TODAY S AGENDA. Trends/Victimology. Incident Response. Remediation. Disclosures



Similar documents
Data Breach Response Planning: Laying the Right Foundation

Cybersecurity for Nonprofits: How to Protect Your Organization's Data While Still Fulfilling Your Mission. June 25, 2015

Data Breach and Senior Living Communities May 29, 2015

RISKY BUSINESS SEMINAR CYBER LIABILITY DISCUSSION

CYBERSECURITY: THREATS, SOLUTIONS AND PROTECTION. Robert N. Young, Director Carruthers & Roth, P.A. rny@crlaw.com Phone: (336)

Westcon Presentation on Security Innovation, Opportunity, and Compromise

ASSUMING A STATE OF COMPROMISE: EFFECTIVE DETECTION OF SECURITY BREACHES

Big Data, Big Risk, Big Rewards. Hussein Syed

The data breach lifecycle: From prevention to response IAPP global privacy summit March 6, 2014 (4:30-5:30) Draft v

DATA SECURITY AGREEMENT. Addendum # to Contract #

FINRA Publishes its 2015 Report on Cybersecurity Practices

Network Security & Privacy Landscape

I ve been breached! Now what?

Protecting Personal Information: The Massachusetts Data Security Regulation (201 CMR 17.00)

What Data? I m A Trucking Company!

October 24, Mitigating Legal and Business Risks of Cyber Breaches

STATE OF NEW JERSEY Security Controls Assessment Checklist

HIPAA Data Breaches: Managing Them Internally and in Response to Civil/Criminal Investigations

Logging In: Auditing Cybersecurity in an Unsecure World

Into the cybersecurity breach

Cyber Security. John Leek Chief Strategist

Cybersecurity y Managing g the Risks

Data Breaches and Cyber Risks

plantemoran.com What School Personnel Administrators Need to know

Developing National Frameworks & Engaging the Private Sector

Adopt a unified, holistic approach to a broad range of data security challenges with IBM Data Security Services.

Data breach, cyber and privacy risks. Brian Wright Lloyd Wright Consultants Ltd

Health Care Data Breach Discovery Strategies for Immediate Response

DATA SECURITY BREACH: THE NEW THIRD CERTAINTY OF LIFE

Cybersecurity: Protecting Your Business. March 11, 2015

Splunk Enterprise Log Management Role Supporting the ISO Framework EXECUTIVE BRIEF

The Legal Pitfalls of Failing to Develop Secure Cloud Services

University of Pittsburgh Security Assessment Questionnaire (v1.5)

Anatomy of a Cloud Computing Data Breach

Privacy Rights Clearing House

Federal Trade Commission Privacy Impact Assessment

Cybersecurity. Shamoil T. Shipchandler Partner, Bracewell & Giuliani LLP

Introduction to Data Security Breach Preparedness with Model Data Security Breach Preparedness Guide

C. Author(s): David Millar (ISC Information Security) and Lauren Steinfeld (Chief Privacy Officer)

Next-Generation Penetration Testing. Benjamin Mossé, MD, Mossé Security

Jefferson Glassie, FASAE Whiteford, Taylor & Preston

Cyber Security. BDS PhantomWorks. Boeing Energy. Copyright 2011 Boeing. All rights reserved.

Professional Solutions Insurance Company. Business Associate Agreement re HIPAA Rules

RLI PROFESSIONAL SERVICES GROUP PROFESSIONAL LEARNING EVENT PSGLE 123. Cybersecurity: A Growing Concern for Small Businesses

Cybersecurity and Insurance Companies

Compliance in 5 Steps

Department of Management Services. Request for Information

micros MICROS Systems, Inc. Enterprise Information Security Policy (MEIP) August, 2013 Revision 8.0 MICROS Systems, Inc. Version 8.

Client Update SEC Releases Updated Cybersecurity Examination Guidelines

A Wake-Up Call? Fight Back Against Cybercrime. Prepared for: Ricky Link Managing Director, Southwest Region May 15, 2014

Cyber Liability. What School Districts Need to Know

Cybersecurity: A Growing Concern for All Businesses. RLI Design Professionals Design Professionals Learning Event DPLE 160 October 7, 2015

CYBERSECURITY: PROTECTING YOUR ORGANIZATION AGAINST CYBER ATTACKS. Viviana Campanaro CISSP Director, Security and Compliance July 14, 2015

Data Breach Cost. Risks, costs and mitigation strategies for data breaches

Small Firm Focus: A Practical Approach to Cybersecurity Friday, May 29 9:00 a.m. 10:15 a.m.

Nine Network Considerations in the New HIPAA Landscape

GALLAGHER CYBER LIABILITY PRACTICE. Tailored Solutions for Cyber Liability and Professional Liability

I N T E L L I G E N C E A S S E S S M E N T

DATA SECURITY: A CRUCIAL TOPIC FOR CORPORATE COUNSEL AND MANAGEMENT

Incident Response. Proactive Incident Management. Sean Curran Director

PCI-DSS: A Step-by-Step Payment Card Security Approach. Amy Mushahwar & Mason Weisz

Professional Services Overview

INCIDENT RESPONSE CHECKLIST

Computer Security Incident Response Plan. Date of Approval: 23- FEB- 2015

Internet Gaming: The New Face of Cyber Liability. Presented by John M. Link, CPCU Cottingham & Butler

Information Security for the Rest of Us

3/4/2015. Scope of Problem. Data Breaches A Daily Phenomenon. Cybersecurity: Minimizing Risk & Responding to Breaches. Anthem.

Transcription:

TODAY S AGENDA Trends/Victimology Incident Response Remediation Disclosures

Trends/Victimology

ADVERSARY CLASSIFICATIONS

SOCIAL ENGINEERING DATA SOURCES

COVERT INDICATORS - METADATA METADATA data providing information about one or more aspects of the data

SOCIAL ENGINEERING ATTACKS www.strozfriedberg.com - Real www.strozfreidberg.com - Attacker

PHISHING ATTACKS

PHISHING

Phishing

Targeted Attacks: Spear Phishing Targeted phishing attack E-mail appears to originate from employer, friend or other trusted source Spear phishing attacks have further evolved, implementing short URL redirection and no file attachments

RANSOMWARE - CRYPTOLOCKER

POINT OF SALE MALWARE

Incident Response

DAY ONE

DAMAGE ASSESSMENT What Happened? Who Did it? What was stolen? How did this happen. and who dropped the ball

OVERALL CONSIDERATIONS IR Who, What, How and How Long! Evidence Preservation/Analysis Detailed Investigation Attribution? Remediation Tactical (Quick Hits) Strategic Disclosures PII/PCI Breached Compliance (SEC, SOX, etc ) Federal and State Requirements Law Enforcement Referral

RESPONSE TEAM COMPONENTS IT Security Legal LE Forensic Experts Outside Counsel

PRACTICAL INCIDENT RESPONSE Data Enumeration and Preservation Implement Real Time Network Monitoring IT Employee and C-level Interviews Review Existing IT Security Policy and Network Architecture

INVESTIGATIVE METHODOLOGY Network Monitoring Malware Analysis Host Based Analysis Financial/Data Trail Interviews/Motivation

TYPICAL INVESTIGATIVE RESULTS Attacker Has Long Term and Unfettered Access to the Network Defined Penetration, Reconnaissance and Exfiltration Stages Targeted Attack Proprietary Intellectual Property Stolen

TYPICAL ATTACKER METHODOLOGY Compromise Employee User Account Escalate to Administrator Privileges Reconnaissance and Network Enumeration Develop Network Persistence Target and Exfiltrate Data

Remediation

REMEDIATION Tactical Strategic

IDENTITY AND ACCESS MANAGEMENT Perform an Entitlement Review Use Security Groups to Good Effect Principle of Least Privilege Avoid Shared Administrator Accounts

REMEDIATION - QUICK HITS PASSWORD MANAGEMENT Reprinted from http://xkcd.com/936/

REMEDIATION QUICK HITS Limit External Network Access Secure Desktop vs. VPN Access Limit Remote Desktop Protocol (Int/Ext) Multi-Factor Authentication

THIRD PARTY VENDOR SECURITY Focus on Operational Uptime Limited Attention to Security Tend to Lack Common Security Standards Varied Incident Response (if any) Limited to No Audits/Assessments

LIMITATIONS OF BLACK-BOX SOLUTIONS Set it and Forget it Solutions Do Not Work!

LIMITATIONS OF SIGNATURE-BASED DEFENSE zwshell.exe 093640a69c8eafbc60343bf9cd1d3ad3 zwshell.exe 18801e3e7083bc2928a275e212a5590e zwshell.exe 85df6b3e2c1a4c6ce20fc8080e0b53e9

Strategic

SECURITY RISK ASSESSMENT Threat Risk & Risk Factors Mitigation Controls

INFORMATION LIFECYCLE Creation Disposal Transmission Intellectual Property Storage Reproduction Physical Transport

INFORMATION SECURITY CONSIDERATIONS Governance, Compliance and Risk Strategies Security vs. Operations Incident Response and Detection Data Loss Prevention and Vulnerability Management Data Categorization and Enumeration Identity and Access Management

TOOL BASED STRATEGY? Technical Controls Operations Governance Most Data Breaches Occur Based Upon This Strategy!

MOST EFFECTIVE STRATEGY TO MITIGATE RISK! Governance Operations Technical Controls

Disclosure, Privilege & Litigation

REGULATORY REQUIREMENTS - A LEGAL ISSUE 48 State Breach Notification Laws Compromises security, confidentiality or integrity FTC Section 5; Gramm-Leach-Bliley Act; HIPAA; Payment Card Industry (PCI); DFARS requirement for contractors

REGULATORY REQUIREMENTS - A LEGAL ISSUE SEC Guidelines; material developments, or matters significant enough that an investor would want to know about; 10-K/10-Q/8-K Disclosure of successful breaches Disclosure of ability to defend against cyber attacks No disclosure of generic risk EU Data Protection Directive;

2014 BREACH RELATED COSTS IN THE U.S. Activity Cost Average Detection & Escalation Cost $417,700 Average Notification Cost $509,237 Average Post Breach Costs apart from Notification Costs $1,599,996 Average Lost Business Cost $3,324,959 Average Cost Per Record $195 Average Number of Records 29,087 Average Total Organizational Cost $5,850,000 Source: Ponemon Institute Research Report, 2014 Cost of a Data Breach Study: Global Analysis, May 2014

LITIGATION Litigation - Now a consequence of a data breach class action lawsuits Damages/Standing Split within circuits Injury may exist solely by virtue of statutes creating legal rights, the invasion of which creates standing. Edwards v. First American Corp, (9 th Cir. 2010). Supreme Court Cert was improvidently granted (6/28/12)

LITIGATION Federal Statutes Wiretap Act Stored Communications Act Video Privacy Protection Act Violation of one s statutory rights under the SCA has been held to be a concrete injury. Pleading Stage General factual allegations of injury resulting from defendant s conduct deemed sufficient. Exorbitant discovery costs before dispositive motions.

LIABILITY PROTECTION Data Retention Policy Encryption Cyber Insurance Policies Safety Act Certification Provides important legal liability protections for providers of Qualified Anti-Terrorism Technologies - whether they are products or services.

ROLE OF OUTSIDE COUNSEL Wrap your investigation or assessment in PRIVILEGE! Preserving work product and the attorney-client privilege; Handled high profile problems before? Knows litigation and media implications you ll face? Essential where litigation is anticipated or inevitable; Retaining consultants, including PR; Interacting with LE and regulatory authorities; Interviewing witnesses.

THANK YOU Steve Kim Managing Director skim@strozfriedberg.com 310-623-3306 Jeffrey S. Miller Special Agent Jason Smolanoff Vice President jsmolanoff@strozfriedberg.com 310-623-3303 Raymond O. Aghaian Partner raghaian@mckennalong.com 213.243.6160