It goes without saying that all IT organizations should have an active Incident Response (IR) Plan in place – i.e. a policy that defines in specific terms what constitutes an information security incident, and provides a step-by-step process to follow when an incident occurs. There’s a lot of good guidance online about how to recruit a data breach response team, set initial policy, and plan for disaster. For those organizations already prepared for IT incident response, be aware that best practices continue to evolve. The best IR plans are nimble enough to adjust over time. However, when the incident in question is feared to be a possible data breach, organizations should add a couple other goals as part of their comprehensive Application Security disaster planning:
CA Veracode’s Information Security Assessment Team, which put together our own IR playbook, recommends that IT groups follow these five emerging guidelines to plan for the reality of today’s risks and threats.
According to the SANS Institute, the first two steps to handling an incident most effectively are preparation and identification. You can’t plan for everything, nor should you. For example, if no business is conducted through the organization’s website, there is probably no need to prepare for a Denial of Service attack. Companies in heavily regulated industries such as financial services or healthcare receive plenty of guidelines and mandates on the types of threats to sensitive and confidential data, but other industries may not enjoy similar “encouragement”. Ask yourselves the question, what is OUR threat landscape, why would hackers and criminals want to attack us? The possible answer(s) will lead to a probable set of root causes for data breach attempts. Focus on what’s possible, but also don’t be afraid to think creatively. The U.S. National Security establishment was famously caught flat-footed by the events of 9/11 as the result of a “lack of imagination” about what terrorists were capable of accomplishing. By constantly re-evaluating your organization’s threat landscape (and by relying on solid threat intelligence to identify new and emerging threats), your data breach response team will remain on its best footing.
Practice: it’s not just the way to Carnegie Hall. IR Plans must not be written and then left on the shelf to gather dust. A proactive and truly prepared information security organization educates its IT staff and users alike of the importance of regularly testing and updating breach response workflows. Plans must be drilled and updated regularly to remain viable. Even if it’s simply around a conference table, run through your response plan. Some organizations do this as often as monthly; your unique industry and the probable threats it faces will determine the ideal frequency of this best practice. At CA Veracode, we run regular Table Top Exercises on a number of possible scenarios. The worst mistakes are typically made before the breach itself. Be prepared. The purpose of IR drills is to ensure that everyone understands what he or she should be doing to respond to a data breach, quickly and correctly. A good rule of thumb here is that “practice makes better, never perfect.” It pays to be honest about your IR team’s capabilities and their ability to effectively neutralize the most likely threats. If the necessary skills don’t exist in-house, then better plan to retain some outside help that can be standing by, just in case.
IR teams should always strive to improve response times – that’s a given – and “within minutes” is today’s reality. On the internet, a service outage of more thanone hour is considered significant. Social media chatter can very quickly amplify the damage that could be done to your business, so get out ahead of the crisis …and stay there. SANS Institute defines the third step in breach response as “containment” – to neutralize the immediate threat and prevent further damage to critical or customer-facing systems. Move quickly to determine the possible severity of the data breach and then follow the customized response workflows in place for that scenario. To borrow some terminology from the military: is your “situation room” responding to a Defcon 1 attack or more like Defcon 5? Even as your IR team moves to eradicate the threat, you can be communicating to key stakeholders appropriately – according to the reality of the situation at hand.
This guideline seems counter-intuitive. Sharing is caring, right? Wrong. Especially when it comes to the fate of your organization’s confidential or sensitive customer information. Your initial notification to customers should almost immediately follow detection as a pre-planned rote response. There will be no time to wordsmith the perfect statement in the thick of battle; better have it pre-packaged and ready ahead of time. That being said, this statement should be short and concise. Acknowledge both your awareness of the incident and the IR team’s continuing efforts to safely restore service, as soon as possible. After that, plan to give updates to all stakeholders on some kind of methodical basis. Act like the NTSB after a plane crash. They give regularly scheduled press conferences on what they know so far, while firmly pushing back on what they don’t. Think like an investigator and deal in facts. Don’t speculate as to the root cause of the breach or even when service will be restored, unless that timeline is precisely known. Your communication to the market, while measured, should always be sympathetic and as helpful as possible. One final piece of advice: tell your customers the same thing you tell the media. There are (few if) no secrets left on the Internet.
The root cause of a data breach incident is typically not immediately known, but that should be no impediment to your restoring service ASAP for customers (once the threat is contained and destroyed, of course). Keep the focus on the customer. Get back online as quickly as possible. Clearly, SANS outlines “recovery” as the step that ensures that no software vulnerabilities remain, but… Ignore the engineers & analysts who want to investigate root cause immediately. With today’s sophisticated attacks, this can take weeks or months to determine, if at all. Still, incident response is not over when it’s “over”. As we’ve asserted, the best organizations – and their IR teams – take the time to learn from any mistakes. Monitor systems closely for any sign of weakness or recurrence. Analyze the incident and evaluate (honestly) how it was handled. What could be improved for better response in the future? Revise your organization’s IR Plan, making any necessary changes in people, processes or technology for when or if there is a next time. Practice any new workflows again and again until you know them cold.
Solid IT risk management strategies include disaster recovery planning and the creation of a living, evolving incident response playbook. Today’s IR plans need to be focused, factual and fast. Every organization needs to budget for the hard IT costs associated with data breach recovery. However, a comprehensive and battle-tested plan will help mitigate the “soft costs” associated with poorly handled data breach incidents. These can include lingering damage to revenue, reputation or market value – long after the initial crisis is resolved.