Cybersecurity Policy Development - Cyber Compliance and Policies

August 10, 2021

The Cyber Rants Podcast

Episode #38 - The Joy of Cybersecurity Policies!

Nobody loves cybersecurity governance documentation like we do! This week, the guys discuss cybersecurity policies and why the proper policies make all the difference for security, compliance, and audits. Plus, learn what documents are most important, why the "one size fits all" cybersecurity policy templates don't work, and how to build documentation to your exact needs.

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Mike's Headlines:

Interesting news from the feds last week we spoke about

Biden Orders CISA and NIST to Develop Cybersecurity Performance Goals for Critical Infrastructure

This week we learn:

US government agencies are failing to meet even basic cybersecurity standards

Something for all of us to ponder……

RANSOMWARE ACTORS INCREASINGLY TARGETING SMB’S

Potentially good news from the Feds….

CISA Launches US Federal Vulnerability Disclosure Platform

Just some headlines……

Remote Print Server Gives Anyone Windows Admin Privileges on a PC

Microsoft: Watch Out for This 'Sneakier than Usual' Phishing Attack

WordPress Download Manager Plugin Was Affected by Two Flaws

SolarWinds Attackers Breached Email of US Prosecutors, Says Department of Justice

Multiple Vulnerabilities in Google Android OS Could Allow for Remote Code Execution

Hackers Are Using CAPTCHA Techniques to Scam Email Users

Raccoon Stealer Bundles Malware, Propagates Via Google SEO

welcome to the cyber rants podcast where we're all about sharing the forbidden secrets and slightly

embellished truths about corporate cyber security programs we're ranting we're raving and we're

telling you the stuff that nobody talks about on their fancy website and trade show giveaways

all to protect you from cyber criminals and now here's your hosts mike rotondo zach fuller and

lauro chavez hello and welcome to cyber rants podcast this is your co-host zach fuller joined

by lauro chavez and mike rotondo and today we have an incredible topic i think is one that one that

everybody needs but a lot of people hate doing and don't want to talk about but we're going to talk

about it anyway because it's important so we are talking about your cyber security policy library

the documentation that your organization needs to have in place in order to meet compliance

requirements align with frameworks and do all kinds of other great things but before we do that

mike why don't you kick us off with news all right so we've got some interesting news this week and

we're trying not to get political on this one so keep this in mind it's just news but last week

we talked about how biden orders cisa and this to develop cyber security performance goals for

critical infrastructure this week we're hearing that u.s government agencies are failing to meet

even basic cyber security standards according to courts qzd.com the threat of cyber tax has

grown significantly over the past decade but the cyber defenses of key us federal agencies remain

woefully inadequate according to a senate over oversight report published april august 3. while

several of the agencies made minimal improvements in one or more areas inspectors general found

essentially the same failures as the prior 10 years state department's inspector general found

the agency couldn't account for 60 percent of the employees who had access to classified network a

network which the report notes contains data which is to close disclosed to an unauthorized person

could cause grave damage to national security so that's awesome just something for us to all

think about one thing in the news and then i think we've kind of seen this playing out with kasaya

uh ransomware actors increasingly targeting smbs this has been going on for a while this is just

a new thing they're actually targeting with small to medium businesses which possess less than 250

employees and they're doing increasingly targeted grants more actors uh making matters worse is the

ransom fees being demanded to unlock hijack date is also rapidly escalating 450k average to now

1.2 million dollars per incident so i know small businesses you know your budget's on tight but

you really need to invest in that i.t security stuff uh we do have some potentially good news

from the feds the system launches a u.s federal vulnerability disclosure platform this is a

public private partnership kind of thing bug hunters who want to help the u.s federal

government secure their online assets to now source all relevant information from a

vulnerability disclosure policy platform offered by cisa it's through a crowdsourcing platform

called the federal civilian executive branch so check that one out it's a good uh good article

and as usual joe posts the urls with the podcast now we just have some headlines and

a couple microsoft ones remote server print server gives anyone windows admin privileges on a pc it's

an interesting story microsoft watch out for the sneakier than usual fishing phishing attack i'm

sure everybody got notified about this this week uh it's pretty vicious you have wordpress headline

wordpress download manager plugin was affected by two flaws one of them is cve 20 21 34 639

solarwinds attackers breached email of us prosecutors as the department of justice

going back to the feds and their vulnerabilities uh multiple vulnerabilities in google android os

could allow for remote code execution hackers are now using capture techniques to scan email users

and i added this last one in simply because i wanted to say this raccoon stealer bundles

malware propagates via google's seo check out raccoon steeler that's all i got lauro what do

you have for us today nothing as cool as raccoon stealer i mean you know the article's interesting

but i just wanted to say raccoon stealer on a podcast yeah raccoon stealer so i wonder if

he's a mecha raccoon anyways yeah so thanks thanks for that mike uh and and um for bringing up that

wordpress again in the news right so um i won't repeat that one um but i do have a a couple good

exploitables this week that i think uh everybody should be aware of if you're out there using a

product called qdpm it's a free web-based project management software that you can download runs on

php or mysql anyways the current version is 9.2 and there's i don't really know if this is an

exploit versus a misconfiguration but it's been made public that uh all of your connection string

information username passwords for the databases are all stored in a yml file and you can just

essentially directory traverse over to that directory um and download that database yml

file and pretty much have all the passwords to everybody who's using the online site so

um check that out if you're using that that free web-based project management tool qdpm um and

then i've got a remote code execution which is an interesting platform it's called moodle and what

moodle is is it's it's kind of another open source software but it's an online learning management

system so in lms and you can essentially you know make your own learning modules and all this all

this bit well yeah the lat the latest version and the last version both have a remote good execution

um dependent and uh that sits out there on github if anybody wants to test it

i think all the testers know where they'll go get this information that's you know a

lot i think a pretty big open source used for scholastics and education and stuff like that so

if you're using moodle make sure you're checking out which versions you're on and working with the

vendor to get something mitigated in place or at least to know when the next release is now

and that's all i got zach what are we uh what are we talking about this week

well you know we're we're going to try to do the impossible here and make cyber security policy

policies fun i you know i don't know maybe you have some ideas but uh but somehow we're gonna

do this we're gonna pull this off but i think what we need to do first just for the listeners benefit

for those people that are building a formalized cyber security program for the first time

we need to talk about what is in that and and why right so what are what are the core components now

let me preface it with i don't want to go too far in the rabbit hole here because there's

i mean you could have a policy library of hundreds of documents if you really wanted to i don't know

why you would but some organizations that just enormous let's talk about kind of your mid-market

type businesses what they need uh and as far as policies go and why so what are your thoughts on

kind of the you know and and maybe they don't have to be in order but the most critical policies that

you need to have in your document set we'll start there well first off this policies are fun so we

don't really need to make it fun exactly this is probably one of the most fun topics you'll hear us

talk about actually and actually sound secret has a massive cyber security policy library we just

don't force them that's right that's right just because you can doesn't mean you should exactly

kind of like when there used to be encyclopedia salesmen and they you know go door-to-door we

could we could start doing that with our policy library it's pretty equivalent exactly i just i

used to sell the rainbow series door-to-door you know the security series from the 80s

a lot of pocket protector and everything got the floppies out and stuff

knock knock knock have you heard about cyber security the department of defense offers the

rainbow series that talks about slamming my face i think i think the listeners

think you guys are like 400 years old well mike is yeah i'm only 350. sorry

hey so let's put in the probably the most important the most epic the most foundational

of the policy documents that you as a business owner and this and this i guess it doesn't matter

how how large or small you are i think this is kind of one of those foundational policies now

i don't want to get caught up in the name of this because different frameworks may call

it different things but mike um would you say that information security policy is probably the

that first piece to put in place yeah it's kind of the one policy to rule them all right

it's what establishes your framework for your policies and kind of gives you an overall of

what exactly is happening and why so yeah i think i definitely agree with you on that one

yeah and that's important you know as you know call it policy you know zero zero or

even zero one if you if you wish right or a um any something beginning right uh i i think that

you know that that particular policy is going to need to have the foundational language

that empowers leadership to commit to cyber security in the company for daily operations

it provides i think what are enforceable controls or should be enforceable controls in that document

for your organization and then also needs to have some form of change management updating

kind of doctrine and care and all these all these documents well but that first document is going

to give you the baseline for implementing a cybersecurity program and it's going to

hold you to it so you can consider that you know that corporate that policy corporate law almost

you know yeah just as you know if you're gonna you know i know a lot of people

executives should sign off on your policies your board should in theory that's the that's the way

it should work however most most board members and ce level executives are not

going to read a policy library but if they're going to read one policy it should be this one

right yeah yeah i think if everybody has to read one policy it probably should be this one

yeah right i mean if if you have to write one policy this would be the one to write

yeah yeah the policy to rule them all like you said we're gonna get you know throwing the lord

over the rings anywhere we can you know the other one that's key and i know if you're done

or not but the other one that's key is the data classification management policy because you need

to know what you're protecting and you know where your data is you know where your gold is as far as

uh you know your critical data your classified data your compliant data as far as you know ephi

or pci or pii or compliant data you own uh you need to know where it is you need to know where

it's stored and how it's stored so that would be your data classification management you could also

add retention and destruction to that title as well or you could break those out into separate

ones if you're you know feeling chatty want to write a lot so yeah totally we talked about that

i think a couple podcasts ago about not being a data hoarder and understanding where your data is

like very upfront in your business processes or at least as you become aware that you need to

do these things um but you're right mike um you know data classification i think needs to be uh

there even if you're not even if you don't think you're holding any regulatory data you're holding

something you need require you require some form of data for your business function i hope

so i mean there's something there whether it's hr data or anything else that you need for people

power resources anything like that right i mean if you go to your employees birthdays and social

security numbers that's important data right especially to them so you want to secure that so

so we got so we got zero zero one right would be cyber security the information security

policy that would be the foundation and then data classification is going to be going to be two and

like you said you can throw some retention and destruction stuff in there as well um to cover you

know if you feel like riding a bunch or you know break that out we think what do you think three

should be probably get with acceptable use and that just tells your users how what they can do

what they can't do as far as a you know give some guard rails basically for how how to function on a

computer and in your it environment i think that's a good number three yeah yeah no absolutely i i

like to point out acceptable use because it falls into a lot of places like mobile device management

um how the employees you need to manage their remote resources and data and stuff like that

and so um a lot of companies you may you may have some of this language in your handbook already

but i think it's important to if you do not have that in your handbook that you you at

least find a way to get to get this into a separate policy and get get it strengthened

and let your your employees know but you know i i think it certainly is an alternative a handbook is

a good way to get around a good handbook that has adequate language that's enforceable is a

good way to get around having the acceptable use if you don't want to create that yeah and that's a

handbook actually if you're looking at like a sock two or something satisfies a lot of requirements

um and uh it's a good thing to get your hr people to work on with your itd

if they're bound in leather it's even better it's even oh yeah you want to be found stamped um

personalized with each team is lost oh yes absolutely go all out go all out make it fun

you guys are right documentation is fun let's keep talking about this but uh let's take a quick break

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and welcome back we were just talking about cyber security documentation your policy library and we

uh we finished previously at the acceptable use policy and your employee handbook what else what

else can we what else would be next what would be your kind of your fourth fourth document in

order of priority incident response probably and you know you can throw you can throw continuity

and disaster recovery planning and that sort of stuff and that in that document if you want to

yeah although you know sometimes you want to break out ir and dr simply for the size of

the document especially if you do like business continuity and disasters one and then ir because

that's more of a focus a different focus whereas dr and bcp is an enterprise focus so that that

could be an argument for two documents yeah because at some point it becomes a manual

right now the other thing about this document that's important is that it should be the

ir document especially and the dr and bcp documents they do need to be a manual you

should have them stored online but you know one of the things that i love to see in documentation is

all right well having this disaster how do we contact everyone oh we're going to email them

all right well what if email's down oh you know it's kind of like uh no you need to have you know

sharepoint is down you need to have a hard manual for the key players and i think it's important

to have something like that and hard manuals are made for those of you who are younger out of paper

that you print stuff out on them and you uh you read the paper the words on the paper so back in

the early days you used to tie the papers to the pigeon's feet right and you send them off exactly

yeah that was uh email got you and that was part of your party or incident response plan right

exactly yeah issues i mean you know issue everybody pagers no don't do that just just

get everybody to have a phone a phone list that they take home with them we used to make one that

uh would fit on a keychain so it had everybody's telephone number on it in case something happened

broke a phone and email's down an early 90s drug dealer you can get a page

yeah but i mean no i still have one i don't want to admit to that i don't it's in the

box it's a motorola that's terrible that i have i have i also have the iphone one

anyways that i also have the old verizon qwerty flip phone that came out that had the first cordy

fad flip never mind anyways back to documentation incident response right that i think being able to

hold your people in an incident yeah mike you're right um seeing an email address in there is not

is not good enough there's not that's not a viable form of contact if something goes down

yeah now yeah if you're sharing something on slack or you know that's more

i guess it's more viable but i mean really you need to print out everybody's phone number

that's on the emergency response team and you need to get that off to everybody who's on the

emergency response team i'll put it on the fridges everybody still has a refrigerator

you know maybe a smart fridge but it's still magnetic for the most part in some places

yeah don't don't encode it into the smart fridge because then if the fridge goes out then you lost

it too so yeah exactly or the iot you know gets hacked well you know i think one one other thing

to be kind of talk about maybe about this is that you know from a hierarchical perspective

you're gonna put these documents in and um you know you know the first one's going to be the

affirmation security policy it's going to it's going to ground and build a foundation for for

ongoing cyber security operationalized inside of your environment from it's a forever machine right

you open these things they're forever you know they're just doing part time right so you're gonna

that's gonna be all on that that first policy the second one's gonna bring all your data together

let you understand it let you understand how to handle it you're gonna have to put requirements

around it even if it's something like hr data just like you know bob villa you know is working

in the you know shipping department and he you know he's got an account that his his data has

to something has to happen to it when he leaves the company right so you have to figure that out

um acceptable use telling people what to do and then incident response continuity

you know disaster recovery breaking that out and those are those are policies i think

i think what's important to point out is that from a higher perspective if you're going to create

these documents you know you're going to need to expand the library at a minimum i think these four

are going to get you a long way from a from a operationalized cybersecurity perspective but

they're going to require other things and those other things are going to be how you configure

or go forth and build these mechanisms these policies require how do we you know how do we do

data destruction right there has to be some programmatic method that we go through to destroy

data when you know bobila leaves the company right so we need to go and have some form of standard on

you know that program and those may be more in the weeds right that we want to go today

as you mentioned mike but those are going to be foundational documents that are going

to tell the company how we handle these things and i think that's something that the auditors

are going to look forward to right the policies good right but we're going to want to see the how

yeah and one thing i would add to is uh two of the policies i would add just on that fifth one is the

onboarding separation and termination policy just to make sure you clean everything up if someone

leaves i'll brilliant yeah absolutely absolutely i think that's something we don't see enough of

is we see a lot of dormant accounts yeah and you know a lot of its tribal knowledge right or

head knowledge or whatever the correct politically correct term is these days is that you uh you know

we know how to terminate someone who's like great write it down in case you're gone you know in case

you're the one that gets terminated right exactly right somebody else needs to pick up in your place

so that's that's key well there's and i think it's important for the listeners to know right there

these are the fundamental documents that's kind of every organization needs this stuff

but there are a lot more right of course there's things like bring your own device

policies right that's a that's i think a big one that a lot of organization

uh organizations struggle with because so many especially mid market emerging companies so many

so many of them are dealing with a mix of byod and company issue devices any thoughts on that

that policy in particular yeah you got to make one

or is that too much for today am i bringing down the mood no no no no no for a byod policy one

of the things that's key is that you have to define what you are allowed to be why

um because you can't have you know going back we're not going to support iphone ones lauro

sorry solid sector doesn't do that um but you know iphone 10 11 12 or whatever versions we're

on now will support that kind of thing so that needs to be defined in that document

because it still goes back to your data security right you need to determine

you know what devices will be allowed to access our data and hardware and our data and network

applications so it's a key policy there needs to be an approval process attached to it as well now

of course of course we have have um staff right this team members for across the organizations

need to sign off on these things are there are there um key policies that you would

say they need to sign off on versus policies that don't really you know that just kind of

exists for the organization itself for saktu and hipaa there's a policy acknowledgement policy

i'm not kidding so yeah um yeah so that i mean but that can be a sign off in the handbook and

that kind of thing sort of thing but you do need to document that you're having your

you know employees or team members sign off on the fact that they read the policies so

yeah they should read them all i mean it's it's a it's a grueling thing but if you're using

you know some form of programmatic security awareness training you know maybe you can you can

attach those to the end but i think at a minimum the acceptable use policy and the mobile device or

bring bring your own device you know policy right i think those those are going to be critical um

for especially today with everybody working remote where the at least a lot more organizations um you

know allowing that work yeah and then uh you know speaking of working remote this isn't one of the

standard policies but a uh office a home office policy uh should be something that should be

discussed and it should be things like uh you know the cable modem that you have shouldn't be the one

you originally got with when you moved into your apartment or house or whatever that's 10 years

old and never been patched it also shouldn't have your you know phone numbers the password

admin shouldn't be admin you know those sort of things so um setting those standards around the

home office um is important as well yeah we may we need to have a whole separate conversation around

that because you make a huge point because you know there's i think there's a lot of organization

out there that are depending on people bringing their own devices like using their personal

laptops and desktops at home and their their home computing networks and the tools that they have

on their own personal computers to interface with you know the business organization and

you know yeah maybe you'd be using office 365 or you know google workspace or something like that

that doesn't matter if those those individuals aren't forced to patch those machines and

keep up to date with security patches and of course just like you said like the life cycle

you know maybe maybe they're using the operating systems that are no longer supported anymore right

right and so that that has to be enforced some way uh because it starts to become a big mess when you

start to ask to deploy tools on um you know on user endpoint devices like laptops and desktops

but i know you know microsoft's got the new intune tool out there or whatever that's kind of being

um you know kind of a new big thing for for at least mobile phone management with office 365

um i i'll be curious to see how how well it does with you know if they see the

expansion up into the home personalized desktop space there's still a little kind

of crossing a line or you're going to get resistance anyway if someone you know from

your office says well i'm going to put these tools on your personal computer that you own

i don't know maybe maybe it's just me but i'd have a problem with that well it's yeah i mean really

what needs to happen is the the company needs to just issue the device i mean that's that's really

what needs to happen and um you know i know that there's a there's a cost savings and a speed to

design or whatever you're trying to achieve by allowing individuals to bring and use their own

tools from home but you're taking a risk to the data and the organization by you know not having

control over the asset so yeah certainly certainly byod needs to be defined and yeah we can probably

have a whole conversation on that well there are a ton of policies i think we could we could

probably spend hours on all the different stuff that you could have but i think it's important

we covered the fundamentals some of the basics and then and then gave people a taste of kind of

what else is out there long story short you gotta tailor your document set to the organization and

it's not a one size fits all so i think that's where a lot of people stumble is they go online

they download some policy set that's just kind of a you know a half-baked approach but hasn't the

thought behind it hasn't really really been put into it for their specific organization and then

they go through an audit or something and get get smashed so um lots of stories around this like

uh that we could go into for sure about you know malicious employees and companies that didn't sign

policies and the company has no recourse all kinds of stuff but we're coming up on time so that said

any final words of wisdom before we jump off well definitely uh personalize your policies and maybe

make them make them fit what you actually do i can't tell you how many times i go and do

an audit on hipaa or sock two or whatever you know even just the cso work that i say are you actually

doing this and i get someone saying no i don't really know what that is but we you know needed

it for the policy or the policy we downloaded had it um you know that's generally an automatic fail

so just keep that in mind that you do need to personalize these not just from an audit

perspective but you know the majority of companies that fail that have policies in place are the ones

that download these policies and then never never implement them or clean them up or personalize

them you got to be invested in them if you're a company as we talked about earlier ransomware

is attacking smbs and it's up to 1.2 million is the average cost now for ransomware on a small

company they're not having mercy on you anymore yeah no you know so take the time to define

the controls that you can do today you don't have to like mike said you know you you need to reflect

what it is that you're you're actually doing at an operational perspective right in the document

so if you're if you're not conducting internal risk assessments you don't need to say that

you're doing that um you need to you need to make sure that you describe what you do

but you also need to you know that maybe that'll help you understand what you're missing as well

you can always add to those documents they're living documents and and they have change tables

for a reason if something changes in the business it needs to change in the document so you know

and invest that time to to manufacture those items and what you write is what you need to

you know buy by the i guess by the governing sense of corporate law if you write the policy

that you do something you need to do it you need to be able to do it or perform it

or have a method to very quickly be able to work towards that goal right in a short amount of time

so don't say if you can't do it if you put in the policy and you're putting these in and you

can't do this stuff within the next you know two to three months it doesn't need to be in there um

so you know put what you can do um everything in there needs to be an enforceable control and

remember that you you write the essentially the defense that you put around yourself right so

you get described out of the document so it's a they're that's why they're fun to us because they

are extremely important they're pivotal they're they're the the actual substrate from which

cyber security programs grow so they're extremely important in what you put the language you use to

put in them is very important and so take that time to do it and once you've done it they're

easy to manage i think that that over the hurdle but custom tailored to your org you know you guys

were right policies are fun so i had fun oh the listener said fine but i i think we should do

another five to 15 episodes on policies and standards and i'm sure we there's there's a

lot more to uncover here a lot more to unpack but excellent points and to everybody listening i mean

it's something that you just just have to do in today's day and age it's just that's that's the

price of using technology and technology has been cheap for a long long time relatively speaking

to its benefits but um these types of things are we're seeing they have to go into place right the

investments have to be made in order to continue using technology it's just part of business now

so um i hope this was valuable for everybody listening if you like the podcast uh by all

means please subscribe on your favorite podcast platform uh reach out cyberrantspodcast.com

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Episode #38 - The Joy of Cybersecurity Policies!

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