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.
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 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?
Wednesday Nov 30, 2022
Wednesday Nov 30, 2022
Recent question I got:
What are the major changes that you have seen from security auditors in recent years and/or where do you see the audit process heading?
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.
Friday Oct 28, 2022
Friday Oct 28, 2022
What is information security versus cybersecurity?
What are policies and why do we care?
Isn't that IT's problem?
Examples to learn from
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.
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.