Utilizing a Quantitative Risk Approach TO DRIVE STRATEGIC IT COMPLIANCE VA SCAN OCTOBER 3, 2013 Glenn R. Wilson Classifying IT Risk Data risk • Breach, loss, corruption, unavailability Operational risk • Performance degradation, denial of service, outages Non-compliance risk Common IT Risks Unauthorized data access and changes Data loss, corruption, unavailability Denial of service attacks, malware Physical device failure, theft or destruction Inadequate system capacity, network architecture Poor application coding, failed implementations Inadequate change management controls Regulatory compliance violations Common IT Risk Impacts Reduced customer satisfaction permanent customer loss Business process interruption lost productivity / revenues Penalties, fines, sanctions, reputational damage, personal liability Fraud, identity theft, loss of financial assets Failure to achieve core business objectives What are the common themes? Mission risk Monetary loss Legal liability Why Comply? Compliance reduces exposure to penalties and litigation Compliance provides a baseline for risk management Compliance is integral to proper corporate governance Compliance requires a business to adopt best practices Compliance promotes organizational effectiveness In Compliance What does it mean to be “in compliance”? How do you know when you have achieved it? How do you sustain a state of compliance? What do we have to comply with? FERPA, HIPAA, HITECH, GLBA, SOX, PCI DSS, FISMA, ECPA, COPPA, EFTA, Bank Secrecy Act, USA Patriot Act, Basel II Accord … The short answer: “industry standards, federal, state and local laws” How many organizations put this statement into their policies and aren’t exactly sure what they are obligating themselves to? Approaching Compliance “Compliance should be the floor, not the ceiling, of your efforts” “It’s the fundamental layer for every security program.” (Rafael Diaz, CISO of the State of Illinois, quoted by Security Magazine from a Nov 2012 Chicago SC Congress event of SC Magazine) Other speakers warned against using compliance as the be-all-end-all of an information security program. “Compliance is a great hammer – if you have a nail”. “Don’t use a hammer if you have a screw”. “Using a FAIR report (Factor Analysis of Information Risk), which can translate the risk into real dollar amounts, making it easier to sell to the C-suite”. (Ward Spangenberg, CISO of Pearl.com, formerly of online gaming giant Zynga, quoted by Security Magazine from a Nov 2012 Chicago SC Congress event of SC Magazine) Source: http://www.securitymagazine.com/blogs/14-security-blog/post/83788-cisos-look-past-compliance-for-new-solutions-to-old-problems Successfully Achieving Compliance Know your organization’s specific compliance exposure Know the processes by which its objectives are achieved Gain executive level support Obtain managerial and staff commitment Where do you start? The invariable starting point is… Business Impact Assessment Realities of Compliance Compliance is not equal to Risk Management (although achieving compliance does mitigate risk) Can achieving compliance create risk? Yes. What kinds? Operational, Financial, Legal Failure to achieve compliance is itself a risk category Drivers of Compliance What is the primary driver of organizational compliance? Non-compliance risk – Penalties, sanctions, liabilities Other risk drivers: Financial, Reputational, Operational & Individual risk Who primarily drives organizational compliance? Board? Executive Management? Compliance Officers? Internal Auditors? Middle Management? Effective programs are driven by a culture of compliance and align with the organization’s strategic planning Degrees of Compliance To what extent should an organization ‘be in compliance’ with a given regulatory requirement or industry standard? 100%? 80%? 50%? 0%? How fast should an organization achieve compliance? How long should an organization be in compliance? How far? How fast? How long? Risk Versus Compliance Risk How does risk vary with compliance? Compliance Greater compliance can decrease risk at many levels Greater compliance may increase risk at many levels Risk Mitigation Versus Cost Risk Diminishing Return Cost What costs may be associated with risk mitigation? Financial resources Human resources Competitive advantage loss “Selling” Compliance The need for compliance sells itself The degree of compliance needs to be driven to levels appropriate for the organization. Compliance costs can be expensive at many levels Risks are well known but often not well understood Do not overstate the merits or consequences Do determine and promote impact awareness Quantifying Risk To Drive Compliance Are numbers persuasive? Join now for only $19.95 per month 4 out of 5 dentists recommend sugarless gum More doctors smoke Camels than any other cigarette (133,597 surveyed) Gartner Group says that 43 percent of companies were immediately put out of business by a “major loss” of computer records, and another 51 percent permanently closed their doors within two years — leaving a mere six percent “survival” rate; (homelandsecuritynewswire.com Feb 19, 2010) Qualitative vs Quantitative Analysis Qualitative • • • • • Faster, not data intensive More cost-effective or is it? It does not provide numerical impact making cost benefit analysis difficult Analysis based on likelihood and impact Results stated in terms of low, med, high or similar numerical scale Good for prioritizing risk and identifying high risks that need immediate mitigation Quantitative • • • • Data intensive simulation and decision analysis Results stated in terms of probabilities and costs Primary advantage is the cost benefit analysis for efficient use of resources Results that are not clear will be qualitatively determined Not every risk requires or is suited to quantitative analysis Define a criteria for meaningful quantitative analysis of your organization’s risks Identify technique(s) to be utilized and develop methods for consistent application Define the expected outputs of the chosen quantitative analysis methods Med High Which Likelihood - Impact pairs should be analyzed? Low Likelihood Risk / Impact Models Low Med High Impact Risk / Impact Assessments Inherent risk = high (9/10), Residual risk = medium (6/10) Risk = (Probability) x (Impact) More scientific ‘closed form’ methods exist using Convolution and Fourier Transforms which require large amounts of data to calculate frequency and severity distributions to obtain an aggregate losses (expected, unexpected, confidence levels) ‘Open form’ solutions such as Monte Carlo simulation and Latin Hypercube sampling that evaluate scenarios for frequency and severity of losses by generating random numbers using each type of distribution (identified using actual loss data). Risk / Impact Distribution Calculations Events and Losses Risk Loss Matrix Frequency & Loss Impact Distributions Value At Risk Calculation Periodic Aggregate Loss Distribution ∞ PROB 20% 3% 10% 7% 35% Pn% IMPACT RISK $5,000.00 $1,000.00 $25,000.00 $750.00 $12,000.00 $1,200.00 $9,000.00 $630.00 $75,000.00 $26,250.00 $In $Rn = 0 + cos =1 + sin VaR = VaR12 + VaR22 + 2 * C2* VaR1 * VaR2 Periodic Aggregate Loss Risk / Impact Calculation Models EF = (((TP×(C/E))×(VF×AP))/100) EF: Exposure factor (% loss of asset) TP: Threat probability C: Criticality factor E: Effort requited to exploit the threat Adrian Munteanu, Alexandru Ioan Cuza University, Iasi, Romania Information Security Risk Assessment: The Qualitative Versus Quantitative Dilemma Managing Information in the Digital Economy: Issues & Solutions 228 Risk = Σan (Σram (Cm*(Vm*Om))) Σan: Sum of the asset risk Σram: Risk sum for each combination of criterion, vulnerability and threat per asset Cm: Criterion value for the current combination Vm: Vulnerability risk level for current combination Om: Threat occurrence for current combination Abbas Asosheh, Bijan Dehmoubed, Amir Khani Tarbiat Modares University Tehran, Iran A New Quantitative Approach for Information Security Risk Assessment 2009 IEEE Risk Exposure = ALE = SLE * ARO ALE: Annualized Loss Expectancy SLE: Single Loss Expectancy ARO: Annual Rate of Occurrence Return On Security Investment (ROSI) – A Practical Quantitative Model Wes Sonnenreich, Jason Albanese and Bruce Stout SageSecure, LLC 116 W. 23rd St., 5th Floor, NY, NY 10011 USA Journal of Research and Practice in Information Technology, Vol. 38, No. 1, February 2006 Risk Score = log(10Risk Score1+10Risk Score2) Likelihood Score = log(10Likelihood Score1 + 10Likelihood Score2) Consequence Score = Risk Score – Likelihood Score Xun Guo Lin & Richard Jarrett Division of Mathematical and Information Sciences A Practical Approach to Quantitative Risk Assessment Canberra & Melbourne Risk Conference, Wellington, 2009 Practical Considerations What are the primary objectives of quantifying risk to drive compliance? To quantify in whole or in part losses, expenses and liability (Some quantification is better than none) To use the methods and results to inform executive decision makers What are the most useful numbers to consider? Loss Expectancies (single and recurring) Occurrence (actual or estimated) Asset Value (tangible and intangible) Recovery Costs Long Term Costs Establishing Impact Scales Risk appetite is organization specific with dependencies on: - Industry Business Mission Capitalization and Cash Flow Board and Executive Management Define risk / loss levels in terms of: - Monetary value - Liabilities / penalties - Mission specific factors IMPACT Insignificant Minor Moderate Severe Disastrous LOSS $ $10,000 $100,000 $500,000 $1,000,000 $10,000,000 SCORE 1 2 3 4 5 IMPACT Insignificant Minor Moderate Severe Disastrous LOSS (Units) 500 1,000 2,500 5,000 10,000 SCORE 1 2 3 4 5 Case Specific Factors Is this a valid quantitative analysis? Annual threat probability Incident cost Weighted cost Annual counter cost Cost benefit 75% $1,000,000 $750,000 $600,000 $150,000 What are the case specific factors? Risk type and nature Basis for numeric values Cost types considered Compliance Checklists Strengths Identifying gaps and deficiencies (a very necessary activity) Weaknesses × Prioritizing remediation of deficiencies × Tracking corrective actions × Cost management × Resource deployment × May not result in value to the organization × Does not ensure adequate security or risk mitigation × May lead to an overburden of overlapping / unnecessary controls Making The Case How related or specific is the compliance type to your business? Exactly what are the associated compliance risks? What are the expected costs and impacts to comply? How much return will be realized in reduction of risk or increased effectiveness? Numbers are most persuasive when they are validly derived, understandable and relevant to a given situation. They can be mixed with qualitative factors. Example – XYZ Act Compliance The new XYZ federal ecommerce regulatory act will go into effect in 3 months. Even though your organization derives significant revenue from ecommerce activities, the new act is not on the radar of executive management even though you first brought the need to comply to their attention 18 months ago and again 3 months ago. You are not directly responsible for ecommerce revenues but are responsible for operating the organization’s ecommerce system within ‘industry standards, applicable federal, state and local laws. Major infrastructure reconfiguration and architectural changes are needed to comply. How can you re-approach the subject with executive management to gain the necessary support? ! According to the last quarter financials, $6k per hour or 46% of revenues come from ecommerce activities. ! There is a new threat vector that we have never faced before and there is a high probability that within months our system will be exploited if it is not hardened to the new standard. The IDS upgrade will cost $200k, and to comply within 3 months it will require 300 staff hours and $240k off peak ecommerce downtime. ! If we do not act and an incident occurs, it will likely be viewed as “willful negligence” and we would incur the maximum fine of $10k a day plus average clean up costs of $80 per affected record of which we have 2 million. Our ecommerce operation could be disrupted or suspended by an external investigation for 7-10 days. ! Every week that this project is delayed will cost an additional $20k in peak downtime and $10k in shift differential compensation. Case 1 – PCI DSS Essential Elements of Compliance: Secure collection, handling, storage and transmission of cardholder data, quarterly system scan by a PCI SSC Approved Scanning Vendor (ASV), annual SAQ Non-Compliance Risk: The payment brands may, at their discretion, fine an acquiring bank $5,000 to $100,000 per month for PCI compliance violations which will pass to the merchant. Bank will also most likely either terminate your relationship or increase transaction fees. PCI is not a law. Compliance Risk: Potential adverse effects on business processes and IT workload Added Value: Mitigate risk of cardholder data breach, improved IT vendor contractual relations Quantifying Risk Factors Payment card revenue (gross and relative amounts) Payment card transactions (gross and relative amounts) Current transaction and processing fees Cost to achieve compliance Recurring costs Case 2 – Sarbanes Oxley (SOX) Essential Elements of Compliance: Publicly traded companies must maintain all controls needed for accurate financial reporting. Financial reports require an internal controls report. Non-Compliance Risk: Exchange de-listing, loss of investor confidence, loss of liability insurance. Incorrect submissions carry up to a $1 million fine and 10 years in imprisonment. Willful incorrect violations allow for up to $5 million fine and 20 years imprisonment. Compliance Risk: Drain on available resources, business process changes, IT requirements are not well defined and attempts to comply may not pass an external audit. Added Value: More reliable financial and asset controls, increased market capitalization Quantifying Risk Factors Stock ownership Current market capitalization Industry sector volatility Case 3 – E911 Essential Elements of Compliance (Virginia): All PBX/MLTS installed after July 1, 2009 must provide ANI and ALI to the local PSAP for 911 calls unless alternate methods of notification have been approved. (Article 8. Emergency Calls on Multiline Telephone Systems.§ 56-484.23) Non-Compliance Risk: (Varies by state) Fines, OSHA sanctions, worker’s compensation claims caused by safety violation, common law liability, reputational damage Compliance Risk: Significant cost to upgrade or replace existing phone system, business interruption, transient risk of media relation issues Added Value: Employee trust, increased productivity, public goodwill, decreased liability Quantifying Risk Factors Age of the existing phone system Cost to upgrade versus replace Number of facilities, geographic distribution and occupancy habits Case law Case 4 – Gramm Leach Bliley (GLBA) Essential Elements of Compliance: Protect consumers’ personal financial information held by financial institutions. There are three principal parts to the privacy requirements: the Financial Privacy Rule, the Safeguards Rule and pretexting provisions. The safeguard rule requires a plan that “contains administrative, technical, and physical safeguards” to “insure the security and confidentiality of customer information; protect against any anticipated threats or hazards to the security or integrity of such information; and protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer. Risk of Non-Compliance Risk: Fines up to $100,000 for each violation, Personal liability to officers and directors of up to $10,000 for each violation, Criminal penalties include imprisonment for up to 5 years. More serious willful violations call for the fine will be doubled and imprisonment for up to 10 years. (Monetary losses (immediate and future), reputational damage, personal liability) Risk of Compliance: Business process and operational change management Added Value: Customer relations, decreased legal liability Quantifying Risk Factors Implementation / recurrent costs versus volume / revenue associated with qualifying financial activities Comments? Questions? Glenn R. Wilson, IT Audit Manager Old Dominion University, Norfolk, VA [email protected] 757-683-3202 Thank you!