabytes of proprietary data, including Game of Thrones future epsodes.

First Sony, then Netflix, and now HBO – what’s a Westerosi to make of this? Continue Reading Game of Hacks

Hurricane between Florida and CubaHurricane season is in full swing.  As I write this, Tropical Storm Emily is drenching Florida, and the governor has declared a state of emergency.  Having lived in Florida myself, I know that most coastal residents do take hurricanes seriously.  There are always those, however, who either don’t grasp the possibility that if a hurricane hits they can suffer real damage, or simply play the odds that it won’t happen to them.  Hurricane readiness for them is a bottle of Cuervo Reserva and some DVDs for entertainment in case the power goes out.  And so, too, it goes with data breaches.

Breach readiness today ranges from total denial, through half-hearted attempts at maintaining current backups, to—for a minority—sophisticated IT security teams and technology ready to detect, respond, and recover.  Even the technologically prepared, though, have likely not planned beyond containment and recovery.  Consider our hurricane scenario.  Minimal readiness includes necessities for riding out the storm: an evacuation plan, water, food, flashlights, medical supplies, and so on.  Those things should get you through the first 48 hours, much like the immediate IT response to a data breach.  But what next?

Continue Reading It’s readiness season

Business woman screaming at laptopMany years ago, before common sense kicked in, I thought it would be a good idea to rent a storage space for all the extra furniture and other stuff I could not fit in my new house.  Knowing it would only be temporary, I stashed everything from upholstered and leather furniture, to boxes of books.  Fast forward twelve months.  The rental agreement was expiring, and I realized that I would never need nor have room for all that I’d stored, so I decided to have a sale to dispose of it.  When I went to the storage space I was horrified to see that everything was covered in a thin film of mold.  (This was years before climate-controlled storage was widely available.)  I had no choice but to trash it all, which both cost me money and prevented me from converting my goods to profit.

I was reminded of this long-ago event when I heard about the latest ransomware attack.  We’ve been reminded countless times of the importance of backup, and ransomware is only the most recent reason.  If you have ever had a hard drive fail, you know the pain that comes with irretrievable data.

So what happens when your backup media fails.? Or your archival media?  Don’t CDs last forever? Continue Reading Backup failure in the age of ransomware

checklistIt’s a common complaint – most U.S. laws requiring data security never cough up the specifics of what must be done to comply. Unlike other areas of business regulation, data security requirements seem hopelessly vague:

  • Several states’ PII laws require businesses to implement and maintain “reasonable security procedures and practices” to protect PII from unauthorized access, destruction, use, modification, or disclosure.
  • Regulations under the Gramm-Leach-Bliley Act compel financial institutions to have a “reasonably designed”comprehensive information security program with administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
  • FACTA regulations require that consumer report information be disposed of “by taking reasonable measures to protect against unauthorized access to or use of the information….”
  • HIPAA covered entities and business associates must address the security standards for ePHI in a way that protects against “reasonably anticipated threats or hazardsto ePHI security or integrity.
  • The FTC enforces reasonable data security under Section 5 of the FTC Act, which prohibits unfair and deceptive acts in commerce, without explicitly mentioning data security and without any supporting regulatory standards for specific data safeguards.

Obviously, we can’t just put “remember to have reasonable data security” in a compliance checklist or internal audit protocol, because “reasonable” tells us nothing concrete about what specific security controls are needed to be compliant.  So, why do these laws stop short of telling us specifically what to do?

Continue Reading Why don’t data security laws simply tell us what we need to do?

Lawyer holding a target on his faceWhile preparing for an upcoming presentation for in-house lawyers on data security, I dusted off the events of three months ago, when Yahoo! Inc. unceremoniously fired its general counsel on March 1st, the very same day it filed its 10-K for fiscal year 2016.  Yahoo’s 10-K disclosed the contemporaneous dismissal as a “Management Change” resulting from its Board of Directors’ Independent Committee investigation into Yahoo’s immense 2013-2014 data breaches, which were not disclosed until 2016. Unlike prior mega-breaches, in which the head of IT or the CEO was let go (Target, Sony), Yahoo singled out its lead in-house lawyer for firing … without separation compensation of any kind.

Henceforth, whether fairly or not, March 1 will be known as In-house Counsel Data Security Awareness Day – because it’s now clearer than ever before that in-house lawyers must take a hands-on approach to breach response, breach response readiness, and data security generally.

Continue Reading In-house Counsel in the Cybersecurity Crosshairs