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.
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.
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.
Retained Forensic & Incident Response Service: how planning for the worst can add value to your business
By Paul Brennecker, Principal Security Consultant and Lead QSA
Paul Brennecker gave a presentation at PCI London on 5th July 2018 and this article first appeared in that event’s publication.
All too often the engagement of a Forensic Investigator is a distress purchase, made at a time of crisis when a breach has already occurred. Yet, waiting until there is a full blown emergency means organisations are missing out on the added value that specialist Retained Forensics professionals can bring.
Forensic Investigators don’t just operate in a crisis. When engaged to provide a Retained service, they can also help to develop a resilient defence strategy. This combines developing and delivering a full strategic cyber defence plan with Incident Response management. Their strategic guidance and practical knowledge enables them to help organisations reduce the level of impact while also meeting legal and regulatory responsibilities in the event of a breach.
In the event of a breach being reported, the Information Commissioner’s Office has made clear that it will look at the level of security in place, as well as the Incident Response strategy when considering the fines it will impose.
With forward planning it is possible to ensure that you get the maximum return for your investment and also secure the service that is best for your business. In business terms, a distress purchase is defined as a purchase made at some critical point, usually during a failure of other unplanned event. This is like buying a plastic cape when caught out in heavy rain: it is unlikely to be the best waterproof nor the best value for money but the purchase was forced by extreme circumstances. Similarly, that present bought in the late afternoon on Christmas Eve may turn out to be the most expensive gift ever purchased.
In today’s cyber security landscape such critical points come, not surprisingly, when least expected. No one can know when a breach or a security incident will take place. One day you are blissfully unaware of its existence; the next you are in a state of crisis with much to do in a very short period of time. This is particularly the case under the terms of GDPR which requires data breaches to be reported within 72 hours. GDPR also requires that you implement robust breach detection, investigation and internal reporting procedures.
One of the first tasks is to secure and contain the breach – a specialist job which can be time consuming and confusing – and for this an industry specialist must be appointed. There are not a vast number of suppliers to speak to. For example, when it comes to a PCI data breach, there are only eight companies in the UK which hold the necessary certifications required by the acquiring banks.
A cyber mature organisation knows that it is not enough to simply be reactive, however. Their aim is to anticipate the critical point and to scope, develop and implement a company-wide cyber security strategy which is constantly challenged and re-enforced. This type of strategic plan will help to ensure effective business continuity and protect from loss of income and reputation.
Working with a Retained Forensics specialist facilitates this strategic approach; from analysing potential weaknesses, to making detailed plans in the event of a breach. This is done in a number of ways, including through the process of Test and Exercise, starting with automated penetration testing to identify potential vulnerabilities. Manual testing is then employed to exploit and develop these weaknesses so the gaps can be plugged. The synergy of these tests provides valuable intelligence about where existing vulnerabilities lie and helps a business to build a robust defence around them.
The world of cybercrime does not stand still, however, and so defences must be continually reviewed and challenged to ensure they are as up to date as possible. So, although PCI compliance for example, is a vital annual check, it does not claim to guarantee that adequate defences are in place all year round. A more resilient strategy therefore uses a regular Test and Exercise programme to keep the process agile and responsive.
Where it is advisable to go a level deeper, organisations can also consider Red Team engagement. Red Teaming is where highly skilled and trained ethical hackers get into the mind-set of a potential adversary, using a range of tools and strategies. This enables organisations not only to identify where a potential attack might take place but also builds in a level of resilience by identifying where potential future vulnerabilities may lie.
The mature organisation works with Retained Forensics to scope the requirements of their business, making it possible to manage the whole process in a timely and cost-effective manner. While building a robust defence is a priority, making detailed plans for how to handle a crisis is equally important. It is perhaps counter-intuitive to plan for a successful attack, but the maxim ‘expect the best but plan for the worst’ is sound advice. Knowing how to react in the unfortunate event of a data breach is a crucial business benefit. An experienced Retained Forensics company will be able to assist you with your plans and help to stage an event, to get everyone into the right mind-set. If the worst does happen, then staff will have a framework to refer to, ensuring that vital steps are taken and time is not lost.
A Retained Forensics team will also undertake the preparation and testing of Incident Response, Business Continuity and Disaster Recovery plans to ensure they are up to date and ready to swing into play at the first sign of an incident. Not only will they have a detailed knowledge of an organisation’s systems and networks, they will have helped to set up breach notification protocols and mitigation strategies; all of which will already be in line with the requirements of GDPR. In this way any damage and disruption will be swiftly minimised and mediated.
Given the benefits of engaging a Retained Forensics service, it is perhaps surprising that some still overlook it, simply engaging a Forensic Investigator when compelled to in the event of a breach. The reason for this is perhaps that the challenge of managing third parties to achieve and maintain the various data standards and compliance is ever increasing, meaning that the procurement of services to assist in the event of a data breach is often overlooked.
Those who plan for the worst while hoping for the best, however, reap significant benefits and have the time to engage with a professional Retained Forensics service before a crisis occurs. By planning ahead, they ensure that they get the maximum return for their outlay and also secure the service that is the best for their business.
How PCI compliance puts you on course for GDPR
For a long time the General Data Protection Regulation has been looming on the horizon but in just a few short days it will arrive; a permanent aspect of the data protection landscape. From 25th May 2018 this European-wide data protection will be a legal requirement for virtually every UK organisation. The task should not be overwhelming; particularly for those who are already PCI compliant, or working towards it. This is because the PCI compliance process means they are already well on course for GDPR. All that remains is an identification of gaps to bring systems and policies in line with GDPR.
The important thing to bear in mind at this stage is that the GDPR, although aimed at the entirety of an organisation and largely enforceable, is less prescriptive than the PCI DSS standard that already exists. GDPR provides detail about what needs protecting but very little in the way of a solid action plan.
PCI DSS on the other hand offers a detailed framework upon which to build, specifying what needs to be done and how, and even giving regular updates and guidance on reviews. The two complement each other and therefore the GDPR will be best enacted alongside the existing PCI DSS. A further aspect to note, is that a PCI breach will also be a GDPR breach, since the information on your cardholder data environment is subject to regulation by GDPR.
GDPR should not be seen in a negative way. It is a positive piece of legislation which will help to build trust. Similarly, PCI DSS compliance provides you and your customers with peace of mind that data is secure. This is the metaphorical carrot. There is also a stick: those who do not comply and suffer a breach will face loss of customer trust, enforced PFI investigations and fines.
For those that are already compliant with the PCI DSS, an annual review of the data being processed should form an integral part of the project. This ensures that any new technologies or processes are not excluded and ongoing compliance is maintained. Once you have identified the data that GDPR affects, applying the PCI approach to the implementation of the GDPR will assist greatly as the framework is already there. There will still be a few gaps to fully adhere to GDPR so professional advice will be of benefit.
And for those who aren’t PCI compliant? Seeking guidance from a qualified advisor and reviewing the gaps in their documentation, policies, training, IT systems and processes should be a pressing matter.
With one of the largest QSA teams in Europe, SRM provide unrivalled technical and compliance expertise within the PCI arena. Our GDPR team provide a business-focused service to organisations at all ends of the GDPR-readiness spectrum. For help and support, or to discuss any aspect of PCI DSS compliance or GDPR contact Mark Nordstrom at firstname.lastname@example.org or 03450 21 21 51.
To gauge your level of GDPR readiness, complete our free GDPR Self Assessment Questionnaire
For more information on our GDPR services, visit our GDPR page.
To view a recording of our webinar GDPR: the roles of manual and automated penetration testing, click here.
Read more on GDPR related blogs.
PCI DSS: With charities gearing up for contactless payments what could possibly go wrong?
More than 40 organisations, including McMillan Cancer, the NSPCC, the RNLI and the Church of England, have introduced technology which means that donations can be made with a quick tap of a card. But as the charitable sector embraces contactless payments their enthusiasm must be tempered by robust compliance with Payment Card Industry (PCI) standards or they risk a world of pain. Just one whiff of a breach will bring notoriety and loss of reputation, bringing this Brave New World of charitable giving crashing down around their ears.
The driver for this new approach is clear. The NSPCC ran a trial which showed that donations by card are higher, compared to cash donations and Barclaycard has estimated that charities will miss out on £80m a year if they only accept cash donations. Some have gone even further with things like the Helping Heart jacket, developed so digital donations can be made via this piece of clothing worn by collectors to a homeless charity, and the Blue Cross ‘tap dogs’ who wear a vest with a sewn-in pocket that holds a contactless device.
So what could possibly go wrong? Well, firstly, in spite of the benign motivation behind the new approach, there is no getting away from the fact that where there is money, there will be crime. Defences will therefore need to be geared specifically for this new technology or charities will risk fatal damage to their reputations.
Secondly, the regulatory environment is getting more stringent with the implementation of the General Data Protection Regulation (GDPR) on 25th May 2018. In addition, the Payment Card Industry (PCI) continues to be hyper vigilant when it comes to the Data Security Standard (PCI DSS) and it has already proved that charities are not exempt from the full force of the law when it comes to administering fines for non-compliance.
If an incident occurs, swift action is required to minimise the impact of an individual attack. But prevention is always better than cure. Those organisations that retain an information security consultant to assist with PCI compliance and to ensure their defences are robust, will reduce the potential of being breached.
SRM offers a full range of services to protect the online environment. Using a range of tools from penetration testing to vulnerability assessments and network security testing, we enhance risk mitigation and ensure that the online environment of our clients is as robust as it is possible to be. We work extensively with charities and HM Government as well as all shapes and sizes of businesses and organisations across various business sectors. For many we provide a bespoke retained PCI Forensic Investigation (PFI) service, working proactively through regular strategic reviews to develop enhanced risk mitigation. Anticipating the potential risk areas for attack, we provide highly-targeted cost-effective solutions.
Given the constantly evolving world of cybercrime and the ingenuity of hackers, attacks can and do happen, however. But with a retained PFI already familiar with a charity’s systems, remediation is rapid and disruption minimal.
For more information on SRM’s PCI services please visit our website.
Or visit our blog:
Network intrusions are on the increase: time to engage a Retained Forensic specialist
Coinhive attacks and how to prepare for the (almost) inevitable
This week’s report that more than 5,000 websites, including that of the Information Commissioner’s Office (ICO) have been hacked, shows that it really can happen to anyone. Other affected websites where malware took over the processing power of their user’s devices include the Student Loans Company, the council website for Manchester City, Camden and Croydon and the home page of the United States Courts. Although the initial reaction may be one of schadenfreude – pleasure in someone else’s misfortune – a more measured response would be to realise and accept that hackers are now so ingenious and creative that everyone, including those with top class cyber defence, is likely to be subject to attack at some point.
This latest hack involved a piece of cryptocurrency mining malware, called Coinhive, which ran in the background while the webpages of the hacked organisations were open. This forced visitors’ computers to run the mining programme which can then be used to gain small fractions of cryptocurrency from each victim.
So, how can we protect ourselves? The honest answer is that we can’t fully. What we can do, however, is to be prepared for the probability that our systems will be attacked at some point and to reduce the potential impact this will have. Developing a robust Incident Response protocol is an important start and here a Retained Forensic (RF) service will be of immense benefit. With a detailed knowledge of your systems, an RF team is able to mitigate the damage swiftly and effectively.
Damage limitation is crucial but, in the long term, building additional layers of security into your system’s architecture is also key. We need to ensure we are not giving away information without meaning to. We should also consider our defensive architecture but it is important that we balance the need for security with the practical requirement for our systems to be functional and easily navigable.
Achieving this balance is a complex issue. SRM’s VirtualCISO (vCISOtm) service can resource and support the incumbent CISO or DPO in managing this task. From providing expert strategic guidance to taking on the full CISO role, our vCISOtm team has many years’ experience in providing robust yet agile defences. We work with our clients across a range of services including Incident Response, Retained PFI, Digital Forensic Investigation and Security Breach, Incident Management and Containment Support.
To find our more, visit our website or contact Mark Nordstrom on 03450 21 21 51 or email@example.com