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The Breach: Final Chapter

The Breach: Final Chapter

The Breach: Final Chapter

 


Why Does The Attorney General of North Carolina Care About Our Data Breach?

Our Data Breach Coaches had filed the necessary communications with several state Attorney Generals.  We were advised that most states would acknowledge, and it would end there. However, the Attorney General’s Office in North Carolina reached out and requested more information. This was surprising to me, as I didn’t know how to respond or why they would be asking for more details. Fortunately, our Data Breach Coach fielded the request, and we had a call to discuss the strategy of how to respond. Our response was most reassuring that we had taken the necessary measures to prevent an issue like this from happening again. This was just another point, where had we not engaged the right people, we would have had no idea the reporting requirement existed and/or how to respond to requests for more information. As I learned, each state has different reporting requirements, and North Carolina was not the last state to request more information.


Credit Monitoring, Makes Sense

After two months, we were rounding the home stretch of our incident response. The final piece was to figure out how to protect the impacted individuals from any potential damages. Our Data Breach Coach asked us how we wanted to proceed. (Let’s pause for a second, this is a common theme throughout the process. At various points, third parties who had expertise in a subject matter would ask us our thoughts on how we’d like to proceed. We wanted guidance from the experts in areas we needed; I thought it strange we were asked this, rather than just presented options, back to the story) Obviously, we didn’t know how to respond, so we asked for options. 


As a sign of “goodwill,” they suggested offering everyone credit monitoring for two years. That seemed reasonable to us. So they referred us to a national brand that provides these services. During our first call, they offered credit monitoring, explained the process. All of which was acceptable, but then they started talking about setting up a call center, handling questions by the impacted individuals, printing notification letters, and lots of other services. All of which sounded like a great idea had the scope of our incident warranted. However, our situation was so small that it seemed like overkill and yet another way to spend the Company’s money needlessly. So, we set up the necessary processes with internal staff, contracted to offer the credit monitored, and sent out the notification letters. Materially, the incident response was effectively over.


You Want A Detailed Recap Of The Breach Response. Are You Sure?

Finally, after all notification requirements were handled, credit monitoring handed out, and all inquiries were answered, we had a chance to exhale a bit. The incident could have been much, much worse. But we’d made it through. After thinking about it, I realized I didn’t have a formal recap of our response from our Data Breach Coach. I thought, should any inquiries be going forward about how we responded, I should have something to prove that we satisfied all the legal requirements and acted ethically. So, I launched a call to our Data Breach Coach. Out of everything we experienced, this final chapter is something that surprised me the most. After a few days, the Data Breach called me back and acknowledged my request. 


Here is our dialog:


Data Breach Coach: What do you want a formal recap of all the activity that occurred on your behalf in responding to this incident?

Me: “Yes, I do; I want to be able to produce some formal documentation of how we responded to our incident in the event it is needed in the future.”

Data Breach Coach: “Are you sure you want this?”

Me: “Yes, I’m sure.”


Data Breach Coach: “Are you
really sure?”


Me: “Rather than ask me if I
really want it, can you just tell me why you are asking if I want it?”


Data Breach Coach:  “If we produced it, it becomes a legally discoverable document, which might not be in your best interest, should future legal action be taken against you and your Company.”


Me: “So, let me get this straight, we spent three months and 250K responding to this incident. We dotted every ‘i’ and crossed every ‘t.’, But it’s not in our best interest to have a formal recap of the actions taken, to prove that we handled the incident in accordance with all the requirements?”


Data Breach Coach: “We can add a high-level summary to your file, should you need it, you can call our office, and we’ll produce it, but having a detailed document isn’t in your best interest.”


Me: “Ok, if that’s what you think is best, then I guess I don’t want it.”


This last interaction left me a little dumbfounded. But in hindsight, I should have expected it. The whole experience was foreign to the Company and me. In the end, we spent our entire amount afforded to use by our insurance coverage to respond to this incident for the potential loss of 250 records. During the initial days, there was lots of confusion, unknowns, and decisions that needed to be made. We didn’t always make the right ones, but we did have enough presence of mind to slow the situation down, get as data as we could, and make informed decisions.


I’m hopeful that our story can help, inform or at least mildly entertain anyone reading. 

 

About the Author:

This blog was written by John Hensberger, Managing Partner of Black Bottle IT.  Earlier in his career, John was also part of a company that experienced a cybersecurity breach. That experience fueled his passion for assisting other companies with their cybersecurity needs to mitigate their risk. As Technology Executive and Cybersecurity Advisor, John was recognized as the Pittsburgh CIO of the Year, 2014.  Connect with John here.

The Breach: Part 3

The Breach: Part 3

The Breach – Part 3

 


In “
The Breach – Part I”  and The Breach – Part 2, Black Bottle IT shares a true story of cybercrime that took place with a manufacturing client and how it unfolded. 

“The Breach” continues…

 

Engaging the Data Breach Coach

 

It turns out; Data Breach Coaches are law firms that specialize in cyber statutes.  It finally felt good to be talking to someone who I thought would guide us through our options.  Their role, as it was explained to me, was to quarterback the breach response.  They would:

  1. Take the lead and run point
  2. Advise our team on what to do next
  3. Bring in third-party expertise, if necessary, to help us mitigate any legal risk. 


This information all sounded great.  My first question was, “Where do we start?” 


A formal engagement letter was emailed to me shortly after our call ended.  I read it and found some language I didn’t like, as with most legal documents.  Most things I could live with, except the clause that says, “Data Breach Coach, acting in the best interest of the client, can engage and agree to terms with third party services, with all financial responsibility passed on the client, without client consent.”  It says the law firm can spend company money without anyone consenting or agreeing.  The second call we would have was to review the engagement letter.  When I questioned this language, “only to be told,” the response was, “It’s standard language, for your own good so that we can move quickly.”  I had this line removed from the agreement and officially engaged the Data Breach Coach.


Forensic Swat Team

 

One of the first things the Data Breach Coach advised was to engage a third-party computer forensic company to determine what data was lost when it was lost, etc.   We had a call, and the person leading the conversation had a super high sense of urgency.  He wanted to send 2-3 forensics technicians on-site the next day.  I paused and said, “How much is that going to cost?” 


Our insurance coverage was up to 250K of expenses.  Anything over was coming from the company coffers.  We were a small company; having thousands of dollars in fees would put the company in a vulnerable financial state.  So, I was always trying to walk the line of protecting the company, doing our duty to investigate, and being very mindful of the financial situation. 


Back to the story – The forensics company said we didn’t have time to wait, which was the best option.  I countered with, can’t we gather information with our staff and send you what you need?  Let’s start there, make a list, and we’ll begin compiling. 


Date of Discovery

 

All along the way,  third-party companies were lining up with their bags wide open, hoping to get them filled with “incident response” money.  Most of them were trying to create some real sense of urgency to engage and take action.  I never fell for the high-pressure tactics; I wanted to get some options, evaluate the risks, and make an informed decision.  However, in the days that followed, the attorneys started educating us in cyber statutes’ generalities.  Most of them had a requirement to respond with their timelines after the “date of discovery.”  This timeframe was the only timeline that mattered.  We had time to rationally engage third-party forensics to identify the scope of the data breach to formulate a responsible response plan.

 

Continue to Part 4

 

 

About the Author:

This blog was written by John Hensberger, Managing Partner of Black Bottle IT.  Earlier in his career, John was also part of a company that experienced a cybersecurity breach. That experience fueled his passion for assisting other companies with their cybersecurity needs to mitigate their risk. As Technology Executive and Cybersecurity Advisor, John was recognized as the Pittsburgh CIO of the Year, 2014.  Connect with John here.

 

My Breach Story: Part 1

My Breach Story: Part 1

The Breach – Part 1


I’m not sure how many cyber security professionals have been on the receiving end of a data breach and had to navigate their way through it.  But, part of my passion for this industry was born in my experience.  I was a typical IT Manager, supporting a companies software and infrastructure.  They had a few on-site IT professionals, and some  outsourced partners, and were focused on growing revenue, operational efficiencies, and doing more with less.  The Company had what I’d consider typical security tools in place.  A firewall with IP blocking and blacklisting, a modern AV/Anti-Malware agent, email security tools, etc.


The Call

 

One typical day, I’m at a lunch meeting with the CEO at Panera.  I got a call from my IT Manager since I was at lunch with the CEO. I wanted to stay focused on our conversation, so I ignored the call.  Immediately following I got an SOS text to call her ASAP.  This was not like her, so I knew something needed to be addressed, so I excused myself from the CEO and stepped outside to call her back.  I could sense a little panic in her voice, so I immediately asked her “What’s wrong?”.  She tells me that they received a call from the FBI, stating that an agent would be on-site the next morning to discuss a cyber security incident and that IT leadership and any 3rd party related to infrastructure should be present.  I paused, and being somewhat skeptical, I said, call the FBI office and verify the information provided (thinking it was a scam call).  She said, I already did, and it’s real.  After returning the table, the CEO asked me “What’s wrong?”, I relayed the information, and his first question was  “Is this something that could put the company out of business?”, to which I replied, “I don’t know yet”.  This was the beginning of a very long and hectic three months.


FBI On-site

 

True to their word, the FBI showed up the next morning, and we had all the necessary players around the table to ask questions and determine the scope of the situation.  Before we could open our mouths the FBI proceeds to tell us that he’s not even a cyber crime agent, he’s a kidnapping/ransom agent.  That he doesn’t know anything about  cyber crime, and his job is to read us the information about the incident.   So, he begins and reads a document that says the FBI had been monitoring some bad actors in eastern Europe and that our Company was 1 of 30 companies transmitting data to foreign IP addresses.  After reading the statement, he gave us the specifics of which IP addresses were in scope.  We start asking questions, to which he simply says “My job was to inform you of this activity, if you need more specifics, here is a card of a cyber crime agent that might help you”.  We shake hands, the meeting is over.


Continue to Part 2

 

 

About the Author:

This blog was written by John Hensberger, Managing Partner of Black Bottle IT.  Earlier in his career, John was also part of a company that experienced a cybersecurity breach. That experience fueled his passion for assisting other companies with their cybersecurity needs to mitigate their risk. As Technology Executive and Cybersecurity Advisor, John was recognized as the Pittsburgh CIO of the Year, 2014.  Connect with John here.

 

Importance of Preventing a Security Breach

Importance of Preventing a Security Breach

Nothing can bring business operations to a halt faster than the words “security breach.”

 

Under the shadow of the GDPR, and other regulations put in place after major security breaches were discovered, every company now works under the understanding that it’s their responsibility to keep their customers’ data safe. Also, if a breach of data occurred, then it’s also their responsibility to act swiftly and inform their customers as soon as possible.

 

As you might have known already, these tasks are easier said than done. Did you know that, on average, a company will find out that there has been a security breach in about 197 days, and then work on containing the threat for 69 days?

 

Keep on reading for our little guide on how to prepare for a security breach. We’ll also highlight how preparation can transform your firm’s response time frame to a breach.

 

Security Breach 101: Setting up a Data Breach Response Plan

 

In the simplest of terms, the best strategy for dealing with a data breach is having a data breach response plan in place. After all, in 2020, there’s a multitude of cybersecurity compliance to keep in mind.

 

Basically, a data breach response plan is the blueprint protocol of damage control and diminishing the impact of a major security leak. 

You’ll find that a well-tailored data breach response plan will have a role for every person in your company, and once a breach has been detected, your company will be working like a well-oiled machine to discover, respond, and contain the threat.

 

What’s great about having such a plan on hand is the peace of mind during a crisis, knowing that there is a well-thought-out plan in place that’s already underway. After all, you can’t expect to formulate a half-decent response in the middle of a breach.

 

The Importance of Preparation on Data Breach Response Time

 

There are very few factors that can impact your company’s response time to a data breach than having preparations ready.

 

According to a Centrify study, “highly secure” companies were able to show a quick reaction to data breaches, as well as showcases recovered stock values after —approximately— seven days.

 

Needless to say, it’s a strong indicator that having a cybersecurity plan in the wings can mean the difference between a mortally-injuring breach, and a minimal breach. 

 

However, you might be wondering what does being prepared actually entail?

 

The Characteristics of a High-Security Posture Organization

 

For a company to secure its data, it needs to have planned for a separate budget purely for staffing and investing in security technologies. 

 

For example, a well-prepared company will have training that tackles identification, containment, and eradication of security breaches. Besides, it needs to have cybersecurity awareness, that can work on combating employee negligence. 

 

Furthermore, conducting regular audits and assessments of security weak points and vulnerabilities can be key to lowering the risk of dealing with a security breach in the first place.

 

Ready to Switch on Your Security Plan?

 

Whether you’re a data protection officer in a huge corporation, or you’re the CEO of a small business, you need to have a security protocol in place for the dreaded security breach that you may encounter as the cost of doing business in the 21st century. 

 

Now, you’re more familiar with essential mechanisms like a data breach response plan, as well as response time. The next step is exploring your security options. 

 

Check out our breach response planning section to learn more. However, if you’re currently dealing with an active breach, make sure to contact us via our breach hotline to get support as soon as possible.