NIS Directive: are you ready?

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Governments across Europe recognised that with increased interconnectiveness a cyber incident can affect multiple entities spanning across a number of countries. Moreover, impact and frequency of cyber attacks is at all-time high with recent examples including:

  • 2017 WannaCry ransomware attack
  • 2016 attacks on US water utilities
  • 2015 attack on Ukraine’s electricity network

In order to manage cyber risk, the European Union introduced the Network and Information Systems (NIS) Directive which requires all Member States to protect their critical national infrastructure by implementing cyber security legislation.

Each Member State is required to set their own rules on financial penalties and must take the necessary measures to ensure that they are implemented. For example, in the UK fines, can be up to £17 million.

And yes, in case you are wondering, the UK government has confirmed that the Directive will apply irrespective of Brexit (the NIS Regulations come into effect before the UK leaves the EU).

Who does the NIS Directive apply to?

The law applies to:

  • Operators of Essential Services that are established in the EU
  • Digital Service Providers that offer services to persons within the EU

The sectors affected by the NIS Directive are:

  • Water
  • Health (hospitals, private clinics)
  • Energy (gas, oil, electricity)
  • Transport (rail, road, maritime, air)
  • Digital infrastructure and service providers (e.g. DNS service providers)
  • Financial Services (only in certain Member States e.g. Germany)

NIS Directive objectives

In the UK the NIS Regulations will be implemented in the form of outcome-focused principles rather than prescriptive rules.

National Cyber Security Centre (NCSC) is the UK single point of contact for the legislation. They published top level objectives with underlying security principles.

Objective A – Managing security risk

  • A1. Governance
  • A2. Risk management
  • A3. Asset management
  • A4. Supply chain

Objective B – Protecting against cyber attack

  • B1. Service protection policies and processes
  • B2. Identity and access control
  • B3. Data security
  • B4. System security
  • B5. Resilient networks and systems
  • B6. Staff awareness

Objective C – Detecting cyber security events

  • C1. Security monitoring
  • C2. Proactive security event discovery

Objective D – Minimising the impact of cyber security incidents

  • D1. Response and recovery planning
  • D2. Lessons learned

Table view of principles and related guidance is also available on the NCSC website.

Cyber Assessment Framework

The implementation of the NIS Directive can only be successful if Competent Authorities  can adequately assess the cyber security of organisations is scope. To assist with this, NCSC developed the Cyber Assessment Framework (CAF).

The Framework is based on the 14 outcomes-based principles of the NIS Regulations outlined above. Adherence to each principle is determined based on how well associated outcomes are met. See below for an example:

NIS

Each outcome is assessed based upon Indicators of Good Practice (IGPs), which are statements that can either be true or false for a particular organisation.

Whats’s next?

If your organisation is in the scope of the NIS Directive, it is useful to conduct an initial self-assessment using the CAF described above as an starting point of reference. Remember, formal self-assessment will be required by your Competent Authority, so it is better not to delay this crucial step.

Establishing an early dialogue with the Competent Authority is essential as this will not only help you establish the scope of the assessment (critical assets), but also allow you to receive additional guidance from them.

Initial self-assessment will most probably highlight some gaps. It is important to outline a plan to address these gaps and share it with your Competent Authority. Make sure you keep incident response in mind at all times. The process has to be well-defined to allow you report NIS-specific incidents to your Competent Authority within 72 hours.

Remediate the findings in the agreed time frames and monitor on-going compliance and potential changes in requirements, maintaining the dialogue with the Competent Authority.

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Vienna Cyber Security Week 2018

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I’ve spend last week in Vienna at the annual intergovernmental conference focused on protecting critical energy infrastructure.

The first two days were dedicated to the issues of security and diplomacy.

A number of panel discussions, talks and workshops covered the following topics:

  • Implementing the EU strategy for safe, open and secure cyberspace
  • Cyber-threats to critical energy infrastructure
  • Operational resilience
  • Reducing the risks of conflicts stemming from the use of cyber-capabilities
  • Cyber-diplomacy: developing capacity and trust between states

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For the rest of the conference we moved from the Diplomatic Academy of Vienna to Tech Gate, a science and technology park and home to a number of local cyber startups.

We’ve discussed trends in technology and cyber security, participated in Cyber Range simulation tutorial and a scenario-based exercise on policy development to address the growing cyber-threat to the energy sector.

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AIT Austrian Institute of Technology together with WKO Austrian Economic Chambers, ASW Austrian Defence and Security Industry, and the Austrian Cyber Security Cluster hosted a technology exhibition of latest solutions and products as well as R&D projects.

Participants had an opportunity to see state-of-the-art of next generation solutions and meet key experts in the field of cyber security for protecting critical infrastructures to fight against cyber-crime and terrorism.

Talks continued throughout the week with topics covering:

  • Securing the energy economy: oil, gas, electricity and nuclear
  • Emerging and future threats to digitalised energy systems
  • Cyber security standards in critical energy infrastructure
  • Public sector, industry and research cooperation in cyber security
  • Securing critical energy infrastructures by understanding global energy markets

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The last day focused on innovation and securing the emerging technologies. The CIO of City of Vienna delivered an insightful presentation about on cities and security implications of digitalisation.  A closing panel discussed projected trends and emerging areas of technology, approaches and methods for verifying and securing new technologies and the future of the cyber threat.


DevOps and Operational Technology: a security perspective

I have worked in the Operational Technology (OT) environment for years, predominantly in major Oil and Gas companies. And yes, we all know that this space can move quite slowly! Companies traditionally employ a waterfall model while managing projects with rigid stage gates, extensive planning and design phases followed by lengthy implementation or development.

It’s historically been difficult to adopt more agile approaches in such an environment for various reasons. For example, I’ve developed architecture blueprints with a view to refresh industrial control assets for a gas and electricity distribution network provider in the UK on a timeline of 7 years. It felt very much like a construction project to me.  Which is quite different from the software development culture that typically is all about experimenting and failing fast. I’m not sure about you, but I would not like our power grid to fail fast in the name of agility. The difference in culture is justified: we need to prioritise safety and rigour when it comes to industrial control systems, as the impact of a potential mistake can cost more than a few days’ worth of development effort – it can be human life.

The stakes are not as high when we talk about software development.  I’ve spent the past several months in one of the biggest dot-coms in Europe and it was interesting to compare and contrast their agile approach to the more traditional OT space I’ve spent most of my career in. These two worlds can’t be more different.

I arrived to a surprising conclusion though: they are both slow when it comes to security. But  for different reasons.

Agile, and Scrum in particular, is great on paper but it’s quite challenging when it comes to security.

Agile works well when small teams are focused on developing products but I found it quite hard to introduce security culture in such an environment. Security often is just not a priority for them.

Teams mostly focus on what they perceive as a business priority. It is a standard practice there to define OKRs – Objectives and Key Results. The teams are then measured on how well they achieved those. So say if they’ve met 70% of their OKRs, they had a good quarter. Guess what – security always ends up in the other bottom 30% and security-related backlog items get de-prioritised.

DevOps works well for product improvement, but it can be quite bad for security. For instance, when a new API or a new security process is introduced, it has to touch a lot of teams which can be a stakeholder management nightmare in such an environment. A security product has to be shoe horned across multiple DevOps teams, where every team has its own set of OKRs, resulting in natural resistance to collaborate.

In a way, both OT and DevOps move slowly when it comes to security. But what do you do about it?

The answer might lie in setting the tone from the top and making sure that everyone is responsible for security, which I’ve discussed in a series of articles on security culture on this blog and in my book The Psychology of Information Security.

How about running your security team like a DevOps team? When it comes to Agile, minimising the friction for developers is the name of the game: incorporate your security checks in the deployment process, do some automated vulnerability scans, implement continuous control monitoring, describe your security controls in the way developers understand (e.g. user stories) and so on.

Most importantly, gather and analyse data to improve. Where is security failing? Where is it clashing with the business process? What does the business actually need here? Is security helping or impeding? Answering these questions is the first step to understanding where security can add value to the business regardless of the environment: Agile or OT.


How to conduct a cyber security assessment

NIST SCF

I remember conducting a detailed security assessment using the CSET (Cybersecurity Evaluation Tool) developed by the US Department of Homeland Security for UK and US gas and electricity generation and distribution networks. The question set contained around 1200 weighted and prioritised questions and resulted in a very detailed report.

Was it useful?

The main learning was that tracking every grain of sand is no longer effective after a certain threshold.

The value add, however, came from going deeper into specific controls and almost treating it as an audit where a certain category is graded lower if none or insufficient evidence was provided.  Sometimes this is the only way to provide an insight into how security is being managed across the estate.

Why?

What’s apparent in some companies – especially in financial services – is that they conduct experiments often using impressive technology. But have they made it into a standard and consistently rolled it out across the organisation? The answer is often ‘no’. Especially if the company is geographically distributed.

I’ve done a lot of assessments and benchmarking exercises against NIST CSF, ISO 27001, ISF IRAM2 and other standards since that CSET engagement and developed a set of questions that cover the areas of the NIST Cybersecurity Framework.

I felt the need to streamline the process and developed a tool to represent the scores nicely and help benchmark against the industry. I usually propose a tailor-made questionnaire that would include 50-100 suitable questions from the bank. From my experience in these assessments, the answers are not binary. Yes, a capability might be present but the real questions are:

  • How is it implemented?
  • How consistently it is being rolled out?
  • Can you actually show me the evidence?

So it’s very much about seeking the facts.

As I’ve mentioned, the process might not be the most pleasant for the parties involved but it is the one that delivers the most value for the leadership.

What about maturity?

I usually map the scores to the CMMI (Capability Maturity Model Integration) levels of:

  • Initial
  • Managed
  • Defined
  • Quantitatively managed and
  • Optimised

But I also consider NIST Cybersecurity framework implementation tiers that are not strictly considered as maturity levels, rather the higher tiers point to a more complete implementation of CSF standards. They go through Tiers 1-4 from Partial through to Risk Informed, Repeatable and finally Adaptive.

The key here is not just the ultimate score but the relation of the score to the coverage across the estate.


Intrusion detection in the ICS environment

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There are many network traffic analysis tools out there but how many of them understand industrial protocols like Modbus, Profibus or DNP3? More importantly, how effective are these solutions in the industrial control systems environment?

In this post I would like to share a quick summary of security vendors in this domain.

Please note that this space moves quickly so the list may not be up-to-date by the time you are reading this. That being said, I hope it provides a high-level overview of vendors and capabilities in this space.

Read the rest of this entry »


Industrial Control Systems Security: Information Exchange

There are a number of global information exchanges related to industrial control systems security. They offer useful guidelines and standards to help protect the environment.

The UK Centre for the Protection of National Infrastructure (CPNI) provides good practice and technical guidance as well as advice on securing industrial control systems.
Secure move to IP-based Networks (SCADA):

They also highlight the risks of wireless connectivity of physical security systems

Similar information exchange centres were established in Japan and Spain,

For the introduction to Industrial Control Systems Security see my previous blogs (Part I, Part II, Part II) or ICS Security Library


Global Industrial Cyber Security Professional (GICSP)

I’ve recently passed my GICSP exam. This certification is deigned to bridge together IT, engineering and cyber security to achieve security for industrial control systems from design through retirement.

This unique vendor-neutral, practitioner focused industrial control system certification is a collaborative effort between GIAC and representatives from a global industry consortium involving organisations that design, deploy, operate and/or maintain industrial automation and control system infrastructure.

GICSP assesses a base level of knowledge and understanding across a diverse set of professionals who engineer or support control systems and share responsibility for the security of these environments.

Here are some useful links for those of you who are interested in sitting the exam:

Exam FAQ

Flashcards

Certification Handbook