Category Archives: Breach Disclosure

Nine lessons for strong incident response and recovery in a data breach

Data breaches are rarely out of the headlines, but the recent proposed fines against BA and Marriott will have pushed this risk back to the forefront for many businesses. Like many security threats, breaches are nothing new; we’ve covered this subject on our blog many times in the past.

A data breach can take many forms; it can involve an employee losing a laptop or mobile device that contains data about an organisation’s employees or customers. It might involve a criminal infiltrating IT systems to steal payment card numbers or bank account details. When the data involved is personally identifiable information, the General Data Protection Regulation comes into play. Under GDPR, organisations must report a breach to the data protection supervisory authority within 72 hours. A look through our archives netted us a valuable haul of nine lessons from past breaches that can help to guide you in forming an incident response plan.

Lesson 1: pay attention to security alerts

Let’s start back in March 2014. News of the now-infamous breach at the US retailer Target was still fresh, having happened the previous November. The security breach resulted in the loss of 40 million payment card details, as well as 70 million other personal records. The kicker? Not long before, Target had installed a network monitoring tool costing a cool $1.6 million. However, operators dismissed its early alerts that could have averted or at least mitigated the subsequent breach. Side note: back in those heady days, data breaches were still things that happened to other people. Our blog quoted the security expert Neira Jones, who confidently predicted that a retailer in the UK or Europe would suffer a data breach before long.

Lesson 2: scammers read the news, too

Fast forward to summer 2015 and the high-profile breach at Ashley Madison. The website’s interesting business model – encouraging extra-marital affairs – meant the loss of more than 30 million personal records had an extra sting. Apart from launching a thousand double entendres (we may have been guilty of a few ourselves), Ashley Madison catapulted the issue of data breaches firmly into the public consciousness. As it turned out, that proved to be a double-edged sword. As our blog writer Lee Munson noted, scammers often take advantage of the publicity surrounding a large breach. He warned companies to watch out for “spam email, identity theft, carefully crafted phishing emails and even potential blackmail attempts”.

Lesson 3: check password re-use

Later that year, four security breaches came to light in one single week. The victims were Experian, Patreon, and Australian retailers Kmart and David Jones. In our blog, we advised being aware of how information can be used against victims. For example, if someone’s password was compromised in one of those breaches, it’s worth checking whether they use the same passwords on other websites.

Lesson 4: check for vulnerability to SQL injection attacks

Soon after, the Chinese toy company Vtech revealed that an unauthorised party had accessed more than six million accounts. That was enough to make it the fourth largest ever breach to that point – however minor by today’s standards. Possibly the least surprising detail in the story was that the attacker used SQL injection to access the data. Lee Munson noted that even in 2015, this was an ancient and well known attack vector.

Lesson 5: employee negligence can lead to breaches too

Not all breaches are the work of external miscreants. ESET estimated that 138,000 smartphones and laptops are left behind in UK bars every year. Let’s leave aside some questionable maths in arriving at such an arresting stat. There’s no denying the risk from leaving devices just lying around when they could well hold personal information. That could include passwords, location history, personal photos and financial information. The survey found that two thirds of lost devices had no security protection. As anyone familiar with data protection and privacy issues will know, encrypting sensitive data is now a must.

Lesson 6: a data security breach can seriously harm your ability to do business

Whatever the source, the steady drip of breaches was starting to have an effect. By early 2016, data breaches ranked second on a listing of the biggest threats to business continuity. TalkTalk, victim of a serious breach the previous year, was a case in point. In the wake of the incident, and the company’s ham-fisted attempts at handling the fallout, a quarter of a million customers took their business elsewhere. Not long after, we covered a separate report that found the cost of online crime had tripled over the previous five years. Lee Munson wrote: “a data breach is not a one-time cost but rather an event that can cause extreme reputational damage (think TalkTalk) or additional loss of revenue when the damage is widespread”.

Lesson 7: mind your language

All too often, companies that have suffered a data breach are quick to throw about phrases like “sophisticated cyberattack”. But it’s often premature and just downright wrong, when any investigation is still ongoing, and the facts are unclear. “It’s hard to escape the suspicion that victim organisations reach for these terms as a shield to deflect blame. By definition, they imply the incident was beyond their means to prevent,” we wrote. Our post carried the headline “Time to remove ‘cyberattack’ from the infosecurity incident response manual?” Our inspiration was the Associated Press Stylebook’s decision to stop using the word cyberattack unless it specifically referred to widespread destruction. As AP lead editor Paula Froke said: “the word is greatly overused for things like hacking”.

That said, positive communication is a key part of any incident response plan. After detailing what word not to use, our post included advice for companies preparing post-incident statements.

  • Deal only in verified facts
  • Avoid speculation
  • Explain the incident in business terms
  • Include details of users or services affected by the breach.

Lesson 8: prepare a security incident response team

By mid-2017, the prospect of GDPR started coming into view, and the need to handle breaches appropriately started becoming clear. Senior management must lead the response efforts. “This is a business issue, not an IT problem,” said Brian Honan, who was speaking at an awareness-raising event. Brian recommended that organisations should assemble an incident response team from across all business functions. Ideally, the team should include people from:

  • IT operations (because they know how data storage systems work)
  • HR (because a data breach could involve staff data, or because a member of staff may have caused the breach inadvertently or deliberately)
  • Legal (because GDPR obliges organisations to notify the regulator)
  • PR or communications (because the company will need to deliver accurate messages to external stakeholders, the media, or internal staff as appropriate)
  • Facilities management (because the organisation may need to recover breach evidence from CCTV or swipe card systems).

Lesson 9: test the security incident response plan

The most critical lesson is to develop and test their incident response processes in advance. Speaking at the same GDPR event, Brian stressed that companies shouldn’t wait for a breach to happen before testing how its policies work. “Find out in advance how well your team works when an incident occurs. Carry out table-top exercises and scenario planning. It is important to have processes and infrastructure in place to respond to a security breach. Developing your incident response plan while responding to a security breach is not the best time to do it,” he said.

Our trawling expedition proves it’s worth planning for something even when you don’t intend for it to happen. The steps we’ve outlined here should help you to recover from a data breach or security incident faster.

If you would like to evaluate your breach response, see our risk assessment services page for more information. Or, if you need guidance in developing a structured incident response plan, contact us.

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Security awareness training: a constant in a changing world

There are two schools of thought when it comes to users and cybersecurity. Some people working in the industry think of users as the weakest link. We prefer to see them as the first line of defence. Cybersecurity training programmes can address staff shortcomings in knowledge, promote positive behaviour and equip non-experts with enough information to be able to spot potential threats or scams.

In our previous post, we looked back through the BH Consulting blog archives to trace the evolution of ransomware. This time, we’ve gone digging for a less technical threat. Instead, it’s a constant challenge for any infosec professional: security awareness.

Training shortfall

Back in April 2014, we reported on a survey which found that just 44 per cent of employees received cybersecurity training. David Monahan, research director with Enterprise Management Associates, summed up the issue perfectly:

“Without training, people will click on links in email and release sensitive information in any number of ways. In most cases they don’t realise what they are doing is wrong until a third-party makes them aware of it. In reality, organisations that fail to train their people are doing their business, their personnel and, quite frankly, the Internet as a whole a disservice because their employees’ not only make poor security decisions at work but also at home on their personal computing devices as well.”

One year later, little had changed. In a post from April 2015, Lee Munson covered a survey by SpectorSoft of 772 IT security professionals. “Not only do many firms have staff who lack even a basic level of security awareness they often, as the report concludes, have poorly trained staff too, with many of the survey respondents citing a lack of expertise as being a significant problem in terms of defending against insider threats.”

Accidents will happen

At least the post acknowledged that damage can sometimes be the result of accidental actions. Too often, security vendors throw around phrases like ‘insider threat’ that, intentionally or not, tar all user actions as malicious.

But could it be that some people are just naturally more susceptible to spilling the beans? Another post from April 2015 reported on a study from Iowa State University that claimed to spot which people are likely to fall for social engineering tricks that cybercriminals often use. It did this by analysing brainwaves. People with low levels of self control were more likely to reveal confidential information like company secrets, the researcher observed.

That’s not, admittedly, an approach many companies could take in practice, but it couldn’t hurt to ask some targeted questions at interview stage.

In June of that year, a UK Government survey found that the number of breaches had increased year on year. The findings also showed that more businesses large and small were providing ongoing security awareness training to their staff compared to the previous year. Despite that, many of the organisations surveyed also saw an increase in staff-related security breaches during the same period.

Must try harder

As Lee Munson wrote: “While budgets and technical controls obviously come into play and affect an organisation’s ability to protect its digital assets, the human aspect still appears to be the area requiring the most work. Staff training and awareness programmes are known to be effective but many companies do not appear to have leveraged them to their full potential.”

Another post put the need for cybersecurity training and awareness squarely into perspective. Security company Proofpoint showed the extent to which attackers aim for an organisation’s human resources rather than its technical defences. Its report found that people still click on 4 per cent of malicious links they find in emails. BH Consulting’s regular blogger Lee Munson found this to be a surprisingly high figure. “Attackers employ psychology to improve the chances of their attacks succeeding,” he wrote.

And if at first you don’t succeed? A post from early in 2016 suggested a radical approach to poor security behaviour: disciplinary measures. The blog quoted a survey by Nuix which determined that human behaviour was the biggest threat to an organisation’s security. It said corporations would tolerate risky behaviour less, and would likely penalise staff who “invite a data breach”. That’s one way to “encourage” people to show better security behaviour.

Communication breakdown

Lee rightly raised the question of whether companies have sufficiently communicated their security policies and procedures in the first place. “So, if companies (including yours) are going to penalise employees for not being up to date on all of their security policies, who is going to police the writing and dissemination of those documents in the first place?”.

The message is that security policies need to be clear, so that even a non-technical member of staff can:

  • Understand them
  • Act on them
  • Remember them.

Taken as a whole, the blogs show that while cybersecurity training is a valuable exercise, it’s got to be delivered in a way that the intended audience will understand.

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GDPR one year on

May 2019 marks the first anniversary since the General Data Protection Regulation came into force. What has changed in the world of privacy and data protection since then? BH Consulting looks at some of the developments around data breaches, and we briefly outline some of the high-profile cases that could impact on local interpretation of the GDPR.

Breach reporting – myths and misconceptions

Amongst the most immediate and visible impacts of the GDPR was the requirement to report data breaches to the supervisory authority. In the context of GDPR, a personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. The regulation introduced a duty on all organisations to report personal data breaches to the supervisory authority where they are likely to pose a risk to data subjects. This report must take place within 72 hours of the controller becoming aware of the breach, where feasible. There are additional obligations to report the breach to data subjects, without undue delay, if the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms.

Between May 2018 when GDPR came into force, and January 2019, there were 41,502 personal data breaches reported across Europe, according to figures from the European Data Protection Board. In Ireland, the Data Protection Commission recorded 3,542 valid data security breaches from 25 May to 31 December 2018. This was a 70 per cent increase in reported valid data breaches compared to 2017.

Notwithstanding the uptick in the number of reported breaches, it has been suggested that many organisations are still unsure how to spot a data breach, when a breach may meet the criteria for reporting, or even how to go about reporting. With this in mind, the key lessons to consider are:

Not every breach needs to be reported

Organisations controlling and processing personal data should have a process in place to assess the risks to data subjects if a breach occurs. This assessment should focus on the severity and likelihood of the potential negative consequences of the breach on the data subject.

Assess the risks

When assessing whether to report, the controller will need to consider the type of breach, sensitivity and volume of the personal data involved, how easily individuals can be identified from it, the potential consequences and the characteristics of the individual or the controller (such as if the data relates to children or it involves medical information).

Who’s reporting first?

It’s possible the supervisory authority may hear about the breach from other sources including the media or affected data subjects. If this is the case, an authority such as the DPC may reach out to the affected organisation first, even before that entity has reported.

Establish the facts

As a final point, it is important not to forget that, even if you do not need to report a breach, the GDPR requires you to document the facts relating to it, its effects and remedial action taken. Therefore, you should keep a record should of all privacy incidents, even if they do not rise to a reportable level. This will help you learn from any mistakes and to meet accountability obligations.

Points to note

Keep in mind that it is not just about reporting a breach; organisations must also contain the breach, attempt to mitigate its negative effects, evaluate what happened, and prevent a repeat.

Breach reporting myths

Several misconceptions quickly emerged about GDPR, so here is a short primer to clarify them:

  1. Not all data breaches need to be reported to the supervisory authority
  2. Not all details need to be provided as soon as a data breach occurs
  3. Human error can be a source of a data breach
  4. Breach reporting is not all about punishing organisations
  5. Fines are not necessarily automatic or large if you don’t report in time

Resource cost – beyond the obvious

There have been a limited number of GDPR-related fines to date (see below) but this amount is likely to increase. Aside from financial penalties relating to breaches, organisations and businesses also need to consider the cost involved in complying with the regulation more generally.

This includes the resources needed to engage with a supervisory authority like the Data Protection Commission, as well as the amount of time it typically takes to manage a subject access request (SAR). The number of SARs is increasing because GDPR allows individuals to make a request free of charge.

GDPR enforcement actions: Google

In the runup to May 25 2018, there had been significant doubts about effective enforcement of the GDPR. If the seemingly invulnerable American social media and technology giants were able to ignore requirements without consequence, what would happen to the credibility and enforceability elsewhere? But against the current global backdrop, those technology companies have become far less invulnerable than they once seemed. Most cases are still making their way through the appeals procedure, but initial verdicts and sanctions are causing ripples for everyone within scope.

On January 21, 2019, the French Supervisory Authority for data protection (CNIL) fined Google €50 million for GDPR violations – the largest data protection fine ever imposed. The case raises several important privacy issues and provides useful insights into how one supervisory authority interprets the GDPR.

CNIL’s decision focuses on two main aspects: (i) violation of Google’s transparency obligations under the GDPR (specifically under Articles 12 and 13) and (ii) the lack of a legal basis for processing personal data (a requirement under Article 6). The CNIL is of the opinion that the consent obtained by Google does not meet the requirements for consent under the GDPR. Google is appealing the decision.

The decision dismisses the application of the GDPR’s one-stop-shop mechanism by holding that Google Ireland Limited is not Google’s main establishment in the EU (which would have made Ireland’s DPC the competent authority, rather than the CNIL). Since the fine is more than €2 million, it is clearly based on the turnover of Alphabet, Google’s holding company in the United States, not on any European entity.

GDPR enforcement actions: Facebook

On 7 February, Germany’s competition law regulator, FCO, concluded a lengthy investigation into Facebook and found that the company abused its dominant market position by making the use of its social network conditional on the collection of user data from multiple sources.

Facebook has not been fined; instead, the FCO imposed restrictions on its processing of user data from private users based in Germany. Facebook-owned services such as WhatsApp and Instagram may continue to collect data but assigning that data to a Facebook user account will only be possible with the user’s voluntary consent. Collecting data from third party websites and assigning it to a Facebook user account will also only be possible with a user’s voluntary consent.

Facebook is required to implement a type of internal unbundling; it can no longer make use of its social network conditional on agreeing to its current data collection and sharing practices relating to its other services or to third party apps and websites. Facebook intends to appeal this landmark decision under both competition and data protection law in the EU.

Other enforcement actions

After Birmingham Magistrates’ Court fined workers in two separate cases for breaching data protection laws, the UK Information Commissioner’s Office warned that employees could face a criminal prosecution if they access or share personal data without a valid reason.

The first hospital GDPR violation penalty was issued in Portugal after the Portuguese supervisory authority audited the hospital and discovered 985 hospital employees had access rights to sensitive patient health information when there were only 296 physicians employed by the hospital. The failure to implement appropriate access controls is a violation of the GDPR, and the hospital was fined €400,000 for the violations.

Lessons from year one

For data controllers and processors, the lessons to be learned from the first year of GDPR are clear:

Transparency is key

You must give users clear, concise, easily accessible information to allow them to understand fully the extent of the processing of their data. Without this information, it is unlikely any consent we collect will be considered to be a GDPR level of consent.

Fines can be large

CNIL’s response to Google demonstrates that regulators will get tough when it comes to fines and take several factors into account when determining the level of fine.

Watch the investigations

There are current 250 ongoing investigations – 200 from complaints or breaches and 50 opened independently by the data protections authorities so these will be interesting to watch in 2019.

Lead Supervisory Authority identity

Google and Facebook have both appointed the DPC in Ireland as their lead supervisory authority and have included this in the appeals process. CNIL took the lead in Google investigation, even though Google has its EU headquarters in Ireland – because the complaints were made against Google LLC (the American entity) in France.

Further challenges

There are further challenges to the way for the tech giants use personal data show no sign of dwindling. A complaint has been filed with Austria’s data protection office in respect of a breach of Article 15 GDPR, relating to users of Amazon, Apple, Netflix, Google (again) and Spotify being unable to access their data. 2019 should be an interesting year for Privacy.

What lies ahead?

The GDPR cannot be seen in isolation; it emerged at the same time as a growing public movement that frames privacy as a fundamental right. The research company Gartner identified digital ethics and privacy as one of its top trends for 2019. From a legislative perspective, the GDPR is part of a framework aimed at making privacy protection more robust.

PECR is the short form of the Privacy and Electronic Communications (EC Directive) Regulations 2003. They implement the e-privacy directive and they sit alongside the Data Protection Act and the GDPR. They give people specific privacy rights on electronic communications and they contain specific rules on marketing calls, emails, texts and faxes, cookies and similar technologies, keeping communications services secure and customer privacy relating to traffic and location data, itemised billing, line identification, and directory listings.

Further afield in the US, the California Consumer Privacy Act (CCPA) was signed into law in June 2018 and will come into effect on 1 January 2020. It’s intended to give California residents the right to know what personal data is being collected about them, and whether that information is sold or disclosed. Many observers believe the Act will trigger other U.S. states to follow suit.

For the remainder of 2019 and beyond, it promises to be an interesting time for privacy and data protection.

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Security roundup: May 2019

We round up interesting research and reporting about security and privacy from around the web. This month: password practice, GDPR birthday, c-suite risk, and further reading for security pros.

Passwords: a good day to try hard

No self-respecting security pro would use easy passwords, but could they say the same for their colleagues (i.e. everyone else)? The answer is no, according to the UK National Cyber Security Centre. It released a list of the 100,000 most hacked passwords, as found in Troy Hunt’s ‘Have I Been Pwned’ data set of breached accounts. Unsurprisingly, ‘123456’ topped the list. A massive 23 million accounts use this flimsy string as “protection” (in the loosest possible sense of the word). Next on the list of shame was the almost as unimaginative ‘123456789’, ‘qwerty’, ‘password’ and 1111111.

The NCSC released the list for two reasons: firstly to prompt people to choose better passwords. Secondly, to allow sysadmins to set up blacklists to block people in their organisations from choosing any of these terrible passwords for themselves. The list is available as a .txt file here and the agency blogged about the findings to give more context. Help Net Security has a good summary of the study. The NCSC published the research in the buildup to World Password Day on May 2, which Euro Security Watch said should be every day.

WP Engine recently performed its own analysis of 10 million compromised passwords, including some belonging to prominent (and anonymised) victims. It makes a useful companion piece to the NCSC study by looking at people’s reasons for choosing certain passwords.

Encouraging better security behaviour through knowledge is one part of the job; effective security controls are another. In April, Microsoft said it will stop forcing password resets for Windows 10 and Windows Server because forcing resets doesn’t improve security. CNet’s report of this development noted Microsoft’s unique position of influence, given its software powers almost 80 per cent of the world’s computers. We recently blogged about what the new FIDO2 authentication standard could mean for passwords. Better to use two-factor authentication where possible. Google’s Mark Risher has explained that 2FA offers much more effective protection against risks like phishing.

GDPRversary getting closer

Almost one year on from when the General Data Protection Regulation came into force, we’re still getting to grips with its implications. The European Data Protection Supervisor, Giovanni Buttarelli, has weighed in on the state of GDPR adoption. He covered many areas in an interview with Digiday, including consent, fines, and legitimate interest. One comment we liked was how falling into line with the regulation is an ongoing activity, not a one-time target to hit. “Compliance is a continued working progress for everyone,” he said.

The European Data Protection Board (formerly known as the Article 29 Working Group) recently issued draft guidance on an appropriate legal basis and contractual obligations in the context of providing online services to data subjects. This is a public consultation period that runs until May 24.

The EDPB is also reportedly planning to publish accreditation requirements this summer. As yet, there are no approved GDPR certification schemes or accreditation bodies, but that looks set to change. The UK regulator recently published its own information about certification and codes of conduct.

Meanwhile, Ireland’s Data Protection Commission has started a podcast called Know Your Data. The short episodes have content that mixes information for data controllers and processors, and more general information for data subjects (ie, everyone).

Breaching the c-suite

Senior management are in attackers’ crosshairs as never before, and 12 times more likely to be targeted in social engineering incidents than in years past. That is one of the many highlights from the 2019 Verizon Data Breach Investigations Report. Almost seven out of ten attacks were by outsiders, while just over a third involved internal parties. Just over half of security breaches featured hacking; social engineering was a tactic in 33 per cent of cases. Errors were the cause of 21 per cent of breaches, while 15 per cent were attributed to misuse by authorised users.

Financial intent was behind 12 per cent of all the listed data breaches, and corporate espionage was another motive. As a result, there is a “critical” need for organisations to make all employees aware of the potential threat of cybercrime, Computer Weekly said. ThreatPost reported that executives are six times more likely to be a target of social engineering than a year ago.

Some sites like ZDNet led with another finding: that nation-state attackers are responsible for a rising proportion of breaches (23 per cent, up from 12 per cent a year ago). It also highlighted the role of system admin issues that subsequently led to breaches in cloud storage platforms. Careless mistakes like misconfiguration and publishing errors also left data at risk of access by cybercriminals.

The Verizon DBIR is one of the most authoritative sources of security information. Its content is punchy, backed by a mine of informative stats to help technology professionals and business leaders plan their security strategies. The analysis derives from 41,000 reported cybersecurity incidents and 2,000 data breaches, featuring contributions from 73 public and private organisations across the globe, including Ireland’s Irisscert. The full report and executive summary are free to download here.

Links we liked

Challenge your preconceptions: a new paper argues cybersecurity isn’t important. MORE

An unfortunate trend that needs to change: security pros think users are stupid. MORE

It’s time to panic about privacy, argues the New York Times in this interactive piece. MORE

Want a career in cybersecurity, or know someone who does? Free training material here. MORE

NIST has developed a comprehensive new tool for finding flaws in high-risk software. MORE

NIST also issued guidelines for vetting the security of mobile applications. MORE

Cybersecurity threats: perception versus reality as reported by AT&T Security. MORE

Here’s a technical deep dive into how phishing kits are evolving, courtesy of ZScaler. MORE

A P2P flaw exposes millions of IoT security cameras and other devices to risks. MORE

A new way to improve network security by analysing compressed traffic. MORE

 

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