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Doug Copley
Effectively Managing
Information Risk
CISO – Beaumont Health
Chairman Emeritus – Michigan Healthcare Cybersecurity Council
Audience Take-Aways
» How to identify the information that needs to
be protected
» Leveraging dependencies in
managing information risk
» Pragmatic steps to demonstrate
progress in managing information risk
2 17-Sep-2015
Information? Not IT?
C – I – S – O
Chief
Information (not IT)
Security
Officer
17-Sep-20153
Why Protect Information?
» Ponemon 2015 Cost of a Data Breach Study:
 Average cost per record in US: $217
 Average cost of data breach: $6.53M
17-Sep-20154
Average cost
per record by
industry
Source: Ponemon Institute©
Breach Costs
17-Sep-20155 Source: Ponemon Institute©
Why Protect Information?
17-Sep-20156 Source: Ponemon Institute©
Barriers to Managing Information Risk
» Lack of leadership
(concern) from CEO or
Board
» Lack of vision on how
future business needs will
impact information security
» Failure by businesses to
articulate the value of
information to the business
17-Sep-20157
Barriers to Managing Information Risk
» Too much focus on IT systems,
and not the information,
which is the real asset
» Board/CEO viewpoint that CIO
focus is technology, not
information
» Culture lacks accountability
for information
17-Sep-20158
WHAT INFORMATION DO I NEED TO
PROTECT?
17-Sep-2015 9
What Information Needs Protection?
» Identification
 Corporate Compliance
 Enterprise Risk
 Internal Audit
 Legal Affairs
 Regulatory Guidance
 Senior organizational
leaders
10 17-Sep-2015
What Information Needs Protection?
» What makes it critical to the organization?
 Confidentiality (PII, PHI)
 Integrity (financials, business intelligence)
 Availability (hourly/daily/weekly processing)
11 17-Sep-2015
Where is the Information?
» Internal
 Servers?
 PCs?
 File cabinets?
 Email?
 Databases and Data Warehouses?
 Backup media (tape/disk)?
 File Servers?
 SharePoint sites?
 Executive reports and archives of them?
12 17-Sep-2015
Where is the Information?
» External
 Supply Chain?
 Hosted Services
 Email?
 Applications?
 Cloud collaboration tools (Box, Onedrive)?
 Backup media stored off site (e.g. Iron Mountain)?
 Data Clearinghouses?
 Information Exchanges?
 Consortiums, Research, Public Health entities?
 Any stored/processed outside the US?
13 17-Sep-2015
Let’s Hope it’s not Here
17-Sep-201514
John Doe’s
WHO CAN HELP ME MANAGE
INFORMATION RISK?
17-Sep-2015 15
Natural Partners in Managing Risk
» Corporate Compliance
» Applicable regulations
» Risk of Non-Compliance
» Enterprise Risk Management
» Manages all risk across the company
» Will measure information risk the same as others
» Internal Audit
 Can help raise risk awareness to Board
 Can report on control effectiveness
16 17-Sep-2015
Natural Partners in Managing Risk
» Legal Affairs – advice
 Retention, litigation, legal precedents
» Human Resources
 Job Descriptions
 Training
» Information Technology
 Will implement technical controls
» Finance
 Will help quantify risk into currency
17 17-Sep-2015
WHERE CAN I START?
17-Sep-2015 18
1. Leverage a Consistent Process
17-Sep-201519
Example risk management process
2. Identify Sensitive Information
» Document what information needs protection
» Identify accountable owners
» Capture meta-data:
 Location or transfer, #records, classification,
#users with access, internally or externally
accessible
 What makes the information critical (C, I, A)
» Document in a repository that can be shared
with business partners
17-Sep-201520
3. Document It
» Information Asset Inventory
» Config Mgmt DB (CMDB) is a great place
 Location or transfer, #records, classification, #users
with access, internally or externally accessible, what
makes the information critical (C, I, A)
» SharePoint list (records by location/transfer)
» Organization-wide risk register
» Business Continuity Plans
21 17-Sep-2015
» Don’t forget to include
routine data transfers
4. Classify the Information
» Make it simple for users
 Ask yourself what requirements
would be different between classifications
 Default classification should require no action
 Is there a way to automate the classification?
» Data Labeling
» Data Handling Policy (information asset
management)
22 17-Sep-2015
Educate, Educate, Educate some more
5. Identify the Threats
» What are the relevant threat vectors?
 Cyber Attack
 Social Engineering & Malware
 Physical modification (ex. POS terminals)
 Web – False sites, man-in-middle, drive-by
downloads
 Mobile devices – IOS, Android, Blackberry, etc.
 Removable media – USB, DVD, Backup drives, etc.
 Email – phishing, malicious URLs and attachments
 Natural disaster – failure to continue/recover
17-Sep-201523
6. Identify Your Vulnerabilities
» Bugs - How’s your patching?
» Misconfigurations?
» Rapid changes in business or IT systems
» Would users know a malicious email or web
site if they seen one?
» Failure to apply due care/diligence in
managing IT systems
» Internal malicious or accidental use
17-Sep-201524
6. Identify Your Vulnerabilities
» Too many systems that don’t integrate
» Poorly authenticated remote access
» Do your systems filter or flag suspicious
emails, URLs or file attachments?
» What devices can attach to your network?
» Do you permit use of removable media?
17-Sep-201525
7. Information Access Administration
» Who’s responsible for the information?
 Do they understand their role?
» Who has access?
» Is the access appropriate? Are roles used?
» Who is approving access?
» Who is administering the access?
» What permission reviews are taking place?
» Is activity also reviewed?
26 17-Sep-2015
8. Evaluate the Risks
» Determine which threats and vulnerabilities
apply to each set of information
» Ask yourself the worse case scenario.
» Assess likelihood and impact
» Do you have controls that mitigate some risk?
» Use Finance to help measure risk in $$
» Rank risks – is there a documented tolerance?
» Evaluate cost and effort of additional
mitigating controls
» Let governance committee decide actions
17-Sep-201527
17-Sep-2015 28
or
17-Sep-2015 29
“Danger, Will Robinson!”
Example: SharePoint Library
Business Unit exchanges PII data with outside
companies or individuals
» External collaborators access SharePoint
» 450 people have access to the data
» Worse case: all data is made public/breached
» Access is authenticated, but each external
company uses a generic credential
» 50,000 records in the site
17-Sep-201530
Example: SharePoint Library
Evaluation Data
» 50,000 records * $200/record = $10M exposure
» Controls mitigates 80%  $2M
» Organization accepts anything $1M or less
 Control: Could issue credentials to every user
 Control: Could perform periodic activity reviews
 Control: Could force 2-factor authentication
 Control: Could alert on access by users not in ACL
» Selected controls - $180,000; reduction to 5%
($500k)
17-Sep-201531
9. What Tools Can Help?
» Information classification
 Titus has a mature product for
classification & retention
» Information location
 Data Loss Prevention tools can scan repositories and
PCs looking for sensitive data
» Information movement
 Data Loss Prevention tools can detect/prevent the
movement of sensitive data
» Good security awareness campaigns
» Lots of GRC tools to help manage your risks
17-Sep-201532
10. Monitor Your Information Risks
» Is information being exposed?
» Is information being used inappropriately?
» Is sensitive data being infiltrated?
» Are outages causing unavailability?
» Periodically re-assess your threats and
assumptions to make sure they’re still valid
17-Sep-201533
Summary
1. Leverage a consistent risk process
2. Identify your sensitive information
3. Document what, where, how much, etc.
4. Classify the information
5. Identify relevant threats
6. Identify your vulnerabilities
7. Identify existing controls that mitigate risk
8. Calculate the residual risk
9. Determine whether action is required
10. Monitor your risks and always look for new ones
34 17-Sep-2015
Questions?
17-Sep-2015 35
Thank You!
17-Sep-2015 36

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Managing Information Risk

  • 1. Doug Copley Effectively Managing Information Risk CISO – Beaumont Health Chairman Emeritus – Michigan Healthcare Cybersecurity Council
  • 2. Audience Take-Aways » How to identify the information that needs to be protected » Leveraging dependencies in managing information risk » Pragmatic steps to demonstrate progress in managing information risk 2 17-Sep-2015
  • 3. Information? Not IT? C – I – S – O Chief Information (not IT) Security Officer 17-Sep-20153
  • 4. Why Protect Information? » Ponemon 2015 Cost of a Data Breach Study:  Average cost per record in US: $217  Average cost of data breach: $6.53M 17-Sep-20154 Average cost per record by industry Source: Ponemon Institute©
  • 5. Breach Costs 17-Sep-20155 Source: Ponemon Institute©
  • 6. Why Protect Information? 17-Sep-20156 Source: Ponemon Institute©
  • 7. Barriers to Managing Information Risk » Lack of leadership (concern) from CEO or Board » Lack of vision on how future business needs will impact information security » Failure by businesses to articulate the value of information to the business 17-Sep-20157
  • 8. Barriers to Managing Information Risk » Too much focus on IT systems, and not the information, which is the real asset » Board/CEO viewpoint that CIO focus is technology, not information » Culture lacks accountability for information 17-Sep-20158
  • 9. WHAT INFORMATION DO I NEED TO PROTECT? 17-Sep-2015 9
  • 10. What Information Needs Protection? » Identification  Corporate Compliance  Enterprise Risk  Internal Audit  Legal Affairs  Regulatory Guidance  Senior organizational leaders 10 17-Sep-2015
  • 11. What Information Needs Protection? » What makes it critical to the organization?  Confidentiality (PII, PHI)  Integrity (financials, business intelligence)  Availability (hourly/daily/weekly processing) 11 17-Sep-2015
  • 12. Where is the Information? » Internal  Servers?  PCs?  File cabinets?  Email?  Databases and Data Warehouses?  Backup media (tape/disk)?  File Servers?  SharePoint sites?  Executive reports and archives of them? 12 17-Sep-2015
  • 13. Where is the Information? » External  Supply Chain?  Hosted Services  Email?  Applications?  Cloud collaboration tools (Box, Onedrive)?  Backup media stored off site (e.g. Iron Mountain)?  Data Clearinghouses?  Information Exchanges?  Consortiums, Research, Public Health entities?  Any stored/processed outside the US? 13 17-Sep-2015
  • 14. Let’s Hope it’s not Here 17-Sep-201514 John Doe’s
  • 15. WHO CAN HELP ME MANAGE INFORMATION RISK? 17-Sep-2015 15
  • 16. Natural Partners in Managing Risk » Corporate Compliance » Applicable regulations » Risk of Non-Compliance » Enterprise Risk Management » Manages all risk across the company » Will measure information risk the same as others » Internal Audit  Can help raise risk awareness to Board  Can report on control effectiveness 16 17-Sep-2015
  • 17. Natural Partners in Managing Risk » Legal Affairs – advice  Retention, litigation, legal precedents » Human Resources  Job Descriptions  Training » Information Technology  Will implement technical controls » Finance  Will help quantify risk into currency 17 17-Sep-2015
  • 18. WHERE CAN I START? 17-Sep-2015 18
  • 19. 1. Leverage a Consistent Process 17-Sep-201519 Example risk management process
  • 20. 2. Identify Sensitive Information » Document what information needs protection » Identify accountable owners » Capture meta-data:  Location or transfer, #records, classification, #users with access, internally or externally accessible  What makes the information critical (C, I, A) » Document in a repository that can be shared with business partners 17-Sep-201520
  • 21. 3. Document It » Information Asset Inventory » Config Mgmt DB (CMDB) is a great place  Location or transfer, #records, classification, #users with access, internally or externally accessible, what makes the information critical (C, I, A) » SharePoint list (records by location/transfer) » Organization-wide risk register » Business Continuity Plans 21 17-Sep-2015 » Don’t forget to include routine data transfers
  • 22. 4. Classify the Information » Make it simple for users  Ask yourself what requirements would be different between classifications  Default classification should require no action  Is there a way to automate the classification? » Data Labeling » Data Handling Policy (information asset management) 22 17-Sep-2015 Educate, Educate, Educate some more
  • 23. 5. Identify the Threats » What are the relevant threat vectors?  Cyber Attack  Social Engineering & Malware  Physical modification (ex. POS terminals)  Web – False sites, man-in-middle, drive-by downloads  Mobile devices – IOS, Android, Blackberry, etc.  Removable media – USB, DVD, Backup drives, etc.  Email – phishing, malicious URLs and attachments  Natural disaster – failure to continue/recover 17-Sep-201523
  • 24. 6. Identify Your Vulnerabilities » Bugs - How’s your patching? » Misconfigurations? » Rapid changes in business or IT systems » Would users know a malicious email or web site if they seen one? » Failure to apply due care/diligence in managing IT systems » Internal malicious or accidental use 17-Sep-201524
  • 25. 6. Identify Your Vulnerabilities » Too many systems that don’t integrate » Poorly authenticated remote access » Do your systems filter or flag suspicious emails, URLs or file attachments? » What devices can attach to your network? » Do you permit use of removable media? 17-Sep-201525
  • 26. 7. Information Access Administration » Who’s responsible for the information?  Do they understand their role? » Who has access? » Is the access appropriate? Are roles used? » Who is approving access? » Who is administering the access? » What permission reviews are taking place? » Is activity also reviewed? 26 17-Sep-2015
  • 27. 8. Evaluate the Risks » Determine which threats and vulnerabilities apply to each set of information » Ask yourself the worse case scenario. » Assess likelihood and impact » Do you have controls that mitigate some risk? » Use Finance to help measure risk in $$ » Rank risks – is there a documented tolerance? » Evaluate cost and effort of additional mitigating controls » Let governance committee decide actions 17-Sep-201527
  • 30. Example: SharePoint Library Business Unit exchanges PII data with outside companies or individuals » External collaborators access SharePoint » 450 people have access to the data » Worse case: all data is made public/breached » Access is authenticated, but each external company uses a generic credential » 50,000 records in the site 17-Sep-201530
  • 31. Example: SharePoint Library Evaluation Data » 50,000 records * $200/record = $10M exposure » Controls mitigates 80%  $2M » Organization accepts anything $1M or less  Control: Could issue credentials to every user  Control: Could perform periodic activity reviews  Control: Could force 2-factor authentication  Control: Could alert on access by users not in ACL » Selected controls - $180,000; reduction to 5% ($500k) 17-Sep-201531
  • 32. 9. What Tools Can Help? » Information classification  Titus has a mature product for classification & retention » Information location  Data Loss Prevention tools can scan repositories and PCs looking for sensitive data » Information movement  Data Loss Prevention tools can detect/prevent the movement of sensitive data » Good security awareness campaigns » Lots of GRC tools to help manage your risks 17-Sep-201532
  • 33. 10. Monitor Your Information Risks » Is information being exposed? » Is information being used inappropriately? » Is sensitive data being infiltrated? » Are outages causing unavailability? » Periodically re-assess your threats and assumptions to make sure they’re still valid 17-Sep-201533
  • 34. Summary 1. Leverage a consistent risk process 2. Identify your sensitive information 3. Document what, where, how much, etc. 4. Classify the information 5. Identify relevant threats 6. Identify your vulnerabilities 7. Identify existing controls that mitigate risk 8. Calculate the residual risk 9. Determine whether action is required 10. Monitor your risks and always look for new ones 34 17-Sep-2015