If you work for or (even better) co-founded a tech startup, you are already busy. Hopefully not too busy to completely ignore security, but definitely busy enough to implement one of the industrial security frameworks, like the NIST Cybersecurity Framework (CSF). Although the CSF and other standards are useful, implementing them in a small company might be resource intensive.
I previously wrote about security for startups. In this blog, I would like to share some ideas for activities you might consider (in no particular order) instead of implementing a security standard straight away. The individual elements and priorities will, of course, vary depending on your business type and needs and this list is not exhaustive.
Information security underpins all products and services to offer customers an innovative and frictionless experience.
- Improve product security, robustness and stability through secure software development process
- Automate security tests and prevent secrets in code
- Upgrade vulnerable dependencies
- Secure the delivery pipeline
Cloud infrastructure security
To deliver resilient and secure service to build customer trust.
- Harden cloud infrastructure configuration
- Improve identity and access management practices
- Develop logging and monitoring capability
- Reduce attack surface and costs by decommissioning unused resources in the cloud
- Secure communications and encrypt sensitive data at rest and in transit
To prevent regulatory fines, potential litigation and loss of customer trust due to accidental mishandling, external system compromise or insider threat leading to exposure of customer personal data.
- Enable device (phone and laptop) encryption and automatic software updates
- Make a password manager available to your staff (and enforce a password policy)
- Improve email security (including anti-phishing protections)
- Implement mobile device management to enforce security policies
- Invest in malware prevention capability
- Segregate access and restrict permissions to critical assets
- Conduct security awareness and training
To prepare for, respond to and recover from cyber attacks while delivering a consistent level of service to customers.
- Identify and focus on protecting most important assets
- Develop (and test) an incident response plan
- Collect and analyse logs for fraud and attacks
- Develop anomaly detection capability
- Regular backups of critical data
- Disaster recovery and business continuity planning
Compliance and data protection
To demonstrate to business partners, regulators, suppliers and customers the commitment to security and privacy and act as a brand differentiator. To prevent revenue loss and reputational damage due to fines and unwanted media attention as a result of GDPR non compliance.
- Ensure lawfulness, fairness, transparency, data minimisation, security, accountability, purpose and storage limitation when processing personal data
- Optimise subject access request process
- Maintain data inventory and mapping
- Conduct privacy impact assessments on new projects
- Data classification and retention
- Vendor risk management
- Improve governance and risk management practices
Image by Lennon Shimokawa.
Outline security requirements at the beginning of the project, review the design to check if the requirements have been incorporated and perform security testing before go-live. If this sounds familiar, it should. Many companies manage their projects using the waterfall method, where predefined ‘gates’ have to be cleared before the initiative can move forward. The decision can be made at certain checkpoints to not proceed further, accepting the sunk costs if benefits now seem unlikely to be realised.
This approach works really well in structured environments with clear objectives and limited uncertainty and I saw great things being delivered using this method in my career. There are many positives from the security point of view too: the security team gets involved as they would normally have to provide their sign-off at certain stage gates, so it’s in the project manager’s interest to engage them early to avoid delays down the line. Additionally, the security team’s output and methodology are often well defined, so there are no surprises from both sides and it’s easier to scale.
If overall requirements are less clear, however, or you are constantly iterating to learn more about your stakeholder’s needs to progressively elaborate on the requirements, to validate and perhaps even pivot from the initial hypothesis, more agile project management methodologies are more suitable.
Embedding security in the agile development is less established and there is more than one way of doing it.
When discussing security in startups and other companies adopting agile approaches, I see a lot of focus on automating security tests and educating developers on secure software development. Although these initiatives have their merits, it’s not the whole story.
Security professionals need to have the bigger picture in mind and work with product teams to not only prevent vulnerabilities in code, but influence the overall product strategy, striving towards security and privacy by design.
Adding security features and reviewing and refining existing requirements to make the product more secure is a step in the right direction. To do this effectively, developing a relationship with the development and product teams is paramount. The product owner especially should be your best friend, as you often have to persuade them to include your security requirements and user stories in sprints. Remember, as a security specialist, you are only one of the stakeholders they have to manage and there might be a lot of competing requirements. Besides, there is a limited amount of functionality the development can deliver each sprint, so articulating the value and importance of your suggestions becomes an essential skill.
Few people notice security until it’s missing, then the only thing you can notice is the absence of it. We see this time and time again when organisations of various sizes are grappling with data breaches and security incidents. It’s your job to articulate the importance of prioritising security requirements early in the project to mitigate the potential rework and negative impact in the future.
One way of doing this is by refining existing user stories by adding security elements to them, creating dedicated security stories, or just adding security requirements to the product backlog. Although the specifics will depend on you organisation’s way of working, I will discuss some examples in my next blog.
I’ve been interviewed for the launch of the ISACA Young Professionals portal that contains a wealth of information for starting and accelerating your career in IT audit and cybersecurity.
I decided to contribute because ISACA played a role in my career development too.
I started attending ISACA London chapter events while I was studying for my Master’s degree in London. Although the university provided a great theoretical foundation on information security, I wanted to know about the real-world challenges that practitioners in the industry were facing.
At the time I had just finished writing my thesis after doing some great research at the university and I wanted to share my findings and the research of my colleagues with the community. The organisers were supportive, so we agreed a day and I delivered a talk on resolving conflicts between security compliance and human behaviour.
It was a rewarding experience as the participants provided some valuable insights and feedback; they helped to bridge the gap between academia and real practical experience. I already had a solid foundation from my postgraduate degree but I was missing was some anecdotes and real life stories about how this could apply in practice. This laid the foundation for my book The Psychology of Information Security.
It worked out for me, but should you get involved in broader activities beyond developing your technical skills? I would say yes.
The value of technical skills and knowledge can’t be overestimated. But there’s another side to this story. Prospective employers are not only looking for technical experts, they want people who are good team players, who can collaborate and communicate effectively with others, who can organise and get things done, who can lead. Getting involved with the community and volunteering gives you the chance to develop and demonstrate these non-technical skills and grow your professional network.
Regardless of where you are on your journey, ISACA provides great opportunities to advance your career through courses, networking and certification programmes, so I highly recommend getting involved!
Read my story on ISACA Blog.
In the past year I had a pleasure working with a number of startups on improving their security posture. I would like to share some common pain points here and what to do about them.
Advising startups on security is not easy, as it tends to be a ‘wicked’ problem for a cash-strapped company – we often don’t want to spend money on security but can’t afford not to because of the potential devastating impact of security breaches. Business models of some of them depend on customer trust and the entire value of a company can be wiped out in a single incident.
On a plus side, security can actually increase the value of a startup through elevating trust and amplifying the brand message, which in turn leads to happier customers. It can also increase company valuation through demonstrating a mature attitude towards security and governance, which is especially useful in fundraising and acquisition scenarios.
Security is there to support the business, so start with understanding the product who uses it. Creating personas is quite a useful tool when trying to understand your customers. The same approach can be applied to security. Think through the threat model – who’s after the company and why? At what stage of a customer journey are we likely to get exposed?
Are we trying to protect our intellectual property from competitors or sensitive customer data from organise crime? Develop a prioritised plan and risk management approach to fit the answers. You can’t secure everything – focus on what’s truly important.
A risk based approach is key. Remember that the company is still relatively small and you need to be realistic what threats we are trying to protect against. Blindly picking your favourite NIST Cybersecurity Framework and applying all the controls might prove counterproductive.
Yes, the challenges are different compared to securing a large enterprise, but there some upsides too. In a startup, more often than not, you’re in a privileged position to build in security and privacy by design and deal with much less technical debt. You can embed yourself in the product development and engineering from day one. This will save time and effort trying to retrofit security later – the unfortunate reality of many large corporations.
Be wary, however, of imposing too much security on the business. At the end of the day, the company is here to innovate, albeit securely. Your aim should be to educate the people in the company about security risks and help them make the right decisions. Communicate often, showing that security is not only important to keep the company afloat but that it can also be an enabler. Changing behaviours around security will create a positive security culture and protect the business value.
How do you apply this in practice? Let’s say we established that we need to guard the company’s reputation, customer data and intellectual property all the while avoiding data breaches and regulatory fines. What should we focus on when it comes to countermeasures?
I recommend an approach that combines process and technology and focuses on three main areas: your product, your people and your platform.
Think of your product and your website as a front of your physical store. Thant’s what customers see and interact with. It generates sales, so protecting it is often your top priority. Make sure your developers are aware of OWASP vulnerabilities and secure coding practices. Do it from the start, hire a DevOps security expert if you must. Pentest your product regularly. Perform code reviews, use automated code analysis tools. Make sure you thought through DDoS attack prevention. Look into Web Application Firewalls and encryption. API security is the name of the game here. Monitor your APIs for abuse and unusual activity. Harden them, think though authentication.
I talked about building security culture above, but in a startup you go beyond raising awareness of security risks. You develop processes around reporting incidents, documenting your assets, defining standard builds and encryption mechanisms for endpoints, thinking through 2FA and password managers, locking down admin accounts, securing colleagues’ laptops and phones through mobile device management solutions and generally do anything else that will help people do their job better and more securely.
Some years ago I would’ve talked about network perimeter, firewalls and DMZs here. Today it’s all about the cloud. Know your shared responsibility model. Check out good practices of your cloud service provider. Main areas to consider here are: data governance, logging and monitoring, identity and access management, disaster recovery and business continuity. Separate your development and production environments. Resist the temptation to use sensitive (including customer) data in your test systems, minimise it as much as possible. Architect it well from the beginning and it will save you precious time and money down the road.
Every section above deserves its own blog and I have deliberately kept it high-level. The intention here is to provide a framework for you to think through the challenges most startups I encountered face today.
If the majority of your experience comes from the corporate environment, there are certainly skills you can leverage in the startup world too but be mindful of variances. The risks these companies face are different which leads to the need for a different response. Startups are known to be flexible, nimble and agile, so you should be too.
Image by Ryan Brooks.
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:
- 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.
- A1. Governance
- A2. Risk management
- A3. Asset management
- A4. Supply chain
- 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
- C1. Security monitoring
- C2. Proactive security event discovery
- 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:
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.
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.
I’ve been invited to talk about human aspects of security at the CyberSecurity Talks & Networking event. The venue and the format allowed the audience to participate and ask questions and we had insightful discussions at the end of my talk. It’s always interesting to hear what challenges people face in various organisations and how a few simple improvements can change the security culture for the better.