[BreachExchange] Don't WannaCry: Ten Questions Boards and Company Management Can Ask in the Wake of Recent Ransomware Attacks

[Audrey McNeil]

http://www.lexology.com/library/detail.aspx?g=084f3a70-f753-40a1-9973-
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The WannaCry ransomware attack that hit computers around the world last
week is yet another reminder that computers play key roles in most
enterprises, and that it does not take much to disable those computers.
Questions remain about who was behind the WannaCry attack and whether it
even was that sophisticated. But even the most robust of systems can be
susceptible to attack, regardless of the attacker’s level of
sophistication. Here are ten questions that Boards and senior management
can ask their information security and business teams to assess how
prepared they are to respond to and recover from future attacks.

1. Do we have a patch management program in place?

WannaCry is a ransomware variant; ransomware has been around for a while,
but this was a particularly virulent version, hitting and encrypting data
on an estimated 230,000 devices in over 150 countries in just days. The
attack appears to have taken advantage of known in dated versions of the
Windows operating system, reportedly hitting companies using Windows XP and
Windows 2003 particularly hard. Victims without readily available backups
of their data could find themselves paying a bitcoin ransom to hopefully
obtain a key to allow them to unlock their files.

Software providers routinely discover vulnerabilities in their software and
often distribute patches to their products to address them. Vulnerabilities
can range from simple performance issues to significant security holes, and
patches from routine to critical. Even though Microsoft stopped supporting
certain of the impacted products some time ago, it released a patch to
address a vulnerability associated with WannaCry two months ago.

One way to help address this issue is to have a program in place to address
patching – for example, a policy that provides for installing routine
software patches on a scheduled basis and critical patches on an expedited
basis, taking into account relevant business and technology considerations.
For example, in many cases, patches need to be tested before deployment. A
patch management program can help to maximize resiliency while minimizing
business interruption.

2. Can users install their own software, and how do we manage admin-level
access?

Users who are permitted to install software can introduce vulnerabilities
into an otherwise secure system. One way to help address this risk is by
restricting user rights to download software. Administrator-level user
accounts are another area of focus because they have broad access
privileges and are permitted to perform a wide spectrum of functions. These
credentials, if compromised, can possibly allow a hacker to install
malicious tools on local machines or, in some instances, move through the
company’s network with greater ease and, potentially even to cover its
tracks to avoid detection. Controls that can help address this issue
include limiting the use of elevated, administrative user accounts
throughout the enterprise. They also include enhanced password complexity
and a regular changes in user account credentials. Companies can also
deploy privileged account management software to monitor administrator
accounts, detect unusual activity and take action to quarantine an attack.

3. Have we considered multi-factor authentication?

Multi-factor authentication involves a log-in process that requires
multiple means of authentication, such as a password plus a temporary token
generated by a separate device at the time of user log-in, each of which is
required to be entered by the user before network access is granted. This
multi-step process can provide a layer of protection particularly where a
user’s password has been compromised, because an attacker cannot get into
the network remotely using the password alone. Context is key, in that
multi-factor authentication can be impractical or more than is needed for
various implementations. But more regulators are showing an interest in
exploring where multi-factor authentication has or has not been adopted as
a control for remote access points into parts of an enterprise’s network.

4. Will our back-ups be available to us, on an acceptable timeframe, if we
are attacked?

A back-up system that allows for quick, seamless recovery of critical
systems and data can bolster resiliency in the wake of an unexpected system
outage or loss of data, whether caused by a ransomware attack or
non-malicious means such as a natural disaster. Attackers know this, and
according to security researchers, ransomware attackers are more and more
looking to target back-up servers as well as main servers in their attacks.
Understanding whether backup systems can withstand a ransomware or other
attack on company systems is therefore important. Having procedures in
place for regular back-ups can help minimize the impact of an outage or
attack. Additionally, back-up systems can be further enhanced by
maintaining them on separate networks or having tightly controlled write
access to those devices, and by procedures for testing the efficacy of
those controls.

5. Have we tested our systems to determine susceptibility and have we
tabletop exercised our incident response plan?

The primary goal of testing information systems is to identify
vulnerabilities before the attackers exploit them. Companies can retain
experienced cybersecurity firms through legal counsel to provide a robust
assessment, under privilege, of what may need to be improved so they can
meet their legal obligations to protect information. These firms can work
to identify vulnerabilities just as a hacker would and determine how well a
company’s cybersecurity program is functioning.

Periodic testing of the incident response plan also can help a company
prepare for an attack. Tabletop exercises involve practice drills of a
“real world” incident simulation. These exercises can often identify flaws
in a company’s incident response plan and help team members learn the
incident response process so they are prepared to respond when a real life
incident occurs. A tabletop exercise can involve all members of the
incident response team, including IT, legal and compliance, and provide
other stakeholders like business teams, HR and corporate communications
with an opportunity to practice coordinating and communicating effectively
with each other across a range of possible scenarios.

Companies can also practice analyzing incidents against applicable
notification statutes and industry-specific laws, as well as contractual
commitments to notify business partners or other third parties. In the
health care industry context, for example, ransomware attacks have been
known to target hospitals, health care providers and other health industry
entities because they tend to have rich repositories of personal and
sensitive data. In practicing an incident response plan, healthcare
providers who use, disclose or access electronic identifiable healthcare
information can review and rehearse how they are meeting their obligations
under relevant laws, including the Health Insurance Portability and
Accountability Act of 1996 (“HIPAA”), as well as various state privacy and
data security laws. In addition, the U.S. Department of Health and Human
Services Office of Civil Rights has indicated that a ransomware attack
involving health care information often results in a breach under the HIPAA
Breach Notification Rule, unless the entity can demonstrate, after
conducting a risk assessment, that there is a low probability that
protected health information has been compromised.

6. What kind of security detection and monitoring capabilities do we have?

When a ransomware attack occurs, a company may learn almost immediately
that its systems have been compromised because the ransomware is designed
to lock a system, and then display an instruction for how to pay the ransom
to secure the key to unlock the files. This is often not true, however, for
other types of attacks. In its 2016 Trends Report, cybersecurity firm
Mandiant reported that the median time from compromise to eventual
discovery of the incident by the company was 146 days. One potential option
that may help here involves the use of security information and event
management (SIEM) technologies that help to detect and respond to
suspicious behavior, potentially allowing a company to isolate impacted
devices or systems until the issue can be investigated and resolved. In
some cases, companies may elect to retain an outside security services firm
to help triage alerts.

7. What type of security training do our employees receive and how
frequently?

Employee training on information security can play a part in reducing
information security risk. Depending on the business, its level of risk and
the particular job function, training topics can include:

Good information security hygiene;
How to recognize and avoid falling victim to attacks, like spoofing and
phishing; and
Company processes for responding to a security threat, including reporting
the incident to the correct contact persons within the organization.

This training can occur upon hire and periodically thereafter.

8. What is our information security budget, and have we allocated the right
resources?

An effective information security program requires appropriate budget and
staffing. Boards and management may want to evaluate what their company
spends on security and identify security requests that have been made but
that may remain unfunded. It is helpful to consult directly with IT and
information security leadership within the company to solicit input on gaps
in resources. These inquiries can help determine whether the company has
allocated the correct amount of funding and number of personnel to
security, taking into account the size and scope of the organization and
the level of sensitivity of the information and systems to be protected.

9. Who is responsible for what aspects of our information security?

Information security is not just an IT function. Many organizations appoint
a cross-functional team to consider and manage the overall enterprise risks
that information security present. On this front, gaining a basic
understanding of the high-level principles of the NIST Cybersecurity
Framework and how to apply them can help an organization develop, maintain
and evolve proper administrative, technical and physical controls designed
to protect the network.

10. Have we reviewed our cyber-insurance coverage lately, and does it
appropriately address the risks we face, including ransomware attacks?

As cybersecurity attacks become more frequent, companies that depend on the
Internet may want to consider obtaining cyber-insurance or reviewing
existing coverage to ensure it appropriately addresses the risk profile of
the company. Working with a qualified professional, companies can review
policies to assure coverage is appropriate for their business in light of
its risk profile and that any policies issued do not contain exclusions
that would render the policies ineffective for the major risks a company
faces. Companies may want to consider whether the policies cover ransomware
attacks. Coverage limits should be selected based on a realistic analysis
of a company’s exposure, keeping in mind that certain laws may impact the
amount of coverage a company should seek. For example, Europe’s General
Data Protection Regulation, which goes into effect in May 2018,
dramatically increases a company’s liability exposure to the extent it is
covered by that law, and this exposure increase may warrant obtaining
additional coverage.

Closing Thoughts

If a ransomware or other security incident happens, affected organizations
should work closely with legal counsel, forensic specialists, IT
professionals and others to determine an appropriate response, including
whether a breach notification is required by law (such as HIPAA or any
other applicable law) or by any contract into which the company may have
entered.

With appropriate planning and resource deployment, companies can ensure
they have the necessary information security infrastructure in place to
maximize protection against ransomware and other cybersecurity attacks, and
to quickly and effectively respond to attacks if and when they occur.
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