GDPR

Why is a Business Continuity Plan important?

Why is a Business Continuity Plan important? It’s simple: because a business’ ability to recover from a cyber breach hinges on its ability to react quickly. Since the enactment of GDPR earlier this year, it is now a statutory requirement that a breach is reported within 72 hours of its discovery. But this is not the only thing to consider. As soon as a breach is identified, certain steps need to be taken to contain and mitigate the extent of the breach to safeguard the future of the business. This process will run much more smoothly if all aspects of the strategy are well known to those responsible and have been pre-planned and pre-agreed.

The impact of a breach is often significantly wider than people first think. It is not necessarily just about money or data being stolen, or the fines imposed by the Information Commissioner’s Office (ICO) as a result, but about the longer-term impact. Loss of trust and reputation can be equally, if not more, damaging over the following months and years.

So, with the threat of a successful (and costly) cyberattack being very real, what can be done? Well, firstly, and perhaps counter-intuitively, the most important thing is to accept the risk and plan for a worst-case scenario. Every robust defence should therefore include a Business Continuity Plan (BCP) which includes Incident Response (IR) and Disaster Recovery (DR) plans. These plans should be continually challenged and reviewed, and correctly-scoped simulation exercises will ensure that all key personnel are experienced in the steps that need to be taken.

However, this is just one piece of the business continuity puzzle. Evaluating your company’s ability to restore IT operations can be a good starting point for company-wide Business Continuity Plan. In fact, many business continuity planning efforts start by conducting a business impact analysis or risk assessment. These studies can reveal weaknesses in your organisation’s ability to continue operations that go far beyond IT. Good business continuity and disaster recovery planning should look at the business as a whole, with a goal to develop business resilience.

Of course, for most businesses in 2018, having a robust cyber defence is the first step and every precaution should be taken to ensure that potential hackers and cyber criminals are kept at bay. It seems reasonable to assume that the harder we make it, the less likely a hacker is to focus their attention on us. They will look to easier targets. But the sad truth about today’s digital environment is that breaches can and do occur, even to the best-defended organisations. After all, it can only take one employee to mistakenly open a phishing email to provide a potential hacker with a route in to an otherwise well-protected system.

Why is a Business Continuity plan important? Because speed is of the essence. The more quickly a breach can be identified and contained the less damage it will cause.

To discuss Business Continuity planning, contact the SRM team on 03450 21 21 51

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To find out more visit our website.

Or read more:

Cyber insurance may be null and void without ‘due care’

Cyber resilience: it’s a board level issue

The key to GDPR is common sense

 

Why get ISO27001 certification?

We are sometimes asked the question, why get ISO27001 certification? The answer is that the ISO standard, and ISO 27001 compliance in particular, demonstrates that your organisation takes information security seriously. This ultimately enhances your reputation and delivers greater business opportunities because ISO27001 lowers the risk for other people of doing business with you.

Certification means a third party accredited independent auditor has performed an assessment of all processes and controls and confirms that operations are in alignment with the comprehensive ISO27001 certification standard. If a company is implementing ISO27001, it demonstrates that careful consideration has been given to what could endanger confidentiality, integrity and the availability of information. Once those risks are known, it is about ensuring that security measures have been implemented in order to decrease them to an acceptable level.

Another benefit of this certification is that, unlike GDPR, which does not have an actual compliance process, ISO27001 provides very clear direction. In this way it can be a useful starting point for ongoing adherence to GDPR. ISO27001 concentrates on policies and processes, including all legal, physical and technical controls involved in an organisation’s information risk management processes. Its value is that it creates a robust environment to protect both staff and customer information assets. But of equal value is the fact that it also provides evidence to potential customers and partner organisations that your company prioritises the security of the information it holds.

Of course, undertaking compliance with ISO27001 can be a rather intimidating prospect.  The ISO standards require risk assessments to be conducted, together with the design and implementation of a comprehensive suite of information security controls. It also requires other forms of risk management to address company and architecture security risks on an ongoing basis. This involves the implementation of any necessary changes to policies and processes (ISO27001) and controls (ISO27002). A cost-effective way to negotiate the rigours of the ISO27001 accreditation process is to seek professional help from specialists with proven track record in achieving the standard.

If you are wondering ‘why get ISO27001 certification?’ you should discuss your requirements with us. The SRM team are experienced in all aspects of ISO27001 accreditation. Starting with a gap analysis which establishes a level of security readiness, we can recommend a prioritised remediation plan based on what gaps there are. We are able to assist with any activities that need to be undertaken and provide guidance all the way up to a pre-audit assessment. Finally, our team can offer on-site audit support if needed, to give you complete peace of mind that your organisation’s ISO 27001 accreditation is achieved and maintained.

To discuss ISO27001 or other certifications, contact the SRM team on 03450 21 21 51.

To receive regular blogs on topics relating to information security, follow us on Linkedin.

To find out more visit our website.

Or read more:

The NIS Directive: who does it apply to and what will it mean?

Cyber resilience: it’s a board level issue

Schools are being targeted by cyber criminals: 6 ways to shore up online defences

In 2017 the Independent Schools’ Bursars Association (ISBA), which supports over 1,000 senior management staff in schools, stated that cyberattacks in schools can no longer be considered ‘isolated incidents’. ISBA’s Chief Exec David Woodgate went on to say that he is concerned that fraudsters are ‘one step ahead’.

He is absolutely right. While schools lag behind universities in their approach to cyber defence, cyber criminals are constantly evolving and refining their skills. Unlike most people employed in the education system, they do not have day jobs to distract their focus. So what can school authorities do to protect against such ingenious criminal minds? Here are six important things to consider.

1. Accept responsibility

Firstly, school boards must embrace the responsibility. A Department for Education spokesperson recently reiterated that ‘schools are directly responsible for the security of all digital information they collate, store and retain.’ This does not, however, simply refer to the IT department but should extend to the board of governors, the school administrators, the staff, the pupils and the parents. Above all, however, it is the senior leadership that is responsible for safeguarding in schools and, as such, cyber security should be on the agenda at every meeting of school governors and senior teams.

2. Know your system

Knowing precisely what hardware and software is being used on the networks is important but senior leadership should also ensure that configuration changes are authorised, documented and implemented appropriately. It is crucial that only approved users can make changes. Software updates and security patches should also be implemented quickly, and systems monitored for unusual activity which could be an indication of an intruder. Criminal incidents should be reported to the police. Breaches must be reported to the relevant statutory authorities within 72 hours under the terms of GDPR.

3. Control user profiles

Access to sensitive information should only be given to specific individuals. Wherever possible, the ability to share information should also be limited to these specified people. Where individuals are provided with access, their privileges should be managed, and they should be provided with the minimum level of access required to do their job. When staff leave, their access should be revoked promptly.

4. Protect the system

Strong firewalls and internet gateways should be in place to protect school networks and these should be constantly monitored and regularly tested.

It is essential to ensure that antivirus software and security mechanisms are up to date and that protocols for frequent password changes and the use of multifactor authentication for sensitive information is enforced.  This means that if a criminal does obtain access to a system, their progress is stalled by encryption tools.

It is not just the internal system which requires protection. Consider the physical security of a system: the hard drives, internet routers, servers and other devices on which data can be stored. School equipment can be targeted by thieves during holiday periods so any device holding sensitive data should be encrypted and stored in an appropriate security cabinet constructed for the purpose.

It is also advisable to limit the use of public-cloud-based services such as OneDrive and Dropbox as well as the widespread use of portable storage devices such as SD cards and memory sticks but, if there is no alternative, such mechanisms must use strong encryption and robust key management procedures.

5. Invest in expertise

The school bursar is not expected to be solely responsible for every aspect of financial planning. Professional accountancy firms provide additional resource and support. In a similar way, those responsible for a school’s data protection require support at both the strategic and practical levels from industry specialists.

6. Be proactive

Rather than wait for a cybercriminal to test the school’s defences, be proactive: conduct regular penetration testing on the system. When done correctly, this is not an off-the-shelf exercise, but employs a synergy of automated and manual testing to deliver the best results. A specialist consultancy will be able to scope the exercise and conduct the testing in a cost-effective and non-disruptive manner.

Red Team engagement can prove highly useful to further investigate vulnerabilities that have been identified. By using simulated exercises around social engineering, all staff can be briefed on best practise, and their role in the team, should an incident arise. The intelligence gained from these exercises means that a proactive and robust defence can be developed, protecting your data as well as your reputation.

To discuss improving your cyber resilience, contact the SRM team on 03450 21 21 51

To receive regular blogs on topics relating to information security, follow us on Linkedin.

To find out more visit our website.

Or read more:

How phishing scams are getting schools in deep water

Cyber resilience: it’s a board level issue

The key to GDPR is common sense

GDPR and data security in the gambling industry

This article first appeared in the Q3 edition of Casino & Gaming International  (CGi )(www.cgimagazine.com/latestedition) and appears here with their kind permission.

As the implications of the General Data Protection Regulation sink in, Paul Brennecker examines its impact on the gambling industry and explains how it is not simply a compliance exercise but an industry-wide altered mind-set that is the key to effective data security.

BACKGROUND

The gambling industry has always been a target for criminals, both in reality and in fiction. From The Sting to Ocean’s Eleven and Lock, Stock and Two Smoking Barrels, the world of cinema has long relished the idea of cunning criminals taking on the casino and winning. There is something inherently satisfying about attractive and engaging rogues beating seemingly anonymous gambling enterprises in what is perceived to be an almost victim-less crime. In the fictional world of Hollywood, the inevitable sequels roll out reflecting, probably unintentionally, the reality of the situation: that repeated breaches are increasingly experienced by casinos and gaming enterprises. What they do not necessarily show, however, is the other reality: that in the new era of online gambling the victims are very real. They are the individuals whose personal data is stolen.

Cyber-attacks come in many forms but they can broadly be categorised into those that disrupt operations, such as distributed denial of service (DDOS) attacks, where infected computers flood the network with traffic. There are also those that are aimed at data theft, targeting customer data, especially financial information like credit card details, which can be sold on the dark web or used for identity fraud, and ransomware attacks. This type of credential abuse is particularly concerning in the gaming industry because it leads to loss of reputation and clients transferring their online business to other providers.

Although the adversarial threat is significant, the threat posed by insiders, often trusted employees, can pose an even greater risk to a business. With privileged access employees can intentionally or unintentionally be involved in a targeted breach of data. Staff in the gambling industry have a tendency to switch roles between competitors, requiring a robust ‘Joiners, Movers, Leavers’ process. It also necessitates a heightened awareness of data leakage from within each organisation.

GDPR & PCI DSS

Under the new GDPR framework which became EU law in May of this year, in the event of a data breach, firms can be fined up to 4% of revenue (or 20m Euros, whichever is higher). Since the terms of GDPR were first known, much has been written about it and the impact it has on the way companies manage their data. Yet, there is an important misconception which need to be addressed.

Contrary to current public perception, there is actually no such thing as GDPR compliance. It is a regulation which requires data systems to be safe but it is open to interpretation and provides nothing in the way of detailed guidance. Nor is there an annual review to validate compliance.

On the other hand, the Payment Card Industry (PCI) Data Security Standard (DSS), which regulates the gaming industry to ensure that payment card details are used with best practice and kept secure, does provide a detailed framework which specifies what needs to be done and how. PCI DSS even provides regular updates and guidance on reviews. Those who are PCI DSS compliant are therefore well on the way to meeting the requirements of GDPR. It is the role of Chief Information Security Officers (CISOs), Data Protection Officers (DPOs) and their advisers to work out where the gaps exist to ensure that an organisation adheres to GDPR in practice.

While the PCI DSS compliance process is undeniably useful, it must be likened to an MOT; it only applies to a given moment in time.  One ill-conceived change of control request or alteration to the process can render that compliance invalid. Ongoing testing and maintenance is essential and this is best managed through an altered corporate mind-set which embeds data security at every level of the organisation.

A BOARD LEVEL APPROACH TO EFFECTIVE DATA SECURITY

GDPR and PCI DSS complement one another and, if managed holistically, can deliver immense benefits to efficiency and reputation, while also mitigating the potential damage of a breach. But given the fact that PCI DSS compliance simply provides validation of compliance at a given moment in time, the key to data security is not to focus on specific compliance targets, following a tick box exercise once a year, but to develop a corporate mind-set which features a ‘compliance out of the box’ approach and has ongoing updating and maintenance built in.

This altered mind-set requires a company-wide strategy which is developed at board level and then disseminated in practical, simple form to each and every employee or partner of the business. For this to be a realistic goal, the responsibility for data security cannot simply be devolved to the CISO or DPO; nor should it be seen as something which is only in the scope of the IT department. To be truly effective, it is the responsibility of the each and every member of the board to drive and oversee the organisation’s data security responsibilities. Data security should be on the agenda at every board meeting.

Realistically, however, given the complexity of data security and compliance processes, specific ownership will be in the hands of these technically qualified individuals. Yet they will not be able to effectively exert influence at board level unless they are provided with the specialist support and resource. Much like the support provided to the financial department by corporate accountants or the support given to the legal department by specialist legal teams, the CISO needs to have access to specialist data security support to provide strategic guidance and technical abilities to enhance the scope of the operation.

THE ROLE OF PENETRATION TESTING, RED TEAMING AND RETAINED FORENSICS IN DEVELOPING A DATA SECURITY STRATEGY

One of the key elements of data security is the development of a robust defence strategy. It is not enough, however, to develop a strategy and build a defence based on what is already known. Cyber criminals are ingenious and exploit not simply known threats and vulnerabilities, but they also have ways to detect those which are not yet known or understood. Those who only use their own understanding to develop a defence will therefore be limited by the extent of their own knowledge. Testing and challenging that knowledge on an ongoing basis is an essential element. This is where a continual programme of Threat Monitoring, Penetration Testing and the use of Retained Forensics comes in.

Threat monitoring is the process of observing the changing nature of cyber-attacks. All commercial websites will be probed for vulnerabilities, initially by automated tools and once something significant is found, a more concerted manual attack may be launched. Having alerts and being set up to monitor the nature of these attacks and countering them is essential for players in the online gaming space.

The next step is regular Penetration Testing, which needs to include both automated and manual elements. After all, the criminal community uses both advanced scanning tools to identify potential areas of weakness as well as the additional sophistication of the human mind to develop and explore these vulnerabilities.

Imagine a room with an almost limitless number of doors. The automated penetration test will identify which doors conceal potential vulnerabilities. The manual tester then prises these doors open and looks at what is behind them.

Taking the analogy a step further, Red Teaming will push the doors wide open and delve and explore into what is behind them. Red Team testers have ethical hacking qualifications from industry respected bodies such as CREST and OSCP and use their sophisticated skills to root around and uncover hitherto unforeseen vulnerabilities.

Armed with this information, the process of closing off potential opportunities for cyber criminals before they are even exposed can begin. In this way a data security strategy can be developed which anticipates vulnerabilities before they are discovered, rather than simply reacting to those which are already known.

These experts will work in partnership with a specialist Retained Team to manage the defence process. In some specialist consultancies the Red Team will also be part of the Retained Forensic capability to help ensure that the process is be an ongoing one, with regular exposure to testing built in. Engaging a Retained Forensics team not only assists in managing a continually evolving the strategic defence but builds in resilience to potential attack.

Given the unrelenting ingenuity of attackers, it is impossible to ever consider an organisation to be immune from attack. The strategy should therefore include detailed plans if this eventuality occurs, particularly for the prompt reporting in the event of a breach. GDPR requires any breach to be reported to the relevant regulatory authority within 72 hours and failure to do so will result in punitive action being taken.

When it comes to issues of business continuity, disaster recovery and containment, having a Retained Forensics team on hand, with a thorough knowledge of the organisation’s systems, means they will be able to manage this process swiftly, thereby limiting any potential damage.

It is also worth noting that not only will the engagement of a Retained Forensics team facilitate the ongoing testing of system security and provide strategic intelligence for effective maintenance and development, it also demonstrates to the relevant authorities that a robust, ongoing process is in place, thereby reducing the level of potential fines.

IN SUMMARY

GDPR should not be considered an encumbrance or an onerous chore. It has been developed to build in safeguards to data security systems protecting both the organisations and their customers from cybercrime. Those who embrace it with enthusiasm, building an ongoing test and exercise regime into their systems, will benefit from enhanced reputation and customer loyalty. Those who make data security the responsibility of all members of the board and who develop a constantly evolving defence strategy can demonstrate to both customers and the regulatory authorities that they take security seriously. They are also in the best possible shape to resist potential attacks, or deflect or reduce the impact of one, making an investment in GDPR and cyber resilience a sound business decision.

Cyber insurance may be null and void without ‘due care’

There is a worrying trend in the world of cyber safety. Many companies believe that cyber insurance will protect against any damage associated with a breach. It is vital that senior board members are aware, however, that if they fail to take reasonable precautions their insurance investment could well be null and void.

Leading business insurer Allianz estimates that the cyber insurance market in Europe alone is on track to be worth nearly $1 billion by the end of 2018, mirroring the rapid expansion of the US cyber insurance market. Although the global insurance industry sees it as a valuable new market full of opportunity they are, predictably, measuring their response with caution.

Cyber insurance has, in the past, been considered a safety net in the event of a breach. But as the incidence of cyber breaches continues to rise so has the level of caution demonstrated by both the government and the insurance industry. In fact, while governments are promoting the cyber insurance market, especially in the US and the UK, they are also using the insurance market as a lever to drive much needed cyber security improvements in the business sector.

According to Phil Huggins, Vice President of Security Science at Stroz Friedberg: ‘Their [the government’s] expectation is that this will align risk assessments with good practice, while incentivising good risk management, thereby reducing the need for direct government involvement and regulation. The recent launch by the UK Government of the ‘UK cyber security: the role of insurance in managing and mitigating the risk’ report is just the latest manifestation of this strategy.’

The strategy is working. Insurers are incentivising behaviours that reduce the potential for harm, including the term ‘due care’. This refers to the precautions ‘a person of ordinary prudence’ would take to safeguard their systems. Demonstrable cyber resilience has become a requirement for cyber insurance and this in turn is driving an increased demand for Retained Forensics.

The essence of Retained Forensics is to develop cyber resilience through the engagement of a small team of industry professionals who are fully briefed about the scope of an organisation’s network and infrastructure. This enables them to:

  • establish, direct and manage a full test and exercise programme;
  • ensure high level management of cyber defences across all network and infrastructure;
  • be on hand and ready to assist in putting the agreed action plan in place in the event of a breach. In this way, the 72 hour reporting element of GDPR will be achievable and the mitigation process will be well in hand before the deadline.

SRM has an international reputation for providing the full range of Retained Forensics services including automated and manual penetration testing, Red Teaming, Incident Management, Disaster Recovery and Business Continuity Management. Through Retained Forensics, ‘due care’ can be demonstrated making an organisation not only less likely to suffer a breach, but able to demonstrate best practice in the event of an insurance claim.

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Or check out our recent blogs:

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