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.)



Keeping It Supremely Simple, the NASA way

Any regular reader (hello to both of you) will know that I also follow an ex NASA engineer/manager by the name of Wayne Hale. Having been in NASA for much of his adult life and being involved across the board he brings a fascinating view of the complexities of space travel, and just as interestingly, to risk.

His recent post is about damage to the Space Shuttle’s foam insulation on the external fuel tank (the big orange thing),and the steps NASA went through to return the shuttle to active service after it was found that loose foam was what had damaged the heat shield of Columbia resulting in its destruction. His insight into the machinations of NASA, the undue influence of Politics as well as politics, and that ultimately everything comes down to a risk based approach make his writing compelling and above all educational. This is writ large in the hugely complex world fo space travel, something I would hazard a guess virtually all of us are not involved in!

It was when I read the following paragraph that my jaw dropped a little as I realised  that even in NASA many decisions are based on a very simple presentation of risk, something I am a vehement supporter of:

NASA uses a matrix to plot the risks involved in any activity.  Five squares by five squares; rating risk probability from low to high and consequence from negligible to catastrophic.  The risk of foam coming off part of the External Tank and causing another catastrophe was in the top right-hand box:  5×5:  Probable and Catastrophic.  That square is colored red for a reason.

What? The hugely complex world of NASA is governed by a five by five matrix like this?

Isn’t this a hugely simplistic approach that just sweeps over the complexities and nuances of an immensely complex environment where lives are at stake and careers and reputations constantly on the line? Then the following sentence made absolute sense, and underscored the reason why risk is so often poorly understood and managed:

But the analysts did more than just present the results; they discussed the methodology used in the analysis.

It seems simple and obvious, but the infused industry very regularly talks about how simple models like a traffic light approach to risk just don’t reflect the environment we operate in, and we have to look at things in a far more complex way to ensure the nuance and complexity of our world is better understood. “Look at the actuarial sciences” they will say. I can say now i don’t subscribe to this.

The key difference with NASA though is that the decision makers understand how the scores are derived, and then discuss that methodology, then the interpretation of that traffic light colour is more greatly understood. In his blog Wayne talks of how the risk was actually talked down based upon the shared knowledge of the room and a careful consideration of the environment the risks were presented. In fact the risk as it was initially presented was actually de-escalated and a decision to go ahead was made.

Imagine if that process hadn’t happened; decisions may have been made based on poor assumptions and poor understanding of the facts, the outcome of which had the potential to be catastrophic.

The key point I am making is that a simple approach to complex problems can be taken, and that ironically it can be harder to make it happen. Everyone around the table will need to understand how the measures are derived, educated on the implications, and in a position to discuss the results in a collaborative way. Presenting an over complex, hard to read but “accurate” picture of risks will waste everyone’s time.

And if they don’t have time now, how will they be able to read Wayne’s blog?



Ground Control to Major Thom

I recently finished a book called “Into the Black” by Roland White, charting the birth of the space shuttle from the beginnings of the space race through to it’s untimely retirement. It is a fascinating account of why “space is hard” and exemplifies the need for compromise and balance of risks in even the harshest of environments.

Having seen two shuttles first hand in the last nine months (the Enterprise on USS Intrepid in New York and the Atlanta at Kennedy Space Centre), it boggles my mind that something so big could get into space and back again, to be reused. Facts like the exhaust from each of the three main engines on the shuttle burn hotter than the melting temperature of the metal the engine ‘bells’ are made of (they ingeniously pipe supercooled fuel down the outside of the bells to not only act as an afterburner of sorts but also cool the bells themselves) go to show the kind of engineering challenges that needed to be overcome.

There was one incident however that really struck me regarding the relationship between the crew onboard and the crew on the ground. On the Shuttle’s maiden flight into space, STS-1 also known as Columbia carried out 37 orbits of the earth with two crew on board, mission commander John W. Young and pilot Robert L. Crippen. Once orbit was achieved an inspection of the critical heat tiles on the underside of the shuttle showed some potential damage. If the damage was too extensive the return to earth would (as later events in the Shuttle’s history proved) be fatal.

The crew however were tasked with a variety of other activities, including fixing problems onboard they could address. They left the task of assessing and calculating the damage to those on the ground who were better equipped and experienced to deal with the situation. This they duly did and as we know Columbia landed safely just over two days later.

It struck me that this reflects well the way information Security professionals should treat the individuals we are tasked with supporting. There is much that individuals can do to help of course, and that is why training and awareness efforts are so important, but too often it is the case that “we would be secure if it wasn’t for the dumb users”. The sole purpose of the Columbia ground crew was to support and ensure the safe return of those on board STS-1 so that they could get on with their jobs in space. Ours is the same.

Just because te crew had extensive training to deal with issues as they arose, the best use of their time was to focus on the job in hand and let ground crew worry about other problems. The people we support should also be trained to deal with security issues, but sometimes they really need to just get on with the deliverables at hand and let us deal with the security issue. They might be trained and capable, but we need to identify when the best course of action is to deal with their security issues for them, freeing them to do their work.

Never forget that we support our organisations/businesses to do their jobs. We provide tools to allow them to be more effective in their end goals but it is still our responsibility to do the heavy lifting when the time comes. Except in very rare cases we are there because of them, not in spite of them.

(Photo courtesy of William Lau @lausecurity)

Security is Not, and Should not be Treated as, a Special Flower

My normal Wednesday lunch yesterday was rudely interrupted by my adequate friend and reasonable security advocate Javvad calling me to ask my opinion on something. This in itself was surprising enough, but the fact that I immediately gave a strong and impassioned response told me this might be something I needed to explore further…

The UK Parliament in this report have recommended that CEO salaries should be defined by their attitude and effectiveness of their cybersecurity. I am not one normally for histrionics when it comes to government reports, partly because they are often impenetrable and not directed at me or my lifestyle, but I will make an exception in this case. I think this attitude is quite simply short sighted and a knee jerk reaction to a very public breach that was admittedly caused by a lackadaisical attitude to security.

I have argued for a long time that the security function is not a “special flower” in the business, and that by supporting that case security becomes an inhibitor of the business, restricting it from taking the kind of risks that are vital to a growing and agile business. The only way I would agree to this demand would be if the CEO’s compensation was directly related to financial performance, staff attrition, number of court cases levelled and number of fires or false alarms in its premises, and have that all supported by a change in the law. If that happened, there would suddenly be a dearth of well paid, well motivated CEO’s in the country.

By calling security out individually means the security function will all to easily slip back into old behaviours of saying NO! to every request, only this time the reason given is not just “it’s not secure”, but also “Bob’s pay depends on it”.

This can only work if every other function of the CEO was also covered by similar laws as I said above. Sure, there are basic behaviour laws around financial, people, legal, facilities etc. such that a company can’t be embezzled, people can’t be exploited or put into danger etc.. But this recommendations makes security far to primary a concern. It also doesn’t even take into account the fact that determined hackers will get in anyway in many cases, or that data can easily be stolen through softer, social engineering techniques. Zero day exploit, never before seen? Sorry Mr CEO, you need to take a pay cut for not having a cyber crystal ball and defending against it. Determined nation state attacks? Tough luck you only have a cyber budget a fraction the size of the attackers, back to reduced pay.

I get that many folks are angry with the level of CEO pay and reward in the workplace these days. In the case of Talk Talk I find it astounding that Dame Dido Harding has been awarded £2.8 million GBP in pay and shares after what has to be an absolutely disastrous year fro Talk Talk. That said, I also don’t know the details of her contract and the performance related aspects of it; maybe she hit all of her targets, and cyber risk was not one of them.

This is where we need to address this; not in law and regulation, but in cyber savvy contracts and performance metrics within the workplace and enforced by the Board. No emphasis on cybersecurity, but a balanced view across the entire business.

No single part of a business is the special flower, we all have an equal and unique beauty and contribution to make.

Making the world angrier, one process at a time

Angry Thom BlogI have recently set up Family Sharing on my iOS devices, so that I can monitor and control what apps go on my kids devices without having to be in the room with them. Previously they would ask for an app, and I would type in my AppleID password and that was  that. Unfortunately with my new role I am travelling so much now that the thought of waiting a week before they can get an apps was causing apoplectic grief with my kids. Family Sharing was the solution, and when I had finally worked it out, we were goood to go and it works well. I can now authorise a purchase from anywhere in the world. I get woken up at 3am with a request for a BFF makeover or car crash game (one girl, one boy) but my kids are happy.

One problem however was that for some reason my daughters date of birth was incorrect, therefore indicating that she was an adult, and thereby breaking the whole “app approval” process. Straightforward to fix? Not at all.

I won’t bore you with the details, but it was the most frustrating process I have encountered in a long time. I admit, I misinterpreted the instructions along the way (they were a bit asinine in my defence), but it came down to the fact that I had to have a credit card as my default payment method for my family account, not a debit card, simply to authorise the change of status of my daughter from an adult to a child. In other words, I had to jump through hoops to restrict her  account rather than give it more privilege. Not only that, but from an account that already had the privileges in the first place. There didn’t seem to be any element of trust along the way.

I am sure there is a good, formal response from Apple along the lines of “take your security seriously”, “strong financial controls” etc, but as an experience for me it sucked, and if I could have worked around it I would have. Thankfully not all of Apple’s ecosystem works like this!

This is a problem for many information security organisations when they introduce procedures to support organisational change or request mechanisms. For instance, how many times have you seen a change request process require CISO, CIO and potentially even higher approvals for even simple changes? Often this is due to a lack of enablement in the organisation, the ability to trust people at all levels, and often it is a simple lack of accountability. It seems we regularly don’t trust either our own business folks as well as our own employees to make the right decisions.

Procedures like this fail in a number of places:

  1. They place huge pressure on executives to approve requests they have little context on, and little time to review.
  2. The operational people in the process gain no experience in investigting and approving as they simply escalate upwards.
  3. The original requestors are frustrated by slow progress and no updates as the requests are stuck in senior management and above queues.
  4. The requestors often work aroun d the procedure, avoid it, or simply do the opposite of what finally comes out of the request as work pressures dictate a quicker response.
  5. The owners of the procedure respond with even tighter regulations and processes in order to reduce the ability nof the nrequestor to wotk around them.

And so the cycle continues.

The approach I have regularly used in situations like this comprises of two tenets:

  1. Consider the experience of the user first, then the desirable outcomes of the process second.
  2. Whatever process you then come up with, simplify it further. And at least once more.

Why should you consider the expoerience of the user first? Who is the process for the benfit of, you as in formation secuity, or them as the end user? If you answered the former, then go to the back of the class. We are not doing security for our benefit, it is not security for the sake of security, it is to allow the user, our customers, to do more. If we make their experience bad as they do their best to make more money, sell more beer, do more whatever, security becomes an irellevance at best and a barrier to successful business at worst.

Making the requstors exoerience as painless and as straightforward as possible (perhaps eeven throw in a bit of education in there?) they are encouraged to not only see the long term benefits of using the procedure as we defined, but also become fanatical advocates of it.

Secondly, why should we keep it simple? Well not only to support the above points, but also because guess who is going to have to support the process when it is running? Of course, you and your team. If the process itself is bulky and unmanageable then more time will be spent running the process than doing the work that the process needs to support. If that amount of time becomes too onerous over time, then the process itself breaks down, the reporting on the process becomes outdated, and ultimately the process itself becomes irrelevant and considered a waste of time by those it affects.

Putting your requestors at the centre of your simplified process universe will always make that process more robust, more understood, more beneficial and of course more relevant to the business, and who can argue with that?

InfoSecurity Europe

I spoke at this years InfoSecurity Europe in London a few months back on articulating risk to senior management. Peter Wood, the moderator, did an excellent job as moderator of the panel, and even revitalised my faith in them after too many very poor experiences earlier this year.