You are no doubt familiar with the recent significant compromise of SolarWinds Orion, a prolific IT system used to perform critical IT security and performance monitoring functions. Of course, SolarWinds was just one of five significant breach or compromise events in the security vendor space recently. The other four:
A troubling aspect of the SolarWinds breach is that the extent of its proliferation may never be known. US-CERT is still dropping updates and analysis of the intrusions. It was propagated via the standard SolarWinds software update process, and the malware enabled multiple attack types for threat-actors, throughout the supply chain.
When was the last time you questioned the security of vendor patching and updates? Unfortunately, it is time to update that little-examined sense of trust and convert it into risk intelligence.
These breaches highlight at least two important considerations for today’s organizations as they outsource more core business functions to third-party vendors:
The short answer to the first: If your Defense in Depth control layers are well implemented and your patch management program is sound, you should have adequate protection to remain safe while you decide what to do about the specific vendor that suffered a failure. If the failure was not severe enough to warrant a change, at least it should trigger a deeper dive into that vendor’s operations. If it is an event of such severity that it makes change necessary, there are multiple vendors in the security space, at each layer of defense, and replacing one is not likely to have significant impact on customers or business operations.
But let us take a step back and focus on the larger picture of third-party service provider management: If your due diligence process and larger vendor management program have not undergone some evolution over last 5 years, then you are overdue for a review.
A chief aspect of that review is to determine if we know enough about the Software Development Lifecycle (SDLC) of our critical vendors, and especially those hosting our core business functions and providing one or more security functions. To learn what needs your attention, and what questions to ask, click here to download Monarch’s free Guide to Vendor SDLC Due Diligence.
We have seen 3rd party due diligence processes mature rapidly over the past 6 years for clients in financial services. This is because after Target, which was caused by a vendor compromise, the FFIEC issued guidance directing banks to pay much closer attention to service providers. We should all move third-party risk management up the priority order in our information / cyber security programs. Our change management practices will also have to evolve. We need a clearer understanding of our systems’ normative behaviors so we can more readily identify anomalous activity during the testing phase of our patching and updating processes.
When upgrades/updates/patches are significant, consider a more robust testing regimen prior to roll-out. Consider the following when making changes:
These events can merely remind us that everyone is vulnerable to the right attack by the right perpetrator; or they can motivate us to go beyond the conceit. That means creating and sustaining quality protections across the layers of preventative and detective controls in our environment. Finally, we need to assess when we should be segregating security layers, such as security testing and security monitoring, for instance, to ensure we have inter-vendor oversight that is an organic aspect of our careful strategic security design.
Vigilance is required because cybercriminals are innovative. They have demonstrated they know how to continue to win with old techniques as well as develop and use new strategies and techniques to stay at least one step ahead. Getting to know our vendors better is incumbent upon us, to put our efforts where we know they will identify and reduce risks we face, every day.
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V-ISO is our most engaged and complete service offering at Monarch ISC. You select the components, and we execute an annualized program acting as an outsourced member of your internal team.
This package may include everything we offer, or any of several sets of core program components. We bundle your choices, provide privileged pricing, and schedule our year together to build the program foundations. Once the foundations are built, we move into Sustainability Mode, still providing whatever level of engagement you choose.
What’s included?
Our highly effective policies and plans are currently in-force at banks, credit unions, healthcare facilities, and DoD contractors. Our careful iterative process ensures your organization is understood before the writing begins. Your policies and plans need to express actual practices, not some templatized check-box fantasy that bears little resemblance to your unique organization.
We will work with you to create a new Information Security Program, or dramatically improve your existing program or any component to include:
Monarch ISC Information Security Program documents have undergone two-decades of regulatory and audit scrutiny, passed every test, and set the standard. They are the bedrock on which you will build your information security program.
People are your weakest link. We deliver effective training to any organizational group to strengthen the whole chain, from end-users, to IT Professionals, to Board of Directors, and every level in-between. Everyone must gain awareness and develop the skills needed in their roles to make an organization resilient to adverse events and incidents.
Our live instructor-led training sessions:
Engage us to follow-up the training with phishing email test campaigns to measure the effectiveness of our training too! We’re confident you’ll see results!
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You made sure your Electronic Medical Record (EMR) system was HIPAA-compliant. Did you know that is just the first step in making your practice HIPAA-compliant?
You take great care of your patients, and you know that means taking great care of your patients’ sensitive personal data, too. But complying with the federal Health Insurance Portability and Accountability Act (HIPAA) can be as complicated as some of the things you learned in medical school.
Monarch Information Security Consulting understands what the law demands of you and your practice, can evaluate what you need to do to meet those expectations, and will create a customized and easy-to-understand plan for you to achieve complete HIPAA compliance and get back to caring for your patients with confidence.
Our consultants have over 40 years of experience in identifying, evaluating, and remediating HIPAA compliance. We take the time to get to know you and your organization, and we create a comprehensive map of your entire data flow. We pinpoint your vulnerabilities and infractions, we provide a smart, straightforward plan to achieve sustainable, HIPAA compliant data security, and we stand by you and our work in the event of an audit.
The FFIEC Cybersecurity Assessment Tool measures the maturity of your financial institution’s information security program. The tool helps define your current inherent risk profile and assess your compliance status across the security domains.
It can be a daunting exercise to complete.
We can help!
Our experts work with your team to complete the assessment and document any gaps in compliance. We will build a timeline for remediation, and can assist with training, risk assessments, policy building, business continuity exercises, board reporting, and more. Our work will fill the gaps and increase your maturity level.
The Cybersecurity Maturity Model Certification (CMMC) has been released!
The certification will be required for all Department of Defense contractors AND sub-contractors. Audits will begin in 2020. The audit timelines and the list of approved auditors have not been released.
Special Note: DoD Guidance for self-assessment scoring has been updated! You will need to provide your self-assessment (Basic) of the NIST 800-171 guidance to the Supplier Performance Risk System (SPRS). The system is online NOW! Do you know your score?
NOW is the time to start the certification process, so contact us for a free consultation.
For many organizations this is a strange new world. Data security requirements have been in place for banks, merchants accepting credit cards, and healthcare organizations, but never have manufacturers and other government contractors with unclassified information faced this type of scrutiny.
This can be an overwhelming amount of work.
The certification domains cover a wide variety of topics from Asset Management to System and Information Integrity. You will need to implement the correct controls, write the appropriate policies, and keep track of your compliance activities in preparation of an audit. Failure to be certified will mean thousands, or millions, of dollars in lost government contracts.
Monarch ISC can help.