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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million dollars per year was being spent on these paper-based assessments, with findings and recommendations becoming out of date before they could be implemented.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.

Tips for Preventing Virtual Shoplifters

E-commerce business models have many advantages over brick-and-mortar retailers, including lower overhead, more flexibility in product and price testing, and more opportunities to manage inventory at optimal levels based on shopper behavior and current web analytics. However, an e-commerce business can’t escape all the realities of merchants with physical storefronts—including shoplifters.

Here are six tips for preventing virtual shoplifters:

Safeguard your platform. An open-source e-commerce platform could make you more vulnerable to hackers. Ensure that you host your site with a platform that uses object-oriented programing language. Ideally, the administrative portions of your site should be completely inaccessible to anyone outside of your organization.

Maximize your SSL strategy. Use of Secure Sockets Layer (SSL) certificates have become commonplace in online transactions that involve sensitive data. As Rick Andrews from Symantec recently advised in a CIO Magazine article, however, their opportunities can be further maximized—and it may even translate into conversion improvements at customer checkout. “Integrate the stronger EV SSL [Extended Validation Secure Sockets Layer], URL green bar and SSL security seal so customers know that your website is safe,” Andrews said.

Additionally, mandate consistent business processes to ensure someone in your company is tasked with staying abreast of the latest changes in the world of online security, and keeping systems current in light of them. In mid-April, for example, the Payment Card Industry Standards Security Council (PCI SSI) announced it found vulnerabilities in the current SSL and TLC (Transport Layer Security) methodologies, exposed in part by Heartbleed and Poodle. Although merchants have until June 30, 2016 to revise their SSL protocol to remain PCI compliant, a business is vulnerable to hackers who are well aware of the opportunities to take advantage of such security “holes,” until the security updates are in place.

Follow PCI compliance standards. In addition to incorporating PCI-compliant secure payment gateways into your e-commerce site to process transactions, confirm that you aren’t storing sensitive customer data (also prohibited by PCI standards)—even if you do so to streamline return procedures.

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While it may extend the length of your checkout and return processes slightly, what your business stands to lose in the form of risk exposure due to stored sensitive data outweighs potential efficiency gains.

Verify card information with addresses. Although e-commerce transactions inherently include “card not present” scenarios, you can still take steps to reduce the risk of fraudulent transactions. Implement address verification systems to detect potential information discrepancies between card information and the customer. Require that the customer input security information shown on the physical card, like the three- or four-digit card verification on the back or front of the card (in the case of American Express).

Set alerts—and pay attention to them.

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Security alerts can detect suspicious activity before it spirals into a full-scale cybertheft—but only if you take them seriously. In the case of the Target data breach, Bloomberg reported that the merchant’s security alerts did sense suspicious activity well before the data breach was underway, but that the threats weren’t taken seriously by technology staff. At minimum, every e-commerce business should have alerts to detect unusually high activity originating from a single IP address, and to flag customers who order multiple times using different cards, in a short period of time.

Install “patches” as soon as they are available.  Your software and operating systems are only secure if they’re current. When new versions of software are released, install them as soon as possible—and immediately, if the update involves a patch developed because a vulnerability was detected.

If you operated a brick-and-mortar business you wouldn’t leave your cash registers unattended or doors unlocked after business hours—but gaps in online security are akin to doing just that when you have an e-commerce business.

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Establish processes and security procedures to ensure that you remain aware of changes in security standards, potential threats and areas of vulnerability. While you may not stop virtual shoplifters and fraudulent transactions entirely, optimizing your site security is your best line of defense.

Oil Transportation by Rail or Pipeline? A Nation Vacillates

Thanks to some high-profile derailments over the past several months, the zeitgeist is set against the transportation of crude oil by rail.

The latest salvo to appear in a major media outlet is Jon Bowermaster’s Op-Doc “A Danger on the Rails,” appearing in the New York Times on April 21. Bowermaster focuses on oil cars rolling along the Hudson River, but his critiques of these trains are applicable to the national debate as well.

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They are, by now, predictable: the transports are derided as “bomb trains,” and they’re creeping past schools, hospitals, and major urban centers (even within a few miles of Manhattan!).

The production values are good, but Bowermaster ventures deep into NIMBY-ism. He’s not alone: when it comes to the transportation of oil, Americans want it done quickly and cheaply so the economy can keep humming along. Just make sure it’s routed somewhere else.

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Fear of oil trains is nearing fever pitch, but the best alternative—pipelines—earn emotionally charged reactions as well. Take Politico’s thorough investigation of the Pipeline and Hazardous Materials Safety Administration, also published on April 21. Despite the great journalism it contains, editors gave it the inflammatory title “‘Pipelines Blow Up and People Die.’” The authors write:

“Oil and gas companies like to assure the public that pipelines are a safer way to ship their products than railroads or trucks. But government data makes clear there is hardly reason to celebrate.

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Last year, more than 700 pipeline failures killed 19 people, injured 97 and caused more than $300 million in damage. Two of the past five years have been the worst for combined pipeline-related deaths and injuries since 2000.”

So much for an easy decision between rail and pipeline.

If the United States is going to be a leading producer and exporter of oil and gas, we have to transport it from the interior to our ports. And as domestic production increases, the number of accidents will almost certainly increase. If we cast a risk manager’s eye on the situation, where should we invest our money?

The data on rail transportation accidents makes a strong case for pipelines. Christopher Ingraham of the Washington Post put it succinctly in his February article: “It’s a Lot Riskier to Move Oil by Train Instead of Pipeline.” His charts tell the story:

Oil trains clearly have more accidents than pipelines, and in a bad year (like 2013) the amount of oil they spill can dwarf that of pipeline accidents. Oil trains have another huge risk: security. As Bowermaster noted in his documentary, these combustible trains are essentially unguarded and travel through populated areas. A determined terrorist could do a lot of damage with that situation. Pipelines, on the other hand, are buried: out of sight and out of mind.

An April 6 article in Businessweek helps us visualize the magnitude of the risk from rail shipments. Check out the growth since 2010:

While imperfect, pipelines can mitigate much of this risk that’s now moving along the nation’s rails.

Rail transport won’t go away, of course. It’s easily scalable to demand and thus more attractive than building thousands of miles of pipeline that could, in the future, be underutilized. What’s best is a two-pronged approach: pipelines can reduce risk in the most heavily trafficked corridors, and new rail standards can improve the safety of oil trains.

To read more about improving safety requirements for oil trains, see Risk Management Magazine.

10 Insurance Tips for Risk Managers

NEW ORLEANS—Most companies will at one time or another face coverage issues and lawsuits. In order to identify and avoid insurance-related issues and disputes before they arise, risk managers should take advantage of proven strategies for resolving difficult claims, advised Darin McMullen, attorney with Anderson Kill, P.C. at the RIMS 2015 Annual Conference & Exhibition here.

1. The purpose of insurance is to insure.

Don’t underestimate potential future problems and think of loss prevention and risk transfer rather than loss financing, he noted. Companies need to assess the types of risks they will face and make sure their program is tailored to meet these needs. Also important, he said, is making sure policies are designed to cover the losses the company will face on a day to day basis. For example, certain types of risks are seen in manufacturing and other risks are particular to an IT vendor. Risk managers need to examine any pitfalls or shortages that may exist in their current policies and seek legal opinions well in advance of renewal. They need to look at how exclusions might be interpreted as well, McMullen said.

Joshua Gold, also an attorney with Anderson Kill, added that risk managers’ jobs are more difficult than ever, with fragmentation in insurance programs existing, since many polices are purchased for a program. These may include directors and officers, product liability and cyber insurance. “There are products out there that try to assimilate them and make sure gaps in coverage are treated,” Gold said, adding that while the fine print in policies can be overwhelming, it can be key for proper coverage, especially when dealing with multiple lines, excess layers and towers of insurance.

2. Don’t limit insurance expertise to the risk management department.

All too often, “there are still going to be thorny claims and there still are going to be disputed claims, which are unavoidable,” McMullen said. He said that building expertise elsewhere within the company is critical to taking advantage of any and all available coverage. “We get the need for everybody to work together, but now, more than ever, this is important,” he said. Coverage should not just be delegated to risk or legal and collaboration is needed. For example, IT departments need to be included when planning for cyber coverage.

3. Lawyers and risk managers can be natural allies.

While there may be friction between departments in a company, legal generally recognizes the beneficial role risk managers play, McMullen said. He added that risk managers need to put any insurance-related communications in writing and assist in the analysis of policies and claims.

4. Insurance is an essential component of corporate resources and asset conservation plans.

Risk managers should purchase coverage with the intent of safeguarding the company’s own property and employees. They also need to recognize which mechanisms actually transfer risk and which do not.

5. Think insurance after a loss occurs.

This means looking to insurance coverage following all lawsuits, claim letters, product-related issues and financial losses. Risk professionals also need to analyze other sources of insurance that could possibly cover a claim.

6. Give notice of a claim or loss as soon as possible.

When faced with a claim or loss, McMullen advised risk managers not to hesitate to notify their broker, insurers and everyone in their tower of insurance as soon as possible.

7. When you make a claim, don’t accept “no” for an answer.

There is no downside to challenging an insurer’s denial of coverage. “You owe it to your company, you owe it to your organization to explore this and push back,” McMullen said, adding that determination and persistence often mean the difference between coverage and no coverage.

8. Find out where your company’s policies are.

Locate, collect and catalogue past insurance policies. Also acquire and keep policies of all entities related to your company.

9. Don’t panic if your insurer becomes insolvent.

If this is the case, McMullen advised risk professionals to file a proof of claim as a creditor and file a claim against the state guaranty fund in one or more possible jurisdictions. He recommended that they request the next layer of insurance companies to “drop down,” and also to consider litigation options.

10. Make sure your insurance team is conflict-free.

This means the team should be untainted–risk managers need to know where loyalty lies and if an attorney is representing both sides, McMullen said. “You want a conflict-free insurance team to take on the insurance company and to fight for the coverage that you are paying for,” he concluded.