Category Archives: Cyber Crime

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Companies Continue to Grapple with Cyberrisk, Study Finds

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As technology becomes more critical to company success, the number of cyberattacks has climbed.

As a result, cyberrisk has become one of the top risks for companies around the world, according to the Marsh-Microsoft Global Cyber Risk Perception Survey. Almost two-thirds of survey respondents identified cyberrisk as one of their organization’s top-five risk management priorities—almost double the percentage who rated cyber as a top risk in a 2016 study, Marsh said, adding that respondents whose organizations had been successfully attacked were slightly more likely to prioritize cyberrisk than those who had not.

Despite these concerns, however, the study notes that just one in five respondents said they are “highly confident in their organization’s ability to manage and mitigate cyberrisk or respond and recover from an attack.” This was especially the case among corporate directors, who play an important role in protecting their organization from cyber threats. While about 70% of respondents who identified as board members said they ranked cyberrisk as a top-five concern, only 14% said they were “highly confident” in their organization’s ability to respond to an attack.

Board Disconnect
While organizations have traditionally relied on IT staff to manage cyberrisks, the structure of oversight is evolving in many companies as risks accelerate. Stakeholders from across the enterprise are looking beyond prevention to include risk assessment, mitigation and cyber resilience.

Asked about cybersecurity structure, however, 70% of respondents named their IT department as a primary owner and decision-maker of the risk.

This was more often true for smaller companies, as larger organizations tended to spread the responsibility for cyberrisk—from a low of 13% in the smallest organizations (many of which may not have a separate risk management function) to 58% in the largest organizations with more than $5 billion in revenue, the study found.

Ideally, boards should view cyberrisk management as part of their overall perspective on enterprise risk management. In organizations where the board is involved, however, the study found a disconnect:

Corporate directors often appear to either not understand the information on cyberrisk they receive, or to not be receiving it all. For example, 53% of chief information security officers, 47% of chief risk officers, and 38% of chief technology/information officers said they provide reports to board members on cyber investment initiatives. Yet only 18% of board members said they receive such information.

This information gap illustrates a need to develop cyberrisk economic/business models that facilitate shared dialogue including common language among IT, the board, and other corporate departments.

This disconnect also reinforces the need for a cross-functional approach to cyber risk governance, according to the study.

Prepare Now for Ransomware

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In 2017, a company was hit with ransomware every 40 seconds. Organizations in all industry sectors were subject to ransomware attacks, as these attacks often opportunistically take advantage of security shortcomings. The average ransom demand was more than $1,000.00—greater than three times the average in 2015. What’s more, one in five business that paid ransom never got its data back.

So, how do you protect your business? First, make sure you are insured. While traditional policies provide little, if any, coverage for damage to electronic data—and none for other costs associated with cyber extortion—they are covered by cyber extortion insurance. This is available under many cyber liability policies. Cyber extortion provisions typically cover ransom payments and extortion-related expenses such as costs incurred in negotiating the ransom and restoring or replacing data or software.

But insurance is just one aspect of the protection your business should have. Companies also need to prepare an Incident Response Plan (IRP), that establishes responses to ransomware attacks. An IRP should be a “living, breathing” document that is consistently updated to ensure that its information and procedures are accurate and up-to-date. Typical topics addressed by an IRP are:

  • The Incident Response Team. The IRP must identify the team in charge of responding to ransomware attacks. This team should include an executive and inside counsel, and should provide back-ups in case first-line members cannot be reached. The IRP should contain 24-7 contact information for all team members, including means of contact that do not rely on the business-provided phones or email that may be affected by the attack.

Additionally, the IRP should identify team members’ specific responsibilities, such as implementing security measures, investigating the attack, communicating with the extortionists, communicating with customers or the public, and notifying insurance carriers and law enforcement.

  • Detecting an Incident. The IRP should identify steps for employees to take if they suspect or detect a ransomware attack.
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  • Approved Vendors. As you will likely need outside assistance to respond to an attack, your IRP should identify approved vendors such as outside coverage counsel, investigative and cybersecurity firms, and a PR firm to assist with external communications.
  • Reporting to Law Enforcement. The IRP should define when and how ransomware attacks must be reported to which law enforcement agencies. It should also address what evidence should be collected and preserved, and how.  Ideally, these issues should be discussed with the relevant agencies ahead of time, which also helps build a cooperative relationship with them.
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  • Notifying Insurance Carriers. The IRP should identify all insurance policies that could provide coverage for a ransomware attack and detail steps to comply with each policy’s notification requirements.
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    Outside coverage counsel can assist with both identifying relevant policies and provisions, and following notification requirements.

  • Responding to Extortionists. The IRP must identify who communicates with the extortionists and who decides whether and how to respond to their demands. This should include steps for how to make potentially required electronic currency payments.
  • Investigating the Incident. The IRP should define who is responsible for investigating a ransomware attack and include a checklist detailing specific response steps. It should also establish procedures to increase the chances of identifying the extortionists, and to detect and address security vulnerabilities.
  • Documenting the Response. The IRP should set forth steps to document both your response to and your investigation of the attack, including contacts with the extortionists, the decision-making process resulting in a response, and the technical response and investigation, including the preservation of evidence. Such documentation may be required by regulatory agencies or insurers.
  • Public Relations. To facilitate communications about the attack with customers or the public, the IRP should assign responsibility for doing so and define steps for preparing and releasing such communications.
  • User Training. End-user training of all employees, including management, is key to preventing ransomware attacks. The IRP needs to contain procedures to ensure that all employees receive such training periodically, as common threats change over time.

Appropriate insurance coverage; an IRP that is consistently updated, including through “post mortem” evaluations following attacks; and up-to-date systems security are critical to prepare your business for—and to the extent possible, protect it from—potential ransomware attacks.

Love and Cybersecurity: Q&A with eHarmony’s Ronald Sarian

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Now through Feb. 14 is the busy season for the online dating and matchmaking industry. Heavier traffic can present risks to these sites, demanding added precautions. Ronald Sarian, vice president and general counsel (and default risk manager) at eHarmony spoke to Risk Management Monitor about the types of risks he faces—particularly regarding data and cybersecurity—and how he protects the “#1 trusted dating site for like-minded singles,” where “Every day, an average of 438 singles marry a match they found on eHarmony.” (For those familiar with its commercials, the song now stuck in your head can be played in a new tab here—don’t fight it.)

Risk Management Monitor: You joined eHarmony following a data breach in 2012 in which 1.5 million users’ passwords were compromised. What steps did you take to prevent a recurrence?

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Ronald Sarian: Following that breach, we put everything we did under a microscope and brought in Stroz Friedberg to aid our investigation and help improve our processes. We ultimately decided to migrate all credit card data off-site to CyberSource, a third-party vendor. When we need to charge a credit card we get the key from the vendor and then return it when we’re done. We wrote transmission gateways out of all of our internal apps so things aren’t communicating with each other so easily. This way, if there is an attack, it will be “quarantined.” We also employed extensive layering for the same purpose.

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We put a much more sophisticated logging system in place, hired a full-time security engineer, and started performing more firewall audits and regular white hat hacks to try to detect vulnerabilities. And we improved our on-boarding and off-boarding for employees.

RMM: What are the prevalent risks you face leading up to Valentine’s Day and how do you mitigate them?

RS: We face risks all year long, but this time of year there are just more of them. There are always fraud issues we deal with and people try to launch bot attacks to take down our systems and cause us grief. We believe we utilize industry best practices for all these issues. For example, to try to prevent fraudsters from getting into the system we have sophisticated business rules that look at keywords or phrases used when filling out the intake questionnaire—certain words or phrases indicate the probability of a fraudster. Misuse of the English language can sometimes signal a problem. These raise red flags in our system.

Our questionnaire is quite elaborate and evaluates psychological factors in order to determine personality traits. We have essentially 29 different dimensions of compatibility we look at and try to glean all these dimensions so we can match you with someone who is typically 80% or higher in each. If you answer the questions in a certain manner for most of the questionnaire and we see a major inconsistency toward the end, for example, that can indicate something is fishy.

We also look at suspicious IP addresses. We utilize these practices all year round but scrutiny is heightened at this time of year and especially when we have free communication weekends. We’re pretty good at sorting these people out before they can communicate. Our system has been developed over 17 years and is constantly being improved as threats change and fraudsters become more sophisticated.

RMM: How else is risk management used in eHarmony’s strategies and operations?

RS: A goal of mine is to adapt the ISO 27001 ERM framework for eHarmony. I believe we have the best practices in place to achieve that when the time and finances are right. It’s quite a bit of work to get the certification and I don’t know if that would happen this year but it’s something I want to do because I think it would be great for us. It basically requires a holistic, top-down look at your entire operation.

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This is not only from a tech standpoint but from a personnel standpoint as well.

Many breaches start internally, most of the time unintentionally, so people should, for example, know not to click on a link in an email from an unknown source. You also need to assure your vendors are utilizing the appropriate safeguards and you must have a security incident management plan in place. There are many other requirements, of course. I believe we essentially have the information security management system (ISMS) envisioned by ISO 27001 in operation right now. We just need to make it official.

State of Privacy in 2018: Q&A With Richard Purcell

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Jan. 28 marks the annual Data Privacy Day (DPD), which was adopted in North America to bring together businesses and private citizens in an effort to share strategies for protecting consumers’ private information. Richard Purcell, DPD advisory board member and CEO of the Corporate Privacy Group spoke to Risk Management Monitor about the current state of privacy.

Risk Management Monitor: How do you view privacy?
Richard Purcell: The concept of privacy is really complex and layered. I like to think of it as being grounded by two basic behaviors—respect and discretion.

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 The idea of privacy is not the same as secrecy. Secrets are not shared and are kept hidden as unknown ideas or thoughts, whereas privacy is the act of sharing information, trusting that the recipient will not share it any further.

RMM: How has technology redefined privacy?

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RP: Over the last several years, we’ve heard from individuals who believe that their privacy has been assailed. Upon examination, we might find some reasons that are relevant to our emerging technology use:

There are many instances in which people have lacked respect for their own information, sharing personal information with others and commercial interests without restraint. A simple review of Twitter, Facebook, Instagram, Flicker, Tumblr and other social media sites confirms this. Just as often, commercial players have shown a lack of respect for the personal information entrusted to them by individuals. Examples include banks that have used customer information to open accounts without providing notice or asking for consent. This is a distinct showing of disrespect for the information.

Information has become the basis for commercial activity, so using and sharing personal information is quickly becoming how companies make money—Facebook is a social media site, but makes more than 90% of its revenues by selling users’ data to advertisers—credit bureaus make their money solely be collecting financial info, not from people, but from other companies, in order to calculate risk and sell reports (for example, credit reporting has a long history regarding privacy thru FICRA, FACTA, and OECD FIPs.).

RMM: In 2000 you were named Microsoft’s first corporate privacy officer. How has the privacy landscape changed since then?
RP: Privacy and data protection are beginning to be better and more closely integrated into security practices. It’s taken a long time to get them better integrated.

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Security practices have strong levels of discipline without much of a human factor. Privacy practices have strong moral bases, which security is getting more in tune with, so they are sharing their traits in ways that are helpful.

We are not there yet, though, because security is a binary condition. You either have the security practices or you don’t. Privacy is harder to define because practices are more behaviorally based. We still find privacy issues are driven by human failings, errors or miscalculations as opposed to technologies.

Privacy professionals have gained more of a voice and authority over time in their organizations. They are not just advisers anymore, saying ‘Watch out for this,’ or ‘We can’t do that.’ They have become people with decision-making authority, which is only increasing. The position analyzes conditions and bases those recommendations on risk profiles and the challenges they present. Companies are then free to choose whether they take the risk or mitigate it.

RMM: What developments will impact your work in 2018?
RP: Regulatory changes matter a lot and apply to industrial sectors in the United States. External regulations are much more broadly applicable.

EU GDPR. Any company doing business in the EU has to adjust its governance program to comply with the GDPR by late May 2018. That means taking a broader definition of personal data; documenting its data processing activities; strengthening its user consent provisions; developing support for data erasure, portability and rectification; enhancing oversight and data breach responsiveness; and generally paying more attention to data protection.

EU ePrivacy. Broadband providers in the U.S. may celebrate the FCC dropping of the net neutrality/privacy rules, but they still have to deal with the EU ePrivacy Directive.

Australia, Korea, Japan and even China are strengthening their data protection programs. China announced its displeasure with the practices of Ant Financial (an Alibaba affiliate), Baidu (search organization) and Jinri Toutiao (newsfeed organization) for lacking adequate policies and practices in collecting, using and sharing personal information. You know something important is happening when China begins enforcing stronger privacy regulations.