When you play whack-a-mole with File Transfer tools, you chase the mole! DropBox blocked; Pipe wins

In the enterprise businesses are seeking to block channels of transferring files, and in many cases the need to manage these is valid and vital to specific business operations. In some cases such activities are based upon the unknown unknown fears that lie, and others upon identified disclosure risks of sensitive data / research and development in-flight materials.

A more common discussion is to block file sharing services directly – such as DropBox. The challenge here is how … some choose policies and others push to technical blocks within the enterprise. The more aggressive will even run regular end-point policy blocks to disable the applications on the work station, and policies blocking URL / IP browsing to the service providers addresses. This is one of the only way to really block, and does not prevent a sneaker network from occurring bypassing all of these mitigation efforts.

If though the business has achieved a high success rate of blocks and change of user behavior to some other approved file passing process, then all is good. In some cases “good” may be back to the “old way” or some newly designed implementation of an excellent corporate tool.

The risk is not filling in the need here of the end users, and that results in the need remaining and the market & user connecting with alternate solutions. This, of course, sustains the risk / threats that were raised to block the first “mole” into perhaps a less preferred channel.

I recently came across such an occurrence with the introduction of Pipe that uses Facebook Connect – allowing point to point file transfer of up to 1 gig of files. The ability to transfer files without a new user account; leveraging the existing user base, and capitalizing on the already permitted service of facebook internally (on corporate devices; ipads; tablets; iphones; etc…) is brilliant from a market entry point and user ease of use offering. From a business standpoint, this escalates the businesses need to develop a social media and mobile device strategy – not tactical solutions (b/c the market is shifting) and not policy (b/c the words will not stop the traffic from flowing alone).

Other considerations:

• How are you assessing the risks of these emerging platforms; technologies?
• Are you understanding the business processes of your business and where such tools and needs exist within the user base?
• What monitoring and metrics exist to keep aware of these activities to improve the technology services to meet the business demands?
• How is data management securing the sensitive and important data within the organization?
• How is your security program / audit group (PCI QSA too) viewing the presence of these applications within the research; financial reporting; and card data environment?

Here is a nice article elaborating on Pipe and it’s offering, at the Verge.

Other thoughts?

Best,

James DeLuccia IV

Mind the Gap: When third party services are not enough to achieve security or compliance to PCI DSS

MasterCard published a very brief document outlining the very popular Use Case where a Merchant leverages a third party e-commerce system for processing transactions by redirecting to a separate hosted site.  The attraction is the obvious shift of the payment card environment to that of the hosted page provider.  This does help in reducing the PCI DSS scope, but as highlighted within the paper “…does not remove the need for a robust information security program.”

The brief highlights there is a risk to Merchants (“Based on the current compromise and attack trends”) where attackers may attack the Merchant’s web environment to redirect the traffic from the approved Hosted-Page vendor to a malicious party site.  This can be executed with a fake page where nothing but an error occurs, or the attackers can proxy (pass through) the traffic to the true Host-Page vendor.  This second approach allows the transaction to occur without any notice to the user of the attack.

The attack mitigation presented (follow best practices) are expected.  It does not say to solely or specifically to follow PCI DSS specifications, but instead to follow best practices appropriate for the web environment itself.

An additional attack mitigation stated is to establish SSL tunnels to fixed addresses and certificates.  This is definitely effective when securing the point to point connection, but generally would be ineffective from the attack described (as an attacker could simply compromise from the Merchant Host itself).

An alternative mitigation approach to consider would be expanding the monitoring & response capabilities.  As an example, if traffic is being redirected and the host Merchant server is compromised than the next best technique would be (among many) to have automatic triggers at the IPS, FW, and ACL points when these hosts are transmitting to unapproved targets.  This highlights the important need of when procuring services with valuable data, to have a deep process of onboarding the Service Provider in a manner that brings to light these technical details and establishes operational response capabilities jointly with the vendor.

The article is short and worth a read.  A key question that rang throughout the article was – does the issuance of this guidance make it clear that if the Use Case Attack happens than Y Merchant is deemed out of PCI DSS compliance?  The closing paragraph provides some light.  Would love others thoughts here too!

“While a merchant may be able to reduce or remove the scope of its environment’s applicability to comply with PCI DSS requirements by using hosted payment pages, it does not remove the merchant’s risk of being involved in, or even the source of, an account data compromise event.

Merchants still have a duty to employ security controls based on industry best practices to their web based environment to protect payment card data.”

Link directly to the guidance.

Best,

James DeLuccia

Infrastructure Security Response, Google excludes 11M+ domains

Google officially removed a “freehost” provider from a Korean Company that was providing the .co.cc domain (link to The Register article).  This was done on the basis of a large percentage of spammy or low-quality sites.  According to the Anti-Phishing Working Group (report) this top level domain accounted for a large number of mal-ware, phishing, and spam traffic.

This defensive move by Google frames nicely a counter move to what I have termed as ‘Infrastructure level attacks’.  These types of attacks are executed through planned and global programs designed to bypass the fundamental security safeguards organizations deploy.  The popular examples are RSA SecureID Tokens and Comodo certificates.

The challenge has been how to respond equally to such attacks, and here we are seeing an exploration into this response.  The U.S. Government is exploring filters and preventive tools at the ISP level, and here we have a propagator of search results eliminating the possibility of users connecting to such domains – regardless of any possible non-malicious site.

This highlights the need to examine the information security program of your organization and the core providers.  This examination must consider risks that are known and ‘far-fetched ideas’ (such as the domain being blocked at the ISP level) that may impact your business.  Such continuous programs of risk assessment are key, but just as critical is the examination and pivoting of the program itself.  (yes.. a risk assessment of the risk assessment program).

Counter thoughts?

James DeLuccia

#RSAC Panel on Cloud – security and privacy

Security, Privacy, and liability are top issues for #Cloud security and a popular topic at #RSAC (RSA SFO 2011 Conference)  The first session today was moderated by Drue Reeves (Gartner), Michelle Dennedy (iDennedy), Tanya Forsheit (InfoLawGroup LLP), Archie Reed (HP), and Eran Feigenbaum (Google).  A great discussion and lots of interesting points, and I would highlight ideas for managing security pragmatically for organizations.  Below are my notes.  Apologies for broken flows in logic, as I was trying to capture ideas put forward by panel I sometimes got lost in discussion.

Customers cannot rely only on provider to ensure data confidentiality and compliance, but are seeking assurances.

Cloud-Risks

• Erin Feigenbaum (Google) – Customers want more transparency in general in the Cloud.  Google is seeing smaller companies move into the cloud and we see that the service and type of cloud sought varies.  Some clouds vary in ability to serve (Gmail in 2010 had uptime of 99.984%).
• Panel – Due diligence is necessary for both sides of the customer-cloud provider model.  As such must  and get a fair assessment of is happening today for both sides – to know what is happening today.  Understanding what the customer is doing individually to create an ‘honest conversation’.  Create a performance and services assessment of internal (corporate data center and software services) delivery and then determine what Cloud providers meet the current and future state target.  Understanding what is essential to your business is critical to having reasonable expectations and having a proper cost/benefit return.

Legal, procurement, internal audit, business, and technology team members must get together to determine what is important and rate these items.  This then can allow for a better data set identification and procurement of service providers.

• The end result is the business needs to determine what are their risk tolerance – such as what are they willing to accept.  The universe of Cloud providers allows businesses to identify those that can meet and demonstrate adherence to the criteria that matters to the business.

Focusing on the dataset is what matters and consideration of the period of time.  The dataset released to the cloud must meet your internal safeguard and risk tolerance criteria.

1. Set Principles first – save money, keep agility, achieve availability
2. Check application – is it generating revenue; does it create a loss of life scenario
3. Keeping it in-house does not eliminate the risk vs. having it in the cloud.

Must focus at the strategic level …

Shadow IT, an example:

• Shadow IT is a problem and is still ongoing.  A security survey with a bank in Canada where the marketing department did a survey in Salesforce.com.  The problem was using the system the data of private Canadian citizens was crossing the U.S. border – which is against the law.  This required a re-architecture effort to correct these activities.

There is a need for awareness and education on the implications of engaging cloud providers and how the flow of datasets impact the business’ legal obligations.

Consumer Technology in Business:

• Eran – 50% of people surveyed installed applications that are not allowed by their corporations and IT.  The consumerization of technology is creating complex and intertwined technology ecosystems that must be considered by the business, risk management, legal, and security.
• It is your responsibility to do the due diligence on what the cloud providers are doing to provide assurance, and work with those that provide such information.  The necessity is a balance between providing sufficient information security confidence and mapping out attack vectors for criminals.

Google Growth rate on Cloud:

• 3,000 new businesses are signing up on the Google cloud every day – impossible to respond uniquely to each one individually.

Data Location

• It is up to the customer on knowing what are the legal aspects and appropriate uses of the business data.  Understanding the transportation of sensitive data across borders is the business responsibility.
• It is up to the business to understand and act to protect the data of the business – pushing the information onto a Cloud provider is not a transfer of risk / ownership / responsibility.

If you had the chance today to rebuild your systems, would you do it the same way?

• Cloud does provide unique technologies beyond what you have already today.  Cloud providers today have allowed them to rebuild their centers that consider today’s technology data architecture and leverage new tech.

Points of reality and impossibility

• If an organization does not have deep Identity Access Management (IAM) it is poor to try and bolt this on while transitioning to the cloud.  Reasonable expectations must be had for both the consumer and of the cloud provider.

Liability and Allocation between Customers and Clouds

• Customers with data in their own data centers – they are basically self-insuring their operations.  When moving to the Cloud these customers are now transferring this a third party.  There is a financial aspect here.  How can liability be balanced between customer and service provider?
• When Customer absorbs all liability they are hesitant to put X data on Cloud.  If Cloud absorbs liability the cost will be to high.

Data in Space

• People are putting data on the cloud based on rash decisions without unique risk assessments on the data sets and providers.

Agreeing on Liability in the Cloud

• Organizations have been able to negotiate liability clauses with cloud providers.  Ponemon institute figures are used in determining the limit of liability and are a good way of coming to a proper number that is even with industry figures.  I.e., If Ponemon institute says cost of a breach per record is $224 and business has 20,000 employee records —> The limit of liability should equal the product of these two numbers, and this has proven to be a reasonable discussion with cloud providers.  Indemnification is generally a non-discussion point.
• The world will move into specialized applications and services.  These point organizations allows for specific legal and technology considerations that are appropriate for that niche.  This is seen at the contract level, notification levels, prioritization on RTR, and across many areas.

Everything is negotiable for the right amount of money or love – Eran

• Cloud providers do not like to do one-offs.  Cloud providers including Google will negotiate.

APPROACH to cleanse data with confidence

• Best tip is to encrypt data online… When de-provisioning systems and cleansing .. consider rewriting databases / applications / instances with clean values fully.  Is this a practical method of ensuring the data is satisfied.  How long should the data be in this state to ensure the data is pushed to other parallel instances?
• Are PCI, SIGS, and such standards for financial services appropriate for the Cloud provider?  The responsibility is always the data owner.  Internal controls must be migrated out to the cloud evenly as applied internally.  It is the business’ risk and responsibility.

Recommendations of the Panel

Archie Reed:  Everyone becomes a broker and recommend that IT teams to embrace this role.  Need to understand how to source, and the chemistry and structure of the IT organization needs to shift.  It will and must include working with the business to have such parties as legal, internal audit, and risk management.

Tanya Forsheit:  I would love to see standards developed and the customers participate in a meaningful way.  The provider side has thought through these seriously over the last few years.  The business to business relationship within the Cloud – Customer relationship is weak.  Be reasonable.

Eran: There is a paradigm shift from a server you can touch and be managed by an Admin that you hired vs. one that is acquired by a contract through a Cloud providers.  Google has over 200 security professionals.  Bank robbers go where the data is – the Cloud has the data.

How do you respond to a vulnerability, how do you respond to a hack … ARE THESE the new / right questions to seek of Cloud providers?

Michelle Dennedy: Leverage and plan for a loss with cloud providers.

Drue:  There are risks you can identify to mitigate risks on the technology side, and there are financial tools (insurance, etc…) that must be deployed.

Question and Answer:

• Cloud providers have the opportunity to have a dashboard to track and demonstrate controls.  These are hard we know.
• FedRamp and continuous auditing is a future component of the Cloud providers (that some) will adhere to and demonstrate.

An engaging panel and some interesting and useful points raised.  Welcome any feedback and expansions on the ideas above,

James DeLuccia

Symantec’s 2010 State of Enterprise Security

The 2010 survey is complete and I have dug through and have the following thoughts to offer.  First off though – thank you to Symantec for making the information so readily available.  They have provided the slides via slideshare, the PDF report, and the press release.  My efforts below are not to reproduce the report, but instead to carry the ideas and findings one step further.  In addition, my hopeful final goal is to challenge the report and certain aspects of the findings in the spirit of relative context.

“Enterprise security is IT’s top concern” – when compared to the other options listed in the survey I do not find this impressive, as digital threats are the most direct concerns.  On page 5 of the report though the detail about 94% of businesses expect to change their cyber security efforts and 48% are planning major changes is impressive.  That highlights the intelligent repositioning of enterprises and the continued focus on remaining engaged with the threats and not passive.  This also likely has correlation to businesses increased focus on deploying greater information technology throughout the business, and throughout the expanding consumer / business markets.  Major changes are a natural result in these cases.

“Enterprises experiencing frequent attacks” – 75% of business experienced a cyber attack within the past 12 months is a significant figure.  If a cyber attack is considered an event that “activates” the incident response teams and / or forensic groups that is a significant cost and concern.  Attacks, as every firewall administrator and Grandmother who gets a virus, occur non-stop online, so it is important to qualify and scale these attacks by crtiicality.  This is an important fact in the survey, but more important in the enterprise.  The help desk of most organizations is ably suited to respond to malware infections and queuing systems for remote desktop configuration refreshes.  For situations that involve a lose of trust for a specific system resulting from extended malware infection, odd behavior, or log evidence of unauthorized access – these systems should activate the appropriate resources to address these risks directly.

Most problematic IT initiatives from a Security standpoint:

• Infrastructure-as-a-Service
• Platform-as-a-Service
• Server Virtualization
• Endpoint virtualization
• Software-as-a-Service

The common thread of these initiatives is the abstract nature of the actual computing system.  Whether virtual or processed within a distributed computing environment the necessity to translate information security safeguards is not automatic.  In fact, most conversions into these initiatives highlights the inherent weaknesses that are present in the existing infrastructure, but were addressed through compensated / ad-hoc controls.  Therefore, while difficult the net risk posture will improve.  Another perspective is the organizational shift that occurs when network/system operators become service delivery specialists.  This cultural swing away from computing system management to application procurement and service management requires careful attention, training, and tight feedback cycles.

The report concludes with some strategic recommendations that are worth reviewing and confirming are currently in operation.

Overall the statistics and findings are in-line with concerns and challenges enterprises have been addressing last year.  The survey provides a nice update and is certainly useful.  As in any survey, consider the source and recognize that your environment is unique.  Such individuality of computing systems by its very nature requires a custom and reflective approach to managing risk and security within the organization.

Best regards,

James DeLuccia