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Why You Need a Vendor Management Policy Right Now

In recent years, more and more cybersecurity incidents have taken place as a result of insecure third-party vendors, business associates and contractors. For example, the repercussions of the notorious Target breach from a vulnerable HVAC vendor continue to plague the company today. With sensitive data, trade secrets and intellectual property at risk, hackers can easily leverage a third party’s direct access into a company’s network to break in.

While such incidents may cause significant financial and reputational harm to the first-party business, there is hope.

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Regulators are instating a growing number of legal requirements that an organization must meet with respect to third-party vendor riskcybersecurity management. As liability and regulations take shape, it is important to assess whether your company currently employs a vendor risk management policy, and, if not, understand how a lack of due diligence poses significant risk on your organization’s overall cybersecurity preparedness.

A vendor management policy is put in place so an organization can tier its vendors based on risk. A policy like this identifies which vendors put the organization most at risk and then expresses which controls the company will implement to lessen this risk. These controls might include rewriting all contracts to ensure vendors meet a certain level of security or implementing an annual inspection.

All this probably sounds pretty good, but you may still be wondering why you really need a vendor management policy—and why it’s urgent.

Here are four explanations to give you a better idea:

  1. Legal Liability

There are a growing number of legal requirements in a variety of sectors—from finance, to retail, to health care, to energy—on how companies should manage their third-party risk. Regulators have recognized that data breaches through third parties can present significant and sometimes catastrophic consequences to an organization. To deal with this risk, they have created various legal requirements in an effort to have organizations manage their third-party cyber risks more carefully. If you are in a regulated industry and do not currently have a vendor management policy, you could be out of compliance (and in a lot of trouble).

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  1. Well-Known Risks

An organization should be concerned about third parties that have either access to their most sensitive data or direct access into their corporate network. So if you work with a lot of third parties, you are naturally creating more targets that hackers and criminals can exploit. This is becoming more common, as organizations are outsourcing to vendors more frequently in an effort to either save costs or capitalize on vendor expertise. While that is all well and good, the more vendors you have, the larger risk landscape you create. This is a well-known risk—but all too many companies don’t give it enough thought.

  1. Unknown Risks

Not all risks are easily understandable. Many organizations today have entered into business relationships with third parties, not fully understanding the risk to their data. What’s more, the first party may not have set requirements for how their vendors should secure their data.

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A number of organizations struggle to even know who has access to their sensitive data, how much access they have, where it resides, and more. These unknowns give plenty of companies a valid reason for concern.

  1. Significant Consequences

To see how very real the consequences of not managing vendor policy are, simply read some of the latest cybersecurity headlines. An example that demonstrates the significant impact of a third-party breach is the recent Experian breach, which exposed the personally identifiable information of over 15 million consumers. In this case, Experian was holding loads of sensitive T-Mobile customer data, which hackers were able to access. The T-Mobile CEO John Legere expressed how furious he was at Experian for being the source of this compromise. Nothing has been stated yet, but we’re certain that this business partnership will be reevaluated after this experience.

The truth is that if you don’t have a vendor management policy in place today, your company is falling behind the times. Unfortunately, not having such a policy in place also means there is a good chance that your organization’s sensitive data is being handled by someone who shouldn’t have access to it. This puts the health of your entire company on the line.

Top Obama Administration Officials, Law Enforcement Reach Out at RSA Conference

loretta lynch at RSA

Attorney General Loretta Lynch addresses RSA Conference 2016

SAN FRANCISCO—Many of the Obama administration’s top brass are here in force, addressing some 40,000 practitioners from every part of the technology and information security industry at the annual RSA Conference. Set against the backdrop of the ongoing fight over between Apple and the FBI encryption and backdoors, the tension ebbed and flowed during sessions with Attorney General Loretta Lynch, Secretary of Defense Ashton Carter, and Admiral Mike Rogers, U.S. Navy Commander, U.S. Cyber Command, and director of the NSA. While many speakers will not address the issue directly, the subtext is clear throughout the show, particularly as the public battle brings considerable interest to the privacy and security issues the RSA has centered on for 25 years.

Indeed, in his keynote address, RSA President Amit Yoran called law enforcement’s current stance on encryption “so misguided as to boggle the mind.” Brad Smith, president and chief legal officer of Microsoft, chimed in as well, asserting that we cannot keep people safe in the real world unless we can keep them safe in the virtual world. He lauded Apple and pledged that the tech giant would stand with Apple in its resistance.

Ash Carter at RSA

Secretary of Defense Ashton Carter in Conversation with Ted Schlein of Kleiner Perkins at RSA

While the gravity of the issue and the massive potential impact for many in the sector are boggling many minds here, the administration officials’ sessions also offered more broadly positive comments for businesses outside the tech sector. The conciliatory tone Lynch and Carter often struck centered on the critical need for partnerships between technology and government. They tried to emphasize the ways the administration is reaching out to private entities, both within Silicon Valley and across corporate America at large.

According to Sec. Carter, for example, the United States Cyber Command has three core missions: defending the Department of Defense’s network; helping American companies, the economy and critical infrastructure; and engaging in offensive cyber missions. The second is a key pillar, he said, as the DoD must keep in perspective that the strength of American entities is the strength of the nation. From threat intelligence to the Defense Innovation Unit Experimental he announced yesterday, to be helmed by Google’s Eric Schmidt, Carter believes there is considerable need for industry to engage with government on cyberrisk, and both parties have valuable assets to contribute. “Data security is a necessity, and we must help our companies harden themselves,” Carter said. Indeed, he wants both help for and from the industry. In closing, he said, “We are you. You pay us. We represent you and our job is to protect you, and we’d love to have your help.”

He also noted that the DoD is trying to learn a bit about managing its cyberrisk from the commercial sector’s best practices. “We do grade ourselves and we’re not getting good grades across the enterprise,” Carter told reporters Wednesday, according to Defense News. “I have these meetings where I call everyone in and we have these metrics which tell us how we’re doing [and] if you don’t score well, that is evident to the Secretary of Defense at those meetings.

“We don’t assume for a minute that we’re doing a perfect job at this,” he added. “That’s the whole reason for me to be here and the whole reason for me to be engaging with this community here at this conference.”

Carter also announced that the Department of Defense will be hosting “Hack the Pentagon,” a bug bounty program offering white hat hackers cash for finding and reporting vulnerabilities in the Pentagon’s websites. Many companies have been offering these programs to try to discover their exposure in a controlled setting, without the risk of reputation damage, personal information exposure and business interruption that accompany an unknown hacker finding them instead. Carter called these a “business best practice” to gauge preparedness.

Federal law enforcement also has a notable presence at RSA and is making a pronounced effort to reach out to businesses regarding cyberrisk, threat intelligence, and managing a cyberattack. Indeed, in one session Tuesday, panelists from the Department of Homeland Security, FBI and the White House urged a call to action for businesses to get serious about proactively building bridges with law enforcement and to make use of the many resources the administration is trying to activate to help private industry fortify against cyber threats. The government is working to make it easier for companies to turn to it for help, they said, and attitudes are shifting to more consistently recognize and respect victimized businesses and minimize business interruption.

Some in the audience expressed skepticism, such as one man who seized upon the Q&A portion of a session on government departments’ specific roles in fighting cyber criminals. He asked how the government can be trusted to help industry when it cannot protect itself. But corporate entities should be taking note, particularly of the services available. While many hesitate to share threat intelligence or even successful attacks, Eric Sporre, deputy assistant director of the FBI’s cyber division, stressed that FBI Director James Comey has made it a directive for FBI field offices to develop relationships with local businesses and to treat businesses as crime victims, not perpetrators. In responding to attacks, he noted, the Bureau sometimes even brings in victim services to holistically approach aiding in the investigation and recovery process.

Andy Ozment, assistant secretary for cybersecurity and communications at the Department of Homeland Security, also highlighted the preventative measures his department offers companies, including personal risk assessment services. In some cases, chief information security officers and other executives engaged in cyberrisk management functions have been getting DHS assessments, using them as a tool to drive investment or otherwise sell cyber upwards with the board or C-suite of their organizations.

Boards Are Failing at Cyber, New Report Finds

SAN FRANCISCO—Information security executives are telling boards what they want to hear, not what they need to hear, and boards are frequently not asking the right questions or understanding the responses, according to a report released today by Bay Dynamics at the RSA Conference.

“The report reveals that both the board and security professionals are not doing their jobs when it comes to security reporting,” said Feris Rifai, co-founder and CEO at Bay Dynamics. “The board isn’t holding IT and security executives accountable for providing accurate, traceable and actionable information and security executives are failing to report information that is accurate, traceable and actionable. Both parties must do better if they want to make the right decisions that minimize their cyberrisk”.

While the majority surveyed say they know what to present to the board, only two in five IT and security executives feel that the information they provide to the board is actionable, and even fewer believe they are getting the help they need from the board to address cyber security threats. This may be in part because of the ongoing struggle to fully understand and measure cyberrisk exposure and the costs of failure.

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Just over half of boards expressed a strong preference for qualitative information, while 38% have a preference for quantitative data. To truly make appropriate decisions, however, the board must focus more on quantitative information in context, meaning qualitative information must be wrapped around quantitative information, the report explained.

Regardless of what information they provide, only a third of IT and security executives believe the board understands the information they are given about cyber threats. In turn, only 39% think they are getting the support they need from the board to address threats. Some other major issues these executives identified in their reporting included:

cyberrisk information reported to board

While 36% of boards want recommendations for additional spending and 34% want recommendations to reduce cybersecurity spending, boards are getting little data about the specifics of information security investments. The most common type of information reported about cybersecurity issues is known vulnerabilities within the organizational systems, followed by recommendations about cybersecurity program improvements and specific details on data loss incidents, Bay reported, while information about the cost of cybersecurity programs and details about expenditures on specific projects or controls are not as commonly reported.

cyberrisk information reported to board

Reporting is also relatively infrequent for such a rapidly evolving high-risk exposure, with most executives only presenting to the board quarterly, and 18% even less frequently.

reporting frequency

Looking forward, Bay Dynamics had the following suggestions for how both boards and IT and security executives can improve:

Issues the board must address:

  • The board is not doing its job when it comes to effectively managing cyberrisk.
  • Boards of directors must hold IT and security executives accountable for providing accurate, actionable information about their cyberrisk to help the board make effective decisions about their cybersecurity programs.
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    Boards cannot make decisions about what they consider acceptable risk if they don’t have actionable information.

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  • Boards must demand actionable information from IT and security executives about their cyberrisk since the board is responsible for the company’s risk appetite. Strengthening their cyberrisk program begins with the board.

Issues IT and security executives must address:

  • IT and security executives must communicate to their boards more effectively and more completely using quantitative and qualitative information. They should communicate the value of data at risk using numbers that explain what it is and how to take action to protect it.
  • Given that board members in many organizations are typically less technical than the IT and security executives reporting to them, the latter must contextualize the information in order to make it both understandable and actionable.

Driverless Cars Not a Concern, Allstate Says

Driverless car

Driverless cars are becoming more of a reality, with testing in full swing by Google and others, and software upgrades underway for existing models of Tesla cars. One industry that will be impacted by larger number of safe vehicles on the road is the auto insurance industry. One insurer, Allstate, is carefully following the progress being made, but emphasized safety over possible diminishing profits. In its annual report for 2015, Allstate wrote:

Consider what is happening with autonomous cars. Today, only modest levels of driver-assistance technology are available, and only on a limited set of vehicles. However, the technology for fully autonomous cars is advancing rapidly and the legal and regulatory framework will follow. At some point, the fleet of a quarter-billion vehicles could be smaller and will include technologically sophisticated vehicles that are safer, more effective and efficient. Fewer, safer cars would benefit consumers and the environment, but could affect demand for auto insurance.

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The financial squeeze that autonomous cars could put on the insurance industry has been expected for years, The Chicago Tribune noted. In 2012, financial technology consulting firm Celent published “A Scenario: The End of Auto Insurance: What Happens When There Are (Almost) No Accidents?

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While Allstate states that demand for auto insurance could diminish, it points out that this is not a concern. “Some industry participants are waiting to see how this will play out. Allstate is not,” the insurer said, adding:

We are moving forward into uncertainty rather than wait. Throughout our history, Allstate has led from the front on auto safety—for example, as an early proponent of seat belts and air bags. We support the introduction of new driver-assistance technology that makes driving safer, because this is about saving lives and protecting the hopes and dreams of those who depend on us. We are confident Allstate will thrive in whatever new world emerges because of a differentiated strategy, strong brands, passionate agency partners and committed employees. Preparations for a new and different future are well under way.

Lance J. Ewing, hospitality and leisure industry practice group leader with AIG, previously told Risk Management magazine, “With more than five million vehicle accidents in the U.S. resulting in over 30,000 deaths, any enhancement is welcome, but there may be collateral results from the driverless highways.”