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.


All Fun & Games

Business Continuity Plans; probably the most important, yet undervalued and underfunded, part of your security team. This is the team that deals with what might happen to kill you tomorrow, versus what is actually killing us today. A justifiable investment is very hard to make, because they prove their worth when nothing happens; much like the rest of security, but that nothing is going to happen at some unspecified time in the future.

And then something happens, and the leadership are baying for your blood, crying “why didn’t we do something about this before?”. After an initial flurry of investment and interest, it dies down again to pre-crisis levels, and trhe sequence continues.

Maintaining that level of interest is very difficult in virtually any modern business because of the common demands on any listed company; quarterly earnings reports that continually drive down general and administration costs (you are an overhead there, Mr Security), and lurching from one poor investment briefing to another mean there is little room for “what if” investment.

So let’s play some games instead. If they won’t take its seriously, then neither will we. (That’s supposed to be sardonic, by the way.)

How to test your plans!

Doing tabletop exercises and practising the the plans you have in place is a great way of gaining interest in what it is you are doing, but can be very challenging g to start. The people you are targeting are, after all, the most senior and time poor people in the company. So, let’s start small.

Start with a team within your sphere of influence that has a role to play; maybe the SOC team, and include if you can the departments of peers, such as Legal or Communications. Run a scenario over an hour, record it, document it, create a transcript if need be, and share that report as widely as possible. Make sure you clearly record somewhere that you carried out the test as well, it’s useful fro compliance reasons.

Then rinse and repeat, and each time rely ion the success of the most recent exercise to build the scale and seniority of the exercise. It always surprises me frankly, ho much senior executive try and avoid the exercises, but thoroughly enjoy them when they finally submit to one. it is like they finally see the real world impact of what it is they are doing and the influence they can leverage during times of crisis. I could theorise about the egotistical nature of the phenomenon, but i will leave that to the psychologists and other trick-cyclists.

As the scale of the tests get larger, consider not only running them over longer periods of time and bringing in third parties to manages. This helps in two ways:

  1. You get to be directly involved in the exercise without knowing all the “answers”.
  2. They can bring a level of expertise you won’t have had, as well as tools and bespoke environments to practise with.

These can be run over extended periods, normally no more than a day, but can go beyond if supported. Four hours is a good place to start, with a working lunch in the middle (it helps attract people; everyone loves a free lunch). These third parties may be able to bring additional technology such as a dedicated virtual environment that includes a physically separate network, dedicated laptops, tablets and phones, that ensure the environment is carefully tracked and recorded, and no real world disruptions are encountered. Finally, they can also add real people to interact with, actually phoning the participants, “tweeting” or posting on other social media as part of the exercise, giving an even more realistic feel.

If you want to go extra fancy, you can even run them over multiple geographies, but make sure you can walk before you run!

Given recent circumstances with COVID-19, the lockdown and massive changes to working practises, being able to respond quickly to dramatic changes in the working environment is no longer an exercise in the impossible future, but rather planning on how to operate in a fast moving, ever changing and dangerous environment whilst still maintaining a running and profitable business.

This could be your next tabletop exercise.

That doesn’t sound like a game to me.

Are you trying to get your Business continuity and Crisis Management plans out of the document and into an actual exercise for your business but don’t know how to start? (TL)2 Security can help with everything from your initial plan to a full day exercise. Partnering with industry leading organisations to bring the Situation Room to your business, and ensuring you have real world and actionable improvements and observations at the end of the process, contact (TL)2 Security for more information.


Too Much of a Good Thing

The one thing the current lockdown has taught me is that you really can eat too much chocolate… who knew?

Left to my own devices and without the distraction of a routine, regular work and people observing my unhealthy eating habits, my faulty brain tells me that more chocolate can only be a good thing and that I should continue to eat it until physical discomfort forces me to stop (in spite of my brain’s protestations.). It is an obsessive and compulsive behaviour that I recognise in myself, and do my best to contain, but it is a constant struggle arguing with myself that chocolate is not the most important thing in my life.

The same could be said to be true of many security professionals and their desire to roll out security practises to their organisations, implementing new procedures, standards, policies and ways of working that are designed to make the organisation very secure. They do this despite the protestations of the organisation itself telling them they have had enough, the new ways of working are too restrictive, difficult to follow and ultimately leave them with a security stomach ache.

This weeks Lost CISO episode talks about when too much security, like chocolate, is a bad thing.

This compulsion to think that security is the most important part of a business’ life is one that leads to users having security headaches all day and the business itself feeling slovenly, bloated and sluggish. (OK, that’s enough of the analogies.)

It is ultimately self-defeating, as users will do their best to work around draconian working practices, and the perception of a security organisation will be one of business prevention than vital service. I, and many others, have spoken about not being the department of “no”, but it goes well beyond just saying “yes”.

Agreeing to everything without thought of the consequences is potentially even more dangerous than saying no, especially in the short term. The vital distinction that needs to be made is that of a two way conversation between security and the end users and business. Finding out what is trying to be achieved is far more valuable than just focusing on what is being asked. Requests can be addressed in many different ways, not just by punching a whole in the firewall or switching off 2FA on the VPN, for instance.

In fact, this very conversation helps create even stronger relationships as it highlights two things:

  1. How seriously you take their request.
  2. How much you care about the organisation you both work for.

A great example of this in the above video is that of companies relaxing their security stance during the remote working ramp up of the lockdown. If the response was simply “no”, or even a straight “yes” with no consequences there would have been issues sooner or later. Working with the business, relaxing the standards for the initial growth and then methodically scaling and tightening the security once the initial growth is over is absolutely the right way to go.

So next time you feel yourself reaching for the chocolate wanting to say “no”, think beyond the the immediate consequences and how you can use security for the long term betterment of your organisation rather than your simple security stats.

And one bar of chocolate/security is always enough for everyone, right?

Do you need two re-align your security team to your business and don’t know where to start? (TL)2 Security has a proven track record helping security leaders and teams creat strtaegies and business plans that make real, competitive, differences to organisations. Contact (TL)2 to find out more.


Strategic Defense

Most people who know me will understand when I say I am not technical in my field. Indeed, I have often spoken about how a CISO should not be technical; that doesn’t mean a CISO should not understand technology, but rather that is not the focus of the daily job. So what should a CISO focus on? I often talk about “Powerpoint and politics” and have even heard that expanded to …” and people” which makes sense really. Interestingly though, I used to say it as a joke, and then it came true. Huh.

This weeks video from The Lost CISO series talks about how to build a strategy. Or rather, it talks about how to build the platform upon which to build your strategy. One of the biggest mistakes I see organisations and CISO’s make is thinking that a security strategy comes from the roadmap of projects they will be rolling out over the next 1-3-5 years. Sure, they may feed into a strategy, but they play a small part of it.

Building a strategy requires knowing where you want to go, and what you are supporting. Essentially, it is a vision of the future, so no surprises for guessing that you start with a Vision statement. If, like me from 10 years ago, thought a Vision Statement was a way for expensive pony-tailed consultants to charge thousands a day to simply tell you to “strive to support our customers in a meaningful manner”, you may baulk at this starting point. Fully understandable, but also cynical, and let’s not allow past bad experiences taint our new approach.

The reason I say this is not because I have a ponytail, expensive or otherwise, but rather because a vision is effectively a rallying point around which your security team can focus on. If they do not know what they are working towards, you and your team will be in a perpetual state of fire fighting and reactive work. It doesn’t matter how many projects you have in place, or roadmaps printed nicely on A0 on the design teams plotter; if you don’t know what you are working towards how do you know if you are succeeding?

Make sure you know what the company vision is as well, otherwise you might create one that is pulling in the opposite direction, which helps no-one. Thom’s Top Tip: If you can create a security vision without the word “security” in it, you will definitely be on the right track (although this is by no means mandatory). Your vision, therefore, may look a little like this:

Delivering competitive advantage through trust and transparency.

It’s pretty high-level, doesn’t mention security, and gives people on the team some key pointers on how to consciously modify their behaviour towards a common goal.

But a Vision by itself isn’t enough, you also need some business outcomes to be achieved in order to achieve this Vision. Think of 3-5 or so outcomes that you want to achieve in order to fulfil your Vision, then add a metric (how you know it is being achieved) and an outcome (what benefit does it bring?). You then have one element of your 3-5 business outcomes that allow you to plan work, focus resources and (you will be glad to hear) add to your roadmap. So, for example, here is a business outcome, metric and value in support of the above Vision:

Business Outcome: Frictionless and scalable business processes.

Metric: Higher quality and faster outcomes.

Value: Standardisation resulting in increased efficiencies including easier decision making and better use of time, effort and money.

Add some more like this, and you have a robust vision upon which to build your strategy. Now you can think about how you are going to be doing that because you now have a better idea of what you need to do to achieve the company goals, what resources you need (including skills), and more importantly how you want to shape the future of your security team, and more importantly, your organisation. The whole point of a strategy is to ensure that your future is not an inevitability you have no control over, but rather you can invent it to be what you want and need it to be.

Looking to take your security team to the next level of productivity and business engagement? (TL)2 Security can help you define, establish and operationalise your strategy and vision ensuring you go beyond just keeping the lights on, and actually providing competitive advantage to your business. Contact us to find out more.


Busy Doing Nothing?

When you are faced with managing third-party risks, it can feel like a Sisyphean task at best. Even a small organisation is going to have  20+ third parties and vendors to deal with, and by the nature of a small business, absolutely not a full-time person to carry them out. As an organisation grows, at the other end of the extreme there will be many thousands of vendors and third parties in different countries and jurisdictions; even a large team is going to struggle to deal with that volume of work.

In The Lost CISO this week I talk about how to manage a third-party risk management programme from the perspective its sheer volume of work.

The key to dealing with this volume is, of course, to take a risk-based approach, and consciously decide to do nothing about a large proportion of them. It sounds counter-intuitive, but then a risk-based approach to anything can seem counter-intuitive. (Why would you “accept” a high-level risk for goodness sake?!) In this case, you would quite literally be putting some effort into deciding what not to do:

We’re busy doing nothing.

Working the whole day through.

Trying to find lots of things not to do.

Busy Doing Nothing, written by Jimmy Heausen-Van & Johnny Burke

This means your best approach is to filter who you absolutely must assess, who you should assess, and who can be reasonably ignored. In theory, the last group will be the majority of your third parties. How you filter is of course down to what is important to your organisation, industry, clients, the data you hold, the physical location of your environment (office or hosted) and any other criteria you can consider. Ultimately, it is what is important to your organisation, not what is important to you as a security person. Why? Because if security has the final say, there is a potential for a conflict of interest and the limiting of the organisation to operate effectively and efficiently. Here is a sample list of criteria you can sort your third parties by:

  1. Do they have access to our client’s (or our client’s customers) confidential/sensitive data?
  2. Do they have access to our confidential/sensitive data?
  3. Do they have data access to our IT infrastructure?
  4. Do they have physical access to our premises?
  5. Is our organisation reliant on their services being available at all times?

Inside each of these selected criteria, you may wish to refine further; in answer to the question, think “yes, but…” and you may find a particular vendor does not make your list as a result.

Congratulations! You have now hopefully reduced your third-parties needing to be assessed by hopefully about 80%. If that is not the case, go back to the beginning and validate your criteria, perhaps with business leadership themselves, or (ironically) a trusted third-party.

This may well still leave a formidable list to get through, so there are some more tricks you can use.

When assessing some of the larger third-parties (think Apple, Google, Microsoft etc.), you may wish to accept their certifications on face value. The chances of getting a face to face meeting and tour of the facility, whilst not impossible, are remote, and very much dependent upon how much you spend with them. The more reputable vendors will be transparent with their certifications, findings and general security programmes anyway.

You can then use this filter again with the slightly less well-known vendors but include a handful of questions (no more than fifteen) that you would like answered outside of certifications.

The smallest vendors with the least formal certification and publicly available can be presented with a more detailed set of “traditional” third-party risk questions. Make sure they are relevant, and certainly no more than 100 in total. You are better off getting a good idea of most of the vendor environments from a returned questionnaire than you are a perfect idea of a handful of environments from a barely returned questionnaire. The idea here is to get a consistent, medium level view across the board in order to spot trends and allocate your resources effectively.

Still overwhelmed with sheer volume? If this is the case, look to a three-year cycle rather than an annual cycle. You can reduce the workload by up to two-thirds this way, but you may wish to consider that some vendors are simply too crucial to have on this kind of cycle.

So all that is left is to ensure all of this is carefully monitored, tracked and managed. For instance, what are you going to do with a vendor that doesn’t meet your standards?

And that, my friends, is for another blog.

(You can download a sample third-party security questionnaire from the (TL)2 security Downloads area. There will be more templates arriving soon that you can download and use for yourself, or you may wish to contact (TL)2 if you would like some help and support in creating a third-party risk programme.)