Recent IT Security Breaches How Organizations Prepare

Recent IT Security Breaches & How Organizations Prepare Evan Mc. Grath Spohn Consulting 19 March 2018

Expertise for Navigating Business Challenges Agenda § § § Recent Breaches Cost of a Security Breach What Hackers Target Regulatory Compliances & State Codes Cyber-Terrorism Things You can do © 2011 Spohn Consulting 2

Expertise for Navigating Business Challenges Recent Security Breaches © 2011 Spohn Consulting 3

Expertise for Navigating Business Challenges Recent Security Breaches © 2011 Spohn Consulting 4

Expertise for Navigating Business Challenges Cost of a Security Breach © 2011 Spohn Consulting

Expertise for Navigating Business Challenges High value data for hackers § Protected Health Information (PHI) – First responders, Ambulatory services § Personal Identifiable Information (PII) – Citizen records, Utility & water records – Criminal records, sheriff departments § Credit card numbers – – Property tax payments Traffic & court fees Utility bills, water, power Vehicle registration § Bank account / payroll information © 2011 Spohn Consulting 6

Expertise for Navigating Business Challenges Regulatory compliance & state codes § Texas Business & Commerce Code § FISMA – NIST SP 800 – 122 – FIPS 200 § HIPAA / HITECH Act § Payment Card Industry (PCI) © 2011 Spohn Consulting 7

Expertise for Navigating Business Challenges Texas Business and Commerce Code TITLE 11, PERSONAL IDENTITY INFORMATION, SUBTITLE B. IDENTITY THEFT, CHAPTER 521. UNAUTHORIZED USE OF IDENTIFYING INFORMATION Sec. 521. 052 BUSINESS DUTY TO PROTECT SENSITIVE PERSONAL INFORMATION. (a) A business shall implement and maintain reasonable procedures, including taking any appropriate corrective action, to protect from unlawful use or disclosure any sensitive personal information collected or maintained by the business in the regular course of business. Sec. 521. 053 NOTIFICATION REQUIRED FOLLOWING BREACH OF SECURITY OF COMPUTERIZED “…shall disclose any breach of system security, after discovering or receiving notification of the breach, to any resident of this state whose sensitive personal information was, or is reasonably believed to have been, acquired by an unauthorized person. The disclosure shall be made as quickly as possible, …” © 2011 Spohn Consulting 8

Expertise for Navigating Business Challenges Federal Information Security Management Act (FISMA) FIPS 200, Minimum Security Requirements for Federal Information and Information Systems, is a mandatory, non-waiverable standard developed in response to the Federal Information Security Management Act of 2002. To comply with the federal standard, agencies must first determine the security category of their information system in accordance with the provisions of FIPS 199, Standards for Security Categorization of Federal Information and Information Systems, and then apply the appropriate set of baseline security controls in NIST Special Publication 800 -53 The combination of FIPS 200 and NIST Special Publication 800 -53 requires a foundational level of security for all federal information and information systems. The agency's Risk Assessment validates the security control set and determines if any additional controls are needed to protect agency operations (including mission, functions, image, or reputation), agency assets, individuals, other organizations, or the Nation. The resulting set of security controls establishes a level of “security due diligence” for the federal agency and its contractors. In addition to the security requirements established by FISMA, there may also be specific security requirements in different business areas within agencies that are governed by other laws, Executive Orders, directives, policies, regulations, or associated governing documents, (e. g. , the Health Insurance Portability and Accountability Act of 1996) It is important that agency officials (including authorizing officials, chief information officers, senior agency information security officers, information system owners, information system security officers, and acquisition authorities) take steps to ensure that: (i) all appropriate security requirements are addressed in agency acquisitions of information systems and information system services; and (ii) all required security controls are implemented in agency information systems. See http: //csrc. nist. gov/sec-cert/ca-compliance. html for additional information on FISMA compliance. © 2011 Spohn Consulting 9

Expertise for Navigating Business Challenges HITECH Notification of Breach Laws Issued August 2009 SECTION 13402 OF THE HEALTH INFORMATION TECHNOLOGY FOR ECONOMIC AND CLINICAL HEALTH (HITECH) ACT by requiring HIPAA covered entities and their business associates to provide notification following a breach of unsecured protected health information. • INDIVIDUAL NOTICE: Covered entities must provide this individual notice in written form by first-class mail, or alternatively, by e-mail if the affected individual has agreed to receive such notices electronically. If the covered entity has insufficient or out-of-date contact information for 10 or more individuals, the covered entity must provide substitute individual notice by either posting the notice on the home page of its web site or by providing the notice in major print or broadcast media where the affected individuals likely reside. • MEDIA NOTICE: Covered entities that experience a breach affecting more than 500 residents of a State or jurisdiction are required to provide notice to prominent media outlets serving the State or jurisdiction. • Notice to the (HHS) Secretary: Covered entities must notify the Secretary of breaches of unsecured protected health information. • A maximum penalty amount of $1. 5 million for all violations of an identical provision. • ENFORCEMENT: HIPAA covered entities were required to comply with the Security Rule beginning on April 20, 2005. OCR became responsible for enforcing the Security Rule on July 27, 2009. (Summary: While HIPAA was established in 1996, it was not until 2009 that we saw widespread enforcement ) http: //www. hhs. gov/ocr/privacy/hipaa/administrative/breachnotificationrule/index. html © 2011 Spohn Consulting 10

Expertise for Navigating Business Challenges Payment Card Industry (PCI) § Anyone who stores, process, or transmits credit card data must be PCI compliant § Common PCI validation requirements § § Report on Compliance (ROC) Self-Assessment Questionnaire (SAQ) Letter of Attestation Quarterly PCI scans § Sample PCI Data Security Standards Requirements § § § Annual Penetration Testing (DSS 11. 3) Security Awareness Training (DSS 12. 6) Quarterly PCI scans (DSS 11. 2) © 2011 Spohn Consulting 11

Expertise for Navigating Business Challenges PCI – Frequently Asked Questions I’m a small merchant who has limited payment card transaction volume. Do I need to be compliant with PCI DSS? If so, what is the deadline? All merchants, whether small or large, need to be PCI compliant. The payment brands have collectively adopted PCI DSS as the requirement for organizations that process, store or transmit payment cardholder data. PCI SSC is responsible for managing the security standards while each individual payment brand is responsible for managing and enforcing compliance to these standards. Myth – Outsourcing card processing makes us compliant Outsourcing simplifies payment card processing but does not provide automatic compliance. Don’t forget to address policies and procedures for cardholder transactions and data processing. Your business must protect cardholder data when you receive it, and process charge backs and refunds. You must also ensure that providers’ applications and card payment terminals comply with respective PCI standards and do not store sensitive cardholder data. You should request a certificate of compliance annually from providers. Does PCI DSS apply to merchants who use payment gateways to process transactions on their behalf, and thus never store, process or transmit cardholder data? PCI DSS requirements are applicable if a Primary Account Number (PAN) is stored, processed, or transmitted. If PAN is not stored, processed, or transmitted, PCI DSS requirements do not apply. However, under PCI DSS requirement 12. 8, if the merchant shares cardholder data with a third party processor or service provider, the merchant must ensure that there is an agreement with that third party processor/service provider that includes their acknowledgement that the third party processor/service provider is responsible for the security of the cardholder data it possesses. © 2011 Spohn Consulting 12

Expertise for Navigating Business Challenges Cyber-Crime vs Drug Trafficking? © 2011 Spohn Consulting 13

Expertise for Navigating Business Challenges Possible cyber-threats … © 2011 Spohn Consulting 14

Expertise for Navigating Business Challenges Things you can do… § Implement Security Policies & Incident Response Plans § Education: Security Awareness Training § Vulnerability Assessments – Internal & External § Penetration Testing – Internal & External § Wireless Penetration Testing § Social Engineering Exercises § Enterprise Security Assessments – Administrative Safeguards – Technical Safeguards – Physical Safeguards © 2011 Spohn Consulting 15