Quality Plus Consulting - Breakfast Bytes

Felicia King is known as the “Packet Whisperer” and considered to be one of the top network layer security strategists in the country. Since launching in 2004 on the WGTD network, her Breakfast Bytes podcast has focused on the current cybersecurity landscape and the security threats business owners need to be aware of. Learn about the most recent threats, what you can do to mitigate your risk, and how to protect your most valuable assets, your data and your time. Use the tags in the menu above to quickly access episode topics most relevant to you. Visit our primary website https://qpcsecurity.com for more articles and webinars. Our public knowledge website is https://kb.qpcsecurity.org

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4 days ago

Part 2 of a series on threats to mobile devices and through mobile devices. Tactics and techniques to deal with those threats.
Cohost: Tom Dean – Consulting Ventures
Tom has decades in capital goods manufacturing industry (fortune 500 scale)
Years of experience in marketing, sales & interfacing with independent dealers/distributors (small/medium scale)
Current focus is strategy & risk management consulting
Lifelong learner and an interest in technology.
Strategy + risk management ---> mobile devices
Apple find my network; useful feature, but privacy considerations
SSO risks where there are too many items that can be compromised if there is a single compromise of a single system
Out of band SMS
Problems with Twilio and 10DLC for VOIP SMS
Know your customer regulations, implications with SMS validation for ownership establishment
Synology came up with their own Synology MFA app and the problems with that
Do not call registry updates; Good news!

Monday Oct 30, 2023

Part 1 of a two-part series on threats to mobile devices and through mobile devices. Tactics and techniques to deal with those threats.
Cohost: Tom Dean – Consulting Ventures
Tom has decades in capital goods manufacturing industry (fortune 500 scale)
Years of experience in marketing, sales & interfacing with independent dealers/distributors (small/medium scale)
Current focus is strategy & risk management consulting
Lifelong learner and an interest in technology.
Strategy + risk management ---> mobile devices
Personal travel:
Laptops have transformed to mobile devices (phones and tablets)
Risk was more contained with laptops, but the impact is much higher with mobile phones. A lot of nuances around "was the password revealed?"
Biometrics are convenient but quite dangerous
Biometrics are a proxy for a numeric passcode on a mobile device.
Physical compromise is a 5-alarm fire situation.
Physical loss when it is not compromised is not that big of an issue as long as authenticators are backed up.
Must have erase after 10 bad password attempts. Turn off notifications on screen lock. Do not have notifications turned on to display on the lock screen.
Avoid banking apps.
The first things that the baddies go after are Venmo, Apple Pay, Cash apps.
Out of band SMS for MFA
SIM swapping risk, or eSIM embedded in the phone
Put a PIN on your physical SIM.
MySudo – Can clone that instance to other phones.
Password manager on phone
Disaster if this is based upon your biometric. You can use a different or secondary PIN. You can use Yubikey.
Password manager helps you recover.
Segmentation strategies
They can see all the emails on your phone and change passwords or password reset is typically done via email
Screentime on Apple can be helpful, but there are weaknesses there. The only way to really secure the device is to use a MDM. You still need to be concerned about MFA and account takeovers.
Need to have an out of band mechanism to receive alerts and ability to remove kill the device.
Microsoft Authenticator and Google Authenticator do not have a separate PIN.
Authy is free. It has its own separate PIN.
Yubikey is great but assumes that you can manage controlling the physical access to that. Do not store on your key chain.
Diversification strategy with inventory.
Kill apps
Apple configurator – small scale
Apple Business Manager
Jamf – requires Apple Business account for security
Inexpensive “Jamf Now” for small businesses. Minimum is one device. The first 3 are free. Still affordable beyond that.
Don’t let anyone change the account on this device.
You have to figure out a lot on your own and block URLs that you don’t want accessed.
Apple devices need to be in supervised mode, so it matters how you buy them.
Risk examples
loss of device (resiliency e.g. MFA)
theft of device involving passcode surrender (loss mitigation)
SIM swap (cellular store employees)
SIM card theft (removal of SIM card from phone)
Risk reduction / resiliency
OS decision (iOS vs. android)
Note that one is not better than the other
Risk reduction is all about an individual's ability to manage the risks based upon platform selection
MDM (remote data wipe): small-scale co (Apple Configurator or JamfNow) vs. corporate MDM
MFA backup/diversification (SMS via cell or VOIP providers vs. TOTP vs. passkey/yubikey etc.)
App selection (OS-based or Independent)
App protection (‘independent’ PIN protection vs. face/touch ID)
‘Attack Surface’ – minimization of exposure (e.g. banking apps, cash apps, findmyfriends etc.)

Thursday Oct 05, 2023

The process of determining how workloads should be hosted is very complex and not a decision that should be abdicated to the IT service provider. Business decision-makers must be involved in those decisions as only they are able to define the key criteria that all other factors are dependent upon.

Friday Sep 01, 2023

CTO Kyle Wentworth joins Felicia for a discussion about how businesses can avoid adverse financial impacts.
Lack of understanding of the language of technology
It changes so incredibly fast that it takes a sea of people who understand the pieces
Complete perspective of how the business of technology should be run
Understand what governance and compliance standards your business is held to
That dictates how you do business.
Some tangible examples of how things can and should be done:
Justification statement annually for expenses
How it is being used and how the costs were arrived at
Assignment of the resource owner
Misallocation of funds paying for items that should not be paid for takes resources from other needed items.
Walk through your business. Identify what you don't understand about the business?
Do you understand every function of the business?
You have to entire your entire business as a whole if you are the leader of the business.
Gaps in your understanding indicate where you need an auditor to identify that your people doing the processes are doing it properly.

Friday Aug 04, 2023

Why it is critical to have an email security expert managing and monitoring email security configurations and delivery of email on an ongoing basis.
Instructions from marketing automation platforms are not adequate.
It matters A LOT what you are trying to do with email. Getting these items configured is an art form.
Vendors are continually failing vendor risk management analysis and losing business over their email not being properly configured.
New website resource:   https://kb.qpcsecurity.org

Friday Jun 16, 2023

Kyle Wentworth of Wentworth Consulting Group joined Felicia to compare/contrast three C-suite level IT/IS related roles.
Kyle has 35 years of business experience and has been working on computers since 1976. He is a:
Fractional CTO
Business coach
Business process modeler
Kyle has a great resource on his website to help people understand the differences between these C-suite roles.
Listen to the podcast for some Kyle truth bombs such as:
"Technology runs your business. You don't. We facilitate technology to run our business. IT is the most critical function of your business."
"Technology is harder to manage than brain surgery. Then why are you having conversations with technologists? Technology footprint is harder to identify and manage than brain surgery."
We talked about Felicia's hot button which is a lack of a quality, enforced procurement policy.
"The reason you give someone the ability to purchase the product is because you don’t understanding why they should NOT buy it."

Zero trust fundamentals

Friday Jun 02, 2023

Friday Jun 02, 2023

Zero trust is not a product you buy.The problem that most organizations have is that they are still not doing the fundamentals well.CIS has a community defense model.I did a detailed webinar on it where I covered a lot of these fundamentals.https://www.qpcsecurity.com/2023/02/16/addressing-information-security-fundamentals-with-cis-and-community-defense-model/
Let's look at inventory management, asset management, change management, onboarding and offboarding.
You must have checks and balances. There must be practices codified in policy with a shared responsibility model which make it so that the issues that are created by mistakes in onboarding or offboarding are caught.
Fundamentally, the most effective thing in zero trust are the protections that are in an always on state.Like for example the recent revelation about flaws in UEFI and SecureBoot.These have prerequisites like TPM, BIOS configs, bios adm pwds, automated firmware updates, procurement policy alignment for supported hardware, onboarding configuration done properly on those endpoints, monitoring of the firmware updates, and of course, no admin access for end users!!!
When an organization does not have a CISO that has policy and management authority over IT, you are guaranteed to have problems.Forget CIO and CTO. I think those are old modes of thinking. Find a CISO that can be the leader of all IT strategy.
Procurement policy must include vetting and testing of cloud app integrations. Monitoring and technical controls must be in place to restrict or eliminate the ability of an end user to buy shadow IT and authorize it on their own. Azure AD has controls for this, but they are not on by default.

Friday May 05, 2023

The IRS regulations for tax preparers being compliant with the FTC Safeguards rule is specified to be enforced starting in June 2023. It is doubtful that the majority of tax preparers are adequately compliant.
The IRS published information about this compliance requirement as far back as 2019.
All of it is common sense and things that orgs should have been doing for ages.
IRS publication 4557
Before you use a tax preparer, ask them for their compliance certification statement.
Practical examples of what to ask of your tax preparer and why
More information on this topic from Joe Brunsman, cybersecurity insurance expert.

Friday Mar 31, 2023

Friday Mar 03, 2023

What is the number one thing you can do as a consumer to protect yourself when dealing with tax preparers?
Practical examples of what to ask for from your tax preparer and why.
What are the total number of people that would have access to my records if I do business with you? You want me to sign a contract with you, terms and conditions that I have to abide by. If you are going to prepare my taxes, show me your affirmation statement where you as a tax prep preparer have put it in writing that you are fully in compliance as a business with the IRS requirements for tax preparers. Put that in writing.
If the IRS is the authority that is providing the designation that an organization is an IRS authorized tax preparer, then the IRS is the entity who defines the standard for what is the requirement put upon that organization or that person in order to have that designation. Therefore, it is completely legitimate to be asking as a prospective customer of that organization, "show me your compliance statements". How do you comply with the IRS requirements for tax preparers? And if you get anything other than a fully prepared premade statement they provided to you in writing,  then that's problematic because it means that they are not compliant.
What is one of the most important things that a business owner can do in order to make their business survive the next decade?
Information security risk management is everyone's problem.
Business leaders cannot delegate and abdicate involvement. 
If you are not having regular meetings with your vCISO, how can you make informed risk decisions? Do you know what the gaps backlog is for your organization? Do you have a risk register? If you refuse to make the time to meet regularly with your vCISO, your business is going to be squeezed by cybersecurity insurance requirements, governmental regulations, and customer requirements.
The executive management team needs to understand that if they do not tell all of the managers in an organization that they need to take responsibility for the ownership over their resources, then what needs to happen is that the executive management team needs to make the CISO or the IT department have full total authoritarian control over those resources. But then that turns into a big can of shut the heck up to the people who've abdicated their responsibility to be involved in the process. Because you can't have it both ways. You can't say that IT is responsible for the security of those assets, but then refuse to be involved in the conversations about who should be having access to what and when. And claim that you don't have time to talk about it, that it is not important. Of course it's important. Are you the resource owner or not? So you can't make it somebody else's responsibility to define the policy around who has access to that resource that ultimately you're responsible for and then yet get grumpy. when your access or the people who you thought should have had access to that resource have their access denied because IT is trying to clean up the mess. You can't have it both ways.
Whose responsibility is information security risk management? Ultimately, it's the executive management team. But they can delegate that through the organization to the resource owners and at the end of the day, IS risk management really needs to be everybody in the entire organization's responsibility. Information security practices need to permeate throughout the entire organization. The end users of an organization are the largest attack surface that an organization has.
Suggestions for tax preparers
Tax preparers need to comply with the FTC Safeguard rule which is currently slated to be enforced starting in June 2023. As of May 2023, the expected plan is that private contractors will be the enforcement auditing arm for compliance. 
In reality, any company that had taken cybersecurity insurance compliance preparedness and had engaged a vCISO proactively several years prior would likely have no issue in this area. But the vast majority of tax preparers were unwilling to invest in the kind of protections that should have been in place for decades. 
Here are some resources.
Page 13 of publication 4557 states that all tax preparers must comply with the FTC Safeguards rule. That means if you or your organization has an IRS tax preparer ID number, you must be in compliance and be able to prove that you are in compliance. 
Tax preparers that are under $2mm in revenue should expect to spend 15% of revenue annually on all inclusive IT costs. If your spend is not that high, then your organization is likely not going to be competitive in the market and is bound to lose market share to players who have invested in becoming FTC Safeguard rule compliant.
Please also be aware that security theater is not compliance. I have seen some scams such as do-it-yourself kits through technical firms who specialize in servicing accountants (per their website). 
More details from Joe Brunsman, cybersecurity insurance expert.

Sunday Feb 19, 2023

I get a lot of questions about PSAs, ERPs, and overall paradigms related to core business software. This podcast summarizes things you should be thinking about in your software selection process.
After three years of investigating PSA and ERP options including spending a lot of money on software and payroll, the product we like is Odoo. Organizations using a PSA with add-ons approach are really missing the mark. There is no PSA that does project management well. None of them have accounting systems. Most of them are terrible at quoting. And they are all expensive. They also are all weak at analytics and business visualization or analysis.
So a company ends up paying for:
eCommerce processor
Payment gateway provider
project management platform
QuickBooks or Xero
website hosting
Applicant tracking system
HR / people management system
email newsletter system
marketing automation platform
Social media marketing platform
and more
Whereas, a business could just get Odoo.
Let's look at a brief cost analysis.
Halo - $15,000/yr
Quotewerks or Zomentum $500/mo
QuickBooks or Xero $1300/yr
ConnectBooster $300/mo or more
Project management  $300/mo or more
ATS $5000/yr
HR system $150/mo/employee
Infusionsoft or Hubspot $1200/yr at least
Social media marketing  $200/mo
CRM - $300/mo
OR you could just stop all that nonsense.
Odoo. $47/mo/user.
Remember that this includes your website hosting too. And it turns out to be much better than WordPress, Joomla, or other smaller CMS.
What I find really hilarious is when I ask other business owners how much they are spending on all the components they use that spackle over the deficiencies in their PSA, they rarely know. It's like it is a financial hole in their business that they don't want to look at.
As of 11/22/2023, our 1 year Zoho subscription that we tried has been set for non-renewal. The primary basis for that was four wasted months of payroll, wasted time working with Zoho support, and wasted time working with Zoho consultants to try to get integrations with other modules in Zoho to work. The modules in Zoho One are designed to work independently. In order to get data to flow between them, integrations between the modules is required. We consistently found that those integrations between the individual Zoho modules did not work properly. We had other problems with it as well, but it became quite clear that Zoho One was not really an ERP because it is not foundationally designed with the premise that all of the modules are fully integrated automatically.
I looked deeply into Manage Engine ServiceDeskPlus for MSP also. I spent about a year on that investigation. I encountered a plethora of challenges with that and it still is a PSA-like mindset where ServiceDeskPlus cannot be a comprehensive business tool.
I encounter MSPs that use an outsourced helpdesk that requires the use of a specific PSA. I don't and won't outsource helpdesk for quality control reasons.
Overall, Odoo does everything better than ZohoOne. Odoo integrations are all there from the very beginning automatically integrated because it was designed as an ERP from day one instead of individual modules.
You can see a demo of Odoo at https://demo.odoo.com. Be aware that there are more modules available than what is shown in the demo, but the demo will give you a good overview. Odoo training is online and free. The documentation is online and free. Support is included with paid subscriptions and we have found that support is effective. Conversely, we rarely had any success with Zoho support. Odoo is more intuitive with things just working and being able to be figured out oneself through the use of documentation, training videos, and just playing with the software.
We use the Maintenance module which is good for a facilities maintenance team. I wanted my team to be able to log time entries against particular maintenance tasks. In 2023, it is not possible for time entries to be applied directly on maintenance tasks that flow through to timesheets for payroll. When I put in a feature request, with Odoo, they responded very quickly stating that they were aware of the limitation and were also aware of the need and value. With Zoho, I would put in a feature request and get a response in 9 months. 
I think that Zoho is so busy writing new modules that they have little to no developer time allocated to making the ZohoOne integrated ERP vision a reality.
We spent a LOT of time trying to use the recruiting module in ZohoOne and found it to be an exercise in frustration. We had a lot of success with the Odoo recruiting module with only a few limitations.
The bottom line is this. Find just one thing you can use Odoo for that can justify the monthly fee for one user. Get in there and start using it.
We have some clients who are using just one module for free. I got one client up and running on the project management module in a couple hours and got the client trained on it.
Another client, we put on the website module. The feedback we get from clients emphatically is that it is intuitive and easy to use.

Thursday Feb 09, 2023

Tech E&O and Cyber insurance with:
Joe Brunsman of The Brunsgroup – Expert on Tech E&O and Cyber Insurance
YouTube channel – Joseph Brunsman
Damage Control book
Tech E&O and cyber
MSP should have a tech E&O policy. They cover different things. What types of third-party claims will they cover? A guy on the Que recently said that he did not think that E&O was required because his customers have never asked for it. You must have a TECH E&O policy.
What is the biggest thing that you need to pay attention into the E&O policy?
Look at the definition of technology services in the policy. Everything past that point, it does not matter if the definition of technology services is correct.
Avoid the named peril policy. An all risks policy is better. These are becoming harder to come by.
Named peril:  Technology services means:   there is a list
You have to prove to the insurance company that what you did falls within that definition.
What do you need to look for? “Including but not limited to”  contra proferentem = ambiguity is held against the draftsman. The onus is on the insurance company to prove that what you did was not covered under the definition.
How much coverage in the policy should they have?
How much cyber insurance do you need? Here are the variables that I think about. – See Youtube video
Brokers – There is no legal requirement that they understand or read the insurance policies.
Average IQ of an insurance broker is 104. They do not understand what they are selling. The onus is on the business owner to ask and to get the right things.
What is your major loss event? What are we worried about? Is that even possible to insure for those issues?
Step 1: Stop relying on the insurance broker.
Step 2: Fellow decision-makers in the business, what are you worried about? Talk to the broker about that. Then the broker finds “these are the options in the cyberinsurance market that address those concerns”.
Joe: Huge proponent of defense in depth over cyber insurance. Rank order the biggest bang for the buck. Felicia has been talking about that for years and is doing a webinar on 2/9/2023 on that very topic.
Insights from plaintiff’s attorney
Joe had a great convo with a plaintiff’s attorney and got his opinion on risk management.
Risk discovery question: What is the one thing that sinks the ship in the lawsuit?
There is an internal email. You knew you were supposed to do this. But they said it was too expensive. They were not going to do that. They understood the risk and just accepted it.
What could the business do in order to circumvent that email being a death blow in the lawsuit?
Plan of implementation.
No business has unlimited resources. No business is perfectly secure. You sit down the with business owners and MSP. We need to work on a plan to better your security. You don’t have unlimited money. I am a business owner too. You need a roadmap. Everyone signs off on it. We were trying, we were getting there.
Felicia: Wow this is astonishing because this is what we have been doing with clients for 20 years. It is the type of thing that a CISO knows how to do, but few others know how to do well.
Life hack tip from Joe:
Convo with the average business owner:
Obviously you are really good at what you do. You have built this business. Build a relationship with them. The MSP is not the subject matter expert on the client’s industry. Fluff their feathers. Transition that. I asked you a bunch of questions, thank you for hearing me. Now we are going to go through this. Can we just do the same thing in reverse? If you do not understand this yet, let me know and let’s break it down.
Joe and Felicia agree:
One way or another, those controls will be implemented. Read any breach notification letter. Magically we found more money to invest in cybersecurity.
Either work on your information security program monthly at a pace that your budget can absorb, or that decision of timing and magnitude will be taken away from you.

Friday Feb 03, 2023

Google and how they do their technology
Things that make security hard.
This is not an exhaustive list of the implications of poor design on security. Covering that topic adequately would likely rival the size of War and Peace. This is a discussion of a tangible example to convey understanding of how technology selection directly correlates to an organizations’ ability to secure or secure their overall environment. In order to accommodate something poorly designed, larger than necessary holes through security may need to be carved. Please get your CISO and security architect to perform a risk assessment technology BEFORE procurement.
Recent security news alerts discussed again why advertisements must be blocked. Google’s own ad network has been used for hosting and serving malware to victims.
Google and their netblocks
Their guidance to you is to whitelist their entire network blocks which is beyond insane. Just like the insanity of whitelisting *.windows.net which is what is advocated by some SaaS providers who host their resources on Azure.
Azure hosted customer resources are on windows.net. That means that a hacker can dial up a hosted VM and that’s on a windows.net FQDN and IP space.
You cannot just whitelist all of Azure either.
Beware that software companies will put out idiotic statements in their support documentation that tell IT professionals to “open ports [range of ports] to all IP addresses contained in the IP blocks listed in Googles ASN.
Let’s be clear. Those are IP addresses not just for Google’s company internal resources. That is customer hosted resources that they don’t control, manage, or secure the content. So the Google netblocks represent 73.5 million domains.
There is NO legal defensibility in creating a hole that massive through any security system. Yet this is likely what 99% of IT professionals are doing because they are not network security architects. Business decision-makers must understand that there is a lot of bad advice that comes out of even major companies as it relates to information security risk management. They put out insane statements such as whitelisting the IP space representing 73.5 million domains.
Even if you look up a separate Google ASN, it is still 18,933,082 domains. That is clearly a massive amount more than just the small amount of resources that you legitimately need to access for something like Google reCAPTCHA to work. But because of the way that Google has designed their infrastructure, your ability to have network security is hampered.
Autoblocking and DNS latency.
One of the major problems with using anything on Google’s infrastructure is that their entire system was never designed for compatibility with selective controls.
It was not mail.google.com. It was google.com/mail.
It was not drive.google.com, it was really google.com/drive. The real infrastructure was hosted as a subdomain of Google.
And then so many web developers have made google analytics a mandatory component of how their website infrastructure works that you have to allow it. It just allows google to be a data vampire.
Microsoft in contrast
There is a strong tendency to among IT support personnel to engage in over-troubleshooting. They follow software vendor’s recommendations and end up driving holes the size of North America through your security configuration. Please ensure that the personnel who are managing network security for your organization are actually qualified to do it.

Wednesday Jan 11, 2023

Kathy Durfee – CEO & Founder of Tech House joined Felicia to discuss dark web breach monitoring
Scenario: FUD report from a competitor
Perceived: Multiple users in their environment were breached. Perceived proof was report with the listing of the users and the passwords and columns that the customers did not know what that data was.
Good: Customer told their current IT service provider about the report.
FUD – Fear, Uncertainty, and Doubt – is, in the wrong hands, a powerful tool to drive snap decisions within a company. However, it is not a viable or valid sales tactic: for all it could potentially do well, causing unnecessary stress and suffering is what it does best. Speaking with Kathy Durfee, CEO and Founder of TechHouse, a managed services and solutions provider based in Florida, we walk through a recent case of FUD with a customer of hers that received a worrisome report from a potential competitor. During our chat, we covered:
The key aspects of FUD (and how it does not work)
What the Dark Web is, and the logistics of monitoring and combating it
Leadership training and best practices for helping a team best meet their security and regulation requirements
Identifying the key differences between commodified and relational partnerships, especially in the technological sphere
Shared responsibility between MSPs, their customers, and those customers’ clients
Where does dark web monitoring and dark web data risk reside on the continuum of risk? How best to mitigate?
What really is the risk and the mitigation?
Put the efforts into prevention.
Put the individual in the driver’s seat of managing the risk that is best managed by them by putting the right tools in their hands.
Perception of the proper allocation of the budget
Businesses must make time for training.
ITSP must include in service catalog what the client is getting in terms of services.
What do we need to do? Cross reference on tools that accomplish outcomes and cover risk mitigation and ensure that the client understands what those are.
Training is how you squeeze the juice out of the orange. Without it you may not get all the juice out of the orange or get any juice out of it at all.
Common business objections to allocating time for training
Payroll costs, but avoiding training is not legally defensible anymore.
The IT Service provider CANNOT alone write policies for you, and they CANNOT approve and enforce your organizational policies.
Four pillars
Technical controls implemented
Automation of technical controls
Reported to the business – It’s YOUR report, your organization.Shared responsibility – some months the CFO does it, some months the CEO does it.Set a schedule and do it. 3 weeks any habit; trainer or partner
Do you look at your P&L and balance sheet every month? You should be understanding the reports from IT.
An interesting lawyer opinion on the topic:

Wednesday Jan 04, 2023

Those who listened to the November 19th, 2022 podcast I did with breach attorney Spencer Pollock know that he stated that 90% of the breaches he was involved in over the prior 12-month period would have been non-reportable had the data been properly encrypted.
(Review link above for attestation and regulatory enforcement proof.)
I have three major points for you in this show.
You need an IRP
You need a CvCISO
And you need to understand how data is being handled in your organization
Let’s first talk about CvCISO
Help you understand why you need a CvCISO working with you on a regular basis because even if you are a really large organization, the probability that all of your processes are clean, secured, compliant, and all your end user training is effective, well that probability is not high.
Incident response plan
Virtually every organization is now required to have a written incident response plan. These are some examples of people that must be specifically listed in the IRP. What does your organization do when they don’t have these people as full-time internal staff? You need a CvCISO.
People you are required to name explicitly as part of your incident response plan:
IT technical staff
Incident response manager (this better be a CvCISO or a certified incident response company)
IT director
Stakeholders such as board of directors and heads of business units
Finance director
Communications manager – this is either your internal PR person, your internal corporate counsel, or your breach attorney
Legal representative – either your internal corporate counsel or breach attorney
Human resource manager
Types of data
Let’s talk about some real-world examples of data insecurity. Let’s start by establishing what some categories of data are. PII, PHI, PCI data.
PHI is personal health information so think of that as drug screening results as well as medical records. So it’s not just healthcare organizations that have it. Anyone who does drug screening will have PHI.
PII is personally identifiable information such as your name, contact information, social security number, I-9 information, a copy of your passport or driver’s license, and non-public photos of you. This is also your direct deposit bank information. I would also include your salary at your job is PII. It is certainly non‑public. So who has that kind of information on you? Well anyone who does HR recruiting or has employees is typically going to have this kind of data.
I encourage small businesses to use a PEO and not store any of this data themselves. They should outsource that entirely. Some HR management firms have areas in their SaaS platform that their customers (your employer) can upload documents to and store them securely and NOT on the employer’s environment anywhere.
PCI is payment card information. If an organization processes credit cards in any way outside of a contained e-commerce and merchant processing platform, then they probably have PCI data that is on a system they control. Many retailers just use SaaS apps that directly integrate with merchant processing to avoid any storage or holding of PCI data. You should expect that larger organizations are retaining your credit card information.
Applicant tracking and employee onboarding systems
The security of these systems is only as good as the security of the company that is using them, their processes, how they handle the data throughout the flow, and how documents you complete for them are disposed of if they were submitted in paper format.
Good process
As you interact with the recruiter or prospective employer, all of the data goes directly into an applicant tracking system that is SaaS by the applicant themselves. The only thing that may be emailed would be a resume. Any assessment results or applicant data is all direct input into the ATS. The ATS is SaaS cloud hosted with a very secure company and all accounts which access the data are on a need to know, RBAC approach with MFA enforcement.
WOTC information is all submitted by you directly into the WOTC company website
All of your PII would be submitted by you directly into the HR enrollment/payroll system without intervention from anyone else. No one else needs to handle your data.
The data you submit is only being submitted to a high security SaaS HR management/payroll platform.
Your employer never needs to download and retain any of that information because it is stored in the HR management system. Nor did your employer ever need to have a copy of the information you submitted because you submitted it yourself. So you know it is not in their email or on their servers anywhere. They also did not print it and then not shred it.
Bad process
You are an applicant and the company you are applying to has you fill out paper forms. You do and then they scan those forms with a scanner and send those files somewhere. Let’s say they are scanned to an insecure location on the internal network. Then someone retrieves the scanned images of the paper you filled out and emails them to a distribution list.
So let’s go over what is in the scanned PDF file that got emailed to an internal company distribution list.
Direct deposit information – full banking account and routing number
Full name and address
I-9 verification which includes social security number, driver’s license number, and birth certificate
W-4 which contains PII and SSN again
Copies of your signature
Date of birth
Your offer letter including salary and benefits
What happened to the physical paper copies of the forms you completed? Were these shredded same day?
Was the information in the email distribution list forwarded to anyone who did not have a complete need to know?
Was the information forwarded to a party external to the company?
Document management platforms
Premise databases often have a lack of encryption
Lack of data encrypted at rest and quite possibly the data is not encrypted in transit. If the system that the data is stored inside of is a premise-based thick client application such as an application that has SQL server as the back end, it is not likely that those communications between the thick client and the database server are encrypted in transit. The SQL server most assuredly is not encrypted because very few applications support SQL database encryption and even fewer IT people know how to set it up.
I have seen document management platforms with 500,000 records in them containing some of the most sensitive PII and this data was not only housed on servers that were unpatchable and fully deprecated, but the data being transmitted to/from the server was not encrypted, nor was the data in the database encrypted at rest.
If you put a dollar figure to the cost of a breach and it is associated with the number of unique records that contain reportable information, the cost of that old, insecure server just went through the roof.
Even if you say $1/record, that is $500k. Wowzers! And it’s not likely that was the only server compromised in the breach.
What data is stored in people’s emails when a company does not have solid policies, end user training, and technical enforcements to prevent the data from being improperly stored?

Wednesday Nov 30, 2022

Recent question I got:
What are the major changes that you have seen from security auditors in recent years and/or where do you see the audit process heading?
Quick response:
For the sake of a high level, automation is and will continue to be used. The size of the IT service provider is NOT a conveyance of their capabilities or capacity.
Many 60 person MSPs are grossly incompetent. Some small teams of about 8 people are exceptionally skilled.
C-suite needs to drive it from the end in mind. The end is compliance attestation. Back into it from there and ONLY use a team which also has the technical capabilities to perform the remediations.
Do not use vCISO services from one company and remediation services from another. You get too many cooks in the kitchen and a disjointed and more expensive outcome will be the likely result.
The insurance companies are pushing the cost of the audit on the insured or applicant. This will involve eating tools and processes that connect with their assessment process.
Hence why it is crucial to work with a company like mine that has these workflows. Most don’t.
In this podcast, I provide an overview of the role of executives, managers, internal IT, and the CISO in business risk management. Until all parties understand that this is not information security risk or cybersecurity risk, it is business risk that they are responsible for managing, then it is not likely the situation will improve.
In order for business risk managers to make good risk decisions, they first have to engage and be involved. They cannot put their head in the sand and believe that "It's an IT problem." No it's not an IT problem. When the HVAC system is open for hacking to everyone on the planet because the facilities director refuses to collaborate with IT security to come up with a solution to maintain business functionality while managing risk, that is a business risk issue.
If the facilities director REALLY believes that it is an IT problem, then IT needs to be provided the authority to rectify the issues. And when the facilities director's access is interrupted, then they will be forced to engage and collaborate at that time. But executive management needs to have the intestinal fortitude to enforce policy. The policy that IT does have that authority and no IT will not be retaliated against. That is one approach. The other approach is that the facilities director needs to acknowledge that THEY are responsible for business risk management of the HVAC system. So if the facilities director wants the right to complain when their access is revoked, then they cannot abdicate their responsibility and accountability for the security of the HVAC system.

Saturday Nov 19, 2022

Breach attorney, Spencer Pollock joins Felicia for a vigorous discussion of what you must do in order to be prepared for an incident or breach. Learn from the breach attorney perspective. 
Spencer is with the well-known firm McDonald Hopkins. 
incident response plan
tabletop exercises
must get breach attorney involved before there is an incident
determine your team in advance
What's new?
regulatory enforcement
multi-state class action lawsuits
attorney generals getting together to class action effort
Regulators DIG
They want to see your policies.
You must demonstrate your administrative, physical, and technical controls.
Attestation proof of state is mandatory
You better be able to enable your breach attorney to tell a legally defensible story.
How many data breaches could have been avoided by properly encrypting the data? - 90%

Friday Oct 28, 2022

What is information security versus cybersecurity?
What are policies and why do we care?
Isn't that IT's problem?
Examples to learn from

Wednesday Oct 12, 2022

Special guest:
Vince Gremillion – President and Founder of Restech: CISSP, CvCISO, GCIH
Travelers policy – requires MFA on switches. They require you comply with the intent of that.
Recent Cowbell application did not require MFA!
What is required is contingent upon the coverage you are asking for.
Some suggestions:
Never fill out an app for a client, not even partially
MSP comms to a client should be in a document in a detailed format and it should be digitally signed and locked for editing through that digital signature. I use Adobe EchoSign for that.
I address everything in a CRAQ format and then include for the client a spreadsheet which is a cross reference. I will never answer any of those questions on the application directly because I can tear holes in every single one of those questions.
I reject many of those cybersecurity insurance application questions as yes or no. Yes/No just does not fit.
All the insurance carriers and underwriters have accepted my method which I fine to be the only defensible approach since yes/no is inadequate and does not protect the insured/applicant or their MSP.
Future strategy
This is exactly why we need CISO platforms which have automatic data ingestion and transmission of the data to insurance carriers in standardize pre-scored format.
Check out this podcast on the topic: https://qpcsecurity.podbean.com/e/ciso-workflows/
Business owners: You own the risk, you decide what to do with that. If you did not vet the MSP or the vendor or their stack, that is ultimately your risk problem.
HUB International as a broker specifically tried to suggest to one of our clients that the MSP should be filling out the cybersecurity insurance application. I found working with HUB International to be very difficult. Marsh McLennan Agency https://www.marshmma.com/ was very good to work with, but they cater only to larger employers.
Gem from Vince: Compliance as a threatIf law firm A can no longer do business with customer B because they don’t have compliance, that is a threat.

CISO Workflows

Friday Sep 30, 2022

Friday Sep 30, 2022

Frank Raimondi, VP of Channel Development at IGI Cyber Labs
IGI CyberLabs has a product called Nodeware which does continuous vulnerability assessment.
PenLogic – regular penetration test – once a quarter deep dive heavy one and a monthly light test.
CEO buyer’s journey
Security velocity
Risk scoring is part of security velocity
Improve your cyber-hygiene – all small businesses
Security 101 is inventory 101
Cysurance – warranty and liability company
It’s good that insurance companies are trying to be more objective about the real risk metrics. Get the scoring and get the data about how risky they are. This feeds into the evaluation data which is used for underwriting.
FTC Safeguards policy impact
Operational security issues – MSPs that post all their personnel information publicly.
The impact of customer contracts and compliance. Squeeze between cost and staying in business in terms of insurance and customer contract requirements.

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