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A Breach Carol
2013 Recap, 2014 Predictions
Agenda
• Introductions

• Ghosts of Security & Privacy Past
• Ghosts of Security & Privacy Future
• Q&A

Page 2
Introductions: Today’s Cast

Ted Julian, Chief Marketing Officer,
Co3 Systems

Ebenezer Scrooge, Chief Financial
Officer, Acme Inc.

Gant Redmon, General Counsel,
Co3 Systems

Bob Cratchit, Chief Privacy Officer,
Acme Inc.

“Tiny” Tim Armstrong, Incident
Response Specialist, Co3 Systems

Tiny Tim, Chief Security Officer,
Acme Inc

Page 3
Co3’s Incident Response Management Platform
Automated Escalation
Accelerate response by easily
creating incidents from the systems
you already have

Industry
Standard
Frameworks

Organizational
SOPs

Global
Privacy Breach
Regulations

Community
Best
Practices

Web Form

Trouble Ticketing

IR Plan

Entry Wizard

SIEM

Instant Creation and
Streamlined Collaboration
IR plans created instantly based on
regulations, best practices, and standard
operating procedure. Collaborate on plan
execution across multiple functions

Contractual
Requirements

Intelligent Correlation

IT

Legal &
Compliance

Marketing

HR

Determine related incidents
automatically to identify broader,
concerted attacks

Integrated Intelligence
Gain valuable threat intelligence
instantly from multiple intelligence feeds

Accelerated Mitigation
Speed results by easily outputting results to your
management platforms
Page 4
Trouble Ticketing

SIEM

GRC

DASHBOARDS & REPORTING

SSAE 16 TYPE II CERTIFIED
HOSTING FACILITY

Email
Prologue
• Where: Acme Inc. HQ, Ebenezer Scrooge’s office
• Who: Ebenezer, Bob, and Tiny Tim
• What: 2014 Budget Review
Bob & Tim asked for modest budget increases. Scrooge
ordered them to return tomorrow (Christmas Eve) with a
plan that showed a 15% reduction.
Bob & Tim drowned their sorrows in egg nog at the
company holiday party. Ebenezer humbugged and went
home early.

Page 5
That night…
Scrooge is visited by the ghost of Jacob Marley, the
deceased former CFO of Acme. Marley tells Scrooge he’ll
be visited by two set of ghosts, the first are…

The Ghosts of
Security &
Privacy Past
Page 6
Security Past
• Snowden
• More use of encryption inside companies who possess
large amounts of data
• Lack of gov’t collaboration
• Increased amount of vigilante-style behavior (AJ)
• Adobe
• Security success story
• Even big guys get breached
• Silversky
• Malware as a business has been heating up
• More competition between malware “vendors”
Page 7
Security Past
• Breach Data
• VZ DBIR
• 92% of threat actors are external
• Collecting and sharing IOC’s and threat data leads to
increased response times
• 69% of breaches discovered by external parties
• 66% took months to discover

Page 8
Privacy Past
• Bloating of the privacy policy and Ts&Cs
• Paypal’s terms longer than Hamlet
• Privacy policies almost as long and are integrated into
Ts&Cs
• David Vladeck, former Director of the Bureau of Consumer
Protection of the Federal Trade Commission, was no fan
• Rule of thumb – longer they are, the less privacy you have

Page 9
Privacy Past
• Apps take on a bigger roll
• -FTC Mobile Privacy Disclosures report says the FTC
wants "timely, easy-to-understand disclosures about what
data they collect and how the data is used."
• FTC action against Path, Inc.
• California Attorney General’s Privacy Enforcement and
Protection Unit has prepared Privacy on the Go:
Recommendations for the Mobile Ecosystem.

Page 10
Privacy Past
• Snowden hands the EU a bat to beat the US cloud providers
- Safe harbor in dangerous waters
• This year saw three phases of the EU leveraging the
Snowden affair: Call for EU clouds, call for the end of Safe
Harbor, and finally the 13 recommendation for Safe Harbor
set forth by the European Commission.
• One of the recommendations looks like a cigarettewarning label.

Page 11
Privacy Past
• Executive Order
• February 2013, President Obama issued Executive Order
13636, Improving Critical Infrastructure Cybersecurity
instructing NIST to lead the development of a framework
to reduce cyber risks to critical infrastructure.
• Fell short of Congressional action providing a litigation
shield to companies sharing attack information with the US
Government. No one seems to want to make it easier for
companies to share info with the government these days.

Page 12
Privacy Past
• HIPAA Final Rule
• When it comes to breach response, the two big stories are
business associates having direct reporting and
notification responsibilities and breaches assumed to have
caused harm.
• As for harm, now we have to dig our way out of a breach
with a risk assessment.

Page 13
Privacy Past

Page 14
POLL
Later That Night…

Scrooge receives another paranormal visit…

The Ghosts of
Security &
Privacy Future
Page 16
Security Future
• More breaches, more severe
• The rise of Breach as a Service
• CSO at a major enterprise is canned
• Tiny Tim: cost argument to CFO re: before v after
• The cost of a breach usually dwarfs that of training and tech
• Breaches impact more diverse verticals
• Moving away from mass malware to more industrial espionage
• Healthcare increases as a target
• Deadline for electronic patient records
• Mobile?
• Data leakage, apps with ad networks that leak
• Fed mandate for minimum security requirements (ex. NIST IR for critical infrastructure)
• Other verticals follow
• More certifications for hosting (like FedRAMP) and personnel

Page 17
Security Future
• IR disaster done right – Tylenol case study? Let’s say this doesn’t happen.
• the company pulled 31 million bottles of tablets back from retailers, making it
one of the first major recalls in American history. The crisis cost the company
more than $100 million, but Tylenol regained 100% of the market share it had
before the crisis. - Wikipedia
• Snowden fallout from a security perspective
• Lack of trust/sharing
• Industry hides from gov’t, over-encrypts data on internal as well as external
networks
• Rise of “NSA-proof” tech - AJ
• Model for best-of-breed IR begins to emerge: people, process, technology
• Long term strategy starts to develop based on awareness of danger
• IR professional services take off

Page 18
Privacy Future
• Unified Breach Notice
• US – No, maybe one more swing
• EU – Yes
• On October 21, 2013, the European Parliament
approved its compromise text of the Draft Regulation to
replace Directive 95/46/EC.
• Next comes approval by the Council of Ministers.
• Then the Parliament, the Council and the Commission
must agree on the final text. A vote is expected before
the parliamentary elections in May 2014.
• Worked for telcos
Page 19
Privacy Future
• Safe Harbor Alive and Well – The 13 Principles from the
European Commission are not too specific or onerous.

Page 20
Privacy Future
• Usernames and passwords
• May the country follow California…again
• S.B. 46, which amends Sections 1798.29 and 1798.82 of
the Civil Code to require businesses and state agencies to
notify consumers if their login credentials are
compromised by a data breach

Page 21
Privacy Future
• Greater personal awareness and responsibility
• Cybermilitia: A Citizen Strategy to Fight, Win, and End
War in Cyberspace
• Authors Siobhan MacDermott and J.R. Smith

Page 22
POLL
The Next Day

Bob & Tiny Tim head to Scrooge’s
office with their slashed budget
proposals.
They’re shocked when a
thoroughly changed Scrooge
awards them a 100% increase!

Page 24
QUESTIONS
Happy Holidays!
“Co3 Systems makes the process of planning for a
nightmare scenario as painless as possible,
making it an Editors’ Choice.”
PC MAGAZINE, EDITOR’S CHOICE

“One of the hottest products at RSA…”
NETWORK WORLD – FEBRUARY 2013

One Alewife Center, Suite 450
Cambridge, MA 02140
PHONE 617.206.3900
WWW.CO3SYS.COM

“Co3…defines what software packages for
privacy look like.”
GARTNER

“Platform is comprehensive, user friendly, and
very well designed.”
PONEMON INSTITUTE

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A Breach Carol: 2013 Review, 2014 Predictions

  • 1. A Breach Carol 2013 Recap, 2014 Predictions
  • 2. Agenda • Introductions • Ghosts of Security & Privacy Past • Ghosts of Security & Privacy Future • Q&A Page 2
  • 3. Introductions: Today’s Cast Ted Julian, Chief Marketing Officer, Co3 Systems Ebenezer Scrooge, Chief Financial Officer, Acme Inc. Gant Redmon, General Counsel, Co3 Systems Bob Cratchit, Chief Privacy Officer, Acme Inc. “Tiny” Tim Armstrong, Incident Response Specialist, Co3 Systems Tiny Tim, Chief Security Officer, Acme Inc Page 3
  • 4. Co3’s Incident Response Management Platform Automated Escalation Accelerate response by easily creating incidents from the systems you already have Industry Standard Frameworks Organizational SOPs Global Privacy Breach Regulations Community Best Practices Web Form Trouble Ticketing IR Plan Entry Wizard SIEM Instant Creation and Streamlined Collaboration IR plans created instantly based on regulations, best practices, and standard operating procedure. Collaborate on plan execution across multiple functions Contractual Requirements Intelligent Correlation IT Legal & Compliance Marketing HR Determine related incidents automatically to identify broader, concerted attacks Integrated Intelligence Gain valuable threat intelligence instantly from multiple intelligence feeds Accelerated Mitigation Speed results by easily outputting results to your management platforms Page 4 Trouble Ticketing SIEM GRC DASHBOARDS & REPORTING SSAE 16 TYPE II CERTIFIED HOSTING FACILITY Email
  • 5. Prologue • Where: Acme Inc. HQ, Ebenezer Scrooge’s office • Who: Ebenezer, Bob, and Tiny Tim • What: 2014 Budget Review Bob & Tim asked for modest budget increases. Scrooge ordered them to return tomorrow (Christmas Eve) with a plan that showed a 15% reduction. Bob & Tim drowned their sorrows in egg nog at the company holiday party. Ebenezer humbugged and went home early. Page 5
  • 6. That night… Scrooge is visited by the ghost of Jacob Marley, the deceased former CFO of Acme. Marley tells Scrooge he’ll be visited by two set of ghosts, the first are… The Ghosts of Security & Privacy Past Page 6
  • 7. Security Past • Snowden • More use of encryption inside companies who possess large amounts of data • Lack of gov’t collaboration • Increased amount of vigilante-style behavior (AJ) • Adobe • Security success story • Even big guys get breached • Silversky • Malware as a business has been heating up • More competition between malware “vendors” Page 7
  • 8. Security Past • Breach Data • VZ DBIR • 92% of threat actors are external • Collecting and sharing IOC’s and threat data leads to increased response times • 69% of breaches discovered by external parties • 66% took months to discover Page 8
  • 9. Privacy Past • Bloating of the privacy policy and Ts&Cs • Paypal’s terms longer than Hamlet • Privacy policies almost as long and are integrated into Ts&Cs • David Vladeck, former Director of the Bureau of Consumer Protection of the Federal Trade Commission, was no fan • Rule of thumb – longer they are, the less privacy you have Page 9
  • 10. Privacy Past • Apps take on a bigger roll • -FTC Mobile Privacy Disclosures report says the FTC wants "timely, easy-to-understand disclosures about what data they collect and how the data is used." • FTC action against Path, Inc. • California Attorney General’s Privacy Enforcement and Protection Unit has prepared Privacy on the Go: Recommendations for the Mobile Ecosystem. Page 10
  • 11. Privacy Past • Snowden hands the EU a bat to beat the US cloud providers - Safe harbor in dangerous waters • This year saw three phases of the EU leveraging the Snowden affair: Call for EU clouds, call for the end of Safe Harbor, and finally the 13 recommendation for Safe Harbor set forth by the European Commission. • One of the recommendations looks like a cigarettewarning label. Page 11
  • 12. Privacy Past • Executive Order • February 2013, President Obama issued Executive Order 13636, Improving Critical Infrastructure Cybersecurity instructing NIST to lead the development of a framework to reduce cyber risks to critical infrastructure. • Fell short of Congressional action providing a litigation shield to companies sharing attack information with the US Government. No one seems to want to make it easier for companies to share info with the government these days. Page 12
  • 13. Privacy Past • HIPAA Final Rule • When it comes to breach response, the two big stories are business associates having direct reporting and notification responsibilities and breaches assumed to have caused harm. • As for harm, now we have to dig our way out of a breach with a risk assessment. Page 13
  • 15. POLL
  • 16. Later That Night… Scrooge receives another paranormal visit… The Ghosts of Security & Privacy Future Page 16
  • 17. Security Future • More breaches, more severe • The rise of Breach as a Service • CSO at a major enterprise is canned • Tiny Tim: cost argument to CFO re: before v after • The cost of a breach usually dwarfs that of training and tech • Breaches impact more diverse verticals • Moving away from mass malware to more industrial espionage • Healthcare increases as a target • Deadline for electronic patient records • Mobile? • Data leakage, apps with ad networks that leak • Fed mandate for minimum security requirements (ex. NIST IR for critical infrastructure) • Other verticals follow • More certifications for hosting (like FedRAMP) and personnel Page 17
  • 18. Security Future • IR disaster done right – Tylenol case study? Let’s say this doesn’t happen. • the company pulled 31 million bottles of tablets back from retailers, making it one of the first major recalls in American history. The crisis cost the company more than $100 million, but Tylenol regained 100% of the market share it had before the crisis. - Wikipedia • Snowden fallout from a security perspective • Lack of trust/sharing • Industry hides from gov’t, over-encrypts data on internal as well as external networks • Rise of “NSA-proof” tech - AJ • Model for best-of-breed IR begins to emerge: people, process, technology • Long term strategy starts to develop based on awareness of danger • IR professional services take off Page 18
  • 19. Privacy Future • Unified Breach Notice • US – No, maybe one more swing • EU – Yes • On October 21, 2013, the European Parliament approved its compromise text of the Draft Regulation to replace Directive 95/46/EC. • Next comes approval by the Council of Ministers. • Then the Parliament, the Council and the Commission must agree on the final text. A vote is expected before the parliamentary elections in May 2014. • Worked for telcos Page 19
  • 20. Privacy Future • Safe Harbor Alive and Well – The 13 Principles from the European Commission are not too specific or onerous. Page 20
  • 21. Privacy Future • Usernames and passwords • May the country follow California…again • S.B. 46, which amends Sections 1798.29 and 1798.82 of the Civil Code to require businesses and state agencies to notify consumers if their login credentials are compromised by a data breach Page 21
  • 22. Privacy Future • Greater personal awareness and responsibility • Cybermilitia: A Citizen Strategy to Fight, Win, and End War in Cyberspace • Authors Siobhan MacDermott and J.R. Smith Page 22
  • 23. POLL
  • 24. The Next Day Bob & Tiny Tim head to Scrooge’s office with their slashed budget proposals. They’re shocked when a thoroughly changed Scrooge awards them a 100% increase! Page 24
  • 27. “Co3 Systems makes the process of planning for a nightmare scenario as painless as possible, making it an Editors’ Choice.” PC MAGAZINE, EDITOR’S CHOICE “One of the hottest products at RSA…” NETWORK WORLD – FEBRUARY 2013 One Alewife Center, Suite 450 Cambridge, MA 02140 PHONE 617.206.3900 WWW.CO3SYS.COM “Co3…defines what software packages for privacy look like.” GARTNER “Platform is comprehensive, user friendly, and very well designed.” PONEMON INSTITUTE