Document and Review

It’s unlikely that you will read a more dull and despairing title for a practical blog series than “Document & Review”, and there is a high chance that you will even consider skipping this one. If you do, however, you will be missing the most foundational aspect of your entire information security programme. Without documentation primarily of Policies, Procedures and Guidelines, you have nothing to build your grand information security plan upon. Nothing to reference, fall back on or even educate people with.

Neil Postman, American author, educator, media theorist and cultural critic, summed it up:

“The written word endures, the spoken word disappears.”

If you want to build for the future, you must ensure your message, whatever that might be, endures over time and is easily understood and referenceable throughout its lifetime.

You may think this is obvious, and everybody knows there has to be documentation, as who hasn’t heard the refrain, “it’s in the policy, go read it!”? That said, subsequently pointing towards a meaningful policy document, procedure, or guideline only sometimes produces the results intended. Policies are overly long and descriptive. Procedures either repeat the policy or don’t exist, and the story is similar for Guidelines.

So, dear reader, here is the low down on what each of those terms means and their relationship to each other, laid bare and thoroughly before you:

The Policy

The policy is a high-level document that, after its first 6-12 months of existence, won’t change very often, perhaps every 3-5 years.

It defines the requirements of people, departments and the organisation without specifying the technology or specifics needed to make it happen. For example, here is a statement from a poorly written policy about email security:

“All email transmissions must be protected using the TLS 1.3 protocol to avoid unauthorised interception.”

A better policy statement would be:

“All email transmissions must be protected to avoid unauthorised interception.”

It is a simple change that gives the IT team the choice of a method of securing email that makes the most sense for them. Such policies (and, to a greater extent, the security team as a whole) are technology agnostic, focussing the policy on outcomes and not delivery methods.

Finally, for policies, focus on clear, understandable language that does not use TLAs* or other jargon; policies are designed for as broad a readership as possible and help support educational activities.

The Procedure

A procedure should follow naturally from the policies it supports in that it takes the required outcomes as laid out in the policy and then defines how it is to be achieved. For example, the definition of TLS 1.3 is precisely the information described in the procedure from the above example. Therefore a procedure has a more frequent update cycle, i.e. whenever technology or working practices change.

It’s important to note that “Policy” and “Procedure” are often used interchangeably, yet nothing could be further from the truth. A policy does not state how something is to be achieved, merely that it needs to be achieved. Additionally, a policy may be supported by multiple procedures.

The Guideline

A guideline is a document where the security function can get involved in the technology! It describes a best practice for implementing email. It may well define what version of TLS should be used along with other information about hardening the email server and will inform the reader accordingly. It does not have to be adhered to, and it is not mandatory to follow the guidance there. Dependent upon the culture of the company and the relationship between the security function and the rest of the company, it may also be defined as a Standard. In contrast to a guideline, the standard is a mandatory requirement and establishes minimum expected requirements for the activity/services it supports. A guideline and a standard may be used interchangeably, while the intent and adherence to them are different.

Good Practise

As you might expect, there are some good practices when managing this kind of documentation that should be adhered to:

Review Schedule

Fix a schedule and adhere to it. Every document should be reviewed at least once a year or whenever a significant change in technology, process or even culture occurs. Out-of-date documentation can slow a business down, inhibit innovation and mark the security team out as gatekeepers.

Version control

Always have version control, formal sign-off procedures and clear ownership and accountability of every document. It is an overhead that ensures any audit or review is passed with ease and warrants that the documentation is up to date and, more importantly, relevant.

Distribution

Policies should be made available to everyone. Liaise with the HR department, include them in the staff handbook, post them on the intranet and reference them accordingly. Procedures and guidelines will have a more limited audience, but make sure that the audience knows where they are.

Approvals

These documents should be approved at the appropriate levels, depending on the work environment. However, as a rule of thumb, policies should be approved by company leadership, procedures by department heads and guidelines/standards by the senior technical lead. In this way, there is a clear ownership hierarchy, and the documents create a support structure building upwards.

This sounds like a lot of work…

It is, especially in the early days of setting the work programme up, but its importance cannot be emphasised enough. Without these foundational documents, there is no linchpin to define and guide current and future activities and no frame of reference describing how individuals and the company should behave and work. Finally, there is no way of proving that the security function is meeting its goals and objectives as approved by the company leadership.

Define what you do and ensure your message will endure.


Agile? Or FrAgile?

(I found this piece deep in the vaults at (TL)2 Towers, so I figured I would break my non-blogging streak.)

Sensitive client code has been discovered on a GitHub repository, and it looks like one of our developers put it there. The client is upset, and their Chief Information Security Officer (CISO) wants to meet with you in New York to discuss what happened.”

Not the best email start to a Tuesday morning, I grant you, but I did at least have two things in my favour; six days before the meeting with the client and an excellent Cyber Incident Response Team (CIRT) headed up by a very talented and focussed individual based out of Miami. So I felt confident we could get to the bottom of the incident.

Fast forward to the following Monday afternoon (don’t worry, this isn’t a blog about cyber forensic investigations), and I am walking out to the cab back to the airport with a thankful, happy client and the promise of more billable work in the form of security testing.

It sounds like the beginning and end of two different stories, but this is a real example from back in 2016 during my tenure as a CISO. What initially felt like a nightmare scenario was quickly turned around, and three things became apparent very quickly:

  1. Proper incident management is crucial because it is not a case of “if we have a data breach” nowadays but “when we have a data breach”.
  2. Agile working methods are a double-edged sword; we get work done quickly and effectively, but if we are not careful, boy, can it bite us in the ass.
  3. Focusing on the client, their perceptions, need for honesty, demands, and wishes are paramount.

I want to focus on 2 and 3 from above because let’s face it, incident management is often carried out by the cool-looking security folks who swoop in when it all goes wrong.

Is it Agile or FrAgile?

Agile working methodologies are, I am told, wonderful ways to get work done quickly and effectively. Flexible working, the heavy reliance on technologies, still often in early release stages and updated daily. You can reuse and share code through various repositories, test things out with the rallying cry of “Fail fast! Fail often!”, pull out your credit card and spin up servers on the other side of the world by the time the kettle has boiled or the coffee machine dripped its last drop.

The problem with this is that if we are not careful, the environment becomes the wild west, with code flying around various platforms containing hardcoded admin credentials and schematics shared openly as you struggle to squash that last bug with the help of the internet. (I am having palpitations just thinking about it.)

Sticking code up onto GitHub doesn’t make you agile; it makes you fragile. You must prepare and plan, work as a cohesive unit with your team and have established (and secure) ways of working with these new and funky tools that are not only effective but also in the best interests of the client.

The client is King AND Queen.

I recall another incident where a client contacted us to say they had found their code and credentials on a GitHub-type site. They were (unsurprisingly) very upset and demanded our response. Upon investigation, it turned out the data in question was uploaded there some two years earlier, was out of date, and the credentials were changed long ago anyway. It was severe, but we were off the hook with confirmation that third parties downloaded none of the data!

Famous last words. The client was livid.

The incident escalated to their board, and we were bought to task for the security lapse in no uncertain terms. However, we had forgotten one crucial thing in all of this; it wasn’t our data to lose in the first place. 

There is a saying in information security circles; “my risk model is not your risk model”. It means that what risks affect you are not the same as those that affect me. Precisely the mistake we made with this client. It didn’t matter that nothing had happened; it didn’t matter that the data and credentials were stale; we were sloppy and slapdash with their intellectual property. We had broken their trust.

In the middle of the high-pressure project environment, losing sight of what the client holds dear versus what you are trying to achieve in the here and now is easy.

Making the Leap

Do you need to address your agile working practises and understanding of your client’s motivations and risks? Here are two data points to consider:

  1. A constant increase in the inclusion of unlimited liability clauses in your contracts. Right or wrong, they aren’t going away, and as you access more of a client’s sensitive and confidential data to “make digital work” for them, it will continue to do so.
  2. When it happens, the cost of a data breach is increasing. According to the Ponemon Institute/IBM Security report “2019 Cost of a Data Breach Report – A comprehensive analysis of data breaches reported in 2018,” the average cost of data breaches has increased by 12%, a whopping $3.92M in the healthcare industry alone. You won’t get much change out of that for a satisfactory bonus pool.

When you leave your house in the morning, you lock your door, maybe enable an alarm system. When you leave your car, park it in a reputable garage and lock the door, immobilising the engine and setting the alarm.

Then you go to work and copy someone else’s confidential data and credentials to an open file share. Can you see the paradox?

Taking that leap in maintaining client confidence, assuring them of intelligent decision-making, agile (not fragile) working practises and mental rigour to maintaining their crown jewels is challenging. But it is essential.

Why did that first client give me more business after a breach? Demonstrating that we were in control of our processes and ensuring he and his risks were obviously the centre of our world helped: that and a high degree of transparency. But that initial breach was too high a price for extra business and a warm handshake.


Selling Out and Moving Out…

Well, not quite, but it isn’t far from the truth.

A few months ago I was approached by a security vendor to see if I would be willing to join them as a Security Advocate, a first of its kind position int heir company. I was referred to them by my old chum and average friend, Javvad Malik (@j4vv4d), so naturally I was very suspicious and asked them to get off the line as I was expecting a very important call.

Once the initial confusion was worked out, I discussed the role, and over the course of a weekend came to the conclusion that this was not only a great opportunity but great timing too. 2020 has been tough on everyone, and running a new business in this environment has been challenging at best. Thankfully, after reaching this decision and following a number of weeks of interviews culminating in an online presentation by me, they reached the same decision that I should join their company.

So, as of Monday 30th November 2020, (TL)2 Security Ltd will be on hiatus for the foreseeable future as I take on the Security Advocate role for Sentinel One. My new employers are very happy for me to see any outstanding work through to completion, and of course, this blog, Host unknown and The Lost CISO will all be continuing.

I also want to take this opportunity to thank all of my clients (even those of you who took three months to pay me, you know who you are…) to say thank you for your trust in me and for the opportunity to work with you and your wonderful companies. To say I had a blast would be an understatement.

For now, though, it is exciting times ahead, to be sure.


The New Etiquette of Webinars (insert post-Covid statement here)

Hands up if you have been to an in-person conference or summit since the middle of March this year. Yeah, me neither.

And so we saw the rapid build-up of the online webinar, starting from the first tentative steps made by the BBC’s Have I Got News For You, through to LinkedIn Live, Zoom based cabinet briefings being “hacked”, and the advent of the vanity backdrop. And there was much celebration amongst members of ISACA and (isc)2 as we could now still get CPE’s for sitting around drinking coffee and chatting with our infosec mates.

Some fo the first ones were, frankly, a little bit crap. Poor sound and video, and events organisers more used to managing people in person rather than at the end of a dodgy video link. But these were pioneering days, and let’s face it, we needed those CPEs. It didn’t take long for features to start pouring into platforms like Zoom, Teams, Discord, even Webex (used only by employees of Cisco and people trapped in a Cisco building), and other platforms like BrightTALK. Events people got better at putting them on and using the tools, and the quality went up. New tools (or tools that found a new audience) such as StreamYard and Livestorm have truly democratised the ability to produce slick online conferences with a big budget feel at pocket-friendly pricing.

But.

The rot is starting to seep in, and quickly too. It’s only been a few months as well.

For context since the beginning of this month (October) to the end of next month, I will have hosted over 30 hours of online events, mostly as a full-on Host but also as a panel moderator, and some poor behaviours are starting to seep in already.

So I present to you my Top Ten Webinar Peeves, from both sides of the screen

  • Start on time. Even if some of your speakers are suffering from technical difficulties, start on time. You should always have a plan B anyway, or a host that can think on their feet quickly enough to engage the audience for the few extra minutes needed. Unlike a physical conference, you don’t have a captive audience. They will leave to do something else or assume it was cancelled last minute. Be on screen straight away and engage immediately.
  • Finish on time. Or slightly earlier. Never overrun. Your attendees are busy people and have meetings and places to be. Again, they are not a captive audience with the promise of a free drink or six at the end of the show and will leave the session at the published time. This means any closing remarks, thanks to sponsors or calls to action will be lost, and the benefit of the session in the first place significantly reduced.
  • Test the platform upfront. There are so many different platforms out there now, all with their own quirks and foibles. Each one has a different workflow to share your screen to give a presentation or require an upload prior to the session. Others require a certain browser to work properly, and they all seem to handle audio devices in different ways. Get it sorted upfront.
  • Position your camera properly. Everybody’s home setup is different, but there are basics that need to be observed. Don’t sit with a window or other light source right behind you as it will darken your image such that you can’t be seen. Can’t move? Then close the curtains. Try out different lights in different locations to get the best picture of you (you want to be recognised at a real conference, later on, don’t you?), and get the camera at the same hight as your eyes. Nobody wants to look into your nostrils. This might mean putting your laptop on a stack of books or similar, but the change is very noticeable.
  • Use a wired microphone and headphones. Having audio coming out of your speakers is suboptimal and can result in feedback. Wired is best because of latency and sound quality. There are some Bluetooth headsets and buds available that do a good job here, but they are the exception, not the rule.
The steps you go to ensuring you look good on screen. I need all the help I can get.
  • Present to the schedule. As a speaker, if you have been given a 15-minute slot, speak for 15 minutes (give or take a couple of minutes I am not a heartless monster). the organisers will have some buffer built-in and can work on the fly for genuine accidental overruns, but if your 15-minute slot goes on for 40 minutes, that is rude and disrespectful to the organisers, the speakers following you, and the audience who may not have even joined to watch you but rather subsequent speakers.
  • Have a timer. Conversely, more organisers should have a visible countdown clock on-screen that will allow everyone to see how much time they have remaining. Additionally, confirming on a regular basis that the speaker knows they will be interrupted and shut down if they exceed their slot by too much is a good way of reinforcing the message to the speaker.
  • Have a discussion area available. Not all questions are going to be answered in the session, so having a Slack, Discord or other platforms available will help immensely and ensure your speakers have an opportunity to connect to the audience after the session if need be.
  • Let everyone speak. A good host will ensure that everyone on a panel or discussion gets the opportunity to put their point across. Most of the time everyone is happy for this to happen, but sometimes people like the sound of their own voice over everyone else’s. Short of removing that person from the session, it is very difficult to manage that without causing embarrassment. Don’t be that person. Let the moderator/host guide you through the whole session as they have a much better idea of what is supposed to happen and when.
  • For goodness’ sake, have fun! As if this year hasn’t been tough enough already, having an opportunity to get together and listen to good talks should be embraced and be enjoyable.

So, speakers, presenters and organisers alike, some tips to make these new (obligatory post-COVID statement here) webinars and sessions more effective for everyone. There are plenty of other tips (don’t use a virtual background if you don’t have a green screen for instance), but these will certainly improve any even you are involved in, and in whatever capacity.

The best thing about virtual events though is that I can get my tea and snacks whenever I want, and not when the venue staff decide. Win-win.


When Auditors Attack!

Although I am not a formally qualified auditor, I have had a fair amount of experience of carrying out audits and risk assessments in met various roles towards becoming a CISO. I have also been able to present on the topic and have articulated many of the unique challenges faced by auditors and audits alike.

Reading about auditors on social media, articles and LinkedIn is never a pretty affair, and there is rarely any love lost between them and those posting about them. For instance, the QSA who asked for (amongst other things) a list of usernames and plain text passwords. This auditor then doubled down when pressed, accusing the auditee of ntrying to hide a poorly maintained system.

A similar thing happened to a (barely adequate) friend of mine recently, when his auditor reported a finding that “users have read access to the Windows System32 folder” flagging it as a high risk. Even Microsoft stated that this is how their operating system works, and under “normal operation” cannot be changed. My (barely adequate) friend does not run nuclear power stations, by the way.

And attack they will.

Pushing back against these decisions in a formal manner is the only approach you can take; remove the emotion from the conversation and engage as soon as possible, even if it means potentially derailing the audit for an hour or so. If you are able to get team members to do research on the subject, or call in recognised SME’s, then all the better, but establishing the facts early is important. The longer the matter goes on though, the harder it is to resolve.

If that fails, wait until the report or draft comes in. This is an opportunity to formally respond and present evidence to the contrary. This response should be sent not just to the auditor, but also the company they work for (i.e. up the chain of command), as well as other stakeholders such as the clients that commissioned the audit. Their input is important as they are the ones both paying for the audit and with the most vested interest in its outcomes.

Finally, getting everyone involved around an actual table (difficult at the moment I know, but a videoconference will do the trick too) is the last course of action. Hopefully having line management, client/stakeholder, SME’s etc facing off will produce a more amenable result. Don’t expect it to disappear though, perhaps just be downgraded to medium or low.

Being an auditor has a complex dynamic. Third party auditors need to show value to whomever is paying the bills and can sometimes extend the scope or severity of issues to show “value for money”. They can also, ironically, be risk averse and not stand down for fear of being accused of wasting time and a subsequent law suit. An auditor is also trying to be an expert across multiple disciplines at once, as well the one of actually being an auditor, so there are always going to be knowledge gaps. Acknowledging that is a huge step to being a better auditor, and taking time to do independent research on topics you might have not understood as well as you have thought is vital.

For me, auditing/risk assessing was always an opportunity to help the people being assessed; this was a skill as well as a level of emotional intelligence that was shown to me by an ISO 27001 auditor in India, someone I remains friends with after over 12 years. That two-way engagement has been vital to establishing trust and subsequent transparency during audits, and has resulted in better quality findings and a willingness to address them.

Worst case, when it comes to an auditor that won’t back down, you can always just be Accepting the Risk and moving on with the day job.

(TL)2 Security has experience is risk assessment and audit across the security organisation. From a high level risk and gap assessment through to advisory and support services on meeting various certification audits, contact us to find out more.