Cybersecurity and Third-Party Risk. Gregory C. Rasner

of time, and often leave undetected or with little evidence left behind for forensics. APTs are starting to utilize the supply chain cyber weaknesses.

Cybersecurity Frameworks

      The information security field has been around long enough for more than a few standards to be written. Security frameworks are a collection of government cybersecurity policies and guidelines, and best practices set in place protect information systems. They often have specific instructions for organizations to handle PII to lower the risk of a breach or damage. Dozens of them exist globally, but you must be aware of a few top useful ones to understand their scope and focus. Cybersecurity frameworks provide defined structures for people, process, and technology that a company uses as a reference to secure their networks, data, and systems from cyber threats. Some are regulatory guidance (e.g., New York Department of Financial Services [NYDFS] or the Health Insurance Portability and Accountability Act [HIPAA]), which provide a framework's structure. Some companies adopt a framework that is aligned with their industry (e.g., Control Objectives for Information and Related Technologies [COBIT] and Finance, or HIPPA and healthcare providers).

National Institute of Standards and Technology Cybersecurity Framework (NIST‐CSF) was created in response to the U.S. Presidential Executive Order 13636, whose purpose was to enhance the security of the country's critical infrastructure. While aimed at critical infrastructure such as power and water delivery, many private companies have adopted it. NIST‐CSF contains the following five functions that manage the risk to data and systems security: Identify, Protect, Detect, Respond, and Recover. This is shown in Figure 2.2.

      The Identify function focuses on identifying physical and software assets as a basis for managing assets. It defines what an organization's supply chain risk management strategy is, according to its priorities, constraints, risk tolerance, and assumptions that support the risk‐based decisions managing their supply chain risks.

The Protect function provides security controls to ensure the security and integrity of an organization's infrastructure systems. Through identity and access management (IAM), an organization seeks to limit and contain any possible damage, thus protecting both its physical and logical access. A data protection program must be aligned with the organization's risk strategy and appetite, and its data protection must align with the cybersecurity core principles of Confidentiality, Integrity and Availability. Its goals are to defend the organization's resources with a patch and vulnerability management programs, and to assist the staff in safeguarding its data and assets with awareness and training in best practices on the safe handling of protected information.

FIGURE 2.2 The NIST Cybersecurity Framework

      The Detect function is as it sounds—it refers to the activity taken to discover indications of a security incident. This detection must be timely. Monitoring capabilities must be continuously implemented in order to find and identify anomalous events to catch malicious or suspicious behavior. When we think of an organization's cyber operations teams defending against hackers, we typically think of them as being in detection mode. Some of the capabilities used to detect are Security Information and Event Management (SIEM), Data Loss Prevention (DLP), Intrusion Detection Systems (IDS), Intrusion Prevention Systems (IPS), and the other tools, which are focused on this detection activity.

      The Respond function ensures that correct actions are taken when a cybersecurity event is detected. Such activity ensures that cyber Incident Response plans are executed according to an organization's previously established processes. All work done to analyze and support recovery work is performed in a timely manner, and corrective activities are carried out to contain the incident and close the issue.

      The Recover function acknowledges any impact, then prioritizes the restoration of services or capabilities in a timely manner to further reduce the event's impact. The execution of a recovery plan as it's designed and implemented ensures the restoration of an organization's systems. A “lessons learned” meeting, or what may be known as a post‐mortem on the incident, must occur to determine if any changes are required in the organization's existing plans. Communications—both inbound and outbound—are coordinated during and post recovery from the event.

What is important about this framework is that it prepares a cybersecurity organization for the inevitable: the breach. Risk is never a zero game, and eventually the vulnerability and threat actors align perfectly. The adoption of this cybersecurity framework forces an organization to best prepare to protect its data, but also for when an event does occur. An organization must have recognized plans in order to limit an attack's impact.

      The ISO 27001 cybersecurity framework is an international standard that states a risk‐based process requires an adopting organization to incorporate measures for detecting security threats to information systems. ISO 27001 has a total of 114 controls that are categorized into 14 categories (with the number of controls):

       Information Security Policies (2 controls)

       Information Security Organization (7 controls)

       Human Resources Security (6 controls)

       Asset Management (10 controls)

       Access Controls (14 controls)

       Cryptography (2 controls)

       Physical and Environmental Security (15 controls)

       Operations Security (14 controls)

       Communications Security (7 controls)

       Systems Acquisition, Development, and Maintenance (13 controls)

       Supplier Relationships (5 controls)

       Information Security Incident Management (7 controls)

       Business Continuity Management (4 controls)

       Compliance (8 controls)

Organizations are not required to implement all 114 controls listed. The framework provides an outline for the controls that can be referred back to when performing a gap analysis and risk assessment compared to the ISO 27001. The downside is that the controls are not described in depth. To compensate for this lack of detail, organizations turn to the supplementary ISO 27002, which provides a lot of specificity to the cybersecurity controls. In ISO 27002, each control is given a page to explain how it operates and how to carry out the control.

      NIST 800‐53 was created to enable government agencies to have effective cybersecurity controls. This framework specifically describes the requirements for federal government agencies to protect data and information systems. It has over 900 security requirements, which makes it very complex for an organization to implement. The number of requirements and the mandates required to enforce the compliance are focused primarily on any company whose systems interact with a federal agency information system. Also because of this complexity, unless the company is required to follow NIST 800‐53, most private companies will adhere to NIST‐CSF.

      The New York Department of Financial Services (NYDFS) framework is a cybersecurity framework that covers nearly any entity performing financial services through the state of New York. The framework originates from NYDFS Cybersecurity Regulation (23 NYCRR 500) and “is designed to promote the protection of customer information as well as the information technology systems or regulated entities.” It requires companies to conduct risk assessments and to implement a program with security controls that detects and responds to cyber events.

      The covered entity, a financial institution, must implement the following six items:

      1 A risk assessment must be conducted periodically to assess the Confidentiality, Integrity and Availability