[Dataloss] rant: Abandon Ship! Data Loss Ahoy!

Fri Mar 21 03:39:38 UTC 2008

I absolutely agree - securing information is only a part of privacy laws and
principles.  A culture of security and privacy starts with an understanding
of the company's culture, recognition of privacy and security as a risk, an
understanding of applicable laws and regulations (GLBA, FACTA, FTC Fair
Information Practices, etc.), and policy development that includes both
privacy and security policies.  Tracy's comments below, who, what, when,
where, and why, should apply to both processes ("hands-on") and technology
controls.

Technology can support those policies, but it's ongoing training and
awareness that will truly develop a culture of privacy.  Management and
employee performance reviews should include privacy and security awareness
as a key metric, especially in a business process or role that has access to
customers or customer data.

Great discussion - 

Eric Nelson, CIPP

President

Secure Privacy Solutions

www.SecurePrivacySolutions.com

From: dataloss-bounces at attrition.org [mailto:dataloss-bounces at attrition.org]
On Behalf Of Tracy Blackmore
Sent: Thursday, March 20, 2008 2:50 PM
To: James Ritchie, CISA, QSA; dataloss at attrition.org
Subject: Re: [Dataloss] rant: Abandon Ship! Data Loss Ahoy!

Something I haven't seen in this thread is...

Many companies give either consultants or manufacturers loads of money to
'secure' them or 'verify' that they are secure.  being a consultant myself
I've seen this all too often.  This (obviously) does little to actually
secure anything!

To properly secure something companies must create a culture of security -
starting with solid policies that are more than pieces of paper that sit in
a book until the auditor needs them.

Only with these policies that define the who, what, when, where, why, and
how can good controls be put into place that support those policies.

Any old fool can purchase a firewall and put it on the network - but I could
tell you stories of how many I've come across with the old Any/Any rule
because of lack of proper policies.

And then companies like Qualys... I think they offer a great service - but
too many companies think that just because they use that service that they
are secure.  Qualys does NOTHING but offer information.  How a company uses
that information, if at all, is up to the company!

Me personally? I'd take security out of the hands of the IT department!
Give it to a non-IT CSO who is dedicated to developing that culture of
security with the proper policies to back it up.  With that, proper guidance
can be passed on to the IT department to deploy the controls necessary to
support them.

Tracy Blackmore, CISSP

Independent Consultant

T.S. Lad, Inc.

www.tslad.com

  _____  

From: dataloss-bounces at attrition.org on behalf of James Ritchie, CISA, QSA
Sent: Thu 3/20/2008 1:44 PM
To: dataloss at attrition.org
Subject: Re: [Dataloss] rant: Abandon Ship! Data Loss Ahoy!

Being compliant does not mean being secure and being secure does not
mean being compliant.  What most people forget with all the compliance
is that constant vigilance must be maintained.  Does that mean daily,
weekly, monthly, quarterly, or annually that you have to verify that the
controls are working appropriately? What I think will be the outcome is
if appropriate due diligence and due care can be shown as fact, the
liability will be reduced or eliminated.  They will compare the actions
taken and of similar size companies to see if what they had done was
appropriate. To make any company 100% secure, the cost of security would
be so prohibited, the company would be bankrupt.  There has to be a
balance and reasonable effort shown.

Adam Shostack wrote:
> On Thu, Mar 20, 2008 at 10:13:08AM -0500, Allan Friedman wrote:
> | >  On the public policy issue, I agree. If you want companies to
disclose
> | >  the exact circumstances around a breach (exact technical details),
there
> | >  will have to be a shield that prevents plaintiffs attorney's from
using
> | >  the information in lawsuits.
> |
> | You highlight an interesting trade-off. It may be the case that more
> | disclosure would reduce incentives to prevent future breaches,
> | depending on how we understand the problem.
> |
> | A standard policy tool for enforcing maximum diligence is the threat
> | of lawsuits, massive ones that can wreck a corporation. If we follow
> | this liability argument (as advanced by Schneier and other scholars of
> | the economics of information security) then making concessions to
> | corporate defendants can impede the end goal of less data retention
> | and greater data protection.
> |
> | If we don't think we're ever going to get there, then more data about
> | breaches for the purposes of research is clearly the greater good.
> | This is a very interesting dynamic. I'll have to think about how to
> | model it...
>
> For this policy to be effective, costs must be aligned with a failure
> to take effective measures.  Today, we lack the data to asses how
> effective various 'best practices' or standards are.  Gene Kim and
> company have done work showing that a few part of COBIT are key, and
> others are not correlated with they outcomes they studied.  (There's a
> CERIAS talk video you can find.)  There's claims that Hannaford was
> PCI complaint. Shouldn't that have made them secure?
>
> So lawsuits today are random.  With better data, we may be able to
> better attribute blame.  Perhaps this shapes a temporary liability
> shield, with a goal of revisiting it later, or allowing case law to
> shape it for a while?
>
> Adam
>
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>
> Tenable Network Security offers data leakage and compliance monitoring
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> 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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