SRM Blog

Ransomware – Could it be you?….

Complacency has always been the enemy of safety; in today’s world, we are all vulnerable!

The digital (cyber) environment may sometimes be opaque and difficult to understand, but it is a contested environment. If we seek to operate within it, and exploit its advantages, we must actively engage or expect to become a victim.

As I write a number of organisations worldwide, are reeling under the hammer of what appears to be a thoroughly industrialised Cyber Attack. Many of these affected organisations have (or claim) a reputation for strong governance. There is no-one, reading this, who doesn’t have actions that they should have taken or should be taking now.

Whilst it is tempting to view this sort of event as spectators, anyone reading this is unlikely to be invulnerable, whether we are part of an organisation or an individual. There are steps we should all be taking to reduce risk to ourselves or our organisations. We ignore these responsibilities at our peril.

Those who are responsible for the safety of organisations will have already taken actions to ensure that they are as safe as possible. This is part of baseline governance needed in today’s world and no organisation can claim to be competently run if it doesn’t have an effective Information or Cyber Security Management System. If you have one – you will probably know about it!

If you haven’t – then now is a good time to start – and if necessary get in touch with someone who can help you. (if you can’t think of anyone specific or are worried, www.srm-solutions.com is a good place to start!) There are a number of excellent schemes and established practices that you can use to raise the bar for attackers. If you have done nothing else yet – at least look at the Cyber Essentials Scheme as a first step.

If you don’t know who is responsible in your company – check – it could be you!

As individuals, however, we are still potential victims of attacks like this, but if we practice basic Cyber Hygiene we dramatically reduce the risks to ourselves and those around us.

Make sure our defences are strong:

Ensure our Anti Virus (even on a mac!), firewalls and software are all up to date and switched on.
Scan our systems with Anti Virus, and do this regularly when attacks are going on.
Stay alert to any suspicious emails, messages and don’t open anything suspicious. If someone sends you something suspicious. Contact them separately to check it is legitimate.
Check that we are using difficult to guess passwords, and that we are not exposing the password protecting our “crown jewels” on untrusted internet sites or unprotected devices.
Check our bank and card statements – Regularly!
Think it through from an attacker’s perspective.

Make sure we are resilient:

Ensure our information is backed and kept somewhere where it isn’t connected to the internet or our main system (e.g. a CD or a Backpack Drive).
Ensure we keep all backup data safe – and if possible encrypted. Ideally under lock and key.
Ensure that any critical information is held safely so that it will be available in the event that our main system is unavailable.

Make sure we know what to do if we are compromised:

Write down a simple plan – stick it on the fridge or the filing cabinet – somewhere we can find it!
Don’t pay ransoms – we shouldn’t need to!
Know who we are going to contact for further advice in emergency.

Don’t Assume – Check that you are as safe as you think you are. Do this periodically and when the risk rises:

Check our Backups are being taken (and that your drive is not full). Check that we can restore them and that they are not corrupted.
Check that you can access your critical data and files if your main system is down.
If you don’t know how to do any of this – learn now – these are basic survival skills! If you have friends or family members who may not be able to do this – it may be worth contacting them to check they are not exposing themselves inadvertently.

Whether we are acting as individuals or are responsible for the safety of an organisation, this is no longer something for someone else to do – we all have a part to play, and must play it to the best of our ability.

Managing Director of SRM, Tom F is a regular contributor to the SRM blog.

No breach too small – the ICO takes action against charities

In December 2016 the Information Commissioner’s Office (ICO) fined a historical society £400 after a laptop containing personal data was stolen while a member of staff was working away from the office. The data was not encrypted and contained details of donors and the artefacts they had gifted. The ICO investigation found ‘the organisation had no policies or procedures around homeworking, encryption and mobile devices which resulted in a breach of data protection law’. So, it is not just big business that needs to comply with data protection law. It applies to everyone, regardless of size or motive. In fact, some well-loved charities ran into trouble with the ICO this year.

In April 2017 an ICO report revealed that thirteen charities have been fined for non-compliance. The ICO is the independent authority set up to ‘uphold information rights in the public interest’. They have the power to take action when data rules are breached, regardless of scale.

Between 2015 and 2017 the ICO carried out an investigation into the practices of charity fundraising. The thirteen charities which were fined included Battersea Dogs’ and Cats’ Home, Cancer Research UK, Great Ormond Street Hospital, Macmillan Cancer Support, Oxfam, NSPCC, The Royal British Legion and Guide Dogs for the Blind Association. Fines ranged from £6,000 – £18,000 depending on the non-compliance identified. The breaches fell into three distinct areas:

Finding information about you, that you didn’t provide. The ICO asserts that the individual has the right to choose what personal information is provided. The practice of using external companies to find missing information or update out of date information is not permitted. Battersea Dogs’ Home received a £9,000 for using this approach in 740,181 cases between 2011 and 2015.

Sharing your details with other charities, no matter what the cause. It is common for some charities to exchange donor information. The practice of sharing donor information is not illegal but using an external organisation and not knowing with which other charities it is being shared is. Cancer Support UK was fined £16,000 for failing to follow data protection rules.

Ranking based on wealth. Some charities profile their donors based on wealth. External companies can also identify donors they believe charities should target because they are most likely to leave money in their wills. It is called legacy profiling. The Guide Dogs for the Blind Association was fined £15,000 for this and for sourcing information they did not have permission to access.

The important message is that it does not matter what size the organisation or whatever its status, the same rules apply. It is also worth noting that the rules regarding personal data will become significantly stricter when the General Data Protection Regulation (GDPR) becomes UK law in May 2018. To find out about your obligations and how to comply, including protecting personal information, see the ICO’s Data Protection Self Assessment Toolkit.

Data protection – the gap widens across the Atlantic

Data protection is a global issue. Yet it is being approached in very different ways on either side of the Atlantic. While Europe and Britain will embrace the more stringent rules of the General Data Protection (GDPR) regulation from May 2018, the situation in the USA is going the other way. On 3rd April President Trump signed a new law making more personal data legally available. Overturning the previous legislation, ISPs are now able to access and use all but the most sensitive personal information. Much of this personal data is likely to be harvested and sold to digital advertisers.

While the global super power Google already grows its business through targeted online advertising, this will open up the practice in the US to a host of other players in the ISP market. Its advocates say this availability of data helps advertisers to target consumers more effectively thereby helping them to make better decisions. Its detractors see it very differently.

Whatever your view, Personal Information Management Services (PIMS) are already huge revenue generators and not just in the United States. A study estimates the value of the UK PIMS market to be currently worth £16.5 billion. But from this moment on, the paths diverge and when it comes to the future of personal data protection, it appears that the differentiator will be regional legislation.

The change in law in the US, with its permissive approach to personal data, will open up the PIMS market and along with it many associated problems. It certainly seems likely that this will create a need for privacy-enhancing tools and services. In Europe, on the other hand, the legislative market under the GDPR might drive online advertising businesses to invest in new models which create value from mining personal data in legal ways. There is little that can be done to prevent opportunism in the world of PIMS and digital advertising, but the American model is fraught with problems and risks, both financial and on a moral basis. We in the UK must be grateful for the very different approach mandated by GDPR.

When GDPR comes into effect, UK companies will be legally obliged to observe new procedures and take even greater responsibility for how they collect, share, and use consumers’ data. Some businesses will complain that the new regulation is burdensome and bureaucratic but they are wrong. Those who shirk it will certainly feel some pain as enforcement will be strict and fines extremely severe. But many will embrace it as an opportunity; as a competitive differentiator. If in any doubt, the complainers will only have to keep an eye on how the permissive data protection laws impact across the Atlantic.

SRM has operated in the data security environment for many years. With a wide range of knowledge and practical experience, our consultants are ready to help you understand the risks to your information and manage them effectively. Our specialist team provides a full portfolio of services which include data protection. We can assist companies to be in a more ready state for GDPR compliance when it comes into effect next year.

GDPR – The General Data Protection Regulation

The uncertainty of Brexit, the certainty of GDPR and the responsibilities of the CISO

 

If Brexit means Brexit, what does GDPR mean?

A data breach damages more than your reputation

Being known as the source of the largest data breach in history is probably not how Yahoo would like to be remembered. The reputations of eBay, Linkedin, MySpace, Talk Talk and Ashley Maddison also took a hit in recent years. Yet these high profile cases are just the tip of the iceberg. A new survey by the British Chamber of Commerce (BCC) reveals that 42 per cent of big businesses have been the victim of cybercrime. The figure for smaller companies is lower with only 18 per cent being attacked which probably reflects the current priorities of hackers.

No one should be complacent, however. In the BCC survey only 24 per cent of the businesses questioned (regardless of size) said they had security measures in place. This means that three quarters have no defence against a data breach. The impact of these, even to smaller companies, cannot be underestimated. Even more worrying is that fact that the vast majority of companies that have suffered a data breach were not aware of it until they were notified by either their customers or industry bodies.

Adam Marshall of the BCC says ‘cyber attacks risk companies’ finances, confidence and reputation, with victims reporting not only monetary losses, but costs from disruption to their business and productivity’.

We know this to be the case. But while a Government spokesman has used the BCC report to advise companies to take advantage of its Cyber Essentials scheme to protect against attacks, we do not believe this goes far enough. Cyber Essentials accreditation is certainly an extremely useful starting point and is now a requirement of any business bidding for a new Government contract. But the rules for the protection of customer data will soon become significantly stricter with the arrival of the General Data Protection Regulation in May 2018. And, besides, protection is not just about compliance; it is about having a robust defence in place as well as a considered strategy to minimise the impact of any potential breach.

This is where we come in. When a data breach occurs that involves payment card data the Payment Card Industry (PCI) calls in a forensic investigator (PFI) to identify and resolve the situation. At SRM we are one of a handful of companies in the UK retained by the PCI to carry out these investigations. But we also offer a bespoke Retained Forensic service, which uses this expertise to proactively manage systems before an attack occurs. In this way, organisations can use our Data Forensic Investigations team to meet compliance requirements but also to build robust defences and test those strategies in a controlled manner, before the worst actually happens.

We do not recommend services or tools you do not need, preferring to use our extensive experience and understanding of the online retail world to set up a targeted plan of action and remediation which will keep your business compliant and as secure as it is possible to be. Given the persistence and resilience of cyber attackers there is a remote chance that a system might still be attacked. With a robust plan in place, however, remedial action will be swift, minimising financial and reputational damage. Demonstrating a proactive approach to protecting your customer’s data also puts you in a stronger position when dealing with acquiring banks or any other regulatory authorities.

Cyber Essentials

PCI PFI

How to protect your business from account data compromise (ADC)

How to protect your business from account data compromise (ADC)

The fact is that all too often the first someone knows that their system has been breached is when they receive a call from their acquiring bank. Someone has reported that they are the common point of purchase for fraudulent activity. It is a conversation every business owner dreads.

The repercussions are serious, triggering a mandatory Payment Card Industry forensic investigation (PFI) which the vendor must pay for. The breach needs to be stemmed and an analysis made of the security issue. If there is culpability, a significant penalty may follow. In addition to that are the financial repercussions to the company’s bottom line and its reputation. So what can be done to anticipate a breach at its earliest stage or, even better, prevent such a breach from occurring?

What are the indications of an Account Data Compromise?

Sometimes it is obvious: a key-logger or a card-skimming device is found. Because malicious attackers are highly skilled, however, more frequently it is a subtle change in activity which is easily overlooked by the vendor until it is too late. Examples of these are:

  • Unexpected internet connections: from non-business-related IP addresses or from countries the business has no dealings with;
  • Log in by unknown or inactive user IDs; or an unusual level of activity from a recognised user ID;
  • Multiple instances of remote access tools present on a system in an ‘always on’ mode;
  • The presence of malware, suspicious files, executables or programs;
  • SQL injection or other suspicious activity on web-facing systems;
  • POS terminals and ATM devices showing signs of tampering;
  • Lost, stolen or misplaced sales receipts or payment card data.

What can be done to protect against such attacks?

  • Use PFI skills to your advantage: working with a respected PCI company with forensic investigation capability is a great starting point. They already have the forensic skills and tools and can use these to help you to build a robust defence;
  • Do not simply tick the annual PCI compliance box but ensure that your compliance is ongoing; continually updated and improved. Working with a PCI compliance expert will help you to do this cost effectively and robustly;
  • Get ahead of the game: go a step further than straight forward compliance and conduct a thorough review, including a penetration test and vulnerability scan to highlight your specific potential threats and vulnerabilities;
  • Be aware of your future obligations: the General Data Protection Regulation (GDPR) comes into effect in May 2018 and you will need to comply. You responsibilities increase and so do the potential penalties if a breach occurs.
  • Consider outsourcing the role of Information Security Officer (ISO): smaller companies will struggle to recruit suitably qualified individuals with the right skill set but working with a Virtual ISO team provides expert strategic input as well as practical input and training.
  • Engage with a company that specialises in forensic investigations. They will be able to test your incident response strategy and ensure that you are able to respond quickly and efficiently if the worst ever happens. Be prepared!

What happens in the event of a breach?

Breaches happen. But having the right team on hand to identify, analyse, correct and report on incidents saves money and reputation while reducing future risk and freeing you to continue to trade. SRM’s dedicated response team is on hand 24/7 x 365, providing professional, pragmatic and strategic support in the event of any type of incident, enabling you to focus on your business activities.

What next?

In the context of the damage an ADC breach can cause any investment is worthwhile. SRM offers a bespoke retained PFI service, working proactively through regular strategic reviews to develop enhanced risk mitigation and ensure rapid remediation and minimal disruption in the event of a breach.

We do not recommend services or tools you do not need, preferring to use our extensive experience and understanding of the online retail world to set up a targeted plan of action and remediation which will keep your business as secure as it is possible to be. Given the persistence and resilience of cyber attackers there is a remote chance that your system might still be attacked. With a robust plan in place, however, including relevant compliance, then remedial action will be swift and acquiring banks will mitigate their stance.

For more information see:

PCI PFI

Bespoke Penetration Testing

The technology gap which leaves organisations vulnerable to attack

Does outsourcing card processing make you PCI compliant?