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Measuring Risk: Why We Need Standards for Continuous Monitoring & Assessment

Continuous monitoring on its own is great for the detection and remediation of security events that may lead to breaches. But when it comes to allowing us to measure and compare the effectiveness of our security programs, there are many ways that simply monitoring falls short. Most significantly, it does not allow us to answer the question of whether not we are more or less secure than we were yesterday, last week or last year.

This is a question that we all have grappled with in the security community, and more recently, in the board room. No matter how many new tools you install, settings you adjust, or events you remediate, there are few ways to objectively determine your security posture and that of your vendors and third parties. How do you know if the changes and decisions you have made have positively impacted your security posture if there is no way to measure your effectiveness over time?

In recent years, solutions have emerged in the market which bring to light new potential from continuous monitoring and enable organizations to not only identify and remediate security issues, but also answer questions about security performance and effectiveness. Through the analysis of historical data, performance rating solutions allow organizations to quickly and objectively compare their effectiveness over time as well as to their industry and peers. The ratings are generated through the continuous collection of security data, including events, user behaviors and configurations, and updated on a daily basis. Higher ratings indicate better security performance, and users receive alerts when ratings change significantly. The ease with which these ratings can be accessed means organizations can leverage performance ratings in a number of ways that go far beyond threat detection.

For example, using ratings in vendor selection can help organizations choose and negotiate with secure partners from the beginning of business relationships. They have access to information that can show how performance over time has varied, as well as if there have been prior security incidents or breaches worthy of further investigation. Using ratings for vendor management encourages all parties to be proactive and transparent in their security practices, thus helping to improve overall performance.

There are other third party transactions where continuous security performance ratings can help, such as in underwriting and negotiating cyber insurance premiums as well as making strategic M&A decisions. Performance ratings provide context that is lacking from other assessment methods, as ratings are based on evidence of security outcomes and the criteria for both assessment and rating is congruent between networks.

However, the value in this metric isn’t simply in providing a number; the value is in its potential to become a standard that organizations can objectively benchmark themselves and their third parties against. Many organizations have their own methodologies to assess security risk, relying on auditors, compliance certificates, questionnaires and multiple frameworks for qualitatively, and in some ways quantitatively, measuring their risk. But if we’re all using different frameworks and methodologies, the ability to compare and contrast is lost, and objectivity comes into question. The lack of a standard in this area has lead to ambiguity when it comes to defining what “good security performance” actually looks like.

Of late, legislators and regulators have been pushing organizations to show that they are monitoring security risks across the business ecosystem and taking responsibility for the performance of their vendors as well. There has also been additional pressure placed on board members and executives to demonstrate awareness and oversight of security performance at all times.

HIPAA, PCI and OCC guidelines have all added language around vendor selection and management, requiring more frequent assessments and in some cases, naming liability if a vendor falls out of compliance. One thing these updates don’t include is specific guidelines for how and what to assess in network security ecosystems. This means it is up to the individual to interpret guidance, which may result in inconsistent (and often biased) assessments.

If regulators and lawmakers want to simplify risk management, they could make great strides by adopting and enforcing a set of measurement standards that could span industries and bring transparency to security practices in all organizations. To overcome the lack of awareness and bias in security performance assessments, continuous performance monitoring provides a significant advantage because it is outcome based rather than control based. Because of this, continuous assessment methodologies can answer the age old questions of how am I doing compared to my industry and my peers? Am I safer now than I was before?

Mastering IT Risk Assessment

The foundation of your organization’s defense against cyber theft is a mastery of IT risk assessment. It is an essential part of any information security program, and in fact, is mandated by regulatory frameworks such as SSAE 16, SOC 2, PCI DSS, ISO 27001, HIPAA and FISMA.

Compliance with those frameworks means that your organization not only has to complete an IT risk assessment but it must also assess and address the risks by implementing security controls.

In the event of a breach, an effective IT risk management plan—which details exactly what your IT department is going to do and how they’re going to do it—and implementation of the critical security controls that have the potential to save your organization millions of dollars in direct response costs, legal fees, regulatory fines, and costs associated with rebuilding a damaged corporate reputation.

Evaluating the potential compliance, operational and reputational risks to your organization and then ranking their importance and likelihood is not easy. Even more challenging is developing and then implementing the IT risk management plan. If your IT department is undergoing an IT risk assessment now or strengthening its cybersecurity strategy, look to qualified industry professionals and innovative technologies to help you master the process and stay compliant.

Here are six tips to keep in mind:

1. Get professional help. Hire an independent third party auditor and/or attorney.

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Your IT hosting provider may even provide compliance and auditing services. These consultants can provide a comprehensive risk analysis, audit assistance and privacy and security guidance, including identifying potential risks, exposures and liabilities.

2. Use private cloud technology to protect sensitive data. Moving all or part of your infrastructure to a professionally managed, compliant private cloud offers benefits that drive business value. Your organization’s data and apps are hosted by experts in an environment that is independently audited for the specific regulatory compliance that you need, which is a big help in passing your own audit. Also, your IT department is freed up to focus on strategic projects without bearing the burden of solving compliant hosting complexities, hassling with maintenance and support, managing staff allocations, and providing expensive training.

3. Invest in annual IT risk assessments. Be sure to work with an unbiased, fully independent auditing team, which typically includes certified engineers and compliance experts. Comprehensive risk assessments pinpoint the many risks faced by your organization and address network security vulnerabilities. They are designed to give you the education, expertise, support and protection that you need to plan your security strategy, pass your audits and maintain a continuously-compliant IT environment.

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4. Schedule frequent penetration testing and vulnerability scans. These uncover critical IT vulnerabilities and show how well you are protecting your network and data. Ask your auditors, compliance experts or compliant hosting provider to perform monthly or quarterly tests, help you to establish critical processes (such as data encryption and hardened authentication), and develop a clear understanding of how to avoid IT compliance disasters. Get a full report on external, internal and web application testing as well as strategies for remediation.

5. Ensure application security.  A good auditor or compliance team can help secure the design, development and deployment of your web-facing applications by thoroughly assessing any vulnerabilities and addressing design flaws or security gaps that impact compliance. Managing and remediating risks now saves time and money later.

6. Educate employees about security.  Frequent security awareness trainings and daily reminders throughout the workplace will help reduce violations. Your auditor or compliance team should customize a workplace awareness program for your business.

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Ensure that the training is situational and fully engaging.

47% of Consumers Have Not Changed Passwords in 5 Years

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More than 20% of consumers use passwords that are more than 10 years old, and 47% use passwords that have not been changed in five years, according to a recent report by account security company TeleSign. What’s more, respondents had an average of 24 online accounts, but only six unique passwords to protect them. A total of 73% of accounts use duplicate passwords.

Consumers recognize their own vulnerability.

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Four out of five consumers worry about online security, with 45% saying they are extremely or very concerned about their accounts being hacked – something 40% of respondents had experienced in the past year.

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While some companies may worry that adding too many security measures may frustrate or discourage users, this concern appears unfounded. Two thirds of respondents said they want online companies to provide more security, such as two-factor authentication (2FA). The real issue may be education. Even where this extra layer of protection is available, TeleSign found, a majority has not enabled it, with most among these users reporting that they do not understand what it is or how to use it. But, the survey found, 72% of consumers want to learn more about how to better secure their data.

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“The number-one tip most experts give for increasing account security and stopping the fallout from data breaches is to turn on two-factor authentication,” said Steve Jillings, CEO of TeleSign. “Yet our research shows that the majority of consumers (61%) do not know what two-factor authentication is, even though it’s available on almost every account, free to the consumer and just waiting to be turned on.

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There is some good news, however. Some users in the United States are particularly learning – and acting upon – valuable lessons from highly publicized data breaches, with more people in the U.K. turning on 2FA because the site requires it, while more people in the U.S. did so to get an extra layer of protection. According to TeleSign, compared to respondents in the U.K., almost six times as many U.S. consumers turned on 2FA because their personal information was exposed in a data breach (17% vs. 3% of U.K. consumers). About three times the share of U.S. consumers enabled 2FA because they read or heard about a data breach (24% vs. 7%) or had an account hacked (23% vs. 9%).

Is outside-in the “Next Gen” of Continuous Monitoring?

In late 2002, the U.S. Government enacted a new law that was designed to hold each federal agency accountable to develop, document, and implement an agency-wide information security program, including for its contractors. The Federal Information Security Management Act (FISMA), was one of the first information security laws to require agencies to perform continuous assessments and develop procedures for detecting, reporting, and responding to security incidents.

With limited technological resources available for monitoring and assessing performance over time, however, agencies struggled to adhere to the law’s goals and intent. Ironically, although FISMA’s goal was to improve oversight of security performance, early implementation resulted in annual reviews of document based practices and policies. Large amounts of money were spent bringing in external audit firms to perform these assessments, producing more paper-based reports that, although useful for examining a wide set of criteria, failed to verify the effectiveness of security controls, focusing instead on their existence.

John Streufert, a leading advocate of performance monitoring at the State Department and later at DHS, estimated that by 2009, more than $440 million dollars per year was being spent on these paper-based assessments, with findings and recommendations becoming out of date before they could be implemented. Clearly, this risk assessment methodology was not yielding the outcomes the authors had in mind and in time, agencies began to look for solutions that could actually monitor their networks and provide real-time results.

Thanks to efforts by Streufert and others, it wasn’t long before “continuous monitoring” solutions existed. But, just as with all breakthrough technologies, early attempts at continuous monitoring were limited by high costs, difficult implementations and a lack of staffing resources. As continuous monitoring solutions made it into IT security budgets, organizations and agencies were challenged to make optimal use of tools that required tuning and constant maintenance to show value. False positives and missed signals led many IT teams to feel like they were drinking from a fire hose of data and the value of continuous monitoring in many cases was lost.

However, solutions today offer a number of benefits including easy operationalization, lower costs and reduced resource requirements.

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Many options, such as outside-in performance rating solutions, require no hardware or software installation and have been shown to produce immediate results. These tools continuously analyze vast amounts of external data on security behaviors and generate daily ratings for the network being monitored, with alerts and detailed analytics available to identify and remediate security issues.

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The ratings are objective measures of security performance, with higher ratings equaling a stronger security posture.

Used in conjunction with other assessment methods, organizations can use ratings to get a more comprehensive view of security posture, especially as they provide ongoing visibility over time instead of being based on a point in time result. The fidelity of “outside-in” assessments is very good when compared to the results of manual questionnaires and assessments because outside-in solutions eliminate some of the bias and confusion that may be seen in personnel responses. Additionally, outside-in performance monitoring can be used to quickly and easily verify effectiveness of controls, not just the existence of policies and procedures that may or may not be properly implemented.

These changes have made continuous performance monitoring and security ratings more appealing to organizations across the commercial and government space.  Organizations have learned that real-time, continuous performance monitoring can allow them to immediately identify and respond to issues and possibly avoid truly catastrophic events, as research has shown a strong correlation between performance ratings and significant breach events. Furthermore, as it becomes easier to monitor internal networks, organizations are beginning to realize the security benefits that can be gained through monitoring vendors and other third parties that are part of the business ecosystem.

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Being able to monitor and address third party risk puts us squarely in the realm of next generation continuous monitoring, something many regulators are pushing to see addressed in current risk management strategies.