Managing a Data Breach: Insights from FinTechSec Solutions Inc.’s Experience

Introduction

In the digital age, data breaches are an inevitable reality. Understanding how to navigate these turbulent waters is essential for any organisation. This blog post offers a detailed case study of FinTechSec Solutions Inc., a hypothetical yet relatable fintech company, as they encounter and address a data breach. This guide aims to provide a thorough understanding of the processes and reasoning behind each step in the data breach response protocol.

Setting the Scene

FinTechSec Solutions Inc., a bustling fintech firm, faces an unforeseen challenge one Friday evening. Their IT team detects unusual network activities and multiple failed login attempts – classic symptoms of a potential data breach. Early recognition of these signs is crucial for prompt and effective action.

Immediate Response Actions

  1. Containment: The team acts swiftly to isolate affected servers, crucial to limit further unauthorised access and potential damage. Suspect accounts are frozen to halt the perpetrators’ activities.
  2. Assessment: An emergency IT meeting assesses the breach’s scope and impact. A third-party forensic team provides an unbiased analysis, identifying that customer financial records might be at risk.

Communications Protocol

  1. Internal Notification: Management is informed, and a crisis management team, including IT, legal, PR, and executives, ensures a coordinated response. Staff are briefed on maintaining confidentiality.
  2. External Communication: Customers and stakeholders are informed transparently yet concisely, adhering to legal obligations while explaining the incident, its potential impacts, and Tech-CyberSec’s remedial actions.

Understanding Notifiable Data Breaches

Notifiable Data Breaches in Australia

Australia’s Notifiable Data Breach (NDB) scheme requires organisations to notify affected individuals and the OAIC about eligible data breaches. An eligible breach is one that likely results in serious harm and where remedial action cannot mitigate this risk. Prompt assessment of suspected breaches is mandated.

Data Breach Regulations in the USA, Canada, and Europe

  • United States: Varying state laws govern data breach notifications, lacking a federal equivalent to Australia’s NDB.
  • Canada: Under PIPEDA, breaches posing a real risk of significant harm necessitate notifying individuals and the Privacy Commissioner of Canada.
  • Europe: GDPR requires notification to the relevant authority within 72 hours of detecting a data breach, with affected individuals informed in high-risk situations.

Investigation and Analysis

The investigation reveals vulnerabilities due to outdated software, which were exploited through phishing emails. System logs show the entry points and movements of the intruders within the network.

Remediation Measures

Immediate actions include software patching, organisation-wide password resets, and enhancing email filters and monitoring tools, reinforcing digital defenses.

Recovery Plan

Operations resume in phases, starting with critical systems. New security verification layers are implemented for system access, coupled with ongoing monitoring for suspicious activities.

Lessons Learned and Future Prevention

The breach highlights the need for regular security audits, enhanced employee cybersecurity training, and the deployment of advanced threat detection systems, fostering a culture of security awareness.

Conclusion

FinTechSec Solutions Inc.’s fictional journey through a data breach offers valuable insights into breach management complexities. Preparation and understanding of each phase, from detection to recovery, are pivotal in developing robust strategies for handling data breaches effectively and strengthening resilience against future threats.


Example Cybersecurity Incident Response Plan (CIRP)

The below example is a framework that will get you started with a basic Cybersecurity Incident Response Plan (CIRP). While they can be much more complex, starting with something is better than nothing! I have used the Cybersecurity Incident Response Plan Guide from the Australian Cyber Security Center as a guide when putting this simple framework together.

Title: Cybersecurity Incident Response Plan (CIRP) for [Organisation Name]


Document Control
Document owner, version number, change history, distribution list, and approval records.

Purpose
Explain the purpose of the CIRP to prepare for, respond to, and recover from cybersecurity incidents.

Scope
Define the types of incidents covered by the plan (e.g., data breaches, malware attacks).

Plan Objectives
List the objectives such as minimising impact, restoring services quickly, and improving future defenses.

Incident Response Team Composition
Roles and responsibilities of team members including contact information.

Activation Criteria
Describe when the CIRP should be activated based on certain thresholds or indicators of compromise.

Incident Classification
Define categories or severity levels of incidents to prioritise response efforts accordingly.

Preparation Measures
Training: Outline regular training schedules for staff.
Tools & Resources: List tools required for detecting and responding to incidents.
Communication Channels: Establish secure communication protocols internally and externally.

Detection & Analysis
Alert System: Describe how alerts will be generated and monitored.
Initial Assessment: Provide steps on assessing validity and severity of an incident.
Documentation Process: Methods for documenting evidence from start to finish.

Containment Strategy
Short-term Containment: Immediate steps like isolating networks or devices.
System Backup: Procedures for backing up data as part of containment strategy.
Long-term Containment: Steps for more permanent solutions post initial containment.

Eradication Process
Identify Root Cause: Detail how to identify vulnerabilities or threats that caused the incident.
Removal & Cleanup: Steps to remove malware or unauthorised access points from systems.

Recovery Plans
Restoration Procedure: Guide on safely restoring services and operations.
Validation Checks: Ensuring all systems are clean before going back online.
Monitoring Post-Recovery: Intensive monitoring period after recovery actions are taken.

Post-Incident Activity
Debriefing Session: Conducting a meeting with all stakeholders involved in managing the incident.
Lessons Learned Report: Compiling insights gained during incident handling into a report.
Update CIRP Accordingly: Revising the response plan based on lessons learned.

Appendices
Appendix A: Contact Lists - Including internal teams, external agencies, law enforcement contacts if necessary
Appendix B: Incident Log Templates - For consistent documentation across all incidents
Appendix C: Checklists & Flowcharts - Visual aids that provide quick reference during an active response

Why Account Lifecycle Management is Important!

It is increasingly important that organisation start taking account lifecycle management more seriously.

Ask yourself these questions: Do any of your departed users have access to your systems still? One more time. Do you know, for sure, if any of your departed user have access to your systems still?

My experience has taught me that most organisations have a fairly generic staff offboarding procedure. The procedures are usually very loosely adhered to. They ensure that appropriate knowledge is transferred. They collect company assets, and illicit feedback with an exit interview. The staff member leaves among a flurry of “we will miss you” and other well wishes and they are on their way.

What is the problem? Well, the two main motives for data breaches are financial and espionage. With the current pandemic, most organisations and individuals are feeling the financial pinch at the moment.

For a business, any impact to operations or cashflow can be devastating – possibly causing the business to collapse. For individuals, anyone with the right motivation and a decent skillset can take advantage of weak security practices.

What does this mean for businesses? Many things. My topic of choice today is ensuring healthy and secure processes are in place to remove access to networks and systems. This is something that organisation just aren’t very good at. Research by Onelogin from 2017 shows that nearly half of ex-employees still had access to systems after departing!

Failing to handle the employee offboarding process can lead to serious information security risks. According to the 2020 Data Breach Investigations Report by Verizon, internal actors account for around 30% of all attacks. This figure is up from 20% just 5 years ago.

Also remember that it isn’t just the user that has departed you need to worry about. What if someone else knows the password? They now have an account they can use and they potentially have someone to blame any wrongdoing on!

Organisations need to put some serious effort into this space to ensure the safety and security of the organisation and its stakeholders.

Photo by Pixabay on Pexels.com

The mitigations for this risk fall into 2 categories: Administrative Controls and Technical Controls. Administrative controls focus on the security policies and procedures surrounding user account lifecycle. While Technical controls consist of the tools (hardware and software) that are implemented to manage the user account lifecycle.

Administrative Controls

You need to make sure you have well defined user account management policies

  • How long is an account inactive before it is disabled?
  • How long after the user has left before the account is disabled?
  • How long are disabled accounts kept before being deleted?
  • What if the account cannot be deleted? How do you secure it?
  • How are temporary of contract staff accounts managed?
  • What about accounts for staff on leave?

All these, and many more, scenarios need to be considered when developing your account management policies.

Technical Controls

Wherever possible the account lifecycle management should be automated. This removes most of the human factor when it comes to making sure things are done in a timely manner. Of course, you need to have a good understanding of your user account types and how each of these are managed.

Understanding the account types should be made much simpler once you have defined your account management policies. This should allow you to configure (or create) the appropriate tools you need to get things automated.

There are plenty of off the shelf tools available, a simple duckduckgo search will give you hundreds of results. Finding the right one for your environment and budget is crucial. You need to make sure it is flexible enough to support your requirements. You also need to make sure it is well supported by the vendor. Speaking of the vendor, you also need to make sure that you are purchasing the tools from a reputable organisation. After all, you are putting a lot of trust into their service!

There are many different ways to approach this problem. I would suggest the adoption of a formalised Cybersecurity Framework. You need to find the framework that suits your organisation and your requirements.

There are many frameworks available, including:

  • NIST
  • ISO IEC 27001/ISO 27002
  • COBIT
  • SOC2

What is the takeaway for this? Make sure you disable user accounts that are inactive, disabled account of staff that have left the organisation or on extended leave!