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Cybersecurity

What are Internal Control Weaknesses?

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A control weakness is a failure in the implementation or effectiveness of internal controls. Malicious actors can leverage internal control weakness to circumvent even the most robust security measures. The wide range of internal controls, countless new technologies, and the rate at which malware evolves necessitate monitoring of data security controls. Regularly monitoring allows organizations to test the effectiveness of their internal controls and expose weaknesses in their implementation-before bad actors can exploit them.

What are Data Security Controls?

Data security controls keep sensitive information safe and act as a countermeasure against unauthorized access. They enable risk management programs by counteracting, detecting, minimizing, or avoiding security risks to computer systems, data, software, and networks.

They include technical controls as well as operational, administrative, and architectural controls. These controls can be preventative, detective, corrective, or compensatory.

Effective internal controls protect your organization by providing reliable financial reporting, as required by various regulations and industry standards governing investment, capital, and credit risks. For example, section 404 of the Sarbanes-Oxley Act of 2002 (SOX) requires annual proof that companies accurately report financial statements and that their procedures ensure effective fraud prevention, as well as demonstration that they have addressed any uncertainty, such as stocks.

What are Technical Control Weaknesses?

Technical security controls focus on hardware and software. Weaknesses in technical controls stem from changes in technology and maintenance or configuration failures. In 2014, the “heartbleed” vulnerability exploited a technical control weakness in SSL to expose data, resulting in a rush of emergency patching.

What are Operational Control Weaknesses?

Operational security (OPSEC) focuses on monitoring operations and enforcing a risk management program. Operational control weaknesses stem from the human factor. When those conducting operations fail to follow established standards and policies, operational controls are weakened.

Incident response is a time-sensitive operational control. It is most effective with rapid intervention. As the interval between the incident and intervention increases, the effectiveness of incident response is exponentially reduced.

What are Administrative Control Weaknesses?

Administrative security controls are also referred to as procedural controls. Failure in daily operations to adhere consistently to established standards or regulations results in administrative control weaknesses. For example, a regularly-scheduled backup routine is an important procedural control related to disaster recovery. Failing to test the integrity and viability of backups exposes the organization to the risk of media degradation, which can have a negative impact on recovery ability or create material weakness following catastrophic events or human error.

What are Architectural Control Weaknesses?

Security architecture focuses on creating a unified design that documents and addresses the risks across an organization’s integrated information technology environment. A weakness in either design or documentation damages the foundation of an organization’s security structure. Unexpected hardware replacement is at high risk for architectural control weakness, due to circumvention of the normal change management process. The urgent nature of these replacements creates the potential for configuration irregularities, missed patches, or other implementation oversights.

How does Risk Management Support Internal Controls?

The core values of governance, risk, and compliance (GRC) focus on defining risks so that your organization can comply with standards or regulations, while continuously monitoring to ensure the processes work. Effective corporate risk management involves creating a structure to support the procedures that protect resources and assets.

Risk management is not a set-and-forget process. Established controls must evolve as the threat landscape evolves. Malicious actors modify their tactics regularly. Maintaining peak effectiveness requires periodic risk reassessment throughout the information system’s life cycle.

Why Organizations Need to Continuously Monitor Their Controls

Continuous monitoring incorporates machine learning tools to provide real-time insights into new vulnerabilities and threats facing your information systems. Although malicious actors regularly modify malware and ransomware to avoid detection, continuous monitoring enables management to respond to threats.

Effective monitoring of internal controls requires integrating internal audit and ongoing activities to ensure that the organization embedded safeguards within normal operations. This harmonizing of detective and preventive measures helps internal analysts review effectiveness. With that information, the audit committee can regularly update the Board of Directors with reports and reviews, to ensure that current information both aligns with and informs strategic decisions.

How Automation Eases the Burden of Continuous Monitoring

As organizations grow, they increase the number of internal controls they need to monitor. Technology use increases the overlap between different types of controls. For example, operational risk now becomes an IT risk. Before computers, an employee accessing hard copies of sensitive information was simply an operational risk because that meant the business did not follow employee internal control procedures. Cloud migration now makes unauthorized access an IT risk as well as an operational risk.

Information systems continue to scale, mirroring businesses’ expanding footprints. Organizations that attempt to rely on manual monitoring face the daunting and expensive task of hiring and training staff. With a shortage of experienced professionals in the field, this constant increase is both cost-prohibitive and reactionary. The result of manual monitoring is an organization with an out-of-date security program that falls behind and eventually becomes a victim of an attack.

Continuous monitoring systems that utilize machine learning and automation allow organizations to keep pace with the integration of new technologies, increased number of internal controls, and the ever-evolving threat landscape.

How ZenGRC Enables Corporate Data Security Control Monitoring

ZenGRC allows you to prioritize tasks so that everyone knows what to do and when to do it. Teams can more rapidly review the “to do” lists and “completed tasks” lists, understanding at a glance current task status.

With our workflow tagging, you can assign tasks to the individuals in your organization responsible for the activities involved in risk assessment, risk analysis, and risk mitigation.

Finally, with our audit trail capabilities, you can document remediation activities to prove that you maintained data confidentiality, integrity, and availability as required by law.

For more information about how ZenGRC can streamline your GRC process, contact us for a demo today.

How to Audit Governance

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Governance, risk, and compliance (GRC) have become buzzwords in cybersecurity. As governments and industry standards organizations respond to the data breach landscape by creating new compliance requirements, governance has become fundamental to creating an effective risk management program. Auditing governance requires organizations to communicate with internal and external stakeholders.

Auditing Governance

What is corporate governance?

To prove governance, companies need to establish rules, practices, and processes.  Even more critical, governance places responsibility on senior management and the Board of Directors to review risk knowledgeably.

What is corporate governance in cybersecurity?

In cybersecurity, corporate governance shifts slightly. While senior-level executives and the Board do not make the security decisions, they need to understand the cybersecurity risks that may arise from business objectives.

Additionally, cybersecurity governance requires reviewing the effectiveness of internal controls.

What is the audit committee’s responsibility?

As cybersecurity compliance increasingly becomes a focus for many companies the audit committee acts as the bridge between the audit program and the Board of Directors.

Thus, while the audit committee members may not need to be technical, they do need to understand cyber risk more than others within the organization. To engage in more detailed conversations, the audit committee needs to incorporate the information technology (IT) leaders within the organization.

How to incorporate cyber risk as part of the audit plan

As companies increase their use of Infrastructure-as-a-Service (IaaS), Platform-as-a-Service (PaaS), and Software-as-a-Service (SaaS) vendors, their audit plans need to address the internal controls that protect from data breaches. Audit plans focus on how you determine key performance indicators (KPIs) for your compliance program. Thus, creating a cybersecurity audit plan becomes the roadmap for how you establish and prove governance.

Timing

Planning for internal audits should be a continuous process. Before setting out an audit plan, you need to review your previous audits for control deficiencies. Then, you can determine the scope.

For example, if your company lacked appropriate software and operating system patch management, then that needs to be considered as part of the scope for the next audit. However, if patching was excellent, but your previous audit found that several systems or networks retained their factory-preset logins, then you should focus on that.

In short, timing and planning should be a continuous process based on consistent improvements to your cybersecurity oversight.

Risk Assessment

Any audit plan needs to incorporate a holistic view of cybersecurity risk.

When creating an audit plan, you need to ensure that you have established a risk tolerance that incorporates data, location, data breach potential, and potential data breach cost.

When determining the audit plan scope, you need to focus on the information assets with the highest risk.

Compliance Committee

A compliance committee includes internal stakeholders who monitor and document internal controls.

The compliance committee, in conjunction with the audit committee, works to keep the company aligned with changes to standards and regulations. As such, they stand as the first line of defense for working to keep controls effective and provide governance over the program.

How internal auditors review cybersecurity governance

The audit plan sets out the scope and contains the needed steps for proving governance. Your internal audit acts as a second-set-of-eyes.

Internal auditing requires an independent individual to review and assess whether your cybersecurity program meets industry standard and regulatory compliance requirements. The internal auditor considers all the documentation related to your cybersecurity compliance program and then tests whether you maintained compliance with the internal controls defined.

In terms of governance, the internal auditor will review not only the controls defined by policies and processes but will also examine whether the compliance committee reports to the audit committee. For example, the internal auditor may review the compliance committee and audit committee meeting notes to ensure that the two teams are communicating risk and monitoring effectively. Then, the auditor will compare those notes to the Board meeting notes to ensure that the information flows through all stakeholders.

In essence, documenting communications and activities provides the proof auditors need to audit governance over the cybersecurity program.

How to use automation to ease auditing governance

Automation facilitates internal auditing of governance by enabling stronger communication and documentation.

Depending on the organization’s size, coordinating communication across the compliance committee, audit committee, and Board of Directors can become burdensome. Moreover, best practices also suggest that audit committee materials include executive summaries needed for identifying risks, issues, and next steps.

Thus, automation provides a way to streamline the governance auditing process. Shared drives can ease some of the communications burdens. Unfortunately, shared drives update any changes automatically which makes finding historical documentation time-consuming. The automatic updates also limit the information’s integrity since anyone with access can make changes, undermining governance.

Thus, organizations need a single-source-of-information that allows them to not only document their compliance activities but provide control over who can edit and change documents.

How ZenGRC enable auditing governance

ZenGRC’s System-of-Record makes continuous auditing and reporting easy. By streamlining the workflow, organizations can eliminate emails while tracing outstanding tasks. Additionally, the unified control management feature allows organizations to map controls across multiple frameworks, standards, and regulations to determine whether compliance gaps exist. This mapping capability enables organizations to ensure consistency that leads to stronger audit outcomes.

For example, as part of the System-of-Record dashboard, organizations have at-a-glance insight into the percentage of controls finalized and a portion of controls mapped to a particular framework.

ZenGRC’s streamlined workflow shows task managers the date on which a vendor provided a response and a status. These details mean that compliance managers no longer need to spend time following up with the organization’s multitudinous vendors.

GRC automation enables organizations to focus on the fundamental issues of compliance while eliminating the tedious tasks that often make compliance feel like a burden. Not only does this help compliance officers feel more effective at their jobs, but it also makes organizations more efficient at the ongoing task of governance and continuous monitoring.

For more information about how ZenGRC can streamline your GRC process, contact us for a demo today.

How to Build a Compliance Program

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As data breach threats increase, governments and industry standards organizations seek to force organizations into maintaining better data security controls. Thus, creating an effective compliance program has become a business operations imperative rather than a series of “best practices.”

Why Companies Need to Establish a Compliance Officer and Compliance Team

The compliance officer is the captain of the compliance program. She reviews the relevant laws and industry standards on a continuous basis to ensure that you maintain the appropriate controls.

However, the company also needs to create a team of internal stakeholders including the Board of Directors and c-suite. To ensure appropriate program oversight, the company must ensure that the primary decision-makers understand and review all compliance efforts.

Why Creating a Risk Management Program Fosters Compliance

Risk management acts as the foundation of a mature compliance program. Organizations need to engage in the risk identification, assessment, analysis, and tolerance process to appropriately protect themselves from the fines and penalties associated with compliance violations, such as regulatory sentencing guidelines.
If an organization chooses to accept a risk, it must prove that it has created mitigation strategies, such as internal controls, to reduce risk.

Why an Organization Needs to Adopt Written Policies, Procedures, and Processes

Written policies, procedures, and processes provide documentation proving the organization’s governance. They establish the internal controls that the organization’s stakeholders use to mitigate risks.
These controls become the playbook for guiding the rest of the program. Therefore, the company needs to make sure that all stakeholders not only engage in the process but understand all the elements necessary to maintain the controls.

Why A Compliance Program Needs an Audit Program

In cybersecurity, the motto is “trust but verify.” Establishing an audit program, with both internal and external auditors, provider-independent assurance over compliance or alerts the organization to compliance issues. As part of the audit program, the organization needs to use its written policies, procedures, and processes to define the audit scope as well as the documentation needed to show governance.

How to Create a Continuous Monitoring Process

Cybercriminals don’t stop trying to gain unauthorized access to networks, systems, and software. In order to maintain compliance with internal controls, the organization needs to continuously monitor the evolving threats associated with these new threat vectors.

How to Use Continuous Monitoring to Create a Response Program

Compliance requires continuous control monitoring and response. An organization cannot simply know that new risks exist. It must respond to them so that it can mitigate them as fast as possible. Continuous monitoring enables the risk mitigation process by easing response.

Why Organizations Need to Document Their Continuous Monitoring

Although a company may establish a continuous monitoring and response program, they also need to document the processes to provide assurance to their auditor. To do this, it needs to make sure that it provides documentation proving its actions.

Using the Elements of an Effective Compliance Program for Stronger Cybersecurity

Although corporate compliance establishes guidelines for maintaining data integrity, confidentiality, and availability, it cannot be used as the primary cybersecurity program.

Organizations starting with compliance often find themselves cross-referencing an ever-increasing number of standards and regulations. As governments and industry organizations seek to protect the public from the damaging effects of data breaches, compliance becomes a spider’s web of controls that feel overwhelming.
Moreover, these regulations and standards remain strangled by bureaucratic processes that leave them unable to keep up with the continuously evolving nature of cybersecurity.

How to Build a Compliance Program Based on Security First

Taking a security-first approach to cybersecurity can ease compliance and cybersecurity burdens. Increasingly, compliance focuses on keeping data protected from cyber criminals rather than simply ensuring specific controls. Even if control is in place, a new control may be necessary – one not on the checklists.

Continuously Mitigate Risks

While the compliance program seeks to document and establish procedures for mitigating risks, focusing solely on required controls may not keep data secure. Therefore, risk mitigation and monitoring control effectiveness become more important than simply checking boxes on audit lists. Organizations need to start with their risk mitigation strategies and continuously review them.

Engage in Continuous Compliance Training

Staff training needs to be more than simply multiple-choice questions at the end of a video or lecture. Employees, including the c-suite and Board of Directors, need to engage in cybersecurity education. To understand security risks such as phishing and spear-phishing, employees need hands-on education that provides them with real-life examples and makes them respond meaningfully.

Create Standards of Conduct

Creating a code of conduct governing password hygiene and public WiFi use can be the difference between data security and data breach. For example, most data breaches arise from weak passwords. Employees using common passwords such as 123456 or Summer2018 can place networks, systems, and software at risk. Therefore, creating standards of conduct over these employee actions can be effective.

Ensure Consistent Discipline

Establishing a code of conduct does no good if the company does not reinforce it with discipline. Password hygiene, for example, needs to be both established and enforced. The same is true for email hygiene. If organizations set policies but failure to follow them have no repercussions, then the organization places itself at risk.

How ZenGRC Enables Two-Way Communication for Compliance

Compliance programs require communication between the internal and external stakeholders and an audit system that enables this.

ZenGRC offers workflow tagging so that you can delegate compliance tasks and monitor their progress and completion. Moreover, it allows you to prioritize tasks so that your team members know how to plan their activities.

ZenGRC’s workflow management capabilities include a centralized dashboard that continuously documents your control effectiveness making compliance documentation easier.

Additionally, it helps you create an audit trail by documenting and remediation activities to support your responses to auditor questions.

Using ZenGRC’s single source of information platform can speed up internal and external stakeholder communications and provide all documentation necessary thus reducing external auditor follow up requests.

For more information on how ZenGRC’s audit management workflows can streamline your process, contact us for a demo.

How to Improve Compliance in a Company

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Highly regulated financial institutions often struggle with compliance management. As a financial institution matures its cybersecurity compliance program, the document management requirements often mean they need to find automated solutions that can create a single source of truth to ease audit stress. Financial institutions store, transmit, and process large amounts of nonpublic personally identifiable information, meaning cyber criminals more heavily target the industry.

As such, while all companies need to create mature cybersecurity compliance programs, the higher standard to regulators hold financial institutions means they need to improve their programs continuously.

7 Steps to Improving Your Company’s Compliance Program

Improving a company’s compliance, specifically for financial institutions, means revisiting and refining the original compliance program. Functionally, improving your compliance program means reiterating the process, drilling down into the original risk analysis, and integrating more specific documentation.

When attempting to mature your cybersecurity program, you need to start with the risk analysis first. Regulatory requirements and industry standards focus on risk-based models which means that if your risk analysis lacks specificity, your overall program will lack maturity.

From there, you need to continue the original process by focusing on details that may have been overlooked when you established your program. Unfortunately, given the dynamic nature of cybersecurity, you need to create a cycle of continuous monitoring, responding, remediating, mitigating, and documenting to provide assurance of governance.

Step 1: Engage in an Annual Risk Analysis

A risk analysis incorporates the risk identification, assessment, and analysis steps. Before you begin to improve your compliance program, you need to ensure that you know all the threats facing your financial institution. To do this effectively, you need to review all the locations where you store, transmit, and process data. This includes systems, networks, and devices. Then you need to review all the types of data you collect and store.

After this, you need to assess the risks to the different types of information and locations. Nonpublic, personally identifiable information is more attractive to cybercriminals so is a higher risk. The same true of things like software or networks that have commonly known vulnerabilities.

Finally, you need to analyze the risk a potential data breach by multiplying the likelihood of a data breach by the potential financial impact on the organization. This allows you to set the risk tolerances necessary for creating policies and mitigating risks.

Step 2: Update Policies at Least Annually

To mature the compliance program, you need documentation of the processes and procedures. Creating policies provides auditors the information they need to understand your internal control processes and align them with cybersecurity regulations. As your data needs change, you need to ensure that your policies reflect those changes.

Step 3: Continuously Monitor to Monitor Accountability

All industry standards and regulatory requirements focus on the importance of continuously monitoring your networks, systems, and software. Since cybercriminals continuously update their threat methodologies, the mitigating controls you set forth in your policies may no longer be adequate.

Step 4: Review Mitigating Controls

Mitigating controls protect you from cybercriminals while also providing assurance over your compliance program. As threats evolve, mitigating controls may need to evolve. As such, a regular review helps ensure that they align with the internal controls set forth in your policies to maintain a robust compliance program. By updating controls, you prove that you are following your response and remediation policy while also strengthening your compliance program.

Step 5: Engage in Continuous Response and Remediation

As new threats emerge, you need to respond and remediate them. As part of your continuous monitoring, you need to will find new risks to your data environment. However, detection is the first step. You need to make sure that you are continuously responding to and remediating any new risks that arise as part of your monitoring program.

Step 6: Continuously Document Program Improvement

Documentation provides assurance over your compliance with internal controls and external regulatory requirements. Documenting the risk process proves your program governance.

Step 7: Continuously Update Your Risk Profile

Since cybercriminals continuously evolve their methodologies and regulatory requirements cannot keep up with that, you need to maintain a strong compliance posture by continuously reviewing your systems and updating your risk profile as new threats emerge. Any time that you make a change to your systems, software, and networks, you need to review their potential impact and update your risk profile.

How ZenGRC Enables Companies to Improve Their Compliance Programs

ZenGRC provides a tracking system where organizations can log their compliance activities so that everyone knows what to do and when to do it so that you can more rapidly review the “to do” lists and “completed tasks” lists.

With our workflow tagging, you can monitor accountability and evaluate productivity over compliance program improvement by assigning tasks to the individuals in your organization responsible for the activities involved.

Finally, with our audit trail capabilities, you can establish a document management program that provides assurance over remediation activities to prove that you maintained data confidentiality, integrity, and availability as required by law.

For more information about how ZenGRC can streamline your GRC process, contact us for a demo today.

Higher Education Security Breaches To Learn From

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Higher education finds itself facing a threat to its financial security even larger than student retention – data breaches. As colleges and universities begin to adopt mobile technologies, they also find themselves increasingly targeted by malicious actors. Understanding the recent security breaches impacting the industry can educate institutions about information security.

Security Breaches in Higher Education

How Multifactor Authentication Protects Admissions Data

On March 7, 2019, cybercriminals accessed admissions information from three colleges – Grinnell, Hamilton, and Oberlin. After obtaining access to the information, they sent applicants emails holding the nonpublic personally identifiable information, such as birth date, hostage.

The unauthorized access traced back to Slate, a software system that many institutions of higher education use to manage applicant data. The Software-as-a-Service platform, used by over 800 colleges worldwide, transmits emails, texts, and new applications. Slate explained that the breach arose from unauthorized users accessing the colleges’ password-reset systems.

A lack of multifactor authentication for single-sign-on systems allowed the cybercriminals access to the platform.

More than merely a hassle over needing to notify students whose data may have been breached, the cyber attack could put the colleges’ student enrollment at risk.  Students worried about data protection and control may choose to attend institutions of higher education who have stronger cybersecurity practices.

Why Protecting Email Matters

On February 27, 2019, Florida Keys Community College announced a data breach arising from unauthorized access to employee email that occurred between May 5, 2018, and November 5, 2018. On October 19, the college discovered suspicious activity. On January 7, 2019, the college confirmed the identities of the people whose data had been compromised. The nonpublic personally identifiable information included name, address, date of birth, Social Security number, passport information, medical information, username, and password.

According to the 2018 Ponemon Cost of a Data Breach Report, the Mean Time to Identify a breach was 197 days, and the Mean Time To Contain was 69 days. Based on the timing above, Florida Keys Community College fared better than some. It took 167 days to identify the suspicious activity and 7 days to contain.

In grading terms, Florida Keys Community College earns a C+ for identification and an A- for incident response.

However, given the information obtained from cybercriminals, students, faculty, and staff may not be comforted by this. Depending on the number of email accounts accessed, the cyber attackers could have used vulnerabilities in the domain and IP configurations, SMTP authentication controls, number of connections to servers, or a variety of other network security issues.

How Vendor Risk Management Protects Student Records

According to the Stanford Daily, a student on campus found a vulnerability in the third-party content management system, NolijWeb, that allowed Standford applicants to access their Common Application forms. In 2015, NolijWeb began offering students access to their files. However, the system used student identification numbers as part of the records’ URL, meaning that anyone could access information by changing a few characters.

Stanford immediately disabled access to the application and suspended online access to the application documents which are protected by the Family Educational Rights and Privacy Act (FERPA).

Since a user needed an authenticated student login to access the site, the regular audits gave the vendor a clean record. However, this also means neither Stanford nor NolijWeb knew how long the vulnerability existed.

However, this is not the first data breach Stanford suffered in recent years. In 2017, a permissions error in the University-wide file sharing system led any Andrew File System (AFS) users to access sexual assault case preparation files. A month later, a vulnerability in the Graduate School of Business site leaked employee information.

All of these data breaches focus on permissions issues and vulnerabilities inherent in third-party vendors.

Four Steps to Securing Higher Education Data

Identify Risk

All of these breaches began with data storage, transmission, and collection points often overlooked in risk review processes. Colleges and universities know they handle sensitive data. However, increased use of Software-as-a-Solution enablements, whether new vendors or updated legacy systems, transform traditional data into electronic information.

Stanford, for example, had been using NolijWeb for scanned documents since 2009, 6 years before the application allowed students web access to the records. Therefore, the vulnerability may have been a part of the update process or new.

Thus, institutions of higher education need to focus more purposefully on identifying all locations that store, transmit, and collect data. Whether using a new integration or an updated legacy provider, colleges and universities need to be more engaged in the risk identification process.

Secure Networks

Higher education incorporates a variety of networks, creating a complex architecture. Library domains, email servers, and guest wireless connections are only a few of these potentially risky networks.

As more students access data via mobile devices, which often lead to man-in-the-middle attacks, colleges and universities need to be more diligent in establishing controls over those networks to protect data.

Focus on User Access and Authentication

Unlike other industries, higher education experiences annual user turnover. Upon graduation, students should no longer be allowed access to systems, software, and networks. Although alumni often love their alma maters, graduates create access and authentication risks.

Moreover, colleges and universities need to be diligent about enforcing multifactor authentication. A lost smartphone or a laptop left open in the library can lead to unauthorized access. Therefore, whether students and faculty like it or not, higher education needs to be more diligent about protecting access by incorporating additional controls.

Monitor Vendor Risk

In the same way that colleges and universities expect incoming first years to prove academic proficiency, they also need to ensure their vendors prove security proficiency.

After identifying risk, institutions need to make sure that they assess and analyze the risk that third parties pose to information. Any SaaS provider that stores, transmits, or collects student, faculty, and staff information needs to align their security controls with the institution’s risk tolerance. Service-level agreements between the institution and its vendor need to document acceptable controls as well as a consequence for failing to maintain control effectiveness.

How ZenGRC Enables Higher Education

Institutions need an automated process for organizing their security reviews.

With ZenGRC’s task prioritization, everyone knows what to do and when to do it, ensuring efficient review the “to do” lists and “completed tasks” lists.

With our workflow tagging, CISOs can assign tasks to the individuals responsible for the activities involved in risk assessment, risk analysis, and risk mitigation.

Finally, with our audit trail capabilities, institutions can document remediation activities to prove that they maintained data confidentiality, integrity, and availability to protect student privacy.

For more information about how ZenGRC can streamline your GRC process, contact us for a demo today.