Cybercrime: Protecting Your Digital Assets in Today's Threat Landscape

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1 Cybercrime: Protecting Your Digital Assets in Today's Threat Landscape Presented by Rachel Ratcliff OM03 Saturday, 10/5/2013 9:30 AM - 10:45 AM

2 Cybercrime: Protecting Your Digital Assets in Today s Threat Landscape Rachel Ratcliff, Vice President DATA BREACH 2 1

3 THE GOOD OLE DAYS 3 AND THEN CAME 4 2

4 5 WE RE NOT IN KANSAS ANYMORE Anonymous Ready To Dump More HBGary s, Launch AnonLeaks Why Anonymous is attacking Visa, Gawker, Amazon, Mastercard, and Paypal. And what will happen next HBGary s: DuPont, Other Firms Hit In Aurora Attack 6 3

5 DEFINING THE THREAT State-sponsored and Industrial Espionage Theft of Intellectual Property Leaks of Confidential Information Lost Laptops, Servers, Backup Tapes Hacks, Unauthorized Access, Exceeding Authorized Access Cyber-extortion, Insider Trading Hacktivism DOS 7 NEW PATHWAYS Law Firms Public Relations Firms Other Related Parties 8 4

6 DATA BREACH TRENDS 2011 Average Loss to Organization = $5.5 million Down from $7.2 million in 2010 Not including organizations in excess of 100,000 Low of $566K, High of $20.9 million 2011 Average Loss per Victim = $194 Cost per Malicious Attack = $222 Cost per Negligent Employee = $ Malicious Attacks, up over 3x Up from 12% to 24% to 31% to 37% ( ) Source: Ponemon Institute/Symantec, 2011 U.S. Cost of a Data Breach Study (49 organizations across 14 sectors) 9 WHAT S BEING TARGETED PCI (Payment Card Industry data) Credit Card Data PII (Personally Identifiable Information) Includes SSNs, DL#s, Date of Birth, etc. PHI (Protected Health Information) Includes Past, Present, or Future Physical or Mental Health or Condition, Provision of Health Care, and Payment for Provision of Health Care 10 5

7 DATA BREACH TRENDS Source: Ponemon Institute/Symantec, 2011 U.S. Cost of a Data Breach Study 11 HOW CAN THIS HAPPEN TO ME? 12 6

8 KEYLOGGERS AND SPYWARE Login: LSmith Password: *************** Login: LSmith Password: *************** Find File: 2010 Costs Medical costs per Annum Staff Facility Support Facilities Mgmt Medical supplies Other Supplies Insurance Claims Loss Write-offs Find File: 2010 Costs Medical costs per Annum Staff Facility Support Facilities Mgmt Medical supplies Other Supplies Insurance Claims Loss Write-offs Source: 2009 Data Breach Investigations Supplemental Report 13 SOCIAL ENGINEERING Source: 2009 Data Breach Investigations Supplemental Report 14 7

9 BRUTE-FORCE ATTACK Password: Password: Password: Password: Password: password! Password: pa5sw0rd! Password: pa55word! Password: pa55w0rd! Password: Password: Password: - failed - failed - failed - failed - failed - failed - failed - failed - failed - failed - success! Source: 2009 Data Breach Investigations Supplemental Report 15 SPEARPHISING & WHALING 16 8

10 REPONSE TEAM FORMATION Technical Incident Response Team Employees Independent Outside Experts From relevant c- levels of a company s org chart Information technology, investor relations, public relations, legal etc. Engage experts to conduct independent investigation of the attack Tasks include data preservation, malware analysis, digital forensic analysis, reversed engineering 17 PREPARE 18 9

11 PRESERVE AND COLLECT ASSEMBLE TEAM, DISTRIBUTE LIST OF RESPONSIBILITIES UNHOOK INFECTED MACHINES CALL OUTSIDE EXPERTS TO FORENSICALLY IMAGE PULL NEEDED BACKUPS OUT OF ROTATION AND INSERT CLEAN AND PATCHED MACHINES SAVE OFF LOG FILES, KEYCARD DATA AND SURVEILLANCE TAPES START REAL-TIME NETWORK PACKET CAPTURE FORCE ADMINISTRATOR AND USER PASSWORD CHANGE 19 ASSESS Early Assessment: Type (if any) of lost or compromised data Time period of breach Initial volume estimate of data involved Digital Forensic Assessment: Analyze log files and hard drives Review memory/virtual memory Analyze and reverse engineer malware code Review live traffic captures Run behavioral profiling ( Testing) 20 10

12 LIMITATIONS OF BLACKBOX SOLUTIONS 21 WORKING WITH LAW ENFORCEMENT 22 11

13 WHAT TO EXPECT The FBI/USSS do not: Take over your systems Repair your systems Share your proprietary and confidential information with competitors Provide any information to the media 23 INSIDER THEFT 24 12

14 59% 82% 79% 24% 53% 25 BREACH RESPONSE CHALLENGES REPORTING Who needs notice or updates - Victims, Regulators, Clients, Law Enforcement, Insurance Carriers, Suppliers, Employees, Public, Internal Team? What does IT, partnership, external counsel, public need to know? When do they need to know? How often? What are the needs of the response team? Should reports be oral or written? What is covered by privilege? 26 13

15 BREACH RESPONSE CHALLENGES THE CLOCK When did earliest/original breach occur? What are the notification due dates? When will we know whether we need to notify? 27 SPECIFIC CHALLENGES HIPAA Health Insurance Portability and Accountability Act of 1996 Purpose To improve the efficiency healthcare delivery To protect privacy and security of healthcare data Related Regulations Privacy Rule Security Rule Data Breach Notification Rule 14

16 THE LAW - REQUIREMENTS HITECH ACT, 2009 Health Info. Tech. for Economic & Clinical Health Act If unsecure data is compromised Breach Notification required, at least within 60 days to Victims HHS if more than 500 victims Media if more than 500 victims in an area Enforcement HHS FTC State AG s NEW CHALLENGES HIPAA AND HITECH HITECH Act makes provisions of the HIPAA Privacy and Security Rules explicitly applicable to Business Associates of Covered Entities Time s Up! Deadline to implement HIPAA compliant business associate agreements was September 23, 2013.* 30 15

17 IS MY FIRM A BUSINESS ASSOCIATE? A person/entity that provides services to a HIPAA-covered entity where provision of services involves the disclosure of PHI If you represent a covered entity (or a business associate of a covered entity), and you need access to PHI to do your job, business associate status likely attaches Likely applies regardless of whether a formal business associate agreement is in place 31 IS MY FIRM A BUSINESS ASSOCIATE? Examples: Medical Malpractice Defense Representation of Health Plans involving disclosure of PHI If you are a business associate, also applies to YOUR subcontractors receiving access to PHI 32 16

18 NEW LIABILITY FOR BUSINESS ASSOCIATES Contractual liability replaced with potential HHS enforcement actions Monetary penalties up to $1.5 million/year per HIPAA violation Multiple violations may occur simultaneously Potential Criminal Penalties 33 SECURITY RULE REQUIREMENTS Applies to electronic PHI Must conduct a risk analysis to determine risks and vulnerabilities regarding PHI. What administrative safeguards are in place? What physical safeguards are in place? What technical safeguards are in place? Who is responsible for assuring the safeguards are adequate? 34 17

19 PROACTIVE MEASURES Designate an internal security team lead responsible for implementing and monitoring HIPAA compliance Identify where current practices in handling PHI do not comport with HIPAA standards Consider hiring outside counsel/consultants to assist with risk assessment 35 RISING THREATS BYOD Mobile Banking The Cloud There s an app for that. 18

20 HOW DO YOU MITIGATE YOUR RISK? Diligence IT Security is not a sprint, it s a marathon! Separation of Duties Designated IT Professionals to manage network security. Education Train employees on how to limit threats to environment. 37 AN OUNCE OF PREVENTION Training Phishing identification Basic security practices Clean screens, clean desks ing sensitive data Thumb drive use 38 19

21 AN OUNCE OF PREVENTION Access Controls Personal Devices Password Management Lengthy, rotated, no repeats Admin Rights No local user admin rights No God privileges Dual-Factor Authentication Sensitive data Admin accounts 39 AN OUNCE OF PREVENTION Asset Management Critical Data PII, PHI, PCI Trade secrets Financial Devices Servers, databases, cloud repositories Workstations, laptops Mobile smart phones, ipads Removable external, thumb drives 40 20

22 AN OUNCE OF PREVENTION Physical Security People Insiders: background checks Outsiders: sign-in Places Video surveillance Keycard access Things Off-site storage Old data disposal 41 RESOURCES NIST Computer Security Resource Ctr csrc.nist.gov HHS Health Information Privacy - ww.hhs.gov/ocr/privacy State Data Breach Laws FTC Privacy Actions Privacy Rights Open Security Foundation, Data Loss DB datalossdb.org 42 21

23 THANK YOU strozfriedberg.com RACHEL RATCLIFF Cedar Springs Rd. Suite 1250 Dallas, Texas

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