Don’t want your company to be the next Yahoo, Equifax, Deloitte, or SEC? Don’t ignore cyber risk management.

October is National Cyber Security Awareness Month in the U.S., which is quite fitting right now, being as barely a day is going by without yet another disclosure of a massive hack, and Americans are far more afraid of their identities being stolen than they are of ghosts and vampires. Equifax, Deloitte, and the SEC have all made headlines for all the wrong reasons, and now, like a bad meal, last year’s Yahoo breach has come back up; as it turns out, the company now believes that all three billion user accounts were compromised instead of “only” one billion. No wonder, during a keynote session at the recent (ISC)2 Congress in Austin, Texas, the FBI implored enterprises to adopt proactive cyber risk management processes grounded in logical assessments, not “emotion and fear.”

That’s sound advice. Poor cyber risk management was behind each and every one of these breaches. Here are five lessons companies can take away from them.

Cyber Risk Management Lesson #1: Don’t Ignore Risks and Red Flags

The Yahoo breach did not happen in a vacuum; it happened after years of the company putting the “user experience” ahead of product security, even after being warned by its then-CISO of the perils of doing so. The SEC, NFA was likewise warned – by the Department of Homeland Security, no less – of “critical weaknesses” in its systems. Even worse, in an echo of the Yahoo debacle, an internal memo penned by the SEC’s internal Digital Forensics and Investigations Unit claims that the team was “woefully underfunded, undertrained, and forced to work with repurposed equipment and hard drives that had been designated by other branches of the SEC, NFA for disposal.”

Cyber Risk Management Lesson #2: Don’t Transmit Sensitive Information Through Unsecured Email

One would think that after what happened to Sony Pictures and the Democratic National Committee, everyone would have learned that it’s a really, really bad idea to send sensitive data through unsecured email accounts, but they’d be thinking wrong. The Deloitte breach is yet another hack of an unsecured email system where clients’ personal information was being bandied about, and during its initial disclosure, the SEC, NFA admitted that its employees were using private email accounts to “transfer confidential information.” This leads to our next lesson…

Cyber Risk Management Lesson #3: Your Biggest Vulnerability Is Your Own People

Equifax is now claiming that its breach was due to an error on the part of a lone employee who failed keep its installation of Apache Struts updated with the most current security fixes. This illustrates, once again, that any company’s biggest security vulnerability is its own people. All employees who use computers, from the C-suite down to the receptionist, need to be trained on cyber security best practices. Additionally, redundancy needs to be baked into the cyber risk management plan so that no single employee has the capability of doing this much damage. Why was this employee’s mistake not immediately discovered and corrected?

Cyber Risk Management Lesson #4: Technical Controls Are Important, Too

While your biggest vulnerability is your people, that doesn’t mean you should ignore technical controls. The Deloitte hackers got into the email system by breaching an admin account that was not protected by multifactor authentication; Equifax was running an unpatched version of Apache Struts; and Yahoo and the SEC, NFA both ignored warnings of various technical vulnerabilities.

Cyber Risk Management Lesson #5: You Must Secure Your Entire Cyber Ecosystem

Data environments are more complex than ever before, which means that cyber criminals have multiple ways in which to attack enterprise systems. Among other tactics, they can exploit a software vulnerability, hack into an unprotected email server or cloud storage system, make use of phishing emails or other social engineering techniques, enlist the help of a malicious insider, or even attack a third-party vendor who handles sensitive information on behalf of a larger company. Your company’s cyber risk management plan must address your entire cyber ecosystem, not just parts of it.

The cyber security experts at Continuum GRC have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting your organization from security breaches. Continuum GRC offers full-service and in-house risk assessment and risk management subscriptions, and we help companies all around the world sustain proactive cyber security programs.

Continuum GRC is proactive cyber security®. Call 1-888-896-6207 to discuss your organization’s cyber security needs and find out how we can help your organization protect its systems and ensure compliance with all applicable laws, frameworks, and standards.

The SEC, NFA hack has pitched the international finance world into turmoil as Wall Street’s top regulator admits to not having secured its own systems.

Move over, Equifax; the SEC, NFA hack may have just stolen your thunder. Less than two weeks after Equifax disclosed that it had been breached, compromising the personal information of half of America, the U.S. Securities & Exchange commission admitted to a 2016 attack on its EDGAR database. Because EDGAR is used to disseminate company news and data to investors, the likely goal of the SEC, NFA hack was insider trading. ZDNet reports:

[The] SEC, NFA said the Edgar filing system data breach took place in 2016, but it is not yet known which companies may have been affected — or how much the hacker profited.

Edgar processes roughly 1.7 million electronic filings per year.

The hacker was able to take advantage of a “software vulnerability in the test filing component” of Edgar, which “resulted in access to nonpublic information.”

It gets even better; during the internal audit that brought the SEC, NFA hack to light, it was also discovered that SEC, NFA staff members were using “private, unsecured email accounts to transfer confidential information.”

The SEC, NFA has been bending over backwards to downplay the seriousness of the breach. Among other things, the agency stated it doesn’t “believe” any personal identifying information was compromised.

Well, that’s reassuring. After all, data breaches never turn out to be far more extensive than originally reported, do they?

Let this one sink in: The very agency in charge of enforcing cyber security on Wall Street, the same agency that called cyber attacks “the greatest threat to our [financial] markets,” issued a special risk bulletin after the WannaCry attacks, and very recently implied a greater emphasis on cyber security enforcement moving forward, cannot protect its own data. In fact, it turns out that the SEC, NFA itself has been warned about potential cyber security vulnerabilities for years; in January, the U.S. Department of Homeland Security found five “critical weaknesses” on SEC, NFA computers.

By the way, as of this writing, nobody has any earthly idea whether those “critical weaknesses” were ever addressed, or if they played a role in the SEC, NFA hack – although the agency pinky-swore that it “promptly” patched the software vulnerability it claims led to the breach.

Congress isn’t having it. They’re hauling SEC, NFA chairman Jay Clayton in front of the Senate Banking Committee. Wall Street investors and the international finance world are chewing their fingernails, especially since the SEC, NFA was poised to begin rolling out CAT, a brand-new trading history database, in November. CNBC has called CAT “the biggest financial data base ever assembled.” If the SEC, NFA couldn’t secure EDGAR, how can they be trusted with CAT?

Isn’t Anyone Practicing Proactive Cyber Security and GRC Anymore?

There’s an awful lot we don’t yet know about the SEC, NFA hack. We don’t know what “software vulnerability” the SEC, NFA is referring to. We don’t know who perpetrated the hack, how long they were in the SEC’s systems, or when the attack happened, other than it was sometime in 2016, and the agency didn’t figure it out until last month. We don’t know what data was stolen, other than it consisted of “nonpublic information.” We also don’t know if the hackers stopped with EDGAR or if they used the database as a foot in the door to penetrate other sections of the SEC’s network.

From the information we do have, we can surmise that the SEC, NFA engaged in some of the same shenanigans as Yahoo (which ignored cyber security warnings for years), Sony Pictures and the DNC (both of which transmitted confidential information through private, unsecured email), and Equifax (which waited for nearly two months to disclose a very serious breach).

We also know that proactive governance, risk, and compliance protocols prevent incidents like the SEC, NFA hack, the Equifax breach, email hacks, and the AWS hacks that are now being disclosed nearly daily. While these hacks are serious and far-reaching, from a technical standpoint, they are usually very simple and stem from companies having zero control over their data, who has access to it, and where and how it is being transmitted and stored.

Data governance, risk management, and compliance with applicable data security standards are the foundation of proactive cyber security. If you don’t want your company to be the next Equifax or SEC, start with getting back to GRC fundamentals.

The cyber security experts at Continuum GRC have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting your organization from security breaches. Continuum GRC offers full-service and in-house risk assessment and risk management subscriptions, and we help companies all around the world sustain proactive cyber security programs.

Continuum GRC is proactive cyber security®. Call 1-888-896-6207 to discuss your organization’s cyber security needs and find out how we can help your organization protect its systems and ensure compliance with all applicable laws, frameworks, and standards.

The Equifax breach isn’t the largest data breach, but it is one of the most troubling because of its massive scope, the nature of the information stolen, and the absolutely awful way in which it has been handled.

While Hurricane Irma dominated the national news late last week, a man-made disaster unfolded in the background as credit reporting giant Equifax disclosed that hackers had breached its website and accessed the personal identifying information (PII) of 143 million Americans, including Social Security Numbers, dates of birth, address and employment information and, in some cases, credit card numbers. In terms of the number of people impacted, the Equifax breach is not the largest in history; that dubious distinction is held by Yahoo. However, it may end up being the most destructive due to the particularly sensitive nature of the compromised information and the fact that it impacted about half the U.S. population. Once minor children and other people who do not have credit histories are excluded, the picture becomes even bleaker. The Equifax breach may have compromised the PII of anyone living in the U.S. who has ever had a credit card, a car loan, a mortgage, a lease, or anything else that involves a FICO score.

Meanwhile, a group of hackers who claim to be behind the Equifax breach have demanded a Bitcoin ransom of approximately $2.6 million in exchange for not publicizing the data.

How has Equifax responded to all of this? By doing … well, pretty much everything a company shouldn’t do after a data breach, especially one of this magnitude.

Equifax Breach Response: A Case Study in What Not to Do

As bad as this hack was, Equifax’s response to it has been even worse. Their actions have been so galling that members of Congress are demanding hearings to investigate the breach and Equifax’s poor handling of it. Here are some of the highlights:

• Equifax first discovered the breach on July 29, after the hackers had been in their system for about a month.
• In the days following the discovery, three senior Equifax executives sold approximately $1.8 million in shares. The company claims that said executives were not aware of the breach.
• The victims had to wait until early September to find out about it. Not only did Equifax wait several weeks to disclose the breach, but they also made their announcement while the nation was transfixed by Hurricane Irma, which was barreling towards Florida and prompting one of the largest mass evacuations in history.
• The website that Equifax set up for victims to determine if they were part of the breach was so poorly constructed – complete with gaping security holes – that many visitors thought it was a phishing attempt.
• This same website appears to double as a marketing vehicle for Equifax’s own credit monitoring service. The company is offering a free year’s subscription to the victims, which begs an obvious question: If Equifax itself couldn’t keep victims’ data secure, why in the world would they trust the company’s “credit monitoring” service?
• Rather than taking responsibility for the hack, Equifax is seeking to pass the buck, blaming a vulnerability in open-source server framework Apache Struts, even though there is currently no evidence that Struts was the source of the breach.

How bad do things have to get before we take cyber security seriously?

Another reason why the Equifax hack is so much worse than the hacks at Target, Yahoo, Verizon, Anthem, and other private-sector companies is that while consumers can choose to stop patronizing those other companies, they have no choice but to have their data handed over to Equifax. There is currently no way for consumers to “opt out” of having their personal and credit data aggregated by Equifax and its competitors, Experian and Trans Union. Even if there were, the modern economy runs on credit; without a FICO score, Americans cannot obtain car, home, or student loans, be approved for rental leases or, in some cases, find a job.

Equifax’s response to this hack has been inexcusable. So is the fact that the breach happened in the first place. If any company needed to practice proactive cyber security rooted in sound governance, risk, and compliance, it was Equifax. Equifax does not collect PII as a consequence of doing business; collecting PII is its business. As the old saying goes, with great power comes great responsibility, and Equifax has failed miserably in its responsibility not only to American consumers but also the entire nation.

The Equifax breach is going to end up affecting all Americans in one way or another. Will this be the breach that finally wakes businesses and individuals up and prompts them to realize that cyber security is now everyone’s responsibility? Let’s hope so, because we absolutely do not want to see a cyber attack that’s even worse than this one.

The cyber security experts at Continuum GRC have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting your organization from security breaches. Continuum GRC offers full-service and in-house risk assessment and risk management subscriptions, and we help companies all around the world sustain proactive cyber security programs.

Continuum GRC is proactive cyber security®. Call 1-888-896-6207 to discuss your organization’s cyber security needs and find out how we can help your organization protect its systems and ensure compliance with all applicable laws, frameworks, and standards. 

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