Why You Need a CTO: Avoiding Costly Mistakes in Document Management

In this riveting episode of Breakfast Bytes, host Felicia King delves into the often overlooked but crucial aspect of business technology: document management platforms. With a sharp focus on how organizations of all sizes can benefit from these systems, Felicia underscores the importance of operational maturity and strategic decision-making.
Through compelling narratives and real-world examples, she illustrates the perils of inadequate technology leadership. From misguided IT directors to costly missteps, Felicia shares stories from her 30-year career, shedding light on the vital role a Chief Technology Officer (CTO) plays in safeguarding a company's resources and ensuring seamless technology integration.
Listeners are invited to explore the intricacies of technology planning, from policy formulation to platform selection, and the far-reaching consequences of neglecting expert guidance. This episode is a must-listen for business leaders eager to avoid lighting money on fire and to achieve sustainable growth through informed technology investments.
 
Quick recap
Felicia King discussed the importance of document management platforms and the need for a technology executive in organizations of all sizes. She emphasized the significance of strategic architecture choices, operational maturity, and inclusive decision-making in implementing these platforms. Felicia also highlighted the challenges of managing contracts with consulting firms and stressed the importance of having a clear engineering and implementation plan before purchasing any technology.
 
 
Next steps
• Business leaders to consult with a qualified CTO before making strategic technology decisions, especially for document management platforms.
• Organizations to develop written requirements, document business processes, and create an engineering/implementation plan before purchasing new technology systems.
• Companies to review and potentially modify contracts with technology vendors to ensure compliance with organizational policies and support protocols.
 
Summary
Document Management and Operational Maturity
In the meeting, Felicia King discussed the importance of document management platforms for organizations with more than one employee. She emphasized the need for operational maturity and the use of systems to scale a business. Felicia also highlighted the necessity of a technology executive, even for small organizations, to navigate complex issues. She stressed the importance of understanding these matters, as they are too complicated to be handled by IT support alone.
 
 
Importance of Technology Executives in Orgs
Felicia discussed the importance of having a technology executive in organizations, emphasizing that an IT director often lacks the necessary skills and capabilities. She shared a past example where an IT director made a costly mistake due to lack of oversight, leading to significant financial losses and compliance issues. Felicia advised business decision-makers to use their technology executive in an advisory capacity to avoid such problems, particularly when making large purchases or embarking on significant projects.
 
 
Avoiding Costly Technical System Mistakes
Felicia discussed a long-standing relationship with a client that migrated to a new system, resulting in numerous issues. She reviewed the service contracts and master services agreements, discovering that the client was sold a system that was technically impossible to achieve an effective outcome with. The system violated its own requirements, leading to constant issues and financial losses for the client. Felicia emphasized the importance of using a chief technology officer to avoid such costly mistakes.
 
 
Strategic Architecture Choices in Document Management
Felicia discussed the importance of strategic architecture choices in document management platforms, emphasizing the need for operational maturity, understanding of business processes, and inclusive decision-making. She highlighted the cost implications of using platforms like Atlassian, Sharepoint, and iManage, and the need for a written set of requirements for any project. Felicia also pointed out the challenges of outsourcing document management platform implementations and the need for a highly qualified CTO for consultation. She suggested that Microsoft 365, with its advanced premium licensing and purview, could be a viable alternative to other platforms.
 
 
Managing Contracts With Consulting Firms
Felicia discussed the challenges of managing contracts with consulting firms and the importance of having a CTO to navigate these complexities. She highlighted the need for clear communication and contractual agreements to ensure project success, as she has often encountered issues with support protocols and project kickoffs. Felicia emphasized the importance of having a CTO who understands business, legal, and economic aspects to ensure smooth project implementation, completion, and ongoing support.
 
 
Clear Engineering Plan for Tech Purchases
Felicia emphasized the importance of having a clear engineering and implementation plan before purchasing any technology, likening it to buying a server without understanding its capabilities. She stressed the need for a Chief Technology Officer (CTO) to review proposals and ensure they meet the business's requirements, as well as to avoid potential breaches of contract with other vendors. Felicia also highlighted the value of having a CTO with the right skills, rather than relying on IT personnel, to make informed decisions.

Understand implications of IT procurement using cabinets as an example

Felicia stressed the importance of informed decision-making in technology services and products, and the need for involving skilled professionals in decision-making processes. She also discussed the longevity of structural furniture, the challenges in network switch installation, and the need for a formal procurement process in the IT department. Furthermore, she highlighted the issues with current wall-mount cabinets and open racks, the business impact of operations beyond regular hours, the need for proper equipment maintenance, and the importance of having an on-site technical point of contact at every facility.
Action items
• Felicia recommends ensuring the IT department follows a defined procurement process with oversight from a technology executive.
• Felicia recommends establishing written requirements and standards for IT infrastructure like racks and cabinets.
• Felicia recommends implementing a policy for designating on-site technical contacts to handle basic equipment issues.
 
Summary
Informed Decision Making in IT Services
Felicia emphasized the importance of informed decision making in technology services and products, which is beneficial for all IT stakeholders. She pointed out the persistent negative financial impact caused by ill-informed decisions, often made by business leaders delegating to inexperienced internal IT departments. Felicia advocated for the involvement of skilled professionals, such as CTOs or senior architects, in decision-making processes to mitigate these adverse effects. She also cautioned against the common practice of selecting the cheapest bid as a decision-making criterion, highlighting it as a recipe for failure.
 
 
Structural Furniture Longevity and Design
Felicia discussed the longevity and durability of structural furniture, particularly cabinets and racks. She emphasized that these pieces, often made of steel, aluminum, glass, and possibly plastic, can last for decades if not physically damaged. Felicia argued that considering a 20-year life cycle for such hardware is a more realistic approach than starting from an acquisition cost requirement. She also highlighted the advantages of a four-post full floor standing cabinet over a two-post rack, especially for secure and critical infrastructure. Finally, she noted the importance of wheels in cabinets from a maintenance perspective and referred to cabinet design as an art form.
 
 
Felicia's Network Switch Installation and Maintenance Insights
Felicia shared her extensive experience and insights on the challenges and considerations in network switch installation and maintenance. She emphasized the preference for a 4-post configuration due to the weight and depth of modern switches, and the issues that may arise with alternative setups. Felicia also highlighted the importance of understanding the ramifications of equipment placement, sharing a troubling example of a poorly executed setup. She suggested ways to prevent such issues from occurring in the future.
 
 
Improper Procurement Process in IT
Felicia discussed the lack of a formal procurement process in the IT department, which leads to inefficient and often unnecessary purchases. She explained that the department, composed of individuals not highly proficient in business value justification or total cost of ownership articulation, often sourced items themselves using credit cards, without proper checks and balances. Felicia emphasized the need for a written requirements list to facilitate better decision-making and prevent the focus on apparent acquisition cost. She indicated that she would provide two examples to illustrate these points.
 
 
Addressing Inadequate Infrastructure and Procurement
Felicia discussed the recurring issues with the current wall-mount cabinets and open racks in the infrastructure, which were not deep enough to accommodate modern switches. She emphasized that this problem wasn't new and had been ongoing for at least a decade. Felicia pointed out that previous investments in these inadequate setups were essentially wasted, not just in terms of money but also project time and potential business unit outages. She underscored the need for an appropriate procurement process and oversight to avoid such issues in the future.
 
 
Managing Operations Outside Regular Hours
Felicia discussed the business impact of operations extending beyond regular business hours. She highlighted that this not only affects payroll and product but also has implications for business continuity outside of IT. Felicia emphasized that IT personnel, such as PC technicians and IT managers, often only consider their own needs, which differs from the perspective of a technology executive. She stressed the importance of a different mindset, drawing from her experience as a chief operating officer and service manager, to effectively manage a large number of remote offices.
 
 
Client's Server Outage Due to Unauthorized Access
Felicia shared a story about a client who opted not to spend $350 on an idrac enterprise card, a decision that led to a server issue causing an outage. She emphasized the importance of proper equipment maintenance and restricting unauthorized access to technology cabinets. Felicia pointed out that allowing staff without proper training or maintenance responsibilities to have access to such spaces can lead to unintentional damage, as seen in the case of the client where a staff member put a box on a server keyboard, causing an outage. She underscored the significance of having a mature policy in place regarding remote support and access to technology cabinets.
 
 
On-Site Technical Point of Contact Importance
Felicia stressed the necessity of having an on-site technical point of contact at every facility to handle minor technical issues. She used the example of rebooting cable modems, which she stated often require physical intervention and should not disrupt other equipment. Felicia also emphasized the importance of setting up the facilities in a way that allows easy access for the on-site technical point of contact to perform these tasks without causing further problems. She underscored that this is a common requirement and should be considered in the facility's setup.
 
 
Technology Executive's Role in Procurement
Felicia emphasized the importance of having a technology executive oversee procurement policies and standards in IT departments to ensure good outcomes. She highlighted that the IT department alone should not be making procurement decisions, as they often lack an understanding of the total cost of ownership. Felicia also rejected the idea that a dollar amount should be the sole determinant of procurement decisions, citing the potential for malware to compromise the system. She advocated for a designated technology executive to establish policies and standards, warning that failing to do so could lead to adverse financial outcomes for the organization.
 
For more information, review this resource about racks and cabinets.
https://www.qpcsecurity.com/2024/04/26/why-buy-racks-and-cabinets-from-qpc-security/
Peruse the value of vCISO services.
https://www.qpcsecurity.com/vciso-services/
 

Unlocking Strategic IT Investments and Information Security

"Unlocking Strategic IT Investments and Information Security: Expert Insights with Gina King" dives into the critical aspects of IT investments and infrastructure. Felicia King, host of 'Breakfast Bytes', engages in a captivating conversation with Gina King, a leading Chief Information Security Officer. The extensive dialogue sheds light on necessary expenditures on Information Systems and Technology, managing and optimizing security investments, and realigning perceptions of IT as a valuable strategic asset.
Through their enriching discussion, Felicia and Gina tackle widespread issues of underinvestment in IT, encouraging businesses to understand and optimize their IT expenditures. Pointing to the risks of non-compliance and inadequate IT security measures, they illustrate how a thorough approach to IT spend analysis can tremendously impact a company's financial bottom line, customer satisfaction, and overall client experience.
The episode highlights the importance of a proactive and continuous IT security investment to nurture an effective information security risk management program. Felicia and Gina underscore the significance of considering cybersecurity as an aspect of overall business risk, rather than an isolated problem. They also emphasize the value of tech-savvy leadership and security education in fostering a vigilant workforce and strengthening an organization's security posture.
Switching gears to effective risk management amidst the digital landscape, the episode ends on a call for creating clear policies, continuous vigilance, and an understanding of organizational identity to safeguard online infrastructures. This engaging discussion is a must-listen for anyone involved in IT procurement, investments, security, and overall business operation.

Domain/DNS hosting, account ownership, security issues and TCO

Join us in this insightful episode of Breakfast Bytes with Felicia King, along with our guest Kyle Wentworth of the Wentworth Group. We delve into a balanced exploration of business needs vs IT security needs, demonstrating the magnitude of this issue with a case study of a massive spam operation hijacking over 8000 trusted brand domains.
https://thehackernews.com/2024/02/8000-subdomains-of-trusted-brands.html
In this detailed conversation, our experts elucidate steps towards prevention and emphasize the significance of effective domain ownership and control. Kyle highlights the central role of Technology Management departments in mitigating IT risks and stresses the importance of a comprehensive understanding of orderly processes for DNS management, timely publishing of DNS records, and the related cost implications.
This episode underscores the need for operational maturity in businesses, and how maintaining domain infrastructures and adhering to robust protocols can protect your business from digital threats. Listen to gain invaluable insights into how businesses of all sizes can level up their understanding of the intersections of business and IT security systems.
The episode also draws attention to the potential vulnerabilities of newly registered domain names and the common pitfalls relating to outsourcing these functions. We underscore the necessity to take caution or face serious losses and discuss the ramifications of transferring control of key business aspects to external vendors.
With a candid look at the dangers of ill-considered network security and the hazards of transferring all risks to an external IT service provider, we make a strong case for integral security measures. Listen in to gain an understanding of the importance of viewing technology as a business partner rather than an expense and to learn how focusing on strengthening your network security can pave the way for business success.

How establishing requirements properly results in best outcomes

Felicia is joined by fellow CISO Dawn Montemayor, partner at PureCyber, which is a security minded business consulting firm. Learn from two CISOs about how vital it is to use operationally mature processes in requirements definitions in order to achieve effective outcomes while avoiding toxic behavior in complex entities.
the importance of vulnerability assessment and management requirements in contracts
It is imperative for resource owners to be designated and held accountable to outcomes.
Exit strategies must be established as part of the procurement process
Lack of right to audit clauses in cloud services contracts
How the lack of an effective paradigm leads to destructive decision-making
IT must not be seen as the dumping ground or janitor. Instead the business must be charged back for the real proportional costs for the cost of service.
True TCO calculations must be made as part of the procurement requirements definition.
Systems integration and interaction maps are incredibly valuable
IT must be seen as a business partner and involved in decision-making.
Just because IT wants to say yes to help the business does not mean the business gets to disrespect IT standards.
Talking to the CISO can lead to utilization of an already vetted, approved platform making the pace of business faster.
Why procurement justification statements are imperative
Why it is necessary to track TCO and actual costs for product and services associated with a business function
Why it is essential to use operationally mature processes in a paradigm focused on governance, accountability, and transparency
Why the CISO and CTO should sign off on procurement of anything for which there is not already an approved policy standard on.
Why your CISO needs to review the contracts for a service or product before an officer of the company signs the contract
Why business leaders must consider how their revenue is event driven
Why the shared responsibility model is imperative. Resource owners must be defined and made accountable.

Operational Maturity is required to have Information Security Risk Management

Felicia is joined by Laura Conrad, a Security Architect with 30 years of experience in enterprise environments. Laura currently reports directly to a CISO, and has been an integral part of the information security program at two large enterprises.
Felicia has consulted with 26 large enterprises and numerous SMB organizations in the last 30 years. She finds that the same problems occur in every organization that lacks operational maturity. 
Are you a person working in information security frustrated by the lack of progress of a security program in an organization because of the org's lack of operational maturity? Do you struggle in dealing with toxic, unproductive people? What approach could address these problems and more? Learn from two experts how they have seen companies engage in self-destructive and resource wasting approaches simply due to the lack of drive by executive leadership to install a structure for governance, accountability, and transparency in the organization. 
Org structure required for CISOs to be effective
This article and its impact are briefly covered as they are related to this topic.
https://www.darkreading.com/cybersecurity-operations/cisos-struggle-csuite-status-expectations-skyrocket
It is quite a good article, but it implies that if the CISO reports directly to the CEO, the problems in an organization will be reduced. While that is partially true, that by itself will absolutely not fix the problems. Felicia and Laura deep dive the decision-making failures that occur throughout an organization and what drives them. Also discussed are methods to truly and structurally correct the problems across an entire company.
95% of information security risk management issues are HR management issues
Executive management want to run the company, not manage people. This leads to toxicity and unproductivity being tolerated when personnel issues are not fully investigated and actioned. The desire to make an emotional problem go away cannot override the need to get to the core of the issue and put a system in place to prevent it from happening again. This is not about firing people. This is about instilling a culture where the facts matter, personnel issues will be investigated, and structural systems will provide the governance to drive productive staff behavior.
Org executives are unaware of the real costs of inputs
It seems to be a pervasive problem across most organizations that there is no financial management structure which facilitates the tracking of expenses as inputs to a service or product delivery to customers. Without this real understanding, leaders persistently price products and services incorrectly. This leads to one business division or a product line losing money and needing to be subsidized by another.
Executives rarely understand that by tolerating operational immaturity in their organization, they are actually failing in their duty to stakeholders to effectively manage the assets of an organization to maximize value.
Drive change and org-wide staff effort alignment with dashboards that drive transparency and healthy internal competition
Felicia and Laura discuss in detail the how and why of dynamically updating dashboards which help CTO, CIO, CISO manage upward to the CEO and board, while driving downward alignment to objectives.
Governance, Accountability, Transparency in IT Security
Felicia and Laura discussed the importance of governance, accountability, and transparency in IT security and business processes. They emphasized that these principles could help prevent problems caused by a lack of collaboration and understanding between IT and business units. Felicia cited instances where poor prior planning led to unnecessary expenses and internal toxicity, which she believes could be avoided with a more mature approach to operations. Laura added that these principles could also lead to cost savings and risk reduction. 
Harden the procurement policies
Felicia and Laura provide many examples of problems that could have or were avoided by having an enforced procurement policy which resulted in all technology purchases being signed off on by the CISO or security architect and often the enterprise architect. It is infinitely easier to rectify issues before an implementation and before signing a contract than to do so after a purchasing decision has already been made.

Zero trust fundamentals

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!!!
FUNDAMENTALS MUST BE MASTERED
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.

FTC SafeguardsRule, IRS requirements, and tax preparers

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.
https://www.irs.gov/newsroom/heres-what-tax-professionals-should-know-about-creating-a-data-security-plan
All of it is common sense and things that orgs should have been doing for ages.
IRS publication 4557
https://www.irs.gov/pub/irs-pdf/p4557.pdf
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
https://qpcsecurity.podbean.com/e/business-survival-over-the-next-decade/
More information on this topic from Joe Brunsman, cybersecurity insurance expert.
https://youtu.be/NOY249doJXg
 

Business survival over the next decade

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.
https://www.irs.gov/newsroom/heres-what-tax-professionals-should-know-about-creating-a-data-security-plan
https://www.irs.gov/pub/irs-pdf/p5293.pdf
https://nvlpubs.nist.gov/nistpubs/ir/2016/NIST.IR.7621r1.pdf
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). 
https://www.irs.gov/pub/irs-pdf/p4557.pdf
 
More details from Joe Brunsman, cybersecurity insurance expert.
https://youtu.be/NOY249doJXg
 
 

Tech E&O and cyber insurance with Joe Brunsman

Tech E&O and Cyber insurance with:
Joe Brunsman of The Brunsgroup – Expert on Tech E&O and Cyber Insurance
YouTube channel – Joseph Brunsman
https://www.youtube.com/@JosephBrunsman
https://www.thebrunsgroup.com/
Damage Control book
https://www.thebrunsgroup.com/book2
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.

The relationship between proper data handling and real risk reduction

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.
https://qpcsecurity.podbean.com/e/what-you-must-do-in-order-to-prepare-for-a-breach/
(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.
https://qpcsecurity.podbean.com/e/understanding-vciso-services-and-why-you-need-them/
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
CIO
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
Concerns
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?

Understanding vCISO services and why you need them

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.