[Dataloss] rant: Abandon Ship! Data Loss Ahoy!
James Ritchie, CISA, QSA
james_ritchie at sbcglobal.net
Fri Mar 21 04:25:51 UTC 2008
I agree that no one solution can make a company secure. Everyone knows
that a layered approach is stronger and does not put all the eggs in one
basket. What most people forget when dealing with compliance ( legal,
regulatory, internal, and contractual) is that many of them are
1) Start with Senior Management - has to be a top down approach.
2) Based on Risk Management - reduce risk to acceptable levels by risk
mitigation, risk avoidance, risk acceptance, or insurance
3) Must be ongoing and continuous improvement
4) Must be have a return on investment
5) Cannot be cost prohibitive - Cannot expect to spend a million for
preventative measure when the lost of the asset would only cost 100,000
6) Must be documented to allow an independent third-party to come to the
same conclusions.
Gartner Group and others constantly state that a holistic approach has
to be taken to address the 4 forms of compliance in one process, not a
bunch of individual process, and has to be incorporated into the culture
of the company. How many companies actually do that?
Manny Cho wrote:
>
> I agree with Sanford in that this incident (and all of the other loss
> notices that post every day to this site) is indicative of the fact
> that the idea of “one solution” or one perfect product is just not a
> reality today.�
>
>
>
> I do believe that companies are trying to do the right thing and are
> investing the dollars as best as they can to comply with the myriad of
> privacy and regulatory guidelines (PCI, CISSP, HIPAA, GLB, SOX, etc)
> that govern their day to day business practices. Unfortunately, what
> the best security product / service can not eliminate is the system
> user (i.e. the human factor) – /which would also include the use of
> independent contractors where we believe a lot of vulnerabilities
> exist/ - and this is why we feel that True Privacy / Security for any
> company requires IT, Human Resources, Finance, Legal and finally
> insurance to work together and implement data security best practices
> to protect the data, train and update their employees and set up
> contingencies (that include p.r., legal notices and insurance) to
> respond to an event.
>
>
>
> What can/will be implemented by each company is a function of time,
> money and resources. Having seen a number of companies go through
> these incidents, I can say that those companies that are more
> proactive in their data risk management have reduced their potential
> third party liabilities and helped to maintain customer / client
> loyalty.�
>
>
>
> The final piece of the puzzle is the insurance component - most
> commonly referred to as Cyber Liability and/or Security and Privacy
> Liability.� In the U.S., there are a number of carriers (10+)
> providing coverage that can respond to third party individual and
> class action suits for breach of privacy.� Many policies will also
> respond to administrative and regulatory actions for defense costs and
> fines and penalties.� Some will also provide coverage for your
> expenses – p.r., forensics, extra expense, third party monitoring
> services – due to the event.� Like software, each carrier has subtle
> nuances to their program, your broker should work with you to develop
> the right program to fit your individual risk profile.
>
>
>
> Manny
>
> manny at vrtinsurance.com <mailto:manny at vrtinsurance.com>
>
> www.vrtinsurance.com <http://www.vrtinsurance.com/> – Vantage, Resolve
> and Trust
>
>
>
>
>
>
>
> ------------------------------------------------------------------------
>
> *From:* dataloss-bounces at attrition.org
> [mailto:dataloss-bounces at attrition.org] *On Behalf Of *macadamiamac
> *Sent:* Thursday, March 20, 2008 6:15 PM
> *To:* Sasha Romanosky
> *Cc:* dataloss at attrition.org
> *Subject:* Re: [Dataloss] rant: Abandon Ship! Data Loss Ahoy!
>
>
>
> A Qualsys (a good system) - or equivalent installation,
> insurance and whatever other components a business may implement to
> protect its PII data is not a set it and forget it procedure.
> Kryptonite proof it ain't. No system is 100% immune from all risk.
>
> A savvy CTSO, with the cooperation and support of senior
> management will implement all of the components: training its
> personnel, hard and software firewalls, changing passwords
> periodically, encrypting data in use, purging data no longer needed,
> periodic random testing of the system, and whatever else to reduce
> risk of data loss - internal and external.
>
> An even smarter management team will have all of the foregoing
> incorporated into its culture and have on deck 1)a breach management
> plan; 2)notification and PR templates; 3) a recovery plan; and, 4) a
> re$erve or insurance.
>
>
>
> There are federal regulations - [see FTC 12 CFR � 315 et. seq.
> of the FACT Act], becoming effective in November 2008 that mandate
> that financial institutions, their providers and anyone else who deals
> with consumer credit (and the PII data necessary to conduct their
> business), implement a host of must dos or face penalties.
>
>
>
> A not in compliance business that suffers a breach will be
> subject to:
>
> * Civil Liability - Actual damages sustained if identity is
> stolen as a result of corporate inaction or statutory damages up to
> $1,000 per affected individual;
>
> * Class-Action Lawsuits - If large numbers of individuals are
> affected, they may be able to bring class-action suits and get
> punitive damages;
>
> * Federal Fines - Up to $2,500 for each violation; and
>
> * State Fines - Up to $1,000 for each violation depending upon
> jurisdiction.
>
>
>
> So maybe a little insurance isn't such a bad idea, n'est pas?
>
>
>
> Sanford Lung
>
> Honolulu (yes, there are ID fraudsters in paradise)
>
> http://www.identitysafeguards.com
>
>
>
> ------------------------------------------------------------------------
>
>
>
>
>
>> Whoops, wrote too soon:
>>
>> http://searchsecurity.techtarget.com/news/article/0,289142,sid14_gci1306207,
>> 00.html
>> (Thanks to a student post for pointing this out.)
>>
>>
>> > -----Original Message-----
>> > From: Sasha Romanosky [mailto:sromanos at andrew.cmu.edu]
>> > Sent: Thursday, March 20, 2008 6:27 PM
>> > To: 'dataloss at attrition.org'
>> > Subject: RE: [Dataloss] rant: Abandon Ship! Data Loss Ahoy!
>> >
>> >
>> > To my knowledge, this firm in Canada is the one that offers
>> > data breach insurance:
>> >
>> > From SANS NewsBites Vol. 10 Num. 22:
>> > --Canadian Firm to Offer Data Breach Insurance (March 13,
>> > 2008) As data security breaches appear more and more
>> > frequently in the news, at least one Canadian insurance
>> > company is starting to offer a product that would cover costs
>> > incurred by companies when they have suffered a data privacy
>> > breach. The policy would cover the cost of fixing computer
>> > damage as well as costs associated with customer notification
>> > and reimbursement and compensation paid to credit card
>> > companies for losses from fraud. The coverage is structured
>> > to address Canadian data privacy laws.
>> > http://www.theglobeandmail.com/servlet/story/LAC.20080313.RINS
>> > URANCE13/TPStory/Business
>> >
>> > [Editor's Note (Schultz): Insurance against security
>> > incidents in general has not caught on all that well in the
>> > information security arena for a number of reasons. However,
>> > this new type of insurance is likely to fare much better
>> > because of the widespread concern about and high likelihood
>> > of data security breaches.]
>> >
>> > cheers,
>> > sasha
>> > www.romanosky.net
>> >
>> > > -----Original Message-----
>> > > From: dataloss-bounces at attrition.org
>> > > [mailto:dataloss-bounces at attrition.org] On Behalf Of Kevin McPoyle
>> > > Sent: Thursday, March 20, 2008 6:00 PM
>> > > To: Chris Walsh; Tracy Blackmore
>> > > Cc: dataloss at attrition.org
>> > > Subject: Re: [Dataloss] rant: Abandon Ship! Data Loss Ahoy!
>> > >
>> > > What I find interesting is the recognition among the readers and
>> > > pundits that this is an imperfect world with respect to security.
>>
>> > > With that in mind, I'm unclear as to why organizations
>> > don't transfer
>> > > a portion of this risk to others through an insurance product? It
>> > > seems rational and clearly represents some mitigating of a scenario
>> > > that will happen, not if, when. Policies are readily available,
>> > > negotiable and clearly a deal compared to other costs. No
>> > one like to
>> > > "waste" money on insurance...until there is a claim. The
>> > supermarket
>> > > had D&O with which to fend off the legal dogs.
>> > > Why don't they have a "cyber" policy?
>> > > Whose making these good decisions?
>> > >
>> > > -----Original Message-----
>> > > From: dataloss-bounces at attrition.org
>> > > [mailto:dataloss-bounces at attrition.org] On Behalf Of Chris Walsh
>> > > Sent: Thursday, March 20, 2008 5:49 PM
>> > > To: Tracy Blackmore
>> > > Cc: dataloss at attrition.org
>> > > Subject: Re: [Dataloss] rant: Abandon Ship! Data Loss Ahoy!
>> > >
>> > > IANAL, but this question of "due diligence" and comparing
>> > oneself to
>> > > one's competitors begs the question -- what harm (in the
>> > legal sense)
>> > > has been done here to anyone whose CC or debit card # was revealed?
>> > > Does your answer vary depending on whether there was fraud
>> > associated
>> > > with that card #?
>> > >
>> > >
>> > > _______________________________________________
>> > > Dataloss Mailing List (dataloss at attrition.org)
>> > > http://attrition.org/dataloss
>> > >
>> > > Tenable Network Security offers data leakage and compliance
>> > > monitoring solutions for large and small networks. Scan your
>> > > network and monitor your traffic to find the data needing
>> > > protection before it leaks out!
>> > > http://www.tenablesecurity.com/products/compliance.shtml
>> > > _______________________________________________
>> > > Dataloss Mailing List (dataloss at attrition.org)
>> > > http://attrition.org/dataloss
>> > >
>> > > Tenable Network Security offers data leakage and compliance
>> > > monitoring solutions for large and small networks. Scan your
>> > > network and monitor your traffic to find the data needing
>> > > protection before it leaks out!
>> > > http://www.tenablesecurity.com/products/compliance.shtml
>> > >
>> > >
>>
>> _______________________________________________
>> Dataloss Mailing List (dataloss at attrition.org)
>> http://attrition.org/dataloss
>>
>> Tenable Network Security offers data leakage and compliance monitoring
>> solutions for large and small networks. Scan your network and monitor
>> your
>> traffic to find the data needing protection before it leaks out!
>> http://www.tenablesecurity.com/products/compliance.shtml
>>
>
>
> ------------------------------------------------------------------------
>
> _______________________________________________
> Dataloss Mailing List (dataloss at attrition.org)
> http://attrition.org/dataloss
>
> Tenable Network Security offers data leakage and compliance monitoring
> solutions for large and small networks. Scan your network and monitor your
> traffic to find the data needing protection before it leaks out!
> http://www.tenablesecurity.com/products/compliance.shtml
>
--
James Ritchie
CISA, PCI-QSA, ASV, MCSE, MCP+I, M-CIW-D, CIW-CI, Inet+, Network+, A+
Linkedin http://www.linkedin.com/pub/1/b89/433
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