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A PM’s Guide to Surviving A Data Breach

A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

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Page 1: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

A PM’s Guide to Surviving A Data Breach

Page 2: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

• Compliance: • PCI QSA and PCI Gap Analysis• FISMA• HIPAA• SSAE 16• GLBA, Red Flags

• Response• Incident Response and Disaster Recovery• Electronic Litigation Support and Forensic

Recovery• Penetration Testing • Business Continuity Planning• Network Architecture Design• Crisis Communications

• Insurance and Liability Planning

We Are Cyber Risk Managers

Page 3: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

The first rule of survival: The first rule of survival:

Don’t Cross the Street Don’t Cross the Street

BlindfoldedBlindfolded

Page 4: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

In cyberspace, you have to be right 100% of the time. A

hacker only has to be right ONCE.

Page 5: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

How does it happen?

• User Credentials• Phishing• User Errors• Malware• Misuse• Unpatched Systems• Web App Attacks

Page 6: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Companies spend money on Companies spend money on the wrong things.the wrong things.

Page 7: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

2% of Revenue

$112 Billion

How much businesses* spend on physical security

Global losses to physical theft**:

$300 Billion

How much businesses spend on cybersecurity

Global losses to cyber attacks**:

.4% of Revenue

* $10M - $100M in revenue (Bloomberg)** 2013 (Ponemon Institute)

Page 8: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Consider…• US credit card fraud in 2013 equaled $7.1B• The entire rest of the world totaled $6.8B

• 71% of cyber attacks happen to businesses with less than 100 employees

• The forecasted average loss for a breach of 1,000 records is between $52,000 and $87,000

• 60% of SMB that experience a data breach are out of business within 6 months

• Extremely effective hacking tools are cheap or free and are easy to obtain and use

• Social engineering and employee error are common causes of a breach, followed by application vulnerability

Page 9: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Technology does not equal security...

Page 10: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Defense-In-Depth: Technology• 99% of exploited

vulnerabilities had an available patch

• More than half of vulnerabilities have an exploit available within 30 days

• 70-90% of malware is unique to an organization

Page 11: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

…neither does compliance.

Page 12: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster
Page 13: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

We trade convenience for security every day.

Page 14: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Commonly Stolen:•Personal Information•Credit Information•Medical Records•Intellectual Property•Customer/Partner Data•Network Credentials•Email Addresses/Passwords

Convenient:•Online Banking•E-Commerce•Medical Portals•Cloud Storage/Access Anywhere•Vendor Access•Remote Management•Single Sign-On Across Platforms

Page 15: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

The second rule of survival: The second rule of survival:

Diamonds vs. ToothbrushDiamonds vs. Toothbrush

Page 16: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Risk Mitigation: Pre-PlanningRisk Mitigation: Pre-Planning

• Identify critical information and map it• Determine data retention requirements• Know compliance and legal

requirements• Identify vendors• Conduct a risk analysis• Determine your threshold• Identify gaps

Page 17: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

What’s Most Important?• Banking CredentialsBanking Credentials

• Cloud StorageCloud Storage

• Vendor AccessVendor Access

• Remote ManagementRemote Management

• Employee PIIEmployee PII

• Credit InformationCredit Information

• Medical RecordsMedical Records

• Social Media PresenceSocial Media Presence

• Intellectual PropertyIntellectual Property

• Customer DataCustomer Data

• Supply Chain DataSupply Chain Data

• Network CredentialsNetwork Credentials

• Email AddressesEmail Addresses

• Legal DataLegal Data

• Financial RecordsFinancial Records

• Payroll and Accounting DataPayroll and Accounting Data

Page 18: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

The third rule of survival: The third rule of survival:

Don’t Go to Costco the Day of Don’t Go to Costco the Day of

the Stormthe Storm

Page 19: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Risk Mitigation: ResponseRisk Mitigation: Response

• Breach response begins before a breach• IR planning is critical• Know your networks and devices• Train employees to recognize and

respond• Success is measured in hours

Page 20: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Risk Mitigation: ResponseRisk Mitigation: Response

• Your team:• Legal Counsel• Network and Security Administrators• Insurance Agents• PR/Crisis Communications• Forensics and Recovery• Decision Makers (CIO, COO, CEO)• HR• Breach Resolution Service

Page 21: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Risk Mitigation: ComplianceRisk Mitigation: Compliance

• Guidelines and standards for protecting critical information

• Most standards allow flexibility based on risk

• Prioritizes spending and drives response criteria

• May require technology solutions• Best defense against fines, fees,

litigation• Compliance does NOT make a company

bulletproof

Page 22: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Risk Mitigation: InsuranceRisk Mitigation: Insurance

• The policy must meet the needs of the business

• Forensics, legal, PR, notification and lost revenue are all insurable events with the right policy

• More information is better when calculating need

• Watch for exclusions• Catastrophic protection vs. Cyber HMO

Page 23: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

The fourth rule of survival: Exercise is good for you.

Page 24: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Risk Mitigation: ExerciseRisk Mitigation: Exercise

• Training, training, training• Tabletop or Simulation• Walk-through responsibility• Evaluate for currency• Allow enough time• Debrief• Repeat at least annually

Page 25: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

The fifth rule of survival:The fifth rule of survival:

It’s best to solve the problem It’s best to solve the problem

with the simplest method.with the simplest method.

Page 26: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Data Breach: When it’s not a drillData Breach: When it’s not a drill• Remove affected devices from the network, don’t turn

it off!• Call your lawyer• Activate the IRP• Interview and document• Determine the extent of the breach• Engage your forensic team• Identify legal obligations• Manage communications• Remediate and recover

Page 27: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Final Thoughts:Final Thoughts:•By 2020, the global Cyber Security market is expected to skyrocket to more than $140 billion•It isn’t possible to manage risk through technology and hardware alone•Cyber is a component of risk management•Vendors are an important part of cyber risk•People make mistakes•Companies must re-think insurance, compliance, liability, and training to include cyber

www.sera-brynn.com | [email protected] | 757-243-1257

Page 28: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

““There are two kinds of companies in There are two kinds of companies in America: those who’ve been breached America: those who’ve been breached and those who don’t know they’ve and those who don’t know they’ve been breached.”been breached.”

FBI Director James ComeyFBI Director James Comey

Page 29: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Helping Your Company or Client:Ask them simple questions about compliance and risk management…• Have you thought about what you would do in a data

breach situation?• What critical information do you have?• Is your legal team ready to handle your data breach?• Do you know if you are compliant?• Does your cyber insurance product meet your needs?

www.sera-brynn.com | [email protected] | 757-243-1257

Page 30: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

Protect Yourself:• Take Personal Responsibility• Consider a credit freeze if you’ve been breached• Secure your home network, use separate networks for

sensitive information• Backup your data• Avoid coffee shop Wi-Fi• Evaluate the convenience vs. privacy tradeoff• Vary your passwords

Page 31: A PM’s Guide to Surviving A Data Breach. Compliance: PCI QSA and PCI Gap Analysis FISMA HIPAA SSAE 16 GLBA, Red Flags Response Incident Response and Disaster

www.sera-brynn.com | [email protected] | 757-243-1257

Heather [email protected]

Questions?