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“You Can’t Unring That Bell!” – What is a”Data Breach” and When Should I Notify? August 21, 2012

Posted by Chris Mark in cybersecurity, Data Breach.
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There are currently over 45 state breach notification laws, several data protection laws, and numerous regulations including PCI DSS, HIPAA/HITECH, FISMA, and more.  I frequently find myself working with companies on data breach notification plans.  One of the more interesting (and heated) discussions comes when I ask them to define a “data breach” or “data compromise”.  More interesting is when I ask them to define a “suspected data breach”.  Visa’ rules state that “suspected” breaches must be reported within 24 hours of identification or there could be penalties. Consider the following example.  You, as CSO, are informed of a malicious software outbreak in the customer service department. Does this require notification under the state breach notification laws, or relevant regulatory regimes?  Maybe, maybe not.  It is dependent upon a number of factors including access to data, data protections (ie. encryption), segmentation, the various laws etc.  In short, it is not easy to decipher yet it is critical to be as accurate as possible.

Understanding what is, and what is NOT, a data breach or data compromise is the first step in defining your company’s data breach notification plan.  The reason it is so critical is in the titled of this article.  Once you notify that your company has been ‘breached’ you cannot ‘unring that bell’.  The genie is out of the proverbial bottle and things start moving quickly.  Most company’s would absolutely hate to make an announcement only to find that, while they may have experienced a security incident, it did not impact sensitive data (PII, CHD, NPI, PHI, etc.).   It is important that you work with your compliance group, legal (don’t forget legal!), and the infosec & risk department to ensure you have a solid understanding of when, and under what conditions your company is required to notify of a breach or suspected breach.  Here are some basic definitions to use as a starting point.  (check with your legal council and don’t simply use these…there..that should protect me!;)

Security Incident/Event – Any event that compromises the availability, accessibility, or integrity of any asset.  This includes systems, personnel, applications, services, etc.

Data Breach – Any exposure of or unauthorized access of sensitive and/or protected data to include PHI, PII, CHD, and NPI.

Suspected Data Breach– In the absence of  direct evidence (identified fraud, or misuse of data, for example), any Security Incident in which it can be reasonable assumed that sensitive and/or protected data was exposed or accessed without authorization.

Remember, some state breach notification laws do not consider a breach of encrypted data as a trigger for notification…others do 😉  If you need help unraveling these issues (insert shameless marketing plug)…contact Mark Consulting Group…www.MarkConsultingGroup.com

graphic by Hippacartoons.com

“Bow-Chicka-Bow-Wow!” – Privacy Failure of Photobucket Can Make You a Porn Star! August 13, 2012

Posted by Chris Mark in cybersecurity, Data Breach.
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For those who like to use the popular photo sharing site Photobucket to share (ahem)..”private” pictures may want to take action immediately.  According to an article on CNN, a privacy flaw in the way Photobucket allows users to share photos resulted in hackers gaining access to numerous R rated and even explicit photos of users.  Photobucket allows users to share photos using direct links.  This means that even if the user does not intend to share a photo, if a person can deduce the URL then the unencrypted file can be directly accessed.   This is a hack known as “Fuscking” and it has been used to access numerous files.  (more…)

“August 2012 TransactionWorld Magazine” – Chris & Heather Mark’s Articles August 13, 2012

Posted by Chris Mark in cybersecurity, Data Breach, Industry News.
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Chris and Heather Mark both have articles in the August 2012 issue of TransactionWorld Magazine.  Chris’ is titled: “The Impact of the Fortress Mentality  & Today’s Compliance Strategies” while Heather’s is titled: “After the Compromise; Security Incident Response and Mitigating the Damage”

One note.  I apparently forgot to update my bio with the Editor in Chief so the article erroneously references me as the Executive Vice President of Data Security and Compliance for a payment processor.  You can visit Mark Consulting Group at the following: www.MarkConsultingGroup.com

“…our own policies were not followed…”; Apple and Amazon Hacks August 8, 2012

Posted by Chris Mark in Data Breach, InfoSec & Privacy.
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This past week, tech writer Matt Honan (of Wired) had his Amazon and Apple accounts hacked and his “…digital life destroyed”.  You can read his first hand account here.  The hacker did not use any special technology rather was able to hack the accounts using a basic social engineering and knowledge of who the systems worked.  Here is a description of the hack from CNN.com:

“At the heart of his story is a dangerous blind spot between the identity verification systems used by Amazon and Apple, two of the tech industry’s most popular vendors.

Like many people, Honan has a variety of email addresses. Several of them can be easily tracked down by anyone hunting around online. The hacker who went after Honan found his @me.com address — a tip-off that Honan had an AppleID account. (more…)

“The Fortress Mentality & Data Compromises” – Chris & Heather Mark in August 2012 TransactionWorld Magazine July 31, 2012

Posted by Chris Mark in cybersecurity, Data Breach.
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This month’s TransactionWorld magazine includes an article by me (Chris Mark) titled: “The Impact Of the Fortress Mentality and Today’s Compliance Strategies”.  The article discusses, among other things, the Global Payments breach, PCI DSS compliance, and provides an overview and opinion on today’s focus on compliance with static standards as opposed to risk based information security.  One important note. I neglected to send an updated BIO to the editor so it still references my position at ProPay.  I have not worked at ProPay for over a year 😉  You can read more about my company Mark Consulting Group at www.MarkConsultingGroup.com.

Heather Mark is also in this month’s TransactionWorld with an article titled: “After the Compromise: Incident Response Plans and Mitigating the Damage”  Heather speaks about data compromises and provides good insight into strategies companies can employ to minimize the impact of such breaches.

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