Quality Plus Consulting - Breakfast Bytes
Decision-making and Procurement
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.
Sunday Feb 19, 2023
Sunday Feb 19, 2023
I get a lot of questions about PSAs, ERPs, and overall paradigms related to core business software. This podcast summarizes things you should be thinking about in your software selection process.
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 11, 2023
Wednesday Jan 11, 2023
Kathy Durfee – CEO & Founder of Tech House joined Felicia to discuss dark web breach monitoring
Scenario: FUD report from a competitor
Perceived: Multiple users in their environment were breached. Perceived proof was report with the listing of the users and the passwords and columns that the customers did not know what that data was.
Good: Customer told their current IT service provider about the report.
FUD – Fear, Uncertainty, and Doubt – is, in the wrong hands, a powerful tool to drive snap decisions within a company. However, it is not a viable or valid sales tactic: for all it could potentially do well, causing unnecessary stress and suffering is what it does best. Speaking with Kathy Durfee, CEO and Founder of TechHouse, a managed services and solutions provider based in Florida, we walk through a recent case of FUD with a customer of hers that received a worrisome report from a potential competitor. During our chat, we covered:
The key aspects of FUD (and how it does not work)
What the Dark Web is, and the logistics of monitoring and combating it
Leadership training and best practices for helping a team best meet their security and regulation requirements
Identifying the key differences between commodified and relational partnerships, especially in the technological sphere
Shared responsibility between MSPs, their customers, and those customers’ clients
Where does dark web monitoring and dark web data risk reside on the continuum of risk? How best to mitigate?
What really is the risk and the mitigation?
Put the efforts into prevention.
Put the individual in the driver’s seat of managing the risk that is best managed by them by putting the right tools in their hands.
Perception of the proper allocation of the budget
Businesses must make time for training.
ITSP must include in service catalog what the client is getting in terms of services.
What do we need to do? Cross reference on tools that accomplish outcomes and cover risk mitigation and ensure that the client understands what those are.
Training is how you squeeze the juice out of the orange. Without it you may not get all the juice out of the orange or get any juice out of it at all.
Common business objections to allocating time for training
Payroll costs, but avoiding training is not legally defensible anymore.
The IT Service provider CANNOT alone write policies for you, and they CANNOT approve and enforce your organizational policies.
Technical controls implemented
Automation of technical controls
Reported to the business – It’s YOUR report, your organization.Shared responsibility – some months the CFO does it, some months the CEO does it.Set a schedule and do it. 3 weeks any habit; trainer or partner
Do you look at your P&L and balance sheet every month? You should be understanding the reports from IT.
An interesting lawyer opinion on the topic:
Wednesday 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