This document provides a checklist for responding to a sensitive data exposure incident with 12 steps. It details actions to identify and contain the incident, assess the damage and data exposure, eradicate vulnerabilities and recover systems, notify affected individuals, and follow up. The checklist contains over 100 sub-steps and references resources to help guide the incident response process.
Improving cyber security using biosecurity experienceNorman Johnson
See the paper that goes with the PPT on my LinkedIn.
See detailed comments in PPT.
Abstract: How does the current planning and response to cyber threats compare to biological threats planning and response? How do the resources of each compare? Biothreats have been a concern for millennia, and humans systems have had significant time and funding to develop a mature response. In this paper we observe that by comparison, cyber response is still in a relatively immature stage, possibly comparable to the state of public health protection prior to the implementation of safe water, sanitary conditions and vaccinations. Furthermore, we argue that because of the similarity between bio- and cyber systems, there are significant opportunities to advance the maturity of cyber research and response, either by using bio analogies for inspiration or by the direct transfer of resources. An analysis of existing cyber resources and gaps are compared to available bio resources. Specific examples are provided for the application of bio-resources to cyber systems.
Task Incident Readiness with Veris, Judy Nowak at TASK Toronto, April 27, 2...patmisasi
Responding to cyber incidents is not what it used to be, the landscape has changed considerably; proactive response now requires the use of many tools and extensive coordination and expertise. Adding to the complexity is the common confusion between IR and forensics. Where does forensics begin and incident response start? What incidents require forensic investigation? And what should you know to pull the pieces together?
Embarking on creating an incident response (IR) program can be challenging and frustrating. This presentation discusses that in order to adequately prepare for security incidents you need an IR framework that can lay the foundation for your IR plan and in turn help describe attacks. Describing attacks is important because you cannot respond to what you cannot identify.
VERIS will be used as an example framework to help you along your path in creating a successful cyber response program.
AN ISP BASED NOTIFICATION AND DETECTION SYSTEM TO MAXIMIZE EFFICIENCY OF CLIE...IJNSA Journal
End users are increasingly vulnerable to attacks directed at web browsers which make the most of popularity of today’s web services. While organizations deploy several layers of security to protect their systems and data against unauthorised access, surveys reveal that a large fraction of end users do not utilize and/or are not familiar with any security tools. End users’ hesitation and unfamiliarity with security products contribute vastly to the number of online DDoS attacks, malware and Spam distribution. This work on progress paper proposes a design focused on the notion of increased participation of internet service providers in protecting end users. The proposed design takes advantage of three different detection tools to identify the maliciousness of a website content and alerts users through utilising Internet Content Adaptation Protocol (ICAP) by an In-Browser cross-platform messaging system. The system also incorporates the users’ online behaviour analysis to minimize the scanning intervals of malicious websites database by client honeypots. Findings from our proof of concept design and other research indicate that such a design can provide a reliable hybrid detection mechanism while introducing low delay time into user browsing experience.
My incident Response from Techfair 2016 in Jersey. The talk explores how incident response could to comply with the requirements set out in the Jersey Financial Services Commission Dear CEO letter on cyber security.
How To Turbo-Charge Incident Response With Threat IntelligenceResilient Systems
Minutes, hours, days - each one counts when responding to a security incident. Yet most firms have a lot of room for improvement. According to the 2013 Verizon Data Breach Investigations Report, in 66% of cases (up from 56% last year), breaches remained undiscovered for years, and in 22% of cases, it took months to fully contain the incident.
This webinar will review the challenges firms face in trying to create a rapid and decisive incident response (IR) process. It will then highlight the crucial role that timely, contextual threat intelligence can play in turbo-charging incident response, particularly when tightly integrated with the broader IR discipline. Finally, it will reveal the power of this approach by demonstrating Co3's integrated threat intelligence capabilities including intel from industry-leader iSIGHT Partners.
CompTIA exam study guide presentations by instructor Brian Ferrill, PACE-IT (Progressive, Accelerated Certifications for Employment in Information Technology)
"Funded by the Department of Labor, Employment and Training Administration, Grant #TC-23745-12-60-A-53"
Learn more about the PACE-IT Online program: www.edcc.edu/pace-it
Improving cyber security using biosecurity experienceNorman Johnson
See the paper that goes with the PPT on my LinkedIn.
See detailed comments in PPT.
Abstract: How does the current planning and response to cyber threats compare to biological threats planning and response? How do the resources of each compare? Biothreats have been a concern for millennia, and humans systems have had significant time and funding to develop a mature response. In this paper we observe that by comparison, cyber response is still in a relatively immature stage, possibly comparable to the state of public health protection prior to the implementation of safe water, sanitary conditions and vaccinations. Furthermore, we argue that because of the similarity between bio- and cyber systems, there are significant opportunities to advance the maturity of cyber research and response, either by using bio analogies for inspiration or by the direct transfer of resources. An analysis of existing cyber resources and gaps are compared to available bio resources. Specific examples are provided for the application of bio-resources to cyber systems.
Task Incident Readiness with Veris, Judy Nowak at TASK Toronto, April 27, 2...patmisasi
Responding to cyber incidents is not what it used to be, the landscape has changed considerably; proactive response now requires the use of many tools and extensive coordination and expertise. Adding to the complexity is the common confusion between IR and forensics. Where does forensics begin and incident response start? What incidents require forensic investigation? And what should you know to pull the pieces together?
Embarking on creating an incident response (IR) program can be challenging and frustrating. This presentation discusses that in order to adequately prepare for security incidents you need an IR framework that can lay the foundation for your IR plan and in turn help describe attacks. Describing attacks is important because you cannot respond to what you cannot identify.
VERIS will be used as an example framework to help you along your path in creating a successful cyber response program.
AN ISP BASED NOTIFICATION AND DETECTION SYSTEM TO MAXIMIZE EFFICIENCY OF CLIE...IJNSA Journal
End users are increasingly vulnerable to attacks directed at web browsers which make the most of popularity of today’s web services. While organizations deploy several layers of security to protect their systems and data against unauthorised access, surveys reveal that a large fraction of end users do not utilize and/or are not familiar with any security tools. End users’ hesitation and unfamiliarity with security products contribute vastly to the number of online DDoS attacks, malware and Spam distribution. This work on progress paper proposes a design focused on the notion of increased participation of internet service providers in protecting end users. The proposed design takes advantage of three different detection tools to identify the maliciousness of a website content and alerts users through utilising Internet Content Adaptation Protocol (ICAP) by an In-Browser cross-platform messaging system. The system also incorporates the users’ online behaviour analysis to minimize the scanning intervals of malicious websites database by client honeypots. Findings from our proof of concept design and other research indicate that such a design can provide a reliable hybrid detection mechanism while introducing low delay time into user browsing experience.
My incident Response from Techfair 2016 in Jersey. The talk explores how incident response could to comply with the requirements set out in the Jersey Financial Services Commission Dear CEO letter on cyber security.
How To Turbo-Charge Incident Response With Threat IntelligenceResilient Systems
Minutes, hours, days - each one counts when responding to a security incident. Yet most firms have a lot of room for improvement. According to the 2013 Verizon Data Breach Investigations Report, in 66% of cases (up from 56% last year), breaches remained undiscovered for years, and in 22% of cases, it took months to fully contain the incident.
This webinar will review the challenges firms face in trying to create a rapid and decisive incident response (IR) process. It will then highlight the crucial role that timely, contextual threat intelligence can play in turbo-charging incident response, particularly when tightly integrated with the broader IR discipline. Finally, it will reveal the power of this approach by demonstrating Co3's integrated threat intelligence capabilities including intel from industry-leader iSIGHT Partners.
CompTIA exam study guide presentations by instructor Brian Ferrill, PACE-IT (Progressive, Accelerated Certifications for Employment in Information Technology)
"Funded by the Department of Labor, Employment and Training Administration, Grant #TC-23745-12-60-A-53"
Learn more about the PACE-IT Online program: www.edcc.edu/pace-it
The key goal for Assignment 1 is to test your knowledge and understanding of all the material that was covered throughout the Digital Forensics module. The assignment will be split into three sections:
Part 1 – General knowledge:
o This section will be a test on your understanding of theoretical knowledge on fundamental concepts of computer security, cybercrime and digital forensics
Part 2 – Comprehension:
o This section will be a test on your comprehension of different aspects of the digital forensics process as outlined in the weekly reading material
Part 3 – Application of knowledge
o This section will be a test on your ability to effectively apply your knowledge and understanding of digital forensics to real-world scenarios
E’s Data Security Company Strategic Security Plan – 2015.docxmydrynan
E’s Data Security Company Strategic Security Plan – 2015
Table of Contents
1 EXECUTIVE SUMMARY 3
1.1 Introduction 3
1.2 Objectives 3
1.3 Determine company position 4
2 INTRODUCTION TO SECURITY 4
2.1 Develop 4
2.2 Information Security Employee Responsibilities 4
2.3 Establish Oversight Authority for Information Security 4
2.4 Establish Reporting Procedures for Leaders 5
2.5 Review of Pertinent or Sensitive Data 5
2.6 Purge Unneeded Data 5
3.3 Unauthorized Systems Access – 6
4.3 Educate employees on cyber threats and trends 6
5 EMERGENCY SITUATIONS 7
5.1 Chain of Command 7
5.2 Communications plan 7
5.3 Safety and Security Drills 7
6. SECURITY RISK MANAGEMENT 7
7 REFERENCES 9
1 EXECUTIVE SUMMARY
Per APA, Always Use Times new Roman 12 Font…
E’s Data Security Company was established in 2010. It is an organization that provides data security and network solutions to the state and local government of the US Virgin Islands. An executive summary is much more than just one sentence… Add much more detail here… I suggest you eliminate the executive summary and start with your introduction.. 1.1 Introduction
In April 2014 E’s Data Security Company began its first phase of implementing a security plan for use within the company. This began what began?? Add more clarity here… by hiring its first Chief Information Security Officer (CISO) for the sole purpose of creating a security program for IT purposes (Scalet, 2006). Initially, the efforts of this plan were focused on obtaining the proper staffing to provide support in the implementation of this plan. It is imperative to understand that the development of an IT Security Program is an ongoing process that is ever-evolving, and a shared responsibility (M.U.S.E., n.d.). By coordinating efforts with local, state, and federal government entities, this plan creates a comprehensive opportunity to address the need for such a plan. Due to the fact that this organization serves a small community, the planning process will mainly rely principally on informal relationships. The formalization of this planning process varies based on the frequency of a particular hazard and its impact on the community.
1.2 Objectives This plan is presented and lists a set of goals for oversight and program implementation.
A. Implement and maintain policies and procedures for data security. B. Implement and maintain procedures to test system resilience.
C. Implement and maintain education for employees regarding system vulnerabilities.
D. Implement and maintain physical security procedures.
E. Implement, maintain and review policies for emergency response(s). 1.3 Determine company position
In order tTo determine where the organization stands, an external and internal audit will be conducted to determine its competency (Entrepreneurs, 2011). What is the purpose of this section?? 2 INTRODUCTION TO SECURITY
2.1 Develop – In collaboration with government agencies, the strategic plan ...
Developing a Continuous Monitoring Action PlanTripwire
At the direction of OMB and NIST, security and IT pros in federal government must develop plans to implement "continuous monitoring," the practice of using IT security controls to constantly monitor and manage the security status of their information systems and networks. The transition from static security to continuous monitoring requires a new approach to IT security, and IT teams must devise a strategy and roadmap to be successful.
In this editorial Webcast, cybersecurity experts will help discuss the tools and processes involved in moving from a traditional security environment to one designed around continuous monitoring. This Webcast will help government IT pros:
Understand the objectives of continuous monitoring, such as reduced threat exposure through real time risk assessment and response.
Identify the steps involved, including determining the security impact of changes to IT systems and producing assessment reports.
Assess system requirements in areas such as malware detection and event and incident management.
Determine the need for upgrades and investment in new technologies.
Deep Learning based Threat / Intrusion detection systemAffine Analytics
The article is about a Threat/Intrusion Detection System, which could be used to detect such data leaks/breaches & take a preventive action to contain, if not stop the damage due to breach.
CompTIA exam study guide presentations by instructor Brian Ferrill, PACE-IT (Progressive, Accelerated Certifications for Employment in Information Technology)
"Funded by the Department of Labor, Employment and Training Administration, Grant #TC-23745-12-60-A-53"
Learn more about the PACE-IT Online program: www.edcc.edu/pace-it
Unit III AssessmentQuestion 1 1. Compare and contrast two.docxmarilucorr
Unit III Assessment:
Question 1
1. Compare and contrast two learning theories. Which one do you believe is most effective? Why?
Your response should be at least 200 words in length.
Question 2
1. Explain how practice helps learning. Give examples of how this has helped you.
Your response should be at least 200 words in length.
Running head: RANSOMWARE ATTACK 1
RANSOMWARE ATTACK 2
Situational Report on Ransomware Attack
Name
Institution
Date
Ransomware Attack-Situational Report
The current attack involves ransomware located inside the organizational network. The ransomware attacker has also raised the demand to $5000 in Bitcoin per nation-state. Virtual currencies such as Bitcoin present significant challenges and has widespread financial implications. The malware was zipped and protected with a password. The affected hosts had executable files and also malicious artifacts. The malware dropped some items in the database. The malware also had to write privileges as it uploaded some files to the webserver (Johnson, Badger, Waltermire Snyder & Skorupka, 2016). The malware also retrieved some files from the server using the “GET” HTTP request. The file hash and requested passed onto the urls indicate a breach of security.
Security Incident Report / SITREP #2017-Month-Report#
Incident Detector’s Information
Date/Time of Report
15/02/2018 1.40 p.m.
First Name
Amanda
Last Name
Smith
OPDIV
Avitel/Information Security
Title/Position
System Analyst
Work Email Address
[email protected]
Contact Phone Numbers
Work 321-527-4477
Government Mobile
Government Pager
Other
Reported Incident Information
Initial Report Filed With (Name, Organization)
CISO, Avitel Analysts
Start Date/Time
15/02/2018
Incident Location
HR Office
Incident Point of Contact (if different than above)
Internal Ransomware
Priority
Level 2
Possible Violation of ISO/IEC 27002:2013
YES ISO/IEC 27002
Privacy Information - ISO 27000 (Country Privacy Act Law)
The incident violated ISO 27000. The attack is an indication of failure in the state of the corporate network or existing security policies.
The target suffered adversely by limiting the conference participants from accessing the network resources. The violation was intentional.
Incident Type
Alteration of information from the server. There are database queries indicating that the attack involved modifying some entries in the database.
US-CERT Category
Ransomware/ Unauthorized Access
CERT Submission Number, where it exists
The ransomware attack can be reported to the CCIRC Canadian Cyber Incidence Response Centre Team for an appropriate response to the incident.
Description
The ransomware makes it quite difficult to guess the password unless the conference participants pay the demanded amount. The Crypto-ransomware locks the system unless the system is unlocked via the password.
1. User asked to update links
2. User disables security controls
3. Malware opens a command prompt
4. The script u ...
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The FBI is the lead federal agency for investigating malicious cyber activity by criminals, nation-state adversaries, and terrorists. To fulfill this mission, the FBI often develops resources to enhance operations and collaboration. One such resource is the FBI’s Internet Crime Complaint Center (IC3) which provides the public with a trustworthy and convenient mechanism for reporting information concerning suspected Internet-facilitated criminal activity. At the end of every year, the IC3 collates information collected into an annual report.
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Credit is due to all original authors and no financial gain was made from the report, Simply sharing an interesting story for educational purposes,
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Credit is due to all original authors and no financial gain was made from the report, Simply sharing an interesting story for educational purposes,
This report is built upon analysis of 41,686 security incidents, of which 2,013 were confirmed data breaches. We will take a look at how results are changing (or not) over the years as well as digging into the overall threat landscape and the actors, actions, and assets that are present in breaches. Windows into the most common pairs of threat actions and affected assets also are provided.
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to address a wide array of practices affecting consumers, including those that emerge with the development of new technologies and business models.
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A credit score is a three -digit number that predicts how likely you are to pay back a loan on time, based on information from your credit reports.
Company names mentioned herein are the property of, and may be trademarks of, their respective owners and are for educational purposes only.
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This guide addresses the steps to take once a
breach has occured. For advice on implementing a
plan to protect consumers’ personal information, to
prevent breaches and unauthorized access, check
out the FTC’s Protecting Personal Information: A
Guide for Business and Start with Security: A Guide
for Business.
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All information, data, and material contained, presented, or provided on is for educational purposes only.
Company names mentioned herein are the property of, and may be trademarks of, their respective owners.
It is not to be construed or intended as providing legal advice.
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Sensitive Data Exposure Incident Checklist
1. Page 1 of 12 – May 8, 2013
SENSITIVE DATA EXPOSURE INCIDENT CHECKLIST
INCIDENT # ________________
Date became aware: ____________ Date reported to Security Office: ____________ Date affected individuals notified: ____________
(should be within one week of incident discovery)
Type and scope of data exposed:
Incident Team:
STEP 1: IDENTIFICATION
Verify that an incident has actually occurred. This activity typically involves the Unit systems administrator and end user, but may also result
from proactive incident detection work of the Security Office or central IT operations. If it is determined that an incident has occurred, inform
appropriate authorities.
Done Task Owner Notes
1.1 Immediately contain and limit exposure:
- If electronic device has been compromised:
o Do not access (do not logon) or alter compromised device
o Do not power off the compromised device
o Do unplug network cable (NOT power cable) from the compromised
device
- Write down how the incident was detected and what actions have been taken
so far. Provide as much specificity as possible, including dates, times, and
impacted machines, applications, websites, etc.
RESOURCES:
a) New York University IT Security Information Breach Notification Procedure
b) University of Massachusetts Amherst Incident Prevention and Response
Procedure
Unit
2. Page 2 of 12 – May 8, 2013
1.2 Alert Security Office immediately
GUIDANCE: Insert appropriate names and telephone numbers, email address, and/or
link to online security incident reporting form.
EXAMPLES:
c) Call John Smith at 999-999-9999 or Mary Jones at 999-999-9999. If you do
not get one of them IN PERSON, then call the Help Desk at 999-999-9999 and
have them contact the Information Security Office. Also send details to it-
incident@xxxxx.edu
d) Report incident according to XYZ policy via online form (preferred) or call
John Smith at 999-99-9999.
RESOURCES:
a) Indiana University Incident Reporting Procedures
b) University of Virginia Information Security Incident Reporting Policy and
online reporting form
Unit
1.3 If the incident involves electronic devices or media stolen or lost within the local
community, also alert law enforcement.
GUIDANCE: This sub-step should be included ONLY if advised to do so by your campus
police department. Be certain to consult with them on this issue.
EXAMPLES:
a) Call Campus Policy Hotline at 999-999-9999
b) Call E-911 to report the incident. The E-911 service will contact the
appropriate city, county, or campus police jurisdiction.
Unit
1.4 Conduct preliminary assessment of type and scope of data exposed. If the incident
potentially exposed sensitive data, notify all appropriate institution officials and
keep them informed as incident investigation progresses:
EXAMPLES:
a) Executive in charge of IT for the institution, e.g., Vice President/CIO
b) Executive in charge of organizational unit in which incident occurred, e.g.,
Vice President, Provost, Dean
c) Campus Chancellor/President (or his/her Chief of Staff)
Security
Office
3. Page 3 of 12 – May 8, 2013
d) Counsel for the institution
e) Law enforcement, e.g., campus police, FBI local office, Secret Service local
office
f) Public Affairs
g) Internal Audit
h) Risk Management
i) Appropriate Data Steward(s) for the type of data potentially at risk
j) Health information compliance office, if HIPAA-protected potentially at risk
k) Vice president for research, if research data potentially at risk
l) Finance office, if credit card #, bank account #, or other sensitive financial
data potentially at risk
1.5 If there is evidence of criminal activity connected with the incident determine
interest of law enforcement in leading the investigation. If law enforcement (e.g.,
FBI) takes lead, subsequent steps may be performed by law enforcement or require
authorization from the law enforcement lead.
STEP 2: DAMAGE CONTAINMENT AND DATA EXPOSURE ASSESSMENT
Identify an Incident Response Lead and assemble an incident response team charged with limiting further damage from the incident.
Conduct a thorough assessment of the type and scope of data exposed following applicable laws, regulation and policy.
2.1 Assemble Incident Response Team
GUIDANCE: Ensure that the representative from the organizational unit where the
incident occurred participates and that this individual is high enough in the
organization to make necessary decisions.
Security
Office
2.2 Review incident response process and responsibilities with Incident Response
Team
- Provide each member with current Sensitive Data Exposure Incident Checklist
- Discuss communications strategy
- Stress importance of maintaining chain of custody
GUIDANCE: Discussing the rules of communication with the team at this stage is
particularly important to ensure accuracy of facts among team members and between
the team and appropriate University officials.
Security
Office
4. Page 4 of 12 – May 8, 2013
EXAMPLES:
a) Team members must not discuss the incident with anyone outside the team
until and only if authorized to do so by the Security Office head.
b) All documentation created by team members must be fact-based, as it may
become important reference or evidence
c) Daily conference call of team members will be held discuss status.
d) Instruct team to track time spent on the incident.
2.3 Collect and preserve evidence
GUIDANCE:
Collect physical and cyber evidence that provides a clear, detailed description of how
the sensitive data was compromised.
EXAMPLES:
a) Image of hard drive(s)Physical equipment
b) Network traffic flow to/from compromised device
c) Workstation and application logs
d) Access logs
e) Digital photographs of the evidence and surrounding area
RESOURCES:
http://www.educause.edu/Resources/ForensicOverview/161135
http://www.cybercrime.gov/ssmanual/index.html
http://csrc.nist.gov/publications/nistpubs/800-61-rev1/SP800-61rev1.pdf
Incident
Response
Team
2.4 Establish and maintain appropriate chain of custody for all evidence.
GUIDANCE:
Inventory pieces of evidence and track who accessed, used, stored, moved or returned
each piece of evidence and when it was accessed.
EXAMPLES:
a) Establish what exactly the evidence is
b) Document who handled it and why
c) Document where and how it was stored
d) When equipment is moved, ensure that a detailed receipt is signed and dated
by the previous person with possession, the mover and the new person with
5. Page 5 of 12 – May 8, 2013
responsibility for the equipment
RESOURCES:
http://www.cert.org/csirts/services.html
http://www.sans.org/score/incidentforms/ChainOfCustody.pdf
2.5 Take actions needed to limit the scope and magnitude of the incident
EXAMPLES:
a) If the incident involves sensitive data improperly posted on one or more
publicly accessible websites, remove active and cached content and request
takedown of cached web page(s) indexed by search engine companies and
other Internet archive entities, e.g., Wayback Machine
b) Change passwords that may have been compromised
c) Cease operation of a compromised application or server
Incident
Response
Team
2.6 Perform forensics and document findings:
a. Analyze evidence
b. Reconstruct incident
c. Provide detailed documentation
GUIDANCE: Preserve original evidence and work on a copy of data
Obtain and preserve with minimal disturbance to units, systems and original evidence
Results should be repeatable
Incident
Response
Team
2.7 Complete final assessment and documentation of type and scope of data exposed,
as well as the availability and type of contact data for individuals affected
Incident
Response
Team
STEP 3: ERADICATION AND RECOVERY
Take steps to remove the cause of the exposure, reduce the impact of the exposure of the sensitive data, restore operations if the incident
compromised or otherwise put out of service a system or network, and ensure that future risk of exposure is mitigated
3.1 Revisit 2.4 and look for additional ways to limit exposure
EXAMPLES:
a) Run web queries periodically to ensure that the data has not been further
6. Page 6 of 12 – May 8, 2013
exposed or cached.
b) Review the inventory of equipment and systems impacted and change
additional passwords that may have been compromised
c) Cease operation of a compromised application or server and develop work-
arounds
3.2 Eradicate and/or mitigate system vulnerabilities, review access privileges and
remediate risks to sensitive data stores
EXAMPLES:
a) Run vulnerability scans on impacted systems;
b) Review and determine where data resides and make adjustments to ensure
increased protection as needed.
c) Limit access to systems to only those who need it;
d) Use software tools to find, delete and secure sensitive data, e.g., Identity
Finder
3.3 Return evidentiary equipment and systems to service once they are secured.
STEP 4: NOTIFICATION
Determine the need to give notice to individuals whose data may have been exposed by the incident. Swiftness in notifying those affected by a
breach of personally identifiable information, as well as informing certain government entities, is legally mandated in many states and,
depending on the nature of the data, also federal law. Speed is also important from a public relations standpoint. To this end, many of the sub-
steps can and should be undertaken in parallel to accommodate these needs.
4.1 Make decisions based upon Incident Response Team findings
- Does level of exposure risk warrant notification letters?
- If yes,
• If applicable, has law enforcement authorized notification to affected
parties?
• Who will issue letter?
• Who will handle telephone and email responses to questions from affected
individuals? Does expected volume warrant setting up call center?
• Does magnitude of exposure warrant a press release? Incident information
website?
• Does exposure risk warrant free credit monitoring?
Appropriate
institution
officials
7. Page 7 of 12 – May 8, 2013
- If a reasonable risk of exposure does not exist, all remaining sub-steps in
this section should be bypassed and STEP 5 Follow-up should commence.
GUIDANCE:
a) Those responsible for making these decisions will vary from institution to
institution, but typically is a subset of officials informed in Sub-step 1.4.
Decisions made should be in line with previous decisions or any deviations
fully justified. Obviously, all incident notification laws, regulations, and
contractual requirements must be followed.
b) While breach notification laws, regulations, and contractual requirements
vary, alternatives to issuing written notices by postal mail are often allowable
depending upon the cost of providing notice, the number of individuals who
must be notified, and/or the availability of contact information. These
alternatives might, for example, include, but are not limited to, one or more of
the following: conspicuous posting of notices on the institution’s website, press
releases, email notices where addresses are known, telephone notices.
c) See EDUCAUSE Data Incident Notification Toolkit for further guidance.
4.2 Collect name and contact information on affected individuals
GUIDANCE: This could be a laborious process if individuals are not current students,
faculty, staff, donors, patients, etc. of the institution. It is advisable that the best
sources of address data for former students, faculty, and staff, as well as alumni,
volunteers, contractors, and other affiliates of the institutions whose sensitive data are
maintained by the institutions be identified in advance, so that notifications can be
made quickly in the event of data exposures.
Ensure that data is collected, transmitted and stored securely and removed when it is
no longer needed.
Unit,
advised by
Security
Office
4.3 Set up telephone and email support for affected individual questions:
- Identify appropriate person(s) to handle calls and emails
- Establish telephone call line/routing infrastructure, if not available
- Identify/set up telephone number to use
- Identify/set up email address to use
- Train individuals handling calls and emails, including providing them with a list
of anticipated questions and answers
Unit,
advised by
Security
Office
8. Page 8 of 12 – May 8, 2013
GUIDANCE: See EDUCAUSE Data Incident Notification Toolkit – FAQ Section for
advice and sample content for telephone and email responder FAQs.
4.4 If deemed appropriate by institution officials in Sub-step 4.1, create website for
affected individuals
- Identify URL and location
- Restrict access until ready to go live
- Draft content
GUIDANCE:
a) Incident websites are typically reserved for situations in which contact
information for individuals affected by the breach is unknown or incomplete.
b) See EDUCAUSE Data Incident Notification Toolkit – Website Section for
advice and sample content
c) Website content should be approved by appropriate institution officials, e.g.,
• Executive in charge of IT for the institution, e.g., Vice President & CIO
• Executive in charge of organization in which incident occurred
• Public affairs office
• Counsel for the institution
Unit,
advised by
Security
Office
4.5 If deemed appropriate by institution officials in Sub-step 4.1, obtain free credit
monitoring services for affected individuals
GUIDANCE: Obtain clear instructions to provide affected individuals signing up for
free credit monitoring services and include this information in notification letters,
websites, and email/telephone support FAQs.
Unit,
advised by
Budget and
Procurement
Offices
4.6 If deemed appropriate by institution officials in Sub-step 4.1, prepare press release
- Identify contact for media
- Compose text for press release
- Develop talking points
GUIDANCE:
a) Press releases are often reserved for situations in which contact information
for individuals affected by the breach is unknown or incomplete, but it’s wise
to have a pre-approved media statement in hand to use in addressing media
inquiries.
Public
Affairs
9. Page 9 of 12 – May 8, 2013
b) See EDUCAUSE Data Incident Notification Toolkit – Press Release Section
for advice and sample content.
c) Content should be approved by appropriate institution officials, e.g.,
• Executive in charge of IT for the institution, e.g., Vice President & CIO
• Executive in charge of organization in which incident occurred
• Public affairs office
• Counsel for the institution
4.7 Prepare notification letter to affected individuals
- Identify letter issuer and letterhead to be used
- Compose draft text
GUIDANCE:
a) See EDUCAUSE Data Incident Notification Toolkit – Letter Section for advice
and sample content.
b) Letter content should be approved by appropriate institution officials, e.g.,
• Executive in charge of IT for the institution, e.g., Vice President & CIO
• Executive in charge of organization in which incident occurred
• Public affairs office
• Counsel for the institution
Unit,
advised by
Security
Office
4.8 Prepare mailing of notification letters (postage, addresses)
- Finalize address information
- Arrange for mail merge and printing/stuffing` of letter and envelopes
GUIDANCE: Avoid personalizing each letter with the affected individuals name, as
this increases the risk of mismatched letters and envelopes
Unit
4.9 If required by state law, notify the State’s Attorney General within the required
notification timeframe
University
Counsel or
other
designated
office
10. Page 10 of 12 – May 8, 2013
4.10 Notify appropriate Federal agency as required by law
EXAMPLES:
a) U.S. Department of Education when FERPA-protected student data is exposed
b) U.S. Department of Health and Human Services when HIPAA-protected
medical data is exposed
RESOURCES:
HIPAA: http://www.hhs.gov/ocr/privacy/
http://www.hhs.gov/ocr/privacy/hipaa/administrative/breachnotificationrule/index.html
FERPA: http://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html
Other data protection laws, http://protect.iu.edu/cybersecurity/data/laws
University
Counsel or
other
designated
office
4.11 Notify granting organizations and research partners if research data
compromised, as dictated by contractual obligations
University
Counsel or
designated
office
4.12 Notify appropriate third-party service providers for the institution if doing so
would reduce the risk of identity theft for affected individuals or dictated by
contracts.
EXAMPLES:
a) Employee benefit vendors
b) Student services vendors
Unit
4.13 If Credit Card data exposed, notify the credit card processor(s) or merchant
banks
GUIDANCE: Specific notification requirements are governed by the card brand.
EXAMPLE:
VISA -- http://usa.visa.com/merchants/risk_management/cisp_if_compromised.html
-
Treasurer
4.14 Notify Credit Bureaus as required by State and upon consultation with
University Council
Treasurer
with advice
from
University
11. Page 11 of 12 – May 8, 2013
Counsel
4.15 Coordinate simultaneous mailing of letters to affected individuals, issuance of
press release if applicable, activation of website if applicable, notifications to
regulatory entities and third-party vendors.
Unit,
Security
Office,
University
Counsel,
and Public
Affairs
4.16 Ensure that notification of the data breach is added to the record of access to
the affected individuals file as required by Federal or State law.
Data
Custodian
STEP 5: FOLLOW-UP
Identity lessons learned from the incident, implement any remediation needs, and securely store a complete record of the incident.
5.1 Collect staff time spent during event and record in the incident documentation
(especially for those cases that might be prosecuted)
Unit gathers
data from all
affected
parties and
provides to
Security
Office
5.2 Schedule a debriefing meeting two to six weeks afterwards to review what could
have been done better in responding to the incident.
Security
Office,
Public
Affairs,
University
Counsel,
and
appropriate
others
5.3 Assess remediation needs
- Issue report to unit manager and executive management if appropriate
- Follow up to ensure completed
Security
Office
12. Page 12 of 12 – May 8, 2013
EXAMPLES:
a) Why was the data stored in a vulnerable place?
b) What more could have been done to avoid the intrusion?
c) Is the unit taking appropriate steps to remediate?
5.4 Initiate plans and projects to implement remediation needs.
- Apply lessons learned and recommended changes to access, sensitive data stores,
systems and processes to increase protection
Unit
5.5 Securely file all records, communications, notes, and other incident artifacts.
Retain and eventually securely destroy this incident information in accordance
with established records retention policies and schedules.
Security
Office