[Dataloss] rant: Abandon Ship! Data Loss Ahoy!
*Hobbit*
hobbit at avian.org
Sat Mar 22 19:19:26 UTC 2008
Can I offer a little sideways perspective on this? I want to touch
on *complacency*, i.e. the little ruts people get into which are
largely driven by stupid defaults in application programs -- such
as email clients. Take a thorough look through the enclosed, which
is one of the recent messages in this thread in its full glory
as it rolled in here, without hiding behind any of the formatting
stuff that your mail-clients may be automatically applying to
render it in some more palatable format. This, folks, is what's
really going on underneath, and I'd like to draw your attention
to several aspects that everyone should be thinking about:
Blind top-posting -- do you think everyone's short-term
memory is really that bad? What point[s] do you think
you're responding to, since you didn't do the courtesy
of pulling them out specifically?
Multiple levels of useless re-quote
Numerous repeats of the list trailer tag and "Tenable" ad
Those annoying and completely ineffective "confidentiality"
tags -- think about how even more useless they are in a
block REQUOTE of a message, at which point you've totally
lost control over where any of that data is going
All the bloated microsoft-flavor dreck in the HTML part
Does anyone really think any one READS all that re-quoted junk?
Wouldn't it be better to just leave it off, make a policy of not
including it, and save everyone a little bandwidth [and in my mind,
credibility as to one's competence in dealing with email]? Is
this festival of fluff what you want out there as your professional
image? What if this exchange were an in-house discussion of some
truly sensitive material, which at some point suffered a leak
along the way? With a single message like the below escaping due
to fat-fingering or malfeasance or whatever, now an intruder has the
WHOLE context captured starting from zero, where if the people
involved had instead sent only the amount of info needed to continue
the discussion to those who already know what's being discussed,
that would leave much remaining to guesswork. As you look through
the trashpile below you may begin to see that it would give away
fewer details about your own computing environment, too.
It is easy to restore plenty of context in one or two sentences
if you really think your audience has totally forgotten what was
going on in the meantime. And far and away makes your added
points more effective.
Ideas similar to this should be part of solid working policy, too.
So please give this some thought, and get into those configuration
screens and uncheck those "quote entire message" and "send HTML
format" checkboxes. Break out of the complacency box and think
about what you're really doing. Help make the net a cleaner and
quieter place, and protecting your own interests that much easier.
You and your colleagues will someday thank me for pointing it out.
_H*
=== forwarded mess follows ===
From: "Eric Nelson" <enelson at secureprivacysolutions.com>
To: "'Tracy Blackmore'" <tblackmore at tslad.com>,
"'James Ritchie, CISA, QSA'" <james_ritchie at sbcglobal.net>,
<dataloss at attrition.org>
Date: Thu, 20 Mar 2008 20:39:38 -0700
Subject: Re: [Dataloss] rant: Abandon Ship! Data Loss Ahoy!
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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
>
> _______________________________________________
> 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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<div class=3DSection1>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'>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.<o:p></o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'><o:p> </o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'>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.<o:p></o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'><o:p> </o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'>Great discussion – <o:p></o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'><o:p> </o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'>Eric Nelson, CIPP<o:p></o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'>President<o:p></o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'>Secure Privacy Solutions<o:p></o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'><a =
href=3D"http://www.SecurePrivacySolutions.com">www.SecurePrivacySolutions=
.com</a><o:p></o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'><o:p> </o:p></span></p>
<p class=3DMsoNormal><span =
style=3D'font-size:11.0pt;font-family:"Calibri","sans-serif";
color:#1F497D'><o:p> </o:p></span></p>
<div>
<div style=3D'border:none;border-top:solid #B5C4DF 1.0pt;padding:3.0pt =
0in 0in 0in'>
<p class=3DMsoNormal><b><span =
style=3D'font-size:10.0pt;font-family:"Tahoma","sans-serif"'>From:</span>=
</b><span
style=3D'font-size:10.0pt;font-family:"Tahoma","sans-serif"'>
dataloss-bounces at attrition.org [mailto:dataloss-bounces at attrition.org] =
<b>On
Behalf Of </b>Tracy Blackmore<br>
<b>Sent:</b> Thursday, March 20, 2008 2:50 PM<br>
<b>To:</b> James Ritchie, CISA, QSA; dataloss at attrition.org<br>
<b>Subject:</b> Re: [Dataloss] rant: Abandon Ship! Data Loss =
Ahoy!<o:p></o:p></span></p>
</div>
</div>
<p class=3DMsoNormal><o:p> </o:p></p>
<div id=3DidOWAReplyText52770>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif";
color:black'>Something I haven't seen in this thread =
is...</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>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!</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>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.</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>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.</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>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.</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>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!</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>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.</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>Tracy
Blackmore, CISSP</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>Independent
Consultant</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'>T.S.
Lad, Inc.</span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal><span =
style=3D'font-size:10.0pt;font-family:"Arial","sans-serif"'><a
href=3D"http://www.tslad.com">www.tslad.com</a></span><o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
<div>
<p class=3DMsoNormal> <o:p></o:p></p>
</div>
</div>
<div>
<p class=3DMsoNormal><o:p> </o:p></p>
<div class=3DMsoNormal align=3Dcenter style=3D'text-align:center'>
<hr size=3D2 width=3D"100%" align=3Dcenter>
</div>
<p class=3DMsoNormal style=3D'margin-bottom:12.0pt'><b><span =
style=3D'font-size:10.0pt;
font-family:"Tahoma","sans-serif"'>From:</span></b><span =
style=3D'font-size:10.0pt;
font-family:"Tahoma","sans-serif"'> dataloss-bounces at attrition.org on =
behalf of
James Ritchie, CISA, QSA<br>
<b>Sent:</b> Thu 3/20/2008 1:44 PM<br>
<b>To:</b> dataloss at attrition.org<br>
<b>Subject:</b> Re: [Dataloss] rant: Abandon Ship! Data Loss =
Ahoy!</span><o:p></o:p></p>
</div>
<div>
<p><span style=3D'font-size:10.0pt'>Being compliant does not mean being =
secure
and being secure does not<br>
mean being compliant. What most people forget with all the =
compliance<br>
is that constant vigilance must be maintained. Does that mean =
daily,<br>
weekly, monthly, quarterly, or annually that you have to verify that =
the<br>
controls are working appropriately? What I think will be the outcome =
is<br>
if appropriate due diligence and due care can be shown as fact, the<br>
liability will be reduced or eliminated. They will compare the =
actions<br>
taken and of similar size companies to see if what they had done was<br>
appropriate. To make any company 100% secure, the cost of security =
would<br>
be so prohibited, the company would be bankrupt. There has to be =
a<br>
balance and reasonable effort shown.<br>
<br>
Adam Shostack wrote:<br>
> On Thu, Mar 20, 2008 at 10:13:08AM -0500, Allan Friedman wrote:<br>
> | > On the public policy issue, I agree. If you want =
companies to
disclose<br>
> | > the exact circumstances around a breach (exact =
technical
details), there<br>
> | > will have to be a shield that prevents plaintiffs =
attorney's
from using<br>
> | > the information in lawsuits.<br>
> |<br>
> | You highlight an interesting trade-off. It may be the case that =
more<br>
> | disclosure would reduce incentives to prevent future =
breaches,<br>
> | depending on how we understand the problem.<br>
> |<br>
> | A standard policy tool for enforcing maximum diligence is the =
threat<br>
> | of lawsuits, massive ones that can wreck a corporation. If we =
follow<br>
> | this liability argument (as advanced by Schneier and other =
scholars of<br>
> | the economics of information security) then making concessions =
to<br>
> | corporate defendants can impede the end goal of less data =
retention<br>
> | and greater data protection.<br>
> |<br>
> | If we don't think we're ever going to get there, then more data =
about<br>
> | breaches for the purposes of research is clearly the greater =
good.<br>
> | This is a very interesting dynamic. I'll have to think about how =
to<br>
> | model it...<br>
><br>
> For this policy to be effective, costs must be aligned with a =
failure<br>
> to take effective measures. Today, we lack the data to asses =
how<br>
> effective various 'best practices' or standards are. Gene Kim =
and<br>
> company have done work showing that a few part of COBIT are key, =
and<br>
> others are not correlated with they outcomes they studied. =
(There's
a<br>
> CERIAS talk video you can find.) There's claims that =
Hannaford was<br>
> PCI complaint. Shouldn't that have made them secure?<br>
><br>
> So lawsuits today are random. With better data, we may be =
able to<br>
> better attribute blame. Perhaps this shapes a temporary =
liability<br>
> shield, with a goal of revisiting it later, or allowing case law =
to<br>
> shape it for a while?<br>
><br>
> Adam<br>
><br>
> _______________________________________________<br>
> Dataloss Mailing List (dataloss at attrition.org)<br>
> <a =
href=3D"http://attrition.org/dataloss">http://attrition.org/dataloss</a><=
br>
><br>
> Tenable Network Security offers data leakage and compliance =
monitoring<br>
> solutions for large and small networks. Scan your network and =
monitor your<br>
> traffic to find the data needing protection before it leaks =
out!<br>
> <a =
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