Quality Plus Consulting - Breakfast Bytes
Friday Mar 03, 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.
Thursday Feb 09, 2023
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.
Wednesday Jan 04, 2023
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)
Stakeholders such as board of directors and heads of business units
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.
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.
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?
Friday Oct 28, 2022
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
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.
Wednesday Sep 21, 2022
Wednesday Sep 21, 2022
This episode of Breakfast Bytes is Part 2 of a series where Felicia King and Dan Moyer of QPC Security continue their conversation on Vulnerability Management. Listen to Part 1 at https://qpcsecurity.podbean.com/e/vulnerability-management-part-1/.
In today’s episode, Felicia and Dan discuss vulnerability management workflows, supply chain risk management, starting with security on the front end rather than retrofitting, and proper patch management.
01:10 CISO-related (Chief Information Security Officer) workflows are at the core of what is today’s necessity, and we will only see it become more mandatory within the next couple of years. Organizations that do not have vulnerability management workflows in place in a comprehensive way are going to find they have too much technical debt, deferred maintenance, or deferred security to be able to dig themselves out. This won’t be from a lack of money either, but a lack of manpower and time in the day to rectify the issue.
Supply chain risk management
02:43 SaaS vendors have vulnerabilities and very few of them have in their contracts your rights and their obligations. What kind of questions should you be asking your SaaS vendors that in many cases you are responsible for as an organization? Here are just a few:
Do they have continuous vulnerability management scanning going on with regards to their SaaS platform?
How are they classifying vulnerabilities?
How quickly are they going to resolve vulnerabilities?
How are they communicating these issues to you?
Do they use API security scanning?
How do they adhere to OWASP API standards and best practices?
What are they doing for you in terms of supply chain risk management or software bill of materials?
Your organization’s CISO or vCISO should be in your court getting answers to these questions if they are not being addressed by your SaaS vendor or addressed in your contract. Having a proactive, highly functional, highly communicative, and open, honest working relationship with your CISO will ensure you have the protections your organization needs.
Proper patch management
04:51 Let's walk through an example of patch management in an environment with Hyper-V hosts, Dell PowerEdge server, domain controllers, business critical SQL servers with essential business applications, virtual machines, remote sites, on-site and offsite backups, hardware at different speeds, and then all these third-party software on these workloads – how do you patch all these things?
06:11 It is exceptionally important to note that some patches will step on or over each other, be required to be put in place and rebooted first, and then other patches applied on top of it. The time it takes to patch a server can be exacerbated by trying to accomplish, say, five patches in one changewindow rather than one patch/reboot followed by another one patch/reboot, and so on.
07:48 Watching the servers reboot is an important piece to verify the workload comes back up reiterating the point made in Part 1 of this series that adequate patch management of an entire server for $50/month cannot be done.
09:19 There tends to be multiple domain controllers or, in the case of just one, it has been designed so that it can reboot whenever it needs to allow for patching. The domain controller is the brain of everything, and since it can reboot whenever needed to apply patches, it can facilitate that while staying available when everything else comes back up.
Typically we will start with domain controllers as the first thing patched and verified. Now if there are multiple, and depending on how critical the environment is, a rolling out patch might be done so that these secondary domain controllers or ones that are not on the best hardware are patched and then they sit for a period.
Backup plans and backstops
11:29 Part of that patching methodology is your backup plans and backstops – having the tools and everything else in place to uninstall a patch if needed. When we set up our servers, we always have Command Prompt and PowerShell already queued up on those devices when we log in. Then we have the availability of pre-planned scripts that we can adjust as we go but most importantly, all the tools are there and available.
Importance of roles on servers
12:25 Part of your ability to have resiliency in the environment is the ability to reboot whenever you need, because you have redundancy and resiliency. Because it is a single role server, it gives you that agility to be able to resolve and prevent issues.
Therefore, workload design is the name of the game. Whatever you think that cost is of that additional virtual machine, that is nothing compared to the problems that you cannot solve because you tried to shove a bunch of stuff together in workloads that did not meet because they were mismatched workloads.
Many patch managers are not comprehensive and there is a lack of consistency in of what is getting patched on a well-designed domain controller versus a third-party party application server.
16:09 Watching a virtual machine reboot while maintaining efficiency and not biting off more than one can chew is crucial, but we are also finding is increasingly important to watch the physical servers and that can only be possible with the right hardware.
How are you auditing and confirming that patches are being applied and which ones have not? At QPC Security, we bring all the virtual machines down and reboot the host as a prerequisite for patching because it gives you a clean slate to start your patches. Then we will use the patching methodology to push specific patches down to it. We use our patching piece to push specific ones because not everything is needed for hosts and other pieces that we have identified will cause an issue, is a multi-patch, or a multi-patch/multi-reboot process.
Taking one step at a time, pull it down, apply patches, make sure everything is happy coming up. Go through that entire process again. While we are connected to iDRAC, we watch the server, reboot, apply patches, come back up, make sure all the VM's are checking in properly, we are making sure everything is available, then they go through that process two to three times. It depends on how many patches are available and what things got pushed out.
Everything has patches
20:39 If you have a hypervisor that is not giving you patches; you should not be using them. Likewise, if there is no product improvement then there is no security management from that vendor. There is no easy button or a set it and forget it.
21:42 When IT is not confident in how a process is going to work, they do not want to touch it and that is exactly where a vulnerability arises. Say a consultant installs Cisco, but without a brand expert or budget in place keep the consultant to maintain it, it remains unpatched and therefore vulnerable. That is precisely why organizations need to have a business continuity and disaster recovery (BCDR) plan in place and a procurement policy that drives effective vulnerability management.
25:26 When people are too afraid to patch the hardware, it does not get patch which accumulates over time in terms of technical debt and the technical issues it accumulates. Attempting to patch too many patches at once or jump too many versions results in the reboot cycle of death or a very time-consuming reboot because you are not running a vetted, tested, and supported configuration. The more time and versions you allow to pass between patches, the more divergent from manufacturer’s tested config those updates become.
Buying the right hardware to begin with saves you money down the line
33:20 A crucial piece to vulnerability management in your workstations is BIOS, drivers, firmware. If you buy the right hardware to begin with that has the automation engine built into it and when you deploy it you are configuring it accordingly, it becomes far less expensive than paying a human being to manually babysit your vulnerability management.
Not all workloads are created equal
34:59 A word of caution when an IT service provider quotes patch management for your organization. When it comes to patching business line apps that need high uptimes because it costs a business thousands of dollars per hour to be down, what patches does the ITSP apply and with what preparation for back out plan?
In many cases, an ITSP is giving a client the perception of patch management, certainly not vulnerability management, but in reality they are simply doing a Windows update and only some third-party patching, which might only be five third party applications. At QPC Security, our catalog of patches of over 9500 software titles that we are patching and there is no automation. Visit https://www.ivanti.com/partners/ivanti-software-catalog to learn more about the normalization of software titles.
Cybersecurity insurance applications require continuous vulnerability assessment and vulnerability management. However, most IT service providers do not offer comprehensive patch management. Their vulnerability management claims are grossly misrepresented to the point of malfeasance.
Vendor documentation & software bill of materials
37:43 You cannot keep your head in the sand – all these things must be considered when receiving a quote from an IT service provider.
In cases when the software vendor is not offering competent documentation, your organization must rely on the legwork of your IT service provider to offer timely patches at opportune times. Do not forget that many ITSPs will charge you to run patches on the weekend or evenings when there will be minimal impact to your business.
43:02 Your ITSP should have vetted and tested procedures and protocols for implementing patches, yet all too many do not. So many times, we see the priority of IT companies are how quickly they can close a ticket and rely on the software companies to do it for them. This focus on first-call closures and ticket metrics (termed here as “titrics”) is grossly underserving their clients and their clients’ organizations. Proper documentation allows for better time management and to offer effective support to best serve the needs of the clients without requiring the assistance of the third-party software vendor.
47:05 Gaps in change management, change control, and documentation for server workloads arise when an ITSP is focused on ticket-based productivity rather than quality of service. The original scope of the project by the ITSP requires evaluation from someone who can accurately evaluate the needs of the client’s organization. When the bid is too low, the needs of the client are not going to be met, the work will not be completed, and the organization is left vulnerable.
50:03 Unfortunately, an incompetent ITSP will leave out what services they had to cut out on the race to the bottom of the pricing model and that leaves it up to you, as the business owner, to be aware of your organization’s cybersecurity insurance policy requirements and how they are being fulfilled.
Questions? Reach out to us
QPC Security proudly serves businesses with virtual CISO services for our clients. If you are interested in learning more about how QPC Security can serve the needs of your organization please visit https://www.qpcsecurity.com/ or call one of our experts directly on (262) 553-6510.
Stay up to date on the most recent episode of Breakfast Bytes by following the podcast on Podbean at https://qpcsecurity.podbean.com/.
Learn more: https://www.complianceforge.com/faq/word-crimes/policy-vs-standard-vs-control-vs-procedure
Wednesday Sep 21, 2022
Wednesday Sep 21, 2022
We have seen some really goofy cybersecurity insurance application questions. It is always best to not answer a question that is goofy, but instead to write an addendum that defines terms and explains the cybersecurity posture of an organization related to the topic. You need to try to figure what the insurance company was trying to evaluate rather than just answering their questions because their questions are frequently not suitable for yes/no answers.
Greg Cloon joins me to discuss this topic.
We also touch on when you would use file hash integrity checking, when to use disk encryption, and when to use encryption for communications.
Here's a link to IISCrypto.
Tuesday Sep 13, 2022
Tuesday Sep 13, 2022
Felicia King and Dan Moyer of QPC Security talk about vulnerability management, patch management and all the things that business owners are generally not understanding adequately. As a result of that, you're being underserved, misled, and in some cases were lied to and ripped off.
Ultimately, many business owners are refusing to pay for what they need for adequate risk management because they don't understand what they need. In today's episode Felicia and Dan fill that gap.
Announced on October 6, 2021, the US Department of Justice Civil Cyber-Fraud Initiative is applying the false claims act to those who:
fail to follow required cybersecurity standards
knowingly provide deficient cybersecurity products or services
misrepresent their cybersecurity practices or protocols
violate obligations to monitor and report cybersecurity incidents and breaches
Just let that sink in for a second. So, is your IT service provider really meeting that standard? I sincerely doubt it.
01:23 The difference between vulnerability management and patch management
Holistic vulnerability management includes, but is certainly not limited to:
Software bill of materials analysis
Supply chain risk management
Third-party risk management
Asset inventory up to date
Continuous vulnerability assessment
Frequency penetration tests
04:38 Cybersecurity insurance applications aren’t asking JUST about patch management
When did you have your last penetration test?
Do you have continuous vulnerability assessment in place?
How long are you going to go without having the patches applied in the environment?
If you think adequate patch management can be done for $50/mo/server, you are hallucinating.
So, what’s included in patch and vulnerability management?
05:34 Patch management
Patches are the building blocks that are improving the software that lives on the hardware. Without software, you can't interact with the piece of hardware unless it's purely mechanical, and even then there's still improvements of usage.
How do you manage and protect those tools of your business from threat factors?
09:20 Third-party patches & vulnerabilities
IT service provider proposals are telling business owners that they can patch their servers and their endpoints and automate Windows updates and some third-party patches. What are those third party applications? What about all your custom business line applications? Do you actually want your critical SQL server to have its SQL instance updated using automation? How much money does it cost you if that workload is down?
10:27 Asset management
Do you know what you have in your environment? Do you have accurate asset management and vulnerability assessments? Simply stated:
“You can’t secure what you don’t have an accurate inventory for.”
It is a regulatory requirement and cybersecurity insurance requirement to adequately document and understand software dependencies in your environment. That requires a proper inventory of your hardware, software, and subcomponents of the software. This is frequently referred to as SBOM - software bill of materials. And if you think your software vendor is going to provide that information, please go ask them for that information. You will probably get a blank stare. IS security engineers can figure it out on their own.
18:48 Implementing proper procurement policies
Does your procurement policy support your vulnerability management strategy? Does your software acquisition and implementation policy (if you even have one) support your cybersecurity insurance and regulatory requirements?
When business decision makers put pressure on an IT service provider or internal IT to implement new software without proper security protocols, vetting, and process documentation, vulnerabilities are nearly always introduced into your environment. Sometimes that comes directly from their insecure software. Sometimes it comes from the tools and connectivity they use to remote into your systems or things like API connectors that your IT is supposed to just blindly trust the software vendor to secure their software with zero validation or proof. A proper CISO on your team or through your ITSP will be able to directly vet the vendor and software itself.
You are required by cybersecurity insurance and Federal regulatory guidance to do so. It is also in your business's best interest to do so.
Be very careful looking for just certifications for someone who says they are a CISO. The majority of CISOs do not have technical chops. They are often compliance managers that cannot do the technical work. Those people have limited usefulness and will not be able to
All of the vCISOs at QPC are hardcore technical because we understand the essential nature of that skillset being a mandatory requirement to deliver effective CISO services.
20:24 Privileged access management and privileged password management
How do you know who has access to remote access to your systems? How many people will have access to your systems? Today, there are many IT service providers who are not disclosing their outsourced Helpdesks that are giving full administrative-level access to a customer’s back end to all those workers at the virtual live Helpdesk. Most ITSPs also fail to disclose the totality of the quantity of people that will end up with admin access to some or all of your systems.
Ask yourself. If you have 25 office personnel, why would it take 30 remote people to have admin access to your systems in order to provide competent support? Do you think it is actually possible to have a high security environment and magically keep 30 people fully up-to-speed on the exact correct configurations required in your environment and what the interaction effects are? It's not possible and will never happen.
24:27 A procurement policy can keep a business' IT costs stable
The number one thing that business owners complain about is the cost of maintenance. With a procurement policy in place and by working with their IT service provider and procuring anything that they do not have a full understanding of the total cost of ownership for – costs can be managed.
Does your procurement policy support your business strategy and needs?
34:22 Understanding the cost and time of device and software procurement
There's also a lot of other risks that the vast majority people don't think about; they tend to only think about the budgetary risk. However, getting the strategic input from a CISO or CIO to develop an understanding of the minimum pricing floor and how that affects the total cost of ownership, can save a business not only money but time.
SaaS can get you closer to a flat-rate cost but you may have inherited additional risk and vulnerabilities, depending on how the new technology interconnects with your systems. Additional risk factors are:
structural increase in cost of doing business risk
accessibility risk (redundant access is then required and cannot be fully mitigated)
external software vendor attack vector risk that cannot be mitigated through Layer3 ACLs
37:33 Cloud vs on-prem security
It's still a fallacy that having your systems in the cloud is better and cheaper, incorrectly thinking they can have as good security in the cloud as they can on premise. Going to SaaS can provide a lower and more predictable TCO if the counterparty risk you accept is worth it. But picking up your servers and hosting them on someone else's infrastructure will never be less expensive. IaaS cost savings are a fallacy for the majority of businesses. The exception being massive companies with heavy DevOps needs for spinning up and down workloads quickly. Most of those items are being migrated to Kubernetes and OpenShift.
46:48 IT/IS is not a utility
The electricity company, the water utility, garbage pickup, fire and safety, ISP – they are monopolies and uni-taskers. Whereas IT is far more complex. People tend to think that if it’s a utility, therefore it’s a commodity, and if it’s a commodity it doesn’t matter which service provider I choose.
Business decision makers are trying to manage budget risk without understanding their requirements. They also want to have budgetary control while abdicating their involvement upon outsourcing their IT to an ITSP.
An IT service provider can be a partner to success and can help businesses develop better business strategies IF there is regular and open communication.
This is part 1 of a 2-part series on vulnerability management. Listen to Part 2 at https://qpcsecurity.podbean.com/e/vulnerability-management-with-felicia-and-dan-part-2. To learn more about QPC Security, visit us at https://www.qpcsecurity.com/
This is another resource for vulnerability management information.
Saturday Jul 16, 2022
Saturday Jul 16, 2022
More than 80% of breaches occur due to credential theft. All organizations have compliance requirements to have org-owned password management systems and MFA enforcement on accounts used by employees and contractors.
Some other needs which must be met are:
Compliance attestation documentation
Proper use of the best MFA method on a per resource basis
Aligning business continuity objectives with cybersecurity objectives
Developing procedures for staff on how to use the company password manager system properly
Aligning procedures with information security policy
Developing/enhancing information security policy
End user awareness training around credentials, MFA, password management
I wrote a 16-page educational guide for clients to help them understand the complexities and challenges of password manager solutions and why this is not an easy button project. This podcast is a supplement to that whitepaper.
See the following supporting podcasts for additional information.
Why buy from QPC
QPC provides managed clients staff onboarding and training documentation. As we update the documentation with new procedures or enhancements, we publish the new versions of the documents to the client’s IT Training SharePoint library. We also make them available through the QPC Security portal which all M365 users have access to.
QPC creates and maintains workflows for cybersecurity insurance and compliance attestation for managed clients. Compliance attestation and the maintenance of the reports and workflows to produce the compliance attestation are mandatory for cybersecurity insurance and some Federal or State regulatory compliance. As supply chain and vendor risk management becomes more prevalent, organizations will need to provide proof of these items to customers or prospective customers as part of contractual due diligence. Organizations can scramble to compile these items on their own. Managed clients benefit from QPC’s compliance preparedness.
Access to QPC’s password manager import/export/business continuity procedures. Our expertise in password manager conversions reduce friction to staff adoption of the system.
Support customized to client’s unique needs
Strategic guidance on how to best use the tool to meet the staff’s needs while being in compliance and alignment HR, information security, and company use of technology policies
Advanced security implementation services
Reduced implementation time compared to implementation by client’s in-house IT
Compliance attestation for cybersecurity insurance
HR policies which support use of the solution; employee use policies
QPC provided password security policy
Training for end users on how to setup what kind of MFA
QPC has systems for shared MFA even when OTP is not an option for a resource client staff are accessing.
Managed clients benefit from QPC’s existing R&D investment as well as ongoing enhancements of managed functionality.
No data loss or business continuity risk in doing so. At any point a client who wishes to separate from QPC can do so. This is covered in the separation area of this document.
QPC has a strong relationship with the software vendor where the feature requests we submit are typically integrated in the product in three months. We submit feature requests for functionality for managed clients.
QPC includes additional compliance modules in the subscription which are not part of the standard direct subscription. Keep this in mind when doing price comparisons.
QPC can co-term licensing for user additions
Direct software vendor support is not designed to be anything other than break/fix
Quicker response time than direct software vendor support
QPC is able to provide enterprise level support for the product whereas a direct customer would need to have a $25,000 per year support contract in order to receive a similar level of support direct from the software vendor.
QPC can be the compliance delegated admin for clients where desired. If not desired, then the client must assign and fully train the compliance manager delegated admin. Responsibilities and recurring tasks must be assigned to that person.
QPC works with managed clients to define staff user roles and assign security policies to them. Some employees should not be accessing the password vaults unless they are on company‑owned and secured systems. We define allowed platforms, security baselines, restrict data exfiltration and more.
QPC can implement additional technical controls to prevent employees from storing passwords where they should not be stored, such as browsers. We strongly recommend technical controls and ongoing cybersecurity awareness training backed by employee policies the reduce the opportunity for storing passwords related to company assets in an unapproved manner.
QPC can provide a separate end user support system for clients where they are able to contact the password manager support via email, chat, and phone. This service is not available for direct purchasers. Direct support includes only Level 1 help desk for basic user configuration or end‑user issues at the quantity of 25 per year. Free online documentation and videos is included of course.
Onboarding, new employee training, and configuration management support is not available for direct accounts.
Not only should all organization or company-related credentials be stored in a company-approved password management system, but at least two individuals in every department should have modify access to any shared credentials. Password management systems which meet the security requirements and are cloud-based tend to have zero trust storage methods.
Zero trust storage is a very important concept. It means is that if a second person was not granted access to that data, it may become irretrievable. It also means that unauthorized parties cannot see your passwords or the content you store with them. That includes your service provider and the password management system hosting provider.
Business continuity also comes from techniques. For example, individuals who share a job function should always have their own unique logins and MFA into a system where possible. That is the dual-‑admin approach. A great example of that is Constant Contact, bank websites, your company UPS account, marketing automation platforms, etc. Multiple people may be sharing a job function, but each person should have their own login IDs where possible.
In the cases where a website or resource does not allow for individual credentials for multiple individuals, the use of a password manager application with shared MFA allows the shared business function staff to have secure access to the same credential with MFA enforcement on the resource. This is a critical feature for security and risk mitigation.
Separation from IT service provider
In the case the client wishes to separate from QPC, they are able to convert to a direct paid account or able to migrate their licensing to another IT service provider. No data loss will occur as long as proper offboarding procedures are followed. The procedure is quite simple. First one must pay for separate licensing. Second, the master administrator account which is like a glass-break recovery account must be transferred to the new designated personnel. This is very easy to do since QPC’s standard business continuity protocol for configuration of a managed tenant involves the inclusion of this glass-break or master recovery account.
Friday Jul 01, 2022
Friday Jul 01, 2022
You should not put things in the cloud unless you can secure them there at least as good as a highly competent professional would have if they had that asset on premise.
Cloud hosted assets have additional risks.
Additional outage and accessibility risk
You have less control
You have less security over the human or governmental access to your content
Zero 4th Amendment protections over that data. It's fully subject to FISA searches that the provider is required to never tell you about.
Also do NOT get sucked into the scam that cloud hosting servers is more secure than if you did them on premise or somehow more cost effective. That is sheer lunacy.
SaaS can be more cost effective and more secure. Look at Office 365 as an example. That is clearly more secure, more cost effective, and more value than a premise Exchange server. SalesForce could be better for you than running your own CRM, but then you are also fully open to their crazy policies which could rip the rug out from under one of your most business critical systems.
There is no one right answer 100% of the time. Context and artistry of security strategy are exceedingly important.
This show is about these things as well as what you must have in place to have premise hosted secure assets. I describe a Tier0 asset scenario in specific and what can easily undermine it.
Premise hosted password managers
It is worth noting that extremely high functionality privileged access management and identity management systems are available in a premise hosted format which are a perpetual licensing model with very low annual software maintenance fees. These systems are exceptionally valuable to IT departments and QPC has extensive experience in these platforms. They are an exceptional value to IT management functions and IT departments.
However, most organizations, even those with full-time IT departments, will not meet the requirements for self-hosting. Why? In order for a self-hosted password management system to be successful, it relies upon many factors which must be in place and be fully executed with extremely high levels of skill and security. This level of skill is outside of the technical skill level of nearly all IT departments of companies with less than 5000 employees.
If the requirements are not fully met continually for the life of use of the platform, the platform and its contents are likely to be compromised. A compromise could consist of the data exfiltration of the entire password vault database which would be catastrophic to the organization.
Baseline requirements for premise password managers
Extremely tight supply chain risk network layer security rules and management
Ability to do offline upgrades for all software and systems involved
Extremely adept underlying server, network, power infrastructure management
Rapid patch management within 48 hours or less
Always on scanning for vulnerability assessment backed by active monitoring and remediation
Multiple first line backups per day with multiple encrypted offsite backups per day
Two physically disparate sites with significant server, network, power infrastructure with automatic backup generator service and redundant internet
Proficiency at managing SQL server replication over WAN links in an active/active SQL server configuration
Proficiency at maintaining active/active application server configurations and automatic failover network configurations
Absolute rigorous discipline to adhere to documented standards for vault creation, password management system administration, application updates, database system updates, OS updates, third party app updates, network layer security management across the entire internal and site-to-site connected networksAny laxity in the discipline of the IT personnel managing the system will cause it to fail to deliver the security profile required for critical assets.
Minimum of two servers involved with the addition of more servers if internet facing roles such as mobile access are desired
IT personnel’s ability to implement and maintain complex privileged access management systems
Regular security compliance and audit report reviews. This will require a CISO and/or compliance officer with significant technical skill.
Saturday Sep 25, 2021
Saturday Sep 25, 2021
How to avoid cybersecurity insurance fraud. If this happens to you, your claim will be denied and you will likely be uninsurable in the future including by other insurance providers.
You have to be working with an extremely operationally mature ITSP with ISOs on staff or you probably will not be able to navigate this complexity.
Great article showing a claims denial and then accompanying lawsuit for a perceived insurance fraud indicent.