Cloud Cyber Risk

Cloud-based storage of an organization’s data attracts cyber hackers like bees to honey. Hackers take time to study and find flaws to breach, extract and sell personal information data. Data Experts Lee Neubecker and John Blair discuss cloud data compliance and legal regulations put in place to protect cloud-based data.

Compliance and Privacy Laws

Cloud cyber risk goes hand in hand when storing data on the Cloud. New compliance and privacy laws have been enacted to protect this cloud-based private information. The State of Illinois has passed a privacy law that specifically addresses how companies gather and store private data.

The Illinois Policy Group, an independent organization that generates public policy, explained that in 2008, Illinois enacted the BIPA, the most stringent law of any state regarding the consent, notice and disclosure procedures private entities must follow when collecting, storing or using people’s biometric information, such as fingerprints, iris scans and face prints. This law forces companies into compliance and makes them more responsible for the collection and storage of private data ultimately, decreasing exposure to cyber risk.

Data Experts Lee Neubecker and John Blair say because of BIPA companies are now more aware of how they secure and store data. They discuss other data compliance and privacy laws such as; California Consumer Privacy Act (CCPA) and Health Insurance Portability and Accountability Act (HIPAA) and how these laws help regulate the healthcare industry and other organizations when storing consumer data, and vendor data in the cloud ultimately protecting the consumer. Watch this video interview to learn more.

View Part 2 of our 3-Part Series on Cloud Data

Part 2 of our 3-Part Series on Cloud Data

Lee Neubecker: Hi I am back again with John Blair. We’re continuing our discussion on cloud security and helping to minimize your cyber risk of having data in the cloud. And today, we’re going to be talking more about some of the compliance and regulatory issues and legal issues that companies face that are having their data and customer data, vendor data in the cloud. So, John, can you tell me a little bit about some of the regulations that impact the healthcare sector specifically?


John Blair: Yeah, the primary one is going to be HIPAA and associated as subsequent acts like HITECH and things like that that augment HIPAA and some of them more clearly defined some of the rules and regulations, primarily Security Rule and Privacy Rule. So those are going to be the ones that primarily come into play, but there are also individual state versions of healthcare acts that you need to abide by and each state has one so you also need to abide by the state regulations as well.

LN: Interesting. So it really, if a company’s operating in multiple states, they have a lot of issues to be looking at.

JB: They have a lot of regulations to be aware of and to be compliant with, yep.

LN: So I know here in Illinois, we have the Illinois Biometric Information Protection Act, otherwise known as BIPA and that’s been creating a lot of stir with Facebook recently had a settlement.

JB: Yep.

LN: And apparently Illinois Residents that have Facebook accounts might be entitled to around $200 per person.

JB: Yep.

LN: If you are in Illinois and have Facebook, so possibly you will be notified.

JB: Yeah, Illinois is the only one.

LN: And do you think it will be through Facebook Messenger?

JB: I do not but Illinois because of that law, Illinois residents are the only ones that are getting anything out of that lawsuit because of that, specifically because of that law.

LN: Got it.

JB: So I don’t know the details of the law but on the surface, it seems to be headed the right direction.

LN: Right, essentially they took the position that your biometric information, unlike your cell phone or your social security number, you can’t change it.

JB: Right.

LN: So if that data becomes compromised such as your facial vector map,

JB: Yeah.

LN: Or your fingerprint or your DNA, that you can’t swap it, it’s part of who you are.

JB: Right and those, you know, we’re finally headed in the right direction where it’s being considered personal.

LN: Yeah.

JB: So which I totally agree with.

LN: We also had just last month the California Consumer Privacy Act, known as CCPA went into effect and that’s got a huge impact on anyone who does business with California residents.

JB: Yeah, that is yet to, I think people were preparing for that prior to that but it’s going forward, I’m sure there’s going to be a lot of repercussions from that because there’s going to be obviously companies and entities that don’t prepare well for that and are going to get caught up in it because it covers, California is a huge state, a lot of people so there’s going to be some lawsuits.

LN: So it’s also been such that if you’re making medical devices for consumers and you have that information, relaying over 3G, 4G networks, we’ve got CPAP machines, pacemakers, all other types Of information. LN: All kinds of monitors

JB: Yep.

LN: And that information going to the cloud, if you’re a California resident and that information gets breached, it could be used by marketers or it could be used In other ways to target people.

JB: Yeah hospitals are going to need to really step up their game with respect to that particular regulation. Hospitals traditionally are a little bit behind technically speaking from an IT point of view, they’re very much on the bleeding edge from a medical device IT point of view but they tend to lag behind because you can’t, it’s hard to afford both

LN: Yeah.

JB: But this is going to, you know, how they allow individuals or access to their networks, what they allow in and what they allow out because that’s the channel these medical devices use is going to be very, very important that they get more control over those things.

LN: So as it relates to healthcare, what are some of the concerns about when a data incident is discovered to actually turn out to be a data breach, what types of reporting and notification requirements are unique to the healthcare sector?

JB: Well, first and foremost, you need to evaluate the situation and then have in conjunction with your legal team and compliance teams, establish whether or not you do officially declare it a breach which means you need to investigate it, you need to involve any vendors that were involved with that data because it may have been the vendor that you’ve contracted with that actually had the breach of the disclosure and not you but since they’re your vendor, you’re also on the hook and that flows all the way up from business associates, which is what those two entities will be up to the covered entity who actually owns the data. So after a thorough investigation and consultation with legal and compliance, a determination needs to be made whether or not you’ve formally declared a breach. And if so, then there’s all kinds of HIPAA standards that come into play about notification to the government, notification to each individual affected by the breach, what needs to take place with respect to that notification, there’s a timeline involved that needs to be met. So there’s all declaring it a breach is a very formal and arduous task.

LN: Yeah, not a pleasant one.

JB: No.

LN: In our next segment on securing data in the cloud, we’re going to be talking more about when a breach is discovered, some of the issues related to reporting the breach and what that can mean to an entity, especially if it’s not handled correctly. So thanks for being on the show again.

JB: Thanks, Lee.

View Part 1 of our 3-Part series on Data Cloud Storage

BIPPA Laws

To learn more about HIPAA

https://www.hhs.gov/hipaa/index.html

Illinois BIPPA policy

https://www.illinoispolicy.org/

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Securing Data in the Cloud

Secure Cloud Data! Large organizations buy cloud services that provide storage on servers and other devices and connect with computer networking equipment throughout the world. So, how are they securing the data? Experts Lee Neubecker and John Blair say start with knowing what data is being stored.

What steps do organizations need to take when securing data in the Cloud?

The Cloud is digital storage that is physically secured and stored on big servers owned by big companies and made accessible through the internet. These big companies are connected with other computer networking equipment throughout the world. Does this sound too big to secure? Experts say there’s no time like today to understand where your data is stored and how it’s secured.

Today on the “The Lee Show”, Forensic Expert, Lee, and his guest John Blair who is cyber governance and information technology expert, explores the complexities of cloud-based security and storage. John suggests starting with obtaining a holistic inventory of your organization’s data and most of all be aware that some employees bring their own applications and use their own personal device to store organizational data. Check out this video on securing data in the cloud to learn more about cloud storage and cyber risk.

Part 1 of our 2-Part Series on the Securing Data in the Cloud

Part 1 in our 2-Part Series on Securing Data in the Cloud

The Video Transcripts on Securing Data in the Cloud follows

Lee Neubecker: Hi, I’m here today with John Blair. John is a cyber governance and information technology expert. He’s on the show here today with me to talk a little bit about securing your data in the cloud. Thanks for being on the show again, John.

John Blair: Hi Lee, good to be back, thank you.

LN: So we’re talking about cloud cyber risk. What do organizations need to be looking at to help secure their data in the cloud?

JB: I think first and foremost, you need to understand where is all the data and how do people get data in and out of their environment? There’s a lot of things typically called Shadow IT, where certain departments or certain users might you know, for example, start sending things to Dropbox to sync data amongst themselves to make it easier for themselves. But they might be syncing confidential information that’s not on Dropbox and the organization has no idea about it. You know, that scenario plays itself out over and over and over again, where there might be departments that actually use applications in the cloud that thus obviously, are processing data as well that the organization might not know about either. So you need to get an inventory of data. Where is it from a holistic point of view?

LN: And today you have the Bring Your Own Cloud, BYOC,

JB: Yes

LN: Many employees are bringing various apps with them that they’re used to using from their prior employers, and they’re wanting to use these apps. Sometimes they’re putting them on their smartphones and whatnot.

JB: And that’s driving a lot of the corporate action towards that. The cloud for first and foremost is a cost-savings for the most part. But what people are not realizing is that along with those savings comes certain responsibilities. And, from a user perspective, you know, people are used to as you said, people are used to certain applications, they’re used to certain things on their phone, or on a tablet or they’re used to working in a certain way with certain applications. And then you get in a corporate environment and those applications or that way of working might not be available. And so people start voicing that, and it becomes, you know, somewhat of a problem for corporate to adapt and keep up.

LN: So organizations, especially healthcare-related organizations, as well as financial services and other organizations that depend on intellectual property have a real risk here, don’t they with people bringing apps?

JB: They have a very big risk. Both of those sectors are heavily regulated. Data needs to be very tightly controlled. Breach notifications in the event that it happens become a very big deal, very public. And if you can’t explain where the date is, and where you know, who has it, then you have a problem.

LN: So isn’t there also risk not only faster dissemination of intellectual property and trade secrets, but what if the information becomes compromised by malware or a hacker to morph the data or destroy the data?

JB: Yeah, your only recourse at that point is to have really, really good backups. Because otherwise, you have no actionable direction to take. If you don’t have a backup of that data, you know, you have no ability to recover. It still might be considered a breach, a lot of times, and certain organizations or certain regulations. So you still might have to report it, even though the data has never left your organization, the fact you’ve lost control of it might be considered a breach. So that might be something you’d have to consider with your legal teams. But it’s not, it’s still a very big deal because you no longer are able to use it.

LN: So don’t you have a risk though, that if your backup is online, that the attacker could compromise your primary source and then your backup drive attached to your server?

JB: Well, hopefully, they haven’t gotten that far. But if generally speaking, your backups are always in the separate physical location, and not necessarily on the network.

LN: So you rotate them?

JB: and they’re separate, you know, media and things like that, but yeah, if you’ve gotten to the point where they’ve corrupted your database, they’ve encrypted your database, and they’ve also encrypted or destroyed your backups, you’re, in a very bad way.

LN: So knowing that hard drives sometimes fail, if you’re using a physical hard drive to write the data to, what do you think most organizations should be doing to ensure they have a certain number of versions that they can restore to?

JB: Well, normally backup systems are version controlled and so you do backups based on frequency. You do daily, you do hourly, you do you know, on the spot, so there point in time, a lot of times where there’s a lot of people, organizations, that can afford it have failover data centers, for example, that are mimicking the primary data center. So there is no loss of processing. but that’s very, very expensive to do. But yeah, you should definitely have you know, off-site storage of data. But those are all historical, and things that are not necessarily online that you can immediately refer to those lesser compromised to your point. LN: So when you’re considering bringing in a cloud provider to your organization, is it an official, non-shadow ware operation? What are some of the questions you ask of your vendors and things that you look for to help secure, ensuring those cloud providers are secure?

JB: Right. First and foremost, do they have some sort of testations with respect to the services you’re going to use for that provider? Cloud providers have hundreds and hundreds of services, not all of them are audited by an independent auditor, not that that guarantees anything, but at least if it’s the services you’re going to use or the applications you’re going to use. or the locations you’re going to use with that cloud provider, then you have something to point to say, you know, we did our due diligence, and they have these SOC 2’s or whatever form it might take. But you have to do something on them to ensure that, because the cloud is half their responsibility and half of yours, and you have to make sure they’re doing their half.

LN: So what other things do you think that organization should look for if they’re using data in the cloud, how to maximize the security of that data?

JB: First and foremost, I think they need to within their own organization, block these drop boxes and the Google drives and all that sort of stuff like that, so that people individually can’t make you know, downloads for example, from the database and then upload it to Dropbox or Google Drive or whatever, and then go home and look at the same documents. You know, from a personal perspective, that’s very convenient, it’s very nice to have to be able to sync and you know, you can use one, one central source of the information, but from a corporate perspective, that isn’t your data. It’s a corporation’s data. And so, you know, the corporation needs to be responsible and know where that data is going, and how to prevent it ideally, from getting there. It’s very easy to drop, you know, to block Dropbox at a network level, you know, but the problem is that there are hundreds of those types of things to block. And so you know, you need to do a lot more care from a corporate perspective internally to make sure that your users aren’t putting data someplace where you lose control of it.

LN: And are there any, any other things that you’d recommend adopting if you’re going to use these cloud platforms to help ensure that hackers don’t get access to user accounts?

JB: That’s an interesting one because as yours been, you know, almost all those user accounts have been hacked at one point or another. And so the only thing protecting me at this point is a password. I think multi factors in you know, bio authentication type of actions are the only thing you can do to improve your chances of those accounts not being used by inappropriate people. Because the accounts themselves are basically public knowledge, you know. Your, you know, your username is public knowledge, the only thing protecting it is a password.

LN: And so, you know, the multi-factor authentication actually addresses and requires that you have to have three factors. Something you know, something you are, or something you have.

JB: Right.

LN: So, for instance, many people know their password. They might have a thumbprint or they might have their cell phone.

JB: Right.

LN: That is something that they have. So you know, having that second factor makes it less likely that someone can simply get the password and get in.

JB: Right, where they send like to your point the phone, they send a code to your phone, you enter the code into the application–

LN: Exactly.

JB: And then you gain access. Until then you’re simply at the network border.

LN: So on our next video, we’re going to be talking a little bit more about, again about the cloud, cyber risk security and specifically we’ll talk about some of the legal and compliance issues that arise. Thanks for being on the show.

JB: Thanks, Lee. My pleasure.

Other related articles about securing data

National Institute of Standards and Technology on Securing Data in the Cloud

https://www.nist.gov/system/files/documents/itl/cloud/SP_500_293_volumeII.pdf

Academia Data Governance Information

https://www.academia.edu/37900938/Information_Governance_Concepts_Strategies_and_Best_Practices.pdf

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