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Cybersecurity principles | Cyber.gov.au
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https://www.cyber.gov.au/resources-business-and-government/essential-cybersecurity/ism/cybersecurity-principles
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cybersecurity fundamentals principles
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# Cybersecurity principles
This rating relates to the complexity of the advice and information provided on the page.
Large organisations & infrastructure
Government
- Cybersecurity principles (March 2025) _846KB .pdf_
## The cybersecurity principles
### Purpose of the cybersecurity principles
The purpose of the cybersecurity principles is to provide strategic guidance on how an organisation can protect their information technology and operational technology systems, applications and data from cyberthreats. These cybersecurity principles are grouped into five functions:
- **GOVERN:** Develop a strong cybersecurity culture.
- **IDENTIFY:** Identify assets and associated security risks.
- **PROTECT:** Implement controls to manage security risks.
- **DETECT:** Detect and analyse cybersecurity events to identify cybersecurity incidents.
- **RESPOND:** Respond to and recover from cybersecurity incidents.
### Govern principles
The govern principles are:
- **GOVERN-1:** A chief information security officer provides leadership and oversight of cybersecurity.
- **GOVERN-2:** Security risk management activities for systems, applications and data are embedded into organisational risk management frameworks.
- **GOVERN-3:** Security risks for systems, applications and data are accepted before they are authorised for use and continuously throughout their operational life.
### Identify principles
The identify principles are:
- **IDENTIFY-1:** The business criticality of systems, applications and data is determined and documented.
- **IDENTIFY-2:** The confidentiality, integrity and availability requirements for systems, applications and data are determined and documented.
- **IDENTIFY-3:** Security risks for systems, applications and data are identified and documented.
### Protect principles
The protect principles are:
- **PROTECT-1:** Systems and applications are designed, deployed, maintained and decommissioned according to their business criticality and their confidentiality, integrity and availability requirements.
- **PROTECT-2:** Systems and applications are delivered and supported by trusted suppliers.
- **PROTECT-3:** Systems and applications are designed and configured to reduce their attack surface.
- **PROTECT-4:** Systems, applications and data are administered in a secure and accountable manner.
- **PROTECT-5:** Vulnerabilities in systems and applications are identified and mitigated in a timely manner.
- **PROTECT-6:** Only trusted and supported operating systems, applications and code can execute on systems.
- **PROTECT-7:** Data is encrypted at rest and in transit between different systems.
- **PROTECT-8:** Data communicated between different systems is controlled and inspectable.
- **PROTECT-9:** Applications, settings and data are backed up in a secure and proven manner on a regular basis.
- **PROTECT-10:** Only trusted and vetted personnel are granted access to systems, applications and data.
- **PROTECT-11:** Personnel are granted the minimum access to systems, applications and data required to undertake their duties.
- **PROTECT-12:** Robust and secure identity and access management is used to control access to systems, applications and data.
- **PROTECT-13:** Personnel are provided with ongoing cybersecurity awareness training.
- **PROTECT-14:** Physical access to systems, supporting infrastructure and facilities is restricted to authorised personnel.
### Detect principles
The detect principles are:
- **DETECT-1:** Event logs are collected and analysed in a timely manner to detect cybersecurity events.
- **DETECT-2:** Cybersecurity events are analysed in a timely manner to identify cybersecurity incidents.
### Respond principles
The respond principles are:
- **RESPOND-1:** Cybersecurity incidents are reported internally and externally to relevant bodies and stakeholders in a timely manner.
- **RESPOND-2:** Cybersecurity incidents are analysed, contained, eradicated and recovered from in a timely manner.
- **RESPOND-3:** Incident response, business continuity and disaster recovery plans support the recovery of normal business operations during and following cybersecurity incidents.
### Maturity modelling
When implementing the cybersecurity principles, an organisation can use the following maturity model to assess the implementation of individual principles, individual functions or the cybersecurity principles as a whole. The five levels of the maturity model are:
- **Incomplete:** The cybersecurity principles are partially implemented or not implemented.
- **Initial:** The cybersecurity principles are implemented, but in a poor or ad hoc manner.
- **Developing:** The cybersecurity principles are sufficiently implemented, but on a project-by-project basis.
- **Managing:** The cybersecurity principles are established as standard business practices and robustly implemented throughout the organisation.
- **Optimising:** A deliberate focus on optimisation and continual improvement exists for the implementation of the cybersecurity principles throughout the organisation.
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Cybersecurity basics: industrial security fundamentals
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https://iebmedia.com/technology/cybersecurity/cybersecurity-basics-industrial-security-fundamentals/
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cybersecurity fundamentals principles
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The fundamentals of industrial cybersecurity are based on key principles including confidentiality, integrity and availability. Cybersecurity often seems like an invincible Hydra but, with practical guidelines, users can setup systems and create strategies that significantly strengthen the security of company networks.
Cybersecurity is a bare necessity, that much is clear. What is less clear, however, are the basic principles that form the foundation of a strong and effective cybersecurity strategy. If they are missing, the entire concept is rickety.
## Part One: Confidentiality, Integrity and Availability
C.I.A. – these three letters stand for the classic understanding of cybersecurity. Even if others are sometimes added, these three form the core. The C stands for confidentiality. This means that only the authorised parties involved are allowed to read the content. The I stands for integrity, which states that the content of a message may not be changed. In addition, the A is availability: a message must be available for exactly as long as necessary, neither longer nor shorter.
When it comes to IT security, these three aspects are considered equally important. In the area of OT, though, availability is the top priority. After all, if there are interruptions in a production line, this can result in vast financial costs. In an operating theatre, it can even be a matter of lives. This means that in the area of OT, not only the threat must be evaluated, but also the effects of security measures.
In an OT network, Principle C (confidentiality) requires the data flow between sensors, controllers and other devices in an OT network to be encrypted, e.g. by using TLS/SSL, so that no unauthorised party can access sensitive information. This might also include the encryption of firewall configurations that contain confidential details about the network’s security design. I for integrity demands that only subscribed or purchased operating systems and software are run on the hardware – also known as secure boot. Moreover, A for availability refers to a network concept that guarantees redundancy to rule out a single point of failure (SPOF).
Controlling access to information ensures confidentiality and integrity. Here, it is important to distinguish between authorisation and authentication. Authentication is the process of checking whether a person or computer is actually who they say they are. This ensures everyone knows with whom they are sharing information. Authorisation, on the other hand, regulates the access rights or privileges of a person or software. Both – clearly defined authorisation guidelines and the systematic authentication of users – are crucial for preventing intrusions.
Following the fundamentals of cybersecurity management creates the discipline required within an organization.
## Types of threat – meaning well does not always equal doing well
The basis of a cybersecurity strategy also includes defining possible dangers. Obvious examples are powerful hacker organisations, international espionage and warfare. Still, this doesn’t mean that anyone who isn’t connected to the internet or company network is safe: around a fifth of threats arise from internal hazards. All it takes, for example, is a disgruntled, dismissed employee whose password hasn’t been changed. In Maroochy, an administrative area of Australia, for example, a worker hooked up the network of a water treatment plant to a Wi-Fi router before switching jobs. Years later, when he was rejected for a position at the town hall, he flooded the park with 1,000 litres of wastewater.
Yet, even with good intentions, employees can cause harm. In terms of security, it makes no difference whether the intention is malicious or not – it is the result that counts. With the dramatic rise in sophisticated social-engineering and deepfake-phishing attempts, the risk of an employee trying to help their manager in a supposedly threatening situation that is actually fake and malicious is growing. In 2019, a major American bank made headlines when it accidentally exposed over 800 million private data records, including driving licence details and bank statements.
Another myth that needs to be invalidated is the idea that it takes powerful supercomputers and the latest technology to cause significant damage. The reality is much simpler: crime is already offered “as a service”. According to Forbes , paralysing an internet-based asset for an hour on the darknet only costs USD 165, while you can obtain a valid credit card number linked to an account with at least USD 10,000 for as little as USD 25.
## Cat-and-mouse game
The rapid development of criminal cyberattacks with ever more complex and precise forms of intrusion poses a challenge for protective measures to keep pace. While brute-force attacks are still common, ransomware continues to grow and social engineering is becoming more sophisticated. Advanced persistent threats (APTs) are used to secretly collect private data over a longer period of time.
Once an attacker has found an easy victim, it is quite possible that they will look for further vulnerabilities. It is a well-known fact that it takes some time to make a weak infrastructure secure. However, even rudimentary cybersecurity measures can significantly reduce the potential extent of damage and the consequences of a successful attack.
## Dealing with vulnerabilities
In this context, it’s important to know how weak points are currently handled. During the development of a network component, they can be recognised at an early stage with static tests or peer reviews. Automated tests are used to check the system’s resistance to common attacks. Intrusion tests are also common practice, in which a third party attempts to systematically and exploratively circumvent the defence measures. Should a vulnerability be discovered in a new product, the manufacturer can fix it immediately. If the product is already on the market, the person carrying out the test usually notifies the manufacturer and gives them time to create a patch before publicising the problem via groups such as MITRE. Although such responsible disclosure is not required by law, it is standard practice in the security industry.
Not only are vulnerabilities publicly available, there are even free search engines that can be used to look for network equipment based on vulnerabilities. This means that weak points in devices and software are known to the public. It is crucial to identify which ones need a firmware update and to execute it in a timely manner.
Fundamentals of Defense in Depth strategies.
## Protection mechanisms
One common shield against online threats is encryption. It prevents information from being intercepted during the communication between two nodes. For example, a Wi-Fi connection can be tapped, but if it uses WPA encryption, the transmitted content cannot be deciphered. Communication via open networks, e.g. in hotels or airports, must be encrypted to maintain confidentiality. However, even if the communication is private, e.g. between employees working from home, all intermediate networks that make up the internet must be considered a threat.
Another encryption application is signatures. In contrast to symmetric encryption, which uses the same key for encryption and decryption, asymmetric methods use different keys. This means that a communication can be encrypted with a secret key and anyone who decrypts it with the publicly available key can read its content. In addition, the recipient knows that the document originates from the owner of the secret key as the document bears a signature. This way, digital certificate authorities (CAs) can provide entities with certificates certifying the authenticity of this entity. This is the case, for example, with websites that use HTTPS. If their certificate is invalid, it cannot be decrypted with the CA’s public key. In this situation, the browser cannot verify the identity of the website and doesn’t display it. The reason is that the website could be an imitation of the original or a malicious intermediary between the user and the original website.
ARC Cybersecurity Maturity Model.
## Security at network topology level
There are further measures that make network topologies resistant to cyberattacks. In the OT sector, air gapping is frequently found. The internal network and the globally networked outside world are separated. Nevertheless, air gapping is no longer considered sufficient because many potentially dangerous actors are located internally. If no physical access control is used in conjunction with air gapping – i.e. control over who can enter the building – anyone can join the network via a USB stick or the Wi-Fi. And do the network engineers have a list of all the computers that have activated Bluetooth? Most of them do not. This means the network is open and connected.
The expression “castle with moat” uses a medieval metaphor to describe a network with extremely robust perimeter security. It is based on the assumption that the outside world is hostile, while the inside is secure. Unfortunately, this model is no longer up to date. Since the COVID pandemic at the latest, many people have been using VPNs to work from home. This blurs the “secure perimeter”: Does it include the home network? Is that secure?
A more advanced design is “defence in depth” with a multi-layer principle: each layer is slightly more secure than the last, with the most important operations and data that must not be compromised under any circumstances in the middle. The “defence in depth” method is the foundation for the Purdue model, which is also recommended in EU cybersecurity guidelines.
One modern architecture is SASE (Secure Access Service Edge). Here, all security functions, including authentication and authorisation, are not located in a central system, but at the edge of the network.
Device security checkpoints.
## Part Two: specific steps for more security in industrial automation
Cybersecurity often seems like the invincible Hydra, constantly growing new heads as soon as one has been cut off. However, with practical guidelines, you can defeat it and significantly strengthen the security of the company network.
## Threat modeling
The first step towards a stable cybersecurity framework is gaining a detailed overview of the existing network and identifying the potential vulnerabilities. To do this, it is advisable to catalogue critical assets, including all machines, systems, and areas in which intellectual property and/or confidential information is saved.
This is followed by a thorough assessment of the direct and indirect consequences of potential threats, allowing you to define a response strategy that reduces immediate risks and prevents long-term consequences. To this end, the risks associated with each identified threat are categorized. Possible responses are considered for each threat:
- _Acceptance_: some risks may be considered acceptable; thresholds are then used to determine the point up to which the risk is tolerable and monitoring is sufficient.
- _Damage containment_: a strategy to reduce the likelihood or impact of potential threats may include implementing security measures, protocols, and redundancies.
- _Elimination_: structural changes to the network, the integration of advanced security technologies and the removal of vulnerable components help eliminate risks from the start.
## Directives, laws, and standards
Compliance with EU directives, national laws and industry-specific cybersecurity standards is a must. However, by keeping up to date with regulations and guidelines, companies not only fulfil their legal obligations, but also increase their own security.
On this basis, it is also important to define governance rules. These should include the policies, procedures and protocols that govern day-to-day operations of industrial automation. Effective cybersecurity governance includes solid risk assessment, ongoing identification of cybersecurity risks and up-to-date guidelines based on industry standards. Integral components include access controls, defined responses to incidents, and the sensitization and training of employees.
Once the governance rules are in place, it is important to monitor them continuously and carry out regular security checks and assessments. This is the only way to identify and resolve new vulnerabilities.
## Setting up a resilient network
The fundamental step to a secure industrial automation network is to carefully assess the security requirements for each segment. Segmentation involves dividing the network into separate segments or zones to control traffic, improve security and mitigate potential attacks. Each segment can have its own security policies and access controls to increase security and minimize the risk of threats. This allows for a targeted security strategy focusing on specific parts of the network while improving overall system security.
When assessing each segment, consider the organization’s critical assets and confidential information, identify potential vulnerabilities, and assess the potential impact of security breaches on each segment. That way, each segment can be assigned a security level based on the probability and possible impact of a successful attack. Resources can thus be allocated effectively and protection prioritized where it is most urgently needed. On this basis, a plan for a secure network model can be created step by step.
To start with, it is advisable to begin with simple hygiene measures. These include regular software updates, password management, and basic access controls, e.g. restricting the use of certain resources to individual MAC addresses.
The next step will show solutions that are more sophisticated. According to the defense-in-depth principle, several layers of security measures can be combined to create a multi-layered defense strategy. A mix of firewalls, intrusion detection systems, and encryption is recommended.
By separating the floor plan from the corporate network with a DMZ (demilitarized zone), a buffer network, direct communication between the corporate and floor network is prevented and access is controlled with firewalls.
In addition, the isolation of critical segments is an important aspect for minimizing the movement and therefore the spread of threats within the network. To this end, the number of access points and the number of neighboring networks that can communicate with the most secure segments are kept to a minimum. This maintains the integrity of the entire network, even if one area is compromised.
Furthermore, authorization mechanisms should be adapted to the functional roles to ensure that people only have access to resources that are necessary for their tasks. It is advisable to separate administrative roles from other functions and thus strictly limit access to critical configurations and sensitive information.
## Software upgrades
It makes sense to approach the topic of software upgrades with a meticulous inventory of the firmware versions of all important devices. This demands caution, professionals should check the authenticity of upgrades with the respective provider. Otherwise, the door is open for counterfeit malware.
The upgrade process should be carried out in stages so that the effects of upgrades can be monitored and evaluated on a smaller scale before they are applied to the entire network.
In many cases, an immediate firmware update is not possible. The recommended alternative is virtual patching. This involves implementing security measures at network or application level so that no changes to the firmware are required. Hence, network traffic can be actively monitored, malicious patterns identified, and vulnerabilities prevented from being exploited by outdated firmware.
## Foster security awareness
In addition to technical measures, the human factor is crucial. Teams must be equipped with the necessary resources to master the intricacies of different types of attack. This starts with creating checklists and step by step procedures that act as practical guides for each type of attack. These materials should be simple and practical, and complex security measures should be broken down into practicable steps. This will enable cybersecurity specialists to empower other teams to respond effectively to threats.
In order to embed cybersecurity awareness in the minds of employees, regular training programs are needed that cover theoretical aspects as well as practical exercises on real-life scenarios.
The corporate culture is also an important pillar for security awareness, emphasizing an environment where team members can report security concerns without fear of reprisals, which is crucial. Placing blame for security incidents is counterproductive. Instead, the focus should be on understanding the causes and taking corrective action. Praise is also an effective way of encouraging positive behavior. Recognizing vigilance and responsiveness encourages employees to actively contribute to the safety of the company.
## Security in the ecosystem
A solid security strategy also takes all of the company’s partners into account. This starts with defining clear rules. Authentication should be one of the non-negotiable security aspects, as it is proof of the legitimacy of interactions within the industrial ecosystem. Of course, authentication protocols must comply with industry standards and regulations. Apart from that, partner assessments, audits and security practices should be continuously scrutinized by experts.
Based on the principle “Together we are stronger”, actively sharing threat intelligence and best practices is also recommended to ensure that security measures are mutually reinforcing.
## Network monitoring
The first step of network monitoring is gaining a comprehensive understanding of the activities within the industrial ecosystem. With the help of modern tools and technologies, network traffic, device interactions and communication patterns can be observed in real time. This allows anomalies, potential vulnerabilities, and unauthorized access to be detected.
Monitoring security breaches requires robust intrusion detection systems, log analysis, and an active search for signs of unauthorized access, malware, or other security breaches. This is where the aforementioned culture of encouraging employees to report security incidents comes into play.
Every security incident should be meticulously documented, even (seemingly) minor incidents. It is helpful to develop a standardized process for recording the details of the incident, the measures taken, and the lessons learned. Such documentation not only ensures compliance with regulations, for example during audits, official inspections, or internal reviews, but also provides valuable insights for the continuous improvement of cybersecurity.
## Continuous improvement
Cybersecurity is a never-ending task. With defined processes for continuous improvement, organizations create the preconditions for a continuous improvement cycle. This should include the regular review and refinement of security protocols, incident response procedures, and monitoring mechanisms. The evaluation should involve team members from different departments and hierarchical levels, and suggestions should be considered without reservation. Training programs, awareness campaigns, and collaboration frameworks should also be part of continuous improvement.
At the same time, the threat landscape is constantly changing. Active participation in threat intelligence networks and industry forums as well as continuous training help prepare people for evolving threats.
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The fundamentals of cybersecurity in the age of AI - Security Magazine
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https://www.securitymagazine.com/articles/101473-the-fundamentals-of-cybersecurity-in-the-age-of-ai
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cybersecurity fundamentals principles
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Cybersecurity Cyber Tactics, Logical Security Security & Business Resilience
### Cyber Tactics
# The fundamentals of cybersecurity in the age of AI
## Advanced technologies should complement, not replace, the fundamental principles of cybersecurity.
As we advance into 2025, the cybersecurity landscape continues to evolve at an unprecedented pace. While discussions around AI's potential to revolutionize security teams are omnipresent, it's crucial not to lose sight of the foundational elements that underpin effective cybersecurity. Among these fundamentals, Identity and Access Management (IAM) remains a cornerstone, ensuring that only authorized individuals can access sensitive information and resources.
This article explores the core principles of cybersecurity, emphasizing the vital role of IAM and how AI can enhance these foundational elements to create a robust security framework.
### The Pillars of Cybersecurity: Confidentiality, Integrity, and Availability
The fundamentals of cybersecurity can be organized into several key categories, providing a structured approach to implementing comprehensive security measures. One crucial category is Information Security (InfoSec), which encompasses the policies and procedures organizations use to protect their information assets. InfoSec is often built upon three primary objectives: Confidentiality, Integrity, and Availability (CIA).
- **Confidentiality:** Like safeguarding a secret, confidentiality ensures that sensitive data remains protected from unauthorized access. Encryption is like putting information in a secure, locked box that only the recipient with the key can open. Access Control Lists (ACLs) act as digital bouncers, determining who enters and what they can access. Identity Management is like issuing IDs and verifying who is allowed entry into specific areas.
- **Integrity:** Maintaining the accuracy and trustworthiness of data is paramount. Hashing acts like a tamper-evident seal; any change in the data alters its unique “fingerprint,” immediately signaling a breach. Version control, similar to tracking changes in a document, ensures that all modifications are recorded and reversible.
- **Availability:** Ensuring that systems and data are accessible when needed is crucial. Redundancy, like having a spare tire, provides backup systems to maintain continuous operation. Failover mechanisms automatically switch to a standby system in case of failure, like a power generator kicking in during an outage. Regular maintenance ensures smooth operation by preventing issues before they arise.
By focusing on core areas such as InfoSec and IAM, and leveraging AI where appropriate, organizations can build robust security frameworks that protect against evolving threats.
### IAM: Guarding Your Digital Kingdom
IAM is a crucial aspect of cybersecurity, focusing on ensuring that only authenticated and authorized individuals can access specific resources. It acts as the gatekeeper, controlling who gets in and what they can access. The two main components of IAM are Authentication and Authorization.
- **Authentication** is the process of verifying the identity of users or systems. Effective authentication ensures that users are who they claim to be, protecting systems from unauthorized access. Common methods of authentication include: - **Passwords:** The most traditional form of authentication, requiring users to provide a secret string of characters.
- **Biometrics:** Uses unique biological characteristics such as fingerprints, retina scans, or facial recognition to verify identity.
- **Multi-Factor Authentication (MFA):** Combines two or more independent credentials, such as something you know (password), something you have (security token), and something you are (biometric verification). This adds an extra layer of security, making it much harder for attackers to gain access.
- **Digital Certificates:** Utilizes a digital document that uses a digital signature to bind a public key with an identity. These are commonly used to secure websites and online transactions.
- **Authorization** determines and grants permissions and privileges to users or systems after authentication. Ensuring proper authorization is critical for protecting resources and data from internal and external threats. Common methods of authorization include: - **Role-Based Access Control (RBAC):** Assigns access based on a user's role within an organization, simplifying the management of individual permissions. For example, a “marketing manager” role might have access to marketing data and tools, while a “finance manager” role would have access to financial systems.
- **Policy Enforcement:** Implements policies that define what users can and cannot do within a system, ensuring adherence to organizational security policies.
### The Rise of AI in Cybersecurity
While adhering to cybersecurity fundamentals is crucial, leveraging AI can significantly enhance the effectiveness of these measures. AI technologies can assist in identifying and mitigating potential threats more efficiently than traditional methods.
For instance, AI-powered systems can enhance IAM by:
- **Providing adaptive authentication methods:** These analyze user behavior and context to dynamically adjust authentication requirements. For example, if a user tries to log in from an unusual location, the system might require additional authentication factors.
- **Detecting anomalies and suspicious activities:** AI algorithms can analyze vast amounts of data to identify patterns and anomalies that might indicate a security breach.
- **Automating security tasks:** AI can automate repetitive tasks such as vulnerability scanning and malware analysis, freeing up security teams to focus on more strategic initiatives.
AI can also assist in:
- **Strengthening data protection:** AI can be used to identify and classify sensitive data, ensuring that appropriate security measures are in place.
- **Improving incident response:** AI can help security teams respond to incidents more quickly and effectively by automating tasks such as threat analysis and containment.
### Embracing the Future: A Balanced Approach
As we navigate the complexities of cybersecurity in 2025 and beyond, it is essential to remember that advanced technologies such as AI should complement, not replace, the fundamental principles of cybersecurity. By focusing on core areas such as InfoSec and IAM, and leveraging AI where appropriate, organizations can build robust security frameworks that protect against evolving threats.
Embracing both the fundamentals and innovations in cybersecurity is key to creating a resilient and secure digital future.
KEYWORDS: artificial intelligence (AI) data protection digital security
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Top 10 cybersecurity best practices: Secure your organization's data
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https://www.infosecinstitute.com/resources/management-compliance-auditing/top-cybersecurity-best-practices-secure-organization-data/
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# Top 10 cybersecurity best practices: Secure your organization’s data
In 2024, having a robust cybersecurity program is as important — or more — than locking your home, car or office doors. However, with so many options for protecting your networks and data, it can be difficult to figure out the best strategy for you or your organization. But you can use these 10 cybersecurity best practices as your personal or business data protection checklist. This breakdown of 10 essential cybersecurity best practices clarifies what you should do and why it can be effective.
## 1\. Conduct regular security assessments
By conducting regular security assessments, you can identify vulnerabilities in your networks and devices. This is essential because you can use this information to develop a security plan to stop attackers from taking advantage of each weak spot.
Understanding how to conduct regular assessments also helps prepare you for cybersecurity certifications, including pinpointing and addressing vulnerabilities. From a career perspective, being adept at figuring out where attackers may try to access your digital assets is a valuable skill because it enables you to help an organization stay a step ahead of hackers.
How frequently should you conduct these assessments? Once every 3 to 6 months is a good starting point for analyzing how hackers may try to access your applications.
## 2\. Implement strong password policies
Strong passwords for apps and devices are like combination locks on safes: In most situations, they are your first line of defense against data thieves and other attackers. Like locks on safes, though, they are most effective when everyone is using the safe and making sure they keep the safe secure at all times. That’s why it’s crucial to implement secure password protocols for your entire organization, including:
- Requiring employees to use a password manager
- Create and generate longer passwords, even requiring employees to have a minimum length to all passwords they use
- Protect your company from breached passwords that criminals have already figured out. Many password management platforms create alerts when passwords saved in your account match with passwords found in data breaches. A company’s IT department may be able to standardize this process
- Use salting and hashing. Salting is when you add extra info to passwords, and hashing is turning a plain password into code
- Don’t use password hints because they can make it easier for attackers to figure out your password. And if you must use password hints on certain platforms, remind your employees to avoid online polls and quizzes involving personal details – hackers frequently start these threads and then go back to harvest possible password hints from the replies!
- Don’t change your password frequently if it will lead to frustration and creating an easy-to-guess password. Better yet, use a password manager and allow it to create a complex password using randomized numbers, letters, and symbols
- Limit the number of attempts allowed to enter a password, which can prevent hackers from executing brute-force attacks
## 3\. Utilize multi-factor authentication (MFA)
Multi-factor authentication (MFA) involves using something you know, such as a password, something you have, like a phone or tablet, and/or something you are, such as a biometric element like a fingerprint. By incorporating two or more of these elements, you make it far more difficult for a hacker to access an account, an app, or a device because it’s unlikely that they’ll have access to the necessary credentials.
While some canny hackers are finding inventive ways to circumvent MFA, moving your organization to Multi-Factor Authentication procedure across the board can prevent the majority of hacks connected to stolen passwords.
## 4\. Keep software and systems updated
Updates and patches are essential because they give you more secure versions of applications, those that manufacturers have released after they’ve addressed vulnerabilities. A quick patch or update can make the difference between an attack, leading to expensive down-time, and smooth sailing.
For example, in the Equifax breach, a hacker figured out that the company was running an unpatched version of the Apache Struts software on its server that was facing the internet. Sadly, the vulnerability had been discovered and addressed two months prior. So, if Equifax had simply implemented a free patch, the breach may never have happened.
## 5\. Employ firewalls and network security tools
Firewalls protect your network by monitoring the traffic that goes in and out of them, preventing suspicious data from moving through your system. Other network security protocols and tools can identify malicious traffic, monitor networks for suspicious activity, and execute mitigation strategies to automatically prevent damage from attacks.
These tools play a critical role in a comprehensive cybersecurity strategy because they give you automated protection that runs 24/7/365 without needing intervention. You can also configure the settings of firewalls and other network security tools to address specific threats and improve accessibility and throughput across your systems.
## 6\. Develop and test a disaster recovery plan
Disaster recovery (DR) strategies are an essential thread in your cybersecurity fabric because they help you maintain continuity in the wake of a disaster or breach. For example, some companies have redundant applications that they can access via the cloud if their on-premises solution fails or gets hacked. In this case, if an organization constantly backs up application data to a cloud instance, its teams will experience minimal downtime in the event of a breach.
Having disaster recovery expertise is also helpful when pursuing certifications and cybersecurity careers because knowing how to maintain continuity gives you a reliable fail-safe if your systems get compromised. Certification exams often have questions regarding disaster recovery, and for organizations of all sizes, job candidates with DR experience have a skill that’s worth its weight in gold!
## 7\. Provide regular security awareness training
When you train your employees regarding cybersecurity threats and how to mitigate them, you transform them from potential victims to soldiers on your front line of defense. You also give yourself a human threat monitoring system once they understand what threats look like and who to report them to. To strengthen your security awareness training, you can incorporate:
- Micro-learning, which involves covering a single topic in 20 minutes or less
- In-the-moment training, where an employee encounters a phishing simulation with a safe, simulated version of threat, while their response (either reporting the unsafe link or document or clicking it) is logged and can be used to drive future training
- Role-based learning, which focuses on teaching people how to deal with the threats they’re most likely to encounter in their specific, day-to-day activities
## 8\. Use VPNs for secure connections
A virtual private network (VPN) creates a secure tunnel through which data can travel by encrypting traffic that moves through it. As the data enters the VPN, it gets encrypted and stays encrypted until it exits the other side. In this way, if a hacker were to intercept one or more data packets, they wouldn’t be able to understand their contents.
From a cybersecurity perspective, VPNs give you a safer way to connect with remote employees and enable on-premises workers access to remote systems, such as those in the cloud. For example, you can provide remote and hybrid workers with access to a VPN that they can use to work within your network while outside of the office. If an attacker were to try to intercept data before it enters your network, they would only get a confusing mix of characters.
## 9\. Conduct penetration testing
Penetration testing is an effective way of identifying a network’s vulnerabilities because it can reveal soft spots in your cyber defenses that may otherwise go unnoticed. For example, you may have a firewall that can’t detect the most recent threats; a penetration tester armed with the right malware can uncover this vulnerability.
Penetration testing skills can be extremely valuable for your cybersecurity career because they enable you to double-check the effectiveness of an organization’s security system. Having an internal employee skilled in penetration testing is crucial because it prevents a company from having to hire an external pen tester and speeds up the process of beginning a pen test.
## 10\. Monitor networks for suspicious activity
Continuous monitoring is important because it gives you a constant stream of data regarding the health of your network and the nature of the attacks it encounters. You can use this data to adjust your cybersecurity tools and configurations, thereby shrinking your attack surface.
Several certifications, such as the AWS Certified Advanced Networking – Specialty and CompTIA Network+, cover network monitoring. There is also no shortage of network monitoring software that can check your network’s performance, availability, traffic, and security status.
## Role of cybersecurity certifications and training
Cybersecurity certifications and the training programs that help you prepare for them are often viewed by hiring managers as significant bonuses because they validate your knowledge of the job roles’ best practices. Instead of merely claiming that you understand how to protect networks and data, holding a certification serves as objective proof of your abilities.
For instance, you can use Infosec’s “How to do application security right” learning path to learn how to hack your own computer to reveal vulnerabilities. You can also check out the top penetration testing certifications to find the one that best fits your career goals. If you’re interested in becoming an analyst who leverages network monitoring tools, you can investigate getting your CySA+ certification.
Regardless of the nature of your network, all employees should understand the basics of cybersecurity, such as how to avoid phishing, how to use multi-factor authentication, engaging the company’s VPN, and understand the dangers of malware and ransomware attacks.
### Use these time-tested best practices to strengthen your security
The 10 best practices include:
- Conducting regular security assessments
- Implementing strong policies
- Using MFA
- Keeping your software and systems updated
- Using firewall and network security tools
- Leveraging disaster recovery plans
- Providing regular security awareness training
- Using VPNs
- Conducting penetration testing
- Monitoring network for suspicious activity
Each of these strategies involves taking a proactive approach to cybersecurity, which is essential for reducing attack risk. To protect your network and the assets connected to it, it’s best to stay informed and commit to continuously improving your cybersecurity measures.
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Data Security Best Practices: Key Strategies for Effective Protection
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https://www.acceldata.io/blog/data-security-best-practices-key-strategies-for-effective-protection
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information security best practices
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Data Engineering
# Data Security Best Practices: Key Strategies for Effective Protection
Safeguarding sensitive information has become an uphill task for businesses in today's hyper-connected, data-driven landscape, where threats evolve faster than defenses can keep up.
According to IBM’s 2024 Data Breach report, the average cost of a data breach exceeds $4.88 million a year. This underscores the significant financial and reputational damage resulting from inadequate security measures.
Businesses rely on data for analytics, growth strategies, and decision-making; therefore, securing this data is of utmost importance.
This article provides guidance on essential data security best practices to safeguard your organization’s confidential information from potential threats.
## Understanding Data Confidentiality
Data confidentiality refers to the protection of sensitive information from unauthorized access. It ensures that only those with proper credentials/rights can access critical data, such as customer details, intellectual property, and financial records.
Data confidentiality is particularly vital in industries such as healthcare and finance, considering the sensitive nature of the information involved. Failure to implement strong confidentiality practices can lead to significant breaches, legal penalties, and loss of trust.
### Identifying the right data for confidentiality protection
Not all data carries the same level of sensitivity. Companies must implement data classification systems to prioritize data security efforts. Information such as customer personal data, intellectual property, employee records, and financial data require the highest level of protection.
A thorough business impact analysis can help assess data that needs additional security measures, ensuring that the most sensitive information is adequately protected. Once identified, such data should be secured with the help of the various security measures available in the market.
Eager to find out how your enterprise can safeguard its financial data?
Learn how we solve it!
## Best Security Practices to Protect Data Confidentiality
Companies can effectively secure data by adhering to established best practices that have proven to be effective. The following methods ensure your data remains well-protected against potential threats:
### 1\. Data encryption
Data encryption is the process of converting data into a coded format that can only be accessed or decrypted by someone with the correct encryption key. This ensures that the data remains unreadable if intercepted or stolen by unauthorized individuals.
**How to achieve it**
To implement effective encryption, businesses must:
- Use Advanced Encryption Standard (AES) with a 256-bit key, which is considered the gold standard.
- Ensure encryption both at rest (stored data) and in transit (data being transmitted over a network).
- Employ encryption key management protocols to safeguard and rotate encryption keys regularly.
**How does it secure your confidential data?** Encryption significantly enhances data security by making stolen or intercepted data unusable without the decryption key. However, mere encryption isn’t enough; it must be supplemented with other security measures, such as strong access controls.
### 2\. Access control mechanisms
Access control mechanisms are policies and technologies used to restrict access to sensitive data. They ensure that only authorized users can view or edit specific data, depending on their role within the organization.
A study by Microsoft found that 99.9% of compromised accounts did not use multi-factor authentication (MFA). This emphasizes the importance of access control in securing confidential data.
**How to achieve it**
To implement robust access control mechanisms:
- Use multi-factor authentication (MFA), which requires users to verify their identity with multiple methods such as a password and mobile authentication app.
- Implement Role-based Access Control (RBAC), which limits access based on a person’s role within the organization.
- Conduct regular audits to ensure access permissions are up-to-date and appropriate for each user’s role.
**How does it secure your confidential data?** Access control mechanisms significantly reduce the risk of data exposure by ensuring that only authorized personnel have access to sensitive information. Combining MFA and RBAC can further strengthen data confidentiality by adding layers of verification.
### 3\. Regular security audits and monitoring
A security audit is a systematic evaluation of an organization’s information system to identify vulnerabilities. On the other hand, continuous monitoring involves real-time surveillance of network activity to detect unauthorized access attempts.
**How to achieve it**
- Conduct annual or bi-annual security audits to identify system vulnerabilities, outdated software, or improper access control settings.
- Use real-time Intrusion Detection Systems (IDS) and Security Information and Event Management (SIEM) tools to monitor system activity and alert IT teams to any suspicious behavior.
- Implement automated alerts for any unauthorized access or unusual activity, enabling swift responses to potential breaches.
**How does it secure your confidential data?** Regular audits and continuous monitoring are essential for identifying and mitigating vulnerabilities before they can be exploited, ensuring that unauthorized access is quickly detected and addressed.
### 4\. Data masking and anonymization
Data masking replaces sensitive information with fictional data that looks real, while anonymization removes personally identifiable information (PII) entirely. These techniques are commonly employed for sharing data in non-production environments or for analytics, ensuring that data privacy is not compromised.
**How to achieve it**
- Implement dynamic data masking, which automatically masks sensitive data when accessed by unauthorized users or in non-production environments.
- Use anonymization techniques when analyzing large datasets for trend analysis to prevent the exposure of PII.
**How does it secure your confidential data?** Data masking and anonymization protect confidential information by making it unreadable in testing, analysis, or non-secure environments. They allow organizations to safely work with sensitive data without risking exposure.
### 5\. Employee training and awareness
Training employees in data security best practices ensures that everyone in the organization understands the policies, risks, and tools necessary to protect confidential information. Training programs cover areas such as identification of phishing attempts, usage of strong passwords, and safe handling of sensitive data.
According to a report presented at the Git Security Summit, human error contributes to 82% of data breaches, with phishing attacks and poor password management being common causes.
**How to achieve it**
- Conduct regular cybersecurity training sessions to educate employees about emerging threats such as phishing scams and ransomware.
- Implement mandatory password management policies that require employees to create strong, unique passwords and enable multi-factor authentication (MFA).
- Foster a security culture by encouraging secure behaviors through incentives and providing regular updates on best practices.
**How does it secure your confidential data?** Employee training plays a key role in minimizing human errors, a leading cause of data breaches. Educating employees about security threats and best practices strengthens the overall security of confidential data.
### 6\. Backup security and disaster recovery
Backup security entails safeguarding copies of data to ensure their availability in the event of data loss or breaches. Disaster recovery plans outline the procedure for restoring data and maintaining operations after a security incident or system failure.
**How to achieve it**
- Ensure all backups are encrypted to protect sensitive information in the event of a data breach.
- Store backups in secure, off-site locations or use cloud-based backup solutions with built-in encryption and security.
- Develop a comprehensive disaster recovery plan that includes regular testing, detailed recovery procedures, and clear roles for all team members.
**How does it secure your confidential data?** Secure backups and a robust disaster recovery plan ensure that critical data remains protected and recoverable in the event of a breach or data loss, minimizing downtime and mitigating damage.
Implementing these data security best practices—encryption, access control mechanisms, regular audits, data masking, employee training, and secure backups—can help organizations effectively safeguard confidential data from internal and external threats. These practices form the foundation of a comprehensive security strategy, ensuring long-term data protection and minimizing the risk of costly breaches.
## Leveraging Advanced Tools for Better Data Security
Businesses increasingly store data in the cloud; therefore, advanced tools such as AI and machine learning are critical for enhancing data confidentiality.
AI-driven security solutions analyze large datasets, detect anomalies, and alert IT teams in real time. This proactive approach enables faster responses to suspicious activities, as companies that leverage AI can detect and block breaches more swiftly than those that do not.
IBM integrates AI into its security solutions, such as IBM QRadar Suite, which uses machine learning to detect and respond to threats in real time. QRadar analyzes large volumes of security data to identify anomalies and reduce response times.
Cloud platforms such as AWS also offer built-in encryption and compliance features. These solutions provide multi-layered security, ensuring that encrypted data remains safe in case of unauthorized access.
AI automation significantly reduces human error, a leading cause of data breaches. These tools manage routine tasks such as monitoring data flow and applying patches, reducing the risk of oversight and underscoring the importance of AI in protecting critical business data.
Businesses can better protect their sensitive information and respond more efficiently to emerging threats by integrating these technologies.
## How Acceldata Optimizes Data Confidentiality for Enterprises
Acceldata’s platform provides real-time monitoring combined with built-in AI capabilities, allowing enterprises to track data access and movement effectively. Businesses can implement customizable security protocols to ensure that only authorized individuals have access to sensitive information.
Acceldata's data observability features assist companies in meeting regulatory requirements while boosting security, making it an essential element of any data confidentiality strategy.
Looking to track data access and boost data security with built-in AI capabilities?
Learn More!
## Strengthening Your Data Fortress
Implementing data security best practices is crucial for safeguarding sensitive information today. Businesses can reduce the risk of data breaches and maintain data confidentiality by utilizing encryption, access control mechanisms, regular audits, and cutting-edge security tools.
Building a strong data security framework ensures operational continuity, fosters customer trust, and helps businesses stay competitive in the digital era. Request a demo today to discover how Acceldata’s platform can enhance your data security strategy.
## Summary
Prioritizing data confidentiality is crucial for organizations in today’s environment, as the increasing volume of sensitive data heightens the risk of breaches, legal challenges, and reputational damage. Implementing key data security best practices is essential to safeguarding this data.
Businesses can prevent data breaches, maintain customer trust, and meet regulatory requirements by adopting a robust security framework. Investing in strong data confidentiality measures not only mitigates risks but also ensures that organizations remain competitive in an increasingly data-driven world.
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A comprehensive guide to cyber security protocols and best practices
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https://www.dataguard.com/blog/cyber-security-protocols-and-best-practices/
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information security best practices
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Cyber security Security best practices Cybersecurity measures
# A comprehensive guide to cyber security protocols and best practices
DataGuard Insights
Cybersecurity has never been more important, with cybercrime constantly evolving and new threats emerging every day. From malware to ransomware, the stakes are high when it comes to protecting both your personal and professional data.
**In this article, we'll break down the most common cyber threats, including insider risks, and share practical strategies to help you strengthen your defenses. You'll also learn about key protocols like incident response and workplace security best practices. By the end, you'll have the tools and insights you need to protect your data, build customer trust, and keep your business secure**
In this blog, we'll cover:
- Understanding cyber security
- Types of cyber attacks
- Best practices for cyber security
- Protocols for cyber security
- Cyber security in the workplace
- Frequently asked questions
## Key Takeaways
- Cybersecurity is crucial in protecting personal information and preventing cyber attacks, especially for remote employees.
- Strong passwords, regular software updates, and multi-factor authentication are key best practices for cybersecurity.
- Implementing protocols such as firewalls, network segmentation, and data encryption can greatly enhance cybersecurity practices.
## Understanding cyber security
Organisations are increasingly affected by threats such as cyber attacks, ransomware, phishing, and insider threats.
As reliance on cloud environments and cloud security continues to rise, implementing effective cybersecurity practices becomes crucial for safeguarding sensitive data and maintaining customer trust, particularly in the context of evolving cybersecurity regulations and privacy standards.
In this high-stakes environment, adopting proactive incident response protocols and robust data protection strategies is vital to mitigate financial losses and protect sensitive information from malicious actors, especially in the context of remote work.
### Defining cyber security and its importance
Cybersecurity is a multifaceted field dedicated to protecting systems, networks, and sensitive data from digital attacks, ensuring the integrity, confidentiality, and availability of information, and combating cybercrime.
It involves measures such as firewalls, intrusion detection systems, and encryption protocols, all working together to defend against unauthorised access and data breaches, which are increasingly facilitated by IoT devices. For organisations, it not only protects valuable intellectual property but also fosters customer trust and ensures regulatory compliance with evolving privacy regulations.
Conversely, inadequate cybersecurity measures can result in severe repercussions, including financial losses, reputational damage, and legal penalties that can jeopardize customer trust.
### This article's just a snippet—get the full information security picture with DataGuard
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## Types of cyber attacks
Cyber attacks come in many forms, all designed to compromise your security and disrupt business operations. These attacks can lead to serious financial losses and damage your organization's reputation, making it critical to train employees and stay prepared.
Let's have a look at the most common types of cyber attacks:
They include malware, phishing, and ransomware, each presenting unique challenges to your organization's cybersecurity efforts, especially in the context of remote work.
Malware refers to a variety of malicious software designed to disrupt, damage, or gain unauthorised access to computer systems. This category includes common variants such as viruses, worms, and Trojans.
Phishing, on the other hand, often targets employees through deceptive emails that trick individuals into revealing sensitive information, including passwords and credit card numbers.
Ransomware attacks are particularly concerning, as they not only encrypt data but also threaten to expose it, putting organisations that rely heavily on their digital assets in a precarious position.
Staying vigilant and implementing strong security measures, like continuous monitoring, are key steps in protecting your business from these ever-present threats.
## Best practices for cyber security
How do you safeguard your organisation? Let's have a look at the best practices for cyber security. Implementing approved measures helps your organisation to safeguard against evolving threats and ensure the integrity of your networks and sensitive data, particularly in the context of cloud security.
By prioritising these practices, you can effectively protect your assets and maintain trust with stakeholders, ensuring compliance with privacy regulations.
### Implementing strong passwords
Implementing strong passwords is a fundamental element of effective user authentication and a critical aspect of cybersecurity practices, especially in the context of remote work.
For both individuals and organisations, understanding the best practices for password creation is essential to safeguarding sensitive information in compliance with privacy regulations. It is advisable to use a combination of uppercase and lowercase letters, numbers, and special characters to ensure that passwords are complex and difficult to guess, promoting better user authentication.
Incorporating password managers can significantly streamline this process, allowing you to generate and store unique passwords for various accounts without the risk of forgetting them. This approach not only reduces the likelihood of password reuse—a common pitfall—but also enhances overall security, particularly in a cloud security environment.
Regularly updating passwords and enabling multi-factor authentication further strengthens your defenses against potential breaches, particularly in the context of remote work.
### Regular software updates
Regular software updates are essential for maintaining network security and protecting against potential vulnerabilities that cyber threats may exploit, especially when utilising cloud infrastructure.
Keeping operating systems, applications, and security tools current is vital not only for optimal performance but also for safeguarding sensitive data within your cloud environments. When updates are deployed, they typically include important patches that address known security loopholes, which malicious actors actively seek to exploit, including those operating through IoT devices. By ensuring that all software is up-to-date, you can significantly reduce your risk of falling victim to malware, ransomware, and other cyberattacks through improved threat detection.
The latest versions often introduce advanced features and enhancements that improve the overall user experience, making it imperative to prioritise this ongoing maintenance as part of a comprehensive cybersecurity strategy that includes security audits.
### Two-factor authentication
Two-factor authentication (2FA) provides an additional layer of security for access management, significantly reducing the risk of unauthorised access to sensitive data.
By requiring users to present two distinct forms of identification—typically something they know, like a password, combined with something they possess, such as a mobile device—organizations can strengthen their defenses against potential breaches and reinforce security policies. This dual approach not only verifies user identities more effectively but also enhances user trust, as individuals are more confident knowing their personal information is better protected, fostering a culture of security awareness.
Implementing 2FA can be a straightforward process, utilising tools and applications that are already available, making it a practical choice for businesses aiming to enhance their cybersecurity strategies while ensuring compliance with cybersecurity regulations.
## Protocols for cyber security
The next thing on your list should be protocols for cyber security.
Implementing comprehensive measures not only protects sensitive information but also enhances overall operational integrity, particularly within the context of cloud security.
### Firewalls and antivirus software
Firewalls and antivirus software are essential security measures that establish a barrier between trusted internal networks and untrusted external networks, crucial for network security.
By monitoring and controlling incoming and outgoing network traffic, these tools effectively prevent unauthorised access and safeguard sensitive data from malicious attacks. Firewalls function as gatekeepers, filtering traffic based on predetermined security rules, while antivirus software scans for, identifies, and removes harmful software that could compromise system integrity, emphasizing the need for security audits.
Implementing these security layers is crucial for any organization committed to maintaining robust cybersecurity protocols. Best practices include:
- Regularly updating software to counteract emerging threats
- Employing a layered security strategy
- Educating users about potential phishing or malware risks
This approach ensures comprehensive coverage against evolving cyber threats.
### Network segmentation
Network segmentation is a critical security measure that involves dividing your computer network into smaller, isolated segments to enhance security and manage insider threats, while ensuring compliance with privacy regulations.
By implementing this strategy, your organisation can effectively reduce the attack surface, making it more difficult for cyber adversaries to access sensitive data and improving threat detection. Each segment operates independently, which not only limits lateral movement within the network during a breach but also aids in complying with regulatory standards related to data protection.
Segmentation allows for more efficient monitoring of traffic and user behaviour, enabling you to swiftly identify anomalies. Ultimately, this approach not only enhances overall network reliability but also provides robust safeguards against data breaches, reinforcing your organisation's defence mechanisms against various cyber threats.
### Data encryption
Data encryption is a cybersecurity practice that transforms sensitive data into a secure format, rendering it unreadable to unauthorised users. This process not only protects personal and financial information but also plays a vital role in maintaining the integrity of your organisation’s data, especially in the context of digital transformation.
With various encryption techniques available, including symmetric and asymmetric algorithms, you can select the most suitable method to safeguard your information. Adhering to regulatory compliance standards such as GDPR and HIPAA is essential for organisations handling sensitive data, as encryption aids in meeting these legal requirements while fostering trust among clients and customers in the evolving cybersecurity landscape.
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## Cyber security in the workplace
Cybersecurity in the workplace needs a comprehensive approach that includes employee training, strict adherence to cybersecurity regulations, and the implementation of robust security policies to safeguard sensitive data, ensuring a secure infrastructure.
### Employee training and education
Employee training and education are essential elements of a robust cybersecurity strategy, equipping staff to recognize and respond effectively to potential cyber threats.
In today's landscape of increasingly sophisticated cyberattacks, it is imperative for organisations to implement comprehensive training programmes that address a range of critical topics. Employees should be trained to identify the tell-tale signs of phishing attempts, allowing them to spot suspicious emails and avoid falling victim to scams. A solid understanding of vital security measures, such as multi-factor authentication and secure password management, is also crucial for safeguarding sensitive information.
Familiarity with cybersecurity regulations like GDPR and HIPAA not only ensures compliance but also promotes a culture of security awareness throughout the organisation.
### Creating a cyber security plan
Building a solid cybersecurity plan protects your organisation from growing threats, especially with the rise of IoT devices. A well-thought-out plan helps you manage risks and stay ahead of potential attacks while ensuring you're compliant with security regulations and policies
This plan should begin with a thorough threat assessment, where you identify potential vulnerabilities in your system and evaluate the likelihood of various cyber threats, including those posed by AI and machine learning. Following this, you must establish an incident response strategy to outline procedures for detecting and addressing security breaches promptly, thereby minimising damage.
Continuous monitoring is crucial; employing real-time analysis tools allows you to stay alert to unusual activities and swiftly adapt to the ever-evolving landscape of cyber threats. By integrating these key components, you can develop a robust cybersecurity framework that fosters a secure environment for both operations and data integrity.
Book your free consultation
## Frequently asked questions
### What are cyber security protocols and why are they important?
Cyber security protocols are procedures and guidelines put in place to protect computer systems and networks from unauthorised access, attacks, and damage. They are important because they help prevent cyber attacks, maintain data confidentiality and integrity, and ensure the availability of systems and networks.
### What are some common cyber security protocols, including **VPN** and **cookie acceptance**?
Some common cyber security protocols include firewalls, antivirus software, encryption, multi-factor authentication, regular software updates and patches, **VPN**, and regular backups of data.
### Why is it important to have strong passwords as a part of cyber security protocols?
Strong passwords are an essential part of cyber security protocols because they help prevent unauthorised access to sensitive information. Weak passwords can easily be guessed or hacked, putting data and systems at risk.
### How often should cyber security protocols be reviewed and updated?
Cyber security protocols should be reviewed and updated regularly, at least once a year or whenever there are significant changes to the organisation's systems or network. It is important to stay vigilant and adapt to emerging security threats.
### What are some best practices for implementing cyber security protocols?
Some best practices for implementing cyber security protocols include educating employees on security awareness and safe online practices, regularly backing up data, implementing strong password policies, and regularly testing and updating security measures.
### Can cyber security protocols be applied to personal devices and accounts, particularly with the use of **IoT**?
Yes, cyber security protocols can and should be applied to personal devices and accounts as well. This includes setting strong passwords, regularly updating software and antivirus programmes, and avoiding suspicious links or emails. Personal information and devices are just as vulnerable to cyber attacks as business systems and networks.
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10 Cybersecurity Best Practices for US Businesses & Individuals
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https://www.fruitiongroup.com/resources/blog/10-cybersecurity-best-practices-for-us-businesses---individuals/
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# 10 Cybersecurity Best Practices for US Businesses & Individuals
In this blog:Cyber and Information SecurityCyber Security
With financial damage caused by cybercrimes expected to reach $10.5 trillion by the end of 2025, cyber security has become a matter of survival for US businesses.
What do businesses and individuals need to do to be on the safe side? The answers lie within the following page.
In this guide, we will take you through 10 essential cybersecurity best practices, explaining what they are, how you can implement them and what can be the consequences if you ignore them.
## Conduct Regular Cyber Security Audits
Just like your annual medical check-up, cybersecurity audits are a critical instrument that ensure nothing, no matter how small, goes unnoticed. Regular audits can drastically reduce the risk of breaches in your business.
From an employee clicking unchecked, unnecessary links to a poorly configured firewall, cybersecurity audits help you identify and patch weak spots in your IT infrastructure, before someone else finds them.
Here's how to perform a cyber security audit…
- Identify and enlist all digital assets – PCs, servers, cloud accounts, IoT devices and endpoints.
- Go through the logs to identify any instance of suspicious access.
- Hire penetration testers, a.k.a., ethical hackers to simulate real-world attacks on each device to find weak spots.
Failing to identify vulnerabilities can be catastrophic. These days it seems like there’s a new breach that hits the news every day. Don’t let this be you.
## Monitoring & Detecting Cyber Threats in Real Time
The most critical aspect of cybersecurity is early identification of attacks and penetration. More often than not, cyber attacks are stealthy, with attackers spending months within a network unnoticed before launching an attack.
If you can detect a breach early, you can stop it before anything happens.
But how can you detect it?
- Use security information and response solutions to monitor endpoints in real time.
- Keep an eye on suspicious activities. Someone logging in from a server in Russia? Block it. Someone using a Virtual Private Network (VPN)? Block it.
Remember, cyber security is mostly about detection. Once detected, you have multiple ways to instantly mitigate the attacks.
## Multi-Factor Authentication (MFA)
Weak passwords are one of the most vulnerable aspects of cyber security.
Around 80% of breaches stem from stolen or weak credentials. Hackers use brute-force attacks, credential stuffing and phishing to steal login information.
MFA or Multi Factor Authentication is one of the most effective best practices for cyber security threats posed by password vulnerabilities. It adds a second layer of defense in case passwords are compromised.
Here are a few things that can be used as MFA.
- Something You Know - A second password or PIN.
- Something You Have - A security key, smartphone app, e.g., Google Authenticator..
- Something You Are - Biometrics such as fingerprint, facial recognition and voice recognition.
A few advanced MFA tactics for maximum security include.
- Using FIDO2 keys such as YubiKey or Titan Security Key, as they are impossible to phish, unlike SMS codes.
- Implementation of adaptive MFA. These include AI-based authentication that adjusts security levels based on user behavior.
- Rotation of MFA methods every 90 days to prevent MFA fatigue.
Even a single leaked password can lead to a full system compromise. In 2021, hackers breached Colonial Pipeline via a single compromised password, causing fuel disruption across the US. Something so small, like a weak password, can cause huge repercussions – you and your workforce need to be aware of this.
## Patch Management – Our Only Defense Zero-Day Attacks
Unpatched software are weak points that provide easy access for cyber criminals into a network. 60% of data breaches result from outdated systems.
Patch management comes after cybersecurity audits. Maintaining the latest software updates allows you to patch vulnerabilities found in audits and close all backdoors into the system, making your defense stronger against potential threats.
Here's how to implement a patch management strategy…
- Patch Prioritization – Rank vulnerabilities by CVSS score or Common Vulnerability Scoring System.
- Virtual Patching – If an update isn't available, use web application firewalls (WAFs) or endpoint protection tools to mitigate the risk.
- Automated Patching – Use tools like WSUS, Ivanti or SCCM to push automated updates.
## Backup Your Data Backups
Ransomware attacks encrypt critical files—without backups, your data is gone unless you pay.
Here are a few cyber security practices to set up a rock-solid backup plan.
1. Follow the 3-2-1 rule.
- 3 copies of your data.
- 2 different storage types - cloud, & offline disk.
- 1 copy stored offline.
2. Immutable backups – use WORM (Write Once, Read Many) storage to prevent backup tampering.
If you don’t have backups, your only option is to pay the ransom that attackers often demand. This still doesn’t guarantee data recovery as it is down to the attacker's choice to give you everything back. 24% of ransomware victims who pay never get their data back.
## Encrypt Sensitive Data
Unencrypted databases can expose millions of customer records—leading to fines, lawsuits and reputational damage. Even if attackers steal your data, effective encryption prevents them from reading it.
Here's how to implement encryption.
- Use AES-256 encryption for files and database storage.
- Enable full-disk encryption using programs such as BitLocker or FileVault, on all company devices.
## Secure Your Network
Weak network security leaves businesses wide open to attacks too. Unsecured Wi-Fi, weak firewalls and outdated protocols make hacking easy.
For instance, unprotected RDP servers led to a ransomware explosion, with gangs like Ryuk and Conti targeting businesses and demanding millions in ransom.
Here's how to secure your network.
- Adopt a Zero Trust Approach – Require authentication for every access attempt.
- Use Next-Gen Firewalls (NGFWs) – Deploy Deep Packet Inspection (DPI) and Intrusion Prevention Systems (IPS).
- Disable unused ports & services – Close open ports like RDP (3389), SMB (445) and Telnet (23) to block attackers.
## Treat Cyber Security as a Separate Department
IT teams focus on system uptime, but cybersecurity teams focus on preventing breaches. Companies need a dedicated cybersecurity team.
You can build a cybersecurity team by hiring a Chief Information Security Officer (CISO) to lead security strategy. The CISO can then establish a Security Operations Center (SOC). You can also work with specialist hiring firms such as Fruition Group to hire top cybersecurity talent in the U.S.
## Implement Role-Based Access Control (RBAC)
Not every employee needs access to every system, and they shouldn’t. With 80% of data breaches linked to excessive access or insider threats, restricting access to only what’s essential can significantly reduce risk.
Here's how to implement RBAC.
- Follow the Principle of Least Privilege (PoLP). Give employees access to only the files, systems and data they need for their job.
- Use Identity & Access Management (IAM) tools like Okta, Microsoft Entra ID or AWS IAM.
- Regularly review and update permissions to ensure former employees and contractors don’t retain access.
## Secure Your Supply Chain
Your security is only as strong as the weakest link – and that weak link is often a third-party vendor. In 2023, 2,769 businesses reported cyberattacks related to their supply chain.
Here's how to ensure your supply chain is safeguarded.
- Vet third-party vendors – Require vendors to follow strict cybersecurity policies before granting access to systems.
- Limit integrations – Only allow essential connections between internal and external systems.
- Monitor vendor activity – Use tools like CyberGRX, BitSight or UpGuard to track third-party security risks.
## Final Thoughts
Cyber threats are evolving every day so your defenses need to evolve too. Implementing these 10 cybersecurity best practices will massively reduce your risk and protect your business from costly cyber breaches.
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A comprehensive guide to cyber security protocols and best practices
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https://www.dataguard.com/blog/cyber-security-protocols-and-best-practices/
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network security protocols
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Cyber security Security best practices Cybersecurity measures
# A comprehensive guide to cyber security protocols and best practices
DataGuard Insights
Cybersecurity has never been more important, with cybercrime constantly evolving and new threats emerging every day. From malware to ransomware, the stakes are high when it comes to protecting both your personal and professional data.
**In this article, we'll break down the most common cyber threats, including insider risks, and share practical strategies to help you strengthen your defenses. You'll also learn about key protocols like incident response and workplace security best practices. By the end, you'll have the tools and insights you need to protect your data, build customer trust, and keep your business secure**
In this blog, we'll cover:
- Understanding cyber security
- Types of cyber attacks
- Best practices for cyber security
- Protocols for cyber security
- Cyber security in the workplace
- Frequently asked questions
## Key Takeaways
- Cybersecurity is crucial in protecting personal information and preventing cyber attacks, especially for remote employees.
- Strong passwords, regular software updates, and multi-factor authentication are key best practices for cybersecurity.
- Implementing protocols such as firewalls, network segmentation, and data encryption can greatly enhance cybersecurity practices.
## Understanding cyber security
Organisations are increasingly affected by threats such as cyber attacks, ransomware, phishing, and insider threats.
As reliance on cloud environments and cloud security continues to rise, implementing effective cybersecurity practices becomes crucial for safeguarding sensitive data and maintaining customer trust, particularly in the context of evolving cybersecurity regulations and privacy standards.
In this high-stakes environment, adopting proactive incident response protocols and robust data protection strategies is vital to mitigate financial losses and protect sensitive information from malicious actors, especially in the context of remote work.
### Defining cyber security and its importance
Cybersecurity is a multifaceted field dedicated to protecting systems, networks, and sensitive data from digital attacks, ensuring the integrity, confidentiality, and availability of information, and combating cybercrime.
It involves measures such as firewalls, intrusion detection systems, and encryption protocols, all working together to defend against unauthorised access and data breaches, which are increasingly facilitated by IoT devices. For organisations, it not only protects valuable intellectual property but also fosters customer trust and ensures regulatory compliance with evolving privacy regulations.
Conversely, inadequate cybersecurity measures can result in severe repercussions, including financial losses, reputational damage, and legal penalties that can jeopardize customer trust.
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## Types of cyber attacks
Cyber attacks come in many forms, all designed to compromise your security and disrupt business operations. These attacks can lead to serious financial losses and damage your organization's reputation, making it critical to train employees and stay prepared.
Let's have a look at the most common types of cyber attacks:
They include malware, phishing, and ransomware, each presenting unique challenges to your organization's cybersecurity efforts, especially in the context of remote work.
Malware refers to a variety of malicious software designed to disrupt, damage, or gain unauthorised access to computer systems. This category includes common variants such as viruses, worms, and Trojans.
Phishing, on the other hand, often targets employees through deceptive emails that trick individuals into revealing sensitive information, including passwords and credit card numbers.
Ransomware attacks are particularly concerning, as they not only encrypt data but also threaten to expose it, putting organisations that rely heavily on their digital assets in a precarious position.
Staying vigilant and implementing strong security measures, like continuous monitoring, are key steps in protecting your business from these ever-present threats.
## Best practices for cyber security
How do you safeguard your organisation? Let's have a look at the best practices for cyber security. Implementing approved measures helps your organisation to safeguard against evolving threats and ensure the integrity of your networks and sensitive data, particularly in the context of cloud security.
By prioritising these practices, you can effectively protect your assets and maintain trust with stakeholders, ensuring compliance with privacy regulations.
### Implementing strong passwords
Implementing strong passwords is a fundamental element of effective user authentication and a critical aspect of cybersecurity practices, especially in the context of remote work.
For both individuals and organisations, understanding the best practices for password creation is essential to safeguarding sensitive information in compliance with privacy regulations. It is advisable to use a combination of uppercase and lowercase letters, numbers, and special characters to ensure that passwords are complex and difficult to guess, promoting better user authentication.
Incorporating password managers can significantly streamline this process, allowing you to generate and store unique passwords for various accounts without the risk of forgetting them. This approach not only reduces the likelihood of password reuse—a common pitfall—but also enhances overall security, particularly in a cloud security environment.
Regularly updating passwords and enabling multi-factor authentication further strengthens your defenses against potential breaches, particularly in the context of remote work.
### Regular software updates
Regular software updates are essential for maintaining network security and protecting against potential vulnerabilities that cyber threats may exploit, especially when utilising cloud infrastructure.
Keeping operating systems, applications, and security tools current is vital not only for optimal performance but also for safeguarding sensitive data within your cloud environments. When updates are deployed, they typically include important patches that address known security loopholes, which malicious actors actively seek to exploit, including those operating through IoT devices. By ensuring that all software is up-to-date, you can significantly reduce your risk of falling victim to malware, ransomware, and other cyberattacks through improved threat detection.
The latest versions often introduce advanced features and enhancements that improve the overall user experience, making it imperative to prioritise this ongoing maintenance as part of a comprehensive cybersecurity strategy that includes security audits.
### Two-factor authentication
Two-factor authentication (2FA) provides an additional layer of security for access management, significantly reducing the risk of unauthorised access to sensitive data.
By requiring users to present two distinct forms of identification—typically something they know, like a password, combined with something they possess, such as a mobile device—organizations can strengthen their defenses against potential breaches and reinforce security policies. This dual approach not only verifies user identities more effectively but also enhances user trust, as individuals are more confident knowing their personal information is better protected, fostering a culture of security awareness.
Implementing 2FA can be a straightforward process, utilising tools and applications that are already available, making it a practical choice for businesses aiming to enhance their cybersecurity strategies while ensuring compliance with cybersecurity regulations.
## Protocols for cyber security
The next thing on your list should be protocols for cyber security.
Implementing comprehensive measures not only protects sensitive information but also enhances overall operational integrity, particularly within the context of cloud security.
### Firewalls and antivirus software
Firewalls and antivirus software are essential security measures that establish a barrier between trusted internal networks and untrusted external networks, crucial for network security.
By monitoring and controlling incoming and outgoing network traffic, these tools effectively prevent unauthorised access and safeguard sensitive data from malicious attacks. Firewalls function as gatekeepers, filtering traffic based on predetermined security rules, while antivirus software scans for, identifies, and removes harmful software that could compromise system integrity, emphasizing the need for security audits.
Implementing these security layers is crucial for any organization committed to maintaining robust cybersecurity protocols. Best practices include:
- Regularly updating software to counteract emerging threats
- Employing a layered security strategy
- Educating users about potential phishing or malware risks
This approach ensures comprehensive coverage against evolving cyber threats.
### Network segmentation
Network segmentation is a critical security measure that involves dividing your computer network into smaller, isolated segments to enhance security and manage insider threats, while ensuring compliance with privacy regulations.
By implementing this strategy, your organisation can effectively reduce the attack surface, making it more difficult for cyber adversaries to access sensitive data and improving threat detection. Each segment operates independently, which not only limits lateral movement within the network during a breach but also aids in complying with regulatory standards related to data protection.
Segmentation allows for more efficient monitoring of traffic and user behaviour, enabling you to swiftly identify anomalies. Ultimately, this approach not only enhances overall network reliability but also provides robust safeguards against data breaches, reinforcing your organisation's defence mechanisms against various cyber threats.
### Data encryption
Data encryption is a cybersecurity practice that transforms sensitive data into a secure format, rendering it unreadable to unauthorised users. This process not only protects personal and financial information but also plays a vital role in maintaining the integrity of your organisation’s data, especially in the context of digital transformation.
With various encryption techniques available, including symmetric and asymmetric algorithms, you can select the most suitable method to safeguard your information. Adhering to regulatory compliance standards such as GDPR and HIPAA is essential for organisations handling sensitive data, as encryption aids in meeting these legal requirements while fostering trust among clients and customers in the evolving cybersecurity landscape.
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## Cyber security in the workplace
Cybersecurity in the workplace needs a comprehensive approach that includes employee training, strict adherence to cybersecurity regulations, and the implementation of robust security policies to safeguard sensitive data, ensuring a secure infrastructure.
### Employee training and education
Employee training and education are essential elements of a robust cybersecurity strategy, equipping staff to recognize and respond effectively to potential cyber threats.
In today's landscape of increasingly sophisticated cyberattacks, it is imperative for organisations to implement comprehensive training programmes that address a range of critical topics. Employees should be trained to identify the tell-tale signs of phishing attempts, allowing them to spot suspicious emails and avoid falling victim to scams. A solid understanding of vital security measures, such as multi-factor authentication and secure password management, is also crucial for safeguarding sensitive information.
Familiarity with cybersecurity regulations like GDPR and HIPAA not only ensures compliance but also promotes a culture of security awareness throughout the organisation.
### Creating a cyber security plan
Building a solid cybersecurity plan protects your organisation from growing threats, especially with the rise of IoT devices. A well-thought-out plan helps you manage risks and stay ahead of potential attacks while ensuring you're compliant with security regulations and policies
This plan should begin with a thorough threat assessment, where you identify potential vulnerabilities in your system and evaluate the likelihood of various cyber threats, including those posed by AI and machine learning. Following this, you must establish an incident response strategy to outline procedures for detecting and addressing security breaches promptly, thereby minimising damage.
Continuous monitoring is crucial; employing real-time analysis tools allows you to stay alert to unusual activities and swiftly adapt to the ever-evolving landscape of cyber threats. By integrating these key components, you can develop a robust cybersecurity framework that fosters a secure environment for both operations and data integrity.
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## Frequently asked questions
### What are cyber security protocols and why are they important?
Cyber security protocols are procedures and guidelines put in place to protect computer systems and networks from unauthorised access, attacks, and damage. They are important because they help prevent cyber attacks, maintain data confidentiality and integrity, and ensure the availability of systems and networks.
### What are some common cyber security protocols, including **VPN** and **cookie acceptance**?
Some common cyber security protocols include firewalls, antivirus software, encryption, multi-factor authentication, regular software updates and patches, **VPN**, and regular backups of data.
### Why is it important to have strong passwords as a part of cyber security protocols?
Strong passwords are an essential part of cyber security protocols because they help prevent unauthorised access to sensitive information. Weak passwords can easily be guessed or hacked, putting data and systems at risk.
### How often should cyber security protocols be reviewed and updated?
Cyber security protocols should be reviewed and updated regularly, at least once a year or whenever there are significant changes to the organisation's systems or network. It is important to stay vigilant and adapt to emerging security threats.
### What are some best practices for implementing cyber security protocols?
Some best practices for implementing cyber security protocols include educating employees on security awareness and safe online practices, regularly backing up data, implementing strong password policies, and regularly testing and updating security measures.
### Can cyber security protocols be applied to personal devices and accounts, particularly with the use of **IoT**?
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Network Security Protocols - Lark
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In today's interconnected digital landscape, ensuring the security of networks and data is paramount. As cyber threats constantly evolve, organizations must embrace advanced _network security protocols_ to fortify their cyber defenses effectively. This comprehensive guide delves into the significance of these protocols in bolstering cybersecurity measures and provides actionable insights for managing them effectively.
Table of Contents
Introduction to advanced network security measures Understanding the importance of network security protocols in cybersecurity An in-depth look at how network security protocols work Actionable tips for managing network security protocols in cybersecurity Related terms and concepts in network security protocols Conclusion Faqs on advanced network security measures in cybersecurity
Discover how Lark's security and compliance solutions can empower your organization's cybersecurity needs.
## Introduction to advanced network security measures
In the realm of cybersecurity, _network security protocols_ are pivotal in safeguarding organizational assets and sensitive information. These protocols, comprising a set of rules and mechanisms, are designed to secure data transmission and mitigate the risk of unauthorized access. As technology continues to advance, the adoption of advanced _network security protocols_ becomes imperative for businesses to counter the growing sophistication of cyber threats.
## Understanding the importance of network security protocols in cybersecurity
#### Defining Network Security Protocols and Their Relevance in Cybersecurity
Network security protocols encompass a suite of security measures and standards that govern the exchange of data across networks. Their relevance in cybersecurity lies in their ability to ensure the confidentiality, integrity, and availability of data, thereby mitigating potential vulnerabilities and threats. By adhering to these protocols, organizations can establish a robust security framework to safeguard their digital assets proactively.
##### How Network Security Protocols Bolster Cybersecurity
Network security protocols serve as a critical line of defense against unauthorized access, data breaches, and malicious activities. Through encryption, authentication, and access control mechanisms, these protocols actively contribute to fortifying cybersecurity by establishing secure communication channels and protecting sensitive information from unauthorized interception.
#### The Purpose of Network Security Protocols in Cybersecurity
At the core, network security protocols are instrumental in preserving the integrity of data transmitted across networks and ensuring that only authorized entities gain access to this information. By implementing robust protocols, organizations can effectively prevent data tampering, eavesdropping, and unauthorized modifications, thereby upholding the confidentiality and trustworthiness of their digital assets.
## An in-depth look at how network security protocols work
#### Practical Implications and Significance
##### Securing Sensitive Information during Data Transmission
One practical implication of advanced _network security protocols_ is their role in encrypting sensitive information during its transmission between devices and networks. Through encryption algorithms and secure communication channels, these protocols shield data from interception by unauthorized entities, thereby preserving its confidentiality and integrity.
##### Ensuring Secure Remote Access to Networks
Amid the prevalence of remote work arrangements, network security protocols are pivotal in facilitating secure remote access to organizational networks. By implementing Virtual Private Network (VPN) protocols and robust authentication mechanisms, businesses can ensure that remote employees access network resources securely, mitigating the risk of unauthorized access and data breaches.
##### Protecting Against Network Intrusions
Another practical implication of network security protocols is their role in mitigating network intrusions and cyber attacks. By leveraging robust firewall configurations, intrusion prevention systems, and access control lists, organizations can effectively fortify their networks against unauthorized access attempts, malware intrusions, and other malicious activities.
#### Best Practices for Implementing Network Security Protocols
Network security protocols necessitate a vigilant approach to their implementation to maximize their efficacy in bolstering cybersecurity. Embracing industry best practices is crucial for organizations seeking to fortify their security posture and safeguard their digital assets effectively.
- Implementing Multi-Factor Authentication
Organizations should adopt a multi-layered authentication approach to fortify their network access. By requiring multiple forms of verification, such as passwords, biometric scans, or security tokens, businesses can significantly enhance the security of network access, minimizing the risk of unauthorized entry by malicious actors.
- Employing Secure Socket Layer (SSL) Certificates
The deployment of SSL certificates for secure data transmission is imperative in fostering trust and integrity within network communications. By encrypting data and verifying the identity of communicating parties, SSL certificates ensure secure and authentic information exchange, mitigating the risk of data interception and tampering.
- Regular Updates and Patch Management
Continuous updating and patching of network security protocols and associated systems are essential to address emerging vulnerabilities and security loopholes effectively. By staying abreast of security updates and promptly implementing patches, organizations can minimize the likelihood of exploitation by cyber threats, enhancing their overall security resilience.
Related:
Bhags for Cybersecurity Teams
Learn more about Lark x Cybersecurity
## Actionable tips for managing network security protocols in cybersecurity
Empowering organizations with actionable insights, the following tips elucidate effective strategies for managing _network security protocols_ and fortifying the cybersecurity infrastructure:
- Ensure Regular Updates and Maintenance
Regularly updating and maintaining network security protocols, along with associated hardware and software, is crucial in preserving their relevance and efficacy in safeguarding organizational networks. Proactive maintenance mitigates the risk of system vulnerabilities, ensuring robust and resilient security measures.
- Implement Secure Access Controls
Establishing granular access controls and permissions is key to managing _network security protocols_ effectively. By defining and enforcing access policies, organizations can regulate the flow of information within their networks, systematically minimizing the risk of unauthorized access and data breaches.
- Conduct Security Audits and Penetration Testing
Periodic security audits and penetration tests are indispensable for evaluating the effectiveness of _network security protocols_ and identifying potential vulnerabilities. By simulating real-world cyber threats and assessing the resilience of security measures, businesses can proactively address security gaps and fortify their cybersecurity posture.
## Related terms and concepts in network security protocols
- _Encryption_: The process of encoding information in a manner that makes it unreadable to unauthorized entities, thereby ensuring its confidentiality and integrity during transmission and storage.
- _Firewall Configuration_: The establishment and management of firewall rules and policies to regulate incoming and outgoing network traffic, effectively mitigating the risk of unauthorized access and cyber attacks.
- _Access Control Lists_: A set of rules and conditions that govern the access permissions granted to users or devices within a network, facilitating the enforcement of security policies and restrictions.
Related:
The Golden Circle Framework for Cybersecurity Teams
Learn more about Lark x Cybersecurity
## Conclusion
In the fast-evolving landscape of cybersecurity, the deployment of advanced _network security protocols_ is indispensable for businesses aiming to fortify their defenses against an array of cyber threats. By comprehensively understanding the significance of these protocols and implementing best practices for their management, organizations can foster a resilient security posture that safeguards their digital assets effectively. Emphasizing the perpetual need for adaptation and learning, businesses can proactively navigate the dynamic nature of cybersecurity and uphold their resilience in the face of evolving cyber threats.
## Faqs on advanced network security measures in cybersecurity
### How do network security protocols impact data transmission?
_Network security protocols play a critical role in securing data transmission by encrypting information and ensuring its integrity and confidentiality during transit. By establishing secure communication channels and authentication mechanisms, these protocols bolster the security of data exchanged across networks, mitigating the risk of unauthorized interception and tampering._
### What are the key components of an effective network security protocol?
_An effective network security protocol comprises essential components such as encryption mechanisms, authentication protocols, access control mechanisms, and intrusion detection systems. Each component contributes to fortifying the security of networks and data, establishing a robust defense against cyber threats._
### How does network security protocols help in preventing unauthorized access?
_Network security protocols prevent unauthorized access by implementing stringent authentication mechanisms, access controls, and encryption protocols. These measures effectively regulate network access and communication, minimizing the risk of unauthorized entry and data breaches._
### Are there different types of network security protocols?
_Yes, there are various types of network security protocols tailored to address specific security requirements. Examples include Transport Layer Security (TLS), Secure Shell (SSH), Internet Protocol Security (IPsec), and Point-to-Point Tunneling Protocol (PPTP), each designed for specific security applications and network environments._
### How can businesses adapt to the dynamic nature of network security protocols?
_Businesses can adapt to the dynamic nature of network security protocols by prioritizing continuous learning and staying abreast of emerging security trends and technologies. Embracing proactive security measures, ongoing skill development, and collaborative information sharing within the cybersecurity community enable organizations to effectively adapt to evolving network security protocols and cyber threats._
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# Protocols & Communication
# 16 Most Common Network Protocols
Computer networks have become integral to our modern digital world. From browsing the web to sending emails and transferring files, network connectivity enables countless applications and services. However, this would not be possible without network protocols, which provide a common language for devices to exchange information reliably.
This article will explore some of the most common network protocols that drive communication and connectivity in networks and the Internet. We’ll explore what network protocols are, the main types, and then dive into 30 of the most common protocols—from foundational communication protocols like TCP/IP to specialized ones for network security, management, and various applications.
## What is a network protocol?
A network protocol consists of guidelines and procedures for communication between network devices. These common languages allow networked systems to understand each other, similar to human languages. For example, people who speak English can understand each other due to the common vocabulary and grammatical rules.
Protocols define rules for transmitting or exchanging data, such as syntax, semantics, synchronization, and error recovery. They enable the reliable transfer of information by formalizing details like formatting, addressing, packaging, and error checking. Like how books have specific structures, such as parts, chapters, sections, and so on, which both the author and the reader can understand.
Network hardware and software require protocol support to understand incoming data and handle tasks like routing traffic to intended destinations. Many key protocols are standardized to ensure cross-platform interoperability. However, some proprietary protocols may only work between devices from the same vendor.
## Main types of network protocols
Network protocols serve different primary purposes, which allow us to categorize them into main functional types. It’s helpful to understand the role of each type within the bigger picture.
### Communication protocols
Like a postal service delivering letters and packages between homes, communication protocols enable devices to exchange messages and data payloads across networks. They establish rules and conventions for reliable data transfer from senders to recipients.
Examples include TCP/IP, the core delivery protocol of the Internet, FTP for file transfers, and SMTP for email.
Communication protocols enable vital networked applications and services we use daily, such as websites, email, file sharing, media streaming, and more. They form the basic transport mechanisms for connectivity.
### Network security protocols
If communication protocols are the messengers moving data between devices, network security protocols act like security guards regulating access and protecting the data flows.
Security protocols employ measures like encryption and authentication to secure communications from eavesdropping or harmful tampering—much like security personnel safeguard facilities.
Protocols like SSH, SSL/TLS, and IPsec create secure tunnels to shield data and validate identities. Just as guards check badges at facility gates, security protocols block unauthorized access.
### Network management protocols
Network management protocols enable administration capabilities to monitor performance and remotely configure network equipment.
They’re like IT administrators overseeing the health of devices across networks and managing configurations. Protocols like SNMP and ICMP provide insights into network status to diagnose and troubleshoot issues. Others like DHCP and DNS dynamically assign IP addresses and map device names.
Management protocols grant networks greater robustness and control just as capable administrators keep enterprise IT infrastructure humming.
## 16 common network protocols
When it comes to the day-to-day functioning of modern networks, a core set of protocols handles the heavy lifting behind the scenes.
Here are some of the most common network protocols you’ll encounter, from the widespread TCP/IP that keeps the Internet humming to more specialized ones routing email, securing remote access, and much more.
## **Communication protocols**
## 1\. Transmission control protocol/Internet protocol (TCP/IP)
The Transmission Control Protocol/Internet Protocol (TCP/IP) suite facilitates communication by handling the encapsulation of data into packets at the sender, transmitting it reliably across networks, routing packets to the destination address via intermediary network devices like routers and switches using Internet Protocol (IP), before finally reassembling packets in the proper order at the receiving host.
Built-in error-checking capabilities automatically request the retransmission of any missing or corrupted packets. This provides reliable end-to-end connectivity crucial for virtually all modern applications to function well over LANs and the Internet alike.
However, attacks such as SYN floods and IP spoofing may attempt to undermine availability by overwhelming target systems with bogus requests or impersonating trusted devices.
## 2\. User datagram protocol (UDP)
User Datagram Protocol (UDP) offers a lean alternative to TCP. It essentially trades reliability for speed, proving useful for time-sensitive purposes like video calling, streaming media, and online gaming. By skipping error-checking steps, UDP saves processing overhead and accelerates data transfers, delivering packets quickly but without guarantees.
Thus, packets may arrive out-of-order or go missing altogether. While acceptable for streaming audio/video applications able to tolerate such losses, UDP can be risky in transferring critical data. Security mechanisms are also lacking, making encrypted alternatives more secure for sensitive applications.
## 3\. File transfer protocol (FTP)
The venerable File Transfer Protocol (FTP) still sees widespread use for uploading and downloading files between client and server over a TCP/IP network. Web hosting environments often employ FTP to provide multiple contributors with file access for routine website updates.
FTP options like directory listings and non-interactive transfers make batch operations convenient. However, privacy is sorely lacking as login credentials and data transfer in cleartext without encryption. The encrypted FTPS variant addresses this issue for use cases requiring tighter security.
## 4\. Session initiation protocol (SIP)
SIP serves as the backbone for multimedia sessions over IP networks. So, while analog signals ran over telephone networks before, SIP helped “packetize” voice and media into data that can be transmitted digitally.
From modern video conferencing apps to entire cloud phone systems used by large contact centers, SIP makes all of that possible. It handles the nitty-gritty signaling, session management, and teardown details so audio, video, and other media exchange happen smoothly across the internet. SIP integrates with standardized voice and video protocols to make internet-based real-time communications possible.
## **Network security protocols**
## 5\. Secure shell (SSH)
Secure shell, commonly known as SSH, is one of the most prevalent network protocols used today. It enables secure remote login connections to devices like servers, switches, and firewall appliances from client software.
SSH sets up an encrypted tunnel to protect the authentication session and subsequent remote access from eavesdroppers. It prevents plainly transmitting credentials that could be intercepted. SSH replaces older insecure protocols like Telnet and rlogin, which are still sometimes used but lack encryption.
Over the years, SSH has become a Swiss-army knife network tool that administrators worldwide rely on for tasks like securely transferring files with SFTP and tunneling or port forwarding network traffic.
Commercial SSH implementations boast advanced features out of necessity focused on availability, compliance, and threat prevention. For example, granular access controls, detailed session logging, and host key management integrate SSH deeply with identity and authentication ecosystems while responding to vulnerabilities.
## 6\. Secure sockets layer (SSL) / Transport layer security (TLS)
Transport layer security (TLS) and its older relative, the Secure sockets layer (SSL), implement cryptographic protections for data in motion across networks. Encrypting application traffic and authenticating connecting parties using certificates prevents tampering and eavesdropping.
Numerous applications transparently overlay TLS/SSL without users noticing. Examples include HTTPS web browsing, Secure shell encrypted terminal sessions (SSH), Virtual Private Network tunnels (VPN), and secure email.
However, TLS is vulnerable because, when faced with certain attacks, it devolves connections to a weaker encryption. Keeping software up-to-date and properly validating certificate chains maintains robust security foundations for applications.
## 7\. Secure FTP (FTPS)
FTP enjoys longevity, securing crucial yet predictable file transfer needs globally across industries. FTPS supercharges FTP by adding SSL/TLS-based encryption, mitigating data theft or tampering risks over unprotected transfers.
Depending on the configuration, FTPS setup modes implicitly presume encryption versus explicitly commanding upfront. Supporting the latest cryptographic agility and enforcement practices is key, given lengthening data retention mandates.
With growing runtime exploitation and malware threats, however, content scanning before final storage brings vital assurances. Overall, while FTPS brings necessary encryption, centralized access controls and integration with funnel points like proxies and firewalls ensure governance beyond just the wire.
FTPS will continue meeting tactical secure file transfer demands while web portals and managed file-sharing services suit more dynamic requirements involving external parties.
## **Network management protocols**
## 8\. Simple network management protocol (SNMP)
What is SNMP?
Simple network management protocol or SNMP is widely used for monitoring and managing all sorts of network-connected devices—from routers and switches to printers, firewalls, and servers. It works by letting an SNMP manager send queries to devices being monitored, which each have a small piece of SNMP agent software installed to collect status and performance data.
SNMP can track valuable telemetry like uptime stats, link utilization, errors spotted, and plenty more. The agents gather all this and report back to monitoring tools so network administrators can get a nice centralized view instead of checking individually. SNMP even supports alerts and notifications for faults or thresholds being crossed, known as SNMP traps, namely messages sent from monitored devices to the manager to indicate an anomaly or issue.
When it comes to SNMP, there are a few different versions available. SNMPv2 and SNMPv3 are the most common currently in use. SNMPv3 is more advanced, introducing stronger security with encryption and authentication, unlike the older SNMPv2.
However, SNMPv2 remains popular still in many organizations due to legacy compatibility issues making it hard to upgrade fully to SNMPv3 across the board. The tradeoffs between SNMP v2 vs. v3 center around improved security and performance gains in the newer standard at the cost of a more complex configuration.
## 9\. Internet control message protocol (ICMP)
The Internet Control Message Protocol (ICMP) handles basic diagnostic functions like querying whether destinations are reachable and responding with status updates. ICMP is best recognized as enabling ubiquitous “ping” connectivity verification requests emitted by network troubleshooting tools, triggering target devices to report back timing and availability data.
By default, networks usually permit ICMP packets as blocking will obstruct vital network monitoring. However, excess ICMP traffic can sometimes be exploited to flood networks in denial-of-service brinksmanship. Like UDP, ICMP eschews hard security, given it predates modern encryption.
## 10\. Address resolution protocol (ARP)
Devices communicate via MAC addresses on local networks. But we often only know IP addresses for destinations. The address resolution protocol bridges this gap by resolving IP addresses to associated MAC addresses that network adapters use. Your computer maintains an ARP table caching these mapped addresses locally.
When you try reaching a new destination, broadcasts seek the MAC for the IP, update the table after getting a reply, and subsequently transmit. Under the hood, the process is invisible to users. Unfortunately, ARP lacks authentication natively, meaning cache entries can get overwritten by spoofing attacks. Protecting ARP behavior is thus important for robust connectivity on local network segments.
## 11\. NetFlow
Where SNMP focuses on device-level statistics, NetFlow lets you step up to network-wide monitoring and analysis by understanding traffic patterns coursing through your infrastructure. By processing flow-based data about connections, the volume, timing, directionality, duration, endpoints, and applications involved all become transparent.
Network flow records cement visibility into network usage and dependency, empowering informed decisions about capacity, security, layout, and more. The catch lies in NetFlow compliance—next-gen firewalls and web proxies generally work, but switches and routers need capabilities enabled. Otherwise, blind spots manifest where critical flows lack visibility.
## 12\. sFlow
sFlow is a packet sampling technology used for monitoring network devices like routers, switches, and wireless access points across vendors. Unlike NetFlow, which samples full packet flows, sFlow randomly samples 1 out of N individual packets passing through an interface. This sampling occurs at wire speed via dedicated hardware chips embedded in the network devices.
A sFlow software agent combines the sampled packet data with interface counters and forwards table info into sFlow datagrams. These datagrams are shipped off to a central sFlow collector for analysis. So, while less comprehensive than NetFlow, sFlow provides network-wide visibility with quantifiable accuracy—especially for bandwidth-heavy traffic like streaming video.
The sFlow collector can feed data to traffic analysis tools. By processing sFlow data from multiple interfaces, these tools deliver valuable capabilities like spotting traffic congestion, detecting rogue apps, and profiling historical trends for proactive performance management.
So, the sFlow vs NetFlow debate lies in whether an organization can work with packet sampling or requires full-flow analysis.
## 13\. Border gateway protocol (BGP)
On the wild internet, BGP helps tame things by managing routing data exchange between organizations. It essentially maintains a large-scale map of network reachability between autonomous systems that agree to share access. Your ISP likely participates, enabling your traffic to traverse multiple networks when accessing websites abroad.
By distributing routing updates, BGP-enabled routers know which paths packets should traverse to reach intended destinations. Validating route announcements and preventing malicious hijacking is thus crucial for BGP security and reliability mechanisms. Within corporate networks as well, BGP is key for connecting privately managed subnets and sharing route data.
## 14\. Domain name system (DNS)
DNS functions as a phonebook for the Internet. This protocol translates domain names that humans can easily remember, like google.com or wikipedia.org, into numerical IP addresses that computers and routers use to fetch the correct websites and content. It essentially matches names with the right numbers.
A breakdown can occur if the DNS information that maps a domain to an IP gets somehow modified or corrupted by an attack. When the DNS “records” providing this name-to-address mapping get poisoned or altered, browsers and apps can get misdirected. This unfortunately remains one of the simpler ways even massive websites go offline suddenly.
## 15\. Dynamic host configuration protocol (DHCP)
Networks keep functioning smoothly in part thanks to DHCP performing helpful background work across all those routers, switches, servers, and devices. Whenever endpoints like laptops, phones, or tablets connect to the wireless network or plug into the wired LAN ports in office buildings, DHCP does the housekeeping work of assigning them valid IP addresses plus other critical networking information as part of the join process.
By automatically allocating IP addresses instead of manual configuration, DHCP simplifies management for devices ranging from home routers to complex enterprise networks. However, if something goes wrong, such as a rogue DHCP server appearing on the network and interfering or a denial-of-service attack flooding a DHCP server with fake requests, new devices won’t be able to obtain the settings they need to get online.
## 16\. Telnet
Despite security shortcomings compared to newer tools, Telnet remains a useful way to remotely access devices over the network. It enables commands to be run on routers, switches, or servers from another system with network connectivity as though seated at the target device’s console, which is handy for tasks like tweaking settings or grabbing debug logs.
However, everything gets exchanged between the admin’s PC and the managed device in plain, unencrypted text, including account credentials and privileged commands. Sniffing the traffic makes stealing sensitive information extremely easy, meaning Telnet access requires additional controls like jumpboxes to limit exposure.
## Tools and resources for network protocol analysis
Analyzing network protocols and traffic is vital for monitoring performance, troubleshooting issues, and identifying security threats on a network. Many tools and platforms provide network administrators visibility into protocols and data flows.
Packet analyzers like Wireshark offer deep inspection into traffic down to individual packets and bytes on a network segment. Wireshark can decode and log TCP/IP communications, ICMP error messages, application protocol exchanges, and more for advanced diagnostics. Platforms like SolarWinds also provide integrated network monitoring and analysis with capabilities like packet capturing to record traffic for examination.
Flow-based analyzers, including ManageEngine NetFlow Analyzer, give longer-term visibility into overall traffic volumes and patterns by tracking IP flows. As an alternative to packet-level data, flow analysis conserves resources for high-level bandwidth monitoring, capacity planning, and usage trends.
Vulnerability scanners like Nessus can uncover weaknesses in the implementation of various network protocols and services. By checking for open ports running outdated protocol versions or known vulnerable software, these tools can reveal services susceptible to compromise. Penetration testing also probes real-world protocol robustness.
Tools like Nmap check for ports and services exposed to networks, reporting on versions and configurations to identify unneeded connectivity that warrants closing to avoid exposure. Port scanning gives administrators network topology visibility to tighten access control and flows between network zones.
Intuitive monitoring systems like Auvik provide an integrated view of network status and performance with automation to reduce the overhead of continually gathering data manually. Auvik leverages capabilities like automated network discovery and mapping to track infrastructure, combined with machine learning for traffic analysis without extensive customization. This enables insight into bandwidth consumption and protocols without hands-on packet inspection.
The wealth of analytics data from Auvik’s TrafficInsights and related tools allows for quick drilling into details when high-level overviews expose anomalies or underperformance. Geolocation of traffic flows also facilitates tracking unauthorized or suspicious connectivity that could reflect vulnerabilities being exploited.
With its configuration change tracking and backup, along with intelligent alerting, Auvik enables administrators to maintain networks proactively. Trend data guards against emerging issues, while rapid fault isolation capabilities speed mitigation when problems do arise.
## Emerging technology influencing network protocols
While entrenched protocols like TCP/IP continue to power much of today’s networks, innovative new approaches are emerging to enable the connectivity demands of cutting-edge technologies on the horizon.
As technologies like self-driving cars, artificial intelligence, Internet of Things (IoT) devices, and new cellular standards like 5G transition from buzzwords to reality, they place unprecedented demands on networks in terms of scale, speed, reliability, and adaptability.
### Lightning speed 5G and AI
5G cellular networks aim to be up to 100x faster than existing 4G networks. We’re talking gigabits per second data rates, allowing HD movie downloads in seconds. Existing protocols may fall short, requiring new optimized mechanisms tailored for technologies like network slicing and software-defined mobile edge computing essential for 5G services.
Similarly, bandwidth-hungry AI and machine learning applications need to shuttle enormous training data sets from sensors and datasets to power predictive analytics, autonomous decision-making, and conversational interfaces. TCP with congestion control throttles throughput for reliability. New protocols like Quick UDP Internet Connections (QUIC) offer innovations like improved congestion handling.
### Internet of things and edge computing
Connecting billions of IoT devices, such as appliances, machinery, meters, and wearables, poses scaling challenges. Low-power devices often lack resources for complex protocols, requiring compact, efficient alternatives.
New device-centric IoT protocols optimize message formats, operating with limited processing capability and intermittent connectivity typical of sensors. Data flows need management from edge gateways.
As edge computing proliferates with intelligence heading closer to local devices, protocol mechanisms customized for localized traffic domination, high-volume data aggregation, and location or context awareness help cut networking overhead. Serverless designs offload connectivity management across decentralized nodes.
### Connected transport
Network protocols for autonomous vehicle systems need location-based optimizations with reliable hand-offs between cells and hardware heading up to gigabit speeds as vehicles rapidly traverse multi-access edge networks.
V2X communication protocols tailored for cloud-supported transport apps offer smart junction negotiation and collective perception for traffic management. Security is also paramount with vehicle communication vulnerabilities being extremely risky.
### Crypto-agile security
With cyberattacks becoming increasingly advanced and devastating, zero-trust approaches are imperative for concealing even metadata like message headers or packet timing via encryption. Improperly implemented cryptography remains a top vulnerability, though.
Future-ready protocols increasingly support algorithm extensibility and agility to allow security upgrades. Design best practices like crypto-first methodologies promote encryption rather than bolting it on later.
In essence, new protocols optimize for specific use cases like high-performance media delivery, reliability in intermittent connections, collective communication within endpoint groups, security hardening, and decentralized operation. These are key expectations from new technology that today’s networks weren’t originally built for.
Adaptable protocols also ease the transition, like improving congestion handling during the 5G rollout. Sometimes, multiple protocols run alongside each other. For example, Wi-Fi and 5G sharing loads in hybrid access. Ultimately, the network shifts from rigid plumbing to a smart, customizable connectivity canvas suiting specialized needs.
## Common network protocols form the foundation of connectivity
Network protocols work tirelessly behind the scenes to drive the connectivity most people take for granted nowadays. These common network protocols come in all shapes and sizes, from foundational communication protocols like TCP/IP that deliver data packets between devices to specialized security protocols like SSH that build encrypted tunnels to protect sensitive information in transit.
New innovative protocols are emerging to handle cutting-edge technologies like 5G and IoT that pose greater demands. But the proven workhorse protocols will continue to provide reliable heavy lifting day in and day out for the networking tasks that we count on.
However, as new connectivity paradigms like edge computing and widespread encryption reshape traffic and access patterns, network administrators need deeper visibility into protocol behavior, performance impact, and security vulnerabilities.
Integrated monitoring and analytics platforms, along with advanced capabilities like machine learning and automation, will be key enablers for next-gen network operations capable of harnessing the protocol innovations to come. By understanding what powers networks beneath the surface, we are better equipped to design, manage, and secure our connectivity infrastructure.
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Network Security Protocols to Know for Cybersecurity and ... - Fiveable
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https://library.fiveable.me/lists/network-security-protocols
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network security protocols
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# Network Security Protocols to Know for Cybersecurity and Cryptography
#### Related Subjects
Systems Approach to Computer Networks Cybersecurity and Cryptography
Network security protocols are essential for protecting data and ensuring safe communication across networks. They use encryption, authentication, and integrity checks to secure information, making them vital in the fields of cybersecurity and cryptography within computer networks.
01. **SSL/TLS (Secure Sockets Layer/Transport Layer Security)**
- Provides encryption for data transmitted over the internet, ensuring confidentiality and integrity.
- Utilizes a handshake process to establish a secure connection between client and server.
- Supports authentication through digital certificates, verifying the identity of parties involved.
02. **IPsec (Internet Protocol Security)**
- Operates at the network layer to secure IP communications by authenticating and encrypting each IP packet.
- Supports two modes: Transport mode (encrypts only the payload) and Tunnel mode (encrypts the entire packet).
- Commonly used in VPNs to create secure connections over untrusted networks.
03. **SSH (Secure Shell)**
- Provides a secure channel over an unsecured network for remote login and command execution.
- Uses public-key cryptography for authentication, ensuring that only authorized users can access the system.
- Supports secure file transfers and tunneling of other protocols.
04. **HTTPS (Hypertext Transfer Protocol Secure)**
- An extension of HTTP that uses SSL/TLS to encrypt data exchanged between web browsers and servers.
- Ensures secure online transactions and protects sensitive information from eavesdropping.
- Widely used for secure communication on the web, indicated by a padlock icon in the browser.
05. **VPN (Virtual Private Network) protocols**
- Creates a secure, encrypted tunnel for data transmission over the internet, protecting user privacy.
- Common protocols include OpenVPN, L2TP/IPsec, and PPTP, each with varying levels of security and performance.
- Allows users to access restricted networks and browse the internet anonymously.
06. **WPA/WPA2/WPA3 (Wi-Fi Protected Access)**
- Security protocols designed to protect wireless networks from unauthorized access and eavesdropping.
- WPA2 uses AES encryption for stronger security, while WPA3 enhances protection against brute-force attacks.
- Implements a robust authentication process to ensure only authorized devices can connect to the network.
07. **Kerberos**
- A network authentication protocol that uses secret-key cryptography to provide secure authentication for users and services.
- Operates on a ticket-based system, where users obtain tickets to access services without repeatedly entering passwords.
- Protects against eavesdropping and replay attacks, ensuring secure communication within a network.
08. **SFTP (Secure File Transfer Protocol)**
- A secure version of FTP that uses SSH to encrypt file transfers, protecting data in transit.
- Provides authentication and integrity checks to ensure that files are transferred securely and without tampering.
- Supports various file operations, including uploading, downloading, and managing files on remote servers.
09. **DNSSEC (Domain Name System Security Extensions)**
- Adds a layer of security to the DNS protocol by enabling the verification of DNS responses through digital signatures.
- Protects against attacks such as DNS spoofing and cache poisoning, ensuring users reach legitimate websites.
- Enhances the integrity and authenticity of DNS data, contributing to overall internet security.
10. **PGP (Pretty Good Privacy)**
- A data encryption and decryption program that provides cryptographic privacy and authentication for data communication.
- Uses a combination of symmetric-key and public-key cryptography to secure emails and files.
- Allows users to sign and encrypt messages, ensuring confidentiality and verifying the sender's identity.
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Encryption, Its Algorithms And Its Future | GeeksforGeeks
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https://www.geeksforgeeks.org/encryption-its-algorithms-and-its-future/
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cryptography encryption algorithms
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Yes (reduced from 38979 to 34188 chars)
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Encryption plays a vital role in today’s digital world, serving a major role in modern cyber security. It involves converting plain text into cipher text, ensuring that sensitive information remains secure from unauthorized access. By making data unreadable to unauthorized parties, encryption helps maintain confidentiality, safeguard data integrity, and verify authenticity, providing a robust defense against cyber threats and ensuring the protection of private information.
## What is Encryption?
**Encryption** in cryptography is a process by which plain text or a piece of information is converted into cipher text or text that can only be decoded by the receiver for whom the information was intended. The algorithm used for the encryption process is known as cipher. It helps to protect consumer information, emails, and other sensitive data from unauthorized access as well as secures communication networks. Presently there are many options to choose from and find the most secure algorithm that meets our requirements.
The components of Encryption are:
- **Plaintext**: The original, unencrypted message that is sent by the sender.
- **Encryption Algorithm**: The process used to transform plaintext into ciphertext, enhancing the security and reliability of the data.
- **Encryption Key**: The key used during the encryption process to convert plaintext into ciphertext.
- **Ciphertext**: The encrypted version of the plaintext, which can only be decrypted back to its original form with the appropriate key.
## Features of Encryption
The features of encryption go beyond just data protection, they provide **confidentiality, integrity, authenticity, and non-repudiation**, forming a comprehensive security framework for communications and data storage. Understanding these features is crucial for evaluating the effectiveness of encryption methods in securing personal, corporate, and governmental data against cyber threats.
Here are the key features that make encryption an essential tool:
### **Confidentiality**
The primary purpose of encryption is to ensure the confidentiality of data. It ensures that only authorized individuals or systems can access the sensitive information by transforming it into an unreadable format. Unauthorized users cannot decipher the encrypted data without the correct decryption key.
### **Integrity**
Encryption helps maintain the integrity of data by ensuring that the data cannot be altered or tampered with during transmission. Even if someone intercepts the encrypted data, any unauthorized modifications will result in an unreadable ciphertext, signaling potential tampering.
### **Authentication**
Encryption allows the sender to prove their identity to the recipient. This is achieved through methods like digital signatures, which use encryption to verify that the data comes from a legitimate source and has not been altered.
### **Non-repudiation**
Encryption provides non-repudiation, meaning that once data is encrypted and sent, the sender cannot deny having sent it. Digital signatures or secure hashing, both encryption-based methods, ensure that the sender’s identity and message authenticity are undeniable.
### **Access Control**
Encryption allows sensitive data to be restricted to authorized users. Only those with the decryption key (or access credentials) can view or modify the encrypted data, adding a layer of security against unauthorized access.
## Types of Encryption
There are two types of key-based encryption algorithms, symmetric encryption algorithms (secret key algorithms) and asymmetric encryption algorithms (or public-key algorithms). Symmetric encryption examples includeAES(Advance Encryption Standard), Triple DES, Twofish and Blowfish Algorithms and RSA is a type of asymmetric algorithm.
## **Symmetric Encryption**
Symmetric encryption is a type of encryption where the **same key** is used for both encrypting and decrypting data. This means that both the sender and the receiver must share a secret key in order to securely exchange information. The main advantage of symmetric encryption is its speed, as it typically requires less computational power compared to asymmetric encryption.
### **1\. AES**( **Advance Encryption Standard**)
Advance Encryption Standard also abbreviated as AES, is a symmetric block cipher which is chosen by United States government to protect significant information and is used to encrypt sensitive data of hardware and software. AES has three 128-bit fixed block ciphers of keys having sizes 128, 192 and 256 bits. Key sizes are unlimited but block size is maximum 256 bits.The AES design is based on a substitution-permutation network (SPN) and does not use the Data Encryption Standard (DES) Feistel network.
### **2\. Triple DES**
Triple DES is a block cipher algorithm that was created to replace its older version Data Encryption Standard(DES). In 1956 it was found out that 56 key-bit of DES was not enough to prevent brute force attack, so Triple DES was discovered with the purpose of enlarging the key space without any requirement to change algorithm. It has a key length of 168 bits three 56-bit DES keys but due to meet-in-middle-attack the effective security is only provided for only 112 bits. However Triple DES suffers from slow performance in software. Triple DES is well suited for hardware implementation. But presently Triple DES is largely replaced by AES (Advance Encryption Standard).
### **3\. Twofish**
Twofish algorithm is successor of blowfish algorithm. It was designed by Bruce Schneier, John Kesley, Dough Whiting, David Wagner, Chris Hall and Niels Ferguson. It uses block ciphering It uses a single key of length 256 bits and is said to be efficient both for software that runs in smaller processors such as those in smart cards and for embedding in hardware .It allows implementers to trade off encryption speed, key setup time, and code size to balance performance.
### 4\. Blowfish
Blowfish was created to solve the DES algorithm's problem. The algorithm is freely usable by everyone and has been released into the public domain. The technique uses a 64-bit block size, and the length of the key can range from 32 to 448 bits. It is the best permutation technique for cipher-related encryption and operates on the Feistel structure using a 16-bit round cipher. The information in the Blowfish algorithm is encrypted and decrypted using a single key.
## **Asymmetric Encryption**
Asymmetric encryption, also known as public-key encryption, uses two different keys: **a public key and a private key**. The public key is used to encrypt the data, and the private key is used to decrypt it. The key pair is mathematically related, but it is computationally infeasible to derive the private key from the public key. Asymmetric encryption is more secure than symmetric encryption for key exchange, as the private key is never shared.
### **1\. RSA (** **Rivest, Shamir and Adleman)**
RSA is an asymmetric key algorithm which is named after its creators Rivest, Shamir and Adleman. The algorithm is based on the fact that the factors of large composite number is difficult: when the integers are prime, this method is known as Prime Factorization. It is generator of public key and private key. Using public key we convert plain text to cipher text and private key is used for converting cipher text to plain text. Public key is accessible by everyone whereas Private Key is kept secret. Public Key and Private Key are kept different.Thus making it more secure algorithm for data security.
## **Future of Encryption**
The future of encryption will see more adaptive and resilient methods emerging, with stronger encryption techniques tailored for modern challenges like quantum computing and cloud security. As quantum-resistant algorithms evolve, they will help protect sensitive data from the growing threat of quantum computing. New encryption forms, like homomorphic encryption, will enable more secure data processing without compromising data privacy. Additionally, the increasing use of BYOE will allow organizations to retain control over their data security, which will be essential for protecting information in the cloud.
Encryption will also become more integrated into every aspect of digital security, evolving to meet the needs of businesses and consumers. While new methods like honey encryption will provide novel ways to mislead attackers, traditional encryption will continue to be enhanced to meet growing demands for security, speed, and ease of use.T
### 1\. **Bring Your Own Encryption (BYOE)**
Bring Your Own Encryption (BYOE) is a trend that empowers organizations to take control of their data security by using their own encryption methods, rather than relying on the encryption solutions provided by cloud service providers. By holding the encryption keys, businesses ensure that their data remains private and protected, even when stored in the cloud. This method enhances security by providing greater autonomy and preventing unauthorized access to sensitive information.
### 2\. **Homomorphic Encryption**
Homomorphic encryption allows computations to be performed on encrypted data without decrypting it. This breakthrough in encryption technology enables secure data processing without exposing the underlying data to risks. Only the results of the computations are decrypted, meaning sensitive information remains protected throughout the process. As this method advances, it will revolutionize secure data analysis and enable safer cloud computing and data-sharing practices.
### 3\. **Quantum Cryptography**
With the rise of quantum computing, quantum cryptography is rapidly becoming a vital field in data security. Unlike traditional encryption methods that rely on complex mathematical problems, quantum cryptography uses the principles of quantum mechanics to enhance security. One of the most prominent applications of quantum cryptography is **Quantum Key Distribution (QKD)**, which allows two parties to securely exchange keys without the risk of interception. Quantum cryptography is expected to be virtually unbreakable, even against quantum computers, making it a game-changer for securing sensitive communications.
### 4\. **Honey Encryption**
Honey encryption is an innovative approach that generates plausible but fake data when incorrect decryption keys are used. This technique confuses attackers, wasting their time and resources on incorrect decryption attempts. By creating a deceptive environment, honey encryption makes it significantly harder for hackers to determine whether they’ve found the correct key. This method is particularly useful for protecting highly sensitive data, as it adds an extra layer of security and complicates the efforts of malicious actors.
## Potential Challenges in Advancing Encryption Techniques
Despite the promising future of encryption, several challenges remain. Homomorphic encryption, while revolutionary, currently suffers from high computational overhead, making it i **nefficient f** or many practical applications. Runtime encryption also faces issues with performance and compatibility. Moreover, the rise of quantum computing presents a significant challenge to current encryption methods, requiring the development of **quantum-resistant algorithms**. While quantum computing promises to disrupt encryption as we know it, it is still in its early stages, and developing effective countermeasures will require significant time and resources.
These challenges highlight the complexities involved in advancing encryption technologies. As encryption continues to evolve, overcoming these obstacles will be crucial for ensuring that these advanced encryption techniques can be seamlessly integrated into everyday use.
In conclusion, while the future of encryption looks promising, it’s clear that it will require continued innovation and collaboration to address the challenges of a rapidly evolving digital landscape.
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Cryptography: Encryption and Hashing - Information Technology
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https://it.csusystem.edu/cryptography-encryption-and-hashing/
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cryptography encryption algorithms
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Yes (reduced from 4362 to 3665 chars)
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In our increasingly interconnected world, safeguarding our data is first. Cryptography is the secret art of communicating privately in a public environment. Two components that often confuse people are encryption and hashing — two processes that serve different yet essential purposes.
## Encryption
What you may hear more often is the term encryption, which is a process that turns plaintext (human readable text) into ciphertext (non-readable text). Human readable text is exactly what it sounds like, the very words you are reading now are plaintext! At a very high-level encryption is just a mathematical algorithm (set of instructions) that generates something called encryption keys. Think of this as a digital key that can lock, unlock, or a combination of both. Encryption can be broken down into two categories, symmetric and asymmetric.
Symmetric encryption generates a single key, that encrypts and decrypts (turns ciphertext into plaintext). Of the two it is the fastest, but key management is more difficult. For example, let us say we have a Microsoft word document we want to send to our boss. We use our symmetric encryption key to encrypt the document. To decrypt the document our boss would also need the same key, presenting the downside of symmetric encryption. Symmetric encryption is much faster than asymmetric encryption but lacks secure key management.
Asymmetric encryption is much slower than symmetric encryption, but in terms of being secure it excels! Asymmetric encryption generates a pair of keys, a public key, and a private key. If you encrypt with one key, you can only decrypt with the other. The public key can be shared, but your private key must be kept by you in a secure location.
## Hashing
Hashing is a one-way (non-reversible) conversion of plaintext into an unreadable format often called hexadecimal notation. Hexadecimal or hex for short, is a base-16 numbering system (multiples of 16) combination of numbers (0-9) and letters (A-F) that represent bigger numbers. The main objective of hashing is to verify the integrity of data (that it hasn’t changed). This process happens by data, inputting that into a hashing function (mathematical formula) that outputs a fixed-length string of hex characters.
How does this check the integrity of data? Well, imagine you’ve downloaded a large file from a website. To ensure that the file hasn’t been tampered with or corrupted during the download, the website provides the hash value (output of hashing function). You can hash the file yourself and compare it to the hash value provided by the website. If there are any differences between the two hash values, the files do not match. That’s what makes hashing so powerful, even if the data is missing a period, the hash value will be completely different.
There are so many types of encryption algorithms, encryption methods, and hashing functions, so much so it could take days to cover them all. Some even combine symmetric and asymmetric encryption, such as hybrid cryptography, and others blend cryptography, hashing, and digital signatures, like signcryption. However, that is beyond our scope for today. While encryption ensures that data stays private, hashing guarantees the integrity of that data. Both processes are essential pillars safeguarding our information as we navigate the ever-changing digital world
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Cryptography Algorithms in Python | by DhanushKumar - Medium
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https://medium.com/@danushidk507/cryptography-algorithms-in-python-3fe41cab9457
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cryptography encryption algorithms
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In Python, several cryptographic techniques are available to secure data, ranging from symmetric and asymmetric encryption to hashing and digital signatures. These techniques are implemented using various libraries, with popular ones like `cryptography`, `PyCryptodome`, and `hashlib`. Here's an overview of the common cryptography techniques in Python:
# Symmetric Encryption (AES, DES)
**Working Principle**: In symmetric encryption, the same key is used for both encryption (turning plaintext into ciphertext) and decryption (turning ciphertext back into plaintext). The key must be kept secret between the sender and the receiver.
**How it works**:
- **Encryption**: Plaintext is combined with a secret key to produce scrambled data (ciphertext).
- **Decryption**: The ciphertext and the same secret key are used to revert the scrambled data back to the original plaintext.
**AES (Advanced Encryption Standard)** is a widely used symmetric encryption algorithm because it’s fast and secure. It encrypts data in fixed block sizes (128-bit blocks) and uses different key lengths (128, 192, or 256 bits).
**Example Scenario**: If you send a message to a friend, both you and your friend have the same key. You use the key to scramble the message (encryption), and your friend uses the same key to unscramble it (decryption).
Symmetric encryption uses a single key for both encryption and decryption. The most popular algorithm is AES (Advanced Encryption Standard).
**Libraries**:
- `cryptography`: Provides high-level and low-level interfaces for encryption.
- `PyCryptodome`: An extensive library for cryptographic operations, including AES.
**Example with AES (using** `cryptography` **):**
from cryptography.hazmat.primitives.ciphers import Cipher, algorithms, modes
from cryptography.hazmat.backends import default_backend
import os
key = os.urandom(32) # 256-bit key
iv = os.urandom(16) # 128-bit IV
cipher = Cipher(algorithms.AES(key), modes.CFB(iv), backend=default_backend())
encryptor = cipher.encryptor()
ciphertext = encryptor.update(b"Secret Data") + encryptor.finalize()
# Asymmetric Encryption (RSA, ECC)
**Working Principle**: Asymmetric encryption uses a pair of keys — a **public key** and a **private key**. The public key is shared openly, while the private key is kept secret. Data encrypted with the public key can only be decrypted with the private key, and vice versa.
**How it works**:
- **Encryption**: The sender uses the recipient’s public key to encrypt the message.
- **Decryption**: The recipient uses their private key to decrypt the message.
**RSA (Rivest-Shamir-Adleman)** is a popular asymmetric encryption algorithm, widely used for securing data transmissions, especially in secure websites (HTTPS).
**ECC (Elliptic Curve Cryptography)** is a more modern version of asymmetric encryption. It achieves the same security as RSA but with shorter keys, making it faster and more efficient.
**Example Scenario**: When you visit a secure website, the website provides its public key to your browser. Your browser encrypts your credit card info using this public key, and only the website’s private key can decrypt it.
# Asymmetric Encryption (RSA, ECC)
Asymmetric encryption uses a public key for encryption and a private key for decryption. RSA and ECC (Elliptic Curve Cryptography) are commonly used algorithms.
**Libraries**:
- `cryptography`: For high-level RSA and ECC encryption.
- `PyCryptodome`: Provides RSA and other asymmetric algorithms.
**Example with RSA (using** `cryptography` **):**
from cryptography.hazmat.primitives.asymmetric import rsa, padding
from cryptography.hazmat.primitives import hashes
# Generate RSA key pair
private_key = rsa.generate_private_key(public_exponent=65537, key_size=2048)
public_key = private_key.public_key()
# Encrypt data
ciphertext = public_key.encrypt(
b"Secret Data",
padding.OAEP(
mgf=padding.MGF1(algorithm=hashes.SHA256()),
algorithm=hashes.SHA256(),
label=None
# Decrypt data
plaintext = private_key.decrypt(
ciphertext,
padding.OAEP(
mgf=padding.MGF1(algorithm=hashes.SHA256()),
algorithm=hashes.SHA256(),
label=None
# Hashing (SHA, MD5)
**Working Principle**: Hashing converts data into a fixed-length string (a hash) that is unique to that data. Hashes are typically one-way, meaning you can’t reverse the process to get back the original data.
**How it works**:
- **Hashing**: A mathematical function is applied to the input data (e.g., a file or message), creating a unique hash (a fixed-length string).
- **Integrity check**: If even one character of the original data changes, the hash will change completely, allowing the detection of tampering.
**SHA (Secure Hash Algorithm)** and **MD5 (Message Digest Algorithm)** are common hashing algorithms. SHA-256, for example, produces a 256-bit hash.
**Example Scenario**: When you download software, the website provides a hash of the file. After downloading, you compute the hash of your copy. If the hash matches the one provided, you know the file hasn’t been tampered with.
Hashing transforms data into a fixed-size string of characters, which is typically irreversible. SHA-256, SHA-512, and MD5 are popular hashing algorithms.
**Libraries**:
- `hashlib`: A standard Python library for hashing.
**Example using SHA-256 (using** `hashlib` **):**
import hashlib
data = b"Important Data"
sha256_hash = hashlib.sha256(data).hexdigest()
print(sha256_hash)
# Key Derivation (PBKDF2, Scrypt, Argon2)
**Working Principle**: Key derivation functions take a password and convert it into a cryptographically secure key, often used to encrypt data. This process makes it harder for attackers to guess passwords using brute force attacks.
**How it works**:
- **Input**: A password and a random value called a “salt.”
- **Process**: The key derivation function applies many rounds of hashing to the password and salt, making it computationally expensive to guess passwords.
- **Output**: A derived key, which can then be used for encryption or authentication.
**PBKDF2 (Password-Based Key Derivation Function 2)**, **Scrypt**, and **Argon2** are algorithms used to slow down password cracking attempts by making each guess computationally expensive.
**Example Scenario**: When you create an account on a website, your password is not stored directly. Instead, the website uses PBKDF2 to hash and store a version of your password, which it compares when you log in.
Key derivation functions are used to derive a cryptographic key from a password.
**Libraries**:
- `cryptography`: Provides PBKDF2 and Scrypt.
- `argon2_cffi`: A library for Argon2, a modern key derivation function
from cryptography.hazmat.primitives.kdf.pbkdf2 import PBKDF2HMAC
from cryptography.hazmat.primitives import hashes
from cryptography.hazmat.backends import default_backend
import os
password = b"mysecretpassword"
salt = os.urandom(16)
kdf = PBKDF2HMAC(
algorithm=hashes.SHA256(),
length=32,
salt=salt,
iterations=100000,
backend=default_backend()
key = kdf.derive(password)
# Digital Signatures (RSA, ECDSA)
**Working Principle**: Digital signatures provide authenticity and integrity. They allow the recipient of a message to verify that the message came from the sender and was not altered during transmission.
**How it works**:
- **Signing**: The sender hashes the message and encrypts the hash using their private key, creating a signature.
- **Verification**: The recipient decrypts the signature using the sender’s public key and compares the resulting hash with the hash of the message they received. If the hashes match, the message is authentic.
**RSA** and **ECDSA (Elliptic Curve Digital Signature Algorithm)** are commonly used for digital signatures.
**Example Scenario**: When a software company releases an update, they include a digital signature. Before installing the update, your computer verifies the signature to ensure that the update came from the company and hasn’t been tampered with.
Digital signatures ensure the authenticity and integrity of a message. RSA and ECDSA are commonly used algorithms for signing data.
**Libraries**:
- `cryptography`: Provides RSA and ECDSA for digital signatures.
**Example using RSA Digital Signature (using** `cryptography` **):**
from cryptography.hazmat.primitives.asymmetric import padding, rsa
from cryptography.hazmat.primitives import hashes
private_key = rsa.generate_private_key(public_exponent=65537, key_size=2048)
message = b"Important Message"
# Sign the message
signature = private_key.sign(
message,
padding.PSS(
mgf=padding.MGF1(hashes.SHA256()),
salt_length=padding.PSS.MAX_LENGTH
hashes.SHA256()
# Verify the signature
public_key = private_key.public_key()
public_key.verify(
signature,
message,
padding.PSS(
mgf=padding.MGF1(hashes.SHA256()),
salt_length=padding.PSS.MAX_LENGTH
hashes.SHA256()
# Message Authentication Code (HMAC)
**Working Principle**: HMAC (Hash-based Message Authentication Code) ensures data integrity and authenticity using a secret key and a hashing function.
**How it works**:
- **Authentication**: The sender hashes the message with a secret key, creating a HMAC.
- **Verification**: The recipient, who also has the secret key, hashes the received message and compares the HMAC. If the values match, the message is authentic.
**Example Scenario**: When two systems communicate (e.g., a client and server), they can use HMAC to ensure that the messages exchanged haven’t been modified during transmission.
HMAC provides both data integrity and authenticity using a cryptographic hash function and a secret key.
**Libraries**:
- `hmac`: A built-in Python module.
**Example using HMAC (using** `hmac` **):**
import hmac
import hashlib
key = b'secret_key'
message = b'Important Message'
hmac_result = hmac.new(key, message, hashlib.sha256).hexdigest()
print(hmac_result)
# Steganography
**Working Principle**: Steganography hides secret data within another file (such as an image, audio, or video file) without visibly altering the original file. Unlike encryption, which makes the data unreadable, steganography conceals the very existence of the data.
**How it works**:
- **Hiding**: Secret data is embedded into the least noticeable parts of the file (for example, in the least significant bits of an image).
- **Extraction**: The secret data is extracted from the original file without anyone else noticing it was there.
**Example Scenario**: You might hide a secret message within an image file by slightly altering some pixel values. To a viewer, the image looks the same, but with the right tool, the secret message can be revealed.
Steganography hides data within another medium, such as images or audio files. While not a core cryptography technique, it’s often used for covert communication.
**Libraries**:
- `Stegano`: A Python library for basic steganography techniques.
**Example using Stegano (hiding text in an image):**
from stegano import lsb
secret = lsb.hide("input_image.png", "Secret message")
secret.save("output_image.png")
# To reveal the message
message = lsb.reveal("output_image.png")
print(message)
# Conclusion :
- **Symmetric Encryption (AES)**: Same key for encryption and decryption, fast and secure, widely used.
- **Asymmetric Encryption (RSA, ECC)**: Public key for encryption, private key for decryption, secure for communication.
- **Hashing (SHA, MD5)**: One-way transformation of data to a fixed-length value, ensures data integrity.
- **Key Derivation (PBKDF2, Argon2)**: Transforms passwords into cryptographic keys, prevents easy password guessing.
- **Digital Signatures (RSA, ECDSA)**: Verifies authenticity of messages or files.
- **HMAC**: Ensures message integrity using a secret key and a hash function.
- **Steganography**: Hides data inside another file to conceal its existence.
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Cybersecurity and Cryptography: Their Eternal Relationship
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https://www.amu.apus.edu/area-of-study/information-technology/resources/cybersecurity-and-cryptography/
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cryptography encryption algorithms
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Yes (reduced from 16957 to 15658 chars)
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# Cybersecurity and Cryptography: Their Eternal Relationship
Information Technology Blog | American Military University
With the rapid, unbridled growth of technology and the internet, people, companies, and governments deeply rely on digital systems for storing, processing, and transmitting sensitive information.
Effective cybersecurity protects the confidentiality, integrity, and authenticity of sensitive data. From personal identification numbers (PINs) to sensitive financial data and national security secrets, the need for keeping information confidential and secure has utmost priority in today's digital world.
Cyber threats – from data breaches and ransomware attacks to phishing scams – are a constant danger. Cryptography, however, plays a vital role in ensuring that data remains secure.
## What Is Cryptography?
In cybersecurity, cryptography uses mathematical algorithms (mathematical formulas) to provide security for digital communications. Cryptography changes data into an encrypted form, accessible to a lone keyholder or any other authorized party. This encryption keeps data protected, even against sophisticated cyber-attacks.
The role of cryptography surpasses the mere protection of information. It underpins secure online transactions, authenticates protocols, and strengthens the communication channels of everything from a smartphone to global financial networks. With the growth of cyber threats, robust cryptographic practices have also grown, acting as a shield against both known and emerging perils.
## Why Is Cryptography Important?
Personal information, financial details, and intellectual property are all types of sensitive data that form the backbone of our society. A big challenge in cybersecurity is the protection of sensitive information against unauthorized access and manipulation.
Over time, cyber threats have grown in sophistication. Consequently, organizations need to adapt robust cryptographic techniques throughout the data lifecycle.
## The Core Principles of Cryptography
Cryptography relies on four basic principles:
- Confidentiality
- Integrity
- Authentication
- Non-repudiation
All four principles act as guidelines for cryptographic algorithms and enable secure communications in our ever-digitizing world.
### Confidentiality
In cryptography, confidentiality ensures that information is kept private and is only available to authorized users with the right type of key. Cryptographic techniques entail symmetric key cryptography and asymmetric encryption to reach this goal. Symmetric encryption, based on the use of the same key for both encryption and decryption, is usually used for the encryption of data due to its speed and efficiency.
The Advanced Encryption Standard (AES) is a widely adopted encryption algorithm of symmetric key cryptography. Symmetric key cryptography protects data packets, both in storage and in transit.
On the other hand, asymmetric encryption uses a public key and its corresponding private key in securing communications. For instance, online transactions use protocols such as Transport Layer Security (TLS).
### Integrity
Data integrity means that no alteration happens with data while it is in transmission or storage. Cryptographic hash functions, like Secure Hash Algorithm-256 (SHA-256), are in wide use for generating unique hash values of the data so that data authenticity can be verified.
If any modification happens to the data requiring protection, the hash value changes and the change signals potential tampering. The applications of cryptographic hash functions include password storage, financial transaction security, and the assurance of the validity of digital certificates.
### Authentication
Authentication establishes the identity of the data’s sender and receiver in any secure communication. Some of the important cryptographic techniques that perform authentication include public key cryptography and digital signatures.
The digital signature – created with the private key of the sender and with its authenticity checked by a public key – guarantees the origin and authenticity of the data. This technique has broad applications in secure data exchanges where sensitive data needs protection, such as communications or online transactions.
There are various mechanisms for authentication. They use encryption protocols and algorithms for digital signatures to ensure that encrypted data is only available to the correct recipient.
### Non-Repudiation
Non-repudiation implies that neither the sender or the receiver can refute an action and is held accountable. The cryptographic system is designed to provide non-repudiation by implementing digital signatures and asymmetric encryption.
Since the cryptographic algorithm involves public and private keys, the sender cannot repudiate a previously signed message, and the recipient cannot forge the sender’s signature. Non-repudiation is particularly important for sensitive data involved in any legal contract or financial transaction.
## Why Is Cryptography Necessary?
Personal information, financial details, and intellectual property are all types of sensitive data that form the backbone of modern digital ecosystems. A big challenge in cybersecurity is the protection of sensitive information against unauthorized access and manipulation.
Over time, cyber threats have grown in sophistication. Consequently, organizations need to adapt robust cryptographic techniques throughout the data lifecycle.
## Types of Cryptographic Algorithms and Their Role in Cybersecurity
Cryptographic algorithms ensure security and have different roles in data protection. They can be divided into three categories:
- Block and stream ciphers
- Hash functions
- Key derivation functions
### Block and Stream Ciphers
Block ciphers, such as AES, encrypt information in fixed-size blocks and are highly efficient for securing large quantities of data. AES has become the de facto encryption standard used in full-disk encryption applications for the protection of data at rest.
On the contrary, stream ciphers, including Rivest Cipher 4 (RC4), encrypt data in either one bit or a byte at a time. Stream ciphers are suitable for applications concerning real-time communication applications that involve voice or video streaming.
### Hash Functions
The cryptographic hash function is a type of algorithm that converts inputted data into a unique, fixed-length hash value. Even a single change to the original data results in a different hash value.
Hash functions are used for password storage, integrity verification of downloaded files, and the creation of digital signatures.
### Key Derivation Functions
Key derivation functions (KDFs) are algorithms used to harden a password or generate a cryptographic key from a user-provided input. Examples of KDFs include:
- Password-Based Key Derivation Function 2 (PBKDF2)
- Bcrypt
KDFs are less vulnerable to brute-force attacks and dictionary attacks. They can be used for the storage of passwords and generation of encryption keys within secure systems.
## Cryptographic Methods for Data Protection
There are various cryptographic methods to ensure that data remains secure. These solutions include:
- Encryption and decryption techniques
- Digital signatures
- Hash functions
- Key management and secure protocols
- Secret key cryptography
- Public key cryptography
### Encryption and Decryption Techniques
To encrypt data at one end and decrypt it at the other end, the sender and the receiver can use symmetrical cryptography or asymmetric cryptography. Both require the use of a private key or a public key.
Symmetrical cryptography uses the same symmetric key to encrypt data or decrypt data. It is very efficient for the bulk transfer of sensitive information, either for data stored within a computer or in raw form. The most notable example of this approach is the AES algorithm.
Asymmetric cryptography depends on a public key for encryption and a private key for decryption, making communication secure without sharing any secret keys. It is the basis for digital certificates, public key encryption, and asymmetric key algorithms in the secure exchanges of data.
### Digital Signatures and Data Integrity
In cryptography, digital signatures are created with a sender's key that is kept private to protect sensitive data and also verified by a public key to ensure data integrity and authenticity. The data can only be verified by an intended party and is difficult to alter.
### Hashing
Hash functions such as SHA-256 allow a digital fingerprint to be created, and systems use that fingerprint to identify encoded data that may have undergone unauthorized changes. Hashing plays an important part in ensuring data integrity, the safe storage and verification of password authenticity, and the validity of digital certificates.
### Key Management and Secure Protocols
Key management is effective in safeguarding encryption keys and enabling authorized users to access data that has been encrypted. TLS and virtual private network (VPN) protocols are used to maintain the security of data packets during transmission.
### Secret Key Cryptography
Secret key cryptography (also known as symmetric encryption) is one of the most deployed cryptographic techniques in cybersecurity. It leverages the same secret key to encrypt and decrypt data, and it is an uncomplicated but effective way of securing data.
Through this technique, plain text is transformed into encrypted data by the sender. The receiver uses the same key to decrypt the data.
Since the same key is used by both sender and receiver, data confidentiality is maintained. If an unauthorized user gains access to the key, then that user could decrypt the data.
Among the very first symmetric encryption algorithms that were developed to protect sensitive information was the Data Encryption Standard (DES). However, DES is now considered obsolete because it uses a short key that is susceptible to brute-force attacks enabled by advances in quantum computing and cryptanalysis.
The need for addressing the shortcomings of DES gave birth to the Advanced Encryption Standard (AES). AES has become the golden standard of cryptography because it offers robust security due to variable key lengths, such as 128-, 192-, or 256-bit keys.
Due to its effectiveness and efficiency, AES is also important for the encryption of financial transactions, data storage, and virtual private networks.
The Triple Data Encryption Standard (3DES) is an extension of DES. It makes use of the block cipher algorithm to keep data confidential and runs on a block of data three times with different keys. While it improves on security compared to DES, 3DES is slower and less efficient than AES.
Symmetric encryption is very fast. As a result, large sets of information can be encrypted quickly, which is particularly useful for real-time secure communications.
Symmetric encryption also requires a low amount of computation. It is helpful for environments when computing resources are meager and very limited.
Symmetric encryption also has its limitations when it comes to keeping data secure. The major problem is key distribution.
Secure key exchange methods should ensure that only the correct decryption key is obtained by the sender or receiver. Otherwise, that key would render an entire communication prone to risk in case any part of it is divulged to the wrong user.
### Public Key Cryptography
Public key cryptography – also known as asymmetric cryptography – employs a public key used for asymmetrically encrypting plaintext or data. It also uses a key that is kept private and reverse-encrypts cyphertext for the receiver. This separation of keys provides an alternative to sharing a single encryption key, allowing key exchanges to be handled more securely.
In public key cryptography, only the intended recipient with the appropriate decryption key can access encrypted data. For data encrypted via a recipient's public key, that data can only be decrypted with a private key to keep it confidential.
Public key cryptography depends on a number of complex encryption algorithms. The Rivest-Shamir-Adleman (RSA) algorithm is one of the earliest and most used algorithms in cryptography. It is based on the mathematical problem of factoring large prime numbers.
Another advanced algorithm involves Elliptic Curve Cryptography (ECC), which offers similar security to RSA but uses smaller key sizes, so that it is more efficient for resource-constrained devices. These algorithms have a key role in data encryption, digital signatures, and secure key exchanges.
Asymmetric cryptography provides better security in cases of exchange of keys or user authenticity than symmetric cryptography. However, it is computatively intensive and slower than symmetric cryptography.
Public key cryptography is unsuitable for large amounts of data encryption. Many cybersecurity specialists use a hybrid approach by first using public keys, then private keys to combining the strengths of the two different systems.
## Future Challenges in the Protection of Sensitive Data
Sensitive information, either in storage or during transmission or processing, often undergoes certain risks. Cybercriminals exploit any security gaps they find and gain unauthorized access to computer systems. The resulting breach results in the loss of data and brings financial losses to an organization.
To protect data at every stage, organizations should implement cryptography for strong encryption techniques, good security management, and security protocols. Other cybersecurity threats such as quantum computing might soon make traditional cryptographic algorithms obsolete. As a result, cybersecurity professionals will need to work harder in the future to further safeguard communication and storage systems.
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What Is Data Encryption: Types, Algorithms, Techniques and Methods
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https://www.simplilearn.com/data-encryption-methods-article
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cryptography encryption algorithms
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Yes (reduced from 49389 to 37556 chars)
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## CATEGORIES
- Generative AI
- AI & Machine Learning
- Data Science & Business Analytics
- Project Management
- Cyber Security
- Agile and Scrum
- Cloud Computing & DevOps
- Business and Leadership
- Software Development
- Product and Design
- IT Service and Architecture
- Quality Management
- Digital Marketing
## OBJECTIVE
- Certifications
- Career Aligned Learning Paths
**What is Data Encryption?** **How Does Data Encryption Work?** **Why Do We Need Data Encryption?** **What are the 2 Types of Data Encryption Techniques?** **What is Hashing?** **What is an Encryption Algorithm?** **Best Encryption Algorithms** **3DES** **The Future of Data Encryption** **Should You Use Symmetric or Asymmetric Encryption?** **Businesses Use Encryption For Many Purposes** **Steps to Implement an Effective Encryption Strategy** **What Is a Key in Cryptography?** **Do You Want to Learn More About Cybersecurity?** **FAQs**
Data encryption is a common and effective security method—a sound choice for protecting an organization’s information. However, there are a handful of different encryption methods available, so how do you choose?
In a world where cybercrimes are on the rise, it’s comforting to know that there are as many methods available to protect network security as there are ways of trying to penetrate it. The real challenge is deciding which techniques an internet security expert should employ that best suits their organization’s specific situation.
## What is Data Encryption?
Data encryption is a method of protecting data by encoding it in such a way that it can only be decrypted or accessed by an individual who holds the correct encryption key. When a person or entity accesses encrypted data without permission, it appears scrambled or unreadable.
Data encryption is the process of converting data from a readable format to a scrambled piece of information. This is done to prevent prying eyes from reading confidential data in transit. Encryption can be applied to documents, files, messages, or any other form of communication over a network.
In order to preserve the integrity of our data, encryption is a vital tool whose value cannot be overstated. Almost everything we see on the internet has passed through some layer of encryption, be it websites or applications.
Noted antivirus and endpoint security experts at Kaspersky define encryption as “… the conversion of data from a readable format into an encoded format that can only be read or processed after it's been decrypted.”
They go on to say that encryption is considered the basic building block of data security, widely used by large organizations, small businesses, and individual consumers. It’s the most straightforward and crucial means of protecting information that passes from endpoints to servers.
Considering the elevated risk of cybercrime today, every person and group that uses the internet should be familiar with and incorporate basic encryption techniques, at the very least.
Looking to excel in data management? Simplilearn's data management courses offer expert insights and practical knowledge for success.
In the realm of cybersecurity education, a comprehensive cyber security bootcamp offers an opportunity to dive into the intricacies of data encryption. Participants gain insights into various encryption methods, such as symmetric and asymmetric encryption, and their significance in safeguarding sensitive information.
## How Does Data Encryption Work?
The data that needs to be encrypted is termed plaintext or cleartext. The plaintext needs to be passed via some encryption algorithms, which are basically mathematical calculations to be done on raw information. There are multiple encryption algorithms, each of which differs by application and security index.
Apart from the algorithms, one also needs an encryption key. Using said key and a suitable encryption algorithm, the plaintext is converted into the encrypted piece of data, also known as ciphertext. Instead of sending the plaintext to the receiver, the ciphertext is sent through insecure channels of communication.
Once the ciphertext reaches the intended receiver, he/she can use a decryption key to convert the ciphertext back to its original readable format i.e. plaintext. This decryption key must be kept secret at all times, and may or not be similar to the key used for encrypting the message. Let’s understand the same with an example.
Let us understand the work process with the help of an example.
### Example
A woman wants to send her boyfriend a personal text, so she encrypts it using specialized software that scrambles the data into what appears to be unreadable gibberish. She then sends the message out, and her boyfriend, in turn, uses the correct decryption to translate it.
Thus, what starts out looking like this:
Fortunately, the keys do all the actual encryption/decryption work, leaving both people more time to contemplate the smoldering ruins of their relationship in total privacy.
Next, in our learning about effective encryption methods, let us find out why we need encryption.
## Why Do We Need Data Encryption?
If anyone wonders why organizations need to practice encryption, keep these four reasons in mind:
- Authentication: Public key encryption proves that a website's origin server owns the private key and thus was legitimately assigned an SSL certificate. In a world where so many fraudulent websites exist, this is an important feature.
- Privacy: Encryption guarantees that no one can read messages or access data except the legitimate recipient or data owner. This measure prevents cybercriminals, hackers, internet service providers, spammers, and even government institutions from accessing and reading personal data.
- Regulatory Compliance: Many industries and government departments have rules in place that require organizations that work with users’ personal information to keep that data encrypted. A sampling of regulatory and compliance standards that enforce encryption include HIPAA, PCI-DSS, and the GDPR.
- Security: Encryption helps protect information from data breaches, whether the data is at rest or in transit. For example, even if a corporate-owned device is misplaced or stolen, the data stored on it will most likely be secure if the hard drive is properly encrypted. Encryption also helps protect data against malicious activities like man-in-the-middle attacks, and lets parties communicate without the fear of data leaks.
Also Read: Bridging The Gap Between HIPAA & Cloud Computing
Let us now find out the important types of data encryption methods.
## What are the 2 Types of Data Encryption Techniques?
There are several data encryption approaches available to choose from. Most internet security (IS) professionals break down encryption into three distinct methods: symmetric, asymmetric, and hashing. These, in turn, are broken down into different types. We’ll explore each one separately.
### What is the Symmetric Encryption Method?
Also called private-key cryptography or a secret key algorithm, this method requires the sender and the receiver to have access to the same key. So, the recipient needs to have the key before the message is decrypted. This method works best for closed systems, which have less risk of a third-party intrusion.
On the positive side, symmetric encryption is faster than asymmetric encryption. However, on the negative side, both parties need to make sure the key is stored securely and available only to the software that needs to use it.
### What is the Asymmetric Encryption Method?
Also called public-key cryptography, this method uses two keys for the encryption process, a public and a private key, which are mathematically linked. The user employs one key for encryption and the other for decryption, though it doesn’t matter which you choose first.
As the name implies, the public key is freely available to anyone, whereas the private key remains with the intended recipients only, who need it to decipher the messages. Both keys are simply large numbers that aren’t identical but are paired with each other, which is where the “asymmetric” part comes in.
## What is Hashing?
Hashing generates a unique signature of fixed length for a data set or message. Each specific message has its unique hash, making minor changes to the information easily trackable. Data encrypted with hashing cannot be deciphered or reversed back into its original form. That’s why hashing is used only as a method of verifying data.
Many internet security experts don’t even consider hashing an actual encryption method, but the line is blurry enough to let the classification stand. The bottom line, it’s an effective way of showing that no one has tampered with the information.
Now that we have gone through the types of data encryption techniques, let us next learn the specific encryption algorithms.
## What is an Encryption Algorithm?
Encryption algorithms are used to convert data into ciphertext. By using the encryption key, an algorithm can alter data in a predictable manner, resulting in the encrypted data appearing random, but it can be converted back into plaintext by using the decryption key.
## Best Encryption Algorithms
There’s a host of different encryption algorithms available today. Here are five of the more common ones.
- AES. The Advanced Encryption Standard (AES) is the trusted standard algorithm used by the United States government, as well as other organizations. Although extremely efficient in the 128-bit form, AES also uses 192- and 256-bit keys for very demanding encryption purposes. AES is widely considered invulnerable to all attacks except for brute force. Regardless, many internet security experts believe AES will eventually be regarded as the go-to standard for encrypting data in the private sector.
- Triple DES. Triple DES is the successor to the original Data Encryption Standard (DES) algorithm algorithm"), created in response to hackers who figured out how to breach DES. It’s symmetric encryption that was once the most widely used symmetric algorithm in the industry, though it’s being gradually phased out. TripleDES applies the DES algorithm three times to every data block and is commonly used to encrypt UNIX passwords and ATM PINs.
- RSA. RSA is a public-key encryption asymmetric algorithm and the standard for encrypting information transmitted via the internet. RSA encryption is robust and reliable because it creates a massive bunch of gibberish that frustrates would-be hackers, causing them to expend a lot of time and energy to crack into systems.
- Blowfish. Blowfish is another algorithm that was designed to replace DES. This symmetric tool breaks messages into 64-bit blocks and encrypts them individually. Blowfish has established a reputation for speed, flexibility, and is unbreakable. It’s in the public domain, so that makes it free, adding even more to its appeal. Blowfish is commonly found on e-commerce platforms, securing payments, and in password management tools.
- Twofish. Twofish is Blowfish’s successor. It’s license-free, symmetric encryption that deciphers 128-bit data blocks. Additionally, Twofish always encrypts data in 16 rounds, no matter what the key size. Twofish is perfect for both software and hardware environments and is considered one of the fastest of its type. Many of today’s file and folder encryption software solutions use this method.
- Rivest-Shamir-Adleman (RSA). Rivest-Shamir-Adleman is an asymmetric encryption algorithm that works off the factorization of the product of two large prime numbers. Only a user with knowledge of these two numbers can decode the message successfully. Digital signatures commonly use RSA, but the algorithm slows down when it encrypts large volumes of data.
## The Future of Data Encryption
As a result, the industry is pushing encryption on several fronts. Some attempts are being made to increase key sizes in order to prevent brute-force decoding. Other initiatives are investigating novel cryptography algorithms. For example, the National Institute of Standards and Technology is testing a quantum-safe next-generation public key algorithm.
The issue is that most quantum-safe algorithms are inefficient on traditional computer systems. To overcome this issue, the industry is concentrating on inventing accelerators to accelerate algorithms on x86 systems.
Homomorphic encryption is a fascinating notion that allows users to do computations on encrypted data without first decrypting it. As a result, an analyst who requires it can query a database holding secret information without having to seek permission from a higher-level analyst or request that the data be declassified.
In addition to securing data in all states, homomorphic encryption also protects it in motion, while in use, and while at rest (on a hard drive). Another advantage is that it is quantum-safe, as it uses some of the same arithmetic as quantum computers.
## Should You Use Symmetric or Asymmetric Encryption?
Asymmetric and symmetric encryption are both better suited to specific scenarios. Symmetric encryption, which employs a single key, is preferable for data-at-rest. Data contained in databases must be encrypted to prevent it from being hacked or stolen. Because this data only has to be secure until it needs to be retrieved in the future, it does not require two keys, simply the one supplied by symmetric encryption. Asymmetric encryption, on the other hand, should be used on data transferred to other persons via email. If only symmetric encryption was used on data in emails, an attacker may steal or compromise the material by obtaining the key used for encryption and decryption. Since their public key was used to encrypt the data, the sender and receiver ensure that only the recipient may decrypt the data using asymmetric encryption. Both methods of encryption are used in conjunction with other procedures, such as digital signature or compression, to give further data protection.
## Businesses Use Encryption For Many Purposes
Data encryption in businesses eliminates information breaches and reduces the cost of their impact. It is one of the most effective security methods for protecting sensitive information, but you must understand what documents to encrypt and how to use them efficiently.
According to a 2019 survey, around 45% of firms have a consistent encryption policy in place across their enterprise. If your firm operates on cloud infrastructure, you must first plan your security requirements for your cloud deployment and any data that will be moved to the cloud. Make a list of all sensitive data sources so you know what needs to be encrypted with which degree of bit-key security.
If your organization is developing a cloud-based website, for example, you will need to allow engineers and manufacturers to exchange source code and design documents among themselves. You would need to install end-to-end encryption protection using one of the numerous ways discussed in this article to safeguard the sensitive data that they would need to communicate. You can ensure the safety of your data in the cloud even if the cloud storage provider or your account is compromised even if some cloud providers provide some level of encryption.
## Steps to Implement an Effective Encryption Strategy
### Collaboration
Developing an encryption strategy necessitates teamwork. It is better to approach it as a large-scale project including members of management, IT, and operations. Begin by gathering important data from stakeholders and identifying the legislation, laws, guidelines, and external forces that will impact purchase and implementation decisions. You can then proceed to identify high-risk places such as laptops, mobile devices, wireless networks, and data backups.
### Define Your Security Requirements
It's helpful to have a general concept of your security requirements. A threat assessment is a smart place to start since it will help you identify what data needs to be encrypted. The strength and processing requirements of different encryption systems might vary, therefore it's also crucial to assess how secure your system needs to be.
### Select the Appropriate Encryption Tools
Once you've determined your security requirements, you can start looking for the solutions that will best fulfill them. Keep in mind that in order to effectively protect your network, you will most likely need to install various data encryption algorithms. For example, you may utilize a secure sockets layer (SSL) protocol to encrypt data sent to and from your website, together with the advanced encryption standard (AES) to safeguard data at rest and backups. Using the correct encryption technologies at each level of data storage and transit will assist to keep your company's data as safe as possible. Encrypted applications, such as encrypted email services, may also help to ensure overall security.
### Prepare to Smoothly Deploy Your Encryption Plan
The execution of your encryption strategy, like any big change in your firm, must be well-planned. If you have customer-facing apps, your new encryption may need to be integrated into the application's back end. Similarly, additional procedures may be required to integrate your new encryption method with legacy systems. You can implement these changes with minimal disturbance if you make excellent planning ahead of time. Working with a third-party IT service provider may also aid in the transition. You will not overload your own IT personnel with too many chores involved with implementing your encryption approach.
### After Installation, Maintain Security Culture
Data encryption, as valuable as it is, is not a panacea for your security problems. To get good outcomes, ensure sure your team is educated to use proper encryption and key management methods. If workers put their encryption keys on insecure servers, hostile attackers may get access to your company's encrypted data. This type of human mistake is thought to be responsible for 84 percent of cybersecurity breaches. Encryption should be used in conjunction with other security techniques to maximize security. Your company may keep its data safe with many levels of security by deploying secure hardware and a strong firewall in conjunction with data encryption.
## What Is a Key in Cryptography?
A key is a string of random characters in a certain sequence. Encryption techniques utilize a key to jumble data so that anybody without the key cannot decipher the information. Algorithms, which are sophisticated mathematical calculations, are used in modern encryption. Modern keys are generally randomized much further than a basic string of random integers.
This is true for a number of reasons:
1. Computers can do significantly more complex computations in far less time than human cryptographers, making more complex encryption not only conceivable but also required.
2. Computers may change information at the binary level, the 1s and 0s that make up data, rather not only at the letter and number level.
3. Computer software can decode encrypted data if it is not sufficiently randomized. True randomness is critical for really safe encryption.
A cryptographic key, when combined with an encryption method, will jumble a text beyond human recognition.
## Do You Want to Learn More About Cybersecurity?
There’s a lot to learn about cybersecurity, and Simplilearn offers a great selection of valuable courses to help you enter this challenging field or improve your existing knowledge by upskilling. For instance, if you want to become an ethical hacker, and have a career testing network systems, check our CEH certification course.
Or check out some enterprise-level security training courses such as CISM, CSSP, CISA, CompTIA, and COBIT 2019.
If you can’t decide between the above courses, why not take a handful of them in one convenient program? The Cyber Security Expert Master’s Program teaches you the principles of CompTIA, CEH, CISM, CISSP, and CSSP.
### Do You Want to Become a Network Security Professional?
If you’re ready to take those first steps on the path to becoming a network security professional, then you should start with Simplilearn’s CISSP certification training course. The course develops your expertise in defining IT architecture and in designing, building, and maintaining a secure business environment using globally approved information security standards.
The course covers industry best practices and prepares you for the CISSP certification exam held by (ISC)². Additionally, consider exploring our cyber security course online and the best cybersecurity bootcamp to further enhance your skills and knowledge in the field.
You get over 60 hours of in-depth learning, the requisite 30 CPEs you need for taking the certification exam, five simulation test papers designed to help you prepare for the exam, plus an exam voucher. Whether you choose self-paced learning, the Blended Learning option, or a corporate training solution, you will get the benefits of Simplilearn’s expert training, and be ready to embark on that challenging and rewarding network security career!
## FAQs
### 1\. What is data encryption?
Data Encryption is the process of protecting and securing data by encoding it in such a way that it can only be accessed or decrypted by someone who has the encryption key. In Data encryption, the data is scrambled before it is sent to the person who can unscramble it using a key.
### 2\. What are the 2 types of data encryption?
The two types of data encryption methods are Symmetric Encryption and Asymmetric Encryption. Symmetric encryption is also known as private-key cryptography or secret key algorithm and requires both the parties of sender and receiver to have access to the same key to decrypt the data. Asymmetric Encryption, also known as public-key cryptography, uses two separate keys for encryption process. One key is a public key and the other is a private key which are linked and used for encryption and decryption.
### 3\. What is encryption used for?
Encryption is used to protect data being transmitted. This ensures data doesn’t fall into the wrong hands of cybercriminals, hackers, internet service providers, spammers, and even government institutions. Any time you access ATM or sending messages across devices such as Snapchat, these messages are encrypted to ensure that no-one other than the person it was sent to can access it.
### 4\. Insights on data encryption?
There is a massive amounts of data being stored on cloud servers and being transmitted everyday. It is virtually impossible to conduct day-to-day operations without storing or transmitting these copious amounts of data. Data encryption software ensure that the data is secured and transmitted safely from one channel to another.
### 5\. How data encryption works
The raw data is in plain text, which means it can be read legibly. This data is then transmitted through encryption algorithms that scramble the data from ‘Hi! How are you?’ to ‘A#$\*Y\*&%($Y#\*%Y%\*’. This data is then transmitted across to the receiver, which then goes through an decryption process before is visually presented as plain text to the receiver.
### 6\. Can encrypted data be hacked?
Yes, encrypted data can be hacked. However, depending on the level of encryption applied on the data, the difficulty level increased.
### 7\. How to implement Data encryption?
Before you start implementing Data encryption, you need to understand and define your security needs. The level of encryption will depend on the level of security required by you and your organization. Choose the right encryption tools that suit your needs. Create and implement a encryption strategy. Learn more in detail about data encryption with our Cyber Security Expert course.
### 8\. What is data encryption examples?
WEP and WPA are encryption technologies that are extensively used in wireless routers. Examples of asymmetric encryption include RSA and DSA. RC4 and DES are two instances of symmetric encryption. In addition to encryption techniques, there are what is known as Common Criteria (CC).
### 9\. What is data encryption and why is it important?
Simply put, encryption is the act of encoding data so that it is concealed from or unavailable to unauthorized users. It aids in the protection of private information and sensitive data, as well as the security of communication between client apps and servers.
### 10\. What is data encryption in DBMS?
Encrypting data involves changing it from a readable (plaintext) format to an unreadable, encoded one (ciphertext). Data that has been encrypted can only be viewed or processed after it has been decrypted with a decryption key or password.
### 11\. What are the 4 basic types of encryption systems?
- Advanced Encryption Standard (AES)
- Triple DES
- Blowfish
- Rivest-Shamir-Adleman (RSA)
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Top 5 Penetration Testing Methodologies - VikingCloud
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https://www.vikingcloud.com/blog/top-5-penetration-testing-methodologies
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# Top 5 Penetration Testing Methodologies
When it comes to protecting networks and infrastructure against cyber-attacks, penetration testing remains one of the most effective and efficient ways to analyze strength and posture. Specifically, this testing **mimics attackers’ actions** so you get a clearer idea of what’s at stake.
That said, there are a few different ways of running and managing penetration testing. In this guide, we explore the **most effective penetration testing methodologies** and how they differ.
## What is Penetration Testing Methodology?
A penetration testing methodology refers to **_how_** **pen testing procedures,** **or ethical hacking, takes place.** It can refer to actions taken, tools used, and specific testing focuses. It’s a series of technical guidelines followed to ensure security vulnerabilities are found and investigated.
For example, some internal penetration test methodologies might focus on attacking internal APIs and servers, while others might focus on code injections through web applications.
Whether external or internal testing, the methodology you use will vary depending on your needs and the processes followed by your chosen tester. Consider researching options such as ISSAF, the Information System Security Assessment Framework, or any of those we explore below.
## Top 5 Penetration Testing Methodologies
Penetration testing is never a one-template process – we’ve brought together the five most popular and effective methodologies used by experts worldwide. Let’s explore what each methodology covers, and why you might consider using them.
### Open Source Security Testing Methodology Manual (OSSTMM)
The OSSTMM, developed by the Institute forSecurity and Open Methodologies, or ISECOM, remains one of the most popular methodologies for its broad acceptance among cybersecurity peers.
This penetration testing framework takes a straightforward, scientific approach to testing infrastructure vulnerabilities.Over the years, it’s expanded from an initial network focus to cover aspects such as IoT, cloud computing, wireless connectivity, and general ops.
**Key elements of this methodology can include:**
- Testing communication channels such as SMS, Bluetooth, email, and WiFi
- Analyzing physical operations, security policy standards, and potential for human error
- Assessing the potential for security maintenance and adherence
- Deep scientific measuring of general test metrics
- Researching potential areas of attacker ingress and egress (e.g., phishing, social engineering, firewall misconfigurations, source code weaknesses)
### Open Web Application Security Project (OWASP)
The OWASP testing guide is a non-profit platform that aims to make web application penetration testing free and accessible to all who might need it.
It’s well-known for its Top 10, which advises business owners and network operators of the biggest threats currently at large. As the name suggests, it’s specifically targeted at the external testing of web applications.
OWASP’s flexible pen test framework proves particularly useful for operators and businesses with custom APIs, IoT devices, and customer-facing mobile applications. It’s also relied upon to spot logical security issues – even in physical security – that might have been missed.
**Key elements of this methodology can include:**
- Simplified testing phases –gather, assess, analyze, review
- Specific code injection, security controls, and authentication analyses
- Detailed test typing and reporting(such as input validation and ID management)
- Flexible web app reconnaissance based on APIs and popular frameworks
### National Institute of Standards and Technology (NIST)
The NIST methodology largely focuses on penetration testing developed to benefit government agencies and holders of highly sensitive information. Many consider the rules set by NIST to be the absolute minimum.
This methodology, otherwise known as NISTSpecial Publication 800-115, is highly specific and routine. It has clear but meticulous guidelines for companies of all sizes. It’s considered one of the most technical network penetration testing methodologies, though it’s designed to run broad and deep.
**Key elements of this methodology can include:**
- Meticulous planning stages and scoping, which includes establishing team responsibilities
- Scrutinous attack method planning and network movement mapping
- Deep reporting covering basic findings, potential diagnoses, and recommended remediation
- Discussion of ethical and legal considerations for penetration testing
### Penetration Testing Execution Standard (PTES)
The PTES methodology was designed by penetration testers and cybersecurity professionals to provide a thorough oversight of network infrastructure vulnerabilities. Essentially, its purpose is to become the absolute “bottom line” of penetration testing on which all operators should follow.
This methodology provides careful technical guidance from the start to the end of any given penetration testing strategy.Many professionals rely on the PTES method to guide them through often complex procedures.
**Key elements of this methodology can include:**
- Exploitation and post-exploitation analysis
- Best practice suggestions for testing methods and attack vectors (e.g., cross-site scripting)
- Detailed pre-engagement rule setting and legal considerations
- In-depth threat modeling and attack vector brainstorming
### Council of Registered Ethical Security Testers (CREST)
CREST refers to an accreditation that penetration testers can obtain to ensure they offer high-quality vulnerability analysis and threat mitigation strategies to clients. It’s a standard that started life in the UK but has since expanded overseas.
CREST’s non-profit approach aims to help people and organizations fine-tune their security standards without letting restrictive budgets or a lack of knowledge get in the way. CREST penetration testing is designed to adhere to regulations recommended by ISO 27001 and PCIDSS and can help companies comply with the GDPR.
**Key elements of this accreditation’s methodology include preparing testers for:**
- Detailed scoping and planning
- Custom reconnaissance procedures
- Exploiting specific weaknesses with pre-agreed testing tools and resources
- Developing a penetration testing report and data protection recommendations
## Why is it Vital to Follow Penetration Testing Methodologies?
Following pen testing methodologies ensures that this type of attack simulation is handled safely and within guidelines set by security professionals.
When arranging penetration testing services, you want complete assurance that the experts you work with have a clear framework in place and that there are no risks of harm dealt through attack simulations.
Methodologies like those used above can help testers and their clients adhere to safe guidelines that will enable them to spot potential vulnerabilities and find recommendations. Blindly testing and mimicking attacks on infrastructure can be extremely hazardous and is never recommended.
Following penetration methodology templates also ensures businesses and operators adhere to regulatory and compliance guidelines. For example, some methodologies are developed with the GDPR and ISO principles in mind. These are specifically developed to cover all legal bases – making it easier for no stone to remain unturned.
**Working without a methodology can also be complex** – some companies might not need the depth of more technical strategies depending on their audiences. Others might not hold the sensitive data commanded by government agencies.
Meanwhile, some methodologies – such as OWASP– focus on web applications, which isn’t relevant to all companies seeking pen testing.
Crucially, a cybersecurity expert or team that follows a penetration testing methodology has a clear template or framework to back up their decisions. What’s more, the clients they work with are reassured that there’s a clear plan in place.
Methodologies also help testers narrow down specific attack choices and ensure they can agree upon vital steps with their clients. It’s better to establish a testing process than to improvise it.
## Stages of Penetration Testing Methodologies
As you’ve seen, the most popular penetration testing methodologies will vary in terms of scope, focus, and depth. However, most will follow the same basic template or skeleton. Here’s what to expect from the average penetration testing methodology, stage by stage:
- **Scoping and planning:** Before any testing takes place, testers will develop clear methodology plans about functionality. This can involve scoping out the organization they’re working with and learning about their infrastructure. At this stage, a tester might decide between white box and black box testing, for example. ****
- **Building inventory:** Once testers know about their client’s scope and needs, they will start to accrue automated tools, interfaces, and processes they can use to start investigating. This can involve diving into methodologies to find recommended attack vectors and testing standards for specific needs. ****
- **Reconnaissance:** At the recon stage, testers use tools and techniques they’ve agreed upon to start looking for vulnerabilities and weaknesses in their clients’ infrastructure. They will record these flaws and use their lists to start their attacks in later stages. ****
- **Analysis:** Some methodologies require testers to further explore vulnerabilities before they start launching attacks. It’sbetter to be sure than to be sorry – and with both manual testing and automated vulnerability scanning, testers can be reassured about the attack vectors they have in mind.
- **Attack launch:** After thorough analysis is complete, testers will use their tools and techniques to assess the strength of a company’s security posture. They do this by focusing on vulnerabilities found, using different attack strategies, and recording insights.
- **Reporting:** The final stage of most penetration testing methodologies is to report back to the client. A tester will have recorded where potential flaws might reside, how they exploited them, and what actions clients should take to harden their network security postures.
As mentioned, this is just a simple overview of what you might expect from different types of penetration testing and the methodologies testers follow.
Ultimately, penetration testing methodologies help cybersecurity experts and their clients stick to the same page – and ensure all recommendations made fall in line with compliance needs.
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What Are the 3 Types of Penetration Testing? Methods, Use Cases ...
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https://www.invicti.com/blog/web-security/types-of-penetration-tests/
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## **Why are penetration tests performed?**
Organizations perform penetration tests to:
- Assess the real-world exploitability of vulnerabilities
- Validate the effectiveness of existing security controls
- Fulfill regulatory and compliance requirements (e.g., PCI DSS, HIPAA, SOC 2)
- Build trust with stakeholders by demonstrating proactive risk management
- Improve overall incident response and security maturity
## **What are the types of penetration testing?**
At a high level, penetration testing methodologies can be classified depending on how much knowledge and access the tester has at the start of the engagement. The approach adopted will vary depending on the specific scope required by the client.
### **Black-box penetration testing**
In black-box or outside-in testing, the tester has no prior knowledge of the target environment or access to its internals. Penetration testing software simulates the actions of an external attacker and reveals what information an outsider could gather and what security weaknesses could be exploited.
### **White-box penetration testing**
White-box testing gives the tester full access to internal documentation, source code, and system architecture. It allows for a thorough, deep-dive assessment of potential vulnerabilities to identify not only immediately exploitable gaps but also internal weaknesses that attackers could target after gaining an initial foothold.
### **Gray-box penetration testing**
Gray-box testing offers a hybrid approach, providing testers with partial insider knowledge, such as selected credentials or limited information about the internal architecture. It aims to simulate what a privileged user (or a compromised privileged account) or an insider threat might achieve.
## **What areas of cybersecurity can you test during penetration testing?**
The scope of a pentesting engagement can vary from one specific area (most commonly network and application security) to a no-holds-barred red-team exercise where testers are allowed to use any and all dirty tricks to try and get their hands on company data and systems.
### **Wireless security testing**
Wireless penetration testing focuses on Wi-Fi networks, access points, and related infrastructure.
#### **Why should you perform wireless network penetration tests?**
Wireless networks can be an easy entry point for attackers if misconfigured or weakly secured. A wireless pen test can identify rogue access points, insecure encryption, and opportunities for man-in-the-middle attacks.
### **Network security testing**
Network penetration tests target internal or external networks to find weaknesses in routers, switches, firewalls, and other infrastructure.
#### **Why should you perform network penetration tests?**
Testing your network helps uncover open ports, misconfigured services, and exploitable vulnerabilities that could allow lateral movement or unauthorized access to sensitive systems.
### **Social engineering resilience testing**
These tests simulate phishing, pretexting, impersonation, or other psychological tactics to trick employees into revealing credentials or other sensitive data.
#### **Why should you perform social engineering tests?**
People are often the weakest link in security. Testing human susceptibility to manipulation helps strengthen training and policies to reduce this risk.
### **Physical security testing**
Physical penetration testing evaluates the security of buildings and facilities to see if a real attacker could gain unauthorized access, bypass locks, or access restricted areas.
#### **Why should you perform a physical penetration test?**
Even the best digital defenses won’t help if an attacker can walk into your data center or steal unencrypted hardware from the office. Physical tests ensure your security controls extend beyond the network.
### **Firewall testing**
This test evaluates the configuration and effectiveness of network and application firewalls in enforcing network segmentation and access controls.
#### **Why should you penetration test your firewall?**
Firewalls are your first line of defense, but they’re only as effective as their rules. Testing can uncover misconfigurations, overly permissive rules, or weaknesses in filtering mechanisms.
### **Web application security testing**
Web app penetration testing simulates attacks against public-facing or internal applications to find vulnerabilities like SQL injection, cross-site scripting (XSS), broken access controls, and more.
#### **Why should you perform web application penetration tests?**
Web apps are the most common cybersecurity attack vector. Pen testing uncovers exploitable flaws in the logic, implementation, or configuration of your applications that could lead to data breaches or service disruptions.
### **Mobile application security testing**
Mobile pen testing evaluates iOS and Android apps, backends, and APIs for insecure storage, weak authentication, and other platform-specific issues.
#### **Why should you pen test mobile applications?**
Mobile apps interact with sensitive user data and APIs, often providing an additional front-end for accessing critical systems. Testing ensures they can’t be exploited via weak client-side logic, ineffective authentication, or insecure data handling.
### **Cloud security testing**
Cloud penetration testing targets misconfigurations and vulnerabilities in services hosted on platforms like AWS, Azure, or Google Cloud.
#### **Why should you pen test your cloud infrastructure?**
Cloud misconfigurations are a leading cause of data leaks. Penetration testing helps ensure that access permissions, network settings, and service configurations align with security best practices.
## **How often should pen testing be conducted?**
Frequency depends on your risk profile, compliance requirements, and change cadence. A good baseline is:
- **Annually** for general security assurance
- **After significant changes** (new deployments, architecture overhauls)
- **Quarterly or continuously** for high-risk systems or regulated environments
Integrating penetration testing with your SDLC workflow can help to ensure you’re not just checking a box but actively improving your security posture.
## **Why DAST matters in the context of penetration testing**
When it comes to scalable, consistent, and actionable testing in modern web application environments, dynamic application security testing (DAST) tools can bridge the gap between human-led assessments and automated precision. DAST aligns with black-box pentesting principles, simulating external attacks by probing running applications without access to the underlying code. This makes it an ideal candidate for discovering vulnerabilities as they would be seen and exploited by real-world attackers.
Most pentesters use manual DAST tools to help them with the recon phase and attack automation, but advanced DAST solutions also provide a standalone complement or even an alternative to manual testing. Unlike typical periodic penetration tests, a good DAST can be integrated into your development lifecycle to provide continuous and fully automated assessments, turning ad-hoc insights into ongoing protection.
Having a DAST-first security program means reduced noise and an increased focus on real, exploitable risks. With advanced technologies like Invicti’s proof-based scanning, DAST tools can find and confirm many common vulnerabilities automatically. This lets your security and development teams fix as many exploitable issues as possible before the pentesters arrive, making DAST a force and value multiplier for manual testing.
## Penetration testing type FAQs
#### What are the possible types of penetration testing?
Penetration testing assignments include wireless, network, social engineering, physical, firewall, web application, mobile application, and cloud infrastructure testing. Each type targets specific areas of your IT environment to uncover real-world security vulnerabilities.
#### What is the difference between black-box, white-box, and gray-box testing?
Black-box testing simulates an external attacker with no internal knowledge. White-box testing provides full access to systems and code. Gray-box testing offers partial information, representing an insider threat or compromised user. All these pentesting approaches also have corresponding automated tools, with DAST performing black-box testing, SAST white-box testing, and IAST gray-box testing.
#### How often should you conduct penetration testing?
Penetration testing frequency depends on your specific compliance and security policy requirements, but testing should be conducted at least annually or after any significant changes to your infrastructure. High-risk environments may require quarterly or continuous testing integrated into development workflows.
#### Why is penetration testing important for web applications?
Web applications are a frequent target for attackers. Penetration testing helps identify vulnerabilities like SQL injection, cross-site scripting (XSS), and broken access controls before they can be exploited. Running an accurate DAST tool before commissioning a pentest lets companies internally resolve many simpler vulnerabilities to get better value from manual testing.
#### How does DAST compare to traditional penetration testing?
DAST tools simulate real-world attacks against live applications without access to source code. Unlike one-time pen tests, DAST enables continuous security testing and automatically validates vulnerabilities to reduce false positives. Note that most pentesters also start their engagements by running some kind of DAST tool.
#### Is social engineering part of a penetration test?
If the engagement scope covers it, social engineering can be a key component of some penetration tests. It assesses how susceptible your users are to tactics like phishing or impersonation, helping strengthen security awareness and policies.
#### What should be included in a penetration test report?
A high-quality report should include an executive summary, risk rankings (e.g., CVSS), technical details of each finding, proof of exploit, and detailed remediation recommendations.
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What is Penetration Testing—Types, Tools & Best Practices
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https://www.testdevlab.com/blog/what-is-penetration-testing-types-tools-best-practices
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### Identifying vulnerabilities
Penetration testing helps organizations discover both known and unknown security vulnerabilities in their systems, networks, and applications. By proactively identifying these weaknesses, companies can address them before attackers have the opportunity to exploit them.
### Protecting sensitive data
Penetration testing ensures that personal, financial, and proprietary information remains secure. This demonstrates a company’s commitment to security and can build trust with customers, partners, and stakeholders.
### Complying with regulations
Many regulatory standards and compliance frameworks require regular penetration testing as part of their security requirements. This includes standards like PCI DSS, HIPAA, and GDPR. It is also a requirement for the ISO 27001 compliance and certification.
### Testing security controls
Penetration testing evaluates the effectiveness of an organization's security controls, such as firewalls, intrusion detection systems, and access controls. It helps validate whether these controls are configured correctly and are capable of defending against real-world threats.
### Improving security posture
By simulating real-world attacks, penetration testing provides valuable insights into an organization’s security posture. It highlights areas of strength and identifies gaps that need improvement, helping organizations enhance their overall security framework and resilience against cyber threats.
### Cost savings
According to a 2023 study by IBM, the average cost of a data breach was $4.45 million. Regular penetration testing can help mitigate such risks and prevent significant financial losses associated with data breaches, regulatory fines, or loss of reputation.
## What gets tested in penetration testing?
Penetration testing is a comprehensive process designed to identify and exploit vulnerabilities across various components of an organization’s IT infrastructure.
Here’s a look at the key areas that are typically assessed during penetration testing:
### 1\. Network infrastructure
#### External network
- **Firewalls and routers**. Testing for misconfigurations, open ports, and weaknesses in filtering rules.
- **Public-facing servers.** Assessing web, email, and other externally accessible servers for vulnerabilities.
- **Network services.** Scanning for vulnerabilities in DNS, FTP, SSH, and other network services.
#### Internal network
- **Internal servers**. Testing file servers, database servers, and application servers for vulnerabilities.
- **Workstations and endpoints.** Evaluating the security of desktop and laptop computers used by employees.
- **Network segmentation.** Checking for weaknesses in the segmentation and isolation of different network zones.
### 2\. Web applications
#### Web application vulnerabilities
- **Injection flaws.** Testing for SQL injection, command injection, and other injection attacks.
- **Cross-site scripting (XSS).** Assessing the potential for XSS attacks, which can lead to data theft and session hijacking.
- **Cross-site request forgery (CSRF).** Ensuring that web applications are protected against CSRF attacks.
- **Authentication and authorization.** Evaluating the strength of login mechanisms and access control measures.
- **Session management.** Checking for weaknesses in session handling, including session fixation and hijacking.
#### API security
- **Endpoint testing.** Assessing the security of API endpoints for unauthorized access and data leakage.
- **Rate limiting.** Ensuring that APIs are protected against abuse through rate limiting and throttling mechanisms.
- **Data validation.** Testing input validation and sanitization to prevent injection attacks and data corruption.
### 3\. Mobile applications
#### Mobile app vulnerabilities
- **Platform-specific flaws**: Identifying vulnerabilities specific to iOS, Android, or other mobile platforms.
- **Data storage security.** Ensuring that sensitive data is securely stored and protected on the device.
- **Network communication.** Testing the security of data transmitted between the app and backend servers.
- **Authentication and authorization.** Evaluating the robustness of login and access control mechanisms within the app.
#### Backend services
- **API security.** Assessing the security of APIs used by the mobile app to communicate with backend services.
- **Server-side validation.** Ensuring that server-side validation and processing are secure against common attacks.
### 4\. Wireless networks
#### Wireless network security
- **Access points.** Testing the security of wireless access points and configurations.
- **Encryption Protocols.** Evaluating the strength of encryption protocols (WEP, WPA, WPA2, WPA3) used to secure wireless communication.
- **Rogue access points.** Detecting unauthorized access points that could be used for attacks like man-in-the-middle (MitM).
### 5\. Social engineering
#### Phishing
- **Email phishing.** Simulating phishing attacks to evaluate the effectiveness of employee awareness and email security measures.
- **Spear phishing.** Conducting targeted phishing attacks to test the security awareness of high-value targets within the organization.
#### Physical security
- **Tailgating.** Testing physical access controls by attempting to gain unauthorized entry to secure areas.
- **USB drops.** Distributing malicious USB drives to test the likelihood of employees connecting unknown devices to the network.
### 6\. Cloud Security
#### Cloud infrastructure
- **Configuration security.** Assessing the security of cloud configurations, including storage buckets, virtual machines, and security groups.
- **Access controls.** Evaluating the effectiveness of identity and access management (IAM) policies and practices.
#### Cloud services
- **Service vulnerabilities.** Testing cloud services for common vulnerabilities, such as insecure APIs, weak authentication, and misconfigurations.
- **Data protection.** Ensuring that data stored and processed in the cloud is adequately protected through encryption and access controls.
### 7\. Physical security
#### Building access
- **Physical entry points.** Testing the security of doors, windows, and other entry points.
- **Security guards and surveillance.** Evaluating the effectiveness of on-site security personnel and surveillance systems.
#### Hardware security
- **Device access.** Ensuring that sensitive hardware, such as servers and network devices, is physically secured against unauthorized access.
## Types of penetration testing
### External testing
External penetration testing focuses on assessing an organization's externally-facing assets, such as web applications, websites, and external servers. This type of testing simulates an attack launched from outside the organization's network, similar to how an external threat actor would target the organization.
**Key benefits:**
- Identifies vulnerabilities that can be exploited over the internet.
- Tests the effectiveness of perimeter defenses like firewalls and intrusion prevention systems.
### Internal testing
Internal penetration testing mimics an attack that originates from within the organization's internal network. This type of testing is useful for identifying vulnerabilities that could be exploited by employees, contractors, or other trusted insiders who have access to the internal network.
**Key benefits:**
- Assesses the security posture from an insider’s perspective.
- Tests the effectiveness of internal security controls and segmentation.
### Black box testing
In black box testing, the penetration tester has no prior knowledge of the target system. This approach simulates the perspective of an external attacker who has little or no information about the organization’s network and infrastructure.
**Key benefits:**
- Provides a realistic simulation of an external cyber attack.
- Tests the ability to gather intelligence and assess vulnerabilities from scratch.
### White box testing
White box testing, in contrast to black box testing, gives the penetration tester full knowledge of the target system. This includes detailed information about the network architecture, source code, and other technical details that are typically available to an internal IT team.
**Key benefits:**
- Allows for a more thorough assessment of vulnerabilities.
- Tests the effectiveness of internal security measures and configurations.
### Gray box testing
Gray box testing blends elements of both black box and white box testing. The penetration tester has partial knowledge of the target system, typically including some network diagrams, system configurations, or other relevant information.
**Key benefits:**
- Mimics the perspective of an attacker who has obtained some insider knowledge or through reconnaissance.
### Targeted testing
Targeted testing, also known as focused testing, involves collaboration between the penetration testing team and the organization’s internal IT team. The goal is to assess specific high-value assets or systems within the organization, with both parties working together to maximize the test’s effectiveness.
**Key benefits:**
- Focuses on critical areas and assets that are most likely to be targeted by attackers.
- Facilitates knowledge sharing and collaboration between the testing team and internal IT staff.
### Blind testing
Blind testing, similar to black box testing, involves no prior knowledge of the target systems. However, unlike black box testing, it’s conducted without the knowledge of the internal security team. This type of testing provides a more realistic simulation of an external attack.
**Key benefits:**
- Tests the organization’s ability to detect and respond to unauthorized activities without prior warning.
- Identifies blind spots in the organization’s detection and response capabilities.
### Double-blind testing
Double-blind testing, also known as complete testing, takes blind testing one step further. In this approach, neither the organization’s internal IT team nor the penetration testing team is aware of the test. This type of testing provides the most realistic assessment of an organization’s ability to detect and respond to an attack.
**Key benefits:**
- Offers the highest level of realism in testing the organization’s defenses.
- Assesses the effectiveness of incident response and detection capabilities under real-world conditions.
## Penetration testing stages
A comprehensive penetration test typically follows these stages:
### Stage 1: Planning
Planning and reconnaissance is the initial phase of a penetration test. During this stage, the objectives and scope of the test are defined, and relevant information about the target is gathered.
**Key activities:**
- **Defining scope**. Determine the systems, networks, applications, and specific areas to be tested.
- **Setting objectives**. Establish clear goals for the test, such as identifying specific types of vulnerabilities.
- **Information gathering**. Collect data about the target using various methods, such as DNS enumeration, network mapping, and social engineering. This phase is also known as footprinting and involves both active and passive reconnaissance.
### Stage 2: Scanning
In the scanning phase, the tester uses various tools to identify potential entry points and vulnerabilities within the target systems.
**Key activities:**
- **Network scanning**. Identify open ports, services, and live hosts using tools like Nmap.
- **Vulnerability scanning**. Detect known vulnerabilities in systems and applications using automated scanners like Nessus.
- **Enumeration**. Extract detailed information about network resources, user accounts, and shares.
### Stage 3: Gaining access
The gaining access phase involves exploiting identified vulnerabilities to gain unauthorized access to the target systems. This stage tests the effectiveness of security defenses and identifies potential attack vectors.
**Key activities:**
- **Exploitation.** Use exploit tools and techniques to gain control of the target system. Tools like Metasploit can be used to automate this process.
- **Privilege escalation.** Attempt to gain higher levels of access within the system to maximize the potential impact of the attack.
### Stage 4: Maintaining access
In the maintaining access phase, the tester aims to ensure persistent access to the compromised system. This stage simulates the actions of an attacker who wants to maintain a foothold within the network for extended periods.
**Key activities:**
- **Installing backdoors.** Deploy malware or backdoors that allow re-entry into the system.
- **Covering tracks.** Use techniques to evade detection and remain undetected within the network.
### Stage 5: Analysis and reporting
The analysis and reporting phase involves documenting the findings of the penetration test and providing actionable recommendations for remediation.
**Key activities:**
- **Data analysis.** Review the results of the penetration test to identify patterns and insights.
- **Reporting.** Create a detailed report that includes an executive summary, technical findings, risk assessments, and recommended mitigation strategies. The report should be clear and understandable for both technical and non-technical stakeholders.
**Key elements of the report:**
- **Executive summary.** High-level overview of the test objectives, scope, and key findings.
- **Technical details.** In-depth analysis of vulnerabilities, exploits used, and the impact of successful attacks.
- **Risk assessment.** Evaluation of the severity and potential impact of identified vulnerabilities.
- **Recommendations.** Actionable steps for remediation, including patching, configuration changes, and improvements to security policies and procedures.
By following these stages of penetration testing, organizations can ensure a comprehensive assessment of their security posture, identify weaknesses before they can be exploited, and take proactive measures to enhance their defenses.
## Penetration testing methodologies
Penetration testing methodologies provide a structured approach to conducting penetration tests, ensuring that the process is thorough, consistent, and effective. Here’s a detailed look at some of the most widely recognized penetration testing methodologies:
### 1\. Open Source Security Testing Methodology Manual (OSSTMM)
The OSSTMM,networks%20security%20testing%20and%20compliance.) is a comprehensive methodology for evaluating the operational security of various domains, including physical locations, workflows, human security, physical security, wireless security, telecommunication security, data networks, and compliance.
**Advantages of OSSTMM:**
- Provides a detailed and rigorous framework for testing.
- Covers a wide range of security domains.
- Emphasizes the measurement and quantification of security.
### 2\. Open Web Application Security Project (OWASP)
The OWASP is one the most widely recognized standards in the industry, providing a set of methodologies used for web application penetration testing ( OWASP Top 10), mobile application penetration testing ( OWASP Mobile Top 10), API penetration testing ( OWASP API Security Top 10), IoT penetration testing ( OWASP IoT Top 10), and LLM penetration testing.
**Advantages of OWASP:**
- Widely recognized and respected in the industry.
- Provides practical guidance and tools for web application testing.
- Regularly updated to reflect emerging threats and vulnerabilities.
### 3\. Penetration Testing Execution Standard (PTES)
The PTES provides a standardized framework for conducting penetration tests. It describes seven phases: pre-engagement interactions, intelligence gathering,
threat modeling, vulnerability analysis, exploitation, post-exploitation, and reporting. The framework provides detailed guidance on each phase.
**Advantages of PTES:**
- Provides a comprehensive and structured approach to penetration testing.
- Covers all phases of the penetration testing life cycle.
- Emphasizes the importance of communication and collaboration with the client.
### 4\. Information Systems Security Assessment Framework (ISSAF)
The ISSAF is a detailed framework for conducting security assessments, including penetration testing. It provides guidance on various aspects of security testing, from planning to execution and reporting.
**Advantages of ISSAF:**
- Provides a detailed and comprehensive framework for security assessments.
- Covers a wide range of security domains and testing techniques.
- Emphasizes the importance of thorough documentation and reporting.
## Penetration testing tools
Penetration testing relies heavily on a variety of tools designed to identify vulnerabilities, exploit weaknesses, and assess the overall security posture of an organization. Let's go through some of the most widely used penetration testing tools, categorized by their primary functions:
### 1\. Reconnaissance and information gathering
#### Nmap
A powerful network scanning tool that discovers hosts and services on a network. It has port scanning, OS detection, version detection, and scripting capabilities. Nmap is widely used to map network topology and identify open ports and services.
#### Recon-ng
A web reconnaissance framework with a modular design, similar to Metasploit. It has modules for gathering information from public sources, including social media, search engines, and DNS. Recon-ng is ideal for collecting and analyzing information during the reconnaissance phase.
### 2\. Vulnerability scanning
#### Nessus
A comprehensive vulnerability scanner that identifies security vulnerabilities in systems and applications. It offers automated scanning, detailed reports, and extensive plugin support for various vulnerability checks. Nessus is commonly used to detect vulnerabilities, misconfigurations, and missing patches.
#### OpenVAS
An open-source vulnerability scanning and management solution with an extensive plugin library, detailed reports, and regular updates. OpenVAS is ideal for conducting thorough vulnerability assessments in various environments.
### 3\. Exploitation
#### Metasploit Framework
A powerful penetration testing framework that provides tools for discovering, exploiting, and validating vulnerabilities. It has an extensive exploit library, payload generation, and post-exploitation modules. This tool is widely used by penetration testers to automate the process of exploiting known vulnerabilities.
#### BeEF (Browser Exploitation Framework)
A penetration testing tool that focuses on web browser vulnerabilities. Some of its features include exploitation of client-side vulnerabilities, browser hijacking, and social engineering tools. BeEF is effective for testing the security of web applications and assessing browser-based attacks.
### 4\. Password cracking
#### John the Ripper
A fast and versatile password cracking tool that supports a wide range of hashing algorithms and password attack techniques. John the Ripper is commonly used to crack passwords from hashed password files and assess password strength.
#### Hashcat
A highly efficient password recovery tool that utilizes GPU acceleration and supports numerous hash algorithms, including MD5, SHA-1, and bcrypt. It is ideal for performing large-scale password cracking tasks quickly and efficiently.
### 5\. Wireless network testing
#### Aircrack-ng
A suite of tools for auditing wireless networks. Some of its features include packet capture and analysis, WEP and WPA/WPA2-PSK cracking, and network monitoring. It is used to test the security of wireless networks and assess the strength of encryption protocols.
#### Kismet
A wireless network detector, sniffer, and intrusion detection system. It offers passive network discovery, packet capture, and support for various wireless protocols. Kismet is ideal for monitoring wireless network activity and detecting unauthorized access points.
### 6\. Web Application Testing
#### Burp Suite
A comprehensive web vulnerability scanner and testing platform. It has a proxy server for intercepting and modifying web traffic, automated scanning, and various testing tools. Burp Suite is widely used for testing web application security, including SQL injection, XSS, and other vulnerabilities.
#### ZAP (Zed Attack Proxy)
An open-source web application security scanner that offers automated scanning, manual testing tools, and a proxy for intercepting web traffic. It is ideal for finding and exploiting security vulnerabilities in web applications.
### 7\. Post-Exploitation
#### Empire
A post-exploitation framework for Windows, macOS, and Linux. It has PowerShell and Python agents, modular design, and various post-exploitation tools. Empire is effective for maintaining access and executing commands on compromised systems.
#### Cobalt Strike
A threat emulation platform used for post-exploitation activities that offers collaboration tools, payload generation, and post-exploitation modules. It is used to simulate advanced persistent threats (APTs) and assess the effectiveness of incident response capabilities.
## Penetration testing best practices
### Define clear objectives and scope
Clearly define what you aim to achieve with the penetration test, like evaluating the effectiveness of existing security measures or identifying a certain number of vulnerabilities. Also, establish the scope of testing by specifying which systems, applications, and network segments should be tested, as well as identifying exclusions and testing boundaries.
### Obtain necessary permission
Ensure that you have the necessary authorization and documentation to conduct the penetration test. Make sure to sign NDAs to protect sensitive information discovered during the test.
### Assemble a skilled team
Engage penetration testers who hold relevant certifications and have experience in conducting penetration tests in similar environments and industries.
### Follow an efficient approach
Utilize established penetration testing frameworks, keep detailed logs of all activities performed during the penetration test, and document all findings with supporting evidence.
### Communicate effectively
Provide regular updates to stakeholders on the progress of the penetration test, using clear and concise language. Deliver a comprehensive report detailing all vulnerabilities discovered, the methods used to exploit them, and the potential impact. Include actionable recommendations for remediation, prioritizing the most critical vulnerabilities.
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Penetration Testing Methodologies: A Deep Dive - LinkedIn
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https://www.linkedin.com/pulse/penetration-testing-methodologies-deep-dive-matt-rosenthal-4teme
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A penetration test without structure is just guesswork. It might uncover a few surface-level issues, but it’s unlikely to give a complete picture of your security posture. That’s why penetration testing methodologies matter. They guide the process from start to finish, making sure no important steps are skipped and no systems are left out.
For businesses, this structure isn’t just technical—it’s strategic. A methodical approach to penetration testing helps align security testing with business goals, risk management plans, and compliance requirements. This blog breaks down what methodologies are, why they’re essential, and how to evaluate whether your provider is following a solid one.
### What Is a Penetration Testing Methodology?
At its core, a penetration testing methodology is a repeatable, structured approach to conducting security tests. It defines what gets tested, how it gets tested, and how results are measured. Without a framework, a test might be inconsistent or miss key vulnerabilities.
Methodologies make testing consistent across teams and timeframes. They also help companies track improvements from one test to the next. The goal is to find real risks, not just pass/fail results.
### Commonly Used Frameworks in the Industry
Different teams use different testing frameworks, but the most respected ones all aim to be thorough and repeatable. Here are a few that top-tier providers rely on:
- PTES (Penetration Testing Execution Standard): Penetration test standards are adopted widely for various activities carried out before or after any test.
- OWASP Testing Guide: Exclusively for web applications, ideal for software penetration testing.
- NIST SP 800-115: A government standard that establishes a formal structure for testing in the U.S.
- MITRE ATT&CK Matrix: Used for simulating known adversary behaviors.
Reputable providers usually combine more than one framework, with the adaptation done along the lines of what kind of system you have and your organization’s security objectives. Certified penetration testingexperts tend to do the same since they also believe that best practices usually align with the business needs.
### Phases of a Standard Penetration Test
A good methodology is broken down into clear steps. While the names may vary slightly across frameworks, most tests follow a similar structure:
### 1\. Pre-engagement and Scoping
Define objectives, scope, systems to test, and testing rules (like what’s off-limits). This phase sets the tone for everything that follows.
### 2\. Reconnaissance
Gather technical and public data. This includes domain records, open ports, software versions, employee info, and more.
### 3\. Threat Modeling and Planning
Based on the data collected, testers map potential entry points and create an attack strategy.
### 4\. Exploitation
This is where the test simulates real attacks. Testers try to gain unauthorized access using tools and manual techniques.
### 5\. Post-Exploitation and Escalation
If access is gained, the next step is to explore how far they can go. Can they move across systems? Can they access sensitive data?
### 6\. Reporting
Detailed documentation of what was found, how it was exploited, and how to fix it. Strong providers offer clear summaries and remediation priorities.
Good penetration testing providers walk clients through this process. It’s one reason choosing the right testing partner matters so much.
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Malware Analysis: Steps & Examples - CrowdStrike
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https://www.crowdstrike.com/en-us/cybersecurity-101/malware/malware-analysis/
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# Malware Analysis Explained
## What is malware analysis?
**Malware analysis** is the process of understanding the behavior and purpose of a suspicious file or URL. The output of the analysis aids in the detection and mitigation of the potential threat.
The key benefit of malware analysis is that it helps incident responders and security analysts:
- Pragmatically triage incidents by level of severity
- Uncover hidden indicators of compromise (IOCs) that should be blocked
- Improve the efficacy of IOC alerts and notifications
- Enrich context when threat hunting
## Types of malware analysis
The analysis may be conducted in a manner that is static, dynamic or a hybrid of the two.
### Static analysis
Basic static analysis does not require that the code is actually run. Instead, **static analysis examines the file for signs of malicious intent**. It can be useful to identify malicious infrastructure, libraries or packed files.
Technical indicators are identified such as file names, hashes, strings such as IP addresses, domains, and file header data can be used to determine whether that file is malicious. In addition, tools like disassemblers and network analyzers can be used to observe the malware without actually running it in order to collect information on how the malware works.
## CrowdStrike 2025 Global Threat Report
## CrowdStrike 2025 Global Threat Report
Get your copy of the must-read cybersecurity report of the year.
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However, **since static analysis does not actually run the code, sophisticated malware can include malicious runtime behavior that can go undetected**. For example, if a file generates a string that then downloads a malicious file based upon the dynamic string, it could go undetected by a basic static analysis. Enterprises have turned to dynamic analysis for a more complete understanding of the behavior of the file.
### Dynamic analysis
**Dynamic malware analysis executes suspected malicious code in a safe environment called a _sandbox_.** This closed system enables security professionals to watch the malware in action without the risk of letting it infect their system or escape into the enterprise network.
Dynamic analysis provides threat hunters and incident responders with deeper visibility, allowing them to uncover the true nature of a threat. As a secondary benefit, automated sandboxing eliminates the time it would take to reverse engineer a file to discover the malicious code.
The challenge with dynamic analysis is that adversaries are smart, and they know sandboxes are out there, so they have become very good at detecting them. To deceive a sandbox, adversaries hide code inside them that may remain dormant until certain conditions are met. Only then does the code run.
### Hybrid analysis (includes both of the techniques above)
Basic static analysis isn’t a reliable way to detect sophisticated malicious code, and sophisticated malware can sometimes hide from the presence of sandbox technology. **By combining basic and dynamic analysis techniques, hybrid analysis provide security team the best of both approaches –** primarily because it can detect malicious code that is trying to hide, and then can extract many more indicators of compromise (IOCs) by statically and previously unseen code. Hybrid analysis helps detect unknown threats, even those from the most sophisticated malware.
For example, one of the things hybrid analysis does is apply static analysis to data generated by behavioral analysis – like when a piece of malicious code runs and generates some changes in memory. Dynamic analysis would detect that, and analysts would be alerted to circle back and perform basic static analysis on that memory dump. As a result, more IOCs would be generated and zero-day exploits would be exposed.
#### Learn More
Falcon Sandbox enables cybersecurity teams of all skill levels to increase their understanding of the threats they face and use that knowledge to defend against future attacks.
Learn more about Falcon Sandbox here.
## Malware analysis use cases
### Malware detection
Adversaries are employing more sophisticated techniques to avoid traditional detection mechanisms. By providing deep behavioral analysis and by identifying shared code, malicious functionality or infrastructure, threats can be more effectively detected. In addition, an output of malware analysis is the extraction of IOCs. The IOCs may then be fed into SEIMs, threat intelligence platforms (TIPs) and security orchestration tools to aid in alerting teams to related threats in the future.
### Threat alerts and triage
Malware analysis solutions provide higher-fidelity alerts earlier in the attack life cycle. Therefore, teams can save time by prioritizing the results of these alerts over other technologies.
### Incident response
The goal of the incident response (IR) team is to provide root cause analysis, determine impact and succeed in remediation and recovery. The malware analysis process aids in the efficiency and effectiveness of this effort.
### Threat hunting
Malware analysis can expose behavior and artifacts that threat hunters can use to find similar activity, such as access to a particular network connection, port or domain. By searching firewall and proxy logs or SIEM data, teams can use this data to find similar threats.
### Malware research
Academic or industry malware researchers perform malware analysis to gain an understanding of the latest techniques, exploits and tools used by adversaries.
## Stages of malware analysis
### Static properties analysis
Static properties include strings embedded in the malware code, header details, hashes, metadata, embedded resources, etc. This type of data may be all that is needed to create IOCs, and they can be acquired very quickly because there is no need to run the program in order to see them. Insights gathered during the static properties analysis can indicate whether a deeper investigation using more comprehensive techniques is necessary and determine which steps should be taken next.
### Interactive behavior analysis
Behavioral analysis is used to observe and interact with a malware sample running in a lab. Analysts seek to understand the sample’s registry, file system, process and network activities. They may also conduct memory forensics to learn how the malware uses memory. If the analysts suspect that the malware has a certain capability, they can set up a simulation to test their theory.
Behavioral analysis requires a creative analyst with advanced skills. The process is time-consuming and complicated and cannot be performed effectively without automated tools.
### Fully automated analysis
Fully automated analysis quickly and simply assesses suspicious files. The analysis can determine potential repercussions if the malware were to infiltrate the network and then produce an easy-to-read report that provides fast answers for security teams. Fully automated analysis is the best way to process malware at scale.
### Manual code reversing
In this stage, analysts reverse-engineer code using debuggers, disassemblers, compilers and specialized tools to decode encrypted data, determine the logic behind the malware algorithm and understand any hidden capabilities that the malware has not yet exhibited. Code reversing is a rare skill, and executing code reversals takes a great deal of time. For these reasons, malware investigations often skip this step and therefore miss out on a lot of valuable insights into the nature of the malware.
#### Learn More
Learn about the largest online malware analysis community that is field-tested by tens of thousands of users every day.
Download: Falcon Sandbox Malware Analysis Data Sheet.
## The world’s most powerful malware sandbox
Security teams can use the CrowdStrike Falcon® Sandbox to understand sophisticated malware attacks and strengthen their defenses. Falcon Sandbox™ performs deep analyses of evasive and unknown threats, and enriches the results with threat intelligence.
**Key benefits of Falcon Sandbox**
- Provides in-depth insight into all file, network and memory activity
- Offers leading anti-sandbox detection technology
- Generates intuitive reports with forensic data available on demand
- Supports the MITRE ATT&CK® framework
- Orchestrates workflows with an extensive application programming interface (API) and pre-built integrations
### Detect unknown threats
Falcon Sandbox extracts more IOCs than any other competing sandbox solution by using a unique hybrid analysis technology to detect unknown and zero-day exploits. All data extracted from the hybrid analysis engine is processed automatically and integrated into Falcon Sandbox reports.
Falcon Sandbox has anti-evasion technology that includes state-of-the-art anti-sandbox detection. File monitoring runs in the kernel and cannot be observed by user-mode applications. There is no agent that can be easily identified by malware, and each release is continuously tested to ensure Falcon Sandbox is nearly undetectable, even by malware using the most sophisticated sandbox detection techniques. The environment can be customized by date/time, environmental variables, user behaviors and more.
### Identify related threats
Know how to defend against an attack by understanding the adversary. Falcon Sandbox provides insights into who is behind a malware attack through the use of malware search a unique capability that determines whether a malware file is related to a larger campaign, malware family or threat actor. Falcon Sandbox will automatically search the largest malware search engine in the cybersecurity industry to find related samples and, within seconds, expand the analysis to include all files. This is important because it provides analysts with a deeper understanding of the attack and a larger set of IOCs that can be used to better protect the organization.
### Achieve complete visibility
Uncover the full attack life cycle with in-depth insight into all file, network, memory and process activity. Analysts at every level gain access to easy-to-read reports that make them more effective in their roles. The reports provide practical guidance for threat prioritization and response, so IR teams can hunt threats and forensic teams can drill down into memory captures and stack traces for a deeper analysis. Falcon Sandbox analyzes over 40 different file types that include a wide variety of executables, document and image formats, and script and archive files, and it supports Windows, Linux and Android.
### Respond faster
Security teams are more effective and faster to respond thanks to Falcon Sandbox’s easy-to-understand reports, actionable IOCs and seamless integration. Threat scoring and incident response summaries make immediate triage a reality, and reports enriched with information and IOCs from CrowdStrike Falcon® MalQuery™ and CrowdStrike Adversary Intelligence provide the context needed to make faster, better decisions.
Falcon Sandbox integrates through an easy REST API, pre-built integrations, and support for indicator-sharing formats such as Structured Threat Information Expression™ (STIX), OpenIOC, Malware Attribute Enumeration and Characterization™ (MAEC), Malware Sharing Application Platform (MISP) and XML/JSON (Extensible Markup Language/JavaScript Object Notation). Results can be delivered with SIEMs, TIPs and orchestration systems.
Cloud or on-premises deployment is available. The cloud option provides immediate time-to-value and reduced infrastructure costs, while the on-premises option enables users to lock down and process samples solely within their environment. Both options provide a secure and scalable sandbox environment.
### Automation
Falcon Sandbox uses a unique hybrid analysis technology that includes automatic detection and analysis of unknown threats. All data extracted from the hybrid analysis engine is processed automatically and integrated into the Falcon Sandbox reports. Automation enables Falcon Sandbox to process up to 25,000 files per month and create larger-scale distribution using load-balancing. Users retain control through the ability to customize settings and determine how malware is detonated.
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What is Malware Analysis? - Xcitium
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https://www.xcitium.com/knowledge-base/malware-analysis/
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# Malware Analysis
Malware analysis is the process of dissecting malicious software to understand its behavior, impact, and potential threats. Security professionals use advanced techniques to identify, detect, and mitigate cyber risks before they can cause damage. Whether combating ransomware, spyware, or trojans, malware analysis plays a crucial role in strengthening cybersecurity defenses. Explore the key methods, tools, and strategies used to analyze and neutralize modern cyber threats.
## What is Malware Analysis
Malware analysis is the process of examining malicious software to understand its origin, functionality, and impact. It is a crucial aspect of cybersecurity that helps experts detect, mitigate, and prevent cyber threats. Malware can take many forms, including viruses, trojans, ransomware, worms, and spyware, all of which can cause significant damage to individuals, businesses, and government organizations. The goal of malware analysis is to determine how a particular piece of malware operates, what vulnerabilities it exploits, and how it can be neutralized or removed from an infected system.
There are several key techniques used in malware analysis, each serving a specific purpose. Static analysis is one of the most common methods and involves examining the malware’s code without executing it. This allows analysts to extract valuable information such as file hashes, IP addresses, domain names, and embedded strings that might indicate malicious behavior. Static analysis is typically faster and safer since it does not require running the malware, but it may not always provide deep insights into how the malware behaves when executed.
Dynamic analysis, on the other hand, involves running the malware in a controlled environment, such as a sandbox, to observe its behavior in real-time. This technique allows analysts to track system modifications, network communications, and any attempts to exploit vulnerabilities. Dynamic analysis is particularly useful for identifying evasive malware that can detect when it is being analyzed and attempt to alter its behavior.
Another advanced technique used in malware analysis is reverse engineering, where security experts decompile the malware’s code to gain a deeper understanding of its inner workings. This method requires extensive knowledge of programming languages, assembly code, and debugging tools, making it more complex and time-consuming. However, reverse engineering can reveal hidden functionalities, encryption methods, and command-and-control (C2) servers used by cybercriminals to manage malware infections.
Malware analysis is essential for cybersecurity teams, incident response professionals, and threat intelligence researchers. It helps in creating effective detection rules, developing security patches, and strengthening overall defenses against cyber threats. Many organizations rely on automated malware analysis tools that use artificial intelligence and machine learning to detect patterns and identify new malware variants.
By understanding how malware operates, cybersecurity experts can better anticipate and counteract evolving threats. As cyberattacks become more sophisticated, malware analysis remains a critical component of modern cybersecurity strategies, ensuring that businesses and individuals stay protected from the growing risks posed by malicious software.
### Key Techniques Used in Malware Analysis
Malware analysis involves several key techniques that cybersecurity professionals use to examine and understand malicious software. These techniques help identify malware behavior, detect potential vulnerabilities, and develop effective countermeasures to mitigate cyber threats. The choice of technique depends on the complexity of the malware and the depth of analysis required. The main techniques used in malware analysis include static analysis, dynamic analysis, and reverse engineering.
Static analysis is the process of examining a malware sample without executing it. This technique involves analyzing the code, file structure, and metadata to extract useful information about the malware's functionality. Security researchers use tools to decompile or disassemble the malware’s code, allowing them to inspect embedded strings, API calls, encryption methods, and network connections. Static analysis is a quick and safe way to detect known malware signatures, but it has limitations when dealing with obfuscated or polymorphic malware that can change its code to evade detection.
Dynamic analysis, also known as behavioral analysis, involves executing the malware in a controlled environment, such as a sandbox, to observe its real-time behavior. By monitoring how the malware interacts with the operating system, network, and files, analysts can detect malicious activities, including unauthorized data access, registry modifications, and network communications with external servers. This technique is highly effective in identifying new malware strains and zero-day threats that might bypass traditional static analysis. However, some sophisticated malware can detect when it is being analyzed in a sandbox and alter its behavior to evade detection.
Reverse engineering is a more advanced technique that involves decompiling the malware’s code to understand its logic and structure. Security experts use debugging tools to step through the code and analyze how the malware executes its functions. Reverse engineering is often used to uncover hidden payloads, encryption algorithms, and command-and-control mechanisms that cybercriminals use to control infected systems. This technique requires deep knowledge of programming languages, assembly code, and debugging tools, making it one of the most challenging yet rewarding methods in malware analysis.
Other techniques used in malware analysis include memory forensics, which involves examining a system’s memory to identify malicious processes, and network analysis, which tracks network traffic to detect signs of malware communication with external servers. These methods help security teams gain deeper insights into how malware spreads, how it communicates, and how it can be neutralized effectively.
By combining these key techniques, cybersecurity professionals can develop stronger defenses against malware threats, enhance threat intelligence, and create better security solutions to protect individuals and organizations from cyberattacks.
### Static vs Dynamic Malware Analysis: What’s the Difference?
Static and dynamic malware analysis are two fundamental techniques used by cybersecurity professionals to examine and understand how malicious software operates. Each method has its own strengths, weaknesses, and use cases, making them complementary in the process of malware detection and mitigation. While static analysis focuses on examining the malware’s code without executing it, dynamic analysis involves running the malware in a controlled environment to observe its behavior in real-time. Understanding the differences between these approaches helps security analysts determine the most effective strategy for analyzing and neutralizing cyber threats.
Static malware analysis is a method where analysts examine a malware sample without executing it. This technique involves inspecting the file structure, code, and metadata to gather information about the malware’s purpose and functionality. Analysts use tools like disassemblers and decompilers to break down the executable file and extract useful insights, such as embedded strings, function calls, API references, and cryptographic routines. One of the biggest advantages of static analysis is its speed and safety, as it does not require executing potentially harmful code. Additionally, static analysis is effective in detecting known malware signatures and identifying code patterns associated with malicious behavior. However, this method has limitations, especially when dealing with obfuscated, encrypted, or polymorphic malware, which can change its code structure to evade detection.
Dynamic malware analysis, also known as behavioral analysis, takes a different approach by executing the malware in a controlled environment, such as a sandbox or virtual machine. This technique allows analysts to observe the malware’s real-time behavior, including system modifications, file changes, network communications, and attempts to exploit vulnerabilities. By monitoring the malware’s activities, analysts can identify how it spreads, what commands it executes, and how it interacts with external servers. Dynamic analysis is particularly useful for detecting new and unknown malware that may not be identifiable through static analysis alone. However, some advanced malware strains are designed to detect sandbox environments and modify their behavior to avoid detection, making dynamic analysis more challenging. Additionally, running malware samples in a live environment carries some risk if not properly isolated.
While static and dynamic analysis each have their own strengths, they are most effective when used together. Static analysis provides quick insights and helps identify known threats, while dynamic analysis reveals real-time behaviors and detects evasive malware. Combining these techniques allows cybersecurity professionals to build a comprehensive understanding of malware threats, improve detection mechanisms, and develop effective countermeasures against cyberattacks.
#### Why Choose Xcitium?
Xcitium’s advanced malware analysis solutions leverage real-time threat intelligence and Zero Trust architecture to ensure that every file, application, or executable is verified before execution, preventing unknown threats from causing harm. With industry-leading containment technology and automated malware analysis, Xcitium provides organizations with proactive protection against evolving cyber threats, ensuring business continuity and data security.
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Malware analysis for beginners (step-by-step) - HackTheBox
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https://www.hackthebox.com/blog/malware-analysis-guide
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## What is malware?
Malware, short for malicious software, is a term for various types of software designed to infiltrate, exploit, or damage computer systems, networks, and data.
Although all malware is used for malicious purposes, the specific objectives of malware can vary among different threat actors. These objectives commonly fall into several categories:
- Disrupting host system operations.
- Stealing critical information, including personal and financial data.
- Gaining unauthorized access to systems.
- Conducting espionage activities.
- Sending spam messages.
- Using the victim's system for Distributed Denial of Service (DDoS) attacks.
- Locking up the victim's files on their host and demanding ransom (also called Ransomware).
##### Intro To Malware Analysis
This HTB module guides you into the world of malware analysis with a particular focus on Windows-based threats. Leveraging industry-standard tools and methodologies, it provides hands-on experience in identifying, understanding, and detecting malware.
Take the malware analysis course
## The different types of malware
In the fast-paced world of cyber threats, we find ourselves up against a broad spectrum of complex and varied malware forms.
In recent years, governments, judicial systems, hospitals, schools, and companies have been attacked by malware and ransomware, such as Stuxnet and WannaCry
Let's peel back the layers of some commonly seen types of malware:
#### Viruses
These notorious forms of malware are designed to infiltrate and multiply within host files, transitioning from one system to another. They latch onto credible programs, springing into action when the infected files are triggered.
Their destructive powers can range from corrupting or altering data to disrupting system functions, and even spreading through networks, inflicting widespread havoc.
#### Worms
Worms are autonomous malware capable of multiplying across networks without needing human intervention. They exploit network weaknesses to infiltrate other systems without permission.
Once inside, they can either deliver damaging payloads or keep multiplying to other vulnerable devices. Worms can initiate swift and escalating infections, resulting in enormous disruption and even potential denial of service (DoS) attacks.
#### Trojans
Also known as Trojan Horses, these are disguised as genuine software to trick users into running them. After entering a system, these programs craft backdoors, allowing attackers to gain unauthorized control remotely.
Trojans can be weaponized to pilfer sensitive data, such as passwords or financial information, and to orchestrate other harmful activities on the compromised system.
#### Ransomware
This type of malware encrypts files on the target's system, making them unreachable. Attackers then demand a ransom in return for the decryption key, effectively holding the victim's data to ransom.
The impacts of ransomware attacks can debilitate organizations and individuals alike, leading to severe financial and reputational harm.
#### Spyware
This type of malware stealthily gathers sensitive data and user activities without the user’s consent. It can track online browsing habits, record keystrokes, and capture login credentials, posing a severe risk to privacy and security. The pilfered data is often sent to remote servers for further attacks.
#### Adware
Though not as destructive, adware can still be an annoyance and a security threat. It shows uninvited and invasive advertisements on infected systems, often resulting in a poor user experience. Adware can also be used to track user behavior and collect data for targeted advertising.
#### Botnets
These are networks of compromised devices, often referred to as bots or zombies, controlled by a central command-and-control (C2) server.
Botnets can be exploited for a variety of harmful activities, including launching DDoS attacks, spreading spam, or disseminating other malware.
#### Rootkits
These are stealthy forms of malware designed to gain unauthorized access and control over the fundamental components (the "Root") of an operating system (OS).
They alter system functions to conceal their presence, making them extremely challenging to spot and eliminate. Attackers can utilize rootkits to maintain prolonged access and dodge security protocols.
#### Backdoors and RATs (Remote Access Trojans)
Backdoors and RATs are crafted to offer unauthorized access and control over compromised systems from remote locations. Attackers can leverage them to retain prolonged control, extract data, or conduct additional attacks.
#### Droppers
These are a kind of malware used to transport and install extra malicious payloads onto infected systems. They serve as a conduit for other malware, ensuring the covert installation and execution of more sophisticated threats.
#### Information stealers
These are tailored to target and extract sensitive data, like login credentials, personal information, or intellectual property, for harmful purposes. This includes identity theft or selling the data on the dark web.
## Types of malware analysis
**Note**: This blog post will cover the basics of static and dynamic malware analysis, but you can learn more about the other types in the _Introduction to Malware Analysis_
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module.
### Static malware analysis
Static malware analysis is an approach to scrutinizing malware code without executing it.
An analyst will examine the file structure, identify strings, search for known signatures, and study metadata to gain preliminary insights into the malware's characteristics.
### Dynamic malware analysis
Dynamic analysis entails executing the malware within a controlled environment, such as a sandbox or virtual machine, to observe its behavior and capture its runtime activities.
This includes monitoring network traffic, system calls, file system modifications, and other interactions.
### Malware code analysis
Code analysis (which includes reverse engineering) involves disassembling or decompiling the malware's code to understand its logic, functions, algorithms, and employed techniques.
This helps in identifying concealed functionalities, exploitation methods, encryption methods, details about the C2 infrastructure, and techniques used for obfuscation and evasion.
**Note**: Code analysis can also help analysts infer ways to discover potential indicators of compromise (IOC).
### Memory analysis
Analyzing the malware's interactions with system memory helps identify injected code, hooks, or other runtime manipulations.
This can be instrumental in detecting rootkits, analyzing anti-analysis techniques, or identifying malicious payloads.
### Malware unpacking
This technique refers to the process of extracting and isolating the hidden malicious code within a piece of malware that uses packing techniques to evade detection.
Malware authors may use packers to compress, encrypt, or obfuscate their malicious code, making it harder for antivirus software and other SOC analyst tools
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to identify the threat.
Unpacking involves reverse-engineering these packing techniques to reveal the original, unobfuscated code for further analysis.
This can allow researchers to understand the malware's functionality, behavior, and potential impact.
## Malware analysis steps
Now, we’ll look at the different steps involved in static malware analysis.
### How to conduct static malware analysis
In malware analysis, we exercise a method called static analysis to study malware without necessitating its execution. This involves the meticulous investigation of malware's code, data, and structural components, serving as a vital precursor for further, more detailed analysis.
This helps us extract important information like:
- File type.
- File hash.
- Strings.
- Embedded elements.
- Packer information.
- Imports.
- Exports.
- Assembly code.
#### Step 1: Identifying the file type
Our first port of call in this stage is to understand the basic information about the malware specimen to lay the groundwork for our investigation.
Given that file extensions can be manipulated and changed, our task is to find a way to identify the _actual_ file type we are encountering.
Establishing the file type plays an integral role in static analysis, because it ensures that the procedures we apply are appropriate and the results obtained are accurate.
Let's use a Windows-based malware named Ransomware.wannacry.exe residing in the /home/htb-student/Samples/MalwareAnalysis directory of this module’s
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target as an illustration.
`The command for checking the file type of this malware would be the following:`
`/home/htb-student/Samples/MalwareAnalysis/Ransomware.wannacry.exe`
`/home/htb-student/Samples/MalwareAnalysis/Ransomware.wannacry.exe: PE32 executable (GUI) Intel 80386, for MS Windows`
From this, we would learn that it is a Portable Executable32 file:
#### Step 2: Malware fingerprinting
In this stage, our mission is to create a unique identifier for the malware sample. This typically takes the form of a cryptographic hash—MD5, SHA1, or SHA256.
To do this, we will employ Fingerprinting techniques. Fingerprinting allows us to perform a variety of tasks, including:
- Identification and tracking of malware samples.
- Scanning an entire system for the presence of identical malware.
- Confirmation of previous encounters and analyses of the same malware.
- Sharing with stakeholders as IoC (Indicators of Compromise) or as part of threat intelligence reports.
To check the MD5 file hash of our example malware, we use the following command, which returns the following results:
`md5sum /home/htb-student/Samples/MalwareAnalysis/Ransomware.wannacry.exe`
`db349b97c37d22f5ea1d1841e3c89eb4 /home/htb-student/Samples/MalwareAnalysis/Ransomware.wannacry.exe`
`Algorithm Hash Path`
`--------- ---- ----`
`MD5 DB349B97C37D22F5EA1D1841E3C89EB4 C:\Samples\MalwareAnalysis\Ra...`
To check the SHA256 file hash of the abovementioned malware, we use the following command and receive the following results:
`PS C:\Users\htb-student> Get-FileHash -Algorithm SHA256 C:\Samples\MalwareAnalysis\Ransomware.wannacry.exe`
`Algorithm Hash Path`
`--------- ---- ----`
`SHA256 24D004A104D4D54034DBCFFC2A4B19A11F39008A575AA614EA04703480B1022C C:\Samples\MalwareAnalysis\Ra..`
#### Step 3: File hash lookup
This next step involves checking the file hash produced in the prior step against online malware scanners and sandboxes, like VirusTotal
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It’s an online malware scanning engine that collaborates with various antivirus vendors and allows us to search for the file hash. This step aids us in comparing our results with existing knowledge about the malware sample.
The following image shows the results from VirusTotal after the SHA256 file hash of the aforementioned malware we submitted.
Even though a file hash like MD5, SHA1, or SHA256 is valuable for identifying identical samples with disparate names, it doesn’t help us as much with identifying similar malware samples.
This is primarily because a malware author can alter the file hash value by making minor modifications to the code and recompiling it.
#### Step 4: String analysis
In this phase, our objective is to extract ASCII & Unicode strings from a binary.
Strings can provide us with clues and valuable insight into the functionality of the malware.
Occasionally, we can unearth unique embedded strings in a malware sample, such as:
- Embedded filenames (e.g., dropped files).
- IP addresses or domain names.
- Registry paths or keys.
- Windows API functions.
- Command-line arguments.
- Unique information that might hint at a particular threat actor.
The following command will reveal strings for a ransomware sample named dharma\_sample.exe residing in the /home/htb-student/Samples/MalwareAnalysis directory of this module’s
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target.
`strings -n 15 /home/htb-student/Samples/MalwareAnalysis/dharma_sample.exe`
`!This program cannot be run in DOS mode.`
`@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@>@@@?456789:;<=@@@@@@@`
`!"#$%&'()*+,-./0123@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@@ABCDEFGHIJKLMNOPQRSTUVWXYZabcdefghijklmnopqrstuvwxyz0123456789+/`
`WaitForSingleObject`
`InitializeCriticalSectionAndSpinCount`
`LeaveCriticalSection`
`EnterCriticalSection`
`C:\crysis\Release\PDB\payload.pdb`
`0123456789ABCDEF`
**Note**: The -n flag specifies to print a sequence of at least the number specified—in our case, 15.
Occasionally, string analysis can facilitate the linkage of a malware sample to a specific threat group if significant similarities are identified.
For example
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, we can use a string containing a PDB path to link the malware sample to the Dharma/Crysis family of ransomware.
## The use cases for malware analysis in cybersecurity
Malware analysis is the process of understanding the behavior and inner workings of malware. It is a crucial aspect of cybersecurity that aids in grasping the threat posed by malicious software and devising effective countermeasures.
Malware analysis serves several use cases:
- **Detection and classification:** Through analyzing malware, we can identify and categorize different types of threats based on their unique characteristics, signatures, or patterns. This helps us develop detection rules and understand the nature of the malware we encounter.
- **Reverse engineering:** Malware analysis often involves the intricate process of reverse engineering the malware's code to discern its underlying operations and employed techniques. This can unveil concealed functionalities, encryption methods, details about the command-and-control (C2) infrastructure, and techniques used for obfuscation and evasion.
- **Behavioral analysis:** Studying the behavior of malware during execution gives us insights into its actions. Such as modifications to the file system, network communications, changes to the system registry, and attempts to exploit vulnerabilities. This information about the impact of the malware on infected systems and assists in devising potential countermeasures.
- **Threat intelligence:** Through malware analysis, threat researchers can amass critical intelligence about attackers, their tactics, techniques, and procedures (TTPs), and the malware's origins. This valuable intelligence can be shared with the wider security community to enhance detection, prevention, and response capabilities.
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Why Prevention-First Security Is the Only Solution to Ransomware
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https://www.morphisec.com/blog/prevention-first-security-is-the-solution-to-ransomware/
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ransomware attack prevention
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## The Evolution of Ransomware and the Failure of Reactive Security
### Ransomware’s Growing Sophistication
Ransomware isn’t just about encrypting files anymore. Modern ransomware attacks are highly sophisticated, leveraging advanced techniques like:
- **Double Extortion**: Attackers not only encrypt data but also exfiltrate it, threatening to leak sensitive information unless a ransom is paid.
- **Fileless Attacks**: Ransomware now hides within legitimate processes, bypassing traditional antivirus tools.
- **Lateral Movement**: Attackers spread ransomware across networks, impacting multiple endpoints and servers simultaneously.
These advancements render detection-based tools increasingly ineffective, as they rely on identifying known signatures or behaviors. According to industry research, **60% of ransomware attacks bypass traditional detection tools**, leaving businesses vulnerable.
### The Problem with Detection and Response
Most cybersecurity solutions focus on detecting ransomware after it has entered the environment. While this approach may limit the extent of the damage, it’s far from ideal. Here’s why detection and response often fail:
1. **Delayed Detection**: Many tools only identify ransomware after it has already encrypted files or exfiltrated data.
2. **Signature Dependency**: Detection tools rely on recognizing known ransomware variants, leaving businesses exposed to zero-day and unknown threats.
3. **Resource-Intensive**: Responding to ransomware requires significant time, resources, and expertise—something many organizations, especially those with lean IT teams, simply cannot afford.
Reactive solutions address the symptoms of ransomware attacks, not the root cause. Businesses need a shift in mindset: **stop ransomware before it starts**.
## The Case for Prevention-First Security
### What Is Prevention-First Security?
Prevention-first security focuses on stopping ransomware and other advanced threats before they can execute. Instead of relying on detection, prevention-first solutions proactively eliminate vulnerabilities, block malicious actions, and prevent attacks from succeeding.
This approach aligns with the **Gartner-defined Preemptive Cyber Defense** category, which is projected to dominate the cybersecurity landscape by 2030. Gartner predicts that **75% of security solutions will adopt preemptive approaches within the next five years** 1, reflecting the growing recognition that prevention is the only way to stay ahead of evolving threats.
### Why Prevention Is the Only Effective Solution
Prevention-first security offers several key advantages over traditional detection and response:
1. **Stops Threats Before Damage Occurs**: By eliminating vulnerabilities and blocking malicious actions, prevention-first solutions ensure ransomware never gets the chance to encrypt files or exfiltrate data.
2. **Reduces Complexity**: Prevention-focused tools require less manual intervention, making them ideal for lean IT teams that need simple, effective protection.
3. **Minimizes False Positives**: Unlike detection tools that flag suspicious behaviors, prevention-first solutions directly stop malicious actions, reducing false alarms.
4. **Future-Proofs Against Ransomware Evolution**: Prevention-first security is not reliant on signatures or known behaviors, making it effective against zero-day and fileless attacks.
### Morphisec: Leading the Prevention-First Revolution
Morphisec has been at the forefront of prevention-first security, offering businesses unparalleled protection through its **Anti-Ransomware Assurance Suite**. Unlike traditional tools, Morphisec’s solutions are designed to stop ransomware at every stage of the attack lifecycle.
## How Morphisec Prevents Ransomware
Morphisec’s prevention-first approach is built on three critical layers of protection:
### 1\. Pre-Execution: Stopping Threats Before They Start
Morphisec eliminates vulnerabilities and reduces the attack surface, ensuring ransomware cannot gain a foothold. Key features include:
- **Monitoring Security Gaps**: Identifying misconfigurations and weaknesses in the IT environment.
- **Detecting Vulnerabilities**: Preventing exploitation of unpatched systems or outdated applications.
- **Exposing Shadow Network Services**: Discovering unauthorized or hidden services that attackers could exploit.
By addressing threats before they can execute, Morphisec ensures that businesses are always one step ahead of ransomware.
### 2\. During-Execution: Blocking Malicious Actions
If ransomware attempts to execute, Morphisec’s advanced capabilities block it in real time. These include:
- **Preventing Encryption and Data Destruction**: Stopping ransomware from locking critical files.
- **Halting Credential Theft and Privilege Escalation**: Blocking attempts to gain elevated permissions.
- **Detecting and Blocking Lateral Movement**: Preventing ransomware from spreading across networks.
Morphisec’s solutions ensure that even the most sophisticated ransomware variants are neutralized before they can cause damage.
### 3\. Post-Execution: Ensuring Rapid Recovery
In the rare event of a ransomware breach, Morphisec enhances recovery with tools like:
- **Encryption Key Recovery**: Restores access to locked files without paying a ransom.
- **Restoration of Hidden Recovery Points**: Recovers secure backups even when ransomware attempts to delete them.
This comprehensive approach ensures minimal downtime and operational disruption.
## How Morphisec Stands Out
Morphisec is more than just another cybersecurity vendor—it’s the **go-to solution for Anti-Ransomware Protection**. Here’s how Morphisec differentiates itself:
- **Prevention-First Approach**: Unlike competitors that focus on detection, Morphisec proactively prevents ransomware attacks.
- **Signatureless Technology**: Morphisec’s solutions are not reliant on known behaviors or signatures, making them effective against zero-day threats.
- **Comprehensive Protection**: Morphisec delivers protection across pre, during-, and post-execution phases, ensuring end-to-end security.
These capabilities make Morphisec the trusted choice for over 7,000 organizations worldwide, protecting more than 9 million endpoints every day.
## Prevention in Action: Real-World Success Stories
Morphisec’s prevention-first approach has proven its effectiveness in real-world scenarios. Here are just a few examples:
- **Houston Eye Associates**: Prevented a ransomware attack and achieved a 40% reduction in cybersecurity costs.
- **TruGreen**: Strengthened its cybersecurity posture by 10x with Morphisec’s solutions.
- **Fortune 500 Manufacturer**: Leveraged Morphisec to fill gaps in its extended detection and response (XDR) strategy.
These success stories demonstrate why businesses across industries trust Morphisec to deliver real results.
### Why Businesses Need Prevention-First Security Now
The rise of ransomware shows no signs of slowing down. Businesses that rely on outdated, reactive tools are putting their data, operations, and reputations at risk. The time to adopt a prevention-first approach is now.
With solutions like Morphisec’s **Anti-Ransomware Assurance Suite**, businesses can:
- Prevent ransomware before it executes.
- Reduce complexity and operational overhead.
- Achieve greater peace of mind with the **Ransomware-Free Guarantee**.
|
Five Ways to Prevent and Protect Against Ransomware Attacks
|
https://www.akamai.com/blog/security/five-ways-to-protect-against-ransomware-attacks
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ransomware attack prevention
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Ransomware is a pervasive type of malware that encrypts and restricts access to an enterprise’s data, including files, documents, and images. Cybercriminals then demand a ransom payment — often in a cryptocurrency like bitcoin — in exchange for restoring the data. If the ransom isn’t fulfilled within the specified period, the attacker either destroys or publicly releases that data to the internet, often via sites on the dark web.
Ransomware incidents pose a significant threat, especially for enterprises with large volumes of proprietary and customer data. Not only is there the upfront cost of paying off a ransom, but ransomware cyberattacks can also damage brand reputation and put organizations at risk of violating data privacy laws and regulations.
Proactive, holistic ransomware protection and prevention measures are crucial to your enterprise’s continued success — especially considering the following statistics:
- The share of global organizations affected by ransomware attacks increased from 55.1% in 2018 to 72.7% in 2023.
- The estimated cost of cybercrime attacks is projected to increase to US$13.82 trillion by 2028.
- Network downtime, critical data loss, and brand/reputation damage are three of the biggest issues for organizations after a ransomware attack.
Read on to learn how ransomware infects target devices and the five steps you can take to protect your digital systems from cybercriminals.
## How is ransomware delivered?
Ransomware is often delivered through compromised websites or phishing emails that appear to have been sent from a legitimate, trusted source. These emails entice users to click malicious links or open attachments that automatically download the ransomware to the user’s device without their consent — and often without their knowledge.
The ransomware may also run after download and without any interaction. Once executed, the ransomware may encrypt the data on that device, but it’s more likely that the attacker will use the compromised device as the means to move throughout the network to discover high-value targets, such as customer lists or company confidential data.
## How to prevent ransomware attacks
Now that you understand how ransomware infections occur, you can apply the security measures needed to protect your organization from these devastating attacks. The following five ways can help you prevent these attacks:
1. Assess your ransomware risk
2. Update your organization’s endpoint devices
3. Create frequent and thorough offline data backups
4. Educate employees to recognize potential ransomware attacks
5. Reduce the attack surface by minimizing the use of VPNs
## 1\. Assess your ransomware risk
Before putting ransomware prevention and protection measures into place, try to analyze the specific ways that your organization may be at risk — evaluate potential vulnerabilities, system misconfigurations, attack vectors, and potentially malicious network activity. Document this information in a ransomware risk report, so your team can choose the most appropriate ransomware prevention and attack mitigation measures for your organization.
Wondering where to start? The Center for Internet Security’s Ransomware Business Impact Analysis Tool can help you quantify the likelihood and potential impacts of a ransomware attack on your enterprise so you can craft a sound incident response plan against hackers.
## 2\. Update your organization’s endpoint devices
Software and operating system vendors frequently release new security and antivirus updates — called patches — for their products. These updates are often designed to address newly discovered security vulnerabilities and emerging malware types — including new ransomware variants. By frequently auditing organization-wide devices, your IT team can discover and address outdated operating systems and applications.
Contemporary operating systems, such as Microsoft Windows, macOS, iOS, Android, and others, offer frequent, proactive patches designed to help bolster endpoint security and protect your devices against ransomware. Applications may automatically update when new updates get released, or they may require a manual update via a web page.
However, in some cases, when a vulnerability is discovered and reported, it may take time for the source code creators to develop and distribute a patch — leaving devices at risk. In these cases, you can apply microsegmentation along with monitoring solutions like Akamai Hunt to protect the vulnerable asset until a patch has been created, filling the critical time gap between when a vulnerability is detected and a patch is issued.
## 3\. Create frequent and thorough offline data backups
At the outset of a successful ransomware attack, the attacker encrypts an organization’s proprietary and customer data and makes it inaccessible to the organization. If the organization neglects to pay the attacker’s ransom demands, their compromised data may be affected in the way specified by the attacker. In some cases, this can mean that sensitive data will be publicly released via sites on the dark web. In other cases, the data will be outright destroyed.
In the latter scenario, having up-to-date backup files for all your organization’s data can help you recover your data. Of course, if your backups are part of the impacted dataset, they’ll be inaccessible. It is best practice to store backup files on devices that are strictly segmented away from the main network or the internet so they can’t be remotely targeted by attackers.
Cloud services that retain previous file versions allow you to roll your compromised data back to an unencrypted version to alleviate the effects of a ransomware attack. Be sure to verify that your backups weren’t infected because of an unknown internet or intranet connection before rolling back so you don’t risk further compromising your data and devices.
Alternatively, you can externally offload your organization’s data to the cloud. Look for cloud storage solutions that offer dependable, easily accessible storage and management functionality you can use to automatically create daily, weekly, or biweekly data backups for your entire organization.
## 4\. Educate employees to recognize potential ransomware attacks
Firewalls can only do so much to protect your organization from external cyberthreats. Malicious software can make its way to unsuspecting organization members in the form of suspicious emails. So the onus is on everyone within your organization, not just those on security teams, to practice strong email security and help stop ransomware attacks from occurring. It’s good practice to mandate ransomware awareness training and education that focuses on:
- Email senders
- Links
- Email attachments
- Remote desktop protocol and credential abuse
### Email senders
When employees receive an email from an unfamiliar sender, or if the content of the email seems suspicious, they should forward that email to your organization’s IT department or help desk. Experts can assess the sender’s legitimacy by inspecting the domain name — for example, official email correspondence from Akamai always contains “@akamai.com” in the sender address — or by referring to a list of approved addresses.
### Links
It’s essential that employees exercise caution when faced with a link to an unknown page, since sending malicious links is a primary ransomware distribution strategy. Educate employees to first inspect a link to verify its validity before clicking on it.
For example, if a link reads “akamai.net,” they can type “Akamai” into a search engine to discover that Akamai’s official website is “akamai.com” — thereby discovering that the link may be malicious in nature. In cases like these, employees should forward the correspondence containing the potentially malicious link to your organization's IT department or help desk to determine its safety and legitimacy.
### Email attachments
Teach your employees to exercise caution when presented with an email that contains an attachment, even when it’s sent by a verified sender. Ransomware executables may be directly embedded in malicious emails, but are often disguised as other files — particularly compressed files with .zip or .rar extensions — which, once opened, will automatically begin encrypting the infected device’s data. No matter the situation, your employees should always alert your organization’s IT department or help desk to confirm an email attachment’s safety before opening it.
### Remote desktop protocol and credential abuse
Remote desktop protocol (RDP) is a secure, interoperable protocol that establishes secure connections among clients, servers, and virtual machines, enabling users to remotely access servers and desktops. RDP can be abused, however. With credentials purchased off the dark web, cyberattackers can use brute-force or credential stuffing attacks to remotely log in to organizational systems while posing as a legitimate user — then infect the network with malware.
This approach works in tandem with other ransomware attack approaches like malicious email and link attacks because those tactics are used to procure user credential information that gets sold and used in RDP attacks. Always ensure that your employees understand the risks that can come with opening a link or email from an unknown user.
Of course, educating your organization’s employees to recognize potential ransomware attacks is only possible when your organization’s leaders are educated themselves. The Akamai Ransomware Threat Report by Akamai’s anti-malware security experts contains information on new and emerging ransomware toolkits as well as trends and mitigation techniques you can refer to in the event of a ransomware attack.
## 5\. Reduce the attack surface by minimizing the use of VPNs
Attackers are continuously looking for ways to gain an initial foothold into an organization. One very common approach is to exploit any security vulnerabilities or misconfigurations in virtual private networks (VPNs), which are used to provide employees with remote access to resources such as business applications. Since a VPN provides network-level access, once an attacker has gained VPN access then they are free to move laterally to find high-value targets.
Zero Trust Network Access ( ZTNA) solutions, such as Akamai Enterprise Application Access, are alternatives to VPNs. Based on Zero Trust principles, access is only provided once a user is authenticated and authorized to access specific resources based on the user’s security policy. In addition, access can be allowed or denied based on the context of the request; for example, Where is the user connecting from? What is the security posture of their device?; Does the device have the latest security patches applied?
Most important, network-level access is eliminated and users only have access to the resources that they need. In addition, inbound firewall ports can be closed because all application connections are made outbound through the firewall, which makes the applications undiscoverable by attackers. The elimination of network-level access, closing inbound firewall access, and hiding resources from the public internet can significantly reduce an organization's attack surface.
To ensure strong authentication for users, deploying a phish-proof multi-factor authentication (MFA) service such as Akamai MFA, in conjunction with ZTNA, eliminates the use of stolen or compromised employee login credentials to take over employee accounts.
## Prevent enterprise ransomware attacks and strengthen cybersecurity with Akamai solutions
By partnering with an experienced cloud security provider, your enterprise can prevent ransomware from infecting your network and impacting your reputation.
If you’re struck by a ransomware attack, it’s crucial to minimize the attack surface by preventing lateral movement of the ransomware across your organization’s devices. Akamai Guardicore Segmentation offers granular controls that make it fast, easy, and intuitive to protect your organization and critical assets from lateral movement in on-premises and multi-cloud environments during a ransomware attack.
This solution enables process-level visibility of your organization’s asset communications and dependencies, as well as robust threat detection capabilities — all so you can more proactively assess risk, prevent ransomware attacks, and protect your organization while receiving real-time notifications on your organization’s security posture.
|
Steps to Help Prevent & Limit the Impact of Ransomware
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https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware
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ransomware attack prevention
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**Maximum Storage Duration**: Session**Type**: HTTP Cookie
- [Hotjar\\
11](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**\_hjAbsoluteSessionInProgress** This cookie is used to count how many times a website has been visited by different visitors - this is done by assigning the visitor an ID, so the visitor does not get registered twice.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**\_hjFirstSeen** This cookie is used to determine if the visitor has visited the website before, or if it is a new visitor on the website.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**\_hjIncludedInPageviewSample** Used to detect whether the user navigation and interactions are included in the website’s data analytics.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**\_hjIncludedInSessionSample\_#** Collects statistics on the visitor's visits to the website, such as the number of visits, average time spent on the website and what pages have been read.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**\_hjRecordingLastActivity** Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**\_hjSession\_#** Collects statistics on the visitor's visits to the website, such as the number of visits, average time spent on the website and what pages have been read.
**Maximum Storage Duration**: 1 day**Type**: HTTP Cookie
**\_hjSessionUser\_#** Collects statistics on the visitor's visits to the website, such as the number of visits, average time spent on the website and what pages have been read.
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
**\_hjTLDTest** Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**hjViewportId \[x2\]** Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**hjActiveViewportIds** This cookie contains an ID string on the current session. This contains non-personal information on what subpages the visitor enters – this information is used to optimize the visitor's experience.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
- [Issuu\\
5](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**SESSION\_STORAGE\_ID\_pico\_ssid** Pending
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**spidersense#event** Pending
**Maximum Storage Duration**: Persistent**Type**: IndexedDB
**spidersense#setup\_response** Pending
**Maximum Storage Duration**: Persistent**Type**: IndexedDB
**spidersense#user\_info** Pending
**Maximum Storage Duration**: Persistent**Type**: IndexedDB
**spidersense:user\_id:v1\_issuu\_web** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
- [LinkedIn\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**AnalyticsSyncHistory** Used in connection with data-synchronization with third-party analysis service.
**Maximum Storage Duration**: 1 month**Type**: HTTP Cookie
- [NewsCred\\
2](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**\_gd#** Pending
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**nc-previous-guid** Pending
**Maximum Storage Duration**: 1 day**Type**: HTTP Cookie
- [Optimizely\\
12](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**optimizelyEndUserId** Used to measure how selected users react to targeted changes to the website's content and functionality, in order to determine what variation is most efficacious in terms of converting users to customers.
**Maximum Storage Duration**: 180 days**Type**: HTTP Cookie
**optimizelySession** Pending
**Maximum Storage Duration**: 180 days**Type**: HTTP Cookie
**#/#$#** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**https://#\_oeu#.#$event\_queue** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**https://#\_oeu#.#$layer\_states** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**https://#\_oeu#.#$session\_state** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**https://#\_oeu#.#$tracker\_optimizely** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**https://#\_oeu#.#$variation\_map** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**https://#\_oeu#.#$visitor\_profile** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**https://www.cisecurity.org\_pending\_events** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**optimizely\_data$#$#$contextual\_mab** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**optimizely\_data$pending\_events** This cookie is set to make split-tests on the website, which optimizes the website's relevance towards the visitor – the cookie can also be set to improve the visitor's experience on a website.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
- [Qualtrics\\
3](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**Q\_INTER** Collects statistics on the visitor's visits to the website, such as the number of visits, average time spent on the website and what pages have been read.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**QSI\_ActionSetHistory** Assigns a specific ID to the visitor. This allows the website to determine the number of specific user-visits for analysis and statistics.
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**QSI\_HistorySession** This cookie is used to determine when the visitor last visited the different subpages on the website.
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
- [Quantcast\\
3](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**\_\_qca** Collects data on the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded with the purpose of generating reports for optimising the website content.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**\_dlt \[x2\]** Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes.
**Maximum Storage Duration**: 1 day**Type**: HTTP Cookie
- [Twitter Inc.\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**personalization\_id** This cookie is set by Twitter - The cookie allows the visitor to share content from the website onto their Twitter profile.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
- [cisecurity.org\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**SC\_ANALYTICS\_GLOBAL\_COOKIE** Used by Sitecore Engagement Analytics to identify the visitor on repeat visits to the website.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
- [enroll.cisecurity.org\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**A/N{39}** Pending
**Maximum Storage Duration**: 1 day**Type**: HTTP Cookie
- [pixel.newscred.com\\
pixel.welcomesoftware.com\\
2](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**px.gif \[x2\]** This cookie is used to determine if the visitor has any adblocker software in their browser – this information can be used to make website content inaccessible to visitors if the website is financed with third-party advertisement.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
- [www.cisecurity.org\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**wistia** Used by the website to track the visitor's use of video-content - The cookie roots from Wistia, which provides video-software to websites.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
- [www.googleoptimize.com\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**\_gid** Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
**Maximum Storage Duration**: 2 days**Type**: HTTP Cookie
- Marketing 86
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
- [Amazon\\
2](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**ad-id** Used by Amazon Advertising to register user actions and target content on the website based on ad clicks on a different website.
**Maximum Storage Duration**: 241 days**Type**: HTTP Cookie
**ad-privacy** Used by Amazon Advertising to register user actions and target content on the website based on ad clicks on a different website.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
- [Google\\
10](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
Some of the data collected by this provider is for the purposes of personalization and measuring advertising effectiveness.
**\_gcl\_au** Used by Google AdSense for experimenting with advertisement efficiency across websites using their services.
**Maximum Storage Duration**: 3 months**Type**: HTTP Cookie
**IDE** Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
**pagead/landing \[x2\]** Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
**pagead/viewthroughconversion/855211744** Pending
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
**ads/ga-audiences** Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
**NID** Pending
**Maximum Storage Duration**: 6 months**Type**: HTTP Cookie
**pagead/1p-conversion/#** Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
**pagead/1p-conversion/#/** Pending
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
**pagead/1p-user-list/#** Tracks if the user has shown interest in specific products or events across multiple websites and detects how the user navigates between sites. This is used for measurement of advertisement efforts and facilitates payment of referral-fees between websites.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
- [Hotjar\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**\_hjRecordingEnabled** This cookie is used to identify the visitor and optimize ad-relevance by collecting visitor data from multiple websites – this exchange of visitor data is normally provided by a third-party data-center or ad-exchange.
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
- [Issuu\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**iutk** Recognises the user's device and what Issuu documents have been read.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
- [LinkedIn\\
3](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**bcookie** Used in order to detect spam and improve the website's security.
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
**bscookie** Used by the social networking service, LinkedIn, for tracking the use of embedded services.
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
**UserMatchHistory** Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor.
**Maximum Storage Duration**: 1 month**Type**: HTTP Cookie
- [Microsoft\\
8](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**\_uetsid** Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**\_uetsid\_exp** Contains the expiry-date for the cookie with corresponding name.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**\_uetvid** Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**\_uetvid\_exp** Contains the expiry-date for the cookie with corresponding name.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**MSPTC** This cookie registers data on the visitor. The information is used to optimize advertisement relevance.
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
**MUID** Used widely by Microsoft as a unique user ID. The cookie enables user tracking by synchronising the ID across many Microsoft domains.
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
**\_uetsid** Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement.
**Maximum Storage Duration**: 1 day**Type**: HTTP Cookie
**\_uetvid** Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences.
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
- [NewsCred\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**\_\_ncuid** Pending
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
- [Optimizely\\
10](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**optimizelyDomainTestCookie \[x2\]** Tracks the conversion rate between the user and the advertisement banners on the website - This serves to optimise the relevance of the advertisements on the website.
**Maximum Storage Duration**: 180 days**Type**: HTTP Cookie
**optimizelyOptOut \[x2\]** Collects visitor data related to the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**optimizely\_data$#$event\_queue** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**optimizely\_data$#$layer\_states** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**optimizely\_data$#$session\_state** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**optimizely\_data$#$tracker\_optimizely** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**optimizely\_data$#$variation\_map** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**optimizely\_data$#$visitor\_profile** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
- [Pardot\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**lpv#** Used in context with behavioral tracking by the website. The cookie registers the user’s behavior and navigation across multiple websites and ensures that no tracking errors occur when the user has multiple browser-tabs open.
**Maximum Storage Duration**: 1 day**Type**: HTTP Cookie
- [Quantcast\\
2](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**\_qcses\_p-5cvC4NOeGmtNA** Pending
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**mc** Collects data on the user's visits to the website, such as what pages have been loaded. The registered data is used for targeted ads.
**Maximum Storage Duration**: 13 months**Type**: HTTP Cookie
- [Tealium\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**utag\_main** Used by Tealium Tag Manager to store a unique visitor ID, a session ID and to persist data about the visitor's interaction with the website, e.g. last page viewed.
**Maximum Storage Duration**: 1 year**Type**: HTTP Cookie
- [The Trade Desk\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**track/pxl/** Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
- [Twitter Inc.\\
9](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**1/i/adsct \[x2\]** Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
**i/adsct \[x2\]** The cookie is used by Twitter.com in order to determine the number of visitors accessing the website through Twitter advertisement content.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
**muc\_ads** Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
**guest\_id** Collects data related to the user's visits to the website, such as the number of visits, average time spent on the website and which pages have been loaded, with the purpose of personalising and improving the Twitter service.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
**guest\_id\_ads** Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
**guest\_id\_marketing** Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website.
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
**i/jot/embeds** Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers.
**Maximum Storage Duration**: Session**Type**: Pixel Tracker
- [YouTube\\
19](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#) Learn more about this provider
**#-#** Used to track user’s interaction with embedded content.
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**\_\_Secure-ROLLOUT\_TOKEN** Pending
**Maximum Storage Duration**: 180 days**Type**: HTTP Cookie
**iU5q-!O9@$** Registers a unique ID to keep statistics of what videos from YouTube the user has seen.
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**LAST\_RESULT\_ENTRY\_KEY** Used to track user’s interaction with embedded content.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**LogsDatabaseV2:V#\|\|LogsRequestsStore** Used to track user’s interaction with embedded content.
**Maximum Storage Duration**: Persistent**Type**: IndexedDB
**remote\_sid** Necessary for the implementation and functionality of YouTube video-content on the website.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**ServiceWorkerLogsDatabase#SWHealthLog** Necessary for the implementation and functionality of YouTube video-content on the website.
**Maximum Storage Duration**: Persistent**Type**: IndexedDB
**TESTCOOKIESENABLED** Used to track user’s interaction with embedded content.
**Maximum Storage Duration**: 1 day**Type**: HTTP Cookie
**VISITOR\_INFO1\_LIVE** Tries to estimate the users' bandwidth on pages with integrated YouTube videos.
**Maximum Storage Duration**: 180 days**Type**: HTTP Cookie
**YSC** Registers a unique ID to keep statistics of what videos from YouTube the user has seen.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
**ytidb::LAST\_RESULT\_ENTRY\_KEY** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**YtIdbMeta#databases** Used to track user’s interaction with embedded content.
**Maximum Storage Duration**: Persistent**Type**: IndexedDB
**yt-remote-cast-available** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**yt-remote-cast-installed** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**yt-remote-connected-devices** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**yt-remote-device-id** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
**yt-remote-fast-check-period** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**yt-remote-session-app** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
**yt-remote-session-name** Stores the user's video player preferences using embedded YouTube video
**Maximum Storage Duration**: Session**Type**: HTML Local Storage
- [learn.cisecurity.org\\
pardot.com\\
resources.cisecurity.org\\
3](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**pardot \[x3\]** Used in context with Account-Based-Marketing (ABM). The cookie registers data such as IP-addresses, time spent on the website and page requests for the visit. This is used for retargeting of multiple users rooting from the same IP-addresses. ABM usually facilitates B2B marketing purposes.
**Maximum Storage Duration**: Session**Type**: HTTP Cookie
- [learn.cisecurity.org\\
resources.cisecurity.org\\
www.googletagmanager.com\\
3](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**\_gcl\_ls \[x3\]** Tracks the conversion rate between the user and the advertisement banners on the website - This serves to optimise the relevance of the advertisements on the website.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
- [ml314.com\\
learn.cisecurity.org\\
resources.cisecurity.org\\
4](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**\_ccmsi \[x4\]** Used to track which users have shown interest in what job postings. The cookie ensures that the most relevant job postings are shown to the specific user.
**Maximum Storage Duration**: Persistent**Type**: HTML Local Storage
- [pi.pardot.com\\
learn.cisecurity.org\\
6](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**visitor\_id# \[x6\]** Used in context with Account-Based-Marketing (ABM). The cookie registers data such as IP-addresses, time spent on the website and page requests for the visit. This is used for retargeting of multiple users rooting from the same IP-addresses. ABM usually facilitates B2B marketing purposes.
**Maximum Storage Duration**: 401 days**Type**: HTTP Cookie
- [www.cisecurity.org\\
1](https://www.cisecurity.org/insights/blog/7-steps-to-help-prevent-limit-the-impact-of-ransomware#)
**SC\_TRACKING\_CONSENT** Pending
**Maximum Storage Duration**: 400 days**Type**: HTTP Cookie
- Unclassified 0
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
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Home Insights Blog Posts Steps to Help Prevent & Limit the Impact of Ransomware
# Steps to Help Prevent & Limit the Impact of Ransomware
From small local government entities to large organizations, ransomware attacks are everywhere. It's up to all of us to help prevent these attacks from being successful.
Ransomware is a type of malware that encrypts files on a system or device in an attempt to coerce the victim to pay a ransom. Threat Actors (TAs) can also warn of files being leaked, erased, or inaccessible. TAs will drop ransom notes claiming responsibility and encourage a response from the victim through the medium they dictate, through encrypted chat or email (for example). Ransomware can be particularly harmful when it targets hospitals, emergency call centers, and other critical infrastructure, as a successful infection could disrupt access to systems and data necessary for delivering life-saving medical treatment and upholding public safety.
To protect against ransomware, you need a holistic, all-hands-on-deck, defense-in-depth approach that brings together your entire organization. Below are four ways you can get started in your efforts to stop attacks and limit the effects of ransomware. We've mapped each step to the applicable security best practices of the CIS Critical Security Controls® (CIS Controls®) so that you can learn more on each topic.
## 1\. Develop Policies and Procedures
Create a scalable and practical incident response plan so you and your staff understand their responsibilities and communication protocols both during and after a cyber incident. Teams to include in your incident response plan include (but aren't limited to) IT, legal, and administrative teams. You should also include a list of contacts such as any partners, insurance providers, or vendors that would need to be notified. These plans should be run through a test process or " tabletop exercise" to assess the implementation, identify any gaps, and then refine plans accordingly. We recommend reviewing the plan on a quarterly basis to account for organizational growth and changes such as end-users/staff or IT assets and infrastructure.
**View **CIS Control 17** for more on incident response management.**
## 2\. Maintain Backups
Backing up important data is the single most effective way of recovering from a ransomware infection. There are some things to consider, however. Your backup files should be appropriately protected and stored offline or out-of-band so they can't be targeted by attackers. You can use cloud services to help mitigate a ransomware infection, as many of these services retain previous versions of files that allow you to roll back to an unencrypted version. Be sure to routinely test backups for efficacy. In the case of an attack, verify that your backups aren't infected and secure your backups immediately following the attack. It is also important to ensure that the integrity of said backups are maintained, and it is also important to confirm before rolling back.
****Control 11** provides more information about how to make a data recovery plan.**
## 3\. Know Your Attack Surface and Harden Your Network
You can't defend what you don't know about, so your first step here is developing asset inventories for your enterprise assets and software. You can do so using Control 1 and Control 2. Once you understand your attack surface, you can then move on ensuring your systems are configured with security in mind. Secure configuration settings can help limit your organization's threat surface and close security gaps left over from default configurations. Toward that end, you can use the secure recommendations of the CIS Benchmarks™, industry-leading, consensus-developed configurations which are freely available to all. Keep reading to explore several examples of effective hardening methods you can consider when reviewing the current security posture of your organization.
### Review Port Settings
Many ransomware variants take advantage of Remote Desktop Protocol (RDP) port 3389 and Server Message Block (SMB) port 445. Consider whether your organization needs to leave these ports open and consider limiting connections to only trusted hosts. Be sure to review these settings for both on-premises and cloud environments, working with your cloud service provider to disable unused RDP ports.
**Control 4 describes different ways your organization can control network ports, protocols, and services.**
### Keep Systems up to Date
Make sure all of your organization’s operating systems, applications, and software are updated regularly. By applying the latest updates, you'll make progress in closing security gaps that attackers are looking to exploit. Where possible, turn on auto-updates so you’ll automatically have the latest security patches. In some environments, out-of-date software is necessary to utilize based on operational need. Strongly consider addressing those systems that contain particularly vulnerable software and deprecate/update as soon as possible.
**Additional information about updating and vulnerability management is available in Control 7.**
### Network Visibility
Prior to an incident, it is important to consider the overall visibility of your network and user accounts. You can improve your visibility by maintaining up-to-date network diagrams and storing them so they can be retrieved from secure containers. This also includes visibility of your end-user accounts. Review Active Directory for accounts that can be removed or no longer needed while implementing a strict naming convention and heavily discouraging the use of shared accounts, which would generate a system of accountability when assigning vendor accounts.
**Check out Control 5 for more details about managing your organization's accounts.**
### Access Control
To gauge your organization's overall security posture, review your access control policy and implementation. Specifically, review how your end-users connect to your network and resources, both internally and externally, and implement safeguards such as multi-factor authentication (MFA) on solutions such as your virtual private network (VPN) client and any portals or resources that can be accessed remotely by end-users. Other things you can consider include lockout policy, password age and complexity requirements, and security challenge questions.
### Implement an IDS
An Intrusion Detection System (IDS) looks for malicious activity by comparing network traffic logs to signatures that detect known malicious activity. A robust IDS will update signatures often and alert your organization quickly if it detects potential malicious activity.
The Center for Internet Security® (CIS®) has developed Albert Network Monitoring Management, an IDS solution tailored to U.S. State, Local, Tribal, Territorial (SLTT) government organizations. It uses a custom set of signatures that are updated daily to help SLTTs detect malicious activity that precedes a ransomware infection.
### Defend Your Endpoints
You can add an additional layer to your ransomware defenses by investing in endpoint protection. Ransomware is constantly evolving, which means you can't rely solely on signatures alone for your defense. You also need to monitor your endpoints to quickly identify and block malicious activity, even in instances where no one else has seen that exact activity before.
That's the logic behind CIS Endpoint Security Services (ESS). CIS ESS uses Next Generation Antivirus (NGAV), Endpoint Detection and Response (EDR), and more to protect your endpoints against both known (signature-based) and unknown (behavior-based) malicious activity. ESS can also kill or quarantine files effectively stopping a ransomware attempt before it develops into an infection.
## 4\. Train the Team
Security awareness training is key to stopping ransomware in its tracks. When your employees can spot and avoid malicious emails, everyone plays a part in protecting the organization. Security awareness training can teach team members what to look for in an email before they click on a link or download an attachment. However, keep in mind that not all security awareness training solutions are created equal. Cost doesn’t drive effectiveness. You can model campaigns after real-world samples and challenge end-users to identify where improvements can be made.
****Control 8** describes the maintenance, monitoring, and analysis of audit logs that are managed by most commercial IDS solutions.**
## Don't Give Ransomware Actors a Time Advantage
When ransomware strikes, your organization needs to learn of an infection and investigate quickly so that you can protect your systems and data. Most organizations struggle to contain incidents quickly, however. In its 2023 Cost of a Data Breach Report, IBM found that organizations took 204 days to identify a breach and 73 days to contain them. That's plenty of time for TAs to encrypt your files.
It doesn't have to be that way. Through Albert Network Monitoring and Management, analysts in the 24x7x365 CIS Security Operations Center (SOC) perform initial investigation by confirming malicious threat activity, reviewing any historical activity from the impacted host, gathering security recommendations for the affected organization, and notifying the affected entity with expert security analysis and guidance. The process takes an average of six minutes between event detection and notification, thus complementing your other ransomware defense measures with timely insights into malicious activity.
Analysts in the CIS Cyber Incident Response Team (CIRT) are also available if your incident meets the criteria for appropriate casework at no cost to SLTTs with services that include incident response, forensic analysis, and malware analysis. You can complete a request for CIS CIRT assistance by contacting the CIS SOC 24x7x365 at soc@cisecurity.org.
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How to Prevent Ransomware & Minimize Its Impact - Commvault
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https://www.commvault.com/learn/ransomware-prevention
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ransomware attack prevention
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##### Overview
## How to Prevent Ransomware & Minimize Its Impact
Ransomware is a harsh reality in today’s world of digital business, and the damage it can inflict on an organization continues to worsen.
There were 2,321 reported ransomware attacks globally between January and June 2024, which represents an increase from the number recorded during the first six months of 2023 and about half the total number tracked for the entire year, according to the Cyber Threat Intelligence Integration Center. Security Intelligence reports that ransomware payments in 2024 reached record highs, with victims paying nearly $460 million to cyber criminals.
The largest single ransom payment also occurred in 2024, when an undisclosed Fortune 50 company paid $75 million to the Dark Angels ransomware group. The median ransom, which was less than $199,000 in early 2023, also dramatically surged to $1.5 million in June 2024, and the average ransom demand in 2024 rose to $2.73 million, nearly $1 million more than in 2023.
The threat of ransomware is both undeniable and constant. While it’s nearly impossible for organizations to prevent all malicious ransomware attacks, they can adopt best practices and strengthen their defenses to significantly mitigate the risk of major damage. With a solid backup and recovery approach, businesses can prevent significant damage during a ransomware attack and enable a fast recovery and return to normal following any disruption. Comprehensive data protection and recovery processes will help you secure your data and prevent ransomware from bringing down your business.
##### 6 Prevention Must-Haves
## Ransomware Prevention Must-Haves
Ransomware prevention and protection requires a multi-layer approach that involves best practices and processes, empowers people with education, and takes advantage of the latest technologies to arm an organization against bad actors. A multi-layer security strategy is paramount recovery readiness is critical.
**1\. Educate and train employees regularly.**
Businesses can protect against ransomware by providing regular training to employees to help them identify malicious attacks. For instance, phishing attempts often rely on social engineering approaches that attempt to trick end users into revealing sensitive information. Train employees, partners, and customers on the signs of such social engineering attempts to avoid them falling victim to an attack.
Teach employees about safe browsing habits and explain why it is important to not click on suspicious links, reinforcing them with knowledge on how to spot and avoid potential threats. Education will empower employees to act as the first line of defense against ransomware attacks by making smarter decisions online – and avoiding known pitfalls.
**2\. Enforce an immutable backup strategy.**
Backup strategies need to be as sophisticated as the bad actors’ best attempt at ransomware. A widely accepted data protection practice involves maintaining three copies of data, storing it on two different types of media, and keeping one copy safely stored off-site.
This 3-2-1 approach mitigates data loss risks in the face of ransomware by diversifying storage locations and media types. Create three copies of critical data, including the original data on the primary system and two backup copies. Store the backup copies on two distinct types of storage media, such as a local hard drive and cloud storge, to prevent a single point of failure.
Experts recommend that businesses store a copy of their data in a secondary storage such as a hyperscale appliance, tape, or on cloud storage. This type of media can help in storing data in ransomware protection mode, which is not easily accessible to ransomware attacks. Be certain one of the backup copies is stored in a remote location, separate from the primary data center, to prevent against local natural disasters.
It is also critical to invest in immutable backup. An immutable backup is a file or data copy that cannot be altered or modified in any way, meaning it remains unchanged even by administrators or malicious actors. Immutable backup protects against data deletion and provides that secure backup that can be restored even if the primary system is compromised by ransomware. Once the backup is made immutable, it cannot be deleted, overwritten, or modified in any way – which is valuable for safeguarding ransomware attacks.
**3\. Utilize isolation, segmentation, and air gap techniques.**
Isolation and air gap techniques refer to a security strategy in which backup data is stored separated and physically isolated from the primary network. This creates a gap that prevents unauthorized access to backup copies, shielding them from any potential malware or ransomware attacks that might infect the primary system. Backup data is separated into isolated storage targets using virtual LANs (VLAN), firewalls, or other network segmentation methods to restrict access. Segmenting the network also will prevent east-west or lateral movement by attackers if they have been able to penetrate perimeter defenses.
Deploy the isolated backup storage to be physically disconnected from the primary network, preventing direct access to the data. Replicate the data to this isolated environment to be sure the backup copies are security transferred to the air-gapped storage. By isolating backup data, air gap techniques significantly reduce the risk of ransomware, encrypting backup copies, as the malware cannot reach them on the isolated network.
**4\. Implement access controls, user privileges, and intrusion detection systems (IDS).**
To better understand the state of an organization’s entire security posture, it is critical to review access control policies and implementation. Review how end users connect to the network internally and externally, and put safeguards in place from password protections to multi-factor authentication on VPNs or any portals or resources that can be accessed remotely by end users or employees.
A robust IDS will proactively look for malicious activity by comparing network traffic logs to signatures that detect known malicious activity. The IDS will alert the organization in the event it detects any malicious activity. This type of layered approach to security including IDS, VPN, firewalls, antivirus software, spam filters, and cloud data loss prevention will make accessing your environment and sensitive data more difficult for would-be attackers.
**5\. Regularly monitor the environment.**
Most organizations already regularly monitor their environments, but to thwart ransomware, monitoring is critical to enable early detection of suspicious activity that could be indicative of an attack. Monitoring traffic for suspicious activity will help security teams identify malware or ransomware earlier and take proactive measures to stop the ransomware from spreading.
With comprehensive data and traffic monitoring systems in place, security teams also can encrypt data before significant damage occurs. Unusual file access patterns, rapid data encryption, or anomalous network traffic all can point to an attempted ransomware attack and by constantly monitoring system activity, security teams can spot bad actors and act quickly to contain the threat.
**6\. Develop an incident response plan.**
All these protections will help prevent and detect malicious activity, but in the event an attack happens, an incident response plan will provide the necessary steps to take after discovering an attack – and reduce the likelihood of future attacks. An incident response plan should detail how to collect data to determine the source, nature, and scope of the ransomware attack. True cyber recovery, which goes beyond incident response, encompasses the ability to quickly restore critical systems and data after an attack.
Organizations should regularly test their incident response plan, so that the people involved understand their roles and responsibilities following a ransomware attack. Consistent testing of the incident response plan also will validate its effectiveness and identify areas for improvement. It is critical to invest in a platform that allows for rapid data recovery and restoration in the event of a cyberattack, providing a swift response and minimizing downtime.
Businesses must invest in a multi-layered ransomware readiness approach, which highlights the importance of robust data protection to prevent threats, detect suspicious activity early, and provide swift recovery of data even in the event of an attack. Using immutable, air-gapped backups, continuous monitoring, and advanced anomaly detection across various environments, organizations can prioritize proactive protections and rapid restoration capabilities to minimize business disruption.
### What is a Data Cleanroom?
Cleanroom recovery provides security teams with an isolated environment to perform investigations, find gaps in defenses, and safely recover data without risk of contamination.
Learn more
### What is a 3-2-1 Backup Plan?
The 3-2-1 backup rule is a cornerstone of modern data protection and digital resilience. Facing an intensifying threat landscape, organizations rely on the 3-2-1 rule so that a clean copy of critical data will be available in the event of a cyberattack, natural disaster, or hardware failure.
Learn more
### What is Disaster Recovery?
Disaster recovery (DR) is the process of restoring an organization’s IT infrastructure and operations after a major disruption or disaster.
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Understanding Social Engineering Tactics: 8 Attacks to Watch Out For
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https://www.tripwire.com/state-of-security/5-social-engineering-attacks-to-watch-out-for
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phishing social engineering defense
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Social engineering is a dangerous weapon many cybercriminals use to achieve their nefarious goals. It leverages psychological manipulation to deceive individuals into divulging confidential or personal information. Unlike traditional hacking, which relies on exploiting software vulnerabilities, social engineering targets human vulnerabilities.
Here are the most common types of social engineering attacks in 2024 and real-world examples to highlight their impact.
## Phishing: Hook, Line, and Sinker
Phishing is one of the most common social engineering attacks. It involves sending fraudulent communications, usually emails, that appear to come from a legitimate source. The goal is to trick recipients into providing sensitive information, such as login credentials or financial details.
**Example:** In 2022, a sophisticated phishing attack aimed at stealing Office 365 credentials, where attackers impersonated the US Department of Labor (DoL). This scam exemplifies the increasing sophistication and convincing nature of modern phishing attempts.
## Spear Phishing: Precision Social Engineering
Spear phishing is a more targeted version of phishing. While phishing attacks are often sent to many recipients with a “mud-against-the-wall” approach, spear phishing targets specific individuals or firms. The malicious actor customizes the message based on information about the target, making it more convincing.
**Example:** As world leaders deliberated on the best response to the escalating tensions between Russia and Ukraine, Microsoft issued a warning in February 2022 about a new spear phishing campaign by a Russian hacking group targeting Ukrainian public sector entities and NGOs.
The group, known as Gamaredon and tracked by Microsoft as ACTINIUM, had reportedly targeted “organizations critical to emergency response and ensuring the security of Ukrainian territory” since 2021.
## Pretexting: Mastering the Art of Social Engineering
Pretexting is another form of social engineering involving creating a fabricated scenario to steal information. These scams use the same social engineering techniques that con artists have used for centuries to manipulate their victims, such as deception, validation, flattery, and intimidation. The attacker pretends to need the information to confirm the victim’s identity or to help with a supposed emergency.
At the organizational level, a pretexting actor may take extensive measures to impersonate trusted figures such as managers, coworkers, or customers. This could involve fabricating identities through fraudulent email addresses, websites, or social media profiles.
In more elaborate scenarios, the attacker might arrange face-to-face meetings with targets. For instance, a hacker masquerading as a vendor representative might schedule a meeting to gain access to confidential customer data. The attacker aims to appear credible during these encounters and build rapport with the target. By establishing trust, the attacker increases the likelihood that the target will comply with requests for sensitive information, believing them to be legitimate.
## Deepfakes: Seeing Isn’t Believing
Deepfakes, which use artificial intelligence (AI) to create realistic but fake audio, video, or images that impersonate real people, are increasingly used in various social engineering attacks to create compelling but fraudulent scenarios. They leverage manipulated audio and video to deceive targets into disclosing sensitive information or performing actions they otherwise would not.
**Example:** In 2019, a deepfake attack targeted a UK-based energy firm. Bad actors used AI-generated audio to impersonate the voice of the parent company's chief executive. They called the target company’s CEO, instructing him to transfer around $243,000 to a Hungarian supplier urgently. The voice was so convincing that the executive complied with the request.
## Not So Quid Pro Quo
Another type of social engineering is quid pro quo attacks, which involve offering a service or benefit in exchange for information. Attackers may promise tech support, free software, or other services to persuade victims to reveal confidential information.
**Examples:** One of the most prevalent quid pro quo attacks involves fraudsters posing as representatives of the US Social Security Administration (SSA). These fraudsters contact individuals randomly, requesting confirmation of their Social Security Numbers under false pretenses, enabling identity theft.
Alternatively, malicious actors identified by the Federal Trade Commission (FTC) create counterfeit SSA websites to obtain personal information illicitly. Frighteningly, attackers don’t need to be that cunning, as previous incidents have demonstrated that office employees are willing to divulge their passwords in exchange for inexpensive items like pens or chocolate bars.
## Honeytraps: Love, Lies, and Larceny
Honeytraps involve creating fake online personas to establish romantic relationships with victims. The goal is to gain and exploit the victim’s trust for financial gain or access to sensitive information.
**Example:** According to police reports, a man from Vancouver Island lost $150,000 in a romance scam. Over several months, the scammer requested money for plane tickets, medical bills, and various other expenses.
## Piggybacking: Hitching a Ride
Two other widespread threats are tailgating and piggybacking. Tailgating, in essence, is unauthorized access to secured spaces, which malefactors gain by exploiting the trust of real users. It involves gaining physical access to a restricted area by following someone with legitimate access and exploiting the courtesy of others to gain entry without proper authorization. It can also involve badge cloning, using unattended devices, or impersonation. Piggybacking happens when someone attempts to piggyback onto a hacker's attempted extortion.
**Example:** In 2018, an individual admitted guilt in England's Reading Crown Court for unauthorized computer access and blackmail while working at Oxford Biomedica, a gene therapy company. There was an incident where the company faced a ransom demand of $370,000 in Bitcoin after an attack.
An employee (ironically part of the response team) altered ransom notes to redirect payments to his cryptocurrency wallet, effectively launching a separate attack against his employer.
## Business Email Compromise: The Impersonation Game
Business email compromise (BEC) is a sophisticated cyberattack where criminals meticulously gather information about an organization's structure and key executives. Using this knowledge, they exploit the trust associated with high-ranking positions, like the CFO, to manipulate employees into transferring funds or divulging sensitive information.
By gaining access to an executive's email account, attackers impersonate them to request urgent financial transactions, such as paying fraudulent invoices. They exploit the time-sensitive nature of these transactions to minimize the chances of detection.
BEC is one of the most common attacks and one of the most costly types of cybercrime. Between 2013 and 2022, the FBI says BEC attacks caused roughly $50.8 billion in losses worldwide.
## Fighting the Exploitation
Social engineering attacks are a growing scourge in today's digital landscape. They exploit human psychology rather than technological weaknesses, making them particularly challenging to defend against. Awareness and education are crucial in combating these attacks.
Companies should integrate the following recommendations into their security awareness training:
- Exercise caution with emails from unfamiliar sources. If you receive a suspicious email, verify its legitimacy by contacting the sender directly via phone or in person.
- Be skeptical of unsolicited offers. If something appears too good to be true, it likely is.
- Always lock your laptop when stepping away from your workstation to prevent unauthorized access.
- Invest in antivirus software. While no antivirus solution offers foolproof protection, it can significantly bolster defenses against social engineering tactics.
- Familiarize yourself with your company’s privacy policy to understand protocols regarding access permissions for external individuals.
- Validate urgent requests from internal contacts before taking action, primarily involving financial transactions or sensitive information.
- Foster a culture of risk awareness to keep employees vigilant. Social engineering thrives on human error, so embedding security awareness into the organizational mindset is crucial. Employees should know how to recognize and report potential incidents promptly.
By understanding the common types of social engineering attacks and recognizing their real-world implications, individuals and organizations can better protect themselves from these pervasive threats.
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6 Types of Social Engineering Attacks and How to Prevent Them
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https://www.mitnicksecurity.com/blog/types-of-social-engineering-attacks
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phishing social engineering defense
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- Security Services
- Penetration Testing\|The Ultimate Tool for Cyber Security Assessment
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- Incident Response\|Comprehensive Expert Help After a Security Incident
- Computer Forensics\|Arm Your Legal Team with Digital Evidence
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- Security Awareness Training\|Your Comprehensive Security Training Library
- Vulnerability Assessment\|See Your System Through the Eyes of a Hacker
- Product Claims Testing\|Get Unbiased Proof From the Best in the Business
- Red Team Operations\|Evaluate Your Response to An Active Data Breach
- Social Engineering Strength Testing\|Safeguarding Your Security From Human Manipulation
# 6 Types of Social Engineering Attacks and How to Prevent Them
Posted by Mitnick Security on Nov 7, 2024 9:05:50 AM
Social engineering attacks account for a massive portion of all cyber-attacks.
In fact, as many as 90% of successful hacks and data breaches start with some form of social engineering. And if you think you’re immune, consider this: 84% of businesses have fallen victim to a social engineering attack. So, even if it hasn’t happened to you, you’re at risk.
The rise of generative AI has led to a significant increase in sophisticated social engineering attacks. Hackers are leveraging AI tools to improve their attacks and results. AI use is enabling hackers with limited technical skills to employ advanced strategies like data scraping to deliver highly targeted attacks that mimic the tone, voice, and style of brands.
Business email compromise — a scam typically driven by social engineering — is “one of the most financially damaging online crimes,” according to the FBI, netting more than $55 billion in losses.
How do you prevent social engineering? You need a strong cybersecurity plan.
In this article, we’ll explore what social engineering is, then take a closer look at the six types of common attacks and provide some best practices to protect your organization.
## What Is a Social Engineering Attack?
Social engineers are clever threat actors who use manipulative tactics to deceive their victims into performing a desired action or disclosing private information. The social engineer exploits vulnerability to carry out the rest of their plans.
Many threat actors targeting organizations will use social engineering tactics on the employees to gain a foothold in the internal networks and systems, where the real damage is done.
## Social Engineering Attack Types
Let’s take a look at the six most common types of social engineering attacks.
### 1\. Phishing
Phishing is a social engineering technique in which an attacker sends fraudulent emails, claiming to be from a reputable and trusted source.
For example, a social engineer might send an email that appears to come from a customer success manager at your bank. They might claim to have important information about your account but require you to reply with your full name, birth date, social security number, and account number first so that they can verify your identity. Ultimately, the person emailing is not a bank employee. It's a person trying to steal private data.
Phishing, in general, casts a wide net and tries to target as many individuals as possible. However, there are a few types of phishing that hone in on particular targets.
Spear phishing is a more targeted type of email phishing. In a spear phishing attack, the social engineer will have done their research and set their sights on a particular user. By scouring through the target's public social media profiles and using Google to find information about them, the attacker can create a compelling, targeted attack.
Imagine that an individual regularly posts on social media and is a member of a particular gym. In that case, the attacker could create a spear phishing email that appears to come from their local gym. The victim is more likely to fall for the scam since they recognized their gym as the supposed sender.
#### What Type of Social Engineering Targets Senior Officials?
Whaling is another targeted phishing scam, similar to spear phishing.
However, in whaling, rather than targeting an average user, social engineers focus on targeting higher-value targets like CEOs and CFOs. Whaling gets its name due to the targeting of the so-called "big fish" within a company.
### 2\. Vishing and Smishing
While phishing is used to describe fraudulent email practices, similar manipulative techniques are practiced using other communication methods, such as phone calls and text messages.
Vishing (short for voice phishing) occurs when a fraudster attempts to trick a victim into disclosing sensitive information or giving them access to the victim's computer over the telephone. The caller often threatens or tries to scare the victim into giving them personal information or compensation.
Smishing (short for SMS phishing) is similar to and incorporates the same social engineering techniques as email phishing and vishing, but it is done through SMS/text messaging.
### 3\. Pretexting
Pretexting is a type of social engineering technique where the attacker creates a scenario where the victim feels compelled to comply under false pretenses.
Pretexting is often used against corporations that retain client data, such as banks, credit card companies, utilities, and the transportation industry.
During pretexting, the threat actor will often impersonate a client or a high-level employee of the targeted organization.
### 4\. Baiting
Baiting puts something enticing or curious in front of the victim to lure them into the social engineering trap. A baiting scheme could offer a free music download or gift card in an attempt to trick the user into providing credentials.
For example, a social engineer may hand out free USB drives to users at a conference. The user may believe they are just getting a free storage device, but the attacker could have loaded it with remote access malware which infects the computer when plugged in.
### 5\. Tailgating and Piggybacking
Tailgating is a simplistic social engineering attack used to gain physical access to access to an unauthorized location.
Tailgating is achieved by closely following an authorized user into the area without being noticed by the authorized user. An attacker may tailgate another individual by quickly sticking their foot or another object into the door right before the door is completely shut and locked.
Piggybacking is similar to tailgating; but in a piggybacking scenario, the authorized user is aware and allows the other individual to "piggyback" off their credentials.
An authorized user may feel compelled by kindness to hold a secure door open for a woman holding what appears to be heavy boxes or for a person claiming to be a new employee who has forgotten his access badge.
### 6\. Quid Pro Quo
Quid pro quo (Latin for “something for something”) is a type of social engineering tactic in which the attacker attempts a trade of service for information.
A quid pro quo scenario could involve an attacker calling the main lines of companies pretending to be from the IT department, attempting to reach someone who was having a technical issue.
Once the attacker finds a user who requires technical assistance, they would say something along the lines of, "I can fix that for you. I'll just need your login credentials to continue." This is a simple and unsophisticated way of obtaining a user's credentials.
## How To Mitigate Risks With Penetration Testing
A penetration test performed by cyber security experts can help you see where your company stands against threat actors. Pentesting simulates a cyber attack against your organization to identify vulnerabilities.
Social engineering testing is a form of penetration testing that uses social engineering tactics to test your employees’ readiness without risk or harm to your organization.
This type of pentest can be used to understand what additional cybersecurity awareness training may be required to transform vulnerable employees into proactive security assets.
## How to Prevent Social Engineering Attacks
Social engineering is one of the most effective ways threat actors deceive employees and managers alike into exposing private information.
The landscape has changed dramatically over the past few years. An ever-escalating number of endpoints and remote workers have made cybersecurity more complex than ever. CISOs have a big job protecting it all.
You need to take proactive steps to avoid falling victim.
System monitoring, multi-factor authentication, next-generation firewalls, and real-time threat intelligence have become mandatory. Security awareness training helps your employees understand the risks and identify threats.
However, preparing your organization starts with understanding your current state of cybersecurity.
The Global Ghost Team at Mitnick Security performs full-scale simulated attacks to show you where and how real threat actors can infiltrate, extort, or compromise your organization. We deploy our senior engineering testers with at least 10 years of experience to test your systems.
Think you’re safe? We have a 100% success rate for breaching systems using social engineering among small to multi-million-dollar corporations. We can show you your vulnerabilities and help you shore up your defenses.
You need social engineering testing to keep your organization safe. Contact Mitnick Security today to fortify your cyber defenses with our penetration testing services.
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Social Engineering Beyond Phishing: New Tactics and ... - AuditBoard
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https://auditboard.com/blog/social-engineering-beyond-phishing-new-tactics-and-how-to-combat-them
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phishing social engineering defense
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Yes (reduced from 15619 to 11512 chars)
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# Social Engineering Beyond Phishing: New Tactics and How to Combat Them
Social engineering is a manipulation technique that exploits human psychology to gain unauthorized access to systems, networks, or data, unlike cyberattacks that rely on technical vulnerabilities, social engineering preys on trust, fear, urgency, and other emotional triggers to deceive individuals into compromising security protocols. It remains one of the most effective tools in a cybercriminal’s arsenal, evolving constantly to stay ahead of traditional defenses.
In its simplest form, social engineering takes advantage of the weakest link in any security system: people. No matter how sophisticated an organization’s technical defenses might be, they can be rendered ineffective if employees are manipulated into granting access or divulging sensitive information. Understanding social engineering mechanisms and adopting robust countermeasures is essential for today’s cybersecurity landscape.
### **Emerging Social Engineering Tactics**
While some methods, like smishing and pretexting, have been around for years, their use continues to adapt to changing technologies and societal behaviors. Here, we focus on newer tactics that pose a significant threat to organizations, especially in the context of audit, risk, and compliance challenges.
### **Deepfake Impersonation**
Deepfake technology leverages artificial intelligence to create hyper-realistic audio and video of individuals, making it nearly impossible to discern authenticity without advanced tools. For instance, a deepfake of a company’s CEO may be used to instruct an employee to authorize a fraudulent transaction under the guise of a “confidential” matter. Deepfake technology has progressed rapidly, with cybercriminals deploying it to bypass traditional verification processes. These attacks often exploit trust within organizations, particularly when employees are conditioned to comply with authority figures. In one case, a finance department wired significant funds to an external account following instructions from what appeared to be their CEO on a video call.
**The Key Risk**
Employees in siloed departments, who may not have direct relationships with executive leadership, are especially vulnerable. Additionally, industries with high turnover rates may struggle to establish the rapport necessary for employees to question the authenticity of such interactions.
### **AI-Powered Chatbots**
Cybercriminals are deploying AI-driven chatbots to simulate authentic conversations. These bots can engage with individuals over extended periods, gradually building trust to extract sensitive information or credentials. These bots—trained to mimic conversational patterns—often pose as customer support agents or recruiters. By simulating familiarity and professionalism, they can manipulate targets into sharing passwords, account details, or even personal identifiers. Organizations with decentralized customer support systems are particularly at risk.
**The Key Risk** Customer-facing teams, such as support staff, may unknowingly provide sensitive data to these bots, thinking they are assisting legitimate users. In larger enterprises, this risk multiplies due to the volume of interactions and the potential for oversight.
### **Augmented Reality (AR) Scams**
Emerging AR technologies are being used to create immersive environments that deceive individuals. For example, an attacker might simulate an IT troubleshooting session through AR glasses, convincing employees to disclose login details or plug in compromised hardware. The sophistication of AR scams lies in their ability to blend the virtual with the physical. Attackers can exploit unfamiliarity with AR devices to create convincing scenarios. For example, an attacker might claim to be an external consultant troubleshooting a system failure, leveraging AR visuals to build credibility.
**The Key Risk**
Organizations leveraging AR for training or operations are particularly susceptible, as attackers can exploit unfamiliarity with this technology. Employees in technical roles, such as IT support, are at the forefront of such risks.
### **IoT Exploitation**
As Internet of Things (IoT) devices proliferate, they become attractive targets for social engineers. For example, attackers may impersonate a smart device technician to gain physical or network access. With IoT devices often lacking robust security measures, attackers can exploit weak entry points to infiltrate broader networks. This tactic becomes particularly concerning in industries like healthcare, where IoT devices are used for critical functions.
**The Key Risk**
Facilities management or IT teams tasked with maintaining IoT devices may inadvertently grant access, believing they are working with legitimate vendors. The interconnected nature of IoT networks means a single compromised device can have far-reaching consequences.
### **Defending Against Social Engineering**
Organizations can mitigate the risk of social engineering by implementing robust defenses and fostering a security-first culture. Below are actionable steps tailored for audit, risk, and compliance professionals:
**Conduct specialized training** and go beyond generic awareness programs to include:
- Real-life case studies demonstrating the impact of newer tactics.
- Role-specific training for departments like finance, HR, and IT to address their unique risks.
- Simulation exercises, such as mock deepfake calls or phishing drills.
**Effective training programs** should also incorporate behavioral psychology principles to make employees more aware of their susceptibility to manipulation. For example, highlighting common emotional triggers—such as urgency and fear—can help employees recognize and resist such tactics.
**Adopt multi-layered authentication** to ensure that sensitive processes require more than just passwords. MFA has proven to be a robust countermeasure, significantly reducing the likelihood of successful credential theft. However, organizations must ensure that employees understand its importance and consistently adhere to authentication protocols.
- Use multi-factor authentication (MFA) with biometric or hardware-based tokens.
- Implement voice recognition software to counteract vishing and deepfake audio threats.
- Require physical confirmation for high-value transactions, such as two-party verification.
**Establish verification protocols** to create clear, enforceable policies for verifying identities. Verification protocols are particularly effective when coupled with tools that flag anomalies, such as unusual request patterns or deviations from standard communication channels.
- Require employees to cross-check any urgent or unusual requests with an independent channel.
- Maintain an internal directory with verified contact methods for key personnel.
- Develop escalation procedures for high-risk scenarios.
**Building a cohesive security culture** requires active participation from leadership. When executives prioritize cybersecurity, it sets a tone that permeates the organization, making it harder for attackers to exploit gaps in responsibility.Social engineers often exploit silos where security and compliance are perceived as “not my job.” Overcome this by:
- Encouraging cross-departmental communication and collaboration.
- Embedding security liaisons within non-technical teams to foster local accountability.
- Conducting regular interdepartmental reviews of security practices.
**Leverage advanced technology** and deploy tools designed to detect and mitigate social engineering attempts. Technology can complement human vigilance, providing a safety net that catches threats employees might overlook. However, tools are only as effective as the policies and training that support them.
- AI-driven software that flags anomalies in communication patterns.
- Endpoint detection systems capable of recognizing spoofed devices or links.
- Real-time monitoring tools for social media to identify potential reconnaissance activities.
**Audit social media practices**, as many attacks originate from overshared personal or organizational information. Social media hygiene should be a core component of any security strategy, as attackers often rely on publicly available information to craft convincing pretexts.
- Conduct regular audits of employees’ public-facing profiles.
- Provide guidance on limiting exposure, such as setting profiles to private and avoiding posts about internal projects.
- Monitor organizational social media channels for signs of impersonation.
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[PDF] Preventing Social Engineering | LACOE
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https://www.lacoe.edu/content/dam/lacoeedu/documents/technologyservices/cybersecurity/cybersecurity-awareness-articles/Preventing%20Social%20Engineering.pdf
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phishing social engineering defense
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# PREVENTING SOCIAL ENGINEERING
# Introduction
"At its core, social engineering is not a cyber-attack. Instead, social engineering is all about the psychology of persuasion: It targets the mind like your old school grifter on con man." When it comes to cyber-attacks on organizations or individuals, $98%$ of those attacks rely on social engineering. So, what is social engineering?
When we think about cyber-security, most of us think about defending ourselves against hackers who use technological weaknesses to attack data networks. But there is another way into organizations and networks, and that's taking advantage of human weakness. This is known as social engineering, which involves tricking someone into divulging information or enabling access to data networks.
There are several types of social engineering attacks. So, it's important to understand the definition of social engineering, as well as, how it works. Once the basic modus operandi is understood, it's much easier to spot these attacks.
Social engineering attacks can be particularly difficult to counter because they're expressly designed to play on natural human characteristics, such as curiosity, respect for authority, and the desire to help one's friends.
Put simply, social engineering is the use of deception to manipulate individuals into enabling access or divulging information or data, but armed with knowledge, you can protect yourself.
# Common Types of Social Engineering Attacks
Social engineering attacks are diverse with each subset of attacks having their own subsets of attacks. To better protect yourself, its critical to understand the common tactics that can be used against you.
# Phishing
This is the most well-known type of social engineering attack. There are many subsets of phishing attacks, but they all have one goal in mind: compromise your data. Phishing attacks use email, phone calls, and SMS/text messages to deceive an individual into divulging sensitive information. Common phishing attacks are vishing, smishing, spear phishing, whaling, impersonation, and clone phishing.
# Scareware
Scareware attacks use pop-ups and/or ads to scare people into visiting a malicious website, install malware onto their devices, contact the attacker, or send money to the attacker. Common examples include fake virus popups, fake tech support, malvertising, and law enforcement scams.
# Tailgating & Shoulder-Surfing
Tailgating involves an unauthorized person closely following another authorized person into a secured area. This can also involve waiting for a person to leave their computer unattended, but logged in. This commonly occurs due to kindness and ignorance, respectively.
Shoulder-surfing involves an attacker discretely observing a user accessing or typing sensitive information.
# Honeytrap
A honey trap is an attack where the social engineer assumes the identity of an attractive person. They then lure the target into false relationships to eventually steal money or their sensitive information. This is commonly used in social media such as e-dating services.
# Deep Faking
Advancements in AI have granted attackers access to the most sophisticated type of social engineering attack we’ve seen thus far. AI now allows attackers to mimic voices, swap faces, and even create fake videos. Though this used to be uncommon, these types of technology have become more accessible and usable for the public. Attackers have already successfully used deep faking to extort millions on dollars.
# Baiting
Baiting is a tactic in which an attacker uses a trap or bait to trick an individual into installing malware or divulging sensitive information. The most common baiting tactic is leaving a malicious USB somewhere unattended in the hopes that a person will plug in the USB to see what is inside. These USBs may have software that can automatically run and compromise a device and the network.
# Psychology of Social Engineering
Social engineering at its core is the manipulation of trust. If we were to create an equation that determines our trust, $\\mathsf{A}\\mathbf{+}\\mathsf{B}\\mathbf{+}\\mathsf{C}\\mathbf{+}\\mathsf{D}\\mathbf{+}\\mathsf{E}\\mathbf{+}\\mathsf{F}\\mathbf{+}\\mathsf{G}=$ Trust, social engineers work the variables that dictate trust by plugging in varying values that affect our sense of fear, authority, reciprocity, urgency, consensus, connection, scarcity, and consistency. To prevent these attackers from solving the equation, it is crucial to understand the aspects of human behavior that can be manipulated.
# Authority
Attackers understand people are naturally inclined to trust and follow authority. Whether it's a lawyer, professor, police officer, or significant other, these types of individuals command respect and trust. This trust can be easily manipulated. By impersonating someone of authority, attackers put themselves in a strong position to successfully exploit their target.
# Reciprocity
When someone does something nice for you, there's a tendency to want to repay the kindness. Cybercriminals exploit this instinct by offering something small, like a gift card, to gain your trust. Once you've accepted their "gift," you might feel more obligated to follow through on their request, such handing over some information.
# Urgency
“Fight or flight” responses are meant to protect us, but attackers see the latter as a powerful tool. Often used with authority, attackers will attempt to pressure the target with fear, causing them to act without considering the consequences.
# Consensus
This concept is grounded in the social norm that individuals tend to act based on what they perceive others would or have. Attackers may exploit this by claiming that your coworker has already clicked this link to complete the survey last week or flooding a malicious website with fake testimonials suggesting legitimacy.
# Connection
We’re naturally more receptive to people we like or share a rapport with. Shared interests, compliments, and cooperation strengthen this sense of connection. The more we feel a connection with someone, the more likely we are to lower our defenses. Attackers exploit this feeling by either building a relationship with you or impersonating someone you already trust.
# Scarcity
Scarcity, often combined with urgency, is a widely used marketing trick—when something seems limited, people are more likely to believe it’s valuable or worth acting on. Attackers utilize scarcity by claiming that a product is running out or only available for a short time. This sense of urgency drives targets to quickly click on a malicious link before they "miss out" on the opportunity.
# Consistency
With integrity in mind, people generally strive to be consistent with their actions and commitments. Studies show that once someone makes a small commitment, they are more likely to stick to it. Attackers exploit this by having you agree to something minor, only to follow up with a larger request, hoping your sense of consistency will lead you to comply.
# Preventing Social Engineering
Now that you understand the common types of social engineering attacks and the psychology behind them, you can more easily recognize and prevent them. Here are some tips to identify and stop social engineers in their tracks.
# Patience Is a Virtue
Attackers often rely on psychological tactics to manipulate targets into making decisions without evaluation. It’s important to cultivate a mindset that is patient. This grants you time to evaluate the situation, review the details, and then make a well-informed decision. It is rare that you don’t have the time to consider the situation, despite what others may say. Whether it is an email, phone call, text message, or in-person talk, take a pause and ask yourself questions like below:
Is the language used trying to appeal to an emotion? Is it driving a sense of urgency or are they building a connection? If there is a connection, is there a request that follows soon after?
Should this person be sending me something? Is that the correct sender or caller? Why is this person requesting something and at this time?
Is this link malicious? Is this attachment malicious?
Taking the time to ask yourself questions and thinking through the answer will help you create a strong defense against social engineers.
# Check the Source and Content
Take a moment to think about where the communication is coming from and what is in that communication; do not trust it blindly. A USB stick turns up on your desk and you do not know what it is. An out of the blue phone call says you've inherited $$5$ million. An email from your CEO asking you to buy gift cards at 3 AM. Your CEO video calls you saying you must transfer funds immediately. These sound suspicious and should be treated as such. Consider the following tips for each scenario.
# For Emails and Messages:
Look at the email header, sender name, or phone number for sender information. Review the content for typos, errors, vagueness, psychological manipulation, and incorrect alerts. Hover over hyperlinks, scan the attachments, and preview QR code links. Consider the context of message, such as the time of receipt, sender information, whether you’re expecting this message and/or the links/attachments in the message. To be safe, contact the person the sender claims to be through a confirmed legitimate number such as on an official website.
# For In-Person:
Do not allow others to tailgate you into a secured area. Lock your devices if you need to leave them unattended. Listen for psychological tactics. Do not plug in any unknown devices into your own device. Store and dispose of sensitive properly Before accessing sensitive data, be sure only authorized personnel can view it.
# For Callers:
Check to see if the caller number is correct. However,
remember hackers can spoof the phone number.
Listen to see if the caller is utilizing psychological tactics. Consider the context of the call, such as the time of call, caller information, and if the content of the call makes sense.
Test for AI voice replication by having the caller replicate emotions, watch for delays in responses, and whether they can be interrupted.
Test for AI video replication and face swapping by having the caller move their head around in wide motions, looking for clipping or distortions, and watching for correct lighting. To be safe, hang up and go to the official website and get in contact with an official representative, as they will be able to confirm if the email/message is official or fake.
# Secure Your Devices
It's also important to secure devices so that a social engineering attack, even if successful, is limited in what it can achieve. The basic principles are the same, whether it's a smartphone, a basic home network or a major enterprise system.
Keep your anti-malware and anti-virus software up to date. This can help prevent malware that comes through phishing emails from installing itself. Use a package like Kaspersky's Antivirus to keep your network and data secure. Keep software and firmware regularly updated, particularly security patches. Don't run your phone rooted, or your network or PC in administrator mode. Even if a social engineering attack gets your user password for your “user” account, it won't let them reconfigure your system or install software on it. Don't use the same password for different accounts. If a social engineering attack gets the password for your social media account, you don't want them to be able to unlock all of your other accounts too. Use multi-factor authentication (MFA) so that just having your password isn't enough to access the account. That might involve voice recognition, use of a security device, fingerprinting, or SMS confirmation codes. If you just gave away your password to an account and think you may have been “engineered,” change the password right away. Keep yourself informed about new cybersecurity risks by becoming a regular reader of our Resource Center. You'll then know all about new methods of attack as they emerge, making you much less likely to become a victim
# Think About Your Digital Footprint
You might also want to give some thought to your digital footprint. Over-sharing personal information online, such as through social media, can help attackers. For instance, many banks have “name of your first pet” as a possible security question — did you share that on Facebook? If so, you could be vulnerable! In addition, some social engineering attacks will try to gain credibility by referring to recent events you may have shared on social networks.
We recommend you turn your social media settings to “friends only” and be careful what you share. You don't need to be paranoid, just be careful.
Think about other aspects of your life that you share online. If you have an online resumé, for instance, you should consider redacting your address, phone number and date of birth - all useful information for anyone planning a social engineering attack. While some social engineering attacks don't engage the victim deeply, others are meticulously prepared - give these criminals less information to work with.
Social engineering is very dangerous because it takes perfectly normal situations and manipulates them for malicious ends. However, by being fully aware of how it works, and taking basic precautions, you'll be far less likely to become a victim of social engineering.
# Closing Tips
By following the rules below, you can ensure that you are creating a security-conscious culture at work and home.
Take your time to review the details of an interaction or message before acting. Be suspicious of unsolicited phone calls, visits, or individuals asking about employees or other internal information. Be conscious of psychological manipulation tactics. Do not provide personal information or information about your organization, including its structures or networks unless you have confirmed it is needed and the recipient is legitimate. Do not reveal personal or financial information in an email. If you plan to send this information, make sure it's encrypted. Be conscious of your digital footprint. The information you put out to the world can be used against you. If you must send sensitive information over the Internet, always check a website's security. Ensure the URLs begin with an "https," which indicates a secure site, not an "HTTP." Always use MFA, although some may see it as a nuisance. MFA adds an extra layer of security, ensuring that the person signing in is the one authorized to sign in. If you are unsure whether an email or message is legitimate, look at the markers of illegitimacy such as headers, errors and typos, false hyper-links, etc. When in doubt, look to contact the sender or caller through information listed on official documentation or websites outside of the original call, email, or message. Keep your devices updated and ensure that antimalware software is installed. Shred or dispose of properly any documentation that may contain Personally Identifiable Information (PII) or Personal Health Information (PHI), such as addresses, SSNs, and other personal information that is not public knowledge.
Maintaining a security-conscious culture where security is ingrained in daily practices enhances resilience against malicious tactics and cultivates a proactive mindset to cybersecurity in the workplace and at home.
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Defending Against Social Engineering: What You Need to Know
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https://www.dataprise.com/resources/blog/defending-against-social-engineering/
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phishing social engineering defense
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# Defending Against Social Engineering: What You Need to Know
## The Basics: What’s Social Engineering?
Social engineering isn’t your usual hack job—it’s all about playing on human nature. Instead of breaking into your system, these attackers trick you into opening the door for them. They might pose as someone you trust, create a sense of urgency, or use other psychological tricks to get what they want.
## Common Tricks Social Engineers Use
Let’s break down some of the most common tactics:
- **Phishing**: Those sketchy emails asking for your login info or trying to get you to click a weird link? Classic phishing.
- **Pretexting**: The attacker makes up a convincing story to get you to spill private info.
- **Baiting**: Ever seen a free download that’s too good to be true? That’s baiting, and it usually comes with a side of malware.
- **Quid Pro Quo**: Someone offers you something in return for your info—like a “free” service that actually costs you your security.
- **Tailgating**: Picture someone sneaking in behind you at the office, pretending they belong. That’s tailgating, and it’s an easy way to bypass physical security.
## How They Get Inside Your Head
Social engineers are pros at playing on emotions:
- **Urgency**: “Act now, or else!” They’ll push you to make quick decisions, which is when mistakes happen.
- **Authority**: “This is your boss speaking…” They might pose as someone important to get you to comply without thinking.
- **Social Proof**: “Everyone else is doing it…” They’ll use peer pressure to get you to follow along.
- **Scarcity**: “Last chance!” FOMO is a powerful motivator, and they know how to use it.
- **Familiarity**: “Remember me?” They might drop details they’ve learned about you to seem trustworthy.
## Real-Life Social Engineering Hits
These aren’t just made-up scenarios. Check out some infamous examples:
- **Kevin Mitnick’s Motorola Hack (1994)**: Mitnick pretended to be an employee and tricked Motorola staff into giving him sensitive info.
- **DNC Spear Phishing Attack (2016)**: Personalized emails led to a massive breach, showing that even top officials can be fooled.
- **Bangladesh Bank Heist (2016)**: A simple spear-phishing email opened the door to one of the biggest bank heists ever.
- **Twitter Account Takeovers (2020)**: Hackers targeted Twitter employees via LinkedIn, eventually taking over high-profile accounts.
These examples show just how varied and dangerous social engineering attacks can be—and why you should always be on your toes.
## Spotting the Red Flags
### Email Warning Signs
Emails are a go-to for social engineers. Here’s what to watch out for:
- Unexpected attachments or links
- Requests that seem off or out of the blue
- Messages that push you to act fast
- Offers that seem too good to be true
- Generic greetings like “Dear User”
- Weird sender addresses
- Poor grammar and spelling
Always double-check before clicking on anything. If something feels off, trust your gut and verify the request another way.
### Suspicious Phone Calls
Social engineers don’t just stick to email—they use the phone too. Be wary of:
- Calls that pressure you to act fast
- Requests for sensitive info over the phone
- Calls from numbers you don’t recognize
If a call seems sketchy, hang up and call back using the official number from the company’s website.
### Social Media Red Flags
Social media is another hotspot for scams. Watch out for:
- Connection requests from people you don’t know
- Profiles that seem incomplete or weirdly vague
- Requests for personal or company info
Always check out profiles before accepting connection requests. Genuine profiles usually have a detailed work history and real recommendations.
## Locking Down Your Security
### Multi-Factor Authentication (MFA)
MFA adds an extra layer of security, but it’s not foolproof. Hackers have figured out ways to get around it, like tricking you into logging into a fake site or spamming you with MFA prompts until you accidentally approve one.
To make MFA more effective:
- Teach your team about these tactics
- Add extra security layers where possible
- Keep your authentication systems up-to-date
### Keep Your Team in the Loop
Your team is your first line of defense. Regular training sessions (not just once a year!) can keep everyone sharp:
- Offer short, focused training every few months
- Highlight specific social engineering tricks
- Reinforce key points over time
- Keep security top of mind with newsletters and regular updates
A well-trained team is a skeptical team, and that’s exactly what you want.
### Regular Security Checkups
Regular security audits are key to staying ahead of threats. Unlike a one-time test, these audits look at everything—from system vulnerabilities to user behavior.
Benefits include:
- Spotting and fixing vulnerabilities before they’re exploited
- Strengthening your overall security measures
- Preparing for potential incidents with a solid response plan
- Identifying areas where your team might need more training
When you’re planning an audit:
- Make sure it covers all the bases relevant to your organization
- Involve staff from different departments for a comprehensive view
- Prioritize fixing the most critical issues first
## Wrapping It Up
Social engineering is a serious threat, but with a little awareness and the right approach, you can protect yourself. It’s all about recognizing the signs, staying skeptical, and using smart security practices like MFA, regular training, and thorough audits.
Remember, security isn’t a one-and-done thing—it’s an ongoing process. Keep learning, stay vigilant, and make sure your defenses are always one step ahead of the bad guys. With the right mindset, you can keep both yourself and your organization safe from even the sneakiest social engineering attacks.
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What is an Advanced Persistent Threat (APT)? - CrowdStrike
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https://www.crowdstrike.com/en-us/cybersecurity-101/threat-intelligence/advanced-persistent-threat-apt/
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advanced persistent threats APT
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## What are the 3 Stages of an APT attack?
To prevent, detect and resolve an APT, you must recognize its characteristics. Most APTs follow the same basic life cycle of infiltrating a network, expanding access and achieving the goal of the attack, which is most commonly stealing data by extracting it from the network.
### Stage 1: infiltration
In the first phase, **advanced persistent threats often gain access through social engineering techniques**. One indication of an APT is a phishing email that selectively targets high-level individuals like senior executives or technology leaders, often using information obtained from other team members that have already been compromised. Email attacks that target specific individuals are called “spear-phishing.”
The email may seem to come from a team member and include references to an ongoing project. If several executives report being duped by a spear-phishing attack, start looking for other signs of an APT.
### Stage 2: escalation and lateral movement
Once initial access has been gained, attackers insert malware into an organization's network to move to the second phase, expansion. They **move laterally to map the network and gather credentials** such as account names and passwords in order to access critical business information.
They may also establish a “backdoor” — a scheme that allows them to sneak into the network later to conduct stealth operations. Additional entry points are often established to ensure that the attack can continue if a compromised point is discovered and closed.
### Stage 3: exfiltration
To prepare for the third phase, cybercriminals typically **store stolen information in a secure location** within the network until enough data has been collected. They **then extract, or “exfiltrate” it without detection**. They may use tactics like a denial-of-service (DoS) attack to distract the security team and tie up network personnel while the data is being exfiltrated. The network can remain compromised, waiting for the thieves to return at any time.
#### Learn More
Want to stay up to date on recent adversary activities? Stop by the Research and Threat Intel Blog for the latest research, trends, and insights on emerging cyber threats.
Research and Threat Intel Blog
## Characteristics of an APT attack
Since advanced persistent threats use different techniques from ordinary hackers, they leave behind different signs. In addition to spear-phishing campaigns that target organization leaders, **symptoms of an advanced persistent threat attack include**:
- Unusual activity on user accounts, such as an increase in high-level logins late at night
- Widespread presence of backdoor Trojans
- Unexpected or unusual data bundles, which may indicate that data has been amassed in preparation for exfiltration
- Unexpected information flows, such as anomalies in outbound data or a sudden, uncharacteristic increase in database operations involving massive quantities of data
## Advanced persistent threat examples
**CrowdStrike currently tracks well over 150 adversaries** around the world, including nation-states, eCriminals and hacktivists.
Here are some notable examples of APTs detected by CrowdStrike:
- **GOBLIN PANDA** (APT27) was first observed in September 2013 when CrowdStrike discovered indicators of attack (IOAs) in the network of a technology company that operates in multiple sectors. This China-based adversary uses two Microsoft Word exploit documents with training-related themes to drop malicious files when opened. Read our full APT profile on Goblin Panda.
- **FANCY BEAR** (APT28), a Russia-based attacker, uses phishing messages and spoofed websites that closely resemble legitimate ones in order to gain access to conventional computers and mobile devices. Read our full APT Group Profile on Fancy Bear.
- **Cozy Bear**(APT29) is an adversary of Russian-origin, assessed as likely to be acting on behalf of the Foreign Intelligence Service of the Russian Federation. This adversary has been identified leveraging large-volume spear phishing campaigns to deliver an extensive range of malware types as part of an effort to target political, scientific, and national security entities across a variety of sectors. Read our full APT Group Profile on Cozy Bear.
- **Ocean Buffalo**(APT32) is a Vietnam-based targeted intrusion adversary reportedly active since at least 2012. This adversary is known to employ a wide range of Tactics, Techniques, and Procedures (TTPs), to include the use of both custom and off-the-shelf tools as well as the distribution of malware via Strategic Web Compromise (SWC) operations and spear phishing emails containing malicious attachments.
- **HELIX KITTEN** (APT34) has been active since at least late 2015 and is likely Iran-based. It targets organizations in aerospace, energy, financial, government, hospitality and telecommunications and uses well-researched and structured spear-phishing messages that are highly relevant to targeted personnel. Read the full APT Profile on HELIX KITTEN.
- **Wicked Panda** (APT41) has been one the most prolific and effective China-based adversaries from the mid 2010s into the 2020s. CrowdStrike Intelligence assesses Wicked Panda consists of a superset of groups involving several contractors working in the interests of the Chinese state while still carrying out criminal, for-profit activities, likely with some form of tacit approval from CCP officials. Read the full APT profile on WICKED PANDA.
## 2024 Threat Hunting Report
In the **CrowdStrike 2024 Threat Hunting Report**, CrowdStrike unveils the latest tactics of 245+ modern adversaries and shows how these adversaries continue to evolve and emulate legitimate user behavior. Get insights to help stop breaches here.
Download Now
## How do you protect against APT attacks?
There are many cybersecurity and intelligence solutions available to assist organizations in better protecting against APT attacks. Here are some of the best tactics to employ:
- **Sensor coverage.** Organizations must deploy capabilities that provide their defenders with full visibility across their environment to avoid blind spots that can become a safe haven for cyber threats.
- **Technical intelligence.** Leverage technical intelligence, such as indicators of compromise (IOCs), and consume them into a security information and event manager (SIEM) for data enrichment purposes. This allows for added intelligence when conducting event correlation, potentially highlighting events on the network that may have otherwise gone undetected.
- **Service provider.** Partnering with a best-of-breed cybersecurity firm is a necessity. Should the unthinkable happen, organizations may require assistance responding to a sophisticated cyber threat.
- A **Web application firewall ( WAF)** is a security device designed to protect organizations at the application level by filtering, monitoring and analyzing hypertext transfer protocol (HTTP) and hypertext transfer protocol secure (HTTPS) traffic between the web application and the internet.
- **Threat intelligence.** Threat intelligence assists with threat actor profiling, campaign tracking and malware family tracking. These days, it is more important to understand the context of an attack rather than just knowing an attack itself happened, and this is where threat intelligence plays a vital role.
- **Threat hunting.** Many organizations will find the need for 24/7, managed, human-based threat hunting to accompany their cybersecurity technology already in place.
## CrowdStrike's advanced threat protection: the importance of speed
**The most essential concept in cybersecurity today is speed**. To defend yourself, you must be faster than your adversary. At CrowdStrike, we use breakout time to assess a threat actor’s operational sophistication and estimate the speed with which a response is required.
Breakout time is how long an intruder takes to start moving laterally within a network after gaining access. It’s a critical metric for tracking how fast adversaries can operate and for evaluating a security team’s detection and response times.
Falcon Insight endpoint detection and response (EDR), another essential piece of the Falcon platform, looks for IOAs to stop attacks before data is lost. The CrowdStrike Adversary Intelligence solution aids incident investigations and speeds breach response by seamlessly integrating automated threat intelligence and custom indicators into endpoint protection. Combined with the expertise of the global CrowdStrike Falcon® Intelligence™ team, the Falcon platform allows organizations of any size to respond more quickly and get ahead of the next APT attack.
Kurt Baker is the senior director of product marketing for Falcon Intelligence at CrowdStrike. He has over 25 years of experience in senior leadership positions, specializing in emerging software companies. He has expertise in cyber threat intelligence, security analytics, security management and advanced threat protection. Prior to joining CrowdStrike, Baker worked in technical roles at Tripwire and had co-founded startups in markets ranging from enterprise security solutions to mobile devices. He holds a bachelor of arts degree from the University of Washington and is now based in Boston, Massachusetts.
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Advanced Persistent Threat (APT): Examples and Prevention
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https://www.legitsecurity.com/aspm-knowledge-base/advanced-persistent-threat-examples
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advanced persistent threats APT
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Advanced persistent threats (APTs) use sophisticated tools and techniques to breach systems and maintain access—all while remaining undetected. Unlike other cyberattacks, APTs work over an extended period, using more resources to achieve specific objectives, such as stealing sensitive data or bringing down operations.
As technology advances and dependence on it grows, APTs have become more common. Here’s a guide to the stages involved and what strategies you can employ to mitigate these attacks, along with some APT examples that showcase their prevalence and impact.
## What Is an Advanced Persistent Threat?
An APT in cybersecurity is a sustained attack in which a threat actor infiltrates a network and attempts to remain undetected. Well-funded actors, such as organized cybercriminals or hacktivist groups, often orchestrate these invasions to achieve strategic, long-term goals.
To gain initial access, hackers often exploit attack vectors like unpatched vulnerabilities. Once inside, the main goal of an APT attack is to establish persistence, sometimes by deploying a backdoor to maintain long-term access.
The real danger of APTs lies in their persistence and precision. Unlike traditional cyberattacks, they focus on highly specific organizations or industries, targeting strategic individuals to gain access to high-value systems and data. And once inside, malicious actors move laterally across the network to access more information, carefully evading detection tools. The longer an APT goes unnoticed, the greater the damage—ranging from financial loss to reputational harm and even national security threats.
## Characteristics of Advanced Persistent Threats
APTs differ from typical cyberattacks due to their precision, duration, and sophistication. Here are some other core characteristics of APTs to help you recognize and address them:
### Persistent and Long-Term Engagement
APTs aren’t quick. Attackers embed themselves within the network for weeks, months, or even years. This persistence lets them carefully monitor activity and execute their objectives without detection.
### Goal-Oriented Attacks
APTs have specific, high-value goals, like stealing classified information, intellectual property, or financial records. Unlike less targeted cyberattacks, these campaigns focus on achieving strategic outcomes, often aligning with political or financial motives.
### Well-Funded Operations
APTs require significant financial and technical resources, which means threat actors are rarely acting alone. People behind these attacks often have backing from nation-states, organized cybercriminal groups, or even well-funded organizations. This support enables them to deploy advanced tools and custom malware.
### Stealth and Evasion Tactics
APTs prioritize secrecy. They use sophisticated techniques like encryption, lateral movement, and polymorphic malware to bypass security defenses and evade detection.
### Targeted and Tailored Campaigns
Attackers customize APTs for specific organizations or industries. For this strategy to work, it needs to be highly specific, so threat actors must gather intelligence and tailor their approaches over time.
## APT Attack Stages
Understanding the stages of an APT in security can help you identify and mitigate attacks before they escalate.
### 1\. Reconnaissance
In this phase, attackers gather intelligence on their target. They identify vulnerabilities, study network architecture, and research employees or third-party partners to find entry points. Techniques often include using open-source intelligence (OSINT) and social engineering.
### 2\. Infiltration
Attackers exploit vulnerabilities to gain initial access to the target’s network. This may involve spear-phishing campaigns, malware deployment, or exploiting unpatched systems. Successful infiltration creates the first foothold, but hackers may also install a backdoor during this phase to ensure continued access.
### 3\. Escalation and Lateral Movement
Once inside, attackers use privilege escalation to gain administrative rights, moving laterally across systems to identify high-value assets. During this phase, they leverage tools to avoid detection and maintain persistence.
### 4\. Data Exfiltration
In the final stage, attackers achieve their primary goal—which could be exfiltrating sensitive data, sabotaging critical infrastructure, or deploying ransomware. By this point, the attackers have often embedded themselves deeply enough to execute their plans without detection.
## APT Attack Examples
APTs often come from groups that repeatedly attack different organizations without detection. Here are some examples of APT groups and specific instances to demonstrate their capabilities and widespread impacts.
### Deep Panda
Deep Panda, a Chinese APT group, is known for targeting industries like healthcare, defense, and finance. By leveraging advanced spear-phishing campaigns and exploiting system vulnerabilities, Deep Panda exfiltrates sensitive data, such as intellectual property and personally identifiable information (PII).
### Helix Kitten
Helix Kitten, sometimes referred to as OilRig or APT34, focuses on infiltrating financial services, energy, and government sectors. This APT uses sophisticated phishing techniques and custom malware to gain long-term network access. Its operations often align with Iran’s geopolitical objectives, so experts suspect Iran is behind its attacks.
### APT29
APT29, also known as Cozy Bear, is a Russian cyber-espionage group linked to high-profile attacks on government agencies and political organizations. Its campaigns often use advanced tactics like supply chain compromises and spear-phishing to access sensitive data. Notable incidents include breaches related to the United States Democratic National Committee.
## 4 Strategies for Preventing Advanced Persistent Threats
Preventing APTs requires a multi-layered approach that combines proactive defense and continuous monitoring. Combining technical controls with well-informed users reduces the risk of APT attacks and can improve APT protection within your organization.
Here are a few strategies to explore:
### 1\. Rapid Vulnerability Patching
Regularly patching known vulnerabilities in the software supply chain prevents attackers from exploiting weaknesses to gain entry. Automated patch management tools also help teams make timely updates and reduce the risk of missing critical fixes.
### 2\. Continuous Monitoring and Incident Response Planning
Continuous monitoring tools detect anomalies and potential threats in real time—no hands-on action necessary. It’s a good idea to pair monitoring with a well-documented incident response plan to contain and mitigate attacks so your team doesn’t need to waste time deciding what to do.
### 3\. Network Segmentation
Segment your network into isolated zones to limit an attacker’s lateral movement. If one part of the network is compromised, segmentation reduces access to other vital systems and data.
### 4\. Threat Intelligence Integration
These solutions help you identify indicators of compromise (IOCs) and stay informed about new APT techniques. This bolsters defenses against known attack methods and puts you in the best position possible to respond quickly.
## Protect Your Business From Advanced Persistent Threats With Legit Security
APTs represent a persistent and growing risk to organizations across industries. Their sophistication and ability to remain undetected for long periods demand a combination of proactive prevention and effective mitigation strategies—and Legit Security can play an important role here.
By offering visibility into application development pipelines, plus continuous vulnerability management, Legit Security equips you with the tools to secure your systems against advanced cyberthreats.
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What is an Advanced Persistent Threat (APT)? - Balbix
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https://www.balbix.com/insights/what-is-advanced-persistent-threat-apt/
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advanced persistent threats APT
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# What is an Advanced Persistent Threat (APT)?
An advanced persistent threat (APT) is a prolonged, targeted cyberattack in which an intruder establishes an undetected presence in a network to steal sensitive data over an extended period. Unlike traditional hit-and-run attacks, APTs are characterized by their stealth, patience, and adaptability.
APTs differ from traditional cyberattacks in their complexity, persistence, and the vast resources behind them. Often sponsored by nation-states or well-funded criminal groups, APT attackers employ advanced techniques to gain a foothold in the target network and maintain long-term access.
APT attackers are usually sophisticated, well-funded teams with significant resources. These threat actors—often linked to nation-states or organized crime groups—carefully plan their attacks to infiltrate specific high-value targets such as government agencies, defense contractors, or large enterprises.
### What are the Motives Behind APT Attacks?
Advanced persistent threats, or APTs, are complex cyberattacks with big goals. They often involve strategies that steal important secrets, like trade info or tech innovations, to gain power or market advantages.
APTs also aim to make money by selling stolen data or demanding ransoms, targeting the systems that keep our society running to cause disruption, and planting themselves deep within networks to stay ahead of future attacks. They can gather useful information and prepare for their next move.
While APTs have traditionally targeted government and defense sectors, the range of potential targets has expanded to include any organization with valuable data or resources. No industry is immune to this threat, from financial institutions to healthcare providers to critical infrastructure operators.
## How does an Advanced Persistent Threat occur?
The primary goal of an APT is to achieve ongoing access to the targeted network rather than execute a quick smash-and-grab attack. By maintaining a persistent presence, the attackers can continuously monitor their target, intercept communications, and exfiltrate sensitive data while remaining undetected.
Executing an APT attack requires more time, skill, and resources than a conventional cyberattack. The process typically involves:
- **Reconnaissance**: Attackers conduct thorough research on the target, identifying weak points such as unpatched systems or exploitable human behaviors. This phase often involves gathering data from public sources or probing the network for vulnerabilities.
- **Infiltration**: Attackers gain initial access to the network by using spear-phishing emails or exploiting zero-day vulnerabilities. This step may involve tricking employees or bypassing weak security defenses.
- **Expansion**: Once inside, attackers deploy malware to create backdoors, escalate privileges, and move laterally through the network, gaining deeper access to sensitive systems and data.
- **Obfuscation**: To avoid detection, attackers use anti-forensic techniques and “living off the land” (using legitimate tools and processes) to blend in with normal activity, making it difficult for security teams to notice their presence.
- **Exfiltration**: Attackers gradually collect and transfer valuable data out of the network. This is often done during distraction events like DDoS attacks, which overwhelm defenses and draw attention away from the data theft.
The stealthy nature of APTs makes them particularly challenging to detect and defend against. Attackers continually adapt their tactics to circumvent security measures, often leveraging legitimate credentials and built-in system tools to blend in with regular network activity.
### White Noise Attacks
A white noise attack is a cybersecurity threat where attackers flood a system with large amounts of random, meaningless data, making it harder for security tools to detect real threats.
In an advanced persistent threat (APT), a white noise attack distracts the system by flooding it with irrelevant data and overwhelming security tools and analysts. This “noise” helps hide the attackers’ activities, allowing them to move undetected, steal data, or establish control.
White noise attacks typically occur during the **Obfuscation** or **Exfiltration** stages to mask lateral movement or distract security teams while data is stolen. This tactic helps APTs stay hidden longer, making it harder for organizations to detect and respond to threats.
## What are the Key Characteristics of APTs?
Advanced persistent threats (APTs) are distinguished by their calculated focus and precision. These threats are not random; they meticulously target specific organizations, with attackers dedicating substantial resources to understanding the intricacies of their intended victim’s network and defenses. The depth of reconnaissance allows attackers to pinpoint weak spots, facilitating a more effective breach.
### Diverse Attack Vectors
APTs employ a sophisticated blend of techniques that extend beyond typical cyber methods. Attackers utilize a combination of digital exploits, physical intrusions, and psychological manipulation to penetrate and maintain their presence within a network.
Cyberattack tactics often involve leveraging zero-day exploits and deploying tailored malware. At the same time, social engineering and physical infiltration add additional layers of complexity, making it difficult for traditional security measures to detect and respond effectively.
### Persistence and Adaptability
The hallmark of an APT is its relentless pursuit of long-term objectives. Attackers do not seek immediate gains; instead, they focus on embedding themselves deeply within the target’s infrastructure. This requires an ability to readjust strategies in response to evolving defensive measures. APT actors continuously refine their tactics to circumvent detection, often using legitimate system tools and credentials to remain inconspicuous.
### Establishing Footholds
To sustain their presence, APTs strategically establish multiple covert points of entry within the network. These entry points are carefully crafted to ensure continuity of access, even if one is compromised.
Attackers can seamlessly navigate the network by employing a combination of malware and legitimate credentials, enabling them to explore and exploit additional vulnerabilities as opportunities arise. This approach secures persistent access and facilitates undetected lateral movement within the network infrastructure.
## How Can Organizations Prevent APTs?
To keep advanced cyber threats at bay, companies must build a strong security plan that does more than just the basics. It’s like layering up in winter; you need multiple layers of protection working together to stay warm. This way, every part of your security system works together, making it harder for hackers to find a way in.
### Use Threat Intelligence
It’s important to stay updated on the latest hacker tactics using solutions like assimilating and analyzing information on indicators of compromise (IOCs) and the tactics, techniques, and procedures (TTPs) used by adversaries so organizations can anticipate and mitigate emerging threats.
### Enhanced Monitoring and Rigorous Access Controls
Solutions focused on monitoring network traffic can detect anomalies that suggest attempts at unauthorized data extraction. They help spot anything odd that might mean hackers are trying to sneak in. At the same time, enforcing stringent access controls ensures that users have the minimum access necessary for their functions, helping keep things even safer.
### Active Threat Hunting and Employee Education
By actively probing for signs of APT activity, organizations can expose and address vulnerabilities that might otherwise remain hidden. Furthermore, consistent security awareness training equips employees to identify and counteract social engineering tactics. Educating staff about the latest phishing schemes and other manipulative techniques strengthens the human element of security, decreasing the likelihood of successful breaches.
However, achieving this level of protection requires a comprehensive understanding of your unique risk profile and the implementation of tailored security solutions. That’s where Balbix comes in. Request a demo today to learn more about how our platform can help you defend against APTs and strengthen your overall cybersecurity posture.
## Frequently Asked Questions
What is an example of an APT?
An example of an Advanced Persistent Threat (APT) is the Stuxnet worm, discovered in 2010. It targeted Iran’s nuclear facilities, specifically designed to damage centrifuges used in uranium enrichment.
Stuxnet demonstrated sophisticated techniques, including exploiting multiple zero-day vulnerabilities and being capable of spreading across networks while remaining undetected for a significant period, showcasing the characteristics of an APT. This cyber attack is notable for its complexity and the fact that it targeted industrial control systems.
What is the typical goal of an APT?
The typical goal of an Advanced Persistent Threat (APT) is to stealthily infiltrate a targeted network to monitor activity and steal sensitive information over an extended period. Unlike other cyber threats, APTs focus on maintaining long-term access to the target’s environment without being detected rather than causing immediate damage or disruption. This allows attackers to regularly gather valuable data, compromising security and privacy.
How Do Most Advanced Persistent Threats (APTs) Begin?
Most Advanced Persistent Threats (APTs) typically start with reconnaissance, where attackers carefully gather information about their target’s vulnerabilities. This phase often involves social engineering tactics or the exploitation of public-facing services.
Once a weakness is identified, attackers exploit it to gain initial access, setting the stage for further infiltration and establishing a foothold within the network while remaining undetected for as long as possible.
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Advanced persistent threat - Wikipedia
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https://en.wikipedia.org/wiki/Advanced_persistent_threat
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advanced persistent threats APT
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Set of stealthy and continuous computer hacking processes
An **advanced persistent threat** ( **APT**) is a stealthy threat actor, typically a state "State (polity)") or state-sponsored group, which gains unauthorized access to a computer network and remains undetected for an extended period.[\[1\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-1)[\[2\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-2) In recent times, the term may also refer to non-state-sponsored groups conducting large-scale targeted intrusions for specific goals.[\[3\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:0-3)
Such threat actors' motivations are typically political or economic.[\[4\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-4) Every major business sector has recorded instances of cyberattacks by advanced actors with specific goals, whether to steal, spy, or disrupt. These targeted sectors include government, defense, financial services, legal services, industrial, telecoms, consumer goods and many more.[\[5\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:2-5)[\[6\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-6)[\[7\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-7) Some groups utilize traditional espionage vectors, including social engineering "Social engineering (security)"), human intelligence "Human intelligence (intelligence gathering)") and infiltration to gain access to a physical location to enable network attacks. The purpose of these attacks is to install custom malware.[\[8\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-8)
APT attacks on mobile devices have also become a legitimate concern, since attackers are able to penetrate into cloud and mobile infrastructure to eavesdrop, steal, and tamper with data.[\[9\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-9)
The median "dwell-time", the time an APT attack goes undetected, differs widely between regions. FireEye reported the mean dwell-time for 2018 in the Americas as 71 days, EMEA as 177 days, and APAC as 204 days.[\[5\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:2-5) Such a long dwell-time allows attackers a significant amount of time to go through the attack cycle, propagate, and achieve their objectives.
## Definition
Definitions of precisely what an APT is can vary, but can be summarized by their named requirements below:
- _Advanced_ – Operators behind the threat have a full spectrum of intelligence-gathering techniques at their disposal. These may include commercial and open source computer intrusion technologies and techniques, but may also extend to include the intelligence apparatus of a state. While individual components of the attack may not be considered particularly "advanced" (e.g. malware components generated from commonly available do-it-yourself malware construction kits, or the use of easily procured exploit materials), their operators can typically access and develop more advanced tools as required. They often combine multiple targeting methods, tools, and techniques in order to reach and compromise their target and maintain access to it. Operators may also demonstrate a deliberate focus on operational security that differentiates them from "less advanced" threats.[\[3\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:0-3)[\[10\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:1-10)[\[11\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-11)
- _Persistent_ – Operators have specific objectives, rather than opportunistically seeking information for financial or other gain. This distinction implies that the attackers are guided by external entities. The targeting is conducted through continuous monitoring and interaction in order to achieve the defined objectives. It does not mean a barrage of constant attacks and malware updates. In fact, a "low-and-slow" approach is usually more successful. If the operator loses access to their target they usually will reattempt access, and most often, successfully. One of the operator's goals is to maintain long-term access to the target, in contrast to threats who only need access to execute a specific task.[\[10\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:1-10)[\[12\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-12)
- _Threat_ – APTs are a threat because they have both capability and intent. APT attacks are executed by coordinated human actions, rather than by mindless and automated pieces of code. The operators have a specific objective and are skilled, motivated, organized and well funded. Actors are not limited to state sponsored groups.[\[3\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:0-3)[\[10\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:1-10)
## History and targets
Warnings against targeted, socially-engineered emails dropping trojans "Trojan horse (computing)") to exfiltrate sensitive information were published by UK and US CERT organisations in 2005. This method was used throughout the early 1990s and does not in itself constitute an APT. The term "advanced persistent threat" has been cited as originating from the United States Air Force in 2006[\[13\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-13) with Colonel Greg Rattray cited as the individual who coined the term.[\[14\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-14)
The Stuxnet computer worm, which targeted the computer hardware of Iran's nuclear program, is one example of an APT attack. In this case, the Iranian government might consider the Stuxnet creators to be an advanced persistent threat.\ _[citation needed_\][\[15\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-15)
Within the computer security community, and increasingly within the media, the term is almost always used in reference to a long-term pattern of sophisticated computer network exploitation aimed at governments, companies, and political activists, and by extension, also to ascribe the A, P and T attributes to the groups behind these attacks.[\[16\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-16) Advanced persistent threat (APT) as a term may be shifting focus to computer-based hacking due to the rising number of occurrences. PC World reported an 81 percent increase from 2010 to 2011 of particularly advanced targeted computer attacks.[\[17\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-17)
Actors in many countries have used cyberspace as a means to gather intelligence on individuals and groups of individuals of interest.[\[18\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-18)[\[19\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-19)[\[20\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-20) The United States Cyber Command is tasked with coordinating the US military's offensive and defensive cyber operations.[\[21\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-21)
Numerous sources have alleged that some APT groups are affiliated with, or are agents of, governments of sovereign states.[\[22\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-22)[\[23\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-23)[\[24\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-24)
Businesses holding a large quantity of personally identifiable information are at high risk of being targeted by advanced persistent threats, including:[\[25\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-Dell_SecureWorks-25)
- Agriculture[\[26\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-Cybersecurity:_Current_Writings_on_Threats_and_Protection_2019-26)
- Energy
- Financial institutions
- Health care
- Higher education[\[27\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-27)
- Manufacturing
- Technology
- Telecommunications
- Transportation
A Bell Canada study provided deep research into the anatomy of APTs and uncovered widespread presence in Canadian government and critical infrastructure. Attribution was established to Chinese and Russian actors.[\[28\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-28)
## Life cycle
[](https://en.wikipedia.org/wiki/File:Advanced_persistent_threat_lifecycle.jpg) A diagram depicting the life cycle staged approach of an advanced persistent threat (APT), which repeats itself once complete.
Actors behind advanced persistent threats create a growing and changing risk to organizations' financial assets, intellectual property, and reputation[\[29\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-29) by following a continuous process or kill chain "Kill chain (military)"):
1. Target specific organizations for a singular objective
2. Attempt to gain a foothold in the environment (common tactics include spear phishing emails)
3. Use the compromised systems as access into the target network
4. Deploy additional tools that help fulfill the attack objective
5. Cover tracks to maintain access for future initiatives
In 2013, Mandiant presented results of their research on alleged Chinese attacks using APT method between 2004 and 2013[\[30\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-mandiant-30) that followed similar lifecycle:
- **Initial compromise** – performed by use of social engineering "Social engineering (security)") and spear phishing, over email, using zero-day viruses. Another popular infection method was planting malware on a website that the victim's employees will be likely to visit.[\[31\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-31)
- **Establish foothold** – plant remote administration software in victim's network, create net backdoors and tunnels allowing stealth access to its infrastructure.
- **Escalate privileges** – use exploits "Exploit (computer security)") and password cracking to acquire administrator privileges over victim's computer and possibly expand it to Windows domain administrator accounts.
- **Internal reconnaissance** – collect information on surrounding infrastructure, trust relationships, Windows domain structure.
- **Move laterally** – expand control to other workstations, servers and infrastructure elements and perform data harvesting on them.
- **Maintain presence** – ensure continued control over access channels and credentials acquired in previous steps.
- **Complete mission** – exfiltrate stolen data from victim's network.
In incidents analysed by Mandiant, the average period over which the attackers controlled the victim's network was one year, with longest – almost five years.[\[30\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-mandiant-30) The infiltrations were allegedly performed by Shanghai-based Unit 61398 of People's Liberation Army. Chinese officials have denied any involvement in these attacks.[\[32\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-32)
Previous reports from Secdev had previously discovered and implicated Chinese actors.[\[33\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-TGN_1-33)
## Mitigation strategies
There are tens of millions of malware variations,[\[34\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-GSEC_GIAC_Security_Essentials_Certification_All_2013-34) which makes it extremely challenging to protect organizations from APT. While APT activities are stealthy and hard to detect, the command and control "Command and control (malware)") network traffic associated with APT can be detected at the network layer level with sophisticated methods. Deep log analyses and log correlation from various sources is of limited usefulness in detecting APT activities. It is challenging to separate noises from legitimate traffic. Traditional security technology and methods have been ineffective in detecting or mitigating APTs.[\[35\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-35) Active cyber defense has yielded greater efficacy in detecting and prosecuting APTs (find, fix, finish) when applying cyber threat intelligence to hunt and adversary pursuit activities.[\[36\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-36)[\[37\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-37) Human-Introduced Cyber Vulnerabilities (HICV) are a weak cyber link that are neither well understood nor mitigated, constituting a significant attack vector.[\[38\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-38)
## APT groups
See also: Cyberwarfare and China, Chinese information operations and information warfare, and Chinese intelligence activity abroad
- PLA Unit 61398 (also known as APT1)
- PLA Unit 61486 (also known as APT2)
- Buckeye") (also known as APT3)[\[39\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-Symantec2019-39)
- Red Apollo (also known as APT10)
- Numbered Panda (also known as APT12)
- DeputyDog (also known as APT17)[\[40\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-40)
- Dynamite Panda or Scandium (also known as APT18, a unit of the People's Liberation Army Navy)[\[41\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:32-41)
- Codoso Team") (also known as APT19)
- Wocao (also known as APT20)[\[42\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-fox-it2019-42)[\[43\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-43)
- APT22 (aka Suckfly)[\[44\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-44)
- APT26 (aka Turbine Panda)[\[45\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-45)
- APT 27[\[46\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-46)
- PLA Unit 78020") (also known as APT30 and Naikon"))
- Zirconium[\[47\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-47) (also known as APT31 and Violet Typhoon)[\[48\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-48)[\[49\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-ms-threat-actors-24-49)[\[50\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-50)
- APT40
- Double Dragon "Double Dragon (hacking organization)")[\[51\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-fireeye2019-51) (also known as APT41, Winnti Group, Barium, or Axiom)[\[52\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-52)[\[53\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:52-53)
- Spamouflage (also known as Dragonbridge or Storm 1376)[\[54\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-54)[\[55\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-55)
- Hafnium "Hafnium (group)")[\[56\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-56)[\[57\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-57)
- LightBasin[\[58\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-techtarget-lightbasin-58)[\[59\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-bleeping-computer-lightbasin-59) (Also known as UNC1945)
- Tropic Trooper[\[60\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-60)
- Volt Typhoon[\[61\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-61)
- Flax Typhoon[\[62\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-:6-62)
- Charcoal Typhoon (also known as CHROMIUM)[\[63\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-OpenAI-63)[\[64\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-AIThreatActors-64)
- Salmon Typhoon (also known as SODIUM)[\[63\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-OpenAI-63)[\[64\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-AIThreatActors-64)
- Salt Typhoon (also known as GhostEmperor or FamousSparrow)[\[65\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-65)[\[66\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-66)
- Liminal Panda[\[67\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-67)
- MirrorFace[\[68\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-68)
### Iran
- Charming Kitten (also known as APT35)
- Elfin Team (also known as APT33)
- Helix Kitten (also known as APT34)
- Pioneer Kitten[\[69\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-69)
- Remix Kitten (also known as APT39, ITG07, or Chafer)[\[70\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-70)[\[71\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-71)
### North Korea
- Kimsuky
- Lazarus Group (also known as APT38)
- Ricochet Chollima (also known as APT37)
### Russia
- Berserk Bear
- Cozy Bear (also known as APT29)
- Fancy Bear (also known as APT28)
- FIN7
- Gamaredon[\[72\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-venturebeatFeb2022-72) (also known as Primitive Bear)[\[a\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-75)
- Sandworm "Sandworm (hacker group)") (also known as APT44)
- Venomous Bear "Turla (malware)")[\[75\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-76)
### Turkey
- StrongPity") (also known as APT-C-41") or PROMETHIUM"))[\[76\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-PROMETHIUM-77)
### United States
- Equation Group[\[77\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-KasperskyLab2015-78)
### Uzbekistan
- SandCat, associated with the State Security Service "State Security Service (Uzbekistan)") according to Kaspersky[\[78\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-79)
### Vietnam
- OceanLotus (also known as APT32)[\[79\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-80)[\[80\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-81)
### India
- Appin "Appin (company)")[\[81\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-82)
- TAI also known as Team Anonymous India.\ _[citation needed_\]
## Naming
Multiple organizations may assign different names to the same actor. As separate researchers could each have their own varying assessments of an APT group, companies such as CrowdStrike, Kaspersky, Mandiant, and Microsoft, among others, have their own internal naming schemes.[\[82\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-threat-group-naming-schemes-83) Names between different organizations may refer to overlapping but ultimately different groups, based on various data gathered.
CrowdStrike assigns animals by nation-state or other category, such as "Kitten" for Iran and "Spider" for groups focused on cybercrime.[\[83\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-cs-2023-gtr-84) Other companies have named groups based on this system — Rampant Kitten, for instance, was named by Check Point rather than CrowdStrike.[\[84\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-etda-rk-85)
Dragos bases its names for APT groups on minerals.[\[82\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-threat-group-naming-schemes-83)
Mandiant assigns numbered acronyms in three categories, APT, FIN, and UNC, resulting in APT names like FIN7. Other companies using a similar system include Proofpoint (TA) and IBM (ITG and Hive).[\[82\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-threat-group-naming-schemes-83)
Microsoft used to assign names from the periodic table, often stylized in all-caps (e.g. POTASSIUM); in April 2023, Microsoft changed its naming schema to use weather-based names (e.g. Volt Typhoon).[\[85\]](https://en.wikipedia.org/wiki/Advanced_persistent_threat#cite_note-ms-lambert-23-86)
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Hello 0-Days, My Old Friend: A 2024 Zero-Day Exploitation Analysis
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https://cloud.google.com/blog/topics/threat-intelligence/2024-zero-day-trends
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zero-day vulnerabilities
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Yes (reduced from 39531 to 33318 chars)
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## Executive Summary
Google Threat Intelligence Group (GTIG) tracked 75 zero-day vulnerabilities exploited in the wild in 2024, a decrease from the number we identified in 2023 (98 vulnerabilities), but still an increase from 2022 (63 vulnerabilities). We divided the reviewed vulnerabilities into two main categories: end-user platforms and products (e.g., mobile devices, operating systems, and browsers) and enterprise-focused technologies, such as security software and appliances.
Vendors continue to drive improvements that make some zero-day exploitation harder, demonstrated by both dwindling numbers across multiple categories and reduced observed attacks against previously popular targets. At the same time, commercial surveillance vendors (CSVs) appear to be increasing their operational security practices, potentially leading to decreased attribution and detection.
We see zero-day exploitation targeting a greater number and wider variety of enterprise-specific technologies, although these technologies still remain a smaller proportion of overall exploitation when compared to end-user technologies. While the historic focus on the exploitation of popular end-user technologies and their users continues, the shift toward increased targeting of enterprise-focused products will require a wider and more diverse set of vendors to increase proactive security measures in order to reduce future zero-day exploitation attempts.
For a deeper look at the trends discussed in this report, along with recommendations for defenders, register for our upcoming zero-day webinar.
## Scope
This report describes what Google Threat Intelligence Group (GTIG) knows about zero-day exploitation in 2024. We discuss how targeted vendors and exploited products drive trends that reflect threat actor goals and shifting exploitation approaches, and then closely examine several examples of zero-day exploitation from 2024 that demonstrate how actors use both historic and novel techniques to exploit vulnerabilities in targeted products. The following content leverages original research conducted by GTIG, combined with breach investigation findings and reporting from reliable open sources, though we cannot independently confirm the reports of every source. Research in this space is dynamic and the numbers may adjust due to the ongoing discovery of past incidents through digital forensic investigations. The numbers presented here reflect our best understanding of current data.
GTIG defines a zero-day as a vulnerability that was maliciously exploited in the wild before a patch was made publicly available. GTIG acknowledges that the trends observed and discussed in this report are based on detected and disclosed zero-days. Our analysis represents exploitation tracked by GTIG but may not reflect all zero-day exploitation.
## Key Takeaways
- **Zero-day exploitation continues to grow gradually.** The 75 zero-day vulnerabilities exploited in 2024 follow a pattern that has emerged over the past four years. While individual year counts have fluctuated, the average trendline indicates that the rate of zero-day exploitation continues to grow at a slow but steady pace.
- **Enterprise-focused technology targeting continues to expand.** GTIG continued to observe an increase in adversary exploitation of enterprise-specific technologies throughout 2024. In 2023, 37% of zero-day vulnerabilities targeted enterprise products. This jumped to 44% in 2024, primarily fueled by the increased exploitation of security and networking software and appliances.
- **Attackers are increasing their focus on security and networking products.** Zero-day vulnerabilities in security software and appliances were a high-value target in 2024. We identified 20 security and networking vulnerabilities, which was over 60% of all zero-day exploitation of enterprise technologies. Exploitation of these products, compared to end-user technologies, can more effectively and efficiently lead to extensive system and network compromises, and we anticipate adversaries will continue to increase their focus on these technologies.
- **Vendors are changing the game.** Vendor investments in exploit mitigations are having a clear impact on where threat actors are able to find success. We are seeing notable decreases in zero-day exploitation of some historically popular targets such as browsers and mobile operating systems.
- **Actors conducting cyber espionage still lead attributed zero-day exploitation.** Between government-backed groups and customers of commercial surveillance vendors (CSVs), actors conducting cyber espionage operations accounted for over 50% of the vulnerabilities we could attribute in 2024. People's Republic of China (PRC)-backed groups exploited five zero-days, and customers of CSVs exploited eight, continuing their collective leading role in zero-day exploitation. For the first year ever, we also attributed the exploitation of the same volume of 2024 zero-days (five) to North Korean actors mixing espionage and financially motivated operations as we did to PRC-backed groups.
## Looking at the Numbers
GTIG tracked 75 exploited-in-the-wild zero-day vulnerabilities that were disclosed in 2024. This number appears to be consistent with a consolidating upward trend that we have observed over the last four years. After an initial spike in 2021, yearly counts have fluctuated but not returned to the lower numbers we saw in 2021 and prior.
While there are multiple factors involved in discovery of zero-day exploitation, we note that continued improvement and ubiquity of detection capabilities along with more frequent public disclosures have both resulted in larger numbers of detected zero-day exploitation compared to what was observed prior to 2021.
# Zero-days by year
Higher than any previous year, 44% (33 vulnerabilities) of tracked 2024 zero-days affected enterprise technologies, continuing the growth and trends we observed last year. The remaining 42 zero-day vulnerabilities targeted end-user technologies.
## Enterprise Exploitation Expands in 2024 as Browser and Mobile Exploitation Drops
### End-User Platforms and Products
In 2024, 56% (42) of the tracked zero-days targeted end-user platforms and products, which we define as devices and software that individuals use in their day-to-day life, although we acknowledge that enterprises also often use these. All of the vulnerabilities in this category were used to exploit browsers, mobile devices, and desktop operating systems.
- Zero-day exploitation of browsers and mobile devices fell drastically, decreasing by about a third for browsers and by about half for mobile devices compared to what we observed last year (17 to 11 for browsers, and 17 to 9 for mobile).
- Chrome was the primary focus of browser zero-day exploitation in 2024, likely reflecting the browser's popularity among billions of users.
- Exploit chains made up of multiple zero-day vulnerabilities continue to be almost exclusively (~90%) used to target mobile devices.
- Third-party components continue to be exploited in Android devices, a trend we discussed in last year’s analysis. In 2023, five of the seven zero-days exploited in Android devices were flaws in third-party components. In 2024, three of the seven zero-days exploited in Android were found in third-party components. Third-party components are likely perceived as lucrative targets for exploit development since they can enable attackers to compromise many different makes and models of devices across the Android ecosystem.
- 2024 saw an increase in the total number of zero-day vulnerabilities affecting desktop operating systems (OSs) (22 in 2024 vs. 17 in 2023), indicating that OSs continue to be a strikingly large target. The proportional increase was even greater, with OS vulnerabilities making up just 17% of total zero-day exploitation in 2023, compared to nearly 30% in 2024.
- Microsoft Windows exploitation continued to increase, climbing from 13 zero-days in 2022, to 16 in 2023, to 22 in 2024. As long as Windows remains a popular choice both in homes and professional settings, we expect that it will remain a popular target for both zero-day and n-day (i.e. a vulnerability exploited after its patch has been released) exploitation by threat actors.
# Zero-days in end-user products in 2023 and 2024
### Enterprise Technologies
In 2024, GTIG identified the exploitation of 33 zero-days in enterprise software and appliances. We consider enterprise products to include those mainly utilized by businesses or in a business environment. While the absolute number is slightly lower than what we saw in 2023 (36 vulnerabilities), the proportion of enterprise-focused vulnerabilities has risen from 37% in 2023 to 44% in 2024. Twenty of the 33 enterprise-focused zero-days targeted security and network products, a slight increase from the 18 observed in this category for 2023, but a 9% bump when compared proportionally to total zero-days for the year.
The variety of targeted enterprise products continues to expand across security and networking products, with notable targets in 2024 including Ivanti Cloud Services Appliance, Palo Alto Networks PAN-OS, Cisco Adaptive Security Appliance, and Ivanti Connect Secure VPN. Security and network tools and devices are designed to connect widespread systems and devices with high permissions required to manage the products and their services, making them highly valuable targets for threat actors seeking efficient access into enterprise networks. Endpoint detection and response (EDR) tools are not usually equipped to work on these products, limiting available capabilities to monitor them. Additionally, exploit chains are not generally required to exploit these systems, giving extensive power to individual vulnerabilities that can single-handedly achieve remote code execution or privilege escalation.
Over the last several years, we have also tracked a general increase of enterprise vendors targeted. In 2024, we identified 18 unique enterprise vendors targeted by zero-days. While this number is slightly less than the 22 observed in 2023, it remains higher than all prior years' counts. It is also a stark increase in the proportion of enterprise vendors for the year, given that the 18 unique enterprise vendors were out of 20 total vendors for 2024. 2024's count is still a significant proportional increase compared to the 22 unique enterprise vendors targeted out of a total of 23 in 2023.
# Number of unique enterprise vendors targeted
The proportion of zero-days exploited in enterprise devices in 2024 reinforces a trend that suggests that attackers are intentionally targeting products that can provide expansive access and fewer opportunities for detection.
### Exploitation by Vendor
The vendors affected by multiple 2024 zero-day vulnerabilities generally fell into two categories: big tech (Microsoft, Google, and Apple) and vendors who supply security and network-focused products. As expected, big tech took the top two spots, with Microsoft at 26 and Google at 11. Apple slid to the fourth most frequently exploited vendor this year, with detected exploitation of only five zero-days. Ivanti was third most frequently targeted with seven zero-days, reflecting increased threat actor focus on networking and security products. Ivanti's placement in the top three reflects a new and crucial change, where a security vendor was targeted more frequently than a popular end-user technology-focused vendor. We discuss in a following section how PRC-backed exploitation has focused heavily on security and network technologies, one of the contributing factors to the rise in Ivanti targeting.
We note that exploitation is not necessarily reflective of a vendor's security posture or software development processes, as targeted vendors and products depend on threat actor objectives and capabilities.
### Types of Exploited Vulnerabilities
Threat actors continued to utilize zero-day vulnerabilities primarily for the purposes of gaining remote code execution and elevating privileges. In 2024, these consequences accounted for over half (42) of total tracked zero-day exploitation.
Three vulnerability types were most frequently exploited. Use-after-free vulnerabilities have maintained their prevalence over many years, with eight in 2024, and are found in a variety of targets including hardware, low-level software, operating systems, and browsers. Command injection (also at eight, including OS command injection) and cross-site scripting (XSS) (six) vulnerabilities were also frequently exploited in 2024. Both code injection and command injection vulnerabilities were observed almost entirely targeting networking and security software and appliances, displaying the intent to use these vulnerabilities in order to gain control over larger systems and networks. The XSS vulnerabilities were used to target a variety of products, including mail servers, enterprise software, browsers, and an OS.
All three of these vulnerability types stem from software development errors and require meeting higher programming standards in order to prevent them from occurring. Safe and preventative coding practices, including, but not limited to code reviews, updating legacy codebases, and utilizing up-to-date libraries, can appear to hinder production timelines. However, patches prove the potential for these security exposures to be prevented in the first place with proper intention and effort and ultimately reduce the overall effort to properly maintain a product or codebase.
## Who Is Driving Exploitation
# 2024 attributed zero-day exploitation
Due to the stealthy access zero-day vulnerabilities can provide into victim systems and networks, they continue to be a highly sought after capability for threat actors. GTIG tracked a variety of threat actors exploiting zero-days in a variety of products in 2024, which is consistent with our previous observations that zero-day exploitation has diversified in both platforms targeted and actors exploiting them. We attributed the exploitation of 34 zero-day vulnerabilities in 2024, just under half of the total 75 we identified in 2024. While the proportion of exploitation that we could attribute to a threat actor dipped slightly from our analysis of zero-days in 2023, it is still significantly higher than the ~30% we attributed in 2022. While this reinforces our previous observation that platforms' investment in exploit mitigations are making zero-days harder to exploit, the security community is also slowly improving our ability to identify that activity and attribute it to threat actors.
Consistent with trends observed in previous years, we attributed the highest volume of zero-day exploitation to traditional espionage actors, nearly 53% (18 vulnerabilities) of total attributed exploitation. Of these 18, we attributed the exploitation of 10 zero-days to likely nation-state-sponsored threat groups and eight to CSVs.
### CSVs Continue to Increase Access to Zero-Day Exploitation
While we still expect government-backed actors to continue their historic role as major players in zero-day exploitation, CSVs now contribute a significant volume of zero-day exploitation. Although the total count and proportion of zero-days attributed to CSVs declined from 2023 to 2024, likely in part due to their increased emphasis on operational security practices, the 2024 count is still substantially higher than the count from 2022 and years prior. Their role further demonstrates the expansion of the landscape and the increased access to zero-day exploitation that these vendors now provide other actors.
In 2024, we observed multiple exploitation chains using zero-days developed by forensic vendors that required physical access to a device (CVE-2024-53104, CVE-2024-32896, CVE-2024-29745, CVE-2024-29748). These bugs allow attackers to unlock the targeted mobile device with custom malicious USB devices. For instance, GTIG and Amnesty International's Security Lab discovered and reported on CVE-2024-53104 in exploit chains developed by forensic company Cellebrite and used against the Android phone of a Serbian student and activist by Serbian security services. GTIG worked with Android to patch these vulnerabilities in the February 2025 Android security bulletin.
### PRC-Backed Exploitation Remains Persistent
PRC threat groups remained the most consistent government-backed espionage developer and user of zero-days in 2024. We attributed nearly 30% (five vulnerabilities) of traditional espionage zero-day exploitation to PRC groups, including the exploitation of zero-day vulnerabilities in Ivanti appliances by UNC5221 (CVE-2023-46805 and CVE-2024-21887), which GTIG reported on extensively. During this campaign, UNC5221 chained multiple zero-day vulnerabilities together, highlighting these actors' willingness to expend resources to achieve their apparent objectives. The exploitation of five vulnerabilities that we attributed to PRC groups exclusively focused on security and networking technologies. This continues a trend that we have observed from PRC groups for several years across all their operations, not just in zero-day exploitation.
### North Korean Actors Mix Financially Motivated and Espionage Zero-Day Exploitation
For the first time since we began tracking zero-day exploitation in 2012, in 2024, North Korean state actors tied for the highest total number of attributed zero-days exploited (five vulnerabilities) with PRC-backed groups. North Korean groups are notorious for their overlaps in targeting scope; tactics, techniques, and procedures (TTPs); and tooling that demonstrate how various intrusion sets support the operations of other activity clusters and mix traditional espionage operations with attempts to fund the regime. This focus on zero-day exploitation in 2024 marks a significant increase in these actors' focus on this capability. North Korean threat actors exploited two zero-day vulnerabilities in Chrome as well as three vulnerabilities in Windows products.
- In October 2024, it was publicly reported that APT37 exploited a zero-day vulnerability in Microsoft products. The threat actors reportedly compromised an advertiser to serve malicious advertisements to South Korean users that would trigger zero-click execution of CVE-2024-38178 to deliver malware. Although we have not yet corroborated the group's exploitation of CVE-2024-38178 as reported, we have observed APT37 previously exploit Internet Explorer zero-days to enable malware distribution.
- North Korean threat actors also reportedly exploited a zero-day vulnerability in the Windows AppLocker driver (CVE-2024-21338) in order to gain kernel-level access and turn off security tools. This technique abuses legitimate and trusted but vulnerable already-installed drivers to bypass kernel-level protections and provides threat actors an effective means to bypass and mitigate EDR systems.
### Non-State Exploitation
In 2024, we linked almost 15% (five vulnerabilities) of attributed zero-days to non-state financially motivated groups, including a suspected FIN11 cluster's exploitation of a zero-day vulnerability in multiple Cleo managed file transfer products (CVE-2024-55956) to conduct data theft extortion. This marks the third year of the last four (2021, 2023, and 2024) in which FIN11 or an associated cluster has exploited a zero-day vulnerability in its operations, almost exclusively in file transfer products. Despite the otherwise varied cast of financially motivated threat actors exploiting zero-days, FIN11 has consistently dedicated the resources and demonstrated the expertise to identify, or acquire, and exploit these vulnerabilities from multiple different vendors.
We attributed an additional two zero-days in 2024 to non-state groups with mixed motivations, conducting financially motivated activity in some operations but espionage in others. Two vulnerabilities (CVE-2024-9680 and CVE-2024-49039, detailed in the next section) were exploited as zero-days by CIGAR (also tracked as UNC4895 or publicly reported as RomCom), a group that has conducted financially motivated operations alongside espionage likely on behalf of the Russian government, based partly on observed highly specific targeting focused on Ukrainian and European government and defense organizations.
## A Zero-Day Spotlight on CVE-2024-44308, CVE-2024-44309, and CVE-2024-49039: A look into zero-days discovered by GTIG researchers
### Spotlight \#1: Stealing Cookies with Webkit
On Nov. 12, 2024, GTIG detected a potentially malicious piece of JavaScript code injected on https://online.da.mfa.gov\[.\]ua/wp-content/plugins/contact-form-7/includes/js/index.js?ver=5.4. The JavaScript was loaded directly from the main page of the website of the Diplomatic Academy of Ukraine, online.da.mfa.gov.ua. Upon further analysis, we discovered that the JavaScript code was a WebKit exploit chain specifically targeting MacOS users running on Intel hardware.
The exploit consisted of a WebKit remote code execution (RCE) vulnerability (CVE-2024-44308), leveraging a logical Just-In-Time (JIT) error, succeeded by a data isolation bypass (CVE-2024-44309). The RCE vulnerability employed simple and old JavaScriptCore exploitation techniques that are publicly documented, namely:
- Setting up addrof/fakeobj primitives using the vulnerability
- Leaking StructureID
- Building a fake TypedArray to gain arbitrary read/write
- JIT compiling a function to get a RWX memory mapping where a shellcode can be written and executed
The shellcode traversed a set of pointers and vtables to find and call `WebCookieJar::cookieRequestHeaderFieldValue` with an empty `firstPartyForCookies` parameter, allowing the threat actor to access cookies of any arbitrary website passed as the third parameter to `cookieRequestHeaderFieldValue`.
The end goal of the exploit is to collect users' cookies in order to access login.microsoftonline.com. The cookie values were directly appended in a GET request sent to https://online.da.mfa.gov.ua/gotcookie?.
This is not the first time we have seen threat actors stay within the browser to collect users' credentials. In March 2021, a targeted campaign used a zero-day against WebKit on iOS to turn off Same-Origin-Policy protections in order to collect authentication cookies from several popular websites. In August 2024, a watering hole on various Mongolian websites used Chrome and Safari n-day exploits to exfiltrate users’ credentials.
While it is unclear why this abbreviated approach was taken as opposed to deploying full-chain exploits, we identified several possibilities, including:
- The threat actor was not able to get all the pieces to have a full chain exploit. In this case, the exploit likely targeted only the MacIntel platform because they did not have a Pointer Authentication Code (PAC) bypass to target users using Apple Silicon devices. A PAC bypass is required to make arbitrary calls for their data isolation bypass.
- The price for a full chain exploit was too expensive, especially when the chain is meant to be used at a relatively large scale. This especially includes watering hole attacks, where the chances of being detected are high and subsequently might quickly burn the zero-day vulnerability and exploit.
- Stealing credentials is sufficient for their operations and the information they want to collect.
This trend is also observed beyond the browser environment, wherein third-party mobile applications (e.g., messaging applications) are targeted, and threat actors are stealing the information only accessible within the targeted application.
### Spotlight \#2: CIGAR Local Privilege Escalations
#### CIGAR's Browser Exploit Chain
In early October 2024, GTIG independently discovered a fully weaponized exploit chain for Firefox and Tor browsers employed by CIGAR. CIGAR is a dual financial- and espionage-motivated threat group assessed to be running both types of campaigns in parallel, often simultaneously. In 2023, we observed CIGAR utilizing an exploit chain in Microsoft Office ( CVE-2023-36884) as part of an espionage campaign targeting attendees of the Ukrainian World Congress and NATO Summit; however, in an October 2024 campaign, the usage of the Firefox exploit appears to be more in line with the group's financial motives.
Our analysis, which broadly matched ESET's findings, indicated that the browser RCE used is a use-after-free vulnerability in the Animation timeline. The vulnerability, known as CVE-2024-9680, was an n-day at the time of discovery by GTIG.
Upon further analysis, we identified that the embedded sandbox escape, which was also used as a local privilege escalation to NT/SYSTEM, was exploiting a newfound vulnerability. We reported this vulnerability to Mozilla and Microsoft, and it was later assigned CVE-2024-49039.
##### Double-Down on Privilege Escalation: from Low Integrity to SYSTEM
Firefox uses security sandboxing to introduce an additional security boundary and mitigate the effects of malicious code achieving code execution in content processes. Therefore, to achieve code execution on the host, an additional sandbox escape is required.
The in-the-wild CVE-2024-49039 exploit, which contained the PDB string `C:\etalon\PocLowIL\@Output\PocLowIL.pdb`, could achieve both a sandbox escape and privilege escalation. The exploit abused two distinct issues to escalate privileges from Low Integrity Level (IL) to SYSTEM: the first allowed it to access the WPTaskScheduler RPC Interface (UUID: `{33d84484-3626-47ee-8c6f-e7e98b113be1}`), normally not accessible from a sandbox Firefox content process via the "less-secure endpoint" `ubpmtaskhostchannel` created in ubpm.dll; the second stems from insufficient Access Control List (ACL) checks in WPTaskScheduler.dll RPC server, which allowed an unprivileged user to create and execute scheduled tasks as SYSTEM.
As detailed in " How to secure a Windows RPC Server, and how not to.," there are three ways to secure an RPC server, and all three were utilized in WPTaskScheduler:
**1\. Securing the endpoint:** In `WPTaskScheduler::TsiRegisterRPCInterface,` the third argument to `RpcServerUseProtseq` is a non-NULL security descriptor (SD).
- This SD should prevent the Firefox "Content" process from accessing the WPTaskScheduler RPC endpoint. However, a lesser known "feature" of RPC is that RPC endpoints are multiplexed, meaning that if there is a less secure endpoint in the same process, it is possible to access an interface indirectly from another endpoint (with a more permissive ACL). This is what the exploit does: instead of accessing RPC using the ALPC port that the WPTaskScheduler.dll sets up, it resolves the interface indirectly via `upbmtaskhostchannel`. ubpm.dll uses a NULL security descriptor when initializing the interface, instead relying on the `UbpmpTaskHostChannelInterfaceSecurityCb` callback for ACL checks:
# NULL security descriptor used when creating "ubpmtaskhostchannel" RPC endpoint in ubpm.dll::UbpmEnableTaskHostChannelRpcInterface, exposing a less secure endpoint for WPTaskScheduler interface
**2\. Securing the interface:** In the same `WPTaskScheduler::TsiRegisterRPCInterface ` function, an overly permissive security descriptor was used as an argument to `RpcServerRegisterIf3`. As we can see on the listing below, the CVE-2024-49039 patch addressed this by introducing a more locked-down SD.
# Patched WPTaskScheduler.dll introduces a more restrictive security descriptor when registering an RPC interface
**3\. Ad-hoc Security:** Implemented in `WPTaskScheduler.dll::CallerHasAccess` and called prior to enabling or executing any scheduled task. The function performs checks on whether the calling user is attempting to execute a task created by them or one they should be able to access but does not perform any additional checks to prevent calls originating from an unprivileged user.
CVE-2024-49039 addresses the issue by applying a more restrictive ACL to the interface; however, the issue with the less secure endpoint described in "1. Securing the endpoint" remains, and a restricted token process is still able to access the endpoint.
#### Unidentified Actor Using the Same Exploits
In addition to CIGAR, we discovered another, likely financially motivated, group using the exact same exploits (albeit with a different payload) while CVE-2024-49039 was still a zero-day. This actor utilized a watering hole on a legitimate, compromised cryptocurrency news website redirecting to an attacker-controlled domain hosting the same CVE-2024-9680 and CVE-2024-49039 exploit.
## Outlook and Implications
Defending against zero-day exploitation continues to be a race of strategy and prioritization. Not only are zero-day vulnerabilities becoming easier to procure, but attackers finding use in new types of technology may strain less experienced vendors. While organizations have historically been left to prioritize patching processes based on personal or organizational threats and attack surfaces, broader trends can inform a more specific approach alongside lessons learned from major vendors' mitigation efforts.
We expect zero-day vulnerabilities to maintain their allure to threat actors as opportunities for stealth, persistence, and detection evasion. While we observed trends regarding improved vendor security posture and decreasing numbers around certain historically popular products—particularly mobile and browsers—we anticipate that zero-day exploitation will continue to rise steadily. Given the ubiquity of operating systems and browsers in daily use, big tech vendors are consistently high-interest targets, and we expect this to continue. Phones and browsers will almost certainly remain popular targets, although enterprise software and appliances will likely see a continued rise in zero-day exploitation. Big tech companies have been victims of zero-day exploitation before and will continue to be targeted. This experience, in addition to the resources required to build more secure products and detect vulnerabilities in responsible manners, permits larger companies to approach zero-days as a more manageable problem.
For newly targeted vendors and those with products in the growing prevalence of targeted enterprise products, security practices and procedures should evolve to consider how successful exploitation of these products could bypass typical protection mechanisms. Preventing successful exploitation will rely heavily on these vendors' abilities to enforce proper and safe coding practices. We continue to see the same types of vulnerabilities exploited over time, indicating patterns in what weaknesses attackers seek out and find most beneficial to exploit. Continued existence and exploitation of similar issues makes zero-days easier; threat actors know what to look for and where exploitable weaknesses are most pervasive.
Vendors should account for this shift in threat activity and address gaps in configurations and architectural decisions that could permit exploitation of a single product to cause irreparable damage. This is especially true for highly valuable tools with administrator access and/or widespread reach across systems and networks. Best practices continue to represent a minimum threshold of what security standards an architecture should demonstrate, including zero-trust fundamentals such as least-privilege access and network segmentation. Continuous monitoring should occur where possible in order to restrict and end unauthorized access as swiftly as possible, and vendors will need to account for EDR capabilities for technologies that currently lack them (e.g., many security and networking products). GTIG recommends acute threat surface awareness and respective due diligence in order to defend against today's zero-day threat landscape. Zero-day exploitation will ultimately be dictated by vendors' decisions and ability to counter threat actors' objectives and pursuits.
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What is a Zero Day Attack? - Rapid7
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https://www.rapid7.com/fundamentals/zero-day-attack/
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zero-day vulnerabilities
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Yes (reduced from 10567 to 9127 chars)
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All Fundamentals
# Zero Day Attack
Defending and remediating when there's already no time left.
Explore Platform
## What is a Zero Day Attack?
A zero-day attack is one that is discovered while it is already in progress, meaning a security team has “zero days” to prepare or remediate the vector through which the attacker gained entry.
Indeed, according to the National Institutes of Standards and Technology (NIST), a zero-day attack “exploits a previously unknown hardware, firmware, or software vulnerability.”
### Zero Day Vulnerability
A zero-day vulnerability one that was previously unknown to the security organization and for which there is currently no existing patch or remedy. This means it must be developed quickly from the ground up before a threat actor finds it and exploits it. If the vulnerability has not yet been exploited, a security operations center (SOC) should consider itself extremely lucky.
But if there are signs the vulnerability has been exploited, then it's time to spring into action to try and limit the impact of the attack-in-progress.
### Zero Day Exploits
A zero-day exploit is simply the threat actor moving into attack mode, exploiting the discovered vulnerability before any related security personnel have been made aware. From there, an attacker would hope they have a maximum amount of time to move around freely on the target network so they can steal as much data as possible.
Organizational reputation can be severely damaged if word of a zero-day exploit becomes public.
## How Do Zero Day Attacks Work?
Zero-day attacks work by a threat actor implementing a phased attack approach to the target network. A threat actor, of course, begins by looking for vulnerabilities. After encountering one – and deciding it’s worth their time to attempt exploitation – the attacker will then deploy code to exploit the vulnerability.
From there, the attacker can pinpoint the vulnerable systems and begin infiltration of the network at that identified entry point. If they’ve gone undetected to this point, the attack can be fully deployed onto the target network so the threat actor can seek out valuable data, hold it for ransom, and/or sell it to the highest bidder.
A zero-day attack could be perpetrated by a threat actor group, working as a team to steal highly sensitive information from their victims. Or, it could be one highly sophisticated perpetrator, compromising dozens or hundreds of organizations simultaneously by leveraging custom tooling to exploit vulnerabilities.
According to Rapid7’s _2024 Attack Intelligence Report_, vulnerabilities exploited in targeted zero-day attacks often have higher-profile backstories. This is also bound to occur naturally, as it’s never a good thing for any company’s reputation to find out their network has an active attack in progress – and it might have been happening for quite some time before it was discovered.
Many cybersecurity researchers now track the time between when vulnerabilities become known to the public and when they are reliably reported as exploited. This window of time is known as “time to known exploitation,” and it has narrowed considerably in the past few years largely as a result of zero-day attacks.
## Examples of Zero Day Attacks
Zero-day attack are perhaps the most sensationalized cybersecurity stories in the world because defenders have literally no time to prepare for these malicious actions.
This means they can cause the ultimate frenzy and adrenaline spikes in an environment that was most likely, and very recently, going about business as usual. Let’s take a look at a few prominent examples of zero-day attacks from the recent past.
- **Linkedin**: The career-focused social-networking platform was leveraged to send messages containing malicious links to users of the site. The ultimate goal was to gain access to a user’s iPhone to then exploit the version of iOS installed at the time of the attack.
- **Alibaba**: For nearly eight months, an attacker went undetected in an Alibaba retail environment. They stole customer data in an effort that affected more than one billion users.
- **SugarCRM**: A remote-code execution was deployed via a vulnerability in the company's platform, allowing threat actors to gain access to instances of customer AWS accounts.
- **Ivanti Connect Secure**: The popular VPN provider experienced a zero-day attack as a result of the exploitation of two vulnerabilities that were chained together to gain initial access, deploy webshells, backdoor legitimate files, capture credentials and configuration data, and pivot further into a victim's environment.
- **Sony Pictures**: Let's take a trip to Hollywood: Sony Pictures experienced a zero-day attack that led to the leak/theft of intellectual property, embarrassing company emails, executive salaries, and more.
To put a cap on the sheer effectiveness, proliferation, and popularity of zero-day attacks with threat actors, 53% of new widespread threat vulnerabilities through the beginning of 2024 were exploited before software producers could implement fixes.
## How to Identify Zero Day Attacks
Identifying zero-day attacks requires a fundamental shift or addition to a SOC’s practices. Specifically, this means shifting to or incorporating proactive measures that enable security practitioners and analysts to go beyond the network perimeter.
In this way, they can actively hunt threats against known telemetry that has been identified in the wider security world as suspicious. With technology like enhanced endpoint telemetry, teams can quickly review logs and gain critical visibility into all endpoint activities. Let’s take a look at some other techniques for identifying zero-day attacks.
### Vulnerability Management
Managing vulnerabilities – or simply becoming aware of them – is perhaps the single most important thing SOCs can do when it comes to identifying potential zero-day attacks.
The overall goal, of course, would be to identify a critical vulnerability before it can be exploited. But if that’s not possible in every instance, then teams can leverage a competent vulnerability management (VM) tool to shrink the amount of time between exploitation and discovery.
### Network Traffic Analysis
This helps monitor network activity so that there is an ever-evolving, real-time record of what’s happening on a network. With network traffic analysis (NTA), a SOC not only gains improved visibility into devices across the network, but also has the ability to respond to investigations faster with rich detail and additional network context.
### Indicators of Compromise
Observing and reporting on verified indicators of compromise (IOCs) can help the cybersecurity community as a whole to review these known IOCs so that they can identify them earlier along their own attack surfaces. IOCs are essentially data discovered in forensic analysis that can alert analysts to past/ongoing attacks or breaches.
## Zero Day Attack Prevention
Pivoting over to the prevention of zero-day attacks, there are several technologies and/or methodologies to aid practioners in what really amounts to seeing in the dark. The goal is to make visible what can be incredibly difficult to see and detect – so a team can act and take down fast.
### Digital Forensics and Incident Response
The process of collecting forensic evidence of a past attack can help a SOC to understand if there was a historical attack that could still be ongoing. Digital forensics and incident response (DFIR) systems both collect this forensic data, also known as artifacts, and proactively hunt for potential IOCs.
### External Attack Surface Management
For a security organization to monitor the business’ internet-facing assets, leveraging external attack surface management (EASM) can be very effective. An EASM platform can monitor for exposed credentials, public-cloud misconfigurations, and other vulnerabilities specific to assets that have a greater inherent exposure risk.
### Intrusion Detection and Prevention Systems
A system of this type is sort of a catch-all for the most sudden or imminent threats, of which zero-day attacks are most certainly a type. Essentially, intrusion detection and prevention systems (IDPS) work by passively motoring traffic and subsequently blocking suspicious or malicious behavior almost immediately after it’s flagged.
### Threat Hunting
With this ultimate proactive security posture technique, teams can attempt to defend their network before any real damage can come to its perimeter. Maintaining real-time visibility into threat feeds, threat hunters can become extremely familiar with circulating threats and ready their network in case it comes their way.
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How to Create an Incident Response Plan: 5 Basic Steps - Bitsight
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https://www.bitsight.com/blog/how-create-incident-response-plan-5-steps
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# How to Create an Incident Response Plan: 5 Steps
No matter how robust your cyber defenses are, there is a high likelihood that your organization will experience a cybersecurity incident—either directly or as a result of a supply chain attack.
Implementing a cybersecurity incident response plan can help you effectively address a cyber event, reduce disruptions to your business operations, and ensure compliance with regulations.
## What is an Incident Response Plan?
An incident response plan outlines the actionable steps required to prepare for, respond to, and recover from a cyberattack.
It can be a crucial differentiator in how your organization contains an attack, limits damage, responds to regulatory oversight, and ensures employee and customer trust. Incident response also plays into your wider risk management strategy and informs decision-making about security performance improvements, investments in controls, and other steps needed to improve your overall security posture.
## A Typical Incident Response Plan Template:
1. An overview of **why cybersecurity incident response is important**
2. An **incident response framework**, or how your organization approaches incident response. NIST defines an incident response framework as having four stages:
- Preparation and prevention
- Detection and analysis
- Containment, eradication, and recovery
- Post-incident activity
3. **What happens during each phase** of incident response
4. **Roles and responsibilities**
5. **A communication plan**
6. **KPIs to measure the effectiveness** of your cybersecurity incident response
## 5 Steps to Building an Incident Response Plan
There are several resources that can help you develop your incident response plan. In addition to NIST, there is SANS Incident Management, which emphasizes preparation, identification, containment, eradication, recovery, and lessons learned. CISA also offers a useful cheat sheet of Incident Response Plan (IRP) Basics.
Whatever method you choose, below are five important steps your cybersecurity incident response plan should cover:
### Step 1: Preparation
Preparation is key to an effective response. Start by developing a policy for how you will manage your incident response, what actions must be prioritized, and who will lead incident handling. Keep the plan simple and not too detailed because you'll need to share it with business executives to get their agreement and support.
Next, assemble your incident response team. Because cyberattacks have far reaching business, operational, customer, and regulatory impacts, include stakeholders from various disciplines including IT, management, legal, HR, and communications/public relations. To ensure buy-in, explain why cybersecurity incident response matters, each individual’s role and responsibilities in the event of an incident, and how an effective plan can help everyone prepare to handle any cyber threats or data breaches.
If you have a global team, you may want to create decentralized teams for each region, each reporting to a single incident response leader.
It’s also a best practice to assign a specific person to be in charge of communicating with your management team. This may be a CISO or other business leader. The key is to have someone who can convey updates about incident response in language the C-suite and board will understand.
Revisit your policy and procedures frequently and ensure that your incident response team is regularly trained and prepared to respond.
### Step 2: Detection and analysis
Take steps to put security safeguards in place. This way, you can quickly determine if your organization is vulnerable or has already been attacked, so you can take action to prevent further harm.
For example, attack surface analytics and continuous monitoring can pinpoint vulnerabilities in your network that attackers look to exploit and help prioritize the most critical risks for proactive remediation. To detect and analyze a potential breach, layer in endpoint monitoring, firewalls, intrusion detection, and security incident event management (SIEM) tools.
### Step 3: Containment, eradication, and recovery
During this phase, the incident response team is focused on mitigating the effects of an incident. To understand what systems are affected, look to your security management tools for intelligence and indicators of compromise, then shut down or isolate these devices, address the root cause, and restore systems.
This phase is guided by how critical the data or assets are, how severe the incident is, and business continuity imperatives. Here, you can score incidents (also known as incident classification) based on the impact they may have on your operations, the systems or data at risk, and the ability to recover.
Don’t forget to include a process for documenting the actions you take and any evidence of compromise collected. This will be instrumental in the next step of your incident response plan and future incident response process planning.
### Step 4: Post-incident activity
After any cybersecurity incident, hold a post mortem meeting to discuss what happened and your organization’s response, including what worked, what didn’t, and what can be improved. Position it as an open and blameless forum for sharing lessons learned with senior leaders and stakeholders. Invite input and feedback on how the organization can be better prepared if or when another incident occurs.
The incident response team leader will use this setting to report the following:
- Incident timeline
- Response metrics, such as mean time to discovery (MTTD) and mean time to repair (MTTR)
- Impacts (data, systems, business disruption, customers and employees, etc.)
- Containment and remediation measures
If your organization is subject to regulations that require reporting of cyber incidents, such as the U.S. Security and Exchange Commission’s (SEC) new cybersecurity disclosure requirements, factor this into your post-incident activity. SEC rules require publicly traded companies to disclose any “material” cybersecurity incident within four business days. Read more about what a “material” cybersecurity incident is and best practices for incident disclosure.
### Step 5: Test your incident response process
Don’t wait until an incident occurs to test your incident response plan. Conduct regular drills and simulation exercises. For instance, one month you can have your incident response team simulate their response to a ransomware attack, and in the following month, shift your focus to another security event, such as a supply chain cybersecurity attack.
## Strengthen your cyber resilience with Bitsight
As your attack surface expands—on-premise, to the cloud, and across geographies—achieving cyber resilience is challenging. It requires a comprehensive security program and continual efforts to respond to and mitigate risks.
However, incident response and recovery is also about ensuring that similar incidents don’t happen again.
To do this you must determine the root cause of a breach and remediate the issue. Using actionable data from Bitsight, you can get to the root cause of a vulnerability—such as outdated software or a misconfigured system—and where risk continues to exist. From there you can implement a targeted mitigation strategy that helps you achieve cyber resilience. You can also use Bitsight to measure security performance improvement over time and show executives how cyber resilient your organization is.
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What Is an Incident Response Plan (IRP)? | Fortra's Digital Guardian
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https://www.digitalguardian.com/blog/what-incident-response-plan-irp
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**An Incident Response Plan (IRP) is a strategic document that outlines the procedures to be followed when a cyber threat or security incident occurs. This plan details the steps to detect, respond to, recover from, and prevent future incidents.**
It guides the organization in managing the incident, limiting the damage, reducing recovery time and costs, and ensuring continuity of operations.
## Why Is Having an Incident Response Plan Important?
Having an Incident Response Plan (IRP) is important for several reasons:
- **Minimizes Damage:** An IRP can help minimize the damage caused by a cyberattack or breach by providing precise and quick action steps.
- **Reduces Recovery Time and Cost:** With a clear plan, organizations can reduce the time it takes to recover from an attack, limiting the financial impact.
- **Protects Company Reputation:** A well-managed response to an incident can help maintain customer trust and protect the organization's reputation.
- **Ensures Compliance:** Many industries require businesses to have an IRP in place to ensure compliance with standards and regulations and data security.
- **Improves Incident Management:** An IRP allows for a structured response to incidents, reducing chaos, ensuring clear communication, and enhancing team coordination.
- **Enhances Cybersecurity Posture:** It enables organizations to learn from past incidents, adapt, and improve their security stance.
- **Provides Continuity:** An effective IRP ensures business continuity by providing a planned approach to resume normal business operations after an incident.
- **Prevention of Future Threats:** The post-incident analysis helps an organization to understand the threat vector and take preventive measures to avoid such breaches in the future.
## How Do IRPs Work?
Incident Response Plans (IRPs) provide a structured, systematic approach to handling security incidents or attacks. However, the specific steps and strategies within each phase can vary depending on the nature of the incident, the industry, and the organization's specific IRP.
Here's a breakdown of how IRPs typically operate:
**Preparation:** This first phase includes establishing an incident response team, setting up communication lines, outlining roles, preparing the necessary tools and resources, and training staff. It also requires an understanding of the organization's crucial IT assets that must be protected.
**Identification:** The IRP is activated when a breach is detected or suspected. In this phase, the incident is confirmed, its severity assessed, and the response team notified.
**Containment:** Next, immediate steps are taken to limit the spread of the breach and prevent it from affecting more parts of the system. Containment strategies may involve isolating the affected components, changing passwords, blocking IP addresses, or installing firewalls.
**Eradication:** After containment, the root cause of the breach is identified and removed. This may involve deleting malicious code, patching vulnerabilities, and improving firewalls or security systems.
**Recovery:** This phase involves restoring the systems to their regular operation’s status quo. This may include restoring data from backups, validating the recovery, and continuously monitoring systems for signs of recurrence.
**Post-Incident Review:** Once the incident has been fully handled, it is reviewed, including what caused it and how it was handled. Lessons learned from the review are then incorporated into updates of the IRP to improve future responses and prevent recurrence.
## What Are the IRP Features?
Features of an Incident Response Plan (IRP) may include:
**Comprehensive Procedures**
An IRP is a blueprint designed to successfully counteract cyber threats by outlining the processes that should be followed in the case of a security incident.
**Defined Roles and Responsibilities**
This document outlines the roles and responsibilities of the incident response team members, senior management, and other stakeholders in case of a cyber attack.
**Communication Strategy**
This strategy contains clear and concise communication guidelines to ensure effective collaboration between teams and, if necessary, communication with external stakeholders.
**Incident Identification**
Procedures to identify and validate that a security incident has occurred.
**Containment Strategy**
Guidelines for containing the incident and mitigating further damage to the organization.
**Recovery Measures**
Plans for restoring affected systems or networks to their normal, operational state.
**Post-Incident Analysis**
Processes to analyze the incident, learn from it, and further strengthen security measures.
**Regular Revision**
A plan for regular updates and amendments according to the evolution of cyber threats or changes in the organization's structure or resources.
**Training Requirements**
Regular training sessions for team members ensure everyone understands and executes the plan effectively.
**Compliance Checkpoints**
Establishes clearly defined steps to ensure the organization conforms to necessary legal, regulatory, and industry standards.
## How an Incident Response Plan Helps Improve Security
An Incident Response Plan (IRP) is integral to a company's cybersecurity strategy. It is designed to handle and manage the fallout from a cyber attack or other security incidents. An IRP helps improve security in a multitude of ways:
- **Proactive Approach:** An IRP helps identify potential weaknesses in your cybersecurity infrastructure, enabling you to reinforce these weak points before a cyber incident happens.
- **Rapid Response:** Time is crucial in handling a cybersecurity incident. An IRP sets the stage for a swift, coordinated response that can help mitigate harm and limit the scope of the breach.
- **Clear Communication:** By clarifying roles and setting out procedures, an IRP helps ensure clear lines of communication, thus minimizing confusion and speeding up incident response.
- **Learning and Adapting:** An IRP typically includes a post-analysis phase to assess how every incident was handled. The lessons learned can strengthen the cybersecurity strategy and improve future incident responses.
- **Regulatory Compliance:** Some regulatory bodies require organizations to have an IRP as part of their data compliance mandate. Having a solid IRP helps ensure you meet these legal and regulatory obligations.
- **Enhanced Employee Training:** Regular testing and updating of the IRP help employees understand their roles during an incident, thereby reducing response time.
- **Reputation Management:** A well-executed IRP can reduce recovery time and potentially negatively impact the company's reputation and customer trust.
- **Continuity Planning:** An IRP is a crucial part of business continuity planning. It ensures that your business can maintain critical operations even during a security incident.
- **Protection of Assets:** The timely measures described in an IRP protect the company's critical data and assets and prevent further losses.
## The Key Components of An Effective Incident Response Plan
An effective Incident Response Plan (IRP) generally consists of the following key components:
**Preparation:** This should include identifying and assessing potential threats and vulnerabilities, as well as inventorying crucial assets and their protections. It should also include training incident response team members and other staff.
**Incident Response Team:** A defined team responsible for managing the incident response process. The team should have defined roles and responsibilities.
**Incident Definition:** Clear definition of what constitutes an incident, including variables such as severity and type.
**Incident Detection and Reporting:** Procedures for detecting, analyzing, and reporting incidents promptly, utilizing resources like intrusion detection systems, logs, and reports.
**Incident Classification and Prioritization:** Procedures to classify and prioritize incidents based on parameters like potential damage, attack vectors, targeted systems, and regulatory compliance requirements.
**Incident Response Procedures:** Detailed workflows and procedures to handle various incidents. This often includes steps to contain the incident, eradicating the threat, and system recovery.
**Communication Plans:** Guidelines for internal and external communications during and after an incident, including legal and regulatory notifications if necessary.
**Forensics and Evidence Collection:** This is an outline of procedures for evidence collection and digital forensics, which are crucial for investigating the incident and possible legal proceedings.
**Post-Incident Analysis:** A process for reviewing and analyzing the incident and the response to improve future incident response efforts and prevent recurrences.
**Plan Maintenance** is the ongoing updating of the plan to keep up with changes in the business environment, systems, and potential threats.
## How To Create an Incident Response Plan?
Creating an effective IRP requires thoroughly understanding your organization's processes, vulnerabilities, and data priorities. Here are some steps to guide you in creating your IRP:
1. **Select an Incident Response Team. This team manages the response to security incidents. It** should be cross-functional and may include members from IT, legal, PR, and other relevant departments.
2. **Define Roles and Responsibilities:** Each team member should know exactly what their role entails in the event of a security incident. This ensures everyone knows who is responsible for what, streamlining communications and responses.
3. **Understand and Prioritize Assets:** Identify the data or systems most critical to your operations. Through data risk assessment, understanding what's at risk will help you strategize effectively and focus resources on protecting these assets.
4. **Identify Potential Incidents:** Identify the types of incidents that could occur. This could range from minor incidents like an employee losing a company laptop to major incidents like a sophisticated cyberattack.
5. **Develop Response Procedures:** Outline the actions to be taken for each type of incident. These procedures should cover detection, containment, eradication, recovery, and post-incident review.
6. **Develop a Communications Plan:** Determine how you’ll communicate internally and externally during an incident. Ensure you have protocols in place for communicating with stakeholders, law enforcement, clients, and the public.
7. **Train Your Team:** Conduct regular training sessions and drills to allow your team to practice the IRP. This will ensure that your team becomes more familiar with and efficient in executing the plan.
8. **Plan for Post-Incident Activities:** Lessons learned after an incident should be documented and used to update the IRP. This proactive approach can help prevent similar incidents in the future or improve the response to them.
9. **Review and Update Regularly:** IT environments and cyber threats change rapidly. Therefore, you should review and update your IRP regularly to ensure it remains effective and relevant.
## Create a Dynamic IRP with Digital Guardian To Defend Your Threat Landscape
An IRP is not a one-time procedure but a living document that should be continuously updated based on evolving risks, lessons learned from past incidents, and changes to business processes or technologies.
Digital Guardian can help you implement a well-designed and proper IRP to provide a decisive advantage in the face of a cyberattack.
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NIST Incident Response: 4-Step Process and Critical Best Practices
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https://www.exabeam.com/explainers/incident-response/nist-incident-response-4-step-process-and-critical-best-practices/
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## What Is the NIST Incident Response Framework?
The NIST incident response framework, documented in the Computer Security Incident Handling Guide ( NIST Special Publication 800-61), is intended to assist organizations in planning and executing an effective incident response strategy. The framework outlines practices that help in identifying, managing, and mitigating cybersecurity incidents efficiently to minimize damage and reduce recovery time and costs.
Adopting this framework provides a structured approach to handling security breaches and other disruptions. It breaks down incident response into clear steps, promotes readiness, and ensures a systematic process is in place, reinforcing the security infrastructure of organizations against future incidents.
**About this Explainer:**
This content is part of a series about incident response.
## Why Is NIST Providing Recommendations on Incident Response?
NIST provides recommendations on incident response to aid organizations in establishing resilient security postures that can counteract the rising sophistication of cyber threats. The guidelines serve as an authoritative reference that firms of all sizes can adopt to fortify their defenses and ensure continuity of operations in the face of security incidents.
By leveraging NIST’s expertise, organizations gain access to proven strategies and practices that mitigate risks associated with cybersecurity threats. This guidance is crucial in helping entities prepare for, respond to, and recover from incidents with an emphasis on minimizing impact and learning from events to bolster future responses.
## The 4 Steps of NIST Incident Response Framework
Image credit: NIST
### Step 1: Incident Preparation and Prevention
Preparation is the first step in the NIST incident response framework. Organizations must develop and implement robust policies and procedures to prevent incidents before they occur. This involves training employees, establishing security best practices, and setting up defensive mechanisms to ward off potential threats.
Preventive measures also include regular updates and patches to systems, thorough security assessments, and proactive network monitoring. These efforts collectively create a fortified environment that discourages potential attackers and reduces the likelihood of successful breaches.
### Step 2: Detection and Analysis
Efficient detection and analysis are paramount in the NIST framework. Organizations must have mechanisms in place to detect incidents rapidly and analyze them to understand their nature and scope. This step involves the use of advanced monitoring tools, intrusion detection systems, and skilled cybersecurity personnel to identify anomalies that could signify a security incident.
The accurate analysis of the incident is crucial for determining the appropriate response strategy. It involves assessing the impact, understanding the entry point, and identifying the perpetrators, which are vital components for tailoring the response efforts effectively.
### Step 3: Containment, Eradication, and Recovery
Once an incident is confirmed, containment strategies must be immediately implemented to limit its spread. This temporary fix allows organizations more time to devise a permanent solution without the risk of further damage. Subsequent to containment, eradication efforts involve removing threats from the environment, like deleting malicious files and closing unauthorized access points.
The recovery step focuses on restoring systems and operations to normal by repairing or replacing affected resources. This phase also involves verifying that the systems are functional and secure post-event, ensuring that no threats remain in the environment to prevent recurrence.
### Step 4: Post-Incident Activity
The post-incident phase revolves around learning and evolving from the security events. This includes a thorough debriefing to discuss what happened, how it was handled, and ways to prevent similar incidents in the future. Documentation is critical during this phase to record details of the incident, response actions, and recovery process.
Organizations should also review and update their incident response plan regularly based on lessons learned and evolving threats. Continuous improvement in this step ensures preparedness for future incidents and strengthens organizational resilience against cyber threats.
## Best Practices for Building Your NIST Incident Response Plan
### Use an Incident Response Plan Template
Starting with a template ensures that an incident response plan covers all necessary aspects as laid out in the NIST framework. Templates provide a clear structure to follow, making sure no essential element is overlooked. They also allow organizations to tailor the procedures according to specific needs without starting from scratch.
Adopting a standard template helps maintain consistency in the response process, which can be crucial for team coordination during a crisis. Templates can be adjusted over time as the organization’s needs and technologies evolve, continually optimizing the incident response strategy.
### Use a Centralized Approach
A centralized approach to incident management aids in maintaining a coherent response strategy across all parts of an organization. This method ensures that all team members are on the same page and that incidents are managed uniformly. Centralization facilitates quicker decision-making and more effective coordination of resources, which is vital during a crisis.
By centralizing incident response, organizations can also better track and analyze trends over time, leading to more insightful and actionable data. This helps in refining the incident response plan and enhances the overall security posture of the organization.
### Utilize Security Experts
Incorporating security experts into the incident response team is critical. Their expertise ensures that the organization’s response strategy is comprehensive and up to date with the latest security practices and threat intelligence. Experts can provide in-depth insights during the creation of the incident response plan and lead effective execution during an incident.
Security professionals can also offer training and support to other team members, elevating the overall skill level of the organization in handling and mitigating incidents. Their continual learning and adaptation to new threats play an essential role in keeping the organization ahead in its security efforts.
### Put Incident Response Technology in Place
Investing in the right technology is crucial for an effective incident response. Tools such as automated security information and event management (SIEM) systems, advanced endpoint detection and response (EDR) solutions, and other forensic tools help in quickly identifying and mitigating incidents. These technologies provide real-time analysis and alerts, facilitating immediate response.
Integration of incident response technologies ensures that the organization can not only respond to current incidents but also proactively anticipate and mitigate potential future threats. Continuous updates and upgrades in technology alignment with incident response strategies ensure robust defense mechanisms are always in place.
### Build Your Own Process for Communication and Post-Event Review
Effective communication is a cornerstone of successful incident response. Organizations should establish predefined communication protocols that outline who to contact, how to communicate during an incident, and the information dissemination hierarchy. This includes designating primary and secondary communication channels to ensure redundancy, such as emails, instant messaging, and secure phone lines. Clear communication ensures that all team members are informed about the incident’s status and can coordinate their efforts efficiently.
After an incident, it’s crucial to conduct a performance review to evaluate how well the incident was handled and to identify areas for improvement. This review should include all stakeholders involved in the incident response to provide a comprehensive perspective. The process should focus on analyzing the effectiveness of the response steps taken, the decision-making process, and the overall time taken to resolve the incident.
## Exabeam Platform Capabilities: SIEM, UEBA, SOAR, Insider Threats, Compliance, TDIR
The Exabeam Security Operations Platform applies AI and automation to security operations workflows for a holistic approach to combating cyberthreats, delivering the most effective threat detection, investigation, and response (TDIR):
- AI-driven detections pinpoint high-risk threats by learning normal behavior of users and entities, and prioritizing threats with context-aware risk scoring.
- Automated investigations simplify security operations, correlating disparate data to create threat timelines.
- Playbooks document workflows and standardize activity to speed investigation and response.
- Visualizations map coverage against the most strategic outcomes and frameworks to close data and detection gaps.
With these capabilities, Exabeam empowers security operations teams to achieve faster, more accurate, and consistent TDIR.
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[PDF] Computer Security Incident Handling Guide
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Computer security incident response has become an important component of information technology (IT) programs. Cybersecurity-related attacks have become not only more numerous and diverse but also more damaging and disruptive. New types of security-related incidents emerge frequently. Preventive activities based on the results of risk assessments can lower the number of incidents, but not all incidents can be prevented. An incident response capability is therefore necessary for rapidly detecting incidents, minimizing loss and destruction, mitigating the weaknesses that were exploited, and restoring IT services. To that end, this publication provides guidelines for incident handling, particularly for analyzing incidentrelated data and determining the appropriate response to each incident. The guidelines can be followed independently of particular hardware platforms, operating systems, protocols, or applications.
Because performing incident response effectively is a complex undertaking, establishing a successful incident response capability requires substantial planning and resources. Continually monitoring for attacks is essential. Establishing clear procedures for prioritizing the handling of incidents is critical, as is implementing effective methods of collecting, analyzing, and reporting data. It is also vital to build relationships and establish suitable means of communication with other internal groups (e.g., human resources, legal) and with external groups (e.g., other incident response teams, law enforcement).
This publication assists organizations in establishing computer security incident response capabilities and handling incidents efficiently and effectively. This revision of the publication, Revision 2, updates material throughout the publication to reflect the changes in attacks and incidents. Understanding threats and identifying modern attacks in their early stages is key to preventing subsequent compromises, and proactively sharing information among organizations regarding the signs of these attacks is an increasingly effective way to identify them.
Implementing the following requirements and recommendations should facilitate efficient and effective incident response for Federal departments and agencies.
Organizations must create, provision, and operate a formal incident response capability. Federal law requires Federal agencies to report incidents to the United States Computer Emergency Readiness Team (US-CERT) office within the Department of Homeland Security (DHS).
The Federal Information Security Management Act (FISMA) requires Federal agencies to establish incident response capabilities. Each Federal civilian agency must designate a primary and secondary point of contact (POC) with US-CERT and report all incidents consistent with the agency’s incident response policy. Each agency is responsible for determining how to fulfill these requirements.
Establishing an incident response capability should include the following actions:
Creating an incident response policy and plan
Developing procedures for performing incident handling and reporting
Setting guidelines for communicating with outside parties regarding incidents
Selecting a team structure and staffing model
Establishing relationships and lines of communication between the incident response team and other groups, both internal (e.g., legal department) and external (e.g., law enforcement agencies)
Determining what services the incident response team should provide
Staffing and training the incident response team.
# Organizations should reduce the frequency of incidents by effectively securing networks, systems, and applications.
Preventing problems is often less costly and more effective than reacting to them after they occur. Thus, incident prevention is an important complement to an incident response capability. If security controls are insufficient, high volumes of incidents may occur. This could overwhelm the resources and capacity for response, which would result in delayed or incomplete recovery and possibly more extensive damage and longer periods of service and data unavailability. Incident handling can be performed more effectively if organizations complement their incident response capability with adequate resources to actively maintain the security of networks, systems, and applications. This includes training IT staff on complying with the organization’s security standards and making users aware of policies and procedures regarding appropriate use of networks, systems, and applications.
# Organizations should document their guidelines for interactions with other organizations regarding incidents.
During incident handling, the organization will need to communicate with outside parties, such as other incident response teams, law enforcement, the media, vendors, and victim organizations. Because these communications often need to occur quickly, organizations should predetermine communication guidelines so that only the appropriate information is shared with the right parties.
# Organizations should be generally prepared to handle any incident but should focus on being prepared to handle incidents that use common attack vectors.
Incidents can occur in countless ways, so it is infeasible to develop step-by-step instructions for handling every incident. This publication defines several types of incidents, based on common attack vectors; these categories are not intended to provide definitive classification for incidents, but rather to be used as a basis for defining more specific handling procedures. Different types of incidents merit different response strategies. The attack vectors are:
External/Removable Media: An attack executed from removable media (e.g., flash drive, CD) or peripheral device.
Attrition: An attack that employs brute force methods to compromise, degrade, or destroy systems, networks, or services.
Web: An attack executed from a website or web-based application. Email: An attack executed via an email message or attachment.
Improper Usage: Any incident resulting from violation of an organization’s acceptable usage policies by an authorized user, excluding the above categories.
Loss or Theft of Equipment: The loss or theft of a computing device or media used by the organization, such as a laptop or smartphone.
Other: An attack that does not fit into any of the other categories.
# Organizations should emphasize the importance of incident detection and analysis throughout the organization.
In an organization, millions of possible signs of incidents may occur each day, recorded mainly by logging and computer security software. Automation is needed to perform an initial analysis of the data and select events of interest for human review. Event correlation software can be of great value in automating the analysis process. However, the effectiveness of the process depends on the quality of the data that goes into it. Organizations should establish logging standards and procedures to ensure that adequate information is collected by logs and security software and that the data is reviewed regularly.
# Organizations should create written guidelines for prioritizing incidents.
Prioritizing the handling of individual incidents is a critical decision point in the incident response process. Effective information sharing can help an organization identify situations that are of greater severity and demand immediate attention. Incidents should be prioritized based on the relevant factors, such as the functional impact of the incident (e.g., current and likely future negative impact to business functions), the information impact of the incident (e.g., effect on the confidentiality, integrity, and availability of the organization’s information), and the recoverability from the incident (e.g., the time and types of resources that must be spent on recovering from the incident).
# Organizations should use the lessons learned process to gain value from incidents.
After a major incident has been handled, the organization should hold a lessons learned meeting to review the effectiveness of the incident handling process and identify necessary improvements to existing security controls and practices. Lessons learned meetings can also be held periodically for lesser incidents as time and resources permit. The information accumulated from all lessons learned meetings should be used to identify and correct systemic weaknesses and deficiencies in policies and procedures. Follow-up reports generated for each resolved incident can be important not only for evidentiary purposes but also for reference in handling future incidents and in training new team members.
# 1.1 Authority
The National Institute of Standards and Technology (NIST) developed this document in furtherance of its statutory responsibilities under the Federal Information Security Management Act (FISMA) of 2002, Public Law 107-347.
NIST is responsible for developing standards and guidelines, including minimum requirements, for providing adequate information security for all agency operations and assets, but such standards and guidelines shall not apply to national security systems. This guideline is consistent with the requirements of the Office of Management and Budget (OMB) Circular A-130, Section 8b(3), “Securing Agency Information Systems,” as analyzed in A-130, Appendix IV: Analysis of Key Sections. Supplemental information is provided in A-130, Appendix III.
This guideline has been prepared for use by Federal agencies. It may be used by nongovernmental organizations on a voluntary basis and is not subject to copyright, though attribution is desired.
Nothing in this document should be taken to contradict standards and guidelines made mandatory and binding on Federal agencies by the Secretary of Commerce under statutory authority, nor should these guidelines be interpreted as altering or superseding the existing authorities of the Secretary of Commerce, Director of the OMB, or any other Federal official.
# 1.2 Purpose and Scope
This publication seeks to assist organizations in mitigating the risks from computer security incidents by providing practical guidelines on responding to incidents effectively and efficiently. It includes guidelines on establishing an effective incident response program, but the primary focus of the document is detecting, analyzing, prioritizing, and handling incidents. Organizations are encouraged to tailor the recommended guidelines and solutions to meet their specific security and mission requirements.
# 1.3 Audience
This document has been created for computer security incident response teams (CSIRTs), system and network administrators, security staff, technical support staff, chief information security officers (CISOs), chief information officers (CIOs), computer security program managers, and others who are responsible for preparing for, or responding to, security incidents.
# 1.4 Document Structure
The remainder of this document is organized into the following sections and appendices:
Section 2 discusses the need for incident response, outlines possible incident response team structures, and highlights other groups within an organization that may participate in incident handling.
Section 3 reviews the basic incident handling steps and provides advice for performing incident handling more effectively, particularly incident detection and analysis.
Section 4 examines the need for incident response coordination and information sharing. Appendix A contains incident response scenarios and questions for use in incident response tabletop discussions.
Appendix B provides lists of suggested data fields to collect for each incident.
Appendices C and D contain a glossary and acronym list, respectively.
Appendix E identifies resources that may be useful in planning and performing incident response.
Appendix F covers frequently asked questions about incident response.
Appendix G lists the major steps to follow when handling a computer security incident-related crisis. Appendix H contains a change log listing significant changes since the previous revision.
# 2\. Organizing a Computer Security Incident Response Capability
Organizing an effective computer security incident response capability (CSIRC) involves several major decisions and actions. One of the first considerations should be to create an organization-specific definition of the term “incident” so that the scope of the term is clear. The organization should decide what services the incident response team should provide, consider which team structures and models can provide those services, and select and implement one or more incident response teams. Incident response plan, policy, and procedure creation is an important part of establishing a team, so that incident response is performed effectively, efficiently, and consistently, and so that the team is empowered to do what needs to be done. The plan, policies, and procedures should reflect the team’s interactions with other teams within the organization as well as with outside parties, such as law enforcement, the media, and other incident response organizations. This section provides not only guidelines that should be helpful to organizations that are establishing incident response capabilities, but also advice on maintaining and enhancing existing capabilities.
# 2.1 Events and Incidents
An event is any observable occurrence in a system or network. Events include a user connecting to a file share, a server receiving a request for a web page, a user sending email, and a firewall blocking a connection attempt. Adverse events are events with a negative consequence, such as system crashes, packet floods, unauthorized use of system privileges, unauthorized access to sensitive data, and execution of malware that destroys data. This guide addresses only adverse events that are computer securityrelated, not those caused by natural disasters, power failures, etc.
A computer security incident is a violation or imminent threat of violation1 of computer security policies, acceptable use policies, or standard security practices. Examples of incidents are:
An attacker commands a botnet to send high volumes of connection requests to a web server, causing it to crash.
Users are tricked into opening a “quarterly report” sent via email that is actually malware; running the tool has infected their computers and established connections with an external host.
An attacker obtains sensitive data and threatens that the details will be released publicly if the organization does not pay a designated sum of money.
A user provides or exposes sensitive information to others through peer-to-peer file sharing services.
# 2.2 Need for Incident Response
Attacks frequently compromise personal and business data, and it is critical to respond quickly and effectively when security breaches occur. The concept of computer security incident response has become widely accepted and implemented. One of the benefits of having an incident response capability is that it supports responding to incidents systematically (i.e., following a consistent incident handling methodology) so that the appropriate actions are taken. Incident response helps personnel to minimize loss or theft of information and disruption of services caused by incidents. Another benefit of incident response is the ability to use information gained during incident handling to better prepare for handling future incidents and to provide stronger protection for systems and data. An incident response capability also helps with dealing properly with legal issues that may arise during incidents.
Besides the business reasons to establish an incident response capability, Federal departments and agencies must comply with law, regulations, and policy directing a coordinated, effective defense against information security threats. Chief among these are the following:
OMB’s Circular No. A-130, Appendix III,3 released in 2000, which directs Federal agencies to “ensure that there is a capability to provide help to users when a security incident occurs in the system and to share information concerning common vulnerabilities and threats. This capability shall share information with other organizations … and should assist the agency in pursuing appropriate legal action, consistent with Department of Justice guidance.”
FISMA (from 2002),4 which requires agencies to have “procedures for detecting, reporting, and responding to security incidents” and establishes a centralized Federal information security incident center, in part to:
“Provide timely technical assistance to operators of agency information systems … including
guidance on detecting and handling information security incidents …
Compile and analyze information about incidents that threaten information security …
Inform operators of agency information systems about current and potential information security
threats, and vulnerabilities … .”
Federal Information Processing Standards (FIPS) 200, Minimum Security Requirements for Federal Information and Information Systems , March 2006, which specifies minimum security requirements for Federal information and information systems, including incident response. The specific requirements are defined in NIST Special Publication (SP) 800-53, Recommended Security Controls for Federal Information Systems and Organizations.
OMB Memorandum M-07-16, Safeguarding Against and Responding to the Breach of Personally Identifiable Information , May 2007, which provides guidance on reporting security incidents that involve PII.
# 2.3 Incident Response Policy, Plan, and Procedure Creation
This section discusses policies, plans, and procedures related to incident response, with an emphasis on interactions with outside parties.
# 2.3.1 Policy Elements
Policy governing incident response is highly individualized to the organization. However, most policies include the same key elements:
Statement of management commitment Purpose and objectives of the policy
Scope of the policy (to whom and what it applies and under what circumstances)
Definition of computer security incidents and related terms
Organizational structure and definition of roles, responsibilities, and levels of authority; should include the authority of the incident response team to confiscate or disconnect equipment and to monitor suspicious activity, the requirements for reporting certain types of incidents, the requirements and guidelines for external communications and information sharing (e.g., what can be shared with whom, when, and over what channels), and the handoff and escalation points in the incident management process
Prioritization or severity ratings of incidents
Performance measures (as discussed in Section 3.4.2)
Reporting and contact forms.
# 2.3.2 Plan Elements
Organizations should have a formal, focused, and coordinated approach to responding to incidents, including an incident response plan that provides the roadmap for implementing the incident response capability. Each organization needs a plan that meets its unique requirements, which relates to the organization’s mission, size, structure, and functions. The plan should lay out the necessary resources and management support. The incident response plan should include the following elements:
Mission
Strategies and goals
Senior management approval
Organizational approach to incident response
How the incident response team will communicate with the rest of the organization and with other organizations
Metrics for measuring the incident response capability and its effectiveness
Roadmap for maturing the incident response capability
How the program fits into the overall organization.
The organization’s mission, strategies, and goals for incident response should help in determining the structure of its incident response capability. The incident response program structure should also be discussed within the plan. Section 2.4.1 discusses the types of structures.
Once an organization develops a plan and gains management approval, the organization should implement the plan and review it at least annually to ensure the organization is following the roadmap for maturing the capability and fulfilling their goals for incident response.
# 2.3.3 Procedure Elements
Procedures should be based on the incident response policy and plan. Standard operating procedures (SOPs) are a delineation of the specific technical processes, techniques, checklists, and forms used by the incident response team. SOPs should be reasonably comprehensive and detailed to ensure that the
priorities of the organization are reflected in response operations. In addition, following standardized responses should minimize errors, particularly those that might be caused by stressful incident handling situations. SOPs should be tested to validate their accuracy and usefulness, then distributed to all team members. Training should be provided for SOP users; the SOP documents can be used as an instructional tool. Suggested SOP elements are presented throughout Section 3.
# 2.3.4 Sharing Information With Outside Parties
Organizations often need to communicate with outside parties regarding an incident, and they should do so whenever appropriate, such as contacting law enforcement, fielding media inquiries, and seeking external expertise. Another example is discussing incidents with other involved parties, such as Internet service providers (ISPs), the vendor of vulnerable software, or other incident response teams. Organizations may also proactively share relevant incident indicator information with peers to improve detection and analysis of incidents. The incident response team should discuss information sharing with the organization’s public affairs office, legal department, and management before an incident occurs to establish policies and procedures regarding information sharing. Otherwise, sensitive information regarding incidents may be provided to unauthorized parties, potentially leading to additional disruption and financial loss. The team should document all contacts and communications with outside parties for liability and evidentiary purposes.
The following sections provide guidelines on communicating with several types of outside parties, as depicted in The double-headed arrows indicate that either party may initiate communications. See Section 4 for additional information on communicating with outside parties, and see Section 2.4 for a discussion of communications involving incident response outsourcers.
Communications with Outside Parties
# 2.3.4.1 The Media
The incident handling team should establish media communications procedures that comply with the organization’s policies on media interaction and information disclosure. For discussing incidents with the media, organizations often find it beneficial to designate a single point of contact (POC) and at least one backup contact. The following actions are recommended for preparing these designated contacts and should also be considered for preparing others who may be communicating with the media:
Conduct training sessions on interacting with the media regarding incidents, which should include the importance of not revealing sensitive information, such as technical details of countermeasures that could assist other attackers, and the positive aspects of communicating important information to the public fully and effectively.
Establish procedures to brief media contacts on the issues and sensitivities regarding a particular incident before discussing it with the media.
Maintain a statement of the current status of the incident so that communications with the media are consistent and up-to-date.
Remind all staff of the general procedures for handling media inquiries. Hold mock interviews and press conferences during incident handling exercises. The following are examples of questions to ask the media contact: Who attacked you? Why? 一 When did it happen? How did it happen? Did this happen because you have poor security practices? How widespread is this incident? What steps are you taking to determine what happened and to prevent future occurrences? What is the impact of this incident? Was any personally identifiable information (PII) exposed? What is the estimated cost of this incident?
# 2.3.4.2 Law Enforcement
One reason that many security-related incidents do not result in convictions is that some organizations do not properly contact law enforcement. Several levels of law enforcement are available to investigate incidents: for example, within the United States, Federal investigatory agencies (e.g., the Federal Bureau of Investigation \[FBI\] and the U.S. Secret Service), district attorney offices, state law enforcement, and local (e.g., county) law enforcement. Law enforcement agencies in other countries may also be involved, such as for attacks launched from or directed at locations outside the US. In addition, agencies have an Office of Inspector General (OIG) for investigation of violation of the law within each agency. The incident response team should become acquainted with its various law enforcement representatives before an incident occurs to discuss conditions under which incidents should be reported to them, how the reporting should be performed, what evidence should be collected, and how it should be collected.
Law enforcement should be contacted through designated individuals in a manner consistent with the requirements of the law and the organization’s procedures. Many organizations prefer to appoint one incident response team member as the primary POC with law enforcement. This person should be familiar with the reporting procedures for all relevant law enforcement agencies and well prepared to recommend which agency, if any, should be contacted. Note that the organization typically should not contact multiple agencies because doing so might result in jurisdictional conflicts. The incident response team should understand what the potential jurisdictional issues are (e.g., physical location—an organization based in one state has a server located in a second state attacked from a system in a third state, being used remotely by an attacker in a fourth state).
# 2.3.4.3 Incident Reporting Organizations
FISMA requires Federal agencies to report incidents to the United States Computer Emergency Readiness Team (US-CERT), which is a governmentwide incident response organization that assists Federal civilian agencies in their incident handling efforts. US-CERT does not replace existing agency response teams; rather, it augments the efforts of Federal civilian agencies by serving as a focal point for dealing with incidents. US-CERT analyzes the agency-provided information to identify trends and indicators of attacks; these are easier to discern when reviewing data from many organizations than when reviewing the data of a single organization.
Each agency must designate a primary and secondary POC with US-CERT and report all incidents consistent with the agency’s incident response policy. Organizations should create a policy that states who is designated to report incidents and how the incidents should be reported. Requirements, categories, and timeframes for reporting incidents to US-CERT are on the US-CERT website. All Federal agencies must ensure that their incident response procedures adhere to US-CERT’s reporting requirements and that the procedures are followed properly.
All organizations are encouraged to report incidents to their appropriate CSIRTs. If an organization does not have its own CSIRT to contact, it can report incidents to other organizations, including Information Sharing and Analysis Centers (ISACs). One of the functions of these industry-specific private sector groups is to share important computer security-related information among their members. Several ISACs have been formed for industry sectors such as Communications, Electric Sector, Financial Services, Information Technology, and Research and Education.10
# 2.3.4.4 Other Outside Parties
An organization may want to discuss incidents with other groups, including those listed below. When reaching out to these external parties, an organization may want to work through US-CERT or its ISAC, as a “trusted introducer” to broker the relationship. It is likely that others are experiencing similar issues, and the trusted introducer can ensure that any such patterns are identified and taken into consideration.
Organization’s ISP. An organization may need assistance from its ISP in blocking a major networkbased attack or tracing its origin.
Owners of Attacking Addresses. If attacks are originating from an external organization’s IP address space, incident handlers may want to talk to the designated security contacts for the organization to alert them to the activity or to ask them to collect evidence. It is highly recommended to coordinate such communications with US-CERT or an ISAC.
Software Vendors. Incident handlers may want to speak to a software vendor about suspicious activity. This contact could include questions regarding the significance of certain log entries or known false positives for certain intrusion detection signatures, where minimal information regarding the incident may need to be revealed. More information may need to be provided in some cases—for example, if a server appears to have been compromised through an unknown software vulnerability. Software vendors may also provide information on known threats (e.g., new attacks) to help organizations understand the current threat environment.
Other Incident Response Teams. An organization may experience an incident that is similar to ones handled by other teams; proactively sharing information can facilitate more effective and efficient incident handling (e.g., providing advance warning, increasing preparedness, developing situational awareness). Groups such as the Forum of Incident Response and Security Teams (FIRST) , the Government Forum of Incident Response and Security Teams (GFIRST) , and the Anti-Phishing Working Group (APWG)13 are not incident response teams, but they promote information sharing among incident response teams.
Affected External Parties. An incident may affect external parties directly—for example, an outside organization may contact the organization and claim that one of the organization’s users is attacking it. Another way in which external parties may be affected is if an attacker gains access to sensitive information regarding them, such as credit card information. In some jurisdictions, organizations are required to notify all parties that are affected by such an incident. Regardless of the circumstances, it is preferable for the organization to notify affected external parties of an incident before the media or other external organizations do so. Handlers should be careful to give out only appropriate information—the affected parties may request details about internal investigations that should not be revealed publicly.
OMB Memorandum M-07-16, Safeguarding Against and Responding to the Breach of Personally Identifiable Information, requires Federal agencies to develop and implement a breach notification policy for personally identifiable information (PII).14 Incident handlers should understand how their incident handling actions should differ when a PII breach is suspected to have occurred, such as notifying additional parties or notifying parties within a shorter timeframe. Specific recommendations for PII breach notification policies are presented in OMB Memorandum M-07-16. Also, the National Conference of State Legislatures has a list of state security breach notification laws.15
# 2.4 Incident Response Team Structure
An incident response team should be available for anyone who discovers or suspects that an incident involving the organization has occurred. One or more team members, depending on the magnitude of the incident and availability of personnel, will then handle the incident. The incident handlers analyze the incident data, determine the impact of the incident, and act appropriately to limit the damage and restore normal services. The incident response team’s success depends on the participation and cooperation of individuals throughout the organization. This section identifies such individuals, discusses incident response team models, and provides advice on selecting an appropriate model.
# 2.4.1 Team Models
Possible structures for an incident response team include the following:
Central Incident Response Team. A single incident response team handles incidents throughout the organization. This model is effective for small organizations and for organizations with minimal geographic diversity in terms of computing resources.
Distributed Incident Response Teams. The organization has multiple incident response teams, each responsible for a particular logical or physical segment of the organization. This model is effective for large organizations (e.g., one team per division) and for organizations with major computing resources at distant locations (e.g., one team per geographic region, one team per major facility). However, the teams should be part of a single coordinated entity so that the incident response process is consistent across the organization and information is shared among teams. This is particularly important because multiple teams may see components of the same incident or may handle similar incidents.
Coordinating Team. An incident response team provides advice to other teams without having authority over those teams—for example, a departmentwide team may assist individual agencies’ teams. This model can be thought of as a CSIRT for CSIRTs. Because the focus of this document is central and distributed CSIRTs, the coordinating team model is not addressed in detail in this document.16
Incident response teams can also use any of three staffing models:
Employees. The organization performs all of its incident response work, with limited technical and administrative support from contractors.
Partially Outsourced. The organization outsources portions of its incident response work. Section 2.4.2 discusses the major factors that should be considered with outsourcing. Although incident response duties can be divided among the organization and one or more outsourcers in many ways, a few arrangements have become commonplace:
The most prevalent arrangement is for the organization to outsource 24-hours-a-day, 7-days-aweek (24/7) monitoring of intrusion detection sensors, firewalls, and other security devices to an offsite managed security services provider (MSSP). The MSSP identifies and analyzes suspicious activity and reports each detected incident to the organization’s incident response team. Some organizations perform basic incident response work in-house and call on contractors to assist with handling incidents, particularly those that are more serious or widespread.
Fully Outsourced. The organization completely outsources its incident response work, typically to an onsite contractor. This model is most likely to be used when the organization needs a full-time, onsite incident response team but does not have enough available, qualified employees. It is assumed that the organization will have employees supervising and overseeing the outsourcer’s work.
# 2.4.2 Team Model Selection
When selecting appropriate structure and staffing models for an incident response team, organizations should consider the following factors:
The Need for 24/7 Availability. Most organizations need incident response staff to be available 24/7. This typically means that incident handlers can be contacted by phone, but it can also mean that an onsite presence is required. Real-time availability is the best for incident response because the longer an incident lasts, the more potential there is for damage and loss. Real-time contact is often needed when working with other organizations—for example, tracing an attack back to its source.
Full-Time Versus Part-Time Team Members. Organizations with limited funding, staffing, or incident response needs may have only part-time incident response team members, serving as more of a virtual incident response team. In this case, the incident response team can be thought of as a volunteer fire department. When an emergency occurs, the team members are contacted rapidly, and those who can assist do so. An existing group such as the IT help desk can act as a first POC for incident reporting. The help desk members can be trained to perform the initial investigation and data gathering and then alert the incident response team if it appears that a serious incident has occurred.
Employee Morale. Incident response work is very stressful, as are the on-call responsibilities of most team members. This combination makes it easy for incident response team members to become overly stressed. Many organizations will also struggle to find willing, available, experienced, and properly skilled people to participate, particularly in 24-hour support. Segregating roles, particularly reducing the amount of administrative work that team members are responsible for performing, can be a significant boost to morale.
Cost. Cost is a major factor, especially if employees are required to be onsite 24/7. Organizations may fail to include incident response-specific costs in budgets, such as sufficient funding for training and maintaining skills. Because the incident response team works with so many facets of IT, its members need much broader knowledge than most IT staff members. They must also understand how to use the tools of incident response, such as digital forensics software. Other costs that may be overlooked are physical security for the team’s work areas and communications mechanisms.
Staff Expertise. Incident handling requires specialized knowledge and experience in several technical areas; the breadth and depth of knowledge required varies based on the severity of the organization’s risks. Outsourcers may possess deeper knowledge of intrusion detection, forensics, vulnerabilities, exploits, and other aspects of security than employees of the organization. Also, MSSPs may be able to correlate events among customers so that they can identify new threats more quickly than any individual customer could. However, technical staff members within the organization usually have much better knowledge of the organization’s environment than an outsourcer would, which can be beneficial in identifying false positives associated with organizationspecific behavior and the criticality of targets. Section 2.4.3 contains additional information on recommended team member skills.
When considering outsourcing, organizations should keep these issues in mind:
Current and Future Quality of Work. Organizations should consider not only the current quality (breadth and depth) of the outsourcer’s work, but also efforts to ensure the quality of future work— for example, minimizing turnover and burnout and providing a solid training program for new employees. Organizations should think about how they could objectively assess the quality of the outsourcer’s work.
Division of Responsibilities. Organizations are often unwilling to give an outsourcer authority to make operational decisions for the environment (e.g., disconnecting a web server). It is important to document the appropriate actions for these decision points. For example, one partially outsourced model addresses this issue by having the outsourcer provide incident data to the organization’s internal team, along with recommendations for further handling the incident. The internal team ultimately makes the operational decisions, with the outsourcer continuing to provide support as needed.
Sensitive Information Revealed to the Contractor. Dividing incident response responsibilities and restricting access to sensitive information can limit this. For example, a contractor may determine what user ID was used in an incident (e.g., ID 123456) but not know what person is associated with the user ID. Employees can then take over the investigation. Non-disclosure agreements (NDAs) are one possible option for protecting the disclosure of sensitive information.
Lack of Organization-Specific Knowledge. Accurate analysis and prioritization of incidents are dependent on specific knowledge of the organization’s environment. The organization should provide the outsourcer regularly updated documents that define what incidents it is concerned about, which resources are critical, and what the level of response should be under various sets of circumstances. The organization should also report all changes and updates made to its IT infrastructure, network configuration, and systems. Otherwise, the contractor has to make a best guess as to how each incident should be handled, inevitably leading to mishandled incidents and frustration on both sides. Lack of organization-specific knowledge can also be a problem when incident response is not outsourced if communications are weak among teams or if the organization simply does not collect the necessary information.
Lack of Correlation. Correlation among multiple data sources is very important. If the intrusion detection system records an attempted attack against a web server, but the outsourcer has no access to the server’s logs, it may be unable to determine whether the attack was successful. To be efficient, the outsourcer will require administrative privileges to critical systems and security device logs remotely over a secure channel. This will increase administration costs, introduce additional access entry points, and increase the risk of unauthorized disclosure of sensitive information.
Handling Incidents at Multiple Locations. Effective incident response work often requires a physical presence at the organization’s facilities. If the outsourcer is offsite, consider where the outsourcer is located, how quickly it can have an incident response team at any facility, and how much this will cost. Consider onsite visits; perhaps there are certain facilities or areas where the outsourcer should not be permitted to work.
Maintaining Incident Response Skills In-House. Organizations that completely outsource incident response should strive to maintain basic incident response skills in-house. Situations may arise in which the outsourcer is unavailable, so the organization should be prepared to perform its own incident handling. The organization’s technical staff must also be able to understand the significance, technical implications, and impact of the outsourcer’s recommendations.
# 2.4.3 Incident Response Personnel
A single employee, with one or more designated alternates, should be in charge of incident response. In a fully outsourced model, this person oversees and evaluates the outsourcer’s work. All other models generally have a team manager and one or more deputies who assumes authority in the absence of the team manager. The managers typically perform a variety of tasks, including acting as a liaison with upper management and other teams and organizations, defusing crisis situations, and ensuring that the team has the necessary personnel, resources, and skills. Managers should be technically adept and have excellent communication skills, particularly an ability to communicate to a range of audiences. Managers are ultimately responsible for ensuring that incident response activities are performed properly.
In addition to the team manager and deputy, some teams also have a technical lead—a person with strong technical skills and incident response experience who assumes oversight of and final responsibility for the quality of the team’s technical work. The position of technical lead should not be confused with the position of incident lead. Larger teams often assign an incident lead as the primary POC for handling a specific incident; the incident lead is held accountable for the incident’s handling. Depending on the size of the incident response team and the magnitude of the incident, the incident lead may not actually perform any actual incident handling, but rather coordinate the handlers’ activities, gather information from the handlers, provide incident updates to other groups, and ensure that the team’s needs are met.
Members of the incident response team should have excellent technical skills, such as system administration, network administration, programming, technical support, or intrusion detection. Every team member should have good problem solving skills and critical thinking abilities. It is not necessary for every team member to be a technical expert—to a large degree, practical and funding considerations will dictate this—but having at least one highly proficient person in each major area of technology (e.g., commonly attacked operating systems and applications) is a necessity. It may also be helpful to have some team members specialize in particular technical areas, such as network intrusion detection, malware analysis, or forensics. It is also often helpful to temporarily bring in technical specialists that aren’t normally part of the team.
It is important to counteract staff burnout by providing opportunities for learning and growth. Suggestions for building and maintaining skills are as follows:
Budget enough funding to maintain, enhance, and expand proficiency in technical areas and security disciplines, as well as less technical topics such as the legal aspects of incident response. This should include sending staff to conferences and encouraging or otherwise incentivizing participation in conferences, ensuring the availability of technical references that promote deeper technical understanding, and occasionally bringing in outside experts (e.g., contractors) with deep technical knowledge in needed areas as funding permits.
Give team members opportunities to perform other tasks, such as creating educational materials, conducting security awareness workshops, and performing research.
Consider rotating staff members in and out of the incident response team, and participate in exchanges in which team members temporarily trade places with others (e.g., network administrators) to gain new technical skills.
Maintain sufficient staffing so that team members can have uninterrupted time off work (e.g., vacations). Create a mentoring program to enable senior technical staff to help less experienced staff learn incident handling.
Develop incident handling scenarios and have the team members discuss how they would handle them. Appendix A contains a set of scenarios and a list of questions to be used during scenario discussions.
Incident response team members should have other skills in addition to technical expertise. Teamwork skills are of fundamental importance because cooperation and coordination are necessary for successful incident response. Every team member should also have good communication skills. Speaking skills are important because the team will interact with a wide variety of people, and writing skills are important when team members are preparing advisories and procedures. Although not everyone within a team needs to have strong writing and speaking skills, at least a few people within every team should possess them so the team can represent itself well in front of others.
# 2.4.4 Dependencies within Organizations
It is important to identify other groups within the organization that may need to participate in incident handling so that their cooperation can be solicited before it is needed. Every incident response team relies on the expertise, judgment, and abilities of others, including:
Management. Management establishes incident response policy, budget, and staffing. Ultimately, management is held responsible for coordinating incident response among various stakeholders, minimizing damage, and reporting to Congress, OMB, the General Accounting Office (GAO), and other parties.
Information Assurance. Information security staff members may be needed during certain stages of incident handling (prevention, containment, eradication, and recovery)—for example, to alter network security controls (e.g., firewall rulesets).
IT Support. IT technical experts (e.g., system and network administrators) not only have the needed skills to assist but also usually have the best understanding of the technology they manage on a daily basis. This understanding can ensure that the appropriate actions are taken for the affected system, such as whether to disconnect an attacked system.
Legal Department. Legal experts should review incident response plans, policies, and procedures to ensure their compliance with law and Federal guidance, including the right to privacy. In addition, the guidance of the general counsel or legal department should be sought if there is reason to believe that an incident may have legal ramifications, including evidence collection, prosecution of a suspect, or a lawsuit, or if there may be a need for a memorandum of understanding (MOU) or other binding agreements involving liability limitations for information sharing.
Public Affairs and Media Relations. Depending on the nature and impact of an incident, a need may exist to inform the media and, by extension, the public.
Human Resources. If an employee is suspected of causing an incident, the human resources department may be involved—for example, in assisting with disciplinary proceedings.
Business Continuity Planning. Organizations should ensure that incident response policies and procedures and business continuity processes are in sync. Computer security incidents undermine the business resilience of an organization. Business continuity planning professionals should be made aware of incidents and their impacts so they can fine-tune business impact assessments, risk assessments, and continuity of operations plans. Further, because business continuity planners have extensive expertise in minimizing operational disruption during severe circumstances, they may be valuable in planning responses to certain situations, such as denial of service (DoS) conditions.
Physical Security and Facilities Management. Some computer security incidents occur through breaches of physical security or involve coordinated logical and physical attacks. The incident response team also may need access to facilities during incident handling—for example, to acquire a compromised workstation from a locked office.
# 2.5 Incident Response Team Services
The main focus of an incident response team is performing incident response, but it is fairly rare for a team to perform incident response only. The following are examples of other services a team might offer:
Intrusion Detection. The first tier of an incident response team often assumes responsibility for intrusion detection. The team generally benefits because it should be poised to analyze incidents more quickly and accurately, based on the knowledge it gains of intrusion detection technologies.
Advisory Distribution. A team may issue advisories within the organization regarding new vulnerabilities and threats.18 Automated methods should be used whenever appropriate to disseminate information; for example, the National Vulnerability Database (NVD) provides information via XML and RSS feeds when new vulnerabilities are added to it. Advisories are often most necessary when new threats are emerging, such as a high-profile social or political event (e.g., celebrity wedding) that attackers are likely to leverage in their social engineering. Only one group within the organization should distribute computer security advisories to avoid duplicated effort and conflicting information.
Education and Awareness. Education and awareness are resource multipliers—the more the users and technical staff know about detecting, reporting, and responding to incidents, the less drain there should be on the incident response team. This information can be communicated through many means: workshops, websites, newsletters, posters, and even stickers on monitors and laptops.
Information Sharing. Incident response teams often participate in information sharing groups, such as ISACs or regional partnerships. Accordingly, incident response teams often manage the organization’s incident information sharing efforts, such as aggregating information related to incidents and effectively sharing that information with other organizations, as well as ensuring that pertinent information is shared within the enterprise.
# 2.6 Recommendations
The key recommendations presented in this section for organizing a computer security incident handling
capability are summarized below.
Establish a formal incident response capability. Organizations should be prepared to respond quickly and effectively when computer security defenses are breached. FISMA requires Federal agencies to establish incident response capabilities.
Create an incident response policy. The incident response policy is the foundation of the incident response program. It defines which events are considered incidents, establishes the organizational structure for incident response, defines roles and responsibilities, and lists the requirements for reporting incidents, among other items.
Develop an incident response plan based on the incident response policy. The incident response plan provides a roadmap for implementing an incident response program based on the organization’s policy. The plan indicates both short- and long-term goals for the program, including metrics for measuring the program. The incident response plan should also indicate how often incident handlers should be trained and the requirements for incident handlers.
Develop incident response procedures. The incident response procedures provide detailed steps for responding to an incident. The procedures should cover all the phases of the incident response process. The procedures should be based on the incident response policy and plan.
Establish policies and procedures regarding incident-related information sharing. The organization should communicate appropriate incident details with outside parties, such as the media, law enforcement agencies, and incident reporting organizations. The incident response team should discuss this with the organization’s public affairs office, legal department, and management to establish policies and procedures regarding information sharing. The team should comply with existing organization policy on interacting with the media and other outside parties.
Provide pertinent information on incidents to the appropriate organization. Federal civilian agencies are required to report incidents to US-CERT; other organizations can contact US-CERT and/or their ISAC. Reporting is beneficial because US-CERT and the ISACs use the reported data to provide information to the reporting parties regarding new threats and incident trends.
Consider the relevant factors when selecting an incident response team model. Organizations should carefully weigh the advantages and disadvantages of each possible team structure model and staffing model in the context of the organization’s needs and available resources.
Select people with appropriate skills for the incident response team. The credibility and proficiency of the team depend to a large extent on the technical skills and critical thinking abilities of its members. Critical technical skills include system administration, network administration, programming, technical support, and intrusion detection. Teamwork and communications skills are
also needed for effective incident handling. Necessary training should be provided to all team members.
Identify other groups within the organization that may need to participate in incident handling. Every incident response team relies on the expertise, judgment, and abilities of other teams, including management, information assurance, IT support, legal, public affairs, and facilities management.
Determine which services the team should offer. Although the main focus of the team is incident response, most teams perform additional functions. Examples include monitoring intrusion detection sensors, distributing security advisories, and educating users on security.
The incident response process has several phases. The initial phase involves establishing and training an incident response team, and acquiring the necessary tools and resources. During preparation, the organization also attempts to limit the number of incidents that will occur by selecting and implementing a set of controls based on the results of risk assessments. However, residual risk will inevitably persist after controls are implemented. Detection of security breaches is thus necessary to alert the organization whenever incidents occur. In keeping with the severity of the incident, the organization can mitigate the impact of the incident by containing it and ultimately recovering from it. During this phase, activity often cycles back to detection and analysis—for example, to see if additional hosts are infected by malware while eradicating a malware incident. After the incident is adequately handled, the organization issues a report that details the cause and cost of the incident and the steps the organization should take to prevent future incidents. This section describes the major phases of the incident response process—preparation, detection and analysis, containment, eradication and recovery, and post-incident activity—in detail. illustrates the incident response life cycle.
Incident Response Life Cycle
# 3.1 Preparation
Incident response methodologies typically emphasize preparation—not only establishing an incident response capability so that the organization is ready to respond to incidents, but also preventing incidents by ensuring that systems, networks, and applications are sufficiently secure. Although the incident response team is not typically responsible for incident prevention, it is fundamental to the success of incident response programs. This section provides basic advice on preparing to handle incidents and on preventing incidents.
# 3.1.1 Preparing to Handle Incidents
The lists below provide examples of tools and resources available that may be of value during incident handling. These lists are intended to be a starting point for discussions about which tools and resources an organization’s incident handlers need. For example, smartphones are one way to have resilient emergency communication and coordination mechanisms. An organization should have multiple (separate and different) communication and coordination mechanisms in case of failure of one mechanism.
Incident Handler Communications and Facilities:
Contact information for team members and others within and outside the organization (primary and backup contacts), such as law enforcement and other incident response teams; information may include phone numbers, email addresses, public encryption keys (in accordance with the encryption software described below), and instructions for verifying the contact’s identity
On-call information for other teams within the organization, including escalation information Incident reporting mechanisms, such as phone numbers, email addresses, online forms, and secure instant messaging systems that users can use to report suspected incidents; at least one mechanism should permit people to report incidents anonymously
Issue tracking system for tracking incident information, status, etc.
Smartphones to be carried by team members for off-hour support and onsite communications Encryption software to be used for communications among team members, within the organization and with external parties; for Federal agencies, software must use a FIPS-validated encryption algorithm20
War room for central communication and coordination; if a permanent war room is not necessary or practical, the team should create a procedure for procuring a temporary war room when needed
Secure storage facility for securing evidence and other sensitive materials
Incident Analysis Hardware and Software:
Digital forensic workstations21 and/or backup devices to create disk images, preserve log files, and save other relevant incident data
Laptops for activities such as analyzing data, sniffing packets, and writing reports
Spare workstations, servers, and networking equipment, or the virtualized equivalents, which may be used for many purposes, such as restoring backups and trying out malware
Blank removable media
Portable printer to print copies of log files and other evidence from non-networked systems
Packet sniffers and protocol analyzers to capture and analyze network traffic
Digital forensic software to analyze disk images
Removable media with trusted versions of programs to be used to gather evidence from systems
Evidence gathering accessories, including hard-bound notebooks, digital cameras, audio recorders, chain of custody forms, evidence storage bags and tags, and evidence tape, to preserve evidence for possible legal actions
# Incident Analysis Resources:
Port lists, including commonly used ports and Trojan horse ports Documentation for OSs, applications, protocols, and intrusion detection and antivirus products Network diagrams and lists of critical assets, such as database servers Current baselines of expected network, system, and application activity Cryptographic hashes of critical files to speed incident analysis, verification, and eradication
Incident Mitigation Software:
Access to images of clean OS and application installations for restoration and recovery purposes
Many incident response teams create a jump kit, which is a portable case that contains materials that may be needed during an investigation. The jump kit should be ready to go at all times. Jump kits contain many of the same items listed in the bulleted lists above. For example, each jump kit typically includes a laptop, loaded with appropriate software (e.g., packet sniffers, digital forensics). Other important materials include backup devices, blank media, and basic networking equipment and cables. Because the purpose of having a jump kit is to facilitate faster responses, the team should avoid borrowing items from the jump kit.
Each incident handler should have access to at least two computing devices (e.g., laptops). One, such as the one from the jump kit, should be used to perform packet sniffing, malware analysis, and all other actions that risk contaminating the laptop that performs them. This laptop should be scrubbed and all software reinstalled before it is used for another incident. Note that because this laptop is special purpose, it is likely to use software other than the standard enterprise tools and configurations, and whenever possible the incident handlers should be allowed to specify basic technical requirements for these specialpurpose investigative laptops. In addition to an investigative laptop, each incident handler should also have a standard laptop, smart phone, or other computing device for writing reports, reading email, and performing other duties unrelated to the hands-on incident analysis.
Exercises involving simulated incidents can also be very useful for preparing staff for incident handling;
see NIST SP 800-84 for more information on exercises and Appendix A for sample exercise scenarios.
# 3.1.2 Preventing Incidents
Keeping the number of incidents reasonably low is very important to protect the business processes of the organization. If security controls are insufficient, higher volumes of incidents may occur, overwhelming the incident response team. This can lead to slow and incomplete responses, which translate to a larger negative business impact (e.g., more extensive damage, longer periods of service and data unavailability).
It is outside the scope of this document to provide specific advice on securing networks, systems, and applications. Although incident response teams are generally not responsible for securing resources, they can be advocates of sound security practices. An incident response team may be able to identify problems that the organization is otherwise not aware of; the team can play a key role in risk assessment and training by identifying gaps. Other documents already provide advice on general security concepts and operating system and application-specific guidelines.24 The following text, however, provides a brief overview of some of the main recommended practices for securing networks, systems, and applications:
Risk Assessments. Periodic risk assessments of systems and applications should determine what risks are posed by combinations of threats and vulnerabilities. This should include understanding the applicable threats, including organization-specific threats. Each risk should be prioritized, and the risks can be mitigated, transferred, or accepted until a reasonable overall level of risk is reached. Another benefit of conducting risk assessments regularly is that critical resources are identified, allowing staff to emphasize monitoring and response activities for those resources.26
Host Security. All hosts should be hardened appropriately using standard configurations. In addition to keeping each host properly patched, hosts should be configured to follow the principle of least privilege—granting users only the privileges necessary for performing their authorized tasks. Hosts should have auditing enabled and should log significant security-related events. The security of hosts and their configurations should be continuously monitored.27 Many organizations use Security Content Automation Protocol $\\mathrm{(SCAP)}^{28}$ expressed operating system and application configuration checklists to assist in securing hosts consistently and effectively.29
Network Security. The network perimeter should be configured to deny all activity that is not expressly permitted. This includes securing all connection points, such as virtual private networks (VPNs) and dedicated connections to other organizations.
Malware Prevention. Software to detect and stop malware should be deployed throughout the organization. Malware protection should be deployed at the host level (e.g., server and workstation operating systems), the application server level (e.g., email server, web proxies), and the application client level (e.g., email clients, instant messaging clients).30
User Awareness and Training. Users should be made aware of policies and procedures regarding appropriate use of networks, systems, and applications. Applicable lessons learned from previous incidents should also be shared with users so they can see how their actions could affect the organization. Improving user awareness regarding incidents should reduce the frequency of incidents. IT staff should be trained so that they can maintain their networks, systems, and applications in accordance with the organization’s security standards.
# 3.2 Detection and Analysis
Incident Response Life Cycle (Detection and Analysis)
# 3.2.1 Attack Vectors
Incidents can occur in countless ways, so it is infeasible to develop step-by-step instructions for handling every incident. Organizations should be generally prepared to handle any incident but should focus on being prepared to handle incidents that use common attack vectors. Different types of incidents merit different response strategies. The attack vectors listed below are not intended to provide definitive classification for incidents; rather, they simply list common methods of attack, which can be used as a basis for defining more specific handling procedures.
External/Removable Media: An attack executed from removable media or a peripheral device—for example, malicious code spreading onto a system from an infected USB flash drive.
Attrition: An attack that employs brute force methods to compromise, degrade, or destroy systems, networks, or services (e.g., a DDoS intended to impair or deny access to a service or application; a brute force attack against an authentication mechanism, such as passwords, CAPTCHAS, or digital signatures).
Web: An attack executed from a website or web-based application—for example, a cross-site scripting attack used to steal credentials or a redirect to a site that exploits a browser vulnerability and installs malware.
Email: An attack executed via an email message or attachment—for example, exploit code disguised as an attached document or a link to a malicious website in the body of an email message.
Impersonation: An attack involving replacement of something benign with something malicious— for example, spoofing, man in the middle attacks, rogue wireless access points, and SQL injection attacks all involve impersonation.
Improper Usage: Any incident resulting from violation of an organization’s acceptable usage policies by an authorized user, excluding the above categories; for example, a user installs file sharing software, leading to the loss of sensitive data; or a user performs illegal activities on a system.
Loss or Theft of Equipment: The loss or theft of a computing device or media used by the organization, such as a laptop, smartphone, or authentication token.
Other: An attack that does not fit into any of the other categories.
This section focuses on recommended practices for handling any type of incident. It is outside the scope of this publication to give specific advice based on the attack vectors; such guidelines would be provided in separate publications addressing other incident handling topics, such as NIST SP 800-83 on malware incident prevention and handling.
# 3.2.2 Signs of an Incident
For many organizations, the most challenging part of the incident response process is accurately detecting and assessing possible incidents—determining whether an incident has occurred and, if so, the type, extent, and magnitude of the problem. What makes this so challenging is a combination of three factors:
Incidents may be detected through many different means, with varying levels of detail and fidelity. Automated detection capabilities include network-based and host-based IDPSs, antivirus software, and log analyzers. Incidents may also be detected through manual means, such as problems reported by users. Some incidents have overt signs that can be easily detected, whereas others are almost impossible to detect.
The volume of potential signs of incidents is typically high—for example, it is not uncommon for an organization to receive thousands or even millions of intrusion detection sensor alerts per day. (See Section 3.2.4 for information on analyzing such alerts.)
Deep, specialized technical knowledge and extensive experience are necessary for proper and efficient analysis of incident-related data.
Signs of an incident fall into one of two categories: precursors and indicators. A precursor is a sign that an incident may occur in the future. An indicator is a sign that an incident may have occurred or may be occurring now.
Most attacks do not have any identifiable or detectable precursors from the target’s perspective. If precursors are detected, the organization may have an opportunity to prevent the incident by altering its security posture to save a target from attack. At a minimum, the organization could monitor activity involving the target more closely. Examples of precursors are:
Web server log entries that show the usage of a vulnerability scanner An announcement of a new exploit that targets a vulnerability of the organization’s mail server A threat from a group stating that the group will attack the organization.
While precursors are relatively rare, indicators are all too common. Too many types of indicators exist to exhaustively list them, but some examples are listed below:
A network intrusion detection sensor alerts when a buffer overflow attempt occurs against a database server. Antivirus software alerts when it detects that a host is infected with malware.
A system administrator sees a filename with unusual characters.
A host records an auditing configuration change in its log. An application logs multiple failed login attempts from an unfamiliar remote system.
An email administrator sees a large number of bounced emails with suspicious content.
A network administrator notices an unusual deviation from typical network traffic flows.
# 3.2.3 Sources of Precursors and Indicators
Precursors and indicators are identified using many different sources, with the most common being computer security software alerts, logs, publicly available information, and people. lists common sources of precursors and indicators for each category.
Common Sources of Precursors and Indicators
# 3.2.4 Incident Analysis
Incident detection and analysis would be easy if every precursor or indicator were guaranteed to be accurate; unfortunately, this is not the case. For example, user-provided indicators such as a complaint of a server being unavailable are often incorrect. Intrusion detection systems may produce false positives— incorrect indicators. These examples demonstrate what makes incident detection and analysis so difficult: each indicator ideally should be evaluated to determine if it is legitimate. Making matters worse, the total number of indicators may be thousands or millions a day. Finding the real security incidents that occurred out of all the indicators can be a daunting task.
Even if an indicator is accurate, it does not necessarily mean that an incident has occurred. Some indicators, such as a server crash or modification of critical files, could happen for several reasons other than a security incident, including human error. Given the occurrence of indicators, however, it is reasonable to suspect that an incident might be occurring and to act accordingly. Determining whether a particular event is actually an incident is sometimes a matter of judgment. It may be necessary to collaborate with other technical and information security personnel to make a decision. In many instances, a situation should be handled the same way regardless of whether it is security related. For example, if an organization is losing Internet connectivity every 12 hours and no one knows the cause, the staff would want to resolve the problem just as quickly and would use the same resources to diagnose the problem, regardless of its cause.
Some incidents are easy to detect, such as an obviously defaced web page. However, many incidents are not associated with such clear symptoms. Small signs such as one change in one system configuration file may be the only indicators that an incident has occurred. In incident handling, detection may be the most difficult task. Incident handlers are responsible for analyzing ambiguous, contradictory, and incomplete symptoms to determine what has happened. Although technical solutions exist that can make detection
easier, the best remedy is to build a team of highly experienced and proficient staff members who can analyze the precursors and indicators effectively and efficiently and take appropriate actions. Without a well-trained and capable staff, incident detection and analysis will be conducted inefficiently, and costly mistakes will be made.
The incident response team should work quickly to analyze and validate each incident, following a predefined process and documenting each step taken. When the team believes that an incident has occurred, the team should rapidly perform an initial analysis to determine the incident’s scope, such as which networks, systems, or applications are affected; who or what originated the incident; and how the incident is occurring (e.g., what tools or attack methods are being used, what vulnerabilities are being exploited). The initial analysis should provide enough information for the team to prioritize subsequent activities, such as containment of the incident and deeper analysis of the effects of the incident.
Performing the initial analysis and validation is challenging. The following are recommendations for making incident analysis easier and more effective:
Profile Networks and Systems. Profiling is measuring the characteristics of expected activity so that changes to it can be more easily identified. Examples of profiling are running file integrity checking software on hosts to derive checksums for critical files and monitoring network bandwidth usage to determine what the average and peak usage levels are on various days and times. In practice, it is difficult to detect incidents accurately using most profiling techniques; organizations should use profiling as one of several detection and analysis techniques.
Understand Normal Behaviors. Incident response team members should study networks, systems, and applications to understand what their normal behavior is so that abnormal behavior can be recognized more easily. No incident handler will have a comprehensive knowledge of all behavior throughout the environment, but handlers should know which experts could fill in the gaps. One way to gain this knowledge is through reviewing log entries and security alerts. This may be tedious if filtering is not used to condense the logs to a reasonable size. As handlers become more familiar with the logs and alerts, they should be able to focus on unexplained entries, which are usually more important to investigate. Conducting frequent log reviews should keep the knowledge fresh, and the analyst should be able to notice trends and changes over time. The reviews also give the analyst an indication of the reliability of each source.
Create a Log Retention Policy. Information regarding an incident may be recorded in several places, such as firewall, IDPS, and application logs. Creating and implementing a log retention policy that specifies how long log data should be maintained may be extremely helpful in analysis because older log entries may show reconnaissance activity or previous instances of similar attacks. Another reason for retaining logs is that incidents may not be discovered until days, weeks, or even months later. The length of time to maintain log data is dependent on several factors, including the organization’s data retention policies and the volume of data. See NIST SP 800-92, Guide to Computer Security Log Management for additional recommendations related to logging.34
Perform Event Correlation. Evidence of an incident may be captured in several logs that each contain different types of data—a firewall log may have the source IP address that was used, whereas an application log may contain a username. A network IDPS may detect that an attack was launched against a particular host, but it may not know if the attack was successful. The analyst may need to examine the host’s logs to determine that information. Correlating events among multiple indicator sources can be invaluable in validating whether a particular incident occurred.
Keep All Host Clocks Synchronized. Protocols such as the Network Time Protocol (NTP) synchronize clocks among hosts.35 Event correlation will be more complicated if the devices reporting events have inconsistent clock settings. From an evidentiary standpoint, it is preferable to have consistent timestamps in logs—for example, to have three logs that show an attack occurred at 12:07:01 a.m., rather than logs that list the attack as occurring at 12:07:01, 12:10:35, and 11:07:06.
Maintain and Use a Knowledge Base of Information. The knowledge base should include information that handlers need for referencing quickly during incident analysis. Although it is possible to build a knowledge base with a complex structure, a simple approach can be effective. Text documents, spreadsheets, and relatively simple databases provide effective, flexible, and searchable mechanisms for sharing data among team members. The knowledge base should also contain a variety of information, including explanations of the significance and validity of precursors and indicators, such as IDPS alerts, operating system log entries, and application error codes.
Use Internet Search Engines for Research. Internet search engines can help analysts find information on unusual activity. For example, an analyst may see some unusual connection attempts targeting TCP port 22912. Performing a search on the terms “TCP,” “port,” and $\\mathbf{\\tilde{2}}2912\\mathbf{\\tilde{\\gamma}}$ may return some hits that contain logs of similar activity or even an explanation of the significance of the port number. Note that separate workstations should be used for research to minimize the risk to the organization from conducting these searches.
Run Packet Sniffers to Collect Additional Data. Sometimes the indicators do not record enough detail to permit the handler to understand what is occurring. If an incident is occurring over a network, the fastest way to collect the necessary data may be to have a packet sniffer capture network traffic. Configuring the sniffer to record traffic that matches specified criteria should keep the volume of data manageable and minimize the inadvertent capture of other information. Because of privacy concerns, some organizations may require incident handlers to request and receive permission before using packet sniffers.
Filter the Data. There is simply not enough time to review and analyze all the indicators; at minimum the most suspicious activity should be investigated. One effective strategy is to filter out categories of indicators that tend to be insignificant. Another filtering strategy is to show only the categories of indicators that are of the highest significance; however, this approach carries substantial risk because new malicious activity may not fall into one of the chosen indicator categories.
Seek Assistance from Others. Occasionally, the team will be unable to determine the full cause and nature of an incident. If the team lacks sufficient information to contain and eradicate the incident, then it should consult with internal resources (e.g., information security staff) and external resources (e.g., US-CERT, other CSIRTs, contractors with incident response expertise). It is important to accurately determine the cause of each incident so that it can be fully contained and the exploited vulnerabilities can be mitigated to prevent similar incidents from occurring.
# 3.2.5 Incident Documentation
An incident response team that suspects that an incident has occurred should immediately start recording all facts regarding the incident.36 A logbook is an effective and simple medium for this,37 but laptops,
audio recorders, and digital cameras can also serve this purpose.38 Documenting system events, conversations, and observed changes in files can lead to a more efficient, more systematic, and less errorprone handling of the problem. Every step taken from the time the incident was detected to its final resolution should be documented and timestamped. Every document regarding the incident should be dated and signed by the incident handler. Information of this nature can also be used as evidence in a court of law if legal prosecution is pursued. Whenever possible, handlers should work in teams of at least two: one person can record and log events while the other person performs the technical tasks. Section 3.3.2 presents more information about evidence.39
The incident response team should maintain records about the status of incidents, along with other pertinent information. Using an application or a database, such as an issue tracking system, helps ensure that incidents are handled and resolved in a timely manner. The issue tracking system should contain information on the following:
The current status of the incident (new, in progress, forwarded for investigation, resolved, et A summary of the incident
Indicators related to the incident
Other incidents related to this incident
Actions taken by all incident handlers on this incident
Chain of custody, if applicable
Impact assessments related to the incident
Contact information for other involved parties (e.g., system owners, system administrators) A list of evidence gathered during the incident investigation
Comments from incident handlers
Next steps to be taken (e.g., rebuild the host, upgrade an application).
The incident response team should safeguard incident data and restrict access to it because it often contains sensitive information—for example, data on exploited vulnerabilities, recent security breaches, and users that may have performed inappropriate actions. For example, only authorized personnel should have access to the incident database. Incident communications (e.g., emails) and documents should be encrypted or otherwise protected so that only authorized personnel can read them.
# 3.2.6 Incident Prioritization
Prioritizing the handling of the incident is perhaps the most critical decision point in the incident handling process. Incidents should not be handled on a first-come, first-served basis as a result of resource limitations. Instead, handling should be prioritized based on the relevant factors, such as the following:
Functional Impact of the Incident. Incidents targeting IT systems typically impact the business functionality that those systems provide, resulting in some type of negative impact to the users of those systems. Incident handlers should consider how the incident will impact the existing functionality of the affected systems. Incident handlers should consider not only the current functional impact of the incident, but also the likely future functional impact of the incident if it is not immediately contained.
Information Impact of the Incident. Incidents may affect the confidentiality, integrity, and availability of the organization’s information. For example, a malicious agent may exfiltrate sensitive information. Incident handlers should consider how this information exfiltration will impact the organization’s overall mission. An incident that results in the exfiltration of sensitive information may also affect other organizations if any of the data pertained to a partner organization.
Recoverability from the Incident. The size of the incident and the type of resources it affects will determine the amount of time and resources that must be spent on recovering from that incident. In some instances it is not possible to recover from an incident (e.g., if the confidentiality of sensitive information has been compromised) and it would not make sense to spend limited resources on an elongated incident handling cycle, unless that effort was directed at ensuring that a similar incident did not occur in the future. In other cases, an incident may require far more resources to handle than what an organization has available. Incident handlers should consider the effort necessary to actually recover from an incident and carefully weigh that against the value the recovery effort will create and any requirements related to incident handling.
Combining the functional impact to the organization’s systems and the impact to the organization’s information determines the business impact of the incident—for example, a distributed denial of service attack against a public web server may temporarily reduce the functionality for users attempting to access the server, whereas unauthorized root-level access to a public web server may result in the exfiltration of personally identifiable information (PII), which could have a long-lasting impact on the organization’s reputation.
The recoverability from the incident determines the possible responses that the team may take when handling the incident. An incident with a high functional impact and low effort to recover from is an ideal candidate for immediate action from the team. However, some incidents may not have smooth recovery paths and may need to be queued for a more strategic-level response—for example, an incident that results in an attacker exfiltrating and publicly posting gigabytes of sensitive data has no easy recovery path since the data is already exposed; in this case the team may transfer part of the responsibility for handling the data exfiltration incident to a more strategic-level team that develops strategy for preventing future breaches and creates an outreach plan for alerting those individuals or organizations whose data was exfiltrated. The team should prioritize the response to each incident based on its estimate of the business impact caused by the incident and the estimated efforts required to recover from the incident.
An organization can best quantify the effect of its own incidents because of its situational awareness. provides examples of functional impact categories that an organization might use for rating its own incidents. Rating incidents can be helpful in prioritizing limited resources.
Functional Impact Categories
provides examples of possible information impact categories that describe the extent of information compromise that occurred during the incident. In this table, with the exception of the ‘None’ value, the categories are not mutually exclusive and the organization could choose more than one.
Information Impact Categories
shows examples of recoverability effort categories that reflect the level of and type of resources required to recover from the incident.
Recoverability Effort Categories
Organizations should also establish an escalation process for those instances when the team does not respond to an incident within the designated time. This can happen for many reasons: for example, cell phones may fail or people may have personal emergencies. The escalation process should state how long a person should wait for a response and what to do if no response occurs. Generally, the first step is to duplicate the initial contact. After waiting for a brief time—perhaps 15 minutes—the caller should escalate the incident to a higher level, such as the incident response team manager. If that person does not respond within a certain time, then the incident should be escalated again to a higher level of management. This process should be repeated until someone responds.
# 3.2.7 Incident Notification
When an incident is analyzed and prioritized, the incident response team needs to notify the appropriate individuals so that all who need to be involved will play their roles. Incident response policies should include provisions concerning incident reporting—at a minimum, what must be reported to whom and at what times (e.g., initial notification, regular status updates). The exact reporting requirements vary among organizations, but parties that are typically notified include:
Head of information security
Local information security officer
Other incident response teams within the organization
External incident response teams (if appropriate)
System owner
Human resources (for cases involving employees, such as harassment through email)
Public affairs (for incidents that may generate publicity)
Legal department (for incidents with potential legal ramifications)
US-CERT (required for Federal agencies and systems operated on behalf of the Federal govern see Section 2.3.4.3)
Law enforcement (if appropriate)
During incident handling, the team may need to provide status updates to certain parties, even in some cases the entire organization. The team should plan and prepare several communication methods, including out-of-band methods (e.g., in person, paper), and select the methods that are appropriate for a particular incident. Possible communication methods include:
Email
Website (internal, external, or portal)
Telephone calls
In person (e.g., daily briefings)
Voice mailbox greeting (e.g., set up a separate voice mailbox for incident updates, and update the greeting message to reflect the current incident status; use the help desk’s voice mail greeting) Paper (e.g., post notices on bulletin boards and doors, hand out notices at all entrance points).
# 3.3 Containment, Eradication, and Recovery
Incident Response Life Cycle (Containment, Eradication, and Recovery)
# 3.3.1 Choosing a Containment Strategy
Containment is important before an incident overwhelms resources or increases damage. Most incidents require containment, so that is an important consideration early in the course of handling each incident. Containment provides time for developing a tailored remediation strategy. An essential part of containment is decision-making (e.g., shut down a system, disconnect it from a network, disable certain functions). Such decisions are much easier to make if there are predetermined strategies and procedures for containing the incident. Organizations should define acceptable risks in dealing with incidents and develop strategies accordingly.
Containment strategies vary based on the type of incident. For example, the strategy for containing an email-borne malware infection is quite different from that of a network-based DDoS attack. Organizations should create separate containment strategies for each major incident type, with criteria documented clearly to facilitate decision-making. Criteria for determining the appropriate strategy include:
Potential damage to and theft of resources
Need for evidence preservation
Service availability (e.g., network connectivity, services provided to external parties) Time and resources needed to implement the strategy
Effectiveness of the strategy (e.g., partial containment, full containment)
Duration of the solution (e.g., emergency workaround to be removed in four hours, temporary workaround to be removed in two weeks, permanent solution).
In certain cases, some organizations redirect the attacker to a sandbox (a form of containment) so that they can monitor the attacker’s activity, usually to gather additional evidence. The incident response team should discuss this strategy with its legal department to determine if it is feasible. Ways of monitoring an attacker’s activity other than sandboxing should not be used; if an organization knows that a system has been compromised and allows the compromise to continue, it may be liable if the attacker uses the compromised system to attack other systems. The delayed containment strategy is dangerous because an attacker could escalate unauthorized access or compromise other systems.
Another potential issue regarding containment is that some attacks may cause additional damage when they are contained. For example, a compromised host may run a malicious process that pings another host periodically. When the incident handler attempts to contain the incident by disconnecting the compromised host from the network, the subsequent pings will fail. As a result of the failure, the malicious process may overwrite or encrypt all the data on the host’s hard drive. Handlers should not assume that just because a host has been disconnected from the network, further damage to the host has been prevented.
# 3.3.2 Evidence Gathering and Handling
Although the primary reason for gathering evidence during an incident is to resolve the incident, it may also be needed for legal proceedings.42 In such cases, it is important to clearly document how all evidence, including compromised systems, has been preserved.43 Evidence should be collected according to procedures that meet all applicable laws and regulations that have been developed from previous discussions with legal staff and appropriate law enforcement agencies so that any evidence can be admissible in court.44 In addition, evidence should be accounted for at all times; whenever evidence is transferred from person to person, chain of custody forms should detail the transfer and include each party’s signature. A detailed log should be kept for all evidence, including the following:
Identifying information (e.g., the location, serial number, model number, hostname, media access control (MAC) addresses, and IP addresses of a computer)
Name, title, and phone number of each individual who collected or handled the evidence during the investigation
Time and date (including time zone) of each occurrence of evidence handling
Locations where the evidence was stored.
Collecting evidence from computing resources presents some challenges. It is generally desirable to acquire evidence from a system of interest as soon as one suspects that an incident may have occurred. Many incidents cause a dynamic chain of events to occur; an initial system snapshot may do more good in identifying the problem and its source than most other actions that can be taken at this stage. From an evidentiary standpoint, it is much better to get a snapshot of the system as-is rather than doing so after incident handlers, system administrators, and others have inadvertently altered the state of the machine during the investigation. Users and system administrators should be made aware of the steps that they should take to preserve evidence. See NIST SP 800-86, Guide to Integrating Forensic Techniques into Incident Response, for additional information on preserving evidence.
# 3.3.3 Identifying the Attacking Hosts
During incident handling, system owners and others sometimes want to or need to identify the attacking host or hosts. Although this information can be important, incident handlers should generally stay focused on containment, eradication, and recovery. Identifying an attacking host can be a time-consuming and futile process that can prevent a team from achieving its primary goal—minimizing the business impact. The following items describe the most commonly performed activities for attacking host identification:
Validating the Attacking Host’s IP Address. New incident handlers often focus on the attacking host’s IP address. The handler may attempt to validate that the address was not spoofed by verifying connectivity to it; however, this simply indicates that a host at that address does or does not respond to the requests. A failure to respond does not mean the address is not real—for example, a host may be configured to ignore pings and traceroutes. Also, the attacker may have received a dynamic address that has already been reassigned to someone else.
Researching the Attacking Host through Search Engines. Performing an Internet search using the apparent source IP address of an attack may lead to more information on the attack—for example, a mailing list message regarding a similar attack.
Using Incident Databases. Several groups collect and consolidate incident data from various organizations into incident databases. This information sharing may take place in many forms, such as trackers and real-time blacklists. The organization can also check its own knowledge base or issue tracking system for related activity.
Monitoring Possible Attacker Communication Channels. Incident handlers can monitor communication channels that may be used by an attacking host. For example, many bots use IRC as their primary means of communication. Also, attackers may congregate on certain IRC channels to brag about their compromises and share information. However, incident handlers should treat any such information that they acquire only as a potential lead, not as fact.
# 3.3.4 Eradication and Recovery
After an incident has been contained, eradication may be necessary to eliminate components of the incident, such as deleting malware and disabling breached user accounts, as well as identifying and mitigating all vulnerabilities that were exploited. During eradication, it is important to identify all affected hosts within the organization so that they can be remediated. For some incidents, eradication is either not necessary or is performed during recovery.
In recovery, administrators restore systems to normal operation, confirm that the systems are functioning normally, and (if applicable) remediate vulnerabilities to prevent similar incidents. Recovery may involve such actions as restoring systems from clean backups, rebuilding systems from scratch, replacing compromised files with clean versions, installing patches, changing passwords, and tightening network perimeter security (e.g., firewall rulesets, boundary router access control lists). Higher levels of system logging or network monitoring are often part of the recovery process. Once a resource is successfully attacked, it is often attacked again, or other resources within the organization are attacked in a similar manner.
Eradication and recovery should be done in a phased approach so that remediation steps are prioritized. For large-scale incidents, recovery may take months; the intent of the early phases should be to increase the overall security with relatively quick (days to weeks) high value changes to prevent future incidents. The later phases should focus on longer-term changes (e.g., infrastructure changes) and ongoing work to keep the enterprise as secure as possible.
Because eradication and recovery actions are typically OS or application-specific, detailed recommendations and advice regarding them are outside the scope of this document.
# 3.4 Post-Incident Activity
Incident Response Life Cycle (Post-Incident Activity)
# 3.4.1 Lessons Learned
One of the most important parts of incident response is also the most often omitted: learning and improving. Each incident response team should evolve to reflect new threats, improved technology, and lessons learned. Holding a “lessons learned” meeting with all involved parties after a major incident, and optionally periodically after lesser incidents as resources permit, can be extremely helpful in improving security measures and the incident handling process itself. Multiple incidents can be covered in a single lessons learned meeting. This meeting provides a chance to achieve closure with respect to an incident by reviewing what occurred, what was done to intervene, and how well intervention worked. The meeting should be held within several days of the end of the incident. Questions to be answered in the meeting include:
Exactly what happened, and at what times?
How well did staff and management perform in dealing with the incident? Were the documented procedures followed? Were they adequate?
What information was needed sooner?
Were any steps or actions taken that might have inhibited the recovery?
What would the staff and management do differently the next time a similar incident occurs?
How could information sharing with other organizations have been improved?
What corrective actions can prevent similar incidents in the future?
■ What precursors or indicators should be watched for in the future to detect similar incidents?
What additional tools or resources are needed to detect, analyze, and mitigate future incidents?
Small incidents need limited post-incident analysis, with the exception of incidents performed through new attack methods that are of widespread concern and interest. After serious attacks have occurred, it is usually worthwhile to hold post-mortem meetings that cross team and organizational boundaries to provide a mechanism for information sharing. The primary consideration in holding such meetings is ensuring that the right people are involved. Not only is it important to invite people who have been involved in the incident that is being analyzed, but also it is wise to consider who should be invited for the purpose of facilitating future cooperation.
The success of such meetings also depends on the agenda. Collecting input about expectations and needs (including suggested topics to cover) from participants before the meeting increases the likelihood that the participants’ needs will be met. In addition, establishing rules of order before or during the start of a meeting can minimize confusion and discord. Having one or more moderators who are skilled in group facilitation can yield a high payoff. Finally, it is also important to document the major points of agreement and action items and to communicate them to parties who could not attend the meeting.
Lessons learned meetings provide other benefits. Reports from these meetings are good material for training new team members by showing them how more experienced team members respond to incidents. Updating incident response policies and procedures is another important part of the lessons learned process. Post-mortem analysis of the way an incident was handled will often reveal a missing step or an inaccuracy in a procedure, providing impetus for change. Because of the changing nature of information technology and changes in personnel, the incident response team should review all related documentation and procedures for handling incidents at designated intervals.
Another important post-incident activity is creating a follow-up report for each incident, which can be quite valuable for future use. The report provides a reference that can be used to assist in handling similar incidents. Creating a formal chronology of events (including timestamped information such as log data from systems) is important for legal reasons, as is creating a monetary estimate of the amount of damage the incident caused. This estimate may become the basis for subsequent prosecution activity by entities such as the U.S. Attorney General’s office. Follow-up reports should be kept for a period of time as specified in record retention policies.45
# 3.4.2 Using Collected Incident Data
Lessons learned activities should produce a set of objective and subjective data regarding each incident. Over time, the collected incident data should be useful in several capacities. The data, particularly the total hours of involvement and the cost, may be used to justify additional funding of the incident response team. A study of incident characteristics may indicate systemic security weaknesses and threats, as well as changes in incident trends. This data can be put back into the risk assessment process, ultimately leading to the selection and implementation of additional controls. Another good use of the data is measuring the success of the incident response team. If incident data is collected and stored properly, it should provide several measures of the success (or at least the activities) of the incident response team. Incident data can also be collected to determine if a change to incident response capabilities causes a corresponding change in the team’s performance (e.g., improvements in efficiency, reductions in costs). Furthermore, organizations that are required to report incident information will need to collect the
necessary data to meet their requirements. See Section 4 for additional information on sharing incident data with other organizations.
Organizations should focus on collecting data that is actionable, rather than collecting data simply because it is available. For example, counting the number of precursor port scans that occur each week and producing a chart at the end of the year that shows port scans increased by eight percent is not very helpful and may be quite time-consuming. Absolute numbers are not informative—understanding how they represent threats to the business processes of the organization is what matters. Organizations should decide what incident data to collect based on reporting requirements and on the expected return on investment from the data (e.g., identifying a new threat and mitigating the related vulnerabilities before they can be exploited.) Possible metrics for incident-related data include:
Number of Incidents Handled.46 Handling more incidents is not necessarily better—for example, the number of incidents handled may decrease because of better network and host security controls, not because of negligence by the incident response team. The number of incidents handled is best taken as a measure of the relative amount of work that the incident response team had to perform, not as a measure of the quality of the team, unless it is considered in the context of other measures that collectively give an indication of work quality. It is more effective to produce separate incident counts for each incident category. Subcategories also can be used to provide more information. For example, a growing number of incidents performed by insiders could prompt stronger policy provisions concerning background investigations for personnel and misuse of computing resources and stronger security controls on internal networks (e.g., deploying intrusion detection software to more internal networks and hosts).
Time Per Incident. For each incident, time can be measured in several ways:
Total amount of labor spent working on the incident
Elapsed time from the beginning of the incident to incident discovery, to the initial impact assessment, and to each stage of the incident handling process (e.g., containment, recovery) How long it took the incident response team to respond to the initial report of the incident How long it took to report the incident to management and, if necessary, appropriate external entities (e.g., US-CERT).
Objective Assessment of Each Incident. The response to an incident that has been resolved can be analyzed to determine how effective it was. The following are examples of performing an objective assessment of an incident:
Reviewing logs, forms, reports, and other incident documentation for adherence to established
incident response policies and procedures
Identifying which precursors and indicators of the incident were recorded to determine how
effectively the incident was logged and identified
Determining if the incident caused damage before it was detected
Determining if the actual cause of the incident was identified, and identifying the vector of attack, the vulnerabilities exploited, and the characteristics of the targeted or victimized systems, networks, and applications 一 Determining if the incident is a recurrence of a previous incident Calculating the estimated monetary damage from the incident (e.g., information and critical business processes negatively affected by the incident) Measuring the difference between the initial impact assessment and the final impact assessment (see Section 3.2.6) 一 Identifying which measures, if any, could have prevented the incident.
Subjective Assessment of Each Incident. Incident response team members may be asked to assess their own performance, as well as that of other team members and of the entire team. Another valuable source of input is the owner of a resource that was attacked, in order to determine if the owner thinks the incident was handled efficiently and if the outcome was satisfactory.
Besides using these metrics to measure the team’s success, organizations may also find it useful to periodically audit their incident response programs. Audits will identify problems and deficiencies that can then be corrected. At a minimum, an incident response audit should evaluate the following items against applicable regulations, policies, and generally accepted practices:
Incident response policies, plans, and procedures Tools and resources Team model and structure
Incident handler training and education
Incident documentation and reports
The measures of success discussed earlier in this section.
# 3.4.3 Evidence Retention
Organizations should establish policy for how long evidence from an incident should be retained. Most organizations choose to retain all evidence for months or years after the incident ends. The following factors should be considered during the policy creation:
Prosecution. If it is possible that the attacker will be prosecuted, evidence may need to be retained until all legal actions have been completed. In some cases, this may take several years. Furthermore, evidence that seems insignificant now may become more important in the future. For example, if an attacker is able to use knowledge gathered in one attack to perform a more severe attack later, evidence from the first attack may be key to explaining how the second attack was accomplished.
Data Retention. Most organizations have data retention policies that state how long certain types of data may be kept. For example, an organization may state that email messages should be retained for only 180 days. If a disk image contains thousands of emails, the organization may not want the image to be kept for more than 180 days unless it is absolutely necessary. As discussed in Section 3.4.2, General Records Schedule (GRS) 24 specifies that incident handling records should be kept for three years.
Cost. Original hardware (e.g., hard drives, compromised systems) that is stored as evidence, as well as hard drives and removable media that are used to hold disk images, are generally individually inexpensive. However, if an organization stores many such components for years, the cost can be substantial. The organization also must retain functional computers that can use the stored hardware and media.
# 3.5 Incident Handling Checklist
The checklist in provides the major steps to be performed in the handling of an incident. Note that the actual steps performed may vary based on the type of incident and the nature of individual incidents. For example, if the handler knows exactly what has happened based on analysis of indicators (Step 1.1), there may be no need to perform Steps 1.2 or 1.3 to further research the activity. The checklist provides guidelines to handlers on the major steps that should be performed; it does not dictate the exact sequence of steps that should always be followed.
Incident Handling Checklist
# 3.6 Recommendations
The key recommendations presented in this section for handling incidents are summarized below.
Acquire tools and resources that may be of value during incident handling. The team will be more efficient at handling incidents if various tools and resources are already available to them. Examples include contact lists, encryption software, network diagrams, backup devices, digital forensic software, and port lists.
Prevent incidents from occurring by ensuring that networks, systems, and applications are sufficiently secure. Preventing incidents is beneficial to the organization and also reduces the workload of the incident response team. Performing periodic risk assessments and reducing the identified risks to an acceptable level are effective in reducing the number of incidents. Awareness of security policies and procedures by users, IT staff, and management is also very important.
Identify precursors and indicators through alerts generated by several types of security software. Intrusion detection and prevention systems, antivirus software, and file integrity checking software are valuable for detecting signs of incidents. Each type of software may detect incidents that the other types of software cannot, so the use of several types of computer security software is highly recommended. Third-party monitoring services can also be helpful.
Establish mechanisms for outside parties to report incidents. Outside parties may want to report incidents to the organization—for example, they may believe that one of the organization’s users is attacking them. Organizations should publish a phone number and email address that outside parties can use to report such incidents.
Require a baseline level of logging and auditing on all systems, and a higher baseline level on all critical systems. Logs from operating systems, services, and applications frequently provide value during incident analysis, particularly if auditing was enabled. The logs can provide information such as which accounts were accessed and what actions were performed.
Profile networks and systems. Profiling measures the characteristics of expected activity levels so that changes in patterns can be more easily identified. If the profiling process is automated, deviations from expected activity levels can be detected and reported to administrators quickly, leading to faster detection of incidents and operational issues.
Understand the normal behaviors of networks, systems, and applications. Team members who understand normal behavior should be able to recognize abnormal behavior more easily. This knowledge can best be gained by reviewing log entries and security alerts; the handlers should become familiar with the typical data and can investigate the unusual entries to gain more knowledge.
Create a log retention policy. Information regarding an incident may be recorded in several places. Creating and implementing a log retention policy that specifies how long log data should be maintained may be extremely helpful in analysis because older log entries may show reconnaissance activity or previous instances of similar attacks.
Perform event correlation. Evidence of an incident may be captured in several logs. Correlating events among multiple sources can be invaluable in collecting all the available information for an incident and validating whether the incident occurred.
Keep all host clocks synchronized. If the devices reporting events have inconsistent clock settings, event correlation will be more complicated. Clock discrepancies may also cause issues from an evidentiary standpoint.
Maintain and use a knowledge base of information. Handlers need to reference information quickly during incident analysis; a centralized knowledge base provides a consistent, maintainable source of information. The knowledge base should include general information, such as data on precursors and indicators of previous incidents.
# Start recording all information as soon as the team suspects that an incident has occurred.
Every step taken, from the time the incident was detected to its final resolution, should be documented and timestamped. Information of this nature can serve as evidence in a court of law if legal prosecution is pursued. Recording the steps performed can also lead to a more efficient, systematic, and less error-prone handling of the problem.
Safeguard incident data. It often contains sensitive information regarding such things as vulnerabilities, security breaches, and users that may have performed inappropriate actions. The team should ensure that access to incident data is restricted properly, both logically and physically.
Prioritize handling of the incidents based on the relevant factors. Because of resource limitations, incidents should not be handled on a first-come, first-served basis. Instead, organizations should establish written guidelines that outline how quickly the team must respond to the incident and what actions should be performed, based on relevant factors such as the functional and information impact of the incident, and the likely recoverability from the incident. This saves time for the incident handlers and provides a justification to management and system owners for their actions. Organizations should also establish an escalation process for those instances when the team does not respond to an incident within the designated time.
Include provisions regarding incident reporting in the organization’s incident response policy. Organizations should specify which incidents must be reported, when they must be reported, and to whom. The parties most commonly notified are the CIO, head of information security, local information security officer, other incident response teams within the organization, and system owners.
Establish strategies and procedures for containing incidents. It is important to contain incidents quickly and effectively to limit their business impact. Organizations should define acceptable risks in containing incidents and develop strategies and procedures accordingly. Containment strategies should vary based on the type of incident.
Follow established procedures for evidence gathering and handling. The team should clearly document how all evidence has been preserved. Evidence should be accounted for at all times. The team should meet with legal staff and law enforcement agencies to discuss evidence handling, then develop procedures based on those discussions.
Capture volatile data from systems as evidence. This includes lists of network connections, processes, login sessions, open files, network interface configurations, and the contents of memory. Running carefully chosen commands from trusted media can collect the necessary information without damaging the system’s evidence.
Obtain system snapshots through full forensic disk images, not file system backups. Disk images should be made to sanitized write-protectable or write-once media. This process is superior to a file system backup for investigatory and evidentiary purposes. Imaging is also valuable in that it is much safer to analyze an image than it is to perform analysis on the original system because the analysis may inadvertently alter the original.
Hold lessons learned meetings after major incidents. Lessons learned meetings are extremely helpful in improving security measures and the incident handling process itself.
The nature of contemporary threats and attacks makes it more important than ever for organizations to work together during incident response. Organizations should ensure that they effectively coordinate portions of their incident response activities with appropriate partners. The most important aspect of incident response coordination is information sharing, where different organizations share threat, attack, and vulnerability information with each other so that each organization’s knowledge benefits the other. Incident information sharing is frequently mutually beneficial because the same threats and attacks often affect multiple organizations simultaneously.
As mentioned in Section 2, coordinating and sharing information with partner organizations can strengthen the organization’s ability to effectively respond to IT incidents. For example, if an organization identifies some behavior on its network that seems suspicious and sends information about the event to a set of trusted partners, someone else in that network may have already seen similar behavior and be able to respond with additional details about the suspicious activity, including signatures, other indicators to look for, or suggested remediation actions. Collaboration with the trusted partner can enable an organization to respond to the incident more quickly and efficiently than an organization operating in isolation.
This increase in efficiency for standard incident response techniques is not the only incentive for crossorganization coordination and information sharing. Another incentive for information sharing is the ability to respond to incidents using techniques that may not be available to a single organization, especially if that organization is small to medium size. For example, a small organization that identifies a particularly complex instance of malware on its network may not have the in-house resources to fully analyze the malware and determine its effect on the system. In this case, the organization may be able to leverage a trusted information sharing network to effectively outsource the analysis of this malware to third party resources that have the adequate technical capabilities to perform the malware analysis.
This section of the document highlights coordination and information sharing. Section 4.1 presents an overview of incident response coordination and focuses on the need for cross-organization coordination to supplement organization incident response processes. Section 4.2 discusses techniques for information sharing across organizations, and Section 4.3 examines how to restrict what information is shared or not shared with other organizations.
# 4.1 Coordination
As discussed in Section 2.3.4, an organization may need to interact with several types of external organizations in the course of conducting incident response activities. Examples of these organizations include other incident response teams, law enforcement agencies, Internet service providers, and constituents and customers. An organization’s incident response team should plan its incident coordination with those parties before incidents occur to ensure that all parties know their roles and that effective lines of communication are established. provides a sample view into an organization performing coordination at every phase of the incident response lifecycle, highlighting that coordination is valuable throughout the lifecycle.
Incident Response Coordination
# 4.1.1 Coordination Relationships
An incident response team within an organization may participate in different types of coordination arrangements, depending on the type of organization with which it is coordinating. For example, the team members responsible for the technical details of incident response may coordinate with operational colleagues at partner organizations to share strategies for mitigating an attack spanning multiple organizations. Alternatively, during the same incident, the incident response team manager may coordinate with ISACs to satisfy necessary reporting requirements and seek advice and additional resources for successfully responding to the incident. provides some examples of coordination relationships that may exist when collaborating with outside organizations.
Coordination Relationships
Organizations may find it challenging to build the relationships needed for coordination. Good places to start building a community include the industry sector that the organization belongs to and the geographic region where the organization operates. An organization’s incident response team can try to form relationships with other teams (at the team-to-team level) within its own industry sector and region, or join established bodies within the industry sector that already facilitate information sharing. Another consideration for building relationships is that some relationships are mandatory and others voluntary; for example, team-to-coordinating team relationships are often mandatory, while team-to-team relationships are usually voluntary. Organizations pursue voluntary relationships because they fulfill mutual selfinterests. Mandatory relationships are usually defined by a regulatory body within the industry or by another entity.
# 4.1.2 Sharing Agreements and Reporting Requirements
Organizations trying to share information with external organizations should consult with their legal department before initiating any coordination efforts. There may be contracts or other agreements that need to be put into place before discussions occur. An example is a nondisclosure agreement (NDA) to protect the confidentiality of the organization’s most sensitive information. Organizations should also consider any existing requirements for reporting, such as sharing incident information with an ISAC or reporting incidents to a higher-level CIRT.
# 4.2 Information Sharing Techniques
Information sharing is a key element of enabling coordination across organizations. Even the smallest organizations need to be able to share incident information with peers and partners in order to deal with many incidents effectively. Organizations should perform such information sharing throughout the incident response life cycle and not wait until an incident has been fully resolved before sharing details of it with others. Section 4.3 discusses the types of incident information that organizations may or may not want to share with others.
This section focuses on techniques for information sharing. Section 4.2.1 looks at ad hoc methods, while Section 4.2.2 examines partially automated methods. Finally, Section 4.2.3 discusses security considerations related to information sharing.
# 4.2.1 Ad Hoc
Most incident information sharing has traditionally occurred through ad hoc methods, such as email, instant messaging clients, and phone. Ad hoc information sharing mechanisms normally rely on an individual employee’s connections with employees in incident response teams of partner organizations. The employee uses these connections to manually share information with peers and coordinate with them to construct strategies for responding to an incident. Depending on the size of the organization, these ad hoc techniques may be the most cost-effective way of sharing information with partner organizations. However, due to the informal nature of ad hoc information sharing, it is not possible to guarantee that the information sharing processes will always operate. For example, if a particularly well-connected employee resigns from an incident response team, that team may temporarily lose the majority of information sharing channels it relies on to effectively coordinate with outside organizations.
Ad hoc information sharing methods are also largely unstandardized in terms of what information is communicated and how that communication occurs. Because of the lack of standardization, they tend to require manual intervention and to be more resource-intensive to process than the alternative, partially automated methods. Whenever possible an organization should attempt to formalize its information sharing strategies through formal agreements with partner organizations and technical mechanisms that will help to partially automate the sharing of information.
# 4.2.2 Partially Automated
Organizations should attempt to automate as much of the information sharing process as possible to make cross-organizational coordination efficient and cost effective. In reality, it will not be possible to fully automate the sharing of all incident information, nor will it be desirable due to security and trust considerations. Organizations should attempt to achieve a balance of automated information sharing overlaid with human-centric processes for managing the information flow.
When engineering automated information sharing solutions, organizations should first consider what types of information they will communicate with partners. The organization may want to construct a formal data dictionary enumerating all entities and relationships between entities that they will wish to share. Once the organization understands the types of information they will share, it is necessary to construct formal, machine-processable models to capture this information. Wherever possible, an organization should use existing data exchange standards for representing the information they need to share.47 The organization should work with its partner organizations when deciding on the data exchange models to ensure that the standards selected are compatible with the partner organization’s incident response systems. When selecting existing data exchange models, organizations may prefer to select multiple models that model different aspects of the incident response domain and then leverage these models in a modular fashion, communicating only the information needed at a specific decision point in the life cycle. Appendix E provides a non-exhaustive list of existing standards defining data exchange models that are applicable to the incident response domain.
In addition to selecting the data exchange models for sharing incident information, an organization must also work with its partner organizations to agree on the technical transport mechanisms for enabling the information exchange to occur in an automated fashion. These transport mechanisms include, at a minimum, the transport protocol for exchanging the information, the architectural model for communicating with an information resource, and the applicable ports and domain names for accessing an information resource in a particular organization. For example, a group of partner organizations may decide to exchange incident information using a Representational State Transfer (REST) architecture to exchange IODEF/Real-Time Inter-Network Defense (RID) data over Hypertext Transfer Protocol Secure (HTTPS) on port 4590 of a specific domain name within each organization’s DMZ.
# 4.2.3 Security Considerations
There are several security considerations that incident response teams should consider when planning their information sharing. One is being able to designate who can see which pieces of incident information (e.g., protection of sensitive information). It may also be necessary to perform data sanitization or scrubbing to remove sensitive pieces of data from the incident information without disturbing the information on precursors, indicators, and other technical information. See Section 4.3 for more information on granular information sharing. The incident response team should also ensure that the necessary measures are taken to protect information shared with the team by other organizations.
There are also many legal issues to consider regarding data sharing. See Section 4.1.2 for additional information.
# 4.3 Granular Information Sharing
Organizations need to balance the benefits of information sharing with the drawbacks of sharing sensitive information, ideally sharing the necessary information and only the necessary information with the appropriate parties. Organizations can think of their incident information as being comprised of two types of information: business impact and technical. Business impact information is often shared in the context of a team-to-coordinating-team relationship as defined in Section 4.1.1, while technical information is often shared within all three types of coordination relationships. This section discusses both types of information and provides recommendations for performing granular information sharing.
# 4.3.1 Business Impact Information
Business impact information involves how the incident is affecting the organization in terms of mission impact, financial impact, etc. Such information, at least at a summary level, is often reported to higherlevel coordinating incident response teams to communicate an estimate of the damage caused by the incident. Coordinating response teams may need this impact information to make decisions regarding the degree of assistance to provide to the reporting organization. A coordinating team may also use this information to make decisions relative to how a specific incident will affect other organizations in the community they represent.
Coordinating teams may require member organizations to report on some degree of business impact information. For example, a coordinating team may require a member organization to report impact information using the categories defined in Section 3.2.6. In this case, for a hypothetical incident an organization would report that it has a functional impact of medium, an information impact of none, and will require extended recoverability time. This high-level information would alert the coordinating team that the member organization requires some level of additional resources to recover from the incident. The coordinating team could then pursue additional communication with the member organization to determine how many resources are required as well as the type of resources based on the technical information provided about the incident.
Business impact information is only useful for reporting to organizations that have some interest in ensuring the mission of the organization experiencing the incident. In many cases, incident response teams should avoid sharing business impact information with outside organizations unless there is a clear value proposition or formal reporting requirements. When sharing information with peer and partner organizations, incident response teams should focus on exchanging technical information as outlined in Section 4.3.2.
# 4.3.2 Technical Information
There are many different types of technical indicators signifying the occurrence of an incident within an organization. These indicators originate from the variety of technical information associated with incidents, such as the hostnames and IP addresses of attacking hosts, samples of malware, precursors and indicators of similar incidents, and types of vulnerabilities exploited in an incident. Section 3.2.2 provides an overview of how organizations should collect and utilize these indicators to help identify an incident that is in progress. In addition, Section 3.2.3 provides a listing of common sources of incident indicator data.
While organizations gain value from collecting their own internal indicators, they may gain additional value from analyzing indicators received from partner organizations and sharing internal indicators for external analysis and use. If the organization receives external indicator data pertaining to an incident they have not seen, they can use that indicator data to identify the incident as it begins to occur. Similarly, an organization may use external indicator data to detect an ongoing incident that it was not aware of due to the lack of internal resources to capture the specific indicator data. Organizations may also benefit from sharing their internal indicator data with external organizations. For example, if they share technical information pertaining to an incident they are experiencing, a partner organization may respond with a suggested remediation strategy for handling that incident.
Organizations should share as much of this information as possible; however, there may be both security and liability reasons why an organization would not want to reveal the details of an exploited vulnerability. External indicators, such as the general characteristics of attacks and the identity of attacking hosts, are usually safe to share with others. Organizations should consider which types of technical information should or should not be shared with various parties, and then endeavor to share as much of the appropriate information as possible with other organizations.
Technical indicator data is useful when it allows an organization to identify an actual incident. However, not all indicator data received from external sources will pertain to the organization receiving it. In some cases, this external data will generate false positives within the receiving organization's network and may cause resources to be spent on nonexistent problems.
Organizations participating in incident information sharing should have staff skilled in taking technical indicator information from sharing communities and disseminating that information throughout the enterprise, preferably in an automated way. Organizations should also attempt to ensure that they only share an indicator for which they have a relatively high level of confidence that it signifies an actual incident.
# 4.4 Recommendations
The key recommendations presented in this section for handling incidents are summarized below.
Plan incident coordination with external parties before incidents occur. Examples of external parties include other incident response teams, law enforcement agencies, Internet service providers, and constituents and customers. This planning helps ensure that all parties know their roles and that effective lines of communication are established.
Consult with the legal department before initiating any coordination efforts. There may be contracts or other agreements that need to be put into place before discussions occur.
Perform incident information sharing throughout the incident response life cycle. Information sharing is a key element of enabling coordination across organizations. Organizations should not wait until an incident has been fully resolved before sharing details of it with others.
Attempt to automate as much of the information sharing process as possible. This makes crossorganizational coordination efficient and cost effective. Organizations should attempt to achieve a balance of automated information sharing overlaid with human-centric processes for managing the information flow.
Balance the benefits of information sharing with the drawbacks of sharing sensitive information. Ideally organizations should share the necessary information and only the necessary information with the appropriate parties. Business impact information is often shared in a team-tocoordinating team relationship, while technical information is often shared within all types of coordination relationships. When sharing information with peer and partner organizations, incident response teams should focus on exchanging technical information.
Share as much of the appropriate incident information as possible with other organizations. Organizations should consider which types of technical information should or should not be shared with various parties. For example, external indicators, such as the general characteristics of attacks and the identity of attacking hosts, are usually safe to share with others, but there may be both security and liability reasons why an organization would not want to reveal the details of an exploited vulnerability.
Incident handling scenarios provide an inexpensive and effective way to build incident response skills and identify potential issues with incident response processes. The incident response team or team members are presented with a scenario and a list of related questions. The team then discusses each question and determines the most likely answer. The goal is to determine what the team would really do and to compare that with policies, procedures, and generally recommended practices to identify discrepancies or deficiencies. For example, the answer to one question may indicate that the response would be delayed because the team lacks a piece of software or because another team does not provide off-hours support.
Organizations should identify a standard set of incident-related data elements to be collected for each incident. This effort will not only facilitate more effective and consistent incident handling, but also assist the organization in meeting applicable incident reporting requirements. The organization should designate a set of basic elements (e.g., incident reporter’s name, phone number, and location) to be collected when the incident is reported and an additional set of elements to be collected by the incident handlers during their response. The two sets of elements would be the basis for the incident reporting database, previously discussed in Section 3.2.5. The lists below provide suggestions of what information to collect for incidents and are not intended to be comprehensive. Each organization should create its own list of elements based on several factors, including its incident response team model and structure and its definition of the term “incident.”
# B.1 Basic Data Elements
Contact Information for the Incident Reporter and Handler
Organizational unit (e.g., agency, department, division, team) and affiliation
Email address
Phone number
Location (e.g., mailing address, office room number)
Incident Details
Status change date/timestamps (including time zone): when the incident started, when the incident was discovered/detected, when the incident was reported, when the incident was resolved/ended, etc.
Physical location of the incident (e.g., city, state)
Current status of the incident (e.g., ongoing attack)
Source/cause of the incident (if known), including hostnames and IP addresses
Description of the incident (e.g., how it was detected, what occurred)
Description of affected resources (e.g., networks, hosts, applications, data), including systems’ hostnames, IP addresses, and function
If known, incident category, vectors of attack associated with the incident, and indicators related to the incident (traffic patterns, registry keys, etc.)
Prioritization factors (functional impact, information impact, recoverability, etc.)
Mitigating factors (e.g., stolen laptop containing sensitive data was using full disk encryption) Response actions performed (e.g., shut off host, disconnected host from network)
Other organizations contacted (e.g., software vendor)
General Comments
# B.2 Incident Handler Data Elements
Current Status of the Incident Response
Summary of the Incident
Incident Handling Actions
Log of actions taken by all handlers Contact information for all involved parties List of evidence gathered
Incident Handler Comments
Cause of the Incident (e.g., misconfigured application, unpatched host)
Cost of the Incident
Business Impact of the Incident49
# Appendix C—Glossary
Selected terms used in the publication are defined below.
Baselining: Monitoring resources to determine typical utilization patterns so that significant deviations can be detected.
Computer Security Incident: See “incident.”
Computer Security Incident Response Team (CSIRT): A capability set up for the purpose of assisting in responding to computer security-related incidents; also called a Computer Incident Response Team (CIRT) or a CIRC (Computer Incident Response Center, Computer Incident Response Capability).
Event: Any observable occurrence in a network or system.
False Positive: An alert that incorrectly indicates that malicious activity is occurring.
Incident: A violation or imminent threat of violation of computer security policies, acceptable use policies, or standard security practices.
Incident Handling: The mitigation of violations of security policies and recommended practices.
Incident Response: See “incident handling.”
Indicator: A sign that an incident may have occurred or may be currently occurring.
Intrusion Detection and Prevention System (IDPS): Software that automates the process of monitoring the events occurring in a computer system or network and analyzing them for signs of possible incidents and attempting to stop detected possible incidents.
Malware: A virus, worm, Trojan horse, or other code-based malicious entity that successfully infects a host.
Precursor: A sign that an attacker may be preparing to cause an incident.
Profiling: Measuring the characteristics of expected activity so that changes to it can be more easily identified.
Signature: A recognizable, distinguishing pattern associated with an attack, such as a binary string in a virus or a particular set of keystrokes used to gain unauthorized access to a system.
Social Engineering: An attempt to trick someone into revealing information (e.g., a password) that can be used to attack systems or networks.
Threat: The potential source of an adverse event.
Vulnerability: A weakness in a system, application, or network that is subject to exploitation or misuse.
Selected acronyms used in the publication are defined below.
1. CERIAS
2. CERT®/C
3. GFIRST
Computer Crime and Intellectual Property Section Center for Education and Research in Information Assurance a C CERT® Coordination Center Chief Information Officer Computer Incident Response Capability Computer Incident Response Center Computer Incident Response Team Chief Information Security Officer Computer Security Incident Response Capability Computer Security Incident Response Team Distributed Denial of Service Department of Homeland Security Domain Name System Denial of Service Frequently Asked Questions Federal Bureau of Investigation Federal Information Processing Standards Forum of Incident Response and Security Teams Federal Information Security Management Act General Accountability Office Government Forum of Incident Response and Security Teams General Records Schedule HyperText Transfer Protocol Internet Assigned Numbers Authority Intrusion Detection and Prevention System Internet Engineering Task Force Internet Protocol Interagency Report Internet Relay Chat Information Sharing and Analysis Center Internet Service Provider Information Technology Information Technology Laboratory Media Access Control Memorandum of Understanding Managed Security Services Provider Network Address Translation Non-Disclosure Agreement National Institute of Standards and Technology National Software Reference Library Network Time Protocol National Vulnerability Database Office of Inspector General Office of Management and Budget Operating System Personally Identifiable Information Personal Identification Number
POC Point of Contact EN-ISAC Research and Education Networking Information Sharing and Analysis Center
RFC Request for Comment
RID Real-Time Inter-Network Defense
SIEM Security Information and Event Management LA Service Level Agreement
SOP Standard Operating Procedure
SP Special Publication
TCP Transmission Control Protocol
TCP/IP Transmission Control Protocol/Internet Protocol
TERENA Trans-European Research and Education Networking Association
UDP User Datagram Protocol
URL Uniform Resource Locator S-CERT United States Computer Emergency Readiness Team
VPN Virtual Private Network
The lists below provide examples of resources that may be helpful in establishing and maintaining an incident response capability.
# Incident Response Organizations
# NIST Publications
# Data Exchange Specifications Applicable to Incident Handling
Users, system administrators, information security staff members, and others within organizations may have questions about incident response. The following are frequently asked questions (FAQ). Organizations are encouraged to customize this FAQ and make it available to their user community.
# 1\. What is an incident?
In general, an incident is a violation of computer security policies, acceptable use policies, or standard computer security practices. Examples of incidents are:
An attacker commands a botnet to send high volumes of connection requests to one of an organization’s web servers, causing it to crash.
Users are tricked into opening a “quarterly report” sent via email that is actually malware; running the tool has infected their computers and established connections with an external host.
A perpetrator obtains unauthorized access to sensitive data and threatens to release the detai to the press if the organization does not pay a designated sum of money. A user provides illegal copies of software to others through peer-to-peer file sharing services.
# 2\. What is incident handling?
Incident handling is the process of detecting and analyzing incidents and limiting the incident’s effect. For example, if an attacker breaks into a system through the Internet, the incident handling process should detect the security breach. Incident handlers will then analyze the data and determine how serious the attack is. The incident will be prioritized, and the incident handlers will take action to ensure that the progress of the incident is halted and that the affected systems return to normal operation as soon as possible.
# 3\. What is incident response?
The terms “incident handling” and “incident response” are synonymous in this document.50
# 4\. What is an incident response team?
An incident response team (also known as a Computer Security Incident Response Team \[CSIRT\]) is responsible for providing incident response services to part or all of an organization. The team receives information on possible incidents, investigates them, and takes action to ensure that the damage caused by the incidents is minimized.
# 5\. What services does the incident response team provide?
The particular services that incident response teams offer vary widely among organizations. Besides performing incident handling, most teams also assume responsibility for intrusion detection system monitoring and management. A team may also distribute advisories regarding new threats, and educate users and IT staff on their roles in incident prevention and handling.
# 6\. To whom should incidents be reported?
Organizations should establish clear points of contact (POC) for reporting incidents internally. Some organizations will structure their incident response capability so that all incidents are reported directly to the incident response team, whereas others will use existing support
structures, such as the IT help desk, for an initial POC. The organization should recognize that external parties, such as other incident response teams, would report some incidents. Federal agencies are required under the law to report all incidents to the United States Computer Emergency Readiness Team (US-CERT). All organizations are encouraged to report incidents to their appropriate Computer Security Incident Response Teams (CSIRTs). If an organization does not have its own CSIRT to contact, it can report incidents to other organizations, including Information Sharing and Analysis Centers (ISACs).
# 7\. How are incidents reported?
Most organizations have multiple methods for reporting an incident. Different reporting methods may be preferable as a result of variations in the skills of the person reporting the activity, the urgency of the incident, and the sensitivity of the incident. A phone number should be established to report emergencies. An email address may be provided for informal incident reporting, whereas a web-based form may be useful in formal incident reporting. Sensitive information can be provided to the team by using a public key published by the team to encrypt the material.
# 8\. What information should be provided when reporting an incident?
The more precise the information is, the better. For example, if a workstation appears to have been infected by malware, the incident report should include as much of the following data as practical:
The user’s name, user ID, and contact information (e.g., phone number, email address)
The workstation’s location, model number, serial number, hostname, and IP address
The date and time that the incident occurred
A step-by-step explanation of what happened, including what was done to the workstation after the infection was discovered. This explanation should be detailed, including the exact wording of messages, such as those displayed by the malware or by antivirus software alerts.
# 9\. How quickly does the incident response team respond to an incident report?
The response time depends on several factors, such as the type of incident, the criticality of the resources and data that are affected, the severity of the incident, existing Service Level Agreements (SLA) for affected resources, the time and day of the week, and other incidents that the team is handling. Generally, the highest priority is handling incidents that are likely to cause the most damage to the organization or to other organizations.
# 10\. When should a person involved with an incident contact law enforcement?
Communications with law enforcement agencies should be initiated by the incident response team members, the chief information officer (CIO), or other designated official—users, system administrators, system owners, and other involved parties should not initiate contact.
# 11\. What should someone do who discovers that a system has been attacked?
The person should immediately stop using the system and contact the incident response team. The person may need to assist in the initial handling of the incident—for instance, physically monitoring the system until incident handlers arrive to protect evidence on the system.
# 12\. What should someone do who is contacted by the media regarding an incident?
A person may answer the media’s questions in accordance with the organization’s policy regarding incidents and outside parties. If the person is not qualified to represent the organization in terms of discussing the incident, the person should make no comment regarding the incident, other than to refer the caller to the organization’s public affairs office. This will allow the public affairs office to provide accurate and consistent information to the media and the public.
This is a list of the major steps that should be performed when a technical professional believes that a
serious incident has occurred and the organization does not have an incident response capability available.
This serves as a basic reference of what to do for someone who is faced with a crisis and does not have
time to read through this entire document.
01. Document everything. This effort includes every action that is performed, every piece of evidence, and every conversation with users, system owners, and others regarding the incident.
02. Find a coworker who can provide assistance. Handling the incident will be much easier if two or more people work together. For example, one person can perform actions while the other documents them.
03. Analyze the evidence to confirm that an incident has occurred. Perform additional research as necessary (e.g., Internet search engines, software documentation) to better understand the evidence. Reach out to other technical professionals within the organization for additional help.
04. Notify the appropriate people within the organization. This should include the chief information officer (CIO), the head of information security, and the local security manager. Use discretion when discussing details of an incident with others; tell only the people who need to know and use communication mechanisms that are reasonably secure. (If the attacker has compromised email services, do not send emails about the incident.)
05. Notify US-CERT and/or other external organizations for assistance in dealing with the incident.
06. Stop the incident if it is still in progress. The most common way to do this is to disconnect affected systems from the network. In some cases, firewall and router configurations may need to be modified to stop network traffic that is part of an incident, such as a denial of service (DoS) attack.
07. Preserve evidence from the incident. Make backups (preferably disk image backups, not file system backups) of affected systems. Make copies of log files that contain evidence related to the incident.
08. Wipe out all effects of the incident. This effort includes malware infections, inappropriate materials (e.g., pirated software), Trojan horse files, and any other changes made to systems by incidents. If a system has been fully compromised, rebuild it from scratch or restore it from a known good backup.
09. Identify and mitigate all vulnerabilities that were exploited. The incident may have occurred by taking advantage of vulnerabilities in operating systems or applications. It is critical to identify such vulnerabilities and eliminate or otherwise mitigate them so that the incident does not recur.
10. Confirm that operations have been restored to normal. Make sure that data, applications, and other services affected by the incident have been returned to normal operations.
11. Create a final report. This report should detail the incident handling process. It also should provide an executive summary of what happened and how a formal incident response capability would have helped to handle the situation, mitigate the risk, and limit the damage more quickly.
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Essential Guide to the Digital Forensics Process - Fidelis Security
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https://fidelissecurity.com/cybersecurity-101/learn/digital-forensic-investigation-process/
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The digital forensics process involves identifying, preserving, analyzing, documenting, and presenting digital evidence. This article will explain each step, providing a clear understanding of how digital investigations are conducted.
## Understanding Digital Forensics
Digital forensics, a specialized branch of forensic science, focuses on recovering and investigating material from digital devices. It is vital in preventing and solving crimes committed using digital technology, including cybercrime and fraud. Retrieving and analyzing digital information, or computer forensics, involves examining digital media to uncover evidence. The growing demand for computer forensic talent underscores the importance of digital forensics in modern investigations.
Digital evidence includes a range of data types, such as logs from network activity, emails, documents, databases, and audio/video recordings, as well as digital data from mobile phones, laptops, and cloud software. This evidence is vital for presenting digital evidence in a court of law. Forensic investigators identify and collect this evidence using well-defined forensic methods to ensure its integrity and authenticity.
Beyond law enforcement agencies, digital forensics is utilized in commercial investigations and private businesses for audits and compliance. Companies rely on digital forensics to uncover fraud, ensure data protection, and maintain regulatory compliance. The growing variety of digital evidence types necessitates the use of advanced forensic tools and techniques, making digital forensics an ever evolving and essential field.
## Phases of a Digital Forensics Investigation
A digital forensics investigation process involves several key phases:
1. Identification
2. Preservation
3. Extraction and analysis
4. Documentation
5. Presentation
These phases ensure the effective management, integrity, and admissibility of digital evidence in court.
Each phase carries its own significance and methodologies, which will be elaborated upon.
### Identification Phase
The identification phase is the initial and one of the most critical steps in a digital forensics investigation, where forensic investigators pinpoint potential sources of digital evidence. This involves identifying a range of devices, including desktops, laptops, servers, smartphones, tablets, and external storage media.
Mobile device forensics zeroes in on smartphones and tablets as evidence sources. Investigators meticulously document all devices that may hold relevant data. This thorough identification ensures that no critical piece of evidence is overlooked during the investigation process.
### Preservation Phase
Following identification, the preservation phase secures data to maintain its integrity for future analysis. The aim is to isolate, secure, and preserve data to prevent tampering.
Tools like FTK Imager create exact digital copies, known as forensic images, without compromising the original evidence. Hardware tools, such as write blockers, maintain evidence integrity by preventing data modifications during analysis.
The original data is securely stored in a safe location. Utilizing well-defined forensic methods and secure environments is key to maintaining data integrity throughout the investigation.
### Extraction and Analysis Phase
In the extraction and analysis phase, investigators employ specialized techniques to retrieve relevant data from identified devices. This involves data acquisition, or the retrieval of Electronically Stored Information from suspected digital assets. A methodical, repeatable approach ensures reliability and accuracy in analyzing digital evidence and to store digital data.
Advanced techniques are then used to examine the extracted data for evidence, which can be presented in court. Forensic image analysis and email forensics are commonly employed to verify image file authenticity and recover deleted emails, respectively.
Digital forensic tools are essential for uncovering, analyzing, and interpreting evidence during a digital forensic investigation conducted by a digital forensic investigator using digital forensic techniques and digital investigations.
### Documentation Phase
Meticulous documentation maintains a clear record of the investigation process and its findings. This phase involves accurately documenting all findings to support the legal admissibility of evidence. Investigators must follow specific legal protocols to validate evidence collection.
Maintaining a chain of custody for all collected data is crucial, ensuring that evidence remains untampered from collection to court presentation. Proper documentation supports legal proceedings and provides transparency and accountability throughout the investigation.
### Presentation Phase
The final phase, presentation, involves compiling and communicating findings to relevant stakeholders, often requiring expert testimony to explain technical details. This ensures that all significant data is accurately represented.
Results are communicated clearly and concisely to facilitate stakeholder understanding. Expert testimony may be needed to explain the methodologies and technical findings.
This phase is crucial for ensuring that the evidence is presented effectively in legal or corporate settings.
## Tools and Techniques Used in Digital Forensics
Digital forensics employs various tools and techniques to uncover and analyze evidence, classified into open-source tools, commercial software solutions, and hardware tools. The internet and mobile device evolution has expanded digital evidence types, necessitating advanced forensic tools and techniques.
Let’s explore some of the most commonly used tools in digital forensics.
### Open-Source Tools
Open-source tools are popular in digital forensics for their accessibility and effectiveness. One such tool, The Sleuth Kit, is used for extracting and analyzing data from disk images, aiding professionals during incident response or from live systems.
Another notable open-source tool, Xplico, is a network forensic analysis tool (NFAT) with components like Decoder Manager, IP Decoder, Data Manipulators, and Visualization System, making it powerful for analyzing network traffic.
### Commercial Software Solutions
Commercial software solutions are crucial in digital forensics. FTK Imager, for instance, allows for data preview and creating forensic images, ensuring evidence integrity.
FTK Imager is a vital tool for forensic professionals conducting thorough investigations.
### Hardware Tools
Hardware tools are vital in digital forensics for effective data extraction and analysis. X-Ways Forensics is favored for manual analysis, offering robust features for disk examination. The capabilities of X-Ways Forensics allow for in-depth analysis, making it a valuable resource in the digital forensics’ toolset.
Incorporating tools like X-Ways Forensics enhances investigation thoroughness and reliability, essential for recovering deleted files and analyzing data from various devices.
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## Challenges in Digital Forensics Investigations
Digital forensics investigators face many challenges due to rapidly evolving technology and complex digital environments, including handling encrypted data, navigating cloud and IoT forensics, and addressing legal and ethical considerations.
Let’s delve into these challenges to understand their impact on digital forensics investigations.
### Handling Encrypted Data
Handling encrypted data is a major challenge in digital forensics. Advanced encryption algorithms complicate access and analysis, requiring specialized techniques and tools to decrypt data without compromising integrity.
### Cloud and IoT Forensics
Reliance on cloud services presents unique challenges for digital forensics, as analyzing cloud-stored data demands new forensic techniques due to its distributed nature. The Internet of Things (IoT) is expanding sources of digital evidence, predicted to reach 29 billion connected devices by 2030, necessitating specialized forensic expertise to manage the vast data generated.
Tools like Velociraptor and Wireshark are essential for gathering evidence from cloud and IoT environments, helping investigators understand cybercriminal tactics and uncover crucial evidence.
### Legal and Ethical Considerations
Legal and ethical considerations are vital in digital forensics. Evidence must be handled to prevent tampering and ensure court admissibility. Data jurisdiction varies by location, complicating cloud data’s legal considerations.
Investigating cloud-stored data is challenging due to varying data jurisdictions affecting legal access. Investigators must navigate these complexities while upholding ethical standards to maintain investigation integrity.
## Trends in Digital Forensics
Technological advancements continuously transform digital forensics. Machine Learning, cloud, and IoT devices are expected to significantly impact the field, with ML enhancing data analysis to uncover hidden trends and connections in large data volumes.
There will be a heightened focus on database, network forensics, and mobile device forensics. Decision intelligence platforms are emerging as powerful tools to analyze large datasets, revealing crucial insights for forensic investigations.
## How to Choose a Digital Forensics Solution
- Selecting the right digital forensics solution is critical for successful investigations.
- A reputable solution should have a strong presence in business and legal communities.
- Positive references are essential when evaluating a digital forensics provider.
- Key qualifications for professionals include education, certifications, and practical experience.
- Experience in electronic discovery and cybersecurity consulting improves efficiency.
- Digital Forensics as a Service (DFaaS) provides cloud-based forensic capabilities for advanced analysis.
## Conclusion
Digital forensics is an essential field in the modern world, playing a critical role in uncovering and analyzing digital evidence. From identifying potential sources of evidence to presenting findings in court, each phase of the digital forensics process is crucial for maintaining the integrity and authenticity of the evidence. By understanding the tools, techniques, and challenges involved, forensic professionals can effectively navigate the complexities of digital investigations and contribute to the resolution of cybercrimes and corporate audits.
## Frequently Ask Questions
### What are the 5 stages of digital forensics investigation?
The five stages of a digital forensics investigation are identification, preservation, analysis, documentation, and presentation. Following these stages ensures a thorough and effective examination of digital evidence.
### What is digital forensics?
Digital forensics is essential for investigating cybercrime, as it involves recovering and examining data from digital devices to uncover evidence. This discipline plays a critical role in enhancing cybersecurity and aiding law enforcement.
### Why is digital forensics important?
Digital forensics is crucial for addressing crimes involving digital technology and ensures that digital evidence is accurately presented in legal proceedings. This field plays a vital role in enhancing security and justice in our increasingly digital world.
### Why are mobile devices critical to a digital forensics investigation?
Mobile devices are crucial in digital forensics because they often contain valuable evidence, such as text messages, call logs, app data, and location history. As mobile usage has become pervasive, these devices hold critical information in criminal investigations, cybersecurity incidents, and civil cases. Forensics experts can extract, analyze, and preserve data from mobile devices to build a comprehensive case.
### What tools are used in digital forensics?
Digital forensics employs a range of tools such as open-source options like The Sleuth Kit, commercial software like FTK Imager, and specialized hardware like X-Ways Forensics. These tools are essential for effective investigation and analysis of digital evidence.
### What are the challenges in digital forensics?
Challenges in digital forensics include managing encrypted data, dealing with the complexities of cloud and IoT environments, and ensuring compliance with legal and ethical standards. These factors can significantly complicate investigations and evidence collection.
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What Is Digital Forensics? When IT Meets Criminal Justice
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https://www.amu.apus.edu/area-of-study/criminal-justice/resources/what-is-digital-forensics-in-criminal-justice/
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Digital technology has infiltrated nearly every aspect of modern society, and forensic investigations are no exception. Electronic devices have become integral to our jobs, communications, and even leisure activities.
As a result, we have collectively created a wealth of digital data. This data, also known as our digital footprints, serves as a record of everything we do on our tablets, desktop computers, smartphones, and other digital devices. It is generated from various activities such as conducting online searches and completing business transactions.
Naturally, a digital footprint also contains evidence of an individual or organization’s involvement in criminal activity. This digital evidence helps forensic investigators piece together clues surrounding both computer and non-computer crimes.
Due to the sheer volume of electronic evidence investigators must comb through, however, law enforcement agencies employ entire teams dedicated to the field of digital forensics.
The U.S. Department of Homeland Security defines digital forensics as “the process of recovering and preserving material found on digital devices during the course of criminal investigations.” Digital forensics is also known as computer forensics or cyber forensics.
Just as traditional forensic investigators collect physical evidence from crime scenes, digital forensic investigators collect and analyze data from computers and other electronic devices.
## What Is Digital Evidence?
If computer forensics is the process of collecting and analyzing digital forensic evidence, then what is this type of evidence? The National Institute of Standards and Technology (NIST) notes that “Digital evidence includes any information in binary form that can be useful in criminal or other legal investigations and proceedings. By its nature, digital evidence resides on physical media, but it is the content and related information, rather than the media, that are most often important.”
Based on this definition, electronics such as computers, tablets, and mobile devices are not technically electronic evidence. Rather, digital forensic evidence consists of the data contained within these electronic devices, such as cache data, cookies, and even deleted information.
## Where Does Digital Forensic Evidence Come From?
Digital investigations involve various forms of electronic data, which come from a broad range of sources. The NIST groups these sources into four categories:
- **Physical media** –Any tangible piece of technology that can store digital data – such as computers, tablets, smartphones, and flash drives – falls under this category.
- **Digital images and files** – This category consists of digital copies of the data investigators collect from physical media and cloud-based systems.
- **Other digital objects** – This category refers to online accounts and other digital content “that does not exist as an image or file,” according to the NIST.
- **Law enforcement-generated evidence** – Electronic records, including but not limited to in-car videos and footage from body-worn cameras, comprise this category.
## What Does a Digital Forensics Analyst Do?
Sometimes referred to as digital forensics investigators or computer forensic analysts, digital forensics analysts play a key role in our justice system. They “preserve and present computer-related evidence in support of criminal, fraud, counterintelligence, or law enforcement investigations,” as O\*Net explains.
Unsurprisingly, these professionals have a long list of duties. In addition to scouring files and data for useful evidence, digital forensic analysts must preserve and duplicate any electronic evidence they find.
Their role also requires them to create reports summarizing their findings. In certain cases, a digital forensic analyst may even need to give a deposition.
According to O\*Net, additional responsibilities for a digital forensic investigator may include:
- Conducting predictive or reactive analyses on cyber security measures
- Developing plans for investigating alleged digital crimes or other suspicious activities
- Developing policies for data collection, processing, or reporting
- Maintaining cyber defense software and hardware
- Understanding the laws, regulations, policies, and other concerns regarding computer forensics and information privacy
- Analyzing file signatures to verify files on storage media and discover potential hidden data
- Writing and executing scripts to automate tasks, such as assessing large data files
The role of a digital forensics analyst is unique because it combines both computer science and law enforcement.
## What Are the Different Specialty Areas in the Digital Forensics World?
Performing forensic data analysis means working with information technology in its many forms. Digital forensic science, accordingly, applies to several specialty areas:
- **Mobile device forensics** – According to the NIST, classic computer forensics processes are insufficient for cases that require investigators to extract data from mobile phones. There are also specific digital forensic tools investigators use for collecting and analyzing digital data from mobile devices.
- **Network forensics** – Forensic investigators identify cyber threats and investigate security breaches using network forensic techniques. NIST says, “Network forensics is the science that deals with the capture, recording and analysis of network events and traffic for detecting intrusions and investigating them, which involves post-mortem investigation of the attack and is initiated after the attack has happened.”
- **Database forensics** – According to scholar Paul Reedy in a Forensic Science International: Synergy article, database forensics is a specialty area that “focuses on the detailed analysis of a database including its contents, log files, metadata, and data files.”
## Notable Organizations in the Computer Forensics Field
The world of digital forensics is a vast one. It includes a wide spectrum of professionals, from police detectives to forensic accountants, and spans both the public and private sectors.
Consequently, there are several organizations that specialize in digital forensics and use digital forensic tools. In this type of organization, an investigator can track down suspected digital assets and recover deleted files from devices.
### The National Cyber Investigative Joint Task Force
According to the FBI, the National Cyber Investigative Joint Task Force (NCIJTF) actively protects our country from cyber threats. It includes over 30 agencies with roots in law enforcement, the Intelligence Community, and the Department of Defense (DoD).
“The NCIJTF also synchronizes joint efforts that focus on identifying, pursuing, and defeating the actual terrorists, spies, and criminals who seek to exploit our nation’s systems,” notes the FBI.
### The Internet Crime Complaint Center
Previously called the Internet Fraud Complaint Center (IFCC), the Internet Crime Complaint Center (IC3) is a resource that connects to the public to the FBI. Through the IC3 website, users can report information to the FBI regarding cybercrimes. These reports not only aid FBI investigations, but they also allow the FBI to track trends and potential threats that could result in computer viruses and deleted files.
### The Cybersecurity and Infrastructure Security Agency
The Cybersecurity and Infrastructure Security Agency (CISA) is an agency within the U.S. Department of Homeland Security. It partners with public- and private-sector organizations “and serves as the national hub for cybersecurity and communications information.”
As a multifunctional agency, CISA prioritizes cybersecurity risk management and leads cyber incident responses to protect national security.
### The US Department of Homeland Security’s Cyber Crimes Center
The Cyber Crimes Center (C3) is part of the Homeland Security Investigations (HSI) federal agency. It focuses on cybercrime activity within the HSI’s jurisdiction. C3’s mission has several components, as its website notes:
- Maintaining awareness of advancements in computer technology and cyber processes
- Employing new technologies to combat illicit activities and defend against potential threats
- Divulging the latest trends, risks, procedures, investigative leads, and other findings with law enforcement organizations worldwide, other field offices, and intelligence agencies
- Using the leading digital forensic techniques and investigative procedures to thwart cyber-related crime
### The Department of Defense Cyber Crime Center
The DoD's Cyber Crime Center (DC3) partners with police, cybersecurity, and national security organizations. Its areas of expertise include cybersecurity and computer forensics, and the organization also operates its own Cyber Forensics Laboratory (CFL).
## The Advantages and Disadvantages That Electronic Evidence Offers to an Active Criminal Investigation
For investigators and analysts, digital evidence offers multiple advantages and disadvantages. These advantages can make – or break – the prosecution of a case.
### Advantages
Digital evidence has become instrumental in solving myriad crimes. For example, investigators rely on electronic evidence in cyber-specific cases, such as those cases surrounding data breaches, hacks, and ransomware. Nonetheless, computer forensics plays an important role in solving non-computer crimes as well.
“Digital evidence can relate to many different types of crime, ranging from fraud to corporate crime and organized crime,” says Dr. Jarrod Sadulski, a criminal justice professor at AMU’s School of Security and Global Studies. “If preserved properly, digital evidence can help to strengthen a case, which can lead to a successful criminal prosecution.”
### Disadvantages
“A disadvantage of digital evidence is that it can be easily lost,” observes Dr. Sadulski. “Forensic investigators must take proper precautions when collecting digital files to avoid losing or compromising important data.”
However, computer forensics teams are only one part of the equation. Hackers and other cyber criminals also pose a threat. “Certain technologies can be accessed remotely, and evidence can be purposely erased,” Sadulski notes.
“To prevent this destruction of evidence, criminal investigators and crime scene personnel should use digital protective devices such as Faraday bags. These bags are designed to ensure that digital evidence cannot be accessed remotely,” he adds.
Given this insight, it makes perfect sense for investigators to duplicate the files they work with.
## Myths People Believe about Digital Forensics
As Dr. Sadulski explains, one of the biggest misconceptions about digital evidence is that it can cut down the time needed to solve a crime. “Utilizing digital evidence takes time and is likely not going to solve crime quicker than other forms of evidence,” he says.
People also tend to mistakenly believe that police organizations can solve any crime that involves collecting and analyzing digital evidence. Unfortunately, this line of thinking fails to account for both encrypted data and the legal protections surrounding the search and seizure phase of an investigation.
“The problem is that encryption involving electronic devices can be an obstacle for digital forensic experts. If an encryption key is needed, investigators may not be able to access a device or recover deleted files,” notes Sadulski. “It is also important to point out that our electronic devices have Fourth Amendment protection.”
## The Future of Digital Forensic Investigations
“Digital forensics will likely remain at the forefront of criminal cases,” Sadulski predicts. “Digital evidence is commonly located on cell phones, computers, cloud technology, smart home technologies, and vehicle computer systems. As technology evolves, it is important that investigators continue to examine ways that evidence can be obtained from these technological advancements.”
Digital forensics tools will also continue to evolve out of necessity as technology continues advancing and the Internet of Things (IoT) expands. Moreover, digital forensics investigators will further solidify their roles within our criminal justice system as digital clues help close more cases.
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[PDF] NIST.SP.800-61r3.pdf
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https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-61r3.pdf
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# NIST Special Publication 800 NIST SP 800-61r3
# Incident Response Recommendations and Considerations for Cybersecurity Risk Management
A CSF 2.0 Community Profile
# Executive Summary
Incident response is a critical part of cybersecurity risk management and should be integrated across organizational operations. All six NIST Cybersecurity Framework (CSF) 2.0 Functions play vital roles in incident response:
• Govern, Identify, and Protect help organizations prevent some incidents, prepare to handle incidents that do occur, reduce the impact of those incidents, and improve incident response and cybersecurity risk management practices based on lessons learned from those incidents. Detect, Respond, and Recover help organizations discover, manage, prioritize, contain, eradicate, and recover from cybersecurity incidents, as well as perform incident reporting, notification, and other incident-related communications.
Many individuals, teams, and third parties hold a wide variety of roles and responsibilities across all of the Functions that support an organization’s incident response. Organizations have no direct control over the tactics and techniques used by their adversaries, nor are they certain about the timing of a future incident other than knowing that another incident is inevitable. However, organizations can use an incident response life cycle framework or model that best suits them to develop strong cybersecurity risk management practices that reduce their risks to acceptable levels.
This publication uses the CSF 2.0 Functions, Categories, and Subcategories to organize its recommendations, considerations, and other information regarding incident response as a CSF 2.0 Community Profile. Doing so provides a common taxonomy that is already widely used for communicating about incident response and cybersecurity risk management and governance. This also enables organizations to access a range of online resources mapped to each Function, Category, and Subcategory through the NIST Cybersecurity and Privacy Reference Tool (CPRT). These resources include mappings to other incident response and cybersecurity risk management standards and guidance, as well as sources of implementation guidance that organizations can choose to utilize as needed.
Organizations should use the incident response life cycle framework or model that suits them best. The model in this document is based on CSF 2.0 to take advantage of the wealth of resources available for CSF 2.0 and aid organizations that are already using the CSF. Regardless of the incident response life cycle framework or model used, every organization should take incident response into consideration throughout their cybersecurity risk management activities.
# 1\. Introduction
Within this document, an event is any observable occurrence that involves computing assets, including physical and virtual platforms, networks, services, and cloud environments. Examples of events are user login attempts, the installation of software updates, and an application responding to a transaction request. Many events focus on security or have security implications. Adverse events are any events associated with a negative consequence regardless of cause, including natural disasters, power failures, or cybersecurity attacks. This guide addresses only adverse cybersecurity events. Additional analysis is often needed to determine whether adverse cybersecurity events indicate that a cybersecurity incident has occurred.
A cybersecurity incident (or simply incident) is …an occurrence that actually or imminently jeopardizes, without lawful authority, the integrity, confidentiality, or availability of information or an information system; or constitutes a violation or imminent threat of violation of law, security policies, security procedures, or acceptable use policies. \[FISMA2014\]
Examples of incidents include an attacker:
• Employing a botnet to send high volumes of connection requests to an internet-facing service, making it unavailable to legitimate service users Obtaining administrative credentials at a software-as-a-service provider, which puts sensitive tenant data entrusted to that provider at risk Intruding upon an organization’s business network to steal credentials and use them to instruct industrial control systems to shut down or destroy critical physical components, causing a major service disruption Deploying ransomware to prevent the use of computer systems and cause multiple data breaches by copying files from those systems Using phishing emails to compromise user accounts and using those accounts to commit financial fraud
Identifying a new vulnerability in network management appliances and exploiting the vulnerability to gain unauthorized access to network communications
Compromising a vendor’s software, which is subsequently distributed to customers in its compromised state
Because of the damage that cybersecurity incidents can inflict on organizations and their customers, business partners, and others, it is vital to respond quickly and effectively when an incident occurs. Effective implementation of incident response processes enables systematic responses to and recovery from incidents by analyzing information and taking appropriate action. This reduces cybersecurity and enterprise risks by minimizing data loss or theft, the disruption of services, and the overall impact of incidents. Lessons learned from incident response activities and root cause analysis help improve cybersecurity risk management and governance efforts and ensure that the organization is better prepared to identify its current technology assets and cybersecurity risks, protect its assets, and detect, respond to, and recover from future incidents.
# 1.1. Purpose and Scope
This publication seeks to help organizations incorporate cybersecurity incident response recommendations and considerations throughout their cybersecurity risk management activities. It also provides a common language that all organizations can use to communicate internally and externally regarding their incident response plans and activities.
The scope of this publication differs significantly from previous versions. Because the details of how to perform incident response activities change so often and vary so much across technologies, environments, and organizations, it is no longer feasible to capture and maintain that information in a single static publication. Instead, this version focuses on improving cybersecurity risk management for all of the NIST Cybersecurity Framework (CSF) 2.0 Functions \[CSF2.0\] to better support an organization’s incident response capabilities.
Readers are encouraged to utilize other NIST resources in conjunction with this document, including the CSF 2.0 publication and supplemental resources, the Incident Response project page, and mappings to additional sources of information on implementing incident response considerations available through the NIST Cybersecurity and Privacy Reference Tool (CPRT). An example of a CPRT mapping is associating CSF 2.0 outcomes with NIST Special Publication (SP) 800-53 controls that can be implemented to help achieve the outcomes. In this way, CSF 2.0 provides a common language that facilitates access to a large number of other resources.
This publication supersedes SP 800-61r2 (Revision 2), Computer Security Incident Handling Guide \[SP800-61r2\].
# 1.2. Document Structure
The remainder of this document is organized into the following sections and appendices:
• Section 2 discusses how incident response has evolved to become a critical part of cybersecurity risk management, as well as how the concept of the incident response life cycle has changed to reflect that. Section 3 presents incident response recommendations and considerations for an organization’s cybersecurity risk management practices. They are organized and documented as a CSF 2.0 Community Profile.
• The References section lists references cited throughout this publication.
• Appendix A and Appendix B provide an acronyms list and a glossary, respectively. Appendix C contains a change log of the major changes made since the previous revision.
# 2\. Incident Response as Part of Cybersecurity Risk Management
This section explains the fundamental concepts of incident response as an integral part of cybersecurity risk management. Section 2.1 explores the incident response life cycle and proposes a new life cycle model based on CSF 2.0 Functions. Section 2.2 discusses incident response roles and responsibilities both inside and outside an organization. Finally, Section 2.3 briefly examines incident response policies, processes, and procedures.
# 2.1. Incident Response Life Cycle Model
Fig. 1 depicts the incident response life cycle model illustrated in the previous version of this publication \[SP800-61r2\].
At that time, incidents were relatively rare, the scope of most incidents was narrow and welldefined, and incident response and recovery was usually completed within a day or two. Under those conditions, it was realistic to treat incident response as a separate set of activities performed by a separate team of personnel and to depict all incident response activities as part of a circular life cycle. Formal post-incident activities would identify needed improvements and feed them into the preparation stage, thus starting the cycle again. Incident response activities were typically intermittent rather than continuous.
However, the current state of incident response has greatly changed since then. Today, incidents occur frequently and cause far more damage. Recovering from them often takes weeks or months due to their breadth, complexity, and dynamic nature. Incident response is now considered a critical part of cybersecurity risk management that should be integrated across organizational operations. The lessons learned during incident response should often be shared as soon as they are identified, not delayed until after recovery concludes. Continuous improvement is increasingly necessary for all facets of cybersecurity risk management in order to keep up with modern threats.
Fig. 2 shows a high-level incident response life cycle model based on the six CSF 2.0 Functions, which organize cybersecurity outcomes at their highest level:
Govern (GV): The organization’s cybersecurity risk management strategy, expectations, and policy are established, communicated, and monitored. Identify (ID): The organization’s current cybersecurity risks are understood. Protect (PR): Safeguards to manage the organization’s cybersecurity risks are used. Detect (DE): Possible cybersecurity attacks and compromises are found and analyzed.
• Respond (RS): Actions regarding a detected cybersecurity incident are taken.
• Recover (RC): Assets and operations affected by a cybersecurity incident are restored.
All six Functions have vital roles in incident response. Govern, Identify, and Protect help organizations prevent some incidents, prepare to handle incidents that do occur, reduce the impact of those incidents, and improve incident response and cybersecurity risk management practices based on lessons learned. Detect, Respond, and Recover help organizations discover, manage, prioritize, contain, eradicate, and recover from cybersecurity incidents, as well as perform incident reporting, notification, and other incident-related communications.
The bottom level reflects that the preparation activities of Govern, Identify, and Protect are not part of the incident response itself. Rather, they are much broader cybersecurity risk management activities that also support incident response. Incident response is shown in the top level of the figure: Detect, Respond, and Recover. Additionally, the need for continuous improvement is indicated as the middle level with the Improvement Category (ID.IM) within the Identify Function and the dashed green lines. Lessons learned from performing all activities in all Functions are fed into Improvement, and those lessons are analyzed, prioritized, and used to inform all of the Functions. This reflects that organizations can learn new lessons at all times
(e.g., detecting the presence of a new threat and characterizing its behavior) and communicate those lessons to the appropriate personnel so that the organization’s incident response and other cybersecurity risk management policies, processes, and practices can be adjusted as needed.
Table 1 maps the previous SP 800-61 incident response life cycle model’s phases to the corresponding CSF 2.0 Functions used in this document.
Organizations should use the incident response life cycle framework or model that suits them best. The model in this document is based on CSF 2.0 to take advantage of the wealth of resources available for CSF 2.0 and aid organizations that are already using the CSF. The appropriate incident response life cycle framework or model for an organization depends on many factors; for example, larger and more technology-dependent organizations are likely to benefit more from using a framework or model emphasizing continuous improvement than other organizations would. Regardless of the incident response life cycle framework or model used, every organization should take incident response into consideration throughout their cybersecurity risk management activities.
# 2.2. Incident Response Roles and Responsibilities
In the past, incident response activities were performed almost exclusively by incident handlers from the organization’s own incident response team. Today, while incident handlers are still critically important, most organizations increasingly recognize that the success of their incident response efforts depend on the participation of many internal and external parties who hold a wide variety of roles and responsibilities and may be spread around the world. Roles and responsibilities will differ for each organization and may also differ within an organization based on the nature of a particular incident.
Examples of incident response roles and responsibilities include the following:
Leadership. The organization’s leadership team oversees incident response, allocates funding, and may have decision-making authority on high-impact response actions, such as shutting down or rebuilding critical services.
Incident handlers. Incident handlers verify that an incident has occurred, collect and analyze data and evidence, prioritize incident response activities, and act appropriately to limit damage, find root causes, and restore operations. Incident handlers also often provide input to others on mitigating cybersecurity issues and improving resiliency. An organization’s incident handlers might be:
o On staff (e.g., an incident response team),
o On contract (e.g., outsourcing a security operations center \[SOC\] to a managed security services provider \[MSSP\] or leveraging a cloud service provider’s incident response team when an incident occurs within that provider’s cloud), and/or
o Available when needed (e.g., from a parent organization, a cybersecurity service provider, a business partner, or a law enforcement agency).
Many organizations may use more than one of these approaches, such as internally performing basic incident response and engaging third-party resources for assistance with certain incidents. Larger organizations may have multiple incident response teams, with each team responsible for a particular logical or physical segment of the organization. When this model is employed, the teams should be part of a single coordinated entity (e.g., a federation) to ensure that incident response processes, procedures, and training are consistent across the organization and that information is shared among teams.
Technology professionals. Cybersecurity, privacy, system, network, cloud, and other technology architects, engineers, and administrators, as well as software developers, may be involved in incident response and recovery efforts.
Legal. Legal experts can review incident response plans, policies, and procedures to ensure compliance with applicable laws and regulations, including the right to privacy. Legal experts can also review contracts with technology suppliers and other third parties when there are incident response implications. In addition, incident responders can seek guidance from their organization’s legal department if a particular incident may have legal ramifications, such as the prosecution of a suspect, lawsuits, or situations that require a memorandum of understanding (MOU) or other binding agreement.
• Public affairs and media relations. Depending on the nature and impact of an incident, it may be necessary to inform the media and, by extension, the public. Sometimes, the media learns of incidents through alternate sources (i.e., not through public affairs personnel). Having a media engagement strategy in place can greatly aid in this situation.
Human resources. Certain human resources practices should consider cybersecurity risk management, including pre-employment screening and employee onboarding, offboarding, and position changes. Human resources may also be involved if an employee is suspected of intentionally causing an incident. Physical security and facilities management. Some computer security incidents occur through physical security breaches or involve coordinated logical and physical attacks. The incident response team may also need access to facilities during incident handling (e.g., to access a compromised workstation in a locked office).
• Asset owners. Asset owners (e.g., system owners, data owners, and business process owners) may have valuable insights on response and recovery priorities for their affected assets. They also need to be kept up to date on the status of response and recovery efforts.
Third parties may be under contract with an organization to help perform incident response activities. Some third parties may fill a primary role (e.g., an MSSP performing incident detection, response, and recovery activities), while other parties (e.g., cloud service providers \[CSPs\] and internet service providers \[ISPs\]) may be involved in certain incident response activities for particular types of incidents. This is a shared responsibility model in which the organization transfers some of its responsibilities to a provider. These responsibilities should be clearly defined in a contract, and the incident response team should be aware of the division of responsibilities, including information flows, coordination, and authority to act on behalf of the organization. This also includes restrictions on what the service provider can do, such as sharing sanitized incident information with other customers or making and implementing operational decisions (e.g., immediately deactivating certain services to contain an incident).
A service provider may detect malicious activity sooner than individual organizations would because it can correlate events across its customers. In some situations, a service provider might be able to use knowledge of an incident with one customer to proactively prevent similar incidents with its other customers. Service providers often have privileged access to organizational systems and may also have access to sensitive organizational data. Accordingly, the risk of malicious insiders or the service provider being compromised should be considered and addressed. Non-disclosure agreements (NDAs) and contracting clauses are options for deterring the unauthorized disclosure of sensitive data.
# 2.3. Incident Response Policies, Processes, and Procedures
Organizations should have policies that govern their cybersecurity incident response. While a policy is highly individualized to the organization, most incident response policies include the same key elements:
Statement of management commitment
· Purpose and objectives of the policy
• Scope of the policy (i.e., to whom and what it applies and under what circumstances)
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• Definition of events, cybersecurity incidents, investigations, and related terms Roles, responsibilities, and authorities, such as which roles have the authority to confiscate, disconnect, or shut down technology assets Guidelines for prioritizing incidents, estimating their severity, initiating recovery processes, maintaining or restoring operations, and other key actions
• Performance measures
Processes and procedures should be based on the incident response policy and plan. Documented procedures should explain how technical processes and other operating procedures should be performed. Procedures can be tested or exercised periodically to verify their accuracy and can be used to help train new personnel. While it is impossible to have detailed procedures for every possible situation, organizations should consider documenting procedures for responding to the most common types of incidents and threats. Organizations should also develop and maintain procedures for particularly important processes that may be urgently needed during emergency situations, such as redeploying the organization’s primary authentication platform.
Many organizations choose to create playbooks as part of documenting their procedures. Playbooks provide actionable steps or tasks for people to perform during various scenarios or situations. Formatting procedures within a playbook instead of another format can improve their usability. See the Cybersecurity and Infrastructure Security Agency (CISA) Cybersecurity Incident & Vulnerability Response Playbooks \[CISA-PB\] for incident response playbook examples.
# 3\. CSF 2.0 Community Profile for Cyber Incident Risk Management
A CSF Community Profile is a baseline of CSF outcomes that is created and published to address shared interests and goals for reducing cybersecurity risk among a number of organizations. A Community Profile is typically developed for a particular sector, subsector, technology, threat type, or other use case \[CSF2.0\].
This section defines NIST’s CSF 2.0 Community Profile for cyber incident risk management. It uses the CSF Core as the basis for highlighting and prioritizing cybersecurity outcomes that are important for incident response, makes recommendations, and provides other supporting information for certain CSF outcomes within the context of incident response \[CSWP32\]. The Community Profile is split into two tables: Table 2 covers Preparation (Govern, Identify, and Protect) and Lessons Learned (Identify-Improvement), while Table 3 covers Incident Response (Detect, Respond, and Recover).
Each CSF 2.0 Function, Category, and Subcategory has its own row in one of the two tables. Each row’s relative priority within the context of incident response is indicated by one of the following:
High: Functions as a core incident response activity for most organizations · Medium: Directly supports incident response activities for most organizations • Low: Indirectly supports incident response activities for most organizations
These priorities are intended as a starting point for organizations, who are encouraged to customize this Community Profile to reflect their own priorities and needs.
The last column may contain one or more items that recommend what to do or describe additional considerations or supporting information for some rows. Each item in that column has an ID starting with one of the following:
• ${}^{\\prime\\prime}{\\mathsf{R}}^{\\prime\\prime}$ (recommendation: something the organization should do) • ${}^{\\prime\\prime}{\\mathsf{C}}^{\\prime\\prime}$ (consideration: something the organization should consider doing) • “N” (note: additional information besides recommendations and considerations)
An R, C, or N designation and its number can be appended to the row’s CSF ID to create an identifier that is unique within the Community Profile (e.g., “GV.OC-03.R1” is recommendation 1 for CSF Subcategory GV.OC-03).
Recommendations, considerations, and notes made at a higher level of the CSF (Function or Category) also apply to their component elements (Categories or Subcategories).
The recommendations, considerations, and notes supplement what the CSF 2.0 already provides through its documents and online resources. The recommendations, considerations, and notes are not comprehensive, and not all of them will be applicable to every organization. Technologies mentioned in recommendations, considerations, and notes are examples as of this writing and may become outdated.
Some recommendations, considerations, and notes use terms that are not defined in this publication (e.g., “data breach”). Organizations that adopt the Community Profile should define these terms in the context of their own environments, use cases, and applicable laws and regulations. Readers may also choose to consult NIST’s glossary, which contains an aggregation of terms and definitions from numerous NIST standards, guidelines, and other publications.
The Community Profile is intended for use by most organizations, regardless of sector, size, or other factors. Additional versions of this Community Profile could be developed for narrower audiences, such as federal agencies, small businesses, or educational institutions. For more information on CSF 2.0 Community Profiles, see the Framework Resource Center.
# 3.1. Preparation and Lessons Learned
Table 2 contains the first part of the Community Profile: Preparation and Lessons Learned, which both support the Incident Response part of the Community Profile defined in Table 3.
Note: Most of the CSF elements in this part of the Profile are not specific to executing incident response activities, so they have lower priorities with respect to incident response and do not contain recommendations or considerations. This does not imply that they are unnecessary for organizations to achieve, but rather that they are outside of the direct scope of responding to incidents.
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Incident Response Recommendations and Considerations for Cyber Risk Management
# 3.2. Incident Response
Table 3 contains the second part of the Community Profile: Incident Response.
Note: All of the CSF elements in this part of the Profile are specific to responding to incidents, so they have higher priorities with respect to incident response than those in the first part. Accordingly, all CSF elements in this part have recommendations or considerations.
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Understanding OT Cyber Threat Intelligence | Dragos
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https://www.dragos.com/blog/what-is-ot-cyber-threat-intelligence/
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cyber threat intelligence
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**Dragos is an industrial cybersecurity company leveraging software, intelligence, and professional services to safeguard civilization. The SANS Institute empowers cybersecurity professionals with high quality training, certifications, degree programs, and more to help them make the world a safer place. Together, we have created a blog series about OT cybersecurity fundamentals, crafted for practitioners and executives alike to gain a better understanding of operational environments and their unique security requirements. This is the fourth blog in our series.**
Cyber threat intelligence (CTI) involves collection, processing, analysis, dissemination, and integration of information about active or emerging cyber threats. The primary purpose of CTI is to uncover malicious cyber activities and adversaries and make this knowledge available to decision-making functions in the organization. Operational technology (OT) cyber threat intelligence addresses the unique challenges and requirements of OT environments. These systems are integral to critical infrastructure such as power plants, manufacturing facilities, gas pipelines, and water treatment plants.
This blog will examine the unique challenges and specific requirements for securing OT environments, highlighting the critical role of specialized cyber threat intelligence in safeguarding these systems.
#### Get Insights into Threats Affecting Industrial Infrastructure
Enhance your operational technology (OT) security with Dragos WorldView, the leading solution for OT cyber threat intelligence.
Request a WorldView Demo
## The Domain of OT Cyber Threat Intelligence
OT Cyber Threat Intelligence is critical to safeguarding the systems that control physical processes. OT cyber threat intelligence involves proactively identifying threats that could alter, degrade, or disrupt physical processes and launching a defense against these threats before they lead to potentially dangerous outcomes. This is distinctly different from IT cyber threat intelligence which involves identifying and subverting cyber threats that aim to steal, corrupt, or exploit information.
## Threat Intelligence Cycle for OT Environments
In the context of OT-specific cyber threat intelligence, the intelligence cycle and the relationship between data, information, and intelligence are intricately connected. The intelligence cycle, consisting of Planning and Direction, Collection, Processing and Exploitation, Analysis and Production, and Dissemination and Integration, is designed to transform raw data from OT environments into actionable intelligence.
This process begins with collecting data from the operational environment, which includes signals specific to OT systems and network traffic. This raw data is then processed to create meaningful information, which is analyzed through the lens of risks in OT environment to produce intelligence. The intelligence cycle ensures that this intelligence is not only accurate and relevant but also effectively integrated into the organization’s security operations, providing actionable insights that inform decision-making and enhance the protection of critical infrastructure.
## OT Cyber Threat Scenarios
Attacks on operational technology networks and industrial control systems (ICS) can impact essential services like electricity, oil and gas, manufacturing, and water. The following threat events and incidents illustrate the types of cyber activities and adversaries that impact industrial environments. These scenarios underscore the need for specialized OT cyber threat intelligence to protect against attacks with severe real-world consequences.
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| **2015-2016 Ukraine Electric Grid Attacks** | In 2015, an attack on a Ukraine electric entity was distributed via an email as a Word document or PowerPoint attachment, luring victims into clicking the seemingly legitimate file. BLACKENERGY3 was deployed to enable a distributed denial-of-service (DDoS) that disrupted electric services for several hours. In 2016, the CRASHOVERRIDE malware was deployed against a Ukraine energy entity, targeting hundreds of systems. The malware aimed to disable control and SCADA systems and launch a denial-of-service (DoS) attack on protective relays to create hazardous conditions. This incident marks the first known use of malicious code designed to target electric substations. |
| **2017 TRISIS Attack on Petrochemical Safety Systems** | The TRISIS malware was deployed against a safety instrumentation system (SIS) at a petrochemical plant in Saudi Arabia. The attackers attempted to disable safety features. However, the attack tripped safety systems that would shut down the plant. It represents the first time that safety features of a system have been targeted and compromised directly. |
| **2022 Emergence of the Cross-Industry OT Toolkit PIPEDREAM** | PIPEDREAM is a multi-tool malware. It targets specific Omron and Schneider Electric controllers, causing loss of view, control, and safety. It also manipulates OPC-UA connections and targets Windows systems, making it capable of an end-to-end attack. Unlike previous examples, which were designed to target a single OT environment, PIPEDREAM can be used in multiple industrial sectors and adapted for thousands of CODESYS devices. Fortunately, the malware was discovered before it was employed. It represents the first cross-industry OT attack toolkit. |
| **2023-2024 Hacktivist Attacks Impacting Water Utilities** | Several self-proclaimed hacktivist groups successfully compromised water utilities throughout the United States, Europe, and Australia. Internet-exposed PLCs were targeted, easily discoverable in Shodan searches, and in some cases, compromised using only the default password for the devices targeted. Other techniques used were relatively unsophisticated. The attacks led to material impacts and disruption in a few locations, underscoring the importance of taking basic security precautions. |
## Cyber Adversaries Targeting OT Environments
The many adversaries targeting operational technology environments and industrial control systems are motivated by different factors. Industrial organizations might encounter:
- State actors motivated by state objectives and that receive direction and support based on that alignment. These groups seek a strategic advantage by collecting information or pre-positioning for an attack later.
- Hacktivist groups with many different social and political motivations. They generally seek to advance a specific agenda, but their actions are sometimes inconsistent and misleading.
- Financially motivated cybercriminals. Ransomware groups are prime examples. They want a payoff by whatever means.
Cyber adversaries targeting industrial organizations and control systems can be informally classified according to their intent, capabilities, familiarity with industrial processes, and impacts.
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| Adversaries that can cause **DIRECT** OT impact | These adversaries directly impact the operation of industrial control systems and have the potential to disrupt, degrade, or destroy operational technology systems. |
| Adversaries that can **FACILITATE** direct OT impact | Some adversaries are interested in industrial organizations, industrial control systems, and operational technology networks for reconnaissance and initial access activities. |
| Adversaries that can cause **INDIRECT** OT impact | Some adversaries targeting IT may indirectly disrupt operational technology environments, such as ransomware attacks that disrupt OT systems during preventative/precautionary shutdowns or adversaries that disrupt availability of IT systems needed for OT processes, absent of intent. |
While this is not an exhaustive categorization of adversaries, it is a helpful rubric for understanding the varied intentions and impacts encountered in OT cyber threat intelligence.
When securing operational technology networks, industrial organizations should focus on adversaries conducting sustained operations that are defensible and focused on industrial.
## Vulnerabilities in OT Environments
Using an IT mindset when addressing OT vulnerabilities is wrong. Industrial infrastructure operates specialized machinery with longer lifecycles than IT equipment. It is heavily engineered to fulfill the core business functions—producing electricity, manufacturing products, distributing oil and gas, and treating water. However, most vulnerability disclosures are written with IT in mind and don’t correctly characterize the risks to OT. When prioritizing vulnerabilities in OT, it’s essential first to research and consider factors such as:
- **Severity** – What capabilities does this vulnerability provide adversaries?
- **OT impact** – What could happen in the OT environment?
- **Network exploitability** – Can it be reached from the network?
- **Ease of exploitation** – How skilled must an adversary be to use it?
- **Events in the wild** – Are adversaries already using it?
Knowing why and when to address vulnerabilities is the starting point. Then, it is a matter of determining what to do. Patch recommendations are standard, which is impractical in continuously running operations. To be effective, vulnerability management in industrial environments requires alternatives to patching and accurate risk information.
## Key Frameworks for OT Cybersecurity Threats
Understanding where an adversary is in their campaign, their capabilities, and the tactics, techniques, and procedures (TTPs) that form their attack enables defenders to make better-informed security and risk management decisions.
Frameworks such as the ICS Cyber Kill Chain and MITRE ATT&CK® for ICS are invaluable tools for OT cyber threat intelligence professionals. These OT-specific frameworks help organizations anticipate, detect, and mitigate threats effectively for the safety and continuity of their operations.
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| **ICS Cyber Kill Chain** | The ICS Cyber Kill Chain represents the entirety of the operation against an organization and its systems.Stage 1 of the ICS Cyber Kill Chain traditionally involves espionage operations, often to gain access to the information within networks and learn the system. Stage 2 consists of using the knowledge gained in Stage 1 to develop, test, and deploy a capability that can meaningfully attack OT. |
| **MITRE ATT&CK for ICS** | MITRE ATT&CK® for ICS is a comprehensive knowledge base of cyber adversary tactics, techniques, and procedures (TTPs) explicitly targeting industrial control systems. MITRE ATT&CK® for ICS details the various stages, from initial access and execution to impact, mapping out the specific threats and attack vectors relevant to ICS environments. |
## OT Cyber Threat Intelligence Data Sources
Industrial organizations rely on multiple data sources to form a comprehensive understanding of cyber threats:
- **Internal IT Data:** Can help identify potential threats before they affect OT environments but is not sufficient alone.
- **OT-Native Network Monitoring:** Essential for knowledge of threats within OT systems. Technologies like the Dragos Platform are critical for this task.
- **Collaboration with Partners:** Sharing first-party data through agreements and networks like Neighborhood Keeper enhances visibility and detection capabilities.
- **External Sources:** Commercial CTI providers like WorldView, ISACs, and regulatory agencies provide a broader context and sector-specific intelligence.
## In Conclusion
Understanding and effectively managing cyber threats facing OT environments is essential. Unlike IT systems, OT environments are directly tied to the physical world, meaning that any disruption can lead to significant physical consequences such as production downtime, equipment damage, and even risks to human safety and the environment.
OT cyber threat intelligence involves understanding, identifying, and responding to distinct adversaries who often employ different threat behaviors and capabilities than those targeting IT systems. Moreover, OT vulnerabilities must be managed differently using tailored mitigations that reflect industrial systems’ business requirements and operational challenges.
Organizations can proactively protect their critical infrastructure by leveraging OT-specific threat intelligence, ensuring operational continuity, safety, and security.
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What are the Types of Cyberthreat Intelligence (CTI)?
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https://www.paloaltonetworks.com/cyberpedia/types-of-cyberthreat-intelligence
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Threats
# What are the Types of Cyberthreat Intelligence (CTI)?
The three main types of cyberthreat intelligence are:
1. **Strategic Threat Intelligence** \- an executive-level intelligence that gives an overall view of the threat landscape, including threat actors, their capabilities, motivations, and attack trends. It enables organizations to make informed security decisions.
2. **Tactical Threat Intelligence** \- helps detect threats in networks by analyzing indicators like IP addresses, file hashes, and domains.
****Operational Threat Intelligence** \- real-time monitoring of networks and systems to identify vulnerabilities and threats. Analysts and responders use this intelligence to detect and respond to cyberthreats quickly.**
The critical difference between these is the level of detail and type of consumption. Strategic intelligence paints the overall picture, while tactical and operational intelligence provide more detailed, actionable data that security teams can operationalize within their specific environments. All three work together to enable organizations to understand and defend against complex cyberthreats.
## What is Cyberthreat Intelligence?
Cyberthreat intelligence (CTI) is an aspect of cybersecurity that involves collecting, analyzing, and sharing information about potential and current cyberthreats and threat actors. It aims to provide organizations with a deep understanding of cyberattack risks, enabling them to prepare and respond effectively.
CTI includes a variety of intelligence, such as:
- tactics, techniques, and procedures (TTPs) used by attackers
- indicators of compromise (IoCs) that suggest an attack is underway
- contextual details like the motives and capabilities of the adversaries
This intelligence is not static; it evolves as cyberthreats and technologies develop, requiring constant updating and refinement. By harnessing CTI, organizations can transition from reactive to proactive defense, staying one step ahead of cybercriminals.
## What is Strategic Threat Intelligence?
Strategic threat intel focuses on the broad threat landscape, covering major threat actors, campaigns, cybercrime/espionage trends, and future risks. It looks at "the big picture". Strategic assessments often leverage open-source intelligence including academic studies, news reports, conferences, and expert analysis.
Strategic intel reports contain high-level assessments, background, motivation assessments, and strategic security recommendations. Intel looks further ahead, focusing on long-term risks, emerging adversaries, geopolitical factors, etc. Reports are meant primarily for senior leadership, such as CISOs, security executives, and risk managers, to inform high-level decisions.
### Stakeholders and Communication
Leaders in the C-suite, board members, and IT management need to know how cyberthreats can impact their organization's strategic decisions, risk management, and resource allocation. Strategic intelligence is communicated in a way that is easy to understand and comprehensive without using technical terms that non-technical leaders may not be familiar with. This helps leaders apply the intelligence to policy and strategy.
### Long-term Risks and Business Implications
Looking beyond immediate threats, Strategic threat intelligence considers the long-term risks that may affect an organization's ability to operate or compete. This might include assessing the impact of a changing regulatory landscape, the potential for targeted attacks from nation-states, or the risks posed by evolving technologies like quantum computing or AI. As a result, businesses can better prepare for future challenges by guiding investments in security infrastructure, shaping incident response planning, and informing company-wide security policies.
## What is Tactical Threat Intelligence?
Tactical threat intelligence is information that helps security teams detect and respond to threats inside their environments. It focuses on current threats and provides data on emerging campaigns, new attacker infrastructure, and prevalent malware variants. Tactical intelligence complements strategic intelligence, which is more geared towards longer-term risks and decision-making.
Tactical intelligence is all about identifying specific indicators of compromise (IOCs) such as file hashes, domain names, and IP addresses. These IOCs are used by known attackers and can be searched for to identify breach activity. Security teams use IOCs to support activities like threat hunting, incident response, forensic analysis, network analytics, and measuring risk exposure.
Detailed information on attackers' tools, behaviors, and infrastructure can help security teams deploy new defenses, perform investigations, manage vulnerabilities, rotate credentials, and more. It enables security teams to configure controls and sensors to detect threats, scan for evidence of compromise, suspend malicious accounts, block communications with C2 servers, and take other necessary actions.
Tactical intelligence is crucial as it helps teams keep up with the rapidly changing threat landscape and enables security measures to be as current as possible. By using this information, security teams can update firewalls, enhance security protocols, and train personnel to recognize and mitigate these threats.
## What is Operational Threat Intelligence?
Operational intelligence is intended to identify characteristic attack vectors and patterns of behavior to proactively identify the likely precursors of an impending attack. Operational intelligence is concerned with real-time monitoring of the "When" "Where" and "How" of an offensive operation and requires an understanding of an adversary's capabilities and of a target's exposure.
Key aspects of Operational Threat Intelligence that organizations should be aware of include the following.
### Real-Time or Near Real-Time Information
Operational threat intelligence needs up-to-date information on active threats, like ongoing cyberattacks, current exploit trends, or newly discovered vulnerabilities.
### Actionable Intelligence
This type of intelligence provides specific details that enable organizations to take immediate action. For example, it may include indicators of compromise (IoCs), such as specific malware signatures, IP addresses, URLs, or tactics, techniques, and procedures (TTPs) used by threat actors.
### Contextual Relevance
The intelligence must be relevant to the organization’s specific environment, assets, and risk profile. It should help security teams understand how a particular threat could impact their systems and operations.
### Integration with Security Tools
Operational threat intelligence is often integrated into security tools such as intrusion detection systems, security information and event management (SIEM) systems, and endpoint protection platforms. This integration allows for automated responses to threats.
### Support for Incident Response
It aids in the rapid response to security incidents by providing information that helps in understanding the nature of the attack, the attacker's identity or motivation, and the best methods for remediation and recovery.
### Collaboration and Sharing
Operational intelligence is most effective when it is shared. Sharing threat intelligence with peers, industry groups, or government entities allows for a broader understanding of threats and coordinated defense strategies.
### Detailed Insights
Incident response teams can achieve significant benefits by obtaining detailed insights into specific threats. Operational threat intel allows them to personalize their response instead of relying on generic strategies. Security professionals use this type of intelligence to improve their defensive tactics and to guide the development of more sophisticated and targeted security measures. It empowers organizations to shift from a reactive security stance to a more proactive one, where threats are countered with greater precision and effectiveness.
## Application of Cyberthreat Intelligence
One key component of effective CTI is the sharing of information between organizations and within various departments of a single organization. Best practices in CTI involve collecting and analyzing data, and contributing to and learning from the broader security community.
### Tools and Platforms for CTI Analysis
Various specialized tools and platforms are available to assist with the collection and analysis of threat intelligence. These tools range from advanced malware analysis systems to comprehensive threat intelligence platforms that aggregate and correlate data from multiple sources.
### Automation and Artificial Intelligence in CTI
The use of automation and artificial intelligence is becoming increasingly prevalent in CTI. These technologies can process vast amounts of data at high speeds, uncover patterns that might elude human analysts, and predict future attacks based on current trends.
## Challenges in Cyberthreat Intelligence
Cyber Threat Intelligence (CTI) faces various challenges and is constantly evolving. Some of the current challenges and potential future developments in CTI include:
**Automation and AI**
The future of CTI will likely see an increased reliance on automation and artificial intelligence. Machine learning algorithms can more efficiently sift through large datasets, identify patterns, and detect anomalies than humans.
**Threat Intelligence Platforms**
Developing advanced threat intelligence platforms will enable organizations to aggregate, correlate, and analyze threat data more effectively. These platforms will offer better visualization, reporting, and integration with other security tools.
**Increased Collaboration**
Organizations will continue to recognize the importance of collaboration in CTI. Public-private partnerships, information sharing, and cooperation between sectors and industries will be essential for collective defense.
**Threat Actor Attribution**
Improving techniques for attributing cyberattacks to specific threat actors or nation-states will become more refined. This will assist in developing more targeted responses and deterrence strategies.
**Supply Chain Security**
With increasingly complex supply chains, CTI will focus more on securing the digital supply chain. This involves monitoring and mitigating threats that can propagate through interconnected systems.
**Quantifying Risk**
Organizations will work on developing more sophisticated methods for quantifying cyber risks. This will help prioritize CTI efforts and allocate resources effectively.
**Standards Developments**
Governments and regulatory bodies may implement new frameworks and standards for CTI and information sharing. These regulations could help streamline and standardize CTI practices.
**Enhanced Threat Sharing**
Improved mechanisms for sharing threat intelligence while addressing privacy and legal concerns will likely emerge. This could involve developing secure information-sharing platforms and standards.
The future of Cyber Threat Intelligence holds promise, but it also presents ongoing challenges. As threats continue to evolve, organizations and governments must adapt by leveraging advanced technologies, fostering collaboration, and addressing data privacy and security complexities. As the digital landscape evolves, CTI will remain a critical component of modern cybersecurity strategies.
## Cyberthreat Intelligence FAQs
### How does cyberthreat intelligence differ from traditional security measures?
Unlike traditional security measures that often focus on reactive defense, cyberthreat intelligence emphasizes proactive measures. It involves anticipating and countering threats before they manifest, based on analyzing trends and patterns in cyber adversary behavior.
### What role does artificial intelligence play in cyberthreat intelligence?
AI enhances cyberthreat intelligence by automating the collection and analysis of threat data, identifying new threats faster, and predicting future attacks through pattern recognition and machine learning algorithms.
### How can organizations effectively integrate cyberthreat intelligence into their security strategy?
Organizations can integrate CTI by establishing a dedicated threat intelligence team, adopting threat intelligence platforms, regularly training staff on the latest threat landscape, and incorporating intelligence feeds into their security tools.
### What are the ethical considerations when dealing with cyberthreat intelligence?
Ethical considerations regarding cyberthreat intelligence include ensuring privacy rights are not violated during intelligence gathering, responsibly sharing threat information, and not engaging in offensive cyber tactics considered unethical or illegal.
### What is the future of cyberthreat intelligence in the context of evolving cyberthreats?
The future of CTI lies in the development of more sophisticated analytical tools, greater collaboration within the cybersecurity community, and the integration of CTI into broader risk management and business continuity frameworks as cyberthreats become more complex.
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Understanding the Cyber Threat Intelligence Lifecycle | Filigran Blog
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https://filigran.io/understanding-cyber-threat-intelligence-lifecycle/
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In today’s threat landscape, cyber threats are emerging and evolving at an alarming pace. This is due not only to the evolution of threat actor tactics, techniques, and procedures (TTPs), but also to the expansion of attack surfaces. Now more than ever, it is essential for organizations to adopt a proactive stance and stay ahead of the myriad of threats they face. You’re probably asking yourself, how can this be done? As a CISO or part of a leadership team, how can I effectively protect my organization? The answer lies in Threat Intelligence.
A mature Threat Intelligence program empowers organizations to make informed decisions at all levels, from strategic leadership level to operational and tactical levels. This program integrates the threat intelligence lifecycle into daily security operations, enabling intelligence analysts to produce insightful reports on current and emerging threat trends. Moreover, these analysts generate operational intelligence for threat hunting, purple teaming, and blocking indicators of compromise using various security tools.
This article aims to guide organizations in implementing a robust Threat Intelligence program by detailing the steps of the intelligence cycle and how to leverage Filigran’s OpenCTI platform for each step.
Cyber Threat Intelligence Lifecycle in OpenCTI
## Planning & Direction
### Priority Intelligence Requirements (PIRs)
The first step in the Cyber Threat Intelligence Lifecycle is Planning & Direction. This phase involves creating Priority Intelligence Requirements (PIR), which are critical intelligence needs that decision-makers must understand to mitigate threats. By identifying these PIRs, organizations can take strategic steps to understand their threat landscape and act proactively to mitigate risks. PIRs also enable an organization to prioritize the most pressing issues. These requirements are strategic in nature and can be broken down into more specific questions, called intelligence gaps or Essential Elements of Information (EEIs), which, when answered, address the overall PIR.
For example, a PIR might be, “How are threat actors targeting my industry?” A corresponding intelligence gap could be, “What specific TTPs have threat actors traditionally used against my industry?” This level of specificity helps focus efforts where they matter most.
### Why are PIRs important?
PIRs help prioritize and focus collection against the most significant threats facing your organization and address leadership questions, enabling the C-suite to make informed decisions. If everything is a priority, then nothing is a priority. In OpenCTI, it is recommend to use the Reports, Groupings, or Request for Information containers to document the PIRs.
PIRs in a Grouping Container
### Collection Plan
Once PIRs and intelligence gaps are identified, the next step is to create a collection plan. This plan outlines the sources you currently use and an assessment of how well those sources are or could address the identified PIRs. If your current sources are inadequate, your team will need to assess which sources might meet your needs, which do not, and which new sources you could add. Your team can then suggest integrating these additional sources into the OpenCTI platform. Sources could include open-source data, premium feeds, TAXII feeds (from ISACs), and connectors to internal security tools like EDRs or SIEMs.
## Collection
With a collection plan in place, the next phase involves gathering intelligence. Analysts must continuously assess whether the collected reports address the established PIRs. In OpenCTI, collection occurs through connectors to various feed vendors, TAXII feeds, and open-source intelligence. OpenCTI can also automate collection based on specified filters related to the PIRs, such as labels.
Using Labels to automate CollectionUsing Playbooks to automate Collection
## Processing
After data collection, the next step is processing, which involves filtering and organizing the information into a usable format. Collected data may come in various formats, including indicators, reports, artifacts, intrusion sets, etc. In OpenCTI, analysts can categorize information related to PIRs, ensuring that all pertinent data is easily accessible for further analysis.
Example of tying entities collected to the PIRs within the grouping container.Example of tying entities collected to the PIRs within the grouping container – details
## Analysis
Once the data is processed and organized, analysts evaluate the information using analytic tools such as OpenCTI’s investigations/enrichment portals and structured analytic techniques like hypothesis testing. They then arrive at an analytic conclusion in response to a PIR or its associated EEIs. Analysts should use assessment language, such as “The Threat Intelligence Team assesses that Scattered Spider will likely target our organization over the next 6 to 12 months”, which could have significant implications if not mitigated. This stage also marks the transition of evidence/information (indicators, TTPs, observables) into intelligence (actionable insights that address a PIR to inform decision-making).
In OpenCTI, analysts can conduct this analysis in multiple ways, including proactively investigating top threat actors by placing them or their intrusion sets into containers, launching investigations, and identifying or pivoting on the malware and tools used by these actors. The finding will inform threat hunting and defensive measures. Analysts can draft and produce finished intelligence reports using assessment language directly from OpenCTI via Reports or the content tab within Groupings or Requests for Information.
Investigation Graphic
## Dissemination
After analysis, the findings are disseminated to relevant stakeholders. Dissemination can take various forms, from strategic reports for leadership to tactical intelligence for security tools.
OpenCTI facilitates this process by enabling analysts to export reports or send tactical results to integrated security tools via live streams and connectors.
## Feedback
The final, and often overlooked, step of the intelligence life-cycle is feedback. After disseminating intelligence, it’s crucial for analysts to gather feedback from the stakeholders to evaluate the effectiveness of the provided intelligence. Organizations can assess impact by determining if the analysis addressed the PIRs and whether tactical intelligence improved metrics like Mean Time to Detect (MTTD) and Mean Time to Respond (MTTR). Finally, members of the intel program can request feedback from the leadership team and other teams within the organization that received the intelligence.
Although the intelligence cycle is iterative, there may be instances when analysts need to loop back to a previous step. For example, during processing, if analysts identify the need for additional information, they may return to the collection phase to gather more data.
## Conclusion
In today’s cybersecurity environment, instituting a Threat Intelligence program is imperative. Such a program enables organizations to prioritize their security efforts, moving away from a reactive, “whack-a-mole” approach. It facilitates the proactive identification, assessment, and mitigation of threats, ultimately safeguarding the organization from potential financial and reputational damage.
Lastly, a threat intelligence program enables organizational leadership to make informed cyber security and business decisions.
If you have any question, request, comment or feedback to share with us, don’t hesitate to join us on Slack!
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Beyond STIX: Next-Level Cyber-Threat Intelligence - Dark Reading
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https://www.darkreading.com/threat-intelligence/beyond-stix-next-level-cyber-threat-intelligence
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Cybersecurity has become central to every enterprise's digital strategy, but to stay ahead of evolving cyber threats, organizations need a common language that turns complex threat data into something universally understandable and actionable. This is where Structured Threat Information Expression (STIX) comes in — a standardized language for sharing, storing, and analyzing cyber threat intelligence.
However, simply organizing the data isn't enough to fully understand or counter the sophisticated tactics used by today's threat actors. As cyber threats evolve, traditional methods of identifying, cataloging, and responding to these threats struggle to keep pace.
## The Evolution of Cyber-Threat Intelligence Sharing
STIX provides a common language for cyber-threat intelligence (CTI) sharing, enabling organizations to categorize and share critical data points like campaigns; threat actors; tactics, techniques, and procedures (TTPs); observables; and incidents. This categorization allows organizations to gain a deeper understanding of a threat actor's capabilities, patterns, and historical actions. Threat information can then be shared and collaboratively acted upon across a wide array of organizations, making it a foundational tool in cybersecurity.
Related: Have Your Say: Dark Reading Seeks Your Input
The STIX language was developed as a serialization and exchange format. As such, it is an excellent means for sharing facts and observations with other organizations.
Since the release of the original STIX 2.1 specification, semantic technologies have advanced. It is now possible to share much richer information with knowledge graphs that provide additional context, detailing motivations (financial, political, or otherwise), skills, resources, TTPs, and behavior and targeting patterns. The added intelligence encapsulated in a knowledge graph gives a more comprehensive profile of a potential threat actor and makes the enhanced threat intelligence more actionable.
To enable this greater representation of the STIX 2.1 exchange language, the Cyber Threat Intelligence Ontology (CTIO) is under development as an extension of the gistCyber ontology.
## A Living, Contextualized View of Cyber Threats
As cyber threats become increasingly complex, relying solely on the original STIX 2.1 exchange language is no longer enough to combat them effectively. To stay ahead of evolving risks, organizations need a richer, more dynamic framework that goes beyond static data representation. This is where translating STIX data from its JSON format into the Web Ontology Language (OWL) and knowledge graphs becomes essential. Knowledge graphs offer a new level of semantic interoperability, enabling organizations to visualize, explore, and query the relationships and hierarchies between various threat entities.
Related: Zscaler Announces Deal to Acquire Red Canary
Knowledge graphs create a living, contextualized view of cyber threats, transforming what was once just a collection of isolated data points into a comprehensive landscape of interconnected threats.
With a knowledge graph, security teams can effectively map an exploit target — such as the infamous Log4Shell vulnerability (CVE-2021-44228) — to specific threat actors who have leveraged it in past campaigns. This capability allows them to prioritize their responses by understanding the vulnerability itself and analyzing its exploitation history, identifying the most likely perpetrators, and assessing the associated risks. This holistic view empowers organizations to adopt a proactive stance against cyber threats, enhancing their overall security posture.
## Merging Human-Readable Descriptions With Machine-based Logic
Using large language models (LLMs) to complement knowledge graphs marks an innovative leap in the application of AI within cybersecurity. By ingesting unstructured text data — such as incident reports, advisories, or analyst notes — LLMs can populate knowledge graphs with contextualized threat information. For instance, an LLM can transform descriptions of a spear-phishing campaign or details from an incident report into structured STIX instances, allowing for automated threat profiling and enhancing real-time decision-making.
Related: Danabot Takedown Deals Blow to Russian Cybercrime
The integration of LLMs and knowledge graphs not only streamlines threat profiling but also sets the stage for utilizing established cybersecurity frameworks to build a more robust understanding of potential threats.
## Building a Comprehensive Blueprint to Anticipate Threats
There is an extensive amount of data available from reliable sources such as MITRE, the National Institute of Standards and Technology (NIST), the Center for Internet Security (CIS), the Cybersecurity and Infrastructure Security Agency (CISA), and the National Vulnerability Database. These sources provide indispensable reference data about vulnerabilities, attack patterns, TTPs, mitigations, controls, computational platforms, and more.
Ontologies and knowledge graphs such as MITRE's D3FEND, MITRE's ATT&CK, and NIST's CVE graph databases provide representations of threat analysis data and logic that is both machine-readable and human-readable, as well as highly actionable. It is cybersecurity expertise represented in graph form.
Standardized ontologies, such as BFO, CCO, gistCyber, and D3FEND, can map out everything from vulnerabilities to TTPs and courses of action. When combined with an OWL-based knowledge graph, these frameworks provide a comprehensive blueprint for organizations to understand and anticipate threats. Adding STIX 2.1 via the CTIO into this mix bridges the gap between global standards and enterprise-specific threat intelligence, creating a consolidated knowledge base that draws on years of cybersecurity expertise.
## A New Paradigm in Cyber Threat Intelligence
The convergence of STIX, gistCyber, CTIO, OWL, knowledge graphs, and LLMs represents the next evolution in cybersecurity. Knowledge graphs enriched by AI create an environment where CTI is shared, contextualized, and made actionable. This is more than just a technical advancement; it's a paradigm shift. Cybersecurity is moving toward a system where threat intelligence is rich with context, immediately actionable, and more accessible.
The ultimate goal in developing these advanced, AI-powered knowledge graphs is to democratize cybersecurity intelligence. While industry experts continue to analyze, interpret, and act on threat data, the complexity of cyber threats necessitates solutions that can quickly convert expert knowledge into machine-readable formats. By leveraging LLMs and knowledge graphs, organizations can enable non-experts to use cybersecurity data effectively.
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What Is A Security Operations Center (SOC)? - Wiz
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https://www.wiz.io/academy/security-operations-center-soc
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security operations center SOC
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## What is a SOC?
A Security Operations Center (SOC) is a centralized function within an organization that employs people, processes, and technology to continuously monitor and improve an organization's security posture while preventing, detecting, analyzing, and responding to cybersecurity incidents.
Every SOC is unique. Made up of teams and processes as well as various tools and technologies, businesses can either outsource their SOC or build and maintain it in-house. Regardless of its implementation, the central objective of a SOC is to constantly optimize an organization's security posture and prevent cyberattacks.
These days, SOCs are increasingly important: After all, the threat landscape is more damaging than ever before. According to _The Independent_, threat actors caused more than 290 million data leaks in 2023. Without a powerful SOC, it’s almost impossible to prevent leaks and compromises; a SOC guards enterprise data, particularly high-value crown jewels such as business secrets, customers’ personally identifiable information (PII), credentials, and intellectual property.
The booming SOC-as-a-service market, which will reach $11.4 billion by 2028, underlines the importance of SOCs. As we’ll see, businesses have many SOC models to choose from and numerous factors to consider before making that decision. However, whichever model a company chooses, the fundamental functions and objectives of a SOC are the same. Let’s take a closer look.
## Key Goals of a Security Operations Center
A security operations center's primary goal is to **protect organizational assets and ensure business continuity**. To achieve this, the SOC aims to:
- **Minimize downtime and financial loss** due to security incidents.
- **Enhance the organization's security posture** by proactively identifying and mitigating risks.
- **Improve incident response time** and reduce the impact of cyberattacks.
- **Maintain compliance with industry regulations** and standards.
- **Build and maintain a strong security culture** within the organization.
- **Optimize security investments** through efficient resource allocation.
### Measuring SOC Goals
To effectively measure SOC performance, key performance indicators (KPIs) are essential. These metrics help quantify the SOC's success in achieving its goals.
**Examples of KPIs:**
- **Incident Response:** Mean Time to Detect (MTTD), Mean Time to Respond (MTTR), Mean Time to Contain (MTTC), and incident resolution rate.
- **Threat Detection:** False positive rate, true positive rate, and threat detection efficiency.
- **Security Posture:** Vulnerability remediation rate, patch compliance, and system configuration compliance.
- **Cost Efficiency:** Cost per incident, cost per protected asset, and return on security investment (ROSI).
wiz academy **SOC Metrics: Measuring SecOps KPIs** Read more
### Aligning SOC Goals with Business Objectives
A successful SOC should directly contribute to the overall business strategy. To achieve this alignment, the SOC must:
- **Understand business priorities:** Identify critical assets, systems, and data that support core business functions.
- **Quantify security risks:** Assess the potential impact of security incidents on business operations, revenue, and reputation.
- **Demonstrate business value:** Show how the SOC's efforts contribute to revenue generation, cost reduction, or risk mitigation.
- **Communicate effectively:** Clearly articulate the SOC's role in achieving business objectives to stakeholders.
wiz blog **CISOs share their top 7 strategies for gaining C-Suite buy-in** Read more
## How does a SOC function?
### What are the main roles within a SOC?
- **Chief information security officers (CISOs)**, who are at the top of the cybersecurity hierarchy, act as the bridge between the SOC and the CEO.
- **SOC managers** oversee all the teams, tools, workflows, and activities of the SOC.
- **Security engineers** build and maintain the enterprise’s cybersecurity architecture.
- **Threat hunters** proactively search for new and hidden threats within the enterprise’s IT estate.
- **Security analysts** monitor IT environments, red-flag anomalous behaviors, and triage alerts.
- **Forensic experts** anatomize cyber incidents to unveil the root cause, which can help enterprises prevent similar exploits in the future.
### What are the day-to-day processes in a SOC?
- **Threat monitoring:** Scanning IT environments and assets to uncover threats
- **Alert triage:** Prioritizing alerts and threats based on business and workload contexts
- **Threat analysis:** Investigating threats to validate their legitimacy and potency
- **Threat isolation:** Reducing the potential blast radius and attack path of each existing threat
- **Remediation:** Recovering compromised systems, patching vulnerabilities, and undoing the damage caused by cyber incidents
- **Forensic investigation:** Conducting thorough studies of threats, cyberattacks, and cloud events to understand adversary tools, tactics, and procedures (TTPs)
### What are the main technologies and tools in a SOC?
An optimal SOC should be holistic and include a spectrum of capabilities. For example, a SOC should provide:
- The means to identify and inventory all IT assets across physical and virtual infrastructures.
- Intrusion detection mechanisms to identify signs of unauthorized access.
- Proactive scanning of virtual machines, containers, container registries, serverless functions, virtual appliances, and managed compute resources (along with prioritization of any uncovered vulnerabilities).
- Behavioral analytics tools to analyze anomalous patterns within IT environments.
- Security information and event management (SIEM) tools to collect, manage, and analyze cybersecurity information from various branches of an organization.
- EDR (endpoint detection and response) to monitor and protect enterprise endpoints.
- Threat intelligence platforms to study an array of threat data from public, private, internal, and external sources.
- Cloud Detection and Response to montor and protect an enterprise’s cloud environments
Figure 1: The Wiz CDR at work
## What are the different types of SOC models?
There are 3 types of SOC models:
1. **In-house SOCs:** Businesses manage and operate their SOC using only in-house resources.
2. **Outsourced SOCs:** Enterpriseshire a third-party SOC-as-a-service provider to manage their SOC.
3. **Hybrid SOCs:** Businesses use a combination of in-house resources and outsourced services to manage their SOC.
According to Gartner, 63% of surveyed enterprises prefer a hybrid SOC model that leverages both in-house and outsourced security resources. Thirty-four percent feature an in-house SOC model that doesn’t include any external service providers.
wiz academy **What is SOC automation? Why and how to automate your SOC** Read more
### Choosing a SOC model
How does a business know which SOC model it should choose? The following are five key considerations for building or choosing in-house and outsourced SOC models:
| Considerations | In-House SOC | Outsourced SOC |
| --- | --- | --- |
| Customization and cost | An in-house SOC gives organizations a higher degree of control. However, in-house models are more expensive. | Businesses may not always be able to intricately tailor off-the-shelf SOC solutions, but they are considerably cheaper. |
| Scalability | In-house SOCs are not easy or affordable to scale. | Outsourced SOCs feature higher degrees of scalability, which can help accommodate future variables. |
| Required expertise | In-house SOC teams have in-depth knowledge of enterprise IT assets and resources. That said, they may lack other critical cybersecurity knowledge or expertise. | Third-party providers may not understand an enterprise’s IT environments as well as in-house security operations teams. On the other hand, third-party teams may have more expertise and skill sets related to the latest cybersecurity threats and trends. |
| Risk of coverage gaps | Because of the close proximity to their own environments, in-house SOC teams may have a biased or limited perspective. | Outsourced SOCs will likely have a more objective and panoramic view of an enterprise’s IT environments and adversaries. |
| Ease of updates | It’s often expensive for in-house SOCs to commission and include new tools and technologies. | Third-party providers constantly update and optimize their backend infrastructure and tools to serve their customers with cutting-edge capabilities. |
As we can see from the above table, both in-house and outsourced SOC models have myriad advantages and disadvantages. That’s perhaps why the majority of enterprises often choose the best of both worlds. In some cases, though, businesses may have a valid reason to choose one over the other. There’s no clear right or wrong answer when it comes to choosing a SOC model. Instead, it’s about understanding your unique IT and cybersecurity requirements and identifying a model that addresses them.
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Core Security Operations Center (SOC) Services
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https://www.justice.gov/jmd/core-security-operations-center-soc-services
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security operations center SOC
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Experience the unique advantages of the Department of Justice (DOJ) SOC services offered to federal agency partners. The Justice Security Operations Center (JSOC) stands as the central hub for 24x7, intelligence-driven network surveillance, incident response, interagency information exchange, threat intelligence, and cybersecurity inquiries.
By adhering to the U.S. Department of Homeland Security (DHS) Cybersecurity and Infrastructure Security Agency (CISA) guidelines for SOC shared service providers, the JSOC will partner with your agency to deliver top-tier security and compliance, ensuring the utmost protection of your valuable data and assets.
The modular nature of our services allows for cost-effective solutions tailored to your agency's unique requirements, while our 24x7 intelligence-driven approach always guarantees the highest level of cybersecurity.
By choosing DOJ SOC services, you are not only investing in the protection of your agency's valuable data and assets, but also fostering a collaborative relationship that promotes the exchange of vital information and best practices in the ever-evolving cybersecurity landscape.
Join us in our mission to safeguard our nation's digital frontiers.
## Cyber Threat Intelligence and Information Sharing
DOJ’s Cyber Threat Analytics Team (CTAT) provides digital threat monitoring, brand reputation monitoring, data breach monitoring, and very important person (VIP) monitoring to identify risks and threats to agency leadership. CTAT curates and distributes a summary of the previous week’s noteworthy cyber threat news. CTAT maintains a portal that provides daily CTI updates, intelligence summaries, DOJ’s block list, and other items of interest for agency partners.
## Detection Content Management
The DOJ curates detection alerts and correlation searches by leveraging our Unified Security Content Catalog (USCC) and existing agency partner content. We provide engineering support to integrate your Splunk instance to the DOJ’s Splunk instance and the Justice Incident Management System (JIMS).
## Network and System Monitoring
The JSOC provides 24x7x365 monitoring for security events identified by best-in-class security tools to identify possible cybersecurity incidents.
## Incident Analysis and Response
Our JSOC team analyzes the incident, parties involved, timeframe, and correlation to other incidents, all based on available agency data. If needed, JSOC requests additional data from the customer to complete its analysis. The JSOC provides agencies with recommendations for additional investigative steps, as well as steps for incident response and recovery. Our JSOC subject matter experts will conduct follow up with the agency customer to track incident closure. DOJ provides access to the JIMS that maintains a record of all security incidents, as well as a portal for customers to access dashboards and knowledge management pertaining to their service.
## Core SOC Benefits
Your organization has unique needs that don’t always translate with commercial cybersecurity vendors. At DOJ, we fully understand your opportunities and how to navigate through the government landscape. When considering the benefits of a managed service, agencies like yours quickly identify DOJ’s advantages. Some of the benefits that set DOJ apart from other cybersecurity options include:
- Reducing your total cost of ownership (TCO) for SOC capabilities by leveraging DOJ’s shared resourcing model
- 24x7x365 analysis of security alerts by DOJ analysts that reduces the time your staff spends trying to detect and respond to incidents
- Gaining the ability to leverage DOJ’s SMEs, intelligence analysts, and cyber threat hunters in the event of a major incident
- Proactive and ongoing cyber threat hunting of Security Information and Event (SIEM) logs based on a variety of curated cyber threat intelligence sources
- Minimizing the impact of staff turnover and reduction of cybersecurity team burnout
- Future-proofing your needs with DOJ’s enhanced scalability and agility
- Securing your alignment with the most current Office of Management and Budget (OMB) and CISA cybersecurity mandates
## Explore premium services:
With the understanding that every agency is unique and has specific needs to address, DOJ bases its model on flexibility and customization, offering customers advanced add-ons, described below. Click on a service to learn more.
### SIEM Platform
Our DOJ team designs, implements, and configures the full SIEM deployment, including the cloud platform and supporting on-premise infrastructure. DOJ provides full-service ongoing administration of the SIEM.
### Endpoint Protection Platform Management")
DOJ assists customers to deploy CrowdStrike agents to endpoints, unlocking capabilities like incident response and cyber threat hunting. Our DOJ SOC provides operations and maintenance for CrowdStrike tenants.
### Advanced Email Security Management")
Before providing expert operations and maintenance, DOJ assists customers to deploy Trellix Email Threat Protection (ETP) within its inbound email flow, including integration with Verizon E3A and the customer’s email provider.
### Cyber Threat Hunting
Utilizing industry best practices, DOJ can perform customized engagement-based cyber threat hunts tailored to the customer risks, concerns, environment, security tools, and specific hunt objectives.
### Digital Forensics
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The Benefits of a Security Operations Center for Financial Institutions
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https://www.bitlyft.com/resources/the-benefits-of-a-security-operations-center-for-financial-institutions
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security operations center SOC
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## The Benefits of a Security Operations Center for Financial Institutions
Financial institutions are prime targets for cybercriminals, and the need for robust security is more critical than ever. A Security Operations Center (SOC) provides continuous monitoring, threat detection, and rapid response to cybersecurity incidents, ensuring that financial institutions stay ahead of potential threats. By integrating real-time surveillance and expert analysis, SOCs help financial institutions protect sensitive financial data and maintain regulatory compliance.
## 24/7 Monitoring and Threat Detection
One of the primary benefits of a SOC is its ability to provide 24/7 monitoring of networks and systems. This continuous oversight allows financial institutions to detect and respond to threats in real-time, reducing the likelihood of successful cyberattacks. The proactive nature of SOC monitoring ensures that any suspicious activity is quickly addressed before it can escalate into a major security breach.
## Did You Know?
> Did you know that financial institutions face three times as many cyberattacks as other industries? A SOC provides the constant vigilance needed to protect sensitive data from these persistent threats.
## Incident Response and Mitigation
A SOC enables financial institutions to respond rapidly to security incidents, mitigating the impact of potential breaches. With dedicated cybersecurity professionals and advanced tools, SOCs can identify, contain, and resolve threats before they cause significant damage. This quick response is critical for maintaining the integrity of financial systems and minimizing downtime.
## Conclusion
A Security Operations Center is an essential component of financial institutions’ security strategies. With continuous monitoring, rapid incident response, and expert threat detection, SOCs provide the protection needed to safeguard sensitive financial data. To learn more about the benefits of implementing a SOC, visit BitLyft AIR® Security Operations Center.
## FAQs
What is a Security Operations Center (SOC)?
A Security Operations Center (SOC) is a centralized unit that provides continuous monitoring, threat detection, and incident response to protect organizations from cyberattacks.
Why do financial institutions need a SOC?
Financial institutions need a SOC because they are frequent targets of cyberattacks. A SOC provides continuous monitoring and rapid incident response, ensuring that sensitive financial data remains protected.
What are the key benefits of a SOC for financial institutions?
Key benefits include 24/7 monitoring, real-time threat detection, rapid incident response, and regulatory compliance, all of which help secure financial data and maintain operational continuity.
How does a SOC improve incident response?
A SOC improves incident response by providing dedicated security professionals and advanced tools to identify, contain, and resolve security incidents quickly, minimizing the impact of cyberattacks.
What is the role of a SOC in regulatory compliance?
A SOC helps financial institutions meet regulatory compliance by providing detailed monitoring, reporting, and threat intelligence that align with industry standards such as PCI DSS and GDPR.
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AWS vs. Azure vs. Google Cloud: A Security Feature Comparison | Jit
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https://www.jit.io/resources/cloud-sec-tools/aws-vs-azure-vs-google-cloud-a-security-feature-comparison
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cloud security AWS Azure
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When comparing the security offerings of AWS, Azure, and Google Cloud, it’s essential to go beyond listing features and understand where each cloud excels. Depending on your organization’s specific security needs—whether focused on identity management, encryption, compliance, or advanced threat detection—one platform may clearly stand out.
Cloud environments face various threats, from misconfigurations to unauthorized access and data breaches. A strong security mindedness not only mitigates these risks but also ensures compliance with industry regulations.
Each cloud provider offers a robust suite of tools, but the differences in their approaches needs to be assessed vs your overall cloud and application security strategy, alongside the primary sources of security threats and concerns for your engineering stack. Similarly, each application has its own unique requirements for data, infrastructure, and runtime security.
In this article, we’ll compare the various cloud security capabilities across AWS, Azure, and GCP to help you find the best cloud provider for your unique security needs.
## The Core Domains of Cloud Security
If we take a look at the core elements that comprise cloud security, they include:
- Identity and Access Management
- Encryption
- Network Security
- Monitoring & Threat intelligence
- Compliance
Among the top three cloud providers we will take a look at in this blog post, there are some unique security features that each cloud offers as well, that may very well tip the scales in their favor.
In this post, we’ll take a head to head look at the security offering of AWS vs. Azure vs. Google Cloud, and help you make the decision which cloud is the right one for you based on your organization’s security needs.
Below is a quick TL;DR comparison table that will help to sort the different cloud provider’s cloud security services into their cloud security categories.
**Comparison Table**
| Feature | AWS | Azure | Google Cloud |
| --- | --- | --- | --- |
| **Identity & Access** | IAM, Organizations | Azure AD, Conditional Access | IAM, BeyondCorp Zero Trust |
| **Encryption** | S3, KMS | Azure Key Vault, Disk Encryption | Default Encryption, CMEK |
| **Network Security** | Shield, WAF | Firewall, DDoS Protection | Cloud Armor, VPC Controls |
| **Monitoring & Threats** | GuardDuty, CloudTrail | Security Center, Sentinel | Chronicle, Command Center |
| **Compliance** | Extensive Certs | Regional Compliance Strength | Privacy-Focused Certifications |
| **Unique Strength** | Nitro System | Microsoft Integration | AI-Driven Analytics |
Below we will dive into each cloud security domain, and provide an overview of how each cloud provider stacks up and also the use case they excel at, and what to consider if this is the primary concern for your applications.
## Identity and Access Management (IAM)
AWS provides a mature and granular IAM system with support for hierarchical account structures through AWS Organizations, which is particularly advantageous for managing complex environments with multiple teams or projects. In the words of AWS’ famed CTO, Werner Vogels (slightly paraphrased), “IAM is the single AWS service that touches every single aspect of the Everything Cloud.”
Azure, however, shines in its deep integration with Microsoft ecosystems, using Azure Active Directory (Azure AD) as a central hub for identity and access management. Its Conditional Access feature enables advanced policies such as adaptive multi-factor authentication (MFA) based on user behavior and risk.
Google Cloud’s IAM, while straightforward, stands out for its implementation of BeyondCorp Zero Trust, offering a modern approach to access without traditional VPNs.
- **Best for centralized and hierarchical identity control:** AWS.
**Use Case:**Managing identities and permissions across multiple teams, accounts, or business units in a large enterprise.
- **Best for Microsoft integration and adaptive policies:**Azure.
**Use Case:**Enterprises heavily reliant on Microsoft Office 365, Windows Server, or Active Directory, needing integrated security and policy enforcement.
- **Best for organizations adopting Zero Trust models:**Google Cloud.
**Use Case:**Companies with a distributed workforce or those building modern SaaS platforms that require secure, remote access without VPN dependencies.
## Encryption and Data Protection
All three providers offer strong encryption features, but the way they implement and manage encryption sets them apart.
AWS leads with a robust Key Management Service (KMS) and comprehensive support for S3 Server-Side Encryption, making it ideal for industries with strict encryption requirements at scale.
Azure provides Azure Key Vault and Azure Disk Encryption, both tightly integrated into its ecosystem, simplifying encryption for enterprises running on Windows or using Azure SQL databases.
Google Cloud takes a different approach, encrypting all data at rest by default and offering Customer-Managed Encryption Keys (CMEK) for greater user control, making it a strong choice for privacy-conscious organizations.
- **Best for large-scale encryption and granular key management:**AWS.
**Use Case:** Organizations managing large volumes of sensitive data across multiple applications, needing fine-grained control over encryption keys and robust scalability.
- **Best for integration with enterprise ecosystems:**Azure.**Use Case:**Enterprises running hybrid environments with a mix of on-premises and cloud infrastructure that rely on Windows and Microsoft tools.
- **Best for privacy-first encryption by default:**Google Cloud.
**Use Case:** Organizations prioritizing stringent privacy regulations and requiring encryption for all data at rest by default without extensive configuration.
## Network Security
AWS sets the standard with AWS Shield and Web Application Firewall (WAF) for DDoS protection and application-layer filtering, catering to businesses requiring always-on, high-availability network security.
Azure offers Azure Firewall and DDoS Protection Standard, which integrate well with Azure-native services, making them seamless for Microsoft-centric architectures.
Google Cloud’s network security tools—Cloud Armor and VPC Service Controls—stand out for their ability to enforce service-level boundaries and protect against large-scale DDoS attacks, particularly for web applications or APIs.
- **Best for comprehensive DDoS protection and application-layer defense:**AWS.
**Use Case:** Organizations running high-traffic web applications or services requiring always-on DDoS protection and robust defense at the application layer.
- **Best for Microsoft-centric network integration:**Azure.
**Use Case:**Enterprises with hybrid cloud environments that need seamless network integration between on-premises infrastructure and Azure cloud services.
- **Best for API security and fine-grained network boundaries:** Google Cloud.
**Use Case:**Businesses developing and deploying API-driven applications that need strict access control and secure communication between services.
## Threat Detection and Monitoring
AWS leads with its machine-learning-powered Amazon GuardDuty and detailed activity logging through AWS CloudTrail. These tools excel in environments requiring continuous threat detection and robust auditing.
Azure brings in a competitive edge with Azure Security Center and Azure Sentinel, its SIEM solution that offers advanced analytics and integration with Microsoft’s threat intelligence network.
Google Cloud uses its expertise in AI with Google Chronicle for threat intelligence and Security Command Center for proactive monitoring, making it the go-to for organizations prioritizing AI-driven insights.
- **Best for real-time threat detection and logging:** AWS.
Use Case: Organizations needing continuous threat monitoring and robust logging capabilities to detect and respond to suspicious activity in real time.
- **Best for SIEM integration and analytics:**Azure.
**Use Case:** Enterprises requiring a centralized Security Information and Event Management (SIEM) solution to analyze and correlate security data from cloud and on-premises environments.
- **Best for AI-driven threat detection and insights:**Google Cloud.
**Use Case:** Organizations prioritizing advanced AI-driven insights for proactive threat detection and root cause analysis.
## Compliance
AWS boasts an extensive range of certifications (e.g., GDPR, SOC 2, HIPAA) and global availability, making it a strong contender for industries with high compliance demands.
Azure differentiates itself by offering strong regional compliance tools, with solutions tailored to meet local data sovereignty laws.
Google Cloud emphasizes privacy-centric certifications like GDPR and CCPA, excelling in jurisdictions with stringent data privacy regulations.
- **Best for global compliance and industry certifications:**AWS.
**Use Case:**Organizations operating across multiple countries and industries requiring a broad spectrum of global compliance certifications.
- **Best for regional and localized compliance needs:** Azure.
**Use Case:**Enterprises with strict data sovereignty requirements or industry-specific regulations in specific regions or countries.
- **Best for privacy-focused compliance frameworks:**Google Cloud.
**Use Case:**Organizations prioritizing privacy-centric regulations and frameworks, such as GDPR or CCPA, to protect sensitive personal data.
## Which Platform is Best Based on Your Security Needs?
- **If you need granular control over access, strong encryption at scale, and global compliance: AWS** is the clear choice. It’s ideal for enterprises managing complex environments or operating in highly regulated industries.
- **If your organization runs on Microsoft products or needs strong SIEM capabilities: Azure**provides seamless integration and analytics, making it the best fit for Windows-based enterprises or teams leveraging Microsoft’s ecosystem.
- **If you prioritize a Zero Trust model, privacy, and AI-driven threat detection: Google Cloud** offers cutting-edge tools and compliance tailored to modern security practices, making it an excellent option for innovative startups or privacy-focused industries.
Ultimately, the right choice comes down to your business goals, regulatory requirements, and technical needs. As businesses increasingly adopt multi-cloud or hybrid strategies, relying solely on a single provider’s security features is rarely sufficient.
The diversity of frameworks, clouds, and compliance requirements demands a vendor-agnostic open ASPM (Application Security Posture Management) approach to unify security across platforms. Jit aims to deliver exactly that—a proactive security management platform that integrates seamlessly with AWS, Azure, and Google Cloud to enhance your overall security posture.
By offering a unified and developer-friendly interface, it becomes less of a cognitive load to manage security across diverse environments without compromising on compliance or control.
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AWS vs. Azure - Comparing Cloud Security Providers - Darktrace
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https://www.darktrace.com/cyber-ai-glossary/aws-cloud-security-vs-azure-cloud-security
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cloud security AWS Azure
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# AWS Cloud Security vs. Azure Cloud Security
Contents
- Introduction: AWS vs Azure cloud security
- Introduction to cloud security
- AWS and Azure cloud security overview
- AWS cloud security pros and cons
- Azure cloud security pros and cons
- How to choose between AWS and Azure cloud security?
- Get the latest cloud security trends for 2025
## Introduction: AWS vs Azure cloud security
A thorough comparison of Amazon Web Services (AWS) and Azure cloud security can help end users chose the best option for their business. AWS and Azure are advanced cloud service providers offering extensive security features, but they differ in elements such as pay structures, interface complexities, and integration. Read more to learn about these key differences.
## Introduction to cloud security
Cloud security platforms make it easier for organizations to **increase information access and collaborate effectively** while protecting their data and processes. AWS and Azure are the two most significant cloud service providers (CSPs) offering the following services:
- **Databases:** AWS and Azure provide secure databases to safely store and back up data, enabling users to protect their data and restore it in the event of an outage, natural disaster, human error, or malicious attack.
- **Computing power:** Users rely on AWS and Azure's high-performance computing capabilities to access resources such as servers, software, and analytics. Both CSPs can perform calculations and process data much faster than a single server.
- **Networking:** Azure and AWS help users manage and protect network connections safely and efficiently.
Choosing the right CSP is essential for protecting your company's data, applications, and confidentiality. The right provider helps you safeguard your online operations and information **against sophisticated cyber-threats**, data breaches, unauthorized access, power outages, and natural disasters.
## AWS and Azure cloud security overview
AWS and Azure are pay-as-you-go cloud security models offering excellent security features. They protect your data and online applications, offering reliable features such as identity and access management, data encryption, and network security.
### What is the key difference between AWS and Azure cloud security?
While AWS and Azure have strong cloud security features, they differ in their approach and implementation. AWS has the most extensive range of key management features and encryption options, and Azure focuses on a multilayered security model and advanced threat protection services.
### Comparing AWS vs. Azure cloud security
AWS and Azure differ in the following key areas.
#### Key management and encryption
AWS features strong granular control and a wide range of encryption options through its Key Management Service's extensive capabilities. Azure features strong encryption, but its key management features and encryption capabilities are slightly less robust than the features and capabilities AWS offers.
#### Data processing
Azure and AWS offer excellent data processing. AWS features Elastic MapReduce (EMR), and Azure offers HD Insights and the Cortana Intelligence Suite, complete with Spark, Storm, HBase, and Hadoop.
#### Identity and access management
AWS's Identity and Access Management (IAM) offers a wider range of features such as policy-based permissions and multifactor authentication. Azure Active Directory (Azure AD) focuses on identity protection and conditional access.
#### Network security
AWS offers network customization and isolation through a virtual private cloud (VPC). Azure uses network security groups (NSGs) and Azure Virtual Network (VNet) to support granular traffic control.
#### Data security and compliance
AWS and Azure comply with various industry-specific regulations and standards, such as the Payment Card Industry Data Security Standard (PCI DSS) and the Health Insurance Portability and Accountability Act (HIPAA). However, AWS offers a wider range of compliance options such as the Federal Risk and Authorization Management Program (FedRAMP) and the General Data Protection Regulation (GDPR).
#### Microsoft product integration
Azure seamlessly integrates with Microsoft programs such as Active Directory and Office 365. It's typically the preferred option for organizations that heavily rely on the Microsoft ecosystem.
## AWS cloud security pros and cons
Determine if AWS is beneficial for your company based on the following pros and cons.
### Pros
- **Cost-effectiveness for larger workloads:** Azure is an excellent option for organizations with larger workloads because of its greater scalability.
- **Enhanced privacy:** AWS's virtual private cloud enables users to create private, secure networks in the Cloud.
- **Advanced open-source networks:** AWS is ideal for companies working on open-source apps and software.
### Cons
- **Complex pricing structure:** AWS's pricing structure is more complex than Azure's, especially for organizations with varying workloads. AWS offers a free basic service tier, but it may take extra examination to understand its full scope of options and choose the right one.
- **Complex interface:** Featuring a more complex interface than Azure's, AWS is better suited for businesses with a large or experienced IT department.
- **Less extensive integration capabilities:** AWS offers excellent integration options such as command line tools, SDKs, and APIs, but its integration capabilities are less flexible than Azure's.
## Azure cloud security pros and cons
Consider if Azure is the right choice for your business based on these pros and cons.
### Pros
- **Wide range of pricing options:** Azure offers various pricing options, such as a free basic service tier, a pay-as-you-go pricing model, and long-term commitment discounts. Azure's pricing options are also slightly more straightforward than AWS's.
- **Cost-effectiveness for smaller workloads:** Azure's pay-as-you-go pricing makes it the most cost-effective option for organizations with smaller workloads.
- **User-friendly interface:** Azure's interface is simple to navigate for organizations with limited IT resources, making it easier to manage online data and operations without an extensive IT team. Azure also features various resources and tools to help companies get started quickly.
- **Flexible integration:** Azure's flexible integration capabilities and various hybrid cloud capabilities make it easier for organizations that lean on Microsoft systems to integrate their existing structure with the Cloud.
### Cons
- **Complex documentation:** While Azure features a more user-friendly interface than AWS, its documentation can be difficult to locate and understand.
- **Less advanced open-source networks:** Azure offers open-source network capabilities and support, but its open-source features are less advanced than AWS's.
## How to choose between AWS and Azure cloud security?
Choosing the right cloud security platform depends on your business size, needs, and IT infrastructure. Smaller companies with limited IT support can benefit from Azure's pay-as-you-go pricing model and user-friendly interface, while larger companies or those that work with open-source software can benefit from AWS's extensive features.
It's also important to consider integration. Azure is the best option if you primarily rely on Microsoft programs because of its smooth integration. Meanwhile, AWS is ideal if you want to work in a VPC, use open-source apps, or access a wider range of encryption options.
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Microsoft Security for AWS - Azure Architecture Center
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https://learn.microsoft.com/en-us/azure/architecture/guide/aws/aws-azure-security-solutions
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Section titled: Microsoft Entra
## Microsoft Entra
Section titled: Centralized identity and access management
### Centralized identity and access management
Microsoft Entra ID is a comprehensive, cloud-based centralized identity and access management solution that can help secure and protect AWS accounts and environments.
Microsoft Entra ID provides strong SSO authentication to almost any app or platform that follows common web authentication standards, including AWS. AWS accounts that support critical workloads and highly sensitive information need strong identity protection and access control. AWS identity management is enhanced when you combine it with Microsoft Entra ID.
AWS organizations that use Microsoft Entra ID for Microsoft 365 or hybrid cloud identity and access protection can quickly and easily deploy Microsoft Entra ID for AWS accounts, often without incurring additional costs. Microsoft Entra ID provides several capabilities for direct integration with AWS:
- Integration with AWS IAM Identity Center for enhanced security, improved user experience, centralized access control, and SSO across legacy, traditional, and modern authentication solutions.
- Microsoft Entra multifactor authentication, including integration with several third-party solutions from Microsoft Intelligent Security Association partners.
- Powerful Conditional Access features for strong authentication and strict governance. Microsoft Entra ID uses Conditional Access policies and risk-based assessments to authenticate and authorize user access to the AWS Management Console and AWS resources.
- Improved protection against identity-based attacks via real-time detection and remediation of risky sign-ins and unusual user behavior.
- Privileged Identity Management (PIM) to enable just-in-time provisioning of specific resources. You can expand PIM to any delegated permission by controlling access to custom groups, like groups that you create for access to AWS roles.
For more information and detailed instructions, see Microsoft Entra identity and access management for AWS.
Section titled: Microsoft Entra Permissions Management
### Microsoft Entra Permissions Management
Permissions Management is a cloud infrastructure entitlement management solution that provides comprehensive visibility into and control over permissions on identities, actions, and resources across multicloud infrastructure on Azure, AWS, and Google Cloud Platform. You can use Permissions Management to:
- Discover the number of unused or excessive permissions across all AWS accounts to identify risks via a multidimensional view of identities, permissions, and resources.
- Remediate and right-size permissions via enforcement of the principle of least privilege across all AWS accounts.
- Monitor and alert anomalous activities to help prevent data breaches caused by misuse and malicious exploitation of permissions.
For more information and detailed onboarding instructions, see Onboard an Amazon Web Services (AWS) account.
Section titled: Microsoft Defender for Cloud Apps
### Microsoft Defender for Cloud Apps
When several users or roles make administrative changes, _configuration drift_ away from intended security architecture and standards can occur. Security standards can also change over time. Security personnel must constantly and consistently detect new risks, evaluate mitigation options, and update security architecture to help prevent potential breaches. Security management across multiple public cloud and private infrastructure environments can become burdensome.
Defender for Cloud Apps provides enhanced protection for software as a service (SaaS) applications. It provides the following features to help you monitor and protect your cloud app data:
- **Fundamental Cloud Access Security Broker functionality**, including shadow IT discovery, visibility into cloud app usage, enhanced protection against app-based threats from anywhere in the cloud, and information protection and compliance assessments.
- **SaaS Security Posture Management features** that enable security teams to improve the organization's security posture.
- **Advanced threat protection**, as part of the Microsoft extended detection and response solution, which enables powerful correlation of signal and visibility across the full cyberattack chain of advanced attacks.
- **App-to-app protection**, which extends the core threat scenarios to OAuth-enabled apps that have permissions and privileges to critical data and resources.
Connecting AWS to Defender for Cloud Apps helps you secure your assets and detect potential threats by monitoring administrative and sign-in activities. You get notifications of possible brute force attacks, malicious use of privileged user accounts, unusual deletions of VMs, and publicly exposed storage buckets. Defender for Cloud Apps helps protect AWS environments from abuse of cloud resources, compromised accounts and insider threats, data leakage, and resource misconfiguration and insufficient access control. The following Defender for Cloud Apps capabilities are especially useful when you work with AWS environments.
- Detect cloud threats, compromised accounts, malicious insiders, and ransomware. Defender for Cloud Apps anomaly detection policies are triggered when there are unusual activities performed by users in AWS. Defender for Cloud Apps continually monitors your users' activities and uses UEBA and machine learning to learn and understand the typical behavior of your users and trigger alerts on any deviations.
- Limit exposure of shared data and enforce collaboration policies. Automate governance controls via actions like notifying users about alerts, requiring re-authentication or suspending users, making an S3 bucket private, or removing collaborators from an S3 bucket.
- Audit activities. Connect AWS auditing to Defender for Cloud apps to get visibility into user, admin, and sign-in activities.
- Get enhanced real-time protection for AWS. Use Defender for Cloud Apps Conditional Access app control to block and help protect downloads of sensitive AWS data by risky users.
For more information on how to connect AWS environments to Defender for Cloud Apps, see Protect your Amazon Web Services environment.
Section titled: Microsoft Defender for Cloud
### Microsoft Defender for Cloud
Defender for Cloud is a Cloud-Native Application Protection Platform that's made up of security measures and practices that are designed to protect cloud-based applications from various cyberthreats and vulnerabilities. Defender for Cloud provides the following capabilities:
- A development security operations solution that unifies security management at the code level across multicloud and multiple-pipeline environments
- A cloud security posture management (CSPM) solution that surfaces actions that you can take to help prevent breaches
- A cloud workload protection platform (CWPP) that provides protection for servers, containers, storage, databases, and other workloads
Defender for Cloud native AWS support provides several benefits:
- Foundational CSPM for AWS resources
- Defender CSPM for AWS resources
- CWPP support for Amazon EKS clusters
- CWPP support for AWS EC2 instances
- CWPP support for SQL servers running on AWS EC2 and RDS Custom for SQL Server
The foundational CPSM and Defender CSPM are both completely agentless. Foundational CSPM provides recommendations on how to best harden your AWS resources and remediate misconfigurations. Defender for Cloud offers foundational multicloud CSPM capabilities for free.
Defender CSPM provides advanced posture management capabilities like attack path analysis, cloud security explorer, advanced threat hunting, and security governance capabilities. It also provides tools to assess your security compliance with a wide range of benchmarks, regulatory standards, and any custom security policies required in your organization, industry, or region.
The CWPP support for AWS EC2 instances provides capabilities like automatic provisioning of prerequisites on existing and new machines, vulnerability assessment, an integrated license for Microsoft Defender for Endpoint, file integrity monitoring, and more.
The CWPP support for Amazon EKS clusters provides capabilities like discovery of unprotected clusters, advanced threat detection for the control plane and workload level, Kubernetes data plane recommendations (via the Azure Policy extension), and more.
The CWPP support for SQL servers running on AWS EC2 and AWS RDS Custom for SQL Server provides capabilities like advanced threat protection, vulnerability assessment scanning, and more.
Security standards provide support for assessing resources and workloads in AWS against regulatory compliance standards like Center for Internet Security (CIS) and Payment Card Industry (PCI) standards, and for the AWS Foundational Security Best Practices standard.
For more information about protecting workloads in AWS, see Connect your AWS account and Assign regulatory compliance standards in Microsoft Defender for Cloud.
Section titled: Microsoft Sentinel
### Microsoft Sentinel
Microsoft Sentinel is a scalable cloud-native security information and event management (SIEM) system that provides an intelligent and comprehensive solution for SIEM and security orchestration, automation, and response. Microsoft Sentinel provides cyberthreat detection, investigation, response, and proactive hunting. It gives you a bird's-eye view across your enterprise.
You can use the AWS connectors to pull AWS service logs into Microsoft Sentinel. These connectors work by granting Microsoft Sentinel access to your AWS resource logs. Setting up the connector establishes a trust relationship between AWS and Microsoft Sentinel. You create this relationship on AWS by creating a role that gives permission to Microsoft Sentinel to access your AWS logs.
The connector can ingest logs from the following AWS services by pulling them from an S3 bucket:
Expand table
| Service | Data source |
| --- | --- |
| Amazon Virtual Private Cloud (VPC) | VPC Flow Logs |
| Amazon GuardDuty | GuardDuty findings |
| AWS CloudTrail | Management and data events |
| AWS CloudWatch | CloudWatch Logs |
For more information on how to install and configure the AWS connector in Microsoft Sentinel, see Connect Microsoft Sentinel to Amazon Web Services to ingest AWS service log data.
Section titled: Recommendations
### Recommendations
Use the Microsoft security solutions and basic AWS security recommendations to protect AWS accounts.
Section titled: Basic AWS account security
#### Basic AWS account security
For information about basic security hygiene for AWS accounts and resources, review the AWS security guidance at Best practices for securing AWS accounts and resources.
- Reduce the risk of uploading and downloading malware and other malicious content by actively inspecting all data transfers via the AWS Management Console. Content that you upload or download directly to resources within the AWS platform, such as web servers or databases, might need additional protection.
- Provide security for access keys by rotating the keys periodically. Avoid embedding them in code. Use IAM roles instead of long-term access keys wherever possible.
- Use security groups and network ACLs to control inbound and outbound traffic to your resources. Implement VPC to isolate resources.
- Encrypt sensitive data at rest and in transit by using AWS Key Management Services.
- Protect devices that administrators and developers use to access the AWS Management Console.
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Kubernetes and Container Security | by Ben Pournader - Medium
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https://benpournader.medium.com/kubernetes-and-container-security-146b4dc7c742
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container security Docker Kubernetes
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Vulnerabilities can affect container images just like any other software. Fundamental cybersecurity tasks, such as building a bill of materials, identifying embedded secrets, and classifying all image layers, remain crucial. The complexity arises from the sheer number of containers running in an application environment and the frequency of updates. With the rise of DevOps practices, organizations often update containerized applications multiple times a week. Each update introduces the potential for vulnerabilities, especially when managing thousands of containers in an IT environment.
One of the most challenging aspects of container security is securing the container runtime. Traditional security tools are not designed to monitor running containers, making it difficult to establish a secure baseline. Legacy tools often can’t inspect inside containers, leaving cybersecurity teams to address application security concerns not covered by traditional firewalls.
Access control to container orchestration platforms like Kubernetes is another critical issue. It’s essential to prevent risks from over-privileged accounts, network attacks, and unwanted lateral movement using allow list techniques, similar to legacy IT environments. Additionally, securing communications between pods within a Kubernetes cluster shared by multiple applications is necessary.
Finally, the operating system (OS) hosting your container environment is a critical yet often overlooked aspect of security. Any compromise to the host environment can provide cybercriminals with access to the entire application ecosystem. Each host must have its own set of security access controls and be continuously monitored for new vulnerabilities discovered after deployment
Kubernetes (aka K8S) security encompasses a wide range of topics aimed at ensuring the safety and integrity of containerized applications and the infrastructure they run on. Focusing on the following topics can help ensure a comprehensive approach to securing Kubernetes environments, safeguarding both the infrastructure and the applications running on it.
**1\. Cluster Setup and Configuration**
- **Secure Cluster Architecture**: Designing a secure Kubernetes cluster architecture, including control plane and worker nodes.
- **Role-Based Access Control (RBAC)**: Implementing RBAC to control access to Kubernetes resources.
- **Network Policies**: Defining network policies to control traffic between pods.
**2\. Authentication and Authorization**
- **User Authentication**: Configuring secure authentication mechanisms for users (e.g., OAuth, LDAP, etc.).
- **Service Account Management**: Managing and securing service accounts used by applications running in the cluster.
- **Pod Security Policies**: Enforcing security policies for pod configurations. A pod is the smallest unit of execution and deployable computing that can be created and managed
**3\. Data Security**
- **Secrets Management**: Securely managing sensitive information such as API keys, passwords, and certificates.
- **Encryption**: Implementing encryption for data at rest and in transit.
- **Persistent Volume Security**: Securing storage solutions used by Kubernetes.
**4\. Network Security**
- **Ingress and Egress Control**: Securing ingress and egress traffic to and from the cluster.
- **Service Mesh**: Using service mesh solutions like Istio for securing service-to-service communication.
- **DNS Security**: Ensuring the security of DNS services within the cluster.
**5\. Image Security**
- **Image Scanning**: Scanning container images for vulnerabilities before deployment.
- **Image Signing and Verification**: Using tools like Notary and TUF (The Update Framework) for image signing and verification.
- **Base Image Hardening**: Ensuring that base images are minimal and secure.
**6\. Runtime Security**
- **Pod Security**: Applying security contexts to pods to limit their capabilities.
- **Container Runtime Security**: Using tools like Falco to monitor and secure container runtime environments.
- **Intrusion Detection and Prevention**: Implementing IDS/IPS solutions to detect and prevent malicious activity.
**7\. Compliance and Monitoring**
- **Audit Logging**: Enabling and managing audit logs for compliance and forensic analysis.
- **Compliance Frameworks**: Adhering to compliance frameworks like PCI-DSS, GDPR, and HIPAA within the Kubernetes environment.
- **Monitoring and Alerting**: Setting up monitoring and alerting for security incidents using tools like Prometheus and Grafana.
**8\. Security Testing and Validation**
- **Penetration Testing**: Conducting regular penetration testing of the Kubernetes environment.
- **Vulnerability Management**: Continuously scanning and addressing vulnerabilities in the cluster.
- **Security Benchmarking**: Using benchmarks like CIS Kubernetes Benchmark to assess the security posture of the cluster.
**9\. Incident Response**
- **Incident Response Plan**: Developing and implementing an incident response plan specific to Kubernetes.
- **Forensics**: Preparing for forensic investigations within a Kubernetes environment.
- **Disaster Recovery**: Ensuring that disaster recovery plans include Kubernetes components.
**10\. Supply Chain Security**
- **Secure CI/CD Pipelines**: Implementing security measures in CI/CD pipelines to ensure secure code deployment.
- **Dependency Management**: Managing and securing dependencies used in applications.
- **Third-Party Integrations**: Securing integrations with third-party services and tools.
## How does a container security scanner or a Kubernetes scanner work?
A container security scanner is designed to detect vulnerabilities and misconfigurations in container images and Kubernetes clusters by:
**Container Image Scanning**
1. **Image Fetching**: The scanner fetches the container image from a container registry or a local repository. This involves pulling the image layers to analyze their contents.
2. **Layer Analysis**: The scanner inspects each layer of the container image. It looks for known vulnerabilities in the software packages, libraries, and binaries included in each layer.
3. **Vulnerability Database Comparison**: The scanner compares the software versions in the image against known vulnerability databases, such as the National Vulnerability Database (NVD), vendor-specific databases, and other sources of security advisories.
4. **Policy Enforcement**: The scanner checks for compliance with predefined security policies, such as prohibited software packages, configuration best practices (e.g., using non-root users) and ensuring no sensitive data (like hard-coded secrets) is included in the image.
5. **Reporting**: A good scanner generates a detailed report of the findings, including a list of detected vulnerabilities, severity levels (e.g., critical, high, medium, low) and recommendations for remediation (e.g., updating specific packages).
**Kubernetes Cluster Scanning**
1. **Configuration Analysis**: The scanner reviews the configuration files (e.g., YAML files) and runtime configurations of the Kubernetes cluster. It checks for security misconfigurations such as insecure API server configurations, improper use of Role-Based Access Control (RBAC), insecure network policies and Pod Security Policies (PSPs).
2. **Runtime Environment Checks**: The scanner monitors the runtime environment to detect any anomalies or suspicious activities. This can include unexpected changes in pod configurations, unauthorized access attempts and unusual network traffic patterns.
3. **Compliance Checks**: The scanner verifies that the cluster complies with security standards and benchmarks such as the CIS Kubernetes Benchmark. It assesses configurations against these best practices and industry standards.
4. **Vulnerability Detection**: Similar to image scanning, the scanner checks the deployed applications and their dependencies for known vulnerabilities. This includes scanning the images running in the cluster and the packages they contain.
5. **Secret Management**: The scanner looks for insecure handling of secrets within the cluster, such as secrets stored in plain text, insecure secret distribution methods, and inadequate access controls to secrets.
6. **Resource Limits and Quotas**: The scanner verifies that resource limits and quotas are properly configured to prevent resource exhaustion attacks and ensure fair resource allocation.
**Integration with CI/CD Pipelines**
- **Continuous Scanning**: Container security scanners can be integrated into CI/CD pipelines to ensure that images are scanned for vulnerabilities and compliance issues before they are deployed to production.
- **Automated Remediation**: Some scanners can provide automated remediation suggestions or even automatically update vulnerable packages if configured to do so.
**Reporting and Alerts**
- **Dashboards**: Scanners often provide dashboards for visualizing the security posture of container images and Kubernetes clusters. These dashboards display vulnerability trends, compliance status, and other key metrics.
- **Alerts**: Scanners can be configured to send alerts for critical vulnerabilities or security incidents detected in real-time. Alerts can be sent via email, messaging platforms (e.g., Slack), or integrated with other monitoring tools.
## Example Tools for scanning Kubernetes
Some popular container and Kubernetes security scanners include:
## 1\. Anchore
**Functions:**
- Performs deep inspection of container images.
- Scans for known vulnerabilities in packages and libraries.
- Enforces security and compliance policies.
- Integrates with CI/CD pipelines for continuous scanning.
**Advantages:**
- Comprehensive analysis and detailed reports.
- Supports custom policy definitions.
- Strong integration capabilities with CI/CD tools.
- Open-source and enterprise versions available.
**Disadvantages:**
- Can be resource-intensive during deep scans.
- Requires proper configuration for optimal performance.
- Some advanced features are only available in the enterprise version.
## 2\. Clair
**Functions:**
- Static analysis of vulnerabilities in container images.
- Fetches vulnerability data from various sources such as NVD, Red Hat, and others.
- Provides API for integration with other tools.
**Advantages:**
- Open-source and free to use.
- Integrates well with other container registry tools like Quay.
- Provides a REST API for flexible integration.
**Disadvantages:**
- Requires additional setup and integration with other tools for complete functionality.
- Not as feature-rich in terms of policy enforcement compared to other tools.
- May require manual updates for the vulnerability database.
## 3\. Trivy
**Functions:**
- Scans container images for vulnerabilities.
- Supports scanning of file systems and Git repositories.
- Detects vulnerabilities in operating system packages and application dependencies.
**Advantages:**
- Simple to use with minimal configuration.
- Fast scanning capabilities.
- Comprehensive coverage of vulnerabilities, including OS packages and application libraries.
- Open-source and lightweight.
**Disadvantages:**
- May not offer as many advanced features as some enterprise tools.
- Limited in terms of policy enforcement and compliance checks.
- May require integration with other tools for comprehensive security management.
## **4\. Aqua Security**
**Functions:**
- Image scanning and runtime protection for containers and Kubernetes.
- Enforces security policies and compliance.
- Monitors and protects against runtime threats.
- Provides network segmentation and controls.
**Advantages:**
- Comprehensive security solution covering both image and runtime security.
- Strong policy enforcement and compliance features.
- Advanced runtime protection with anomaly detection.
- Supports multiple orchestrators and cloud environments.
**Disadvantages:**
- Enterprise-level tool with associated costs.
- May require a learning curve to fully utilize advanced features.
- Resource-intensive and may require significant infrastructure to deploy.
## 5\. Sysdig Secure
**Functions:**
- Vulnerability management for containers and Kubernetes.
- Compliance checks and policy enforcement.
- Real-time monitoring and threat detection.
- Incident response and forensics capabilities.
**Advantages:**
- Strong runtime security features with real-time monitoring.
- Detailed compliance and audit reports.
- Integration with popular CI/CD tools.
- Comprehensive incident response features.
**Disadvantages:**
- Enterprise-focused with associated costs.
- Can be complex to set up and configure.
- May require significant resources for deployment and operation.
## 6\. Twistlock (now part of Prisma Cloud by Palo Alto Networks)
**Functions**:
- Image scanning and vulnerability management.
- Runtime defense and compliance enforcement.
- Integrates with CI/CD pipelines and container registries.
- Provides risk assessment and visibility into container environments.
**Advantages:**
- Comprehensive feature set covering image and runtime security.
- Strong integration with CI/CD tools and registries.
- Advanced threat detection and compliance features.
- Backed by a well-established security vendor (Palo Alto Networks).
**Disadvantages:**
- Enterprise-focused with higher costs.
- Can be complex and resource-intensive to deploy.
- Some users may find the interface and configuration options overwhelming.
## 7\. Qualys Container Security
**Functions:**
- Vulnerability scanning for container images and registries.
- Continuous monitoring of running containers.
- Policy compliance and enforcement.
- Integration with CI/CD pipelines for continuous security.
**Advantages:**
- Strong integration with existing Qualys security products.
- Comprehensive vulnerability and compliance management.
- Real-time monitoring and alerting.
- Scalable for large environments.
**Disadvantages:**
- Enterprise-focused with higher costs.
- Requires Qualys platform subscription.
- May be complex to integrate with non-Qualys environments.
## 8\. Kube-bench
**Functions:**
- Checks Kubernetes clusters against the CIS Kubernetes Benchmark.
- Provides detailed reports on compliance and security posture.
- Easy to run as a Kubernetes job or standalone tool.
**Advantages:**
- Open-source and free to use.
- Specifically tailored for Kubernetes security benchmarks.
- Simple to set up and run within a Kubernetes cluster.
**Disadvantages:**
- Limited to CIS Benchmark checks.
- Does not provide real-time monitoring or threat detection.
- May require additional tools for comprehensive security coverage.
# Other Tools for Container Security
## **1\. Container Monitoring Tools**
Container monitoring tools are essential for applying and maintaining container security. These tools are necessary to track containers, which are among the most ephemeral atomic units of computing ever created. As developers constantly rip and replace containers, monitoring tools become critical for cybersecurity and IT operations teams. They enable the application of time-series stamps to containers, which is crucial for determining precisely what happened and when in a containerized environment.
## **2\. Container Firewalls**
A container firewall is a security tool specifically designed to inspect, monitor, and protect network traffic associated with containerized applications. It provides similar functionalities to traditional firewalls but is tailored to the dynamic and ephemeral nature of containers. Key aspects of a container firewall are:
**2.a. Key Functions of Container Firewalls**
1\. **Traffic Inspection**: Monitors and inspects all inbound and outbound traffic to and from containers. This includes traffic between containers, as well as traffic between containers and external networks or legacy applications.
2\. **Access Control**: Enforces security policies to control which traffic is allowed or denied. This can include rules based on IP addresses, ports, protocols, and other criteria.
3\. **Threat Detection and Prevention**: Identifies and blocks malicious traffic and potential attacks. This includes protection against common threats like DDoS attacks, unauthorized access, and data breaches.
4\. **Network Segmentation**: Helps segment network traffic between different containers and microservices, ensuring that only authorized communication paths are used. This reduces the risk of lateral movement by attackers.
5\. **Visibility and Logging**: Provides visibility into network traffic patterns and logs traffic events for analysis and auditing purposes. This helps in understanding traffic flows and identifying unusual or suspicious activities.
**2.b.Deployment Models of Container Firewalls**
· **Sidecar Containers**: Many container firewalls are deployed as sidecar containers, meaning they run alongside the application containers they are protecting. This model allows the firewall to inspect and control traffic for each specific application container.
· **Service Mesh Integration**: Some container firewalls integrate with service mesh architectures, providing security controls as part of the service mesh’s traffic management capabilities.
**2.c. Advantages of Container Firewalls**
- **Granular Security**: Provides fine-grained control over container network traffic, allowing for precise security policies tailored to individual containers and microservices.
- **Scalability**: Designed to scale with containerized environments, handling the dynamic nature of container deployments where containers are frequently created and destroyed.
- **Automation**: Often integrates with DevOps tools and CI/CD pipelines, enabling automated deployment and updating of security policies as part of the application lifecycle.
**2.d. Challenges of Container Firewalls**
- **Complexity**: Managing security policies across a large number of containers and microservices can be complex and require sophisticated tools and processes.
- **Performance**: Adding additional layers of inspection and control can introduce latency, so it’s important to balance security with performance considerations.
- **Integration**: Requires integration with container orchestration platforms (e.g., Kubernetes) and other security tools to provide comprehensive protection.
**2.e. Some Examples for Container Firewalls**
- **Aqua Security**: Provides container firewall capabilities as part of its broader container security platform.
- **Twistlock (Prisma Cloud)**: Offers a range of container security features, including network security and firewall capabilities.
- **Cilium**: An open-source project that provides networking, security, and observability for containers, with firewall features based on eBPF (extended Berkeley Packet Filter).
- **Calico**: A networking and network security solution for containers that includes firewall capabilities for Kubernetes environments.
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Configure a Security Context for a Pod or Container - Kubernetes
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https://kubernetes.io/docs/tasks/configure-pod-container/security-context/
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container security Docker Kubernetes
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Yes (reduced from 39426 to 32086 chars)
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# Configure a Security Context for a Pod or Container
A security context defines privilege and access control settings for
a Pod or Container. Security context settings include, but are not limited to:
- Discretionary Access Control: Permission to access an object, like a file, is based on
user ID (UID) and group ID (GID).
- Security Enhanced Linux (SELinux):
Objects are assigned security labels.
- Running as privileged or unprivileged.
- Linux Capabilities:
Give a process some privileges, but not all the privileges of the root user.
- AppArmor:
Use program profiles to restrict the capabilities of individual programs.
- Seccomp: Filter a process's system calls.
- `allowPrivilegeEscalation`: Controls whether a process can gain more privileges than
its parent process. This bool directly controls whether the
`no_new_privs`
flag gets set on the container process.
`allowPrivilegeEscalation` is always true when the container:
- is run as privileged, or
- has `CAP_SYS_ADMIN`
- `readOnlyRootFilesystem`: Mounts the container's root filesystem as read-only.
The above bullets are not a complete set of security context settings -- please see
SecurityContext
for a comprehensive list.
## Before you begin
You need to have a Kubernetes cluster, and the kubectl command-line tool must
be configured to communicate with your cluster. It is recommended to run this tutorial on a cluster with at least two nodes that are not acting as control plane hosts. If you do not already have a
cluster, you can create one by using
minikube
or you can use one of these Kubernetes playgrounds:
- Killercoda
- KodeKloud
- Play with Kubernetes
To check the version, enter `kubectl version`.
## Set the security context for a Pod
To specify security settings for a Pod, include the `securityContext` field
in the Pod specification. The `securityContext` field is a
PodSecurityContext object.
The security settings that you specify for a Pod apply to all Containers in the Pod.
Here is a configuration file for a Pod that has a `securityContext` and an `emptyDir` volume:
`pods/security/security-context.yaml`
```yaml
apiVersion: v1
kind: Pod
metadata:
name: security-context-demo
securityContext:
runAsUser: 1000
runAsGroup: 3000
fsGroup: 2000
supplementalGroups: [4000]
volumes:
- name: sec-ctx-vol
emptyDir: {}
containers:
- name: sec-ctx-demo
image: busybox:1.28
command: [ "sh", "-c", "sleep 1h" ]
volumeMounts:
- name: sec-ctx-vol
mountPath: /data/demo
securityContext:
allowPrivilegeEscalation: false
In the configuration file, the `runAsUser` field specifies that for any Containers in
the Pod, all processes run with user ID 1000. The `runAsGroup` field specifies the primary group ID of 3000 for
all processes within any containers of the Pod. If this field is omitted, the primary group ID of the containers
will be root(0). Any files created will also be owned by user 1000 and group 3000 when `runAsGroup` is specified.
Since `fsGroup` field is specified, all processes of the container are also part of the supplementary group ID 2000.
The owner for volume `/data/demo` and any files created in that volume will be Group ID 2000.
Additionally, when the `supplementalGroups` field is specified, all processes of the container are also part of the
specified groups. If this field is omitted, it means empty.
Create the Pod:
```shell
kubectl apply -f https://k8s.io/examples/pods/security/security-context.yaml
Verify that the Pod's Container is running:
```shell
kubectl get pod security-context-demo
Get a shell to the running Container:
```shell
kubectl exec -it security-context-demo -- sh
In your shell, list the running processes:
```shell
The output shows that the processes are running as user 1000, which is the value of `runAsUser`:
```none
PID USER TIME COMMAND
1 1000 0:00 sleep 1h
6 1000 0:00 sh
In your shell, navigate to `/data`, and list the one directory:
```shell
cd /data
The output shows that the `/data/demo` directory has group ID 2000, which is
the value of `fsGroup`.
```none
drwxrwsrwx 2 root 2000 4096 Jun 6 20:08 demo
In your shell, navigate to `/data/demo`, and create a file:
```shell
cd demo
echo hello > testfile
List the file in the `/data/demo` directory:
```shell
The output shows that `testfile` has group ID 2000, which is the value of `fsGroup`.
```none
-rw-r--r-- 1 1000 2000 6 Jun 6 20:08 testfile
Run the following command:
```shell
The output is similar to this:
```none
uid=1000 gid=3000 groups=2000,3000,4000
From the output, you can see that `gid` is 3000 which is same as the `runAsGroup` field.
If the `runAsGroup` was omitted, the `gid` would remain as 0 (root) and the process will
be able to interact with files that are owned by the root(0) group and groups that have
the required group permissions for the root (0) group. You can also see that `groups`
contains the group IDs which are specified by `fsGroup` and `supplementalGroups`,
in addition to `gid`.
Exit your shell:
```shell
### Implicit group memberships defined in `/etc/group` in the container image
By default, kubernetes merges group information from the Pod with information defined in `/etc/group` in the container image.
`pods/security/security-context-5.yaml`
```yaml
apiVersion: v1
kind: Pod
metadata:
name: security-context-demo
securityContext:
runAsUser: 1000
runAsGroup: 3000
supplementalGroups: [4000]
containers:
- name: sec-ctx-demo
image: registry.k8s.io/e2e-test-images/agnhost:2.45
command: [ "sh", "-c", "sleep 1h" ]
securityContext:
allowPrivilegeEscalation: false
This Pod security context contains `runAsUser`, `runAsGroup` and `supplementalGroups`.
However, you can see that the actual supplementary groups attached to the container process
will include group IDs which come from `/etc/group` in the container image.
Create the Pod:
```shell
kubectl apply -f https://k8s.io/examples/pods/security/security-context-5.yaml
Verify that the Pod's Container is running:
```shell
kubectl get pod security-context-demo
Get a shell to the running Container:
```shell
kubectl exec -it security-context-demo -- sh
Check the process identity:
```shell
The output is similar to this:
```none
uid=1000 gid=3000 groups=3000,4000,50000
You can see that `groups` includes group ID `50000`. This is because the user ( `uid=1000`),
which is defined in the image, belongs to the group ( `gid=50000`), which is defined in `/etc/group`
inside the container image.
Check the `/etc/group` in the container image:
```shell
$ cat /etc/group
You can see that uid `1000` belongs to group `50000`.
```none
user-defined-in-image:x:1000:
group-defined-in-image:x:50000:user-defined-in-image
Exit your shell:
```shell
#### Note:
_Implicitly merged_ supplementary groups may cause security problems particularly when accessing
the volumes (see kubernetes/kubernetes#112879 for details).
If you want to avoid this. Please see the below section.
## Configure fine-grained SupplementalGroups control for a Pod
FEATURE STATE: `Kubernetes v1.33 [beta]` (enabled by default: true)
This feature can be enabled by setting the `SupplementalGroupsPolicy` feature gate for kubelet and
kube-apiserver, and setting the `.spec.securityContext.supplementalGroupsPolicy` field for a pod.
The `supplementalGroupsPolicy` field defines the policy for calculating the
supplementary groups for the container processes in a pod. There are two valid
values for this field:
- `Merge`: The group membership defined in `/etc/group` for the container's primary user will be merged.
This is the default policy if not specified.
- `Strict`: Only group IDs in `fsGroup`, `supplementalGroups`, or `runAsGroup` fields
are attached as the supplementary groups of the container processes.
This means no group membership from `/etc/group` for the container's primary user will be merged.
When the feature is enabled, it also exposes the process identity attached to the first container process
in `.status.containerStatuses[].user.linux` field. It would be useful for detecting if
implicit group ID's are attached.
`pods/security/security-context-6.yaml`
```yaml
apiVersion: v1
kind: Pod
metadata:
name: security-context-demo
securityContext:
runAsUser: 1000
runAsGroup: 3000
supplementalGroups: [4000]
supplementalGroupsPolicy: Strict
containers:
- name: sec-ctx-demo
image: registry.k8s.io/e2e-test-images/agnhost:2.45
command: [ "sh", "-c", "sleep 1h" ]
securityContext:
allowPrivilegeEscalation: false
This pod manifest defines `supplementalGroupsPolicy=Strict`. You can see that no group memberships
defined in `/etc/group` are merged to the supplementary groups for container processes.
Create the Pod:
```shell
kubectl apply -f https://k8s.io/examples/pods/security/security-context-6.yaml
Verify that the Pod's Container is running:
```shell
kubectl get pod security-context-demo
Check the process identity:
```shell
kubectl exec -it security-context-demo -- id
The output is similar to this:
```none
uid=1000 gid=3000 groups=3000,4000
See the Pod's status:
```shell
kubectl get pod security-context-demo -o yaml
You can see that the `status.containerStatuses[].user.linux` field exposes the process identitiy
attached to the first container process.
```none
status:
containerStatuses:
- name: sec-ctx-demo
linux:
gid: 3000
supplementalGroups:
uid: 1000
#### Note:
Please note that the values in the `status.containerStatuses[].user.linux` field is _the first attached_
process identity to the first container process in the container. If the container has sufficient privilege
to make system calls related to process identity
(e.g. `setuid(2)`,
`setgid(2)` or
`setgroups(2)`, etc.),
the container process can change its identity. Thus, the _actual_ process identity will be dynamic.
### Implementations
**Note:** This section links to third party projects that provide functionality required by Kubernetes. The Kubernetes project authors aren't responsible for these projects, which are listed alphabetically. To add a project to this list, read the content guide before submitting a change. More information.
The following container runtimes are known to support fine-grained SupplementalGroups control.
CRI-level:
- containerd, since v2.0
- CRI-O, since v1.31
You can see if the feature is supported in the Node status.
```yaml
apiVersion: v1
kind: Node
status:
features:
supplementalGroupsPolicy: true
#### Note:
At this alpha release(from v1.31 to v1.32), when a pod with `SupplementalGroupsPolicy=Strict` are scheduled to a node that does NOT support this feature(i.e. `.status.features.supplementalGroupsPolicy=false`), the pod's supplemental groups policy falls back to the `Merge` policy _silently_.
However, since the beta release (v1.33), to enforce the policy more strictly, **such pod creation will be rejected by kubelet because the node cannot ensure the specified policy**. When your pod is rejected, you will see warning events with `reason=SupplementalGroupsPolicyNotSupported` like below:
```yaml
apiVersion: v1
kind: Event
type: Warning
reason: SupplementalGroupsPolicyNotSupported
message: "SupplementalGroupsPolicy=Strict is not supported in this node"
involvedObject:
apiVersion: v1
kind: Pod
## Configure volume permission and ownership change policy for Pods
FEATURE STATE: `Kubernetes v1.23 [stable]`
By default, Kubernetes recursively changes ownership and permissions for the contents of each
volume to match the `fsGroup` specified in a Pod's `securityContext` when that volume is
mounted.
For large volumes, checking and changing ownership and permissions can take a lot of time,
slowing Pod startup. You can use the `fsGroupChangePolicy` field inside a `securityContext`
to control the way that Kubernetes checks and manages ownership and permissions
for a volume.
**fsGroupChangePolicy** \- `fsGroupChangePolicy` defines behavior for changing ownership
and permission of the volume before being exposed inside a Pod.
This field only applies to volume types that support `fsGroup` controlled ownership and permissions.
This field has two possible values:
- _OnRootMismatch_: Only change permissions and ownership if the permission and the ownership of
root directory does not match with expected permissions of the volume.
This could help shorten the time it takes to change ownership and permission of a volume.
- _Always_: Always change permission and ownership of the volume when volume is mounted.
For example:
```yaml
securityContext:
runAsUser: 1000
runAsGroup: 3000
fsGroup: 2000
fsGroupChangePolicy: "OnRootMismatch"
#### Note:
This field has no effect on ephemeral volume types such as
`secret`,
`configMap`,
and `emptydir`.
## Delegating volume permission and ownership change to CSI driver
FEATURE STATE: `Kubernetes v1.26 [stable]`
If you deploy a Container Storage Interface (CSI)
driver which supports the `VOLUME_MOUNT_GROUP` `NodeServiceCapability`, the
process of setting file ownership and permissions based on the
`fsGroup` specified in the `securityContext` will be performed by the CSI driver
instead of Kubernetes. In this case, since Kubernetes doesn't perform any
ownership and permission change, `fsGroupChangePolicy` does not take effect, and
as specified by CSI, the driver is expected to mount the volume with the
provided `fsGroup`, resulting in a volume that is readable/writable by the
`fsGroup`.
## Set the security context for a Container
To specify security settings for a Container, include the `securityContext` field
in the Container manifest. The `securityContext` field is a
SecurityContext object.
Security settings that you specify for a Container apply only to
the individual Container, and they override settings made at the Pod level when
there is overlap. Container settings do not affect the Pod's Volumes.
Here is the configuration file for a Pod that has one Container. Both the Pod
and the Container have a `securityContext` field:
`pods/security/security-context-2.yaml`
```yaml
apiVersion: v1
kind: Pod
metadata:
name: security-context-demo-2
securityContext:
runAsUser: 1000
containers:
- name: sec-ctx-demo-2
image: gcr.io/google-samples/hello-app:2.0
securityContext:
runAsUser: 2000
allowPrivilegeEscalation: false
Create the Pod:
```shell
kubectl apply -f https://k8s.io/examples/pods/security/security-context-2.yaml
Verify that the Pod's Container is running:
```shell
kubectl get pod security-context-demo-2
Get a shell into the running Container:
```shell
kubectl exec -it security-context-demo-2 -- sh
In your shell, list the running processes:
```shell
ps aux
The output shows that the processes are running as user 2000. This is the value
of `runAsUser` specified for the Container. It overrides the value 1000 that is
specified for the Pod.
USER PID %CPU %MEM VSZ RSS TTY STAT START TIME COMMAND
2000 1 0.0 0.0 4336 764 ? Ss 20:36 0:00 /bin/sh -c node server.js
2000 8 0.1 0.5 772124 22604 ? Sl 20:36 0:00 node server.js
Exit your shell:
```shell
## Set capabilities for a Container
With Linux capabilities,
you can grant certain privileges to a process without granting all the privileges
of the root user. To add or remove Linux capabilities for a Container, include the
`capabilities` field in the `securityContext` section of the Container manifest.
First, see what happens when you don't include a `capabilities` field.
Here is configuration file that does not add or remove any Container capabilities:
`pods/security/security-context-3.yaml`
```yaml
apiVersion: v1
kind: Pod
metadata:
name: security-context-demo-3
containers:
- name: sec-ctx-3
image: gcr.io/google-samples/hello-app:2.0
Create the Pod:
```shell
kubectl apply -f https://k8s.io/examples/pods/security/security-context-3.yaml
Verify that the Pod's Container is running:
```shell
kubectl get pod security-context-demo-3
Get a shell into the running Container:
```shell
kubectl exec -it security-context-demo-3 -- sh
In your shell, list the running processes:
```shell
ps aux
The output shows the process IDs (PIDs) for the Container:
USER PID %CPU %MEM VSZ RSS TTY STAT START TIME COMMAND
root 1 0.0 0.0 4336 796 ? Ss 18:17 0:00 /bin/sh -c node server.js
root 5 0.1 0.5 772124 22700 ? Sl 18:17 0:00 node server.js
In your shell, view the status for process 1:
```shell
cd /proc/1
cat status
The output shows the capabilities bitmap for the process:
CapPrm: 00000000a80425fb
CapEff: 00000000a80425fb
Make a note of the capabilities bitmap, and then exit your shell:
```shell
Next, run a Container that is the same as the preceding container, except
that it has additional capabilities set.
Here is the configuration file for a Pod that runs one Container. The configuration
adds the `CAP_NET_ADMIN` and `CAP_SYS_TIME` capabilities:
`pods/security/security-context-4.yaml`
```yaml
apiVersion: v1
kind: Pod
metadata:
name: security-context-demo-4
containers:
- name: sec-ctx-4
image: gcr.io/google-samples/hello-app:2.0
securityContext:
capabilities:
add: ["NET_ADMIN", "SYS_TIME"]
Create the Pod:
```shell
kubectl apply -f https://k8s.io/examples/pods/security/security-context-4.yaml
Get a shell into the running Container:
```shell
kubectl exec -it security-context-demo-4 -- sh
In your shell, view the capabilities for process 1:
```shell
cd /proc/1
cat status
The output shows capabilities bitmap for the process:
CapPrm: 00000000aa0435fb
CapEff: 00000000aa0435fb
Compare the capabilities of the two Containers:
00000000a80425fb
00000000aa0435fb
In the capability bitmap of the first container, bits 12 and 25 are clear. In the second container,
bits 12 and 25 are set. Bit 12 is `CAP_NET_ADMIN`, and bit 25 is `CAP_SYS_TIME`.
See capability.h
for definitions of the capability constants.
#### Note:
Linux capability constants have the form `CAP_XXX`.
But when you list capabilities in your container manifest, you must
omit the `CAP_` portion of the constant.
For example, to add `CAP_SYS_TIME`, include `SYS_TIME` in your list of capabilities.
## Set the Seccomp Profile for a Container
To set the Seccomp profile for a Container, include the `seccompProfile` field
in the `securityContext` section of your Pod or Container manifest. The
`seccompProfile` field is a
SeccompProfile object consisting of `type` and `localhostProfile`.
Valid options for `type` include `RuntimeDefault`, `Unconfined`, and
`Localhost`. `localhostProfile` must only be set if `type: Localhost`. It
indicates the path of the pre-configured profile on the node, relative to the
kubelet's configured Seccomp profile location (configured with the `--root-dir`
flag).
Here is an example that sets the Seccomp profile to the node's container runtime
default profile:
```yaml
securityContext:
seccompProfile:
type: RuntimeDefault
Here is an example that sets the Seccomp profile to a pre-configured file at
`<kubelet-root-dir>/seccomp/my-profiles/profile-allow.json`:
```yaml
securityContext:
seccompProfile:
type: Localhost
localhostProfile: my-profiles/profile-allow.json
## Set the AppArmor Profile for a Container
To set the AppArmor profile for a Container, include the `appArmorProfile` field
in the `securityContext` section of your Container. The `appArmorProfile` field
AppArmorProfile object consisting of `type` and `localhostProfile`.
Valid options for `type` include `RuntimeDefault`(default), `Unconfined`, and
`Localhost`. `localhostProfile` must only be set if `type` is `Localhost`. It
indicates the name of the pre-configured profile on the node. The profile needs
to be loaded onto all nodes suitable for the Pod, since you don't know where the
pod will be scheduled.
Approaches for setting up custom profiles are discussed in
Setting up nodes with profiles.
Note: If `containers[*].securityContext.appArmorProfile.type` is explicitly set
to `RuntimeDefault`, then the Pod will not be admitted if AppArmor is not
enabled on the Node. However if `containers[*].securityContext.appArmorProfile.type`
is not specified, then the default (which is also `RuntimeDefault`) will only
be applied if the node has AppArmor enabled. If the node has AppArmor disabled
the Pod will be admitted but the Container will not be restricted by the
`RuntimeDefault` profile.
Here is an example that sets the AppArmor profile to the node's container runtime
default profile:
```yaml
containers:
- name: container-1
securityContext:
appArmorProfile:
type: RuntimeDefault
Here is an example that sets the AppArmor profile to a pre-configured profile
named `k8s-apparmor-example-deny-write`:
```yaml
containers:
- name: container-1
securityContext:
appArmorProfile:
type: Localhost
localhostProfile: k8s-apparmor-example-deny-write
For more details please see, Restrict a Container's Access to Resources with AppArmor.
## Assign SELinux labels to a Container
To assign SELinux labels to a Container, include the `seLinuxOptions` field in
the `securityContext` section of your Pod or Container manifest. The
`seLinuxOptions` field is an
SELinuxOptions
object. Here's an example that applies an SELinux level:
```yaml
securityContext:
seLinuxOptions:
level: "s0:c123,c456"
#### Note:
To assign SELinux labels, the SELinux security module must be loaded on the host operating system.
On Windows and Linux worker nodes without SELinux support, this field and any SELinux feature gates described
below have no effect.
### Efficient SELinux volume relabeling
FEATURE STATE: `Kubernetes v1.28 [beta]` (enabled by default: true)
#### Note:
Kubernetes v1.27 introduced an early limited form of this behavior that was only applicable
to volumes (and PersistentVolumeClaims) using the `ReadWriteOncePod` access mode.
Kubernetes v1.33 promotes `SELinuxChangePolicy` and `SELinuxMount` feature gates
as beta to widen that performance improvement to other kinds of PersistentVolumeClaims,
as explained in detail below. While in beta, `SELinuxMount` is still disabled by default.
With `SELinuxMount` feature gate disabled (the default in Kubernetes 1.33 and any previous release),
the container runtime recursively assigns SELinux label to all
files on all Pod volumes by default. To speed up this process, Kubernetes can change the
SELinux label of a volume instantly by using a mount option
`-o context=<label>`.
To benefit from this speedup, all these conditions must be met:
- The feature gate `SELinuxMountReadWriteOncePod` must be enabled.
- Pod must use PersistentVolumeClaim with applicable `accessModes` and feature gates:
- Either the volume has `accessModes: ["ReadWriteOncePod"]`, and feature gate `SELinuxMountReadWriteOncePod` is enabled.
- Or the volume can use any other access modes and all feature gates
`SELinuxMountReadWriteOncePod`, `SELinuxChangePolicy` and `SELinuxMount` must be enabled
and the Pod has `spec.securityContext.seLinuxChangePolicy` either nil (default) or `MountOption`.
- Pod (or all its Containers that use the PersistentVolumeClaim) must
have `seLinuxOptions` set.
- The corresponding PersistentVolume must be either:
- A volume that uses the legacy in-tree `iscsi`, `rbd` or `fc` volume type.
- Or a volume that uses a CSI driver.
The CSI driver must announce that it supports mounting with `-o context` by setting
`spec.seLinuxMount: true` in its CSIDriver instance.
When any of these conditions is not met, SELinux relabelling happens another way: the container
runtime recursively changes the SELinux label for all inodes (files and directories)
in the volume. Calling out explicitly, this applies to Kubernetes ephemeral volumes like
`secret`, `configMap` and `projected`, and all volumes whose CSIDriver instance does not
explicitly announce mounting with `-o context`.
When this speedup is used, all Pods that use the same applicable volume concurrently on the same node
**must have the same SELinux label**. A Pod with a different SELinux label will fail to start and will be
`ContainerCreating` until all Pods with other SELinux labels that use the volume are deleted.
FEATURE STATE: `Kubernetes v1.33 [beta]` (enabled by default: true)
For Pods that want to opt-out from relabeling using mount options, they can set
`spec.securityContext.seLinuxChangePolicy` to `Recursive`. This is required
when multiple pods share a single volume on the same node, but they run with
different SELinux labels that allows simultaneous access to the volume. For example, a privileged pod
running with label `spc_t` and an unprivileged pod running with the default label `container_file_t`.
With unset `spec.securityContext.seLinuxChangePolicy` (or with the default value `MountOption`),
only one of such pods is able to run on a node, the other one gets ContainerCreating with error
`conflicting SELinux labels of volume <name of the volume>: <label of the running pod> and <label of the pod that can't start>`.
#### SELinuxWarningController
To make it easier to identify Pods that are affected by the change in SELinux volume relabeling,
a new controller called `SELinuxWarningController` has been introduced in kube-controller-manager.
It is disabled by default and can be enabled by either setting the `--controllers=*,selinux-warning-controller` command line flag,
or by setting `genericControllerManagerConfiguration.controllers` field in KubeControllerManagerConfiguration.
This controller requires `SELinuxChangePolicy` feature gate to be enabled.
When enabled, the controller observes running Pods and when it detects that two Pods use the same volume
with different SELinux labels:
1. It emits an event to both of the Pods. `kubectl describe pod <pod-name>` the shows
`SELinuxLabel "<label on the pod>" conflicts with pod <the other pod name> that uses the same volume as this pod with SELinuxLabel "<the other pod label>". If both pods land on the same node, only one of them may access the volume`.
2. Raise `selinux_warning_controller_selinux_volume_conflict` metric. The metric has both pod
names + namespaces as labels to identify the affected pods easily.
A cluster admin can use this information to identify pods affected by the planning change and
proactively opt-out Pods from the optimization (i.e. set `spec.securityContext.seLinuxChangePolicy: Recursive`).
#### Warning:
We strongly recommend clusters that use SELinux to enable this controller and make sure that
`selinux_warning_controller_selinux_volume_conflict` metric does not report any conflicts before enabling `SELinuxMount`
feature gate or upgrading to a version where `SELinuxMount` is enabled by default.
#### Feature gates
The following feature gates control the behavior of SELinux volume relabeling:
- `SELinuxMountReadWriteOncePod`: enables the optimization for volumes with `accessModes: ["ReadWriteOncePod"]`.
This is a very safe feature gate to enable, as it cannot happen that two pods can share one single volume with
this access mode. This feature gate is enabled by default sine v1.28.
- `SELinuxChangePolicy`: enables `spec.securityContext.seLinuxChangePolicy` field in Pod and related SELinuxWarningController
in kube-controller-manager. This feature can be used before enabling `SELinuxMount` to check Pods running on a cluster,
and to pro-actively opt-out Pods from the optimization.
This feature gate requires `SELinuxMountReadWriteOncePod` enabled. It is beta and enabled by default in 1.33.
- `SELinuxMount` enables the optimization for all eligible volumes. Since it can break existing workloads, we recommend
enabling `SELinuxChangePolicy` feature gate + SELinuxWarningController first to check the impact of the change.
This feature gate requires `SELinuxMountReadWriteOncePod` and `SELinuxChangePolicy` enabled. It is beta, but disabled
by default in 1.33.
## Managing access to the `/proc` filesystem
FEATURE STATE: `Kubernetes v1.33 [beta]` (enabled by default: true)
For runtimes that follow the OCI runtime specification, containers default to running in a mode where
there are multiple paths that are both masked and read-only.
The result of this is the container has these paths present inside the container's mount namespace, and they can function similarly to if
the container was an isolated host, but the container process cannot write to
them. The list of masked and read-only paths are as follows:
- Masked Paths:
- `/proc/asound`
- `/proc/acpi`
- `/proc/kcore`
- `/proc/keys`
- `/proc/latency_stats`
- `/proc/timer_list`
- `/proc/timer_stats`
- `/proc/sched_debug`
- `/proc/scsi`
- `/sys/firmware`
- `/sys/devices/virtual/powercap`
- Read-Only Paths:
- `/proc/bus`
- `/proc/fs`
- `/proc/irq`
- `/proc/sys`
- `/proc/sysrq-trigger`
For some Pods, you might want to bypass that default masking of paths.
The most common context for wanting this is if you are trying to run containers within
a Kubernetes container (within a pod).
The `securityContext` field `procMount` allows a user to request a container's `/proc`
be `Unmasked`, or be mounted as read-write by the container process. This also
applies to `/sys/firmware` which is not in `/proc`.
```yaml
securityContext:
procMount: Unmasked
#### Note:
Setting `procMount` to Unmasked requires the `spec.hostUsers` value in the pod
spec to be `false`. In other words: a container that wishes to have an Unmasked
`/proc` or unmasked `/sys` must also be in a
user namespace.
Kubernetes v1.12 to v1.29 did not enforce that requirement.
## Discussion
The security context for a Pod applies to the Pod's Containers and also to
the Pod's Volumes when applicable. Specifically `fsGroup` and `seLinuxOptions` are
applied to Volumes as follows:
- `fsGroup`: Volumes that support ownership management are modified to be owned
and writable by the GID specified in `fsGroup`. See the
Ownership Management design document
for more details.
- `seLinuxOptions`: Volumes that support SELinux labeling are relabeled to be accessible
by the label specified under `seLinuxOptions`. Usually you only
need to set the `level` section. This sets the
Multi-Category Security (MCS)
label given to all Containers in the Pod as well as the Volumes.
#### Warning:
After you specify an MCS label for a Pod, all Pods with the same label can access the Volume.
If you need inter-Pod protection, you must assign a unique MCS label to each Pod.
## Clean up
Delete the Pod:
```shell
kubectl delete pod security-context-demo
kubectl delete pod security-context-demo-2
kubectl delete pod security-context-demo-3
kubectl delete pod security-context-demo-4
|
Docker Scout in Kubernetes: Advanced Container Security for Cloud ...
|
https://dev.to/docker/docker-scout-in-kubernetes-advanced-container-security-for-cloud-native-environments-10gm
|
container security Docker Kubernetes
|
Yes (reduced from 13447 to 8975 chars)
|
As organizations scale their Kubernetes deployments, container security becomes increasingly critical. Docker Scout offers powerful security features for Kubernetes environments, enabling DevSecOps teams to implement robust container security across their cloud-native infrastructure. This comprehensive guide explores how to leverage Docker Scout for Kubernetes security automation and vulnerability management.
## Implementing Docker Scout in Kubernetes Clusters
First, let's set up a comprehensive Kubernetes security scanning pipeline using Docker Scout:
# kubernetes-security-operator.yaml
apiVersion: apps/v1
kind: Deployment
metadata:
name: scout-security-operator
namespace: container-security
selector:
matchLabels:
app: scout-security
template:
containers:
- name: scout-operator
image: scout-security-operator:latest
- name: KUBERNETES_CLUSTER
valueFrom:
fieldRef:
fieldPath: metadata.namespace
volumeMounts:
- name: docker-socket
mountPath: /var/run/docker.sock
volumes:
- name: docker-socket
hostPath:
path: /var/run/docker.sock
Enter fullscreen modeExit fullscreen mode
## Custom Kubernetes Controllers for Container Security
Implement a custom controller for automated security scanning:
from kubernetes import client, config, watch
from typing import Dict, List
import docker
import logging
class KubernetesSecurityController:
def __init__(self):
config.load_incluster_config()
self.v1 = client.CoreV1Api()
self.docker_client = docker.from_env()
self.setup_security_logging()
def watch_pod_events(self):
w = watch.Watch()
for event in w.stream(self.v1.list_pod_for_all_namespaces):
if event['type'] == 'ADDED':
self.scan_pod_containers(event['object'])
async def scan_pod_containers(self, pod):
"""Scan all containers in a Kubernetes pod"""
for container in pod.spec.containers:
scan_results = await self.run_security_scan(container.image)
self.process_scan_results(pod.metadata.name, scan_results)
except Exception as e:
logging.error(f"Container security scan failed: {str(e)}")
async def run_security_scan(self, image: str) -> Dict:
"""Execute Docker Scout security scan"""
result = await self.docker_client.containers.run(
'docker/scout:latest',
command=['cves', image, '--format', 'json']
return json.loads(result)
Enter fullscreen modeExit fullscreen mode
## Kubernetes Security Policies with Docker Scout
Implement custom security policies for your Kubernetes environment:
# kubernetes-security-policy.yaml
apiVersion: security.k8s.io/v1beta1
kind: PodSecurityPolicy
metadata:
name: scout-security-policy
privileged: false
seLinux:
rule: RunAsAny
supplementalGroups:
rule: RunAsAny
runAsUser:
rule: MustRunAsNonRoot
fsGroup:
rule: RunAsAny
volumes:
- configMap
- emptyDir
- projected
- secret
- downwardAPI
- persistentVolumeClaim
Enter fullscreen modeExit fullscreen mode
## Multi-Cluster Security Management
Implement centralized security monitoring across Kubernetes clusters:
class MultiClusterSecurityManager:
def __init__(self, clusters: List[str]):
self.clusters = clusters
self.security_results = {}
async def scan_all_clusters(self):
"""Execute security scans across all Kubernetes clusters"""
for cluster in self.clusters:
config.load_kube_config(context=cluster)
v1 = client.CoreV1Api()
pods = v1.list_pod_for_all_namespaces()
for pod in pods.items:
await self.scan_pod_security(cluster, pod)
async def scan_pod_security(self, cluster: str, pod):
"""Scan individual pod security across clusters"""
security_results = await self.run_security_scan(pod)
self.security_results[f"{cluster}/{pod.metadata.name}"] = security_results
def generate_security_report(self) -> Dict:
"""Generate comprehensive security report"""
return {
'clusters_scanned': len(self.clusters),
'total_vulnerabilities': self.count_total_vulnerabilities(),
'critical_vulnerabilities': self.count_critical_vulnerabilities(),
'cluster_security_status': self.get_cluster_security_status()
Enter fullscreen modeExit fullscreen mode
## GitOps Integration for Security Automation
Implement security automation through GitOps:
# security-gitops-pipeline.yaml
apiVersion: argoproj.io/v1alpha1
kind: Application
metadata:
name: security-automation
namespace: argocd
project: container-security
source:
repoURL: https://github.com/org/security-automation
path: kubernetes/security
targetRevision: HEAD
destination:
server: https://kubernetes.default.svc
namespace: container-security
syncPolicy:
automated:
prune: true
selfHeal: true
Enter fullscreen modeExit fullscreen mode
## Best Practices for Kubernetes Security
1. **Continuous Security Monitoring**
- Implement real-time container scanning
- Monitor Kubernetes security posture
- Track security compliance status
2. **Security Automation Patterns**
- Automate vulnerability remediation
- Implement security policy enforcement
- Enable automated security reporting
3. **Cluster Security Optimization**
- Optimize security resource usage
- Implement security rate limiting
- Configure security priorities
4. **Security Compliance Management**
- Maintain security audit trails
- Generate compliance reports
- Document security changes
## Conclusion
Integrating Docker Scout with Kubernetes creates a robust container security platform that enables organizations to maintain strong security postures across their cloud-native infrastructure. By implementing these patterns and practices, teams can ensure consistent security coverage while automating critical security operations.
|
Security | Kubernetes
|
https://kubernetes.io/docs/concepts/security/
|
container security Docker Kubernetes
|
Yes (reduced from 11459 to 6175 chars)
|
# Security
Concepts for keeping your cloud-native workload secure.
This section of the Kubernetes documentation aims to help you learn to run
workloads more securely, and about the essential aspects of keeping a
Kubernetes cluster secure.
Kubernetes is based on a cloud-native architecture, and draws on advice from the
CNCF about good practice for
cloud native information security.
Read Cloud Native Security and Kubernetes
for the broader context about how to secure your cluster and the applications that
you're running on it.
## Kubernetes security mechanisms
Kubernetes includes several APIs and security controls, as well as ways to
define policies that can form part of how you manage information security.
### Control plane protection
A key security mechanism for any Kubernetes cluster is to
control access to the Kubernetes API.
Kubernetes expects you to configure and use TLS to provide
data encryption in transit
within the control plane, and between the control plane and its clients.
You can also enable encryption at rest
for the data stored within Kubernetes control plane; this is separate from using
encryption at rest for your own workloads' data, which might also be a good idea.
### Secrets
The Secret API provides basic protection for
configuration values that require confidentiality.
### Workload protection
Enforce Pod security standards to
ensure that Pods and their containers are isolated appropriately. You can also use
RuntimeClasses to define custom isolation
if you need it.
Network policies let you control
network traffic between Pods, or between Pods and the network outside your cluster.
You can deploy security controls from the wider ecosystem to implement preventative
or detective controls around Pods, their containers, and the images that run in them.
### Admission control
Admission controllers
are plugins that intercept Kubernetes API requests and can validate or mutate
the requests based on specific fields in the request. Thoughtfully designing
these controllers helps to avoid unintended disruptions as Kubernetes APIs
change across version updates. For design considerations, see
Admission Webhook Good Practices.
### Auditing
Kubernetes audit logging provides a
security-relevant, chronological set of records documenting the sequence of actions
in a cluster. The cluster audits the activities generated by users, by applications
that use the Kubernetes API, and by the control plane itself.
## Cloud provider security
**Note:** Items on this page refer to vendors external to Kubernetes. The Kubernetes project authors aren't responsible for those third-party products or projects. To add a vendor, product or project to this list, read the content guide before submitting a change. More information.
If you are running a Kubernetes cluster on your own hardware or a different cloud provider,
consult your documentation for security best practices.
## Policies
You can define security policies using Kubernetes-native mechanisms,
such as NetworkPolicy
(declarative control over network packet filtering) or
ValidatingAdmissionPolicy (declarative restrictions on what changes
someone can make using the Kubernetes API).
However, you can also rely on policy implementations from the wider
ecosystem around Kubernetes. Kubernetes provides extension mechanisms
to let those ecosystem projects implement their own policy controls
on source code review, container image approval, API access controls,
networking, and more.
|
How to Secure IoT Devices - NinjaOne
|
https://www.ninjaone.com/blog/how-to-secure-iot-devices/
|
IoT device security
|
Yes (reduced from 32598 to 26874 chars)
|
## Introduction to IoT device security
Remote access and interconnectivity make life easier for users; unfortunately, they also create opportunities for bad actors looking to steal your private data. Properly securing IoT and IIoT devices from cyber threats and attacks is crucial for protecting yourself from data theft, network compromise, and financial loss. Although IoT devices are convenient because they are interconnected on local networks, using them can be risky, especially if you aren’t following all recommended IoT devices security practices. That’s why organizations must prioritize security. Hence, they employ IT teams and MSPs to protect IoT devices and ensure they are capable of addressing potential vulnerabilities within their IoT networks.
A few of the potential security vulnerabilities associated with IoT devices include weaknesses from inconsistent patches and updates, weak or default credentials, and poorly secured networks. Many IoT device owners set up their devices and then forget about them, frequently keeping the default username and password (which can easily be found on the dark web) and neglecting to take security precautions. This makes your IT environment vulnerable to attacks. To mitigate these risks, consulting with top US Pentest Companies can provide comprehensive security assessments and recommendations for safeguarding your IoT ecosystem.
## Security threats for IoT devices
The greatest strength of IoT devices is arguably its biggest weakness. The convenience these devices provide expands their attack surface, increasing your organization’s exposure to cybercrime.
Because IoT devices are part of a networked system of interconnected computing devices, compromised or insecure devices could be more vulnerable to:
- Distributed denial of service
- Firmware exploits
- Man-in-the-middle attacks
- Brute force
- Data inception
- Ransomware
- Radiofrequency jamming
- Unauthorized access
It’s also worth considering that:
- **Many IoT devices have limited built-in security.** In general, IoT endpoints have limited built-in security, especially for older devices. This implies that connected devices can remain unprotected for years. We’ll discuss how to mitigate this risk in the next section.
- **IoT devices are almost always on with remote access.** IoT devices are connected 24/7—which makes them great when you need to connect to them remotely, but also means that anyone can attempt to log in.
- **Lack of awareness.** Users often don’t think about IoT devices, thinking they are already secured. This lack of proactive IT management increases their risk of being hacked.
- **Increased risk of sprawl.** The more IoT devices you have, the higher the risk of software sprawl. The sheer number of connected devices in an organization could overwhelm its ability to secure each endpoint.
## Challenges of managing IoT devices
- **IoT security.** By its very nature, IoT opens networks to a higher risk of hacking. It’s worth noting that every innovation comes with its own unique vulnerability. In this case, IoT’s inherent connectivity opens itself up to hacking.
- **Managing device updates.** Many IoT devices require frequent updates, which can only be done manually. However, many new wireless devices now allow automatic over-the-air (OTA) updates.
- **Detecting vulnerabilities.** As mentioned earlier, many IoT devices are not built with security in mind. This means they are not equipped with the same security features as standard computers.
**Securing encryption.** Many IoT devices do not encrypt communications when transferring data over a public Wi-Fi network
## How to secure IoT devices
### 1) Use strong passwords and authentication
Changing the default credentials is the most important first step to securing your devices. However, if you change the password to something simple and easy, you haven’t done yourself much good. Instead, be sure to use unique and strong passwords for IoT devices. Avoid reusing passwords across devices, and be sure that any password storage solution that you use is encrypted and secure. Additionally, consider implementing multi-factor authentication (MFA) for enhanced security where possible. Never respond to MFA requests that you did not initiate.
### 2) Carefully manage device inventory
Device discovery and inventory will also improve your security. Knowing all connected IoT devices on the network means you are able to secure all connected devices ( _this is a tricky thing to accomplish if you don’t have a way to identify every device that you need to secure_). Any unsecured device is a potential attack vector, so it’s important to use best security practices on every device connected to your network.
Although many people struggle to manage many IoT devices in their environments, you can stay a step ahead of attackers by employing automated tools for device discovery and maintaining an inventory with a device management system. NinjaOne offers a network monitoring solution that will track and monitor all IoT devices, as well as other networking equipment like routers and switches.
### 3) Isolate IoT devices from critical systems and data
Network segmentation divides a network into smaller networks to better manage traffic or to improve security. For IoT device security, network segmentation contributes by isolating IoT devices from critical systems and data. Essentially, it’s insulation that keeps your information from leaking and prevents attackers from accessing all of your devices, so even if attackers infiltrate your network, they are limited to that subnet rather than allowed access to the whole.
Having subnets also gives you more control and monitoring ability. You can more easily identify who is accessing your network and isolate the new device or user. It’s a good idea to follow zero-trust protocols in network segmentation, meaning that all new devices are immediately quarantined and cannot connect to others until after review. Finally, you can use your subnets to limit IoT device access to the Internet and reduce or eliminate outgoing traffic.
### 4) Regularly patch and update IoT devices
It’s important for IT professionals to recognize the role of regular patching and updates in IoT security. Like any other devices, IoT devices use software to complete their various functions, and that software needs to be regularly updated to prevent attackers from exploiting known vulnerabilities. Many of the applications that are available are built on open-source software, which means that attackers could be studying how to infiltrate your network long before they actually make the attempt. So, if there are any known vulnerabilities, it’s a good idea to patch them as soon as possible, especially those labeled critical or high-risk.
Establishing an efficient patch management process for IoT devices is also important. It can be challenging to keep up with all of the necessary updates for every IoT device that connects to your network, so implementing a Remote Management and Monitoring (RMM) solution that can facilitate your efforts may be useful. RMM solutions enable you to schedule updates and patches and will push them out to all relevant devices automatically, reducing your workload and allowing your team to vastly improve its efficiency. It also improves the overall speed of addressing vulnerabilities, which means you will be able to patch more of them than you would if you were patching manually.
### 5) Eliminate unused IoT devices
If you don’t use one of your IoT devices, don’t be tempted to leave it in your environment. Any device still connected but not maintained poses a potential security risk. You likely won’t be monitoring or patching a device you aren’t thinking about, which means that any attackers who attempt to access it may have a relatively easy time exploiting it. To protect your other devices, eliminate these extraneous potential attack vectors.
### 6) Use centralized management
A single pane of glass platform helps you easily monitor device behavior, network traffic, and data flows to detect anomalies that may indicate a breach in IoT devices security. This proactive approach allows you to respond swiftly to threats and minimize potential damage.
Additionally, a unified platform enables you to implement and enforce security policies across your IoT network. By setting clear guidelines and monitoring IT compliance, you can ensure your devices adhere to industry standards and regulations. This helps to protect sensitive data and maintain a secure operating environment.
### 7) Leverage automation
Automated responses can significantly reduce the window of opportunity for malicious actors to exploit weaknesses in connected devices. By implementing automated follow-up procedures, organizations can minimize the risk of compromise and maintain the integrity of their IoT networks.
### 8) Encrypt your connection
Encrypt your connection whenever possible to safeguard IoT data both in transit and at rest. Organizations can significantly reduce the risk of unauthorized access and data breaches by encrypting data as it travels between devices and back-end systems.
### 9) Prioritize vendor security
Vendors of IoT devices typically lay out their strategies for protecting their products to prevent susceptibility. You can do extensive research to be informed which vendors prioritize security in their product design and development processes. You want to ensure that the manufacturers of your chosen IoT devices have robust security measures. These security measures may include timely updates and patches to address known vulnerabilities.
### 10) Implement strong access controls
Take time in curating Role-Based Access Controls (RBAC) by granting users only the necessary privileges to perform their tasks. This helps limit potential damages in cases of unauthorized usage. Enforcing ideal password policies like frequent password changes can also help with this strategy.
### 11) Monitor and log device activities
Consistently logging IoT device activities is also a great way to maintain IoT devices security within your network. Use reliable tools that can monitor and log events within your IoT network to ensure every instance, such as device interactions, network traffic, and user activity, is recorded.
### 12) Secure firmware updates
Make sure that you and other users install firmware updates only from trusted sources. This can help prevent malicious code injections. When installing firmware updates, you must use secure channels to transfer them to prevent interception and tampering.
### 13) Conduct penetration testing
Another thing you can do is employ regular penetration testing by conducting security audits. This can help identify and address potential vulnerabilities in your IoT devices and infrastructure. You can also perform penetration testing by simulating real-world attacks to identify weaknesses in your security measures. These actions can help alleviate and remediate identified vulnerabilities and minimize threatening risks to your IoT environment.
### 14) Train users on best practices
Everyone who uses IoT devices within your network must know how to manage their security and protection. Awareness training about the threats on IoT networks can amplify the development and enforcement of clear security policies for IoT device usage. Conduct regular security awareness campaigns to inform users about the latest threats and best practices.
### 15) Consider a security-focused IoT platform
To bolster IoT security, consider employing managed security services to delegate security tasks to specialists. Additionally, opt for IoT platforms prioritizing robust security features such as encryption, secure boot mechanisms, and intrusion detection systems. These combined approaches can significantly enhance the overall security posture of your IoT environment.
## Implementing stronger IoT device security policies
There are some basic steps that you can take to experience better IoT device security.
Utilize encryption methods like AES or DES to secure data transmitted by IoT devices. Implement data protection strategies, including antivirus, automated monitoring, data visibility solutions, and strong passwords with multi-factor authentication to safeguard sensitive information.
Simple Network Management Protocol (SNMP) monitoring and management is a useful tool for keeping your IoT devices secure. SNMP is a protocol that collects information and manages devices on a network so that they are secured against unauthorized access. To efficiently manage your network with SNMP, however, monitoring and management tools or solutions are recommended.
SNMP solutions provide a central platform for monitoring all of your network-connected devices, allowing you to monitor traffic, access, and activity. You can also keep an eye on hardware performance and set up customized alerts to inform you of unusual activity. Additionally, a high-quality SNMP solution like NinjaOne can also discover new devices and categorize them based on authentication credentials.
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How to Make Sure IoT Devices Don't Compromise Security
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https://www.infosecurityeurope.com/en-gb/blog/threat-vectors/iot-device-security.html
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# How to Make Sure IoT Devices Don’t Compromise Security
The Internet of Things (IoT) has revolutionised the way we live, work, and interact with our surroundings. However, the proliferation of IoT devices has also introduced new security risks and vulnerabilities.
Forescout’s _The Riskiest Connected Devices in 2024_ report, found that devices containing vulnerabilities surged by 136% compared to the previous year.
IoT devices include wireless access points, routers, printers, voice over Internet Protocol (VoIP) and IP cameras, all of which were Forescout found to have vulnerabilities.
Rik Ferguson, VP Security Intelligence at Forescout, previously told _Infosecurity_ that threat actors primarily target IoT devices connected to the enterprise stack, such as IP cameras and building management systems, ahead of consumer smart products.
“There are tutorials shared in underground forums about how to compromise and use them for lateral movement, exfiltration and command and control, because they are invisible in most cases to the enterprise security stack,” noted Ferguson.
Research by Irdeo found that cyber-attacks on IoT devices could cost the UK economy over £1bn each year. As well as causing downtime, attacks on IoT devices can compromise data.
## Manufacturer Responsibilities on IoT Security
Many argue that the responsibility for securing these devices must be placed on the manufacturers. Vulnerabilities are often present in devices because those making them have not develop them to high enough security standards.
“The market for IoT devices is characterised by rapid innovation and short product cycles. Manufacturers are under pressure to get new products to market quickly to stay ahead of competitors,” noted Nikki Webb, Global Channel Manager at Custondian360. “This rush can lead to security being an afterthought, as speed to market often takes precedence over comprehensive security testing.”
In order to tackle this, there have been a number of attempts to design standards and pass legislation to enhance the security of IoT devices.
These include:
- UK’s Product Security and Telecommunications Infrastructure (PSTI) Bill which aims to strengthen the security of IoT devices. This came into effect in April 2024 and requires manufacturers of UK consumer connectable products to comply with the relevant obligations set out in the Act, which include ensuring they and their products meet the relevant minimum security requirements.
- The US 2019 IoT Cybersecurity Improvement Act, passed in 2020, sets minimum security standards for connected devices the federal government uses.
- The EU Cyber Resilience Act introduces specific obligations for products with digital elements, aiming to embed cybersecurity into their entire lifecycle.
- NIST’s IoT Cybersecurity Program, launched in 2016, which aims to supports the development and application of standards, guidelines, and related tools to improve the cybersecurity of IoT systems and the environments in which they are deployed.
Despite these efforts, Webb commented that in many regions there are still few stringent regulations specifically addressing IoT security.
“Without regulatory requirements or penalties for non-compliance, manufacturers might not feel compelled to prioritise security,” she said.
She also noted that the IoT industry overall lacks uniformed security standards, leading to inconsistencies in how security is implemented.
One way to overcome this challenge, Webb argued, is to promote the concept of security by design, inserting security into the design phase of product development. She also argued that offering tax incentives, subsidies, or other financial benefits to manufacturers that implement robust security measures could be an effective solution.
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## Advice for CISOs on Approaching IoT Security
Regulations and standards are just one part of the puzzle when it comes to security surrounding IoT devices, there is a lot that CISOs and cybersecurity leaders can do to ensure that they are not left vulnerable by the devices connected to their networks.
### Know your Supply Chain
The IoT supply chain is complex with multiple vendors contributing different components and software to a single device. Security gaps can emerge when devices are integrated without sufficient oversight.
“Organisations must adopt auditing of their supply chains, make sure you have the right documentation from the supply. Don’t cut corners, only buy from reputable providers,” Webb commented.
### Secure Password Practices
Many devices, most obviously routers, come with a pre-programmed default password which are often weak and easy to hack.
These should be changed as soon as possible, ideally the first time the device is connected to the network and where applicable two-factor authentication (2FA) integrated.
### Regularly Update Devices
Patching and software updates on devices should be done regularly. Updates frequently release software updates that will address vulnerabilities, but these must be implemented.
If there are devices that are no longer supported by the manufacturer and do not receive updates, consider swapping these out for newer IoT devices that can be updated and patched regularly.
### Network Segmentation
Reducing the attack surface can be done by eliminating unnecessary internet connections to IoT devices. Zero trust practices can be useful here but may not provide a silver bullet.
Consider IoT device identification systems that can detect and isolate IoT from the network and other devices if necessary.
By having a segmented network your network is divided into partitions so if an IoT device vulnerability was to cause issues it would not disrupt your entire system.
Isolating certain devices on a separate network also helps prevent them from secretly collecting data and limits their access to only the information and devices necessary for their operation.
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IoT Security Risks: Stats and Trends to Know in 2025 - JumpCloud
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https://jumpcloud.com/blog/iot-security-risks-stats-and-trends-to-know-in-2025
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The Internet of Things (IoT) has transformed workplaces. Smart sensors, connected cameras, and automated systems make everything faster, smarter, and more efficient. But there’s a catch—these same devices open up serious security risks.
Think about it: An unsecured smart thermostat could let hackers into your corporate network. A connected medical device could be exploited to put lives at risk. And botnets? They turn everyday IoT gadgets into weapons for cybercriminals.
The reality? Most businesses aren’t prepared. IoT security is often overlooked, leaving networks wide open for attacks. Let’s break down why this matters, what’s at risk, and how you can protect your organization before it’s too late.
## IoT Security Risks: Editor’s Picks
Before we go into the full breakdown, here are some of the most eye-opening IoT security stats:
- More than 50% of IoT devices have critical vulnerabilities that hackers can exploit right now. ( IBM X-Force Threat Intelligence)
- One in three data breaches now involves an IoT device. ( Verizon DBIR)
- The Mirai botnet turned unsecured IoT devices into an army of attack machines, launching one of the biggest DDoS attacks ever recorded. ( Kaspersky)
- Healthcare IoT devices are a prime target, with attacks on medical devices increasing by 123% year over year. ( Statista)
- Unpatched firmware is responsible for 60% of IoT security breaches. ( IoT Security Foundation)
- Compromised smart cameras and sensors have led to major surveillance breaches in corporate and government settings. ( CISA)
- IoT security failures cost businesses an average of $330,000 per incident. ( NIST)
IoT devices are everywhere—and so are the risks. Now, let’s go even deeper into what IoT security is, why it matters, and the biggest threats you need to be aware of.
### What Is IoT and Why Does Security Matter?
IoT stands for Internet of Things—a network of connected devices that communicate with each other over the internet. Think smart thermostats, security cameras, factory sensors, medical devices, and even coffee machines. They collect, share, and process data to make everyday operations faster, more efficient, and automated.
But here’s the problem: Most IoT devices aren’t built with security in mind. They’re easy targets for hackers, and once compromised, they can serve as an open door to entire corporate networks.
#### Why Should You Care?
An unsecured IoT device is a full-fledged business risk. Attackers can:
- Steal sensitive data by breaching IoT-connected systems.
- Shut down entire operations by attacking industrial IoT (IIoT) in factories and supply chains.
- Hijack smart security cameras to spy on companies.
- Launch large-scale botnet attacks using compromised IoT devices.
And the scariest part? Most businesses don’t realize they’re at risk until it’s too late. According to Verizon’s 2024 Data Breach Investigations Report, one in three breaches now involves an IoT device.
#### The Compliance Factor
Beyond security, businesses must also consider compliance risks. Regulations like GDPR, HIPAA, and NIST’s IoT Cybersecurity Framework require organizations to secure IoT devices and protect user data. Failing to comply? That means hefty fines, lawsuits, and reputational damage.
IoT is becoming more and more embedded in how businesses operate. But without proper security measures, it’s an open door for cyber threats. Next, let’s take a closer look at the biggest IoT security risks you need to watch out for.
## Key IoT Security Risks Backed by Data
Every connected device is a potential attack vector. Here’s how IoT devices put organizations at risk—backed by hard data.
### Device Vulnerabilities
- 60% of IoT breaches come from unpatched firmware and outdated software. ( IoT Security Foundation)
- One in five IoT devices still uses default passwords—making them ridiculously easy to hacked. ( IoT World Congress)
### Botnets & DDoS Attacks
- The Mirai botnet took down major websites (like Twitter, Spotify, and Netflix) by hijacking unsecured IoT devices. ( Kaspersky)
- IoT botnets are now responsible for 35% of all DDoS attacks. ( CISA)
### Data Privacy Breaches
- Connected devices expose sensitive data, from financial transactions to employee locations.
- More than 25% of IoT-related breaches involve stolen personal data. ( IBM X-Force Threat Intelligence)
### Industrial IoT (IIoT) Risks
- Critical infrastructure (power grids, water treatment plants) rely on IoT—but many lack proper security.
- Cyberattacks on industrial IoT increased by 75% in the past two years. ( Verizon DBIR)
### Physical Security Risks
- Compromised smart locks have led to break-ins in corporate offices and hotels.
- Connected cars have been remotely hacked and a significant number of lives have been put at risk. ( Statista)
### Direct Costs of IoT Breaches
- IoT security failures cost businesses an average of $330,000 per incident. ( NIST)
- Companies in regulated industries (healthcare, finance) face additional fines, often reaching millions.
### Reputation Damage
- Customers lose trust fast. 78% of consumers say they’d stop using a company’s services after a major IoT-related breach. ( IoT Security Foundation)
### Downtime & Business Disruptions
- Cyberattacks on IoT networks lead to an average of 6.5 hours of downtime per incident. ( CISA)
- For manufacturing and supply chain businesses, that can mean millions in lost revenue.
## Industries Most at Risk
Some industries are playing with fire when it comes to IoT security. They’re stacked with connected devices, yet most aren’t prepared for an attack. If your industry is on this list, it’s time to rethink security before a breach shuts everything down.
### Healthcare
Medical IoT devices are revolutionizing patient care, but they’re also a hacker’s dream. Many of these devices run on outdated software which makes them way too easy to exploit. When hospitals get hit, patient safety is on the line.
- 75% of healthcare IoT devices still use outdated operating systems. ( IBM X-Force)
- A single ransomware attack can lock hospitals out of critical systems and delay urgent treatments.
- Medical IoT breaches cost an average of $10 million per attack, the highest across all industries. ( Verizon DBIR)
### Smart Cities
Public infrastructure is becoming smarter and more connected. That also makes it a prime target. Hackers can take control of city systems and unleash massive disruptions that impact millions.
- Cyberattacks on smart city infrastructure jumped 50% last year. ( Verizon DBIR)
- Traffic lights, surveillance cameras, and public Wi-Fi can all be hijacked if left unsecured.
- A single breach could shut down power grids, disrupt emergency services, or freeze city operations.
### Manufacturing
Factories rely on Industrial IoT (IIoT) devices to automate production and manage supply chains. But when security takes a backseat, entire operations are at risk of being hijacked.
- Over 70% of manufacturers reported cyber incidents linked to IoT devices. ( Kaspersky)
- Hackers can halt production lines, damage equipment, or manipulate supply chains for profit.
- Cyberattacks on manufacturing surged by 87% last year. Naturally, it is one of the most targeted industries.
### Retail
IoT is changing how retailers manage inventory, process payments, and track shipments. But every smart device is another potential entry point for cybercriminals.
- Retailers lost over $20 billion to IoT cyberattacks in 2024. ( Statista)
- Unsecured payment systems allow hackers to steal credit card info straight from connected POS terminals.
- Smart inventory trackers and connected devices can be used to disrupt supply chains and cause shortages.
### Who’s Next?
IoT adoption is expanding fast. Finance, logistics, and education are all next in line for major IoT-based attacks. If your business relies on connected devices, securing them needs to be a top priority.
## Strategies to Mitigate IoT Security Risks
IoT devices aren’t going away, but the threats surrounding them are getting worse. Instead of waiting for a breach, businesses need to take action now. Here’s how to stay ahead of attackers and lock down IoT security.
### Adopt IoT Security Frameworks
Blindly adding IoT devices without security measures is asking for trouble. Organizations need to follow recognized frameworks that outline best practices for IoT security.
- The NIST IoT Cybersecurity Framework provides detailed security guidelines for IoT devices.
- Businesses that implement IoT security frameworks reduce cyberattack risks by 60%.
- Compliance with industry standards helps prevent regulatory fines and legal issues.
### Network Segmentation
Letting IoT devices freely connect to your main business network is a massive mistake. A single compromised device can open the door to critical systems.
- IoT devices should be isolated on their own network to prevent lateral movement.
- Segmenting networks ensures an attack on one system won’t spread to others.
- Businesses that use network segmentation reduce breach costs by 35%.
### Update Firmware Regularly
Most IoT devices ship with preloaded vulnerabilities. If businesses aren’t updating firmware, they’re leaving doors wide open for attackers.
- 60% of IoT breaches happen due to outdated firmware. ( IoT Security Foundation)
- Enabling automatic updates ensures patches are applied before hackers can exploit flaws.
- Companies that regularly update IoT firmware cut attack risks in half.
### Strong Authentication
Weak or default passwords are the number one cause of IoT breaches. Attackers know that businesses rarely change default credentials. And they are licking their chops because of it.
- Every IoT device should have unique, strong passwords to block unauthorized access.
- Multi-factor authentication (MFA) adds an extra layer of protection.
- Businesses using strong authentication see 90% fewer IoT-related security incidents.
### Device Encryption
Many IoT devices transmit sensitive data without any encryption, leaving it exposed to hackers. Without encryption, data can be intercepted, modified, or stolen.
- Encrypting data in transit and at rest ensures attackers can’t read stolen information.
- End-to-end encryption helps block man-in-the-middle attacks.
- Businesses that encrypt IoT data reduce breach costs by an average of $1.4 million.
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Role of AI & ML in Enhancing Cybersecurity Against Threats
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https://www.eccouncil.org/cybersecurity-exchange/network-security/role-of-ai-ml-in-enhancing-cybersecurity-against-threats/
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Technological advancements in recent years have been actively accompanied by cyberattacks targeting associated vulnerabilities. Recent data suggests that cybercrime is projected to cost businesses trillions of dollars annually, with global estimates indicating an increase of 6.4 trillion USD (+69.41%) from 2024 to 2029, reaching a peak of 15.63 trillion USD by 2029 (Petrosyan, 2024a). As attacks grow in both number and sophistication, the impact on targets has also intensified.
In response to these evolving threats, organizations are enhancing their mitigation strategies to incorporate advanced technologies like Artificial Intelligence (AI) and Machine Learning (ML). Unlike traditional methods, these innovations offer more effective ways to identify, prevent, and counteract cyberattacks.
## Navigating Cybercrime Landscape
Cybercrime refers to any illegal activity that exploits digital technologies. Cybercriminals use the internet to carry out a range of offenses, including identity theft, credit card fraud, and the theft of personal information. These actions can lead to significant financial losses, reputational damage, and the disruption of essential services, thereby affecting individuals, organizations, and even entire nations. As technology advances, cybercrime is becoming increasingly sophisticated, presenting a growing threat worldwide. Cyberattacks are usually classified according to their primary purpose:
### Financial Crimes
These involve criminal activities targeting financial transactions or scams, often digital means. Common examples include phishing schemes designed to steal money from individuals via online fraud, such as credit card scams and banking attacks.
### Data Breaches
Data breach implies unauthorized access to and theft of sensitive information, including personally identifiable data. This can occur through methods such as intercepting encrypted communications before they reach their intended recipients.
### Disruption and Destruction
These involve efforts to turn off operations, damage control systems and equipment, or cause irreversible changes that render systems non-functional. Examples include Distributed Denial of Service (DDoS) attacks, malware, and cyberattacks on critical infrastructure.
### Espionage
The act of stealing sensitive information to gain financial or political advantage is termed espionage. Targets can include private individuals, businesses, or government entities.
### Reputational Damage
This involves actions aimed at tarnishing the reputation of a person or organization, resulting in a loss of trust. This can involve social engineering, spreading false rumors, or harassment through online platforms.
Source: (Petrosyan, 2024b)
As per studies and surveys, credit card and online banking-related frauds are some of the prominent cybersecurity concerns faced by consumers in the United States. In contrast, account hijacking and data breaches are the top concerns of financial institutions regarding data and financial security and protection efforts (Petrosyan, 2024b).
## Roles of AI and ML in Cybersecurity
The role of AI and ML can be considered critical for enhancing cybersecurity through advanced and automated detection, analysis, management, and incident response. Threat identification based on AI and ML can also be trained to detect and mitigate AI-driven threats and social engineering attacks. Some of the prominent applications of AI and ML-driven security capabilities are listed below.
### Automated Threat Detection and Analysis
Humans use conventional methods to recognize and mitigate threats. However, these tactics can be swamped by the magnitude and sophistication of cyberattacks. Through real-time data analysis at a large scale, AI and ML may quickly identify suspicious trends, computer viruses, or traces that might indicate an imminent harmful intrusion into information systems (Stanham, 2023).
### Forecasting Based on Analytic Predictions and Assessing Uncertainty
AI and ML examine past information regarding cyber offenses and delicate areas to come up with future risks while ensuring there are areas with fewer security measures. Consequently, businesses are given a chance to rank security measures based on significance and manage costs. In terms of proactive security measures, machine learning plays an important role in detection through learning models. Increasing the scope of the learning database will allow ML-driven security capabilities to detect anomalies that may not raise alerts in traditional systems (Kaur et al., 2023).
### Incident Response
Systems with artificial intelligence can perform some parts of incident response operations automatically, including isolating compromised machines, separating threats from other data, and alerting security agencies. As a result, the amount of time taken for containment is also reduced, making it easier for the victims’ organizations to deal with potential loss (high level).
### Social Engineering and Anomaly detection
As phishing and social engineering are among the initial steps in any attack vector, threat actors aim to automate these steps in addition to incorporating AI to implement more advanced and realistic attempts at successful social engineering attacks. These advanced social engineering strategies by online invaders are aimed at enticing unsuspecting network users into sharing their confidential details. On the other hand, security teams can utilize AI and ML as a countermeasure against AI-enabled social engineering attacks.
### Phishing Detection and Behavioral Analysis
A machine can scan email text for words and other written things. Machine learning algorithms can discern regular behavior patterns of users and systems. Any variance from those patterns, like weird login attempts or data access requests, might signal some potential anomalies that point to a cyberattack.
## Utilizing AI and ML to Fight Against Cybercrime
Artificial intelligence and machine learning are credited with transforming the field of cybersecurity and have taken it to another level by using superior skills to find incidents before they happen, including detecting, preventing, or responding to online menaces. These technologies leverage big data analytics to examine massive datasets obtained from several sources, such as system logs, networks, and user behavioral analysis logs, to find tell-tale signs demonstrating malfeasance remotely perpetrated against webs.
With the help of machine learning algorithms, cybersecurity systems can be used to recognize anomalies and doubtful activities immediately, thus enabling companies to take first-hand measures to defend themselves against online fraud. Equally significant, historical information helps predict future risks that need to be dealt with in advance by business organizations (Sarker et al., 2024).
Artificial intelligence and machine learning also play a significant role in identifying process-level file-associated functionalities throughout different types of malware. These technologies are fundamental in identifying mechanisms used by malicious software and preventing their operation (e.g., checking file characteristics and the activities associated with them to discover both recognized malicious software signatures and unknown, unique types of viruses). Furthermore, they assist in fighting against phishing and social engineering by studying the content of letters as well as addresses belonging to sites in order to block any unwanted emails and sites.
Additionally, AI-driven security orchestration platforms automate incident response and resolution mechanisms, which help businesses act fast when there is a security crisis in order to prevent severe outcomes. These technologies are exceptionally adept at scanning through large datasets, picking out unusual behavior, or even forecasting possible hazards at splinter speeds. Evidently, artificial intelligence and machine learning have presented several levels of preventing cyber security breaches that empower organizations.
### Limitations
Artificial intelligence or machine learning is not the ultimate solution. Based on the quality and quantity of data it has been trained on, the efficiency of AI or ML algorithms is highly reliant on the frequency of data dependency as well as its quality. If the information is biased or incomplete, one can anticipate wrong predictions, thereby missing out on identifying threats. Sometimes, AI models are like black boxes, making it hard to figure out how they arrive at decisions. Given the lack of transparency, issues related to responsibility and probable prejudices in algorithms may come to the surface.
## Conclusion
AI and ML have helped to make sure that cyber security is more secure than ever before in several ways. This has been achieved by incorporating these technologies across organizations of different levels (multi-layered defense strategy). Organizations have enacted measures to protect themselves from ongoing cyber challenges and achieve complete protection for their systems while keeping all confidential information safe.
A large part of how cybersecurity defense systems are made better can be attributed to the use of artificial intelligence as well as machine learning, which helps in improving early warnings of emerging dangers and predicting future trends based on historical data, thereby taking timely actions against changing internet risk adversaries.
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AI and machine learning in cybersecurity - Mastercard Data & Services
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https://www.mastercardservices.com/en/industries/retail-banking/insights/ai-and-machine-learning-cybersecurity
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## Introduction
The latest paper from Mastercard Advisors’ Cyber and Digital Resilience Practice explores how artificial intelligence (AI) and machine learning (ML) can help organizations improve their security posture with robust tools to:
- boost threat detection
- enhance risk management
- enable proactive cyber defenses
These technologies significantly improve threat detection by analyzing vast datasets, recognizing patterns and continuously learning from real-time inputs. Organizations are then empowered to mitigate vulnerabilities, reduce response times and ensure a faster recovery from cyber incidents, thereby protecting digital assets and customer data more effectively.
AI technologies also enable organizations to automate repetitive tasks easily. This allows cyber security teams to focus on more sophisticated threats and events, promoting a proactive cyber security environment.
Mastercard has dedicated responsible AI teams that review models to make sure they are being used correctly and responsibly. Mastercard aims to ensure that AI can help us protect our customers and advance the safety and security of our systems while minimizing the risks that it poses.
## Three AI technologies reshaping cybersecurity
For organizations to make the most of these emerging opportunities, they should be aware of three key AI and ML trends and how they can be used in cyber security:
Deep Reinforcement Learning (DRL)
Large Language Models (LLMs)
Generative AI (GenAI)
### Deep Reinforcement Learning (DRL)
DRL can enhance an organization’s cybersecurity systems in three main ways:
1. Threat detection
2. Threat response automation and incident management
3. Risk assessment optimization
#### Threat detection
By leveraging deep neural networks, DRL models can significantly expand an organization’s **threat detection** capabilities by improving anomaly detection, intrusion identification and malware classification.
DRL can identify non-linear patterns in data and adapt to dynamic environments through reinforcement learning. This empowers the models to improve their performance continually over time.
One of the key advantages of DRL models is their capacity to handle the complex and dynamic nature of cyberspace, enabling them to detect new and emerging threats that may elude other systems. By analyzing vast amounts of data and learning from feedback, DRL models can quickly adapt to changing attack vectors and novel cyber threats, upgrading the ability of organizations to stay ahead of more sophisticated adversaries.
#### Threat response automation and incident management
By learning from historical data and observing expert decision-making processes, DRL algorithms can autonomously make informed decisions during cyber incidents, enabling faster and more effective response actions.
This reduces response times, minimizes the impact of breaches and facilitates the restoration of normal operations.
#### Risk assessment optimization
By analyzing a multitude of variables and continuously learning from real-time inputs, DRL algorithms provide adaptive risk assessments. This enables organizations to:
- Identify and prioritize vulnerabilities more accurately
- Allocate resources efficiently
- Implement targeted security measures based on the current threat landscape
### Large Language Models (LLMs)
LLMs, such as GPT, are evolving rapidly and have become an essential part of any cybersecurity toolkit. They currently have three main applications:
1. Threat detection
2. Security analysis automation
3. Development and implementation of cybersecurity strategies
#### Threat detection
LLM models are another tool, along with deep learning based on knowledge graphs data, that can enable the identification and analysis of natural language-based threats like phishing attacks. By processing vast amounts of textual data, LLMs can quickly recognize suspicious patterns and help stop potential cybercriminal activities.
#### Security analysis automation
LLMs are instrumental in automating security analysis processes. By scrutinizing source code and documentation, these models excel at uncovering patterns and anomalies that may indicate security vulnerabilities. This capability empowers organizations to proactively address software weaknesses, thus mitigating the risk of security breaches and fortifying their defenses against future attacks.
#### Development and implementation of cybersecurity strategies
LLMs contribute to the development of robust cybersecurity policies. Leveraging their language generation capabilities, these models can assist companies in either summarizing and simplifying the discovery of complex policies, or crafting comprehensive and well-documented cybersecurity policies that align with industry best practices.
They can also aid in the implementation of widely recognized cybersecurity frameworks like OWASP (Open Web Application Security Project), ensuring that applications are built with security in mind right from the development phase. This is useful for delivering more secure products and product features.
### Other Advanced Deep Learning Architectures
By leveraging advanced techniques such as generative adversarial networks (GANs) and variational autoencoders (VAEs), GenAI models contribute significantly to strengthening cybersecurity measures, in particular:
1. Defensive data generation
2. Cyberattack simulations
3. Analysis and understanding of virus variations
#### Defensive data generation
GenAI enables defensive data generation, where synthetic data is created to train machine learning models. This approach involves generating realistic (yet fabricated) data, aiding organizations to build robust models capable of effectively detecting and classifying threats. By augmenting the accuracy and reliability of cybersecurity systems, GenAI safeguards sensitive customer information.
#### Analysis and understanding of virus variations
GenAI can generate synthetic variants of known viruses, enabling security teams to study the behavior and characteristics of different ‘strains’. This knowledge is invaluable for developing robust antivirus solutions and effectively countering the risks posed by evolving virus variations.
#### Cyberattack simulations
In combination with other AI technologies, GenAI allows organizations to simulate authentic cyber attack scenarios for training.
‘Red teams’\* can leverage AI and ML to devise highly realistic attacks and simulations, mirroring the rapidly evolving world of cyber threats. These technologies simplify and speed up threat modelling and vulnerability assessments, leading to more efficient and accurate detection of potential security flaws.
‘Blue teams’\* also benefit from these technologies by enabling real-time identification and prediction of potential cyber attacks, capabilities beyond human capacity. ML algorithms can use historic data to identify anomalous activities and predict potential threats, significantly boosting incident response times. Finally, AI can assist ‘blue teams’ to automate repetitive tasks, allowing them to concentrate on more complex security challenges.
By adopting this proactive approach, organizations can strengthen their preparedness and resilience against real-world cyber attacks.
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How AI and machine learning are transforming cybersecurity
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https://its.uiowa.edu/news/2025/03/how-ai-and-machine-learning-are-transforming-cybersecurity
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# How AI and machine learning are transforming cybersecurity
Artificial intelligence (AI) and machine learning (ML) are becoming increasingly integral to cybersecurity efforts at institutions like the University of Iowa. IT support and administrative staff play essential roles in helping these technologies succeed. While central IT leads the implementation of AI-powered tools, frontline staff bridge the gap between users and technology.
## What you should know
**AI is enhancing cybersecurity and technology.**AI helps identify threats faster and more accurately through behavioral analysis, adaptive defense, and automated threat detection. This is especially useful in higher education environments where systems are open and complex.
**Human support still matters.**AI can misidentify harmless activity as a threat (a false positive), making your understanding of normal user behavior and context more important than ever. Your feedback to central IT helps refine and improve these systems.
## How you can improve quality and efficiency
**Watch for and report suspicious behavior:**Stay alert to new phishing tactics, especially those that might look more realistic due to AI (e.g., deepfakes or highly tailored emails). If something seems off, report it to central IT or the Help Desks, even if you’re unsure.
**Provide context to alerts:**When users report account lockouts or access denials, take the time to understand what they were doing. Sharing this context with security teams can help them distinguish false positives from real threats.
**Help set expectations with end users:**Let users know that enhanced security tools may trigger alerts more often, but they’re part of a smarter, evolving defense system. Reinforce the importance of reporting rather than ignoring suspicious messages.
**Promote security awareness:**Encourage colleagues and users to stay informed about new AI-based threats, like AI-generated phishing and social engineering. Point them to university-provided training when appropriate.
**Foster collaboration:**Support efforts to build a culture of information sharing between departments and central IT. Your frontline insights are valuable in detecting emerging trends and potential vulnerabilities.
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Blockchain in Cybersecurity: Applications and Challenges
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https://globalcybersecuritynetwork.com/blog/blockchain-in-cybersecurity-applications-and-challenges/
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## How Blockchain Contributes to Security
When integrated with cybersecurity, blockchain offers several advantages that address common vulnerabilities in traditional systems:
- **Preserving Data Integrity:** Blockchain’s immutability means recorded data cannot be changed without consensus, helping prevent data tampering.
- **Decentralized Structure:** Blockchain’s decentralized network eliminates single points of failure, enhancing resilience against attacks.
- **Advanced Encryption:** Using cryptographic techniques, blockchain ensures data is accessible only to authorized parties, bolstering confidentiality.
Additionally, blockchain’s transparency allows for continuous monitoring, aiding rapid detection and response to suspicious activities. This transparency, combined with an unchangeable audit trail, can significantly boost accountability in data protection practices.
## Real-World Uses of Blockchain in Data Security
Blockchain’s applications in securing digital information are diverse and continue to expand, offering solutions for various security needs:
- **Identity Verification:** Blockchain enables secure and decentralized identity systems, reducing identity theft and fraud risks.
- **Securing Transactions:** In finance, blockchain safeguards transaction integrity, lowering the chances of fraud.
- **Protecting IoT Devices:** Blockchain offers a secure framework for authenticating IoT devices and preventing unauthorized access.
- **Data Breach Mitigation:** Blockchain makes it harder for attackers to compromise information at scale by distributing data across multiple nodes.
Beyond these applications, blockchain is being used to improve supply chain security, safeguard intellectual property, and provide secure voting systems. In healthcare, it helps ensure patient data is stored and shared securely, enhancing data privacy.
## Challenges and Considerations
Despite its benefits, implementing blockchain for data protection comes with some challenges that need to be addressed:
- **Scalability:** Current blockchain models’ processing speed and data capacity can limit their use in high-volume environments.
- **Energy Demands:** Blockchain systems can be energy-intensive, especially in networks using proof-of-work models.
- **Regulatory Issues:** Legal and regulatory concerns may arise, particularly in international applications of blockchain technology.
- **Vulnerabilities:** While blockchain is secure, smart contracts and key management practices must be rigorously tested to prevent exploitation.
To address these issues, organizations must carefully plan integration with existing systems and manage resources effectively. Navigating these challenges is critical to achieving blockchain’s benefits in enhancing data protection.
## Future Trends in Blockchain Security
The field is evolving rapidly, with several promising trends emerging that combine blockchain with other advanced technologies:
- **AI Integration:** Merging blockchain with AI can enhance data protection capabilities and aid in quick threat detection and response.
- **Quantum-Resistant Algorithms:** As quantum computing advances, researchers develop blockchain models that withstand quantum-based attacks.
- **Cross-Industry Adoption:** Blockchain security is expanding beyond traditional sectors, with new applications in healthcare, logistics, and more.
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What is Blockchain Security? | Is Blockchain Safe? - Kaspersky
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https://www.kaspersky.com/resource-center/definitions/what-is-blockchain-security
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# What is Blockchain Security?
Blockchain security is the risk management procedure or security
system that is put in place to protect a blockchain network from online
threat actors. Blockchain security uses a combination of cybersecurity
best practices, tested frameworks and technical assurances to protect
against fraud and cyberattacks.
Since the advent of Bitcoin, blockchain technology has fast become a
new kind of normal in today’s societies. Known, originally, for its role
in cryptocurrency circles as the distributed ledger technology that
allowed decentralized trade and verification (without an institutional
3rd party, so to speak), today, there are numerous different
blockchain networks supporting various currencies and digital services
around the world. From banking and healthcare to supply chains and
traceability, blockchains play an increasingly integral role in our
daily lives.
As a consequence, it’s becoming equally important to understand what
kinds of blockchains are out there and, most importantly, how they are
secured. That’s why we’ve written this guide to the blockchain and its
security. Read on to discover what it is, the different types that exist
today, how secure they are, what cybersecurity protocols should be
considered when engaging with a blockchain, and what attacks are common
to blockchain networks.
## Blockchain Definition
In essence, a blockchain can be defined as a distributed database
(known as a ledger) that is shared between different computer users. The
data in a blockchain is structured into blocks, connected together by a
cryptographic chain. When a transaction or bundle of transactions (in
the form of a new data block) is added to the blockchain, the block is
then validated and agreed upon by a consensus mechanism (sometimes known
as a PoW or proof of work). The consensus mechanism involves the
collective participation of some of the members (known as nodes) across
the distributed network. In Bitcoin (and other cryptocurrencies) this is
done through the process of “mining” and “hashing”, which involves
significant computing power. As a result of the above, distributed
ledger technologies (DLTs) cannot be changed by a single person on the
network. Thus, there is no single point of failure and any risk is
distributed.
Now you understand the blockchain, let’s examine the different types
of blockchain that are out there.
## Types of Blockchains
Blockchains differ primarily in who can and can’t participate and
access the data in their networks. Largely speaking there are two main
types of blockchains:
### Public Blockchains
Public blockchain networks (sometimes known as an open or
permissionless blockchain network) are open to anyone to join, with all
of the members (who usually remain anonymous) being able to validate
transactions if they choose to. Public blockchains validate transactions
via public keys, using computers that are connected to the internet.
These public cryptographic keys are the primary way of identifying and
accessing data on this type of network.
### Private Blockchains
Private blockchains require membership and identifying information to
access the network’s data. For this reason, private blockchains are
known as permissioned blockchain networks and they achieve consensus
through a mechanism known as selective endorsement (where only certain
members of the network are permitted to verify transactions from within,
often using special permissions to access the network’s distributed
ledger to do this). Often, private blockchain networks consist of known
and trusted entities and organizations.
### Hybrid Blockchain
In essence, a hybrid blockchain is a mix of private and public
blockchains that are interoperable. They are designed to leverage the
advantages of the two main types of blockchains that are used today.
## How Secure is Blockchain?
By virtue of its decentralized design and use of cryptography,
blockchains are, in general, fairly secure. Once a block of data has
been added to the chain and verified, it cannot be removed, and multiple
blocks are always stored linearly (so it’s easy to check the ledger for
systematic problems). Equally, the records stored in most blockchains
are encrypted, so sensitive data is often difficult to access even when
hacked. However, blockchain networks are more complicated. Despite the
ledger technology itself being theoretically “impenetrable”, the network
itself is not immune to cyberattacks and attempted fraud. Since their
inception, there have been a number of different attacks on various
blockchain networks.
## Blockchain Attacks
Broadly speaking, there are four main types of cyberattack that
blockchain networks are vulnerable to:
### 51% Attacks
A particularly processing-intensive and power-intensive cyberattack,
a 51% attack is instigated by a group of “miners” (originally part of
the network) who leverage their combined resources to control enough of
the network’s mining power (more specifically, the network’s mining hash
rate). In doing so, they effectively gain control of the ledger itself.
Once they have control of the ledger, the rogue miners can manipulate
the transactions on it to enact financial fraud. Private networks are
not usually susceptible to this type of attack.
### Routing Attacks
A routing attack is very hard to spot because most of the attack
happens behind the scenes. This attack involves intercepting data being
transferred to your internet service provider, dividing the network, and
targeting a certain chain between certain nodes. Essentially having
created a kind of parallel chain, the attacker can then steal any
currency or personal information from their targeted area.
### Sybil Attacks
A Sybil attack involves a hacker using a node to create multiple fake
identities or ‘Sybil identities’ to flood a network. This then allows
them to carry out a 51% attack, see above, where they gain a 51%
majority control of the network’s computing power: thereby giving the
hacker a disproportionately large influence or presence in the network.
Common in distributed systems, it undermines trust and integrity,
prompting defense through identity verification and cryptographic
protocols.
### Phishing Attacks
A classic online scamming technique that many users should be
well-acquainted with, [phishing\\
attacks](https://www.kaspersky.com/resource-center/preemptive-safety/phishing-prevention-tips) on a blockchain network are not necessarily an attack on the
network in the same way that the last 3 examples are. A blockchain
phishing attack targets the members of the blockchain with phishing
emails to attain their credentials, with the intention of stealing
currency from their accounts.
As can be seen from the variety of threats above, cybersecurity best
practices play an important role in blockchain security today.
## Blockchain and Cybersecurity
The role of cybersecurity, or more precisely, data security in
blockchain networks is integral to today’s publicly (and privately) used
distributed ledger technologies. Below, we’ve combined a list of best
practices and frameworks that both enterprises and network
administrators can use to enhance their blockchain security moving
forward.
- **Identity and Access Management:** For both public
and private networks, access controls and legitimatizing communication
between users and nodes are integral to the internal protection of
sensitive data transfers and currency. This includes deciding whether
block payloads are encrypted or not and how users’ private and public
keys are managed and revoked.
- **Governance and Risk Management:** Consider what
your disaster recovery plan for the blockchain participants is, if the
worst should happen. Perform regular risk assessments to discover
important vulnerabilities or other weaknesses in your chain. Equally,
remember that blockchains are subject to all cybersecurity and privacy
laws, regulations, and other nation-specific requirements throughout
their lifecycle.
- **Use a proven VPN** **:** Recommend
that users and nodes activate a trusted and proven VPN when making
transactions. A Virtual Private Network works by creating an encrypted
private tunnel between a user’s remote computer and any external
servers, so your data or transactions will remain protected from any
outside threats to the network.
- **Choose a Dedicated Antivirus Software:** Overall,
known threats to blockchain networks, particularly phishing scams, are
much easier to avoid if you have a dedicated antivirus software
installed on your local machine. A good antivirus system will not only
defend you from known threats but will also run regular scans to warn
you of any new ones. Equally, antivirus software provides you with an
extra layer of protection when you’re validating transactions as a node.
We recommend using our dedicated security software Kaspersky Premium, which offers regular updates,
scans, and consistent help and support with all your digital
activity.
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Blockchain Security: Common Issues & Vulnerabilities | NordLayer
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https://nordlayer.com/blog/blockchain-security-issues/
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Transparency, speed, and high levels of trust make blockchains an increasingly popular option. Those benefits are well-recognized among forward-thinking businesses. However, **blockchain security issues** are much less prominent, and that's a problem. Read on to discover common blockchain risks and use our best practices to secure every link in the chain.
## Key takeaways
- Blockchains are **decentralized ledgers** consisting of blocks with unique cryptographic hashes. The blocks form an immutable chain that every user can inspect. This transparency enhances trust and integrity in information transmission.
- **Blockchain security** is coming into focus as the technology becomes mainstream. Threats include man-in-the-middle, Sybil, and 51 attack types that exploit insecure nodes. Blockchains are vulnerable to traditional phishing and endpoint vulnerabilities. Smart contracts and poorly designed routing systems also put blockchains at risk.
- Mitigate threats by following **blockchain security best practices.** Users should implement robust encryption and Identity and Access Management (IAM) solutions. Secure development practices, multi-signature wallets, fail-safes, regular audits, and Zero Trust Security solutions mitigate blockchain security risks.
Blockchains are **decentralized digital ledgers** that record transactions between different devices or individuals. **Chains consist of "blocks".** Each block has a unique cryptographic hash. Subsequent blocks create hashes based on previous blocks, generating a chain where each entry is connected but unique.
Blockchains are tough to change after creating blocks. This immutability makes them a good fit for verifying information transmission. Participants can see information about block generation, making the process extremely transparent.
Analysts project the global blockchain market will grow to $40 billion by 2025, and use cases will multiply. Secure information exchange, digital identification, and tracing financial transactions are just a few areas emerging blockchain technologies are disrupting.
However, as with all new digital technologies, decentralized ledgers potentially pose critical security risks. Hackers routinely use untraceable crypto wallets to mount ransomware attacks. Consensus protocols that establish ledger entries are vulnerable to attack. Poorly designed smart contracts can also put businesses at risk.
This article will take a closer look at blockchain security issues. We will explore how blockchains work and discuss how you can safely capitalize on blockchain technology.
## Introducing the main types of blockchain
Blockchains are defined by whether they use public or private keys to verify transactions.
**Public blockchain networks** are accessible to everyone. Cryptocurrencies like Ethereum or BitCoin fall into this category. Public systems create public _and_ private keys for blockchain participants. The public key enables users to engage transparently with other currency holders, while the private key protects their digital wallets.
Public blockchain technology is decentralized, with no single controlling entity. Decentralization promotes trust among participants and makes the blockchain more resilient. Distributed ledgers are hard to tamper with, as changes need approval from the user community. They also enable access for customers or larger user groups.
**Private keys** are limited to a defined community of users. Each authorized user receives a private key. Digital signatures based on this key verify interactions with the blockchain ledger.
Private blockchain security ensures control and confidentiality for the blockchain owner, making it suitable for many enterprise uses. However, private blockchains can be vulnerable to insider attacks. Attackers can also exploit centralized chains, using the blockchain controller as an attack vector.
## Exploring blockchain security issues
Users often think blockchains guarded by encryption are safer than traditional information transfer systems. Ledgers supposedly make tampering difficult. In theory, changing data blocks without authorization is unlikely without a user's private keys.
However, there are questions about this reputation for security. Blockchains can put sensitive data at risk, resulting in significant financial losses or data exposure. Companies adopting private or public blockchain solutions should thoroughly assess their security vulnerabilities.
### Phishing attacks
Blockchains are as vulnerable to phishers as traditional networks. In this case, phishing attacks target the **private keys used by blockchain participants.** Cunning attackers persuade key holders to hand over the passwords used as ciphers for private key hashes. When they get the key, hackers can make transactions, extract information, and ruin the integrity of blockchain ledgers.
**Solution:** The best remedy for phishing attacks is improving employee security training. Include blockchain security issues in cybersecurity training. Every ledger user should know the risks of sharing their private keys.
### Routing attacks
Blockchains rely on consensus mechanisms to establish the legitimacy of transactions. However, attackers can use routing attacks to **intercept consensus requests** and isolate blockchain nodes. Isolated nodes can’t make transactions or ledger changes. Attackers can slow down business processes and launch damaging 51% of attacks (please see below).
**Solution:** Organizations can cut the risk of routing attacks by protecting blockchain communications with strong encryption and using network monitoring tools to identify suspicious traffic patterns.
### Sybil attacks
Sybil attacks create many **fake identities or "dishonest nodes."** Dishonest nodes seem authentic to blockchain users ("honest nodes"). However, dishonest nodes enable attackers to control network traffic. They can then force honest nodes to act against their interests.
Sybil attacks enable attackers to leech sensitive information about blockchain users (IP data, for example). Malicious actors can also block new transactions, effectively holding users to ransom.
**Solution:** Fortunately, Sybil attacks are usually easy to detect. They tend to affect blockchain operators with weak validation and monitoring systems. Ensure you have robust measures in place to authenticate every node.
### 51% attacks
In 51% of attacks, malicious actors control over half of a blockchain's computational power. Control matters because attackers can then dominate how the ledger functions.
The most common method involves creating fake "pools" and enticing legitimate users to join. The attacker separates this pool from the original ledger, creating a second parallel blockchain. Attackers then leverage their pool to add blocks faster than users on the original chain.
Problems arise when hackers reintegrate the fake blockchain with the original. If standard rules apply, the largest blockchain becomes the default version. Rules may reverse transactions on the legitimate ledger, eroding user trust.
During a 51% attack, **the blockchain is no longer fully decentralized or transparent.** A single user can change ledger entries and block additions and potentially force double transactions, leeching money from currency users. For example, in 2020, Ethereum Classic suffered three 51% attacks. Each attack cost currency holders $9 million through double transactions.
**Solution:** Organizations can cut the risk of 51% attacks by switching from proof-of-work (PoW) consensus algorithms to proof-of-stake (PoS) algorithms. Slowing down transaction confirmations can also make attacks prohibitively expensive.
### Man-in-the-middle attacks
Hackers use man-in-the-middle attacks to place themselves between users and digital wallets. Attackers posing as legitimate nodes can intercept transmissions and change their destination or contents. After that, thieves can divert cryptocurrency to their wallets. Because hackers recycle transmission data to the legitimate sender, the diversion may be very hard to detect.
Man-in-the-middle techniques can also steal private keys, giving attackers unlimited access to a user's blockchain assets. Both attack methods compromise information stored on the blockchain and undermine trust.
**Solution** : Robust encryption and consensus mechanisms usually mitigate MITM attacks. Blockchain users should adopt secure protocols and verify all transaction details independently.
### Endpoint vulnerabilities
Some blockchain security issues start close to home. Users may store their private keys locally and fail to apply protective measures. Stolen smartphones and compromised apps can divulge authentication information. Third-party vendors can expose blockchain keys, putting client assets at risk.
**Solution** : Do everything possible to prevent encryption key theft. Encrypt devices that store keys and implement rigorous physical security.
### Smart contract vulnerabilities
Smart contracts are becoming increasingly popular but can also be risky. Developers build these self-executing contracts into blockchain operations. When two users meet pre-defined conditions, the contract processes their transaction. There is no need for an intermediary to verify credentials. Transactions should be faster and more secure.
However, that's not always the case. The code base of smart contracts could contain flaws, creating room for malicious exploits. For instance, in 2021, hackers leveraged code flaws in smart contracts to extract over $600 million from Poly Network.
**Solution** : The problem with smart contracts often lies in the code. Apply code audits and verify every contract before use. Follow secure development practices to ensure high-quality outputs and use trusted code libraries when building contracts.
## Blockchain security best practices
The list above may be concerning, and it should be. Blockchain usage is generally safe, but users must be aware of common blockchain security issues to mitigate critical risks. If not, one of the attacks we've discussed will eventually materialize.
Help is at hand. Follow the best practices below to benefit from blockchain technology _and_ ensure secure transactions.
### Apply robust encryption to blockchain networks
The first blockchain security fundamental is obvious. Always **encrypt private keys** used to access and change blockchain network nodes.
Use AES-256 (or even more secure standards) to generate blockchain hashes. Remember: every link in the chain should be unique and verifiable. Meeting these conditions is only possible with virtually undecipherable encryption.
Additionally, use **encrypted digital signatures** to verify blockchain network transactions. Signatures based on the Elliptic Curve Digital Signature Algorithm (ECDSA) should deliver sufficient security.
### Implement Identity and Access Management (IAM) solutions
**Controlling access** to your blockchain network is all-important. IAM solutions define who can use private keys and change the blockchain ledger. Unauthorized users are blocked at the source, making it harder to launch insider attacks.
IAM also makes phishing more complex. Hackers may obtain user credentials. However, IAM systems can detect suspicious logins via contextual verification. Just having a password is not enough to manipulate blockchains.
Combining IAM with robust **multi-factor authentication** is also advisable. MFA dramatically cuts risks linked to endpoint vulnerabilities.
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What Is Blockchain? Blockchain In Cyber Security - Keepnet Labs
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https://keepnetlabs.com/blog/what-is-blockchain-security-common-blockchain-security-challenges
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# What Is Blockchain Security? Common Blockchain Security Challenges
Explore how blockchain security protects decentralized systems from evolving threats like phishing, smart contract bugs, and routing attacks. Learn how to reduce risks and secure your blockchain environment with the right strategies and tools.
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In 2024, hackers stole more than $3 billion from blockchain platforms through scams and cyberattacks, according to PeckShield. As more companies adopt decentralized technology, keeping these systems secure is becoming harder and more important.
A major example is the $160 million hack of Wintermute, a crypto company based in the UK. This breach shows how even large, well-funded firms can be vulnerable. These attacks don’t just cause financial losses—they also hurt the company’s reputation and destroy customer trust.
In this blog, we’ll explain what blockchain security is, explore the most common threats and challenges, uncover how fraudsters target blockchain systems, and share practical strategies to better protect your organization.
## What Is Blockchain Security?
Blockchain security refers to the tools, protocols, and practices used to protect blockchain systems from cyberattacks, fraud, and technical failures. It relies on encryption, consensus mechanisms, and decentralized networks to ensure data integrity and prevent unauthorized changes.
Security in blockchain goes beyond the network—it also includes safeguarding wallets, smart contracts, and exchanges. As blockchain is adopted across more industries, strong security practices like audits, monitoring, and user training are essential to keep systems resilient and trustworthy.
### Why Is Blockchain Security Important?
Blockchain security matters because once something is added to a blockchain, it can’t be changed. This is great for trust—but it also means that if hackers find a way in, the damage can’t be undone.
If wallets, smart contracts, or exchanges are not well protected, attackers can steal money, leak private data, or shut down services. As more companies use blockchain for important tasks, keeping these systems secure is the only way to protect users, prevent losses, and keep things running smoothly.
## Blockchain in Cyber Security
Blockchain in cyber security offers a new way to protect data by removing central points of failure. Because information is stored across a network of computers, it’s much harder for attackers to tamper with or delete data.
Blockchain also creates a permanent, time-stamped record of all activity, which helps with tracking and auditing. It’s being used for secure identity management, data sharing, and even detecting fraud. By combining transparency with strong encryption, blockchain adds an extra layer of protection to modern cybersecurity systems.
## How Does Blockchain Work?
Blockchain is a special type of database that stores information in a secure and transparent way. Here's how it works step by step:
- Data is grouped into blocks: Each block holds a set of transactions or records. When the block is full, it’s sealed and added to the chain.
- Each block is linked to the previous one: Blocks are connected using cryptographic hashes—unique codes that act like digital fingerprints. This forms a secure chain where one block depends on the one before it.
- Data is stored across a network: Instead of one central server, blockchain data is shared and stored on many computers (called nodes). Everyone in the network has a copy of the same data.
- Transactions must be verified: Before a block is added, network participants use a consensus method—like Proof of Work or Proof of Stake—to agree that the transactions are valid.
- Once added, blocks can't be changed: Changing one block would require changing every block after it on every copy in the network—making tampering nearly impossible.
This structure makes blockchain transparent, secure, and resistant to fraud, which is why it's increasingly used in cybersecurity, finance, supply chain, and beyond.
### Key Threats of Blockchain
While blockchain is secure by design, it’s not immune to threats. Here are some of the main risks:
- 51% Attacks: If a single group controls more than 50% of the network’s power, they can manipulate transactions, such as double-spending coins.
- Smart Contract Vulnerabilities: Bugs or coding errors in smart contracts can be exploited to steal funds or change how the contract behaves.
- Private Key Theft: If hackers steal a user’s private key, they can access and control that user’s assets—there’s no way to reverse it.
- Phishing Scams: Cybercriminals trick users into revealing sensitive information through fake emails or websites, often targeting wallet credentials.
These threats highlight the need for strong protections around blockchain networks, applications, and user access.
### Emerging Threats to Blockchain Networks
As blockchain technology evolves, so do the tactics used to attack it. Here are some of the newer and growing threats:
- Quantum Computing Risks: Future quantum computers could break the cryptographic algorithms used in blockchain, potentially exposing private keys and transaction data.
- Cross-Chain Vulnerabilities: Blockchains that connect with other chains or use bridges can introduce weak spots where attackers can exploit bugs or misconfigurations.
- Sybil Attacks: In this attack, a hacker creates many fake identities (nodes) to gain influence over the network, disrupting consensus and spreading false information.
- Consensus Manipulation: Attackers may exploit weaknesses in less secure consensus algorithms to take control of the network or delay transaction processing.
These threats highlight the need for ongoing innovation in blockchain security to stay ahead of increasingly advanced cyber risks.
## How Fraudsters Attack Blockchain Technology
While blockchain itself is secure, attackers often target the systems and users connected to it. They use phishing to steal private keys, carry out routing attacks to intercept or delay data, and launch Sybil attacks to manipulate network activity. Understanding these specific methods is essential to strengthening blockchain defenses.
### Phishing Attacks
Phishing is one of the most common threats in blockchain security. Attackers create fake wallet apps, crypto exchange websites, or browser extensions to trick users into entering their private keys or seed phrases. Once this information is stolen, attackers can instantly transfer the user’s crypto assets. There is no central authority in blockchain to reverse transactions, which makes these attacks especially damaging and irreversible.
To better understand how scammers use emotional manipulation in phishing, explore the techniques explained in Keepnet’s article: Phishing Examples by Emotional Triggers: How Scammers Exploit Human Emotions.
### Routing Attacks
Routing attacks target the internet pathways used to transmit data between blockchain nodes. Instead of attacking the blockchain directly, cybercriminals exploit flaws in the underlying network infrastructure—specifically the Internet Service Providers (ISPs) or routers handling blockchain traffic.
During a routing attack, data can be intercepted, delayed, or rerouted, allowing attackers to disrupt communication between nodes. This may lead to temporary network splits, transaction delays, or even attempts to double-spend assets before the network syncs again. These attacks don’t alter the blockchain itself, but they can undermine its reliability and user confidence.
### Sybil Attacks
In a Sybil attack, a hacker floods the blockchain network with many fake accounts or nodes. These fake identities are used to gain an unfair influence over the system.
With enough control, the attacker can disrupt how the network works—blocking real users, affecting consensus, or even controlling decisions. Since blockchain relies on honest participation, this type of attack can seriously damage trust and stability. Preventing Sybil attacks involves verifying users and limiting who can join the network.
## Common Blockchain Security Challenges
Blockchain offers strong built-in protection, but it's not immune to threats—especially when used in large-scale operational environments. From coding flaws in smart contracts to user-targeted attacks like phishing and malware, many risks emerge at the edges of the system. This section highlights the most common security challenges organizations face when using blockchain technology.
### Phishing Attacks on Blockchain Users
Phishing attacks in blockchain often target the trust users place in digital platforms. Instead of exploiting technical flaws, attackers exploit human behavior—posing as popular wallet providers, token projects, or support teams.
What makes this especially dangerous in blockchain is the lack of recovery options. There are no password resets or chargebacks. Once a private key or seed phrase is handed over, full control is lost. For businesses and individuals alike, this means traditional email security isn’t enough—security awareness must extend to recognizing deceptive blockchain-specific tactics.
To explore how phishing techniques are becoming more advanced, read Keepnet’s blog: 6 Shocking Advanced Phishing Attack Examples in 2025.
### Malware Targeting Blockchain Wallets
Malware designed to steal from blockchain wallets is a growing threat. These malicious programs can infect devices through fake apps, email attachments, or compromised websites. Once inside, they monitor user activity, steal wallet credentials, or even replace copied wallet addresses with the attacker’s own.
Unlike traditional banking, there’s no recovery process once funds are sent. This makes malware attacks especially harmful in the blockchain space. Protecting wallets requires up-to-date antivirus tools, secure device practices, and user training to spot suspicious behavior.
### Smart Contract Bugs and Exploits
Since smart contracts are immutable once deployed, coding errors can lead to irreversible losses. Proper testing, auditing, and formal verification are essential to counter these blockchain security issues.
## How to Ensure Blockchain Security
Blockchain technology is secure by design, but that doesn’t mean it’s fully protected out of the box. Security gaps often appear at the user level, in application code, or through third-party integrations. To fully protect blockchain systems, organizations must take proactive steps that go beyond the basics. Let’s dive into the key strategies that help strengthen blockchain environments and reduce the risk of attacks.
### Implementing Multi-Signature Wallets
Multi-signature wallets (or multisig wallets) require multiple private keys to authorize a single transaction. For example, a 2-of-3 multisig setup means that any two out of three authorized users must approve a transaction before it can go through.
This setup adds a strong layer of protection. Even if one private key is stolen or lost, attackers can’t access the funds without the other required keys. It also helps organizations reduce the risk of internal fraud or human error by ensuring that no single individual can move assets alone.
Multi-signature wallets are especially valuable for companies managing shared crypto assets, treasury accounts, or high-value transfers that require extra oversight.
### The Role of Encryption in Blockchain
Encryption is a core part of blockchain security, protecting data from unauthorized access and tampering. It ensures that only authorized parties can view or interact with sensitive information.
Blockchain uses two main types of encryption:
- Hashing: Secures data within each block by converting it into a fixed-length code. If the data changes, the hash changes—making tampering easy to detect.
- Public-key cryptography: Enables users to send and receive transactions securely. Each user has a public key (shared) and a private key (kept secret) to sign and verify transactions.
Without encryption, blockchain could not offer the privacy, integrity, and trust it’s known for. It’s the technology that keeps data secure, users anonymous, and transactions verifiable.
### Importance of Regular Security Audits
Regular security audits are essential for identifying hidden vulnerabilities in blockchain systems—especially in smart contracts, wallet integrations, and third-party applications.
Audits involve reviewing code, testing for weaknesses, and checking system configurations to ensure everything works as intended. Since blockchain systems are often permanent and publicly accessible, even a small bug can lead to major losses.
By running routine audits, organizations can fix issues early, prevent exploits, and build trust with users and stakeholders. It’s one of the most effective ways to maintain long-term blockchain security.
## The Future of Blockchain Security
As blockchain adoption grows, so do the threats targeting it. Future blockchain security will rely on smarter technologies and stronger defenses to keep up with evolving attacks.
New solutions like zero-knowledge proofs, privacy-preserving protocols, and AI-powered threat detection are already shaping how blockchains are secured. These tools aim to improve user privacy, strengthen authentication, and detect threats in real time.
The future also demands better user education, stricter blockchain development standards, and more collaboration across the industry. Staying ahead of threats means treating security as a continuous process—not a one-time fix.
### Emerging Technologies Enhancing Blockchain Security
New technologies are pushing blockchain security to the next level. These innovations help prevent attacks, protect user data, and build more trustworthy systems.
- Zero-Knowledge Proofs (ZKPs): Allow users to prove something is true without revealing the actual data—boosting privacy and reducing exposure to data leaks.
- AI-Powered Threat Detection: Uses artificial intelligence to monitor blockchain activity, detect unusual behavior, and identify threats faster than manual methods.
- Privacy-Preserving Protocols: Tools like homomorphic encryption and secure multi-party computation protect sensitive data while keeping blockchains transparent and functional.
As these technologies mature, they’ll play a key role in making blockchain systems more secure, scalable, and resilient.
## How Keepnet Can Help Secure Blockchain Environments
Blockchain networks are only as strong as the people who use them. While the technology itself is secure, human error—like falling for phishing emails or social engineering—remains a major risk. That’s where Keepnet comes in.
Keepnet’s Extended Human Risk Management platform helps organizations protect blockchain environments by addressing the human side of security. It uses AI-driven phishing simulations, adaptive training, and automated phishing response to reduce insider threats and stop social engineering attacks before they cause harm.
By educating users, detecting risky behaviors, and automating threat response, Keepnet empowers companies to build a strong security culture—essential for maintaining trust and resilience in blockchain systems.
Check out the Keepnet Human Risk Management platform to reduce human-related risks and protect your blockchain environment more effectively.
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How Blockchain is Shaping the Future of Cybersecurity - EIMT
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https://www.eimt.edu.eu/how-blockchain-is-shaping-the-future-of-cybersecurity
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blockchain cybersecurity
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The digital revolution has made cybersecurity a major concern due to the increasing scale and complexity of cyber threats. Blockchain technology, still in its early stages, is gaining attention as a promising solution for securing data and systems. Blockchain is expected to play a key role in the future of cybersecurity by safeguarding digital assets and enhancing privacy.
We are living in a world that is increasingly interconnected enabled by digital revolution. With the growth of this connectivity, however, cybersecurity has emerged as a primary concern of businesses, governments, and individuals alike. The threats in the cyber world have significantly increased in terms of scale and complexity. There is an impending need for innovative solutions to protect data and systems. Blockchain is one such novel technology that is gaining popularity and momentum. It is in its nascent stage, and is yet to establish itself as a full-fledged robust tool in fighting cyber threats. Nevertheless, it's providing new avenues to protect digital assets so that the privacy is intact, and it is building trust.
> **In this article, we will depict the usefulness of blockchain in defining the future of cybersecurity. We shall also see its potential to address some of the most pressing security issues that we are currently facing.**
## **Quick Rundown of Blockchain Technology**
Blockchain is conceived as a decentralized, distributed ledger technology or DDLT that records transactions across various computers. It is implemented in such a way that the registered transactions can't be altered retroactively without altering all subsequent blocks and with a consensus of the network. Simply, envision a digital ledger that records transactions or data in "blocks". This block is somehow associated or chained with the earlier one. In this sense, there is a continued series. This chain is actually spread throughout a network of computers known as nodes making it nearly impossible to tamper with data.
What makes blockchain particularly appealing in the realm of cybersecurity is its decentralized nature. This is in contrast to the traditional centralized systems that hold data on a single server or database. But in blockchain, it relies on a network of nodes. The feature ensures there is no single point of failure and thus makes blockchain much more resilient to attacks.
## **Blockchain and Cybersecurity: A Perfect Match**
It may sound somewhat futuristic when we think of fusion between blockchain technology and cybersecurity. However, this is rapidly becoming a reality. Let's understand how blockchain is being applied to enhance security:
**1\. Data integrity and transparency**
Ensuring the integrity of data is oneof the bigger challenges in cybersecurity. This is because most hackers modify or corrupt the data, which may bring about financial loss or even compromise the system. These issues can be addressed by employing blockchain, as it makes data tampering difficult. Each block includes a unique cryptographic hash, timestamp, and transaction data. In scenarios where data is altered, the hash changes, and thus breaks the chain and alerts the network. With the blockchain's decentralized system, each participant carries a copy of the blockchain, thus confirming changes in the information. Therefore, it is ideal for securing sensitive data such as financial transactions, medical records, and legal documents. This is due to high integrity and transparency in the data stored.
**2\. Decentralized authentication and identity management**
Before accessing sensitive information cybersecurity requires identity verification of the user. Conventional methods such as passwords and centralized systems are always prone to attacks and are under the risk of mass credential compromise. Incorporating blockchain facilitates a safer, decentralized approach where users can take control of their identity and credentials through public-key cryptography. This avoids the use of a central authority to reduce identity theft and credential fraud. This avoids the use of a central authority to reduce identity theft and credential fraud. Based on blockchain, self-sovereign identity systems empower users to control their own data and share it selectively with trusted parties, thereby minimizing exposure during breaches and creating a more secure and private means of handling digital identities.
**3\. Secure smart contracts**
Smart contracts are self-executing agreements with terms written into code, automatically executing when predefined conditions are met. This eliminates intermediaries and reduces human error or fraud. In cybersecurity, smart contracts enhance security by automating transactions and ensuring adherence to agreed terms. Running on blockchain, they inherit security features like immutability and decentralization, preventing tampering. Through a smart contract, one could make payment systems automated for releases only after the concerned security checks are met to guarantee authenticity and traceability of products in supply chain management.
**4\. Distributed denial of service (DDoS) attack mitigation**
DDoS attacks flood the system with traffic, making a system unavailable to legitimate users. Distributed denial of service attacks can thus be mitigated by blockchain technology with decentralized hosting of websites and applications, spreading the workload into multiple nodes, and subsequently reducing vulnerability to a single point of failure. Moreover, blockchain can track and identify malicious actors by analyzing traffic patterns within a decentralized network. This enables pinpointing the origin of the attack and blocking malicious traffic without disrupting legitimate users, enhancing protection against such cyberattacks.
**5\. Enhancing data privacy**
Data breach and surveillance have become major issues with sensitive information. Privacy in the digital world is improved by blockchain through encryption and decentralization. This ensures data encryption and storage that can only be decrypted by the owner. Even if hackers penetrate this encrypted data, they are not able to read or alter it without the decryption key. Blockchain can work with other privacy technologies, such as zero-knowledge proofs, which verify information without showing sensitive data. This hybrid of encryption, decentralization, and privacy techniques provides blockchain with the security for personal, financial, and government data.
## **Blockchain and Cybersecurity:** **Concerns and Challenges**
While blockchain offers promising solutions to cybersecurity challenges, there remain several hurdles that are yet to be crossed. Scalability of blockchain network is one big challenge, especially when dealing with large amounts of data or transactions. Secondly, integrating blockchain with existing systems and infrastructures can also be complex and costly.
Another area of concern is the potential vulnerabilities existing in the blockchain itself, smart contract bugs, or an error in the cryptographic algorithm. As blockchain technology undergoes evolution, it will be necessary for experts in cyber security to continue to assess and improve upon its defences.
## **Blockchain and Cybersecurity:** **Concluding Thoughts**
Undoubtedly, blockchain technology is revolutionizing cybersecurity with decentralized, secure, and transparent solutions for data protection, identity management, and trust enhancement. Despite challenges, blockchain will remain a vital technology in securing global digital systems, improving data integrity, protection of privacy and safeguarding digital assets against dynamic cyber threats.
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HIPAA Security Rule Notice of Proposed Rulemaking to Strengthen ...
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https://www.hhs.gov/hipaa/for-professionals/security/hipaa-security-rule-nprm/factsheet/index.html
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healthcare cybersecurity HIPAA
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# HIPAA Security Rule Notice of Proposed Rulemaking to Strengthen Cybersecurity for Electronic Protected Health Information
## Fact Sheet
On December 27, 2024, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) issued a Notice of Proposed Rulemaking (NPRM) to modify the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Security Rule to strengthen cybersecurity protections for electronic protected health information (ePHI). OCR administers and enforces the Security Rule, which establishes national standards for the protection of individuals’ ePHI by covered entities (health plans, health care clearinghouses, and most health care providers), and their business associates (together, regulated entities). Today’s proposed rule seeks to strengthen cybersecurity by updating the Security Rule’s standards to better address ever-increasing cybersecurity threats to the health care sector.
The proposed rulemaking is one of many actions taken by HHS in support of President Biden’s commitment to improving the cybersecurity of critical infrastructure. In 2023, the Biden-Harris Administration released the National Cybersecurity Strategy and its plan for implementing the strategy; version 2 was released in May of 2024. 1 Also in 2023, HHS released its Healthcare Sector Cybersecurity concept paper outlining the Department’s path forward to advance cybersecurity enhancements for the health care sector. 2 These plans included the publication of voluntary cybersecurity best practices and a strategy for greater cybersecurity enforcement and accountability, which included updating the HIPAA Security Rule with new cybersecurity requirements.
The NPRM proposes to strengthen the Security Rule’s standards and implementation specifications with new proposals and clarifications, including:
- Remove the distinction between “required” and “addressable” implementation specifications and make all implementation specifications required with specific, limited exceptions.
- Require written documentation of all Security Rule policies, procedures, plans, and analyses.
- Update definitions and revise implementation specifications to reflect changes in technology and terminology.
- Add specific compliance time periods for many existing requirements.
- Require the development and revision of a technology asset inventory and a network map that illustrates the movement of ePHI throughout the regulated entity’s electronic information system(s) on an ongoing basis, but at least once every 12 months and in response to a change in the regulated entity’s environment or operations that may affect ePHI.
- Require greater specificity for conducting a risk analysis. New express requirements would include a written assessment that contains, among other things:
- A review of the technology asset inventory and network map.
- Identification of all reasonably anticipated threats to the confidentiality, integrity, and availability of ePHI.
- Identification of potential vulnerabilities and predisposing conditions to the regulated entity’s relevant electronic information systems
- An assessment of the risk level for each identified threat and vulnerability, based on the likelihood that each identified threat will exploit the identified vulnerabilities.
- Require notification of certain regulated entities within 24 hours when a workforce member’s access to ePHI or certain electronic information systems is changed or terminated.
- Strengthen requirements for planning for contingencies and responding to security incidents. Specifically, regulated entities would be required to, for example:
- Establish written procedures to restore the loss of certain relevant electronic information systems and data within 72 hours.
- Perform an analysis of the relative criticality of their relevant electronic information systems and technology assets to determine the priority for restoration.
- Establish written security incident response plans and procedures documenting how workforce members are to report suspected or known security incidents and how the regulated entity will respond to suspected or known security incidents.
- Implement written procedures for testing and revising written security incident response plans.
- Require regulated entities to conduct a compliance audit at least once every 12 months to ensure their compliance with the Security Rule requirements.
- Require that business associates verify at least once every 12 months for covered entities (and that business associate contractors verify at least once every 12 months for business associates) that they have deployed technical safeguards required by the Security Rule to protect ePHI through a written analysis of the business associate’s relevant electronic information systems by a subject matter expert and a written certification that the analysis has been performed and is accurate.
- Require encryption of ePHI at rest and in transit, with limited exceptions.
- Require regulated entities to establish and deploy technical controls for configuring relevant electronic information systems, including workstations, in a consistent manner. New express requirements would include:
- Deploying anti-malware protection.
- Removing extraneous software from relevant electronic information systems.
- Disabling network ports in accordance with the regulated entity’s risk analysis.
- Require the use of multi-factor authentication, with limited exceptions.
- Require vulnerability scanning at least every six months and penetration testing at least once every 12 months.
- Require network segmentation.
- Require separate technical controls for backup and recovery of ePHI and relevant electronic information systems.
- Require regulated entities to review and test the effectiveness of certain security measures at least once every 12 months, in place of the current general requirement to maintain security measures.
- Require business associates to notify covered entities (and subcontractors to notify business associates) upon activation of their contingency plans without unreasonable delay, but no later than 24 hours after activation.
- Require group health plans to include in their plan documents requirements for their group health plan sponsors to: comply with the administrative, physical, and technical safeguards of the Security Rule; ensure that any agent to whom they provide ePHI agrees to implement the administrative, physical, and technical safeguards of the Security Rule; and notify their group health plans upon activation of their contingency plans without unreasonable delay, but no later than 24 hours after activation.
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HIPAA Security Rule To Strengthen the Cybersecurity of Electronic ...
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https://www.federalregister.gov/documents/2025/01/06/2024-30983/hipaa-security-rule-to-strengthen-the-cybersecurity-of-electronic-protected-health-information
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healthcare cybersecurity HIPAA
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# Proposed Rule
# HIPAA Security Rule To Strengthen the Cybersecurity of Electronic Protected Health Information
A Proposed Rule by the Health and Human Services Department on 01/06/2025
### A. Overview
In this notice of proposed rulemaking (NPRM), the Department of Health and Human Services (HHS or “Department”) proposes modifications to the Security Standards for the Protection of Electronic Protected Health Information (“Security Rule”), issued pursuant to section 262(a) of the Administrative Simplification provisions of title II, subtitle F, of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).\ [1\]
The Security Rule \ [2\]
is one of several rules, collectively known as the HIPAA Rules,\ [3\]
that protect the privacy and security of individuals' protected health information \ [4\]
(PHI), which is individually identifiable health information \ [5\]
(IIHI) transmitted by or maintained in electronic media or any other form or medium, with certain exceptions.\ [6\]
The Security Rule applies only to electronic PHI (ePHI), which is IIHI that is transmitted by or maintained in electronic media.\ [7\]
The Security Rule was initially published in 2003 and most recently revised in 2013.\ [8\]
Since its publication, there have been significant changes to the environment in which health care is provided and how the health care industry operates. Today, cybersecurity is a concern that touches nearly every facet of modern health care, certainly more than it did in 2003 or even 2013.
( printed page 900)
Almost every stage of modern health care relies on stable and secure computer and network technologies, including, but not limited to, the following: appointment scheduling, prescription orders, telehealth visits, medical devices, patient records, medical and pharmacy claims submissions and billing, insurance coverage verifications, payroll, facilities access and management, internal and external communications, and clinician resources. These tools and technologies are an integral part of the modern health care system, but they also present opportunities for bad actors to cause harm through hacking, ransomware, and other means. Covered entities and business associates (collectively, “regulated entities”) may also experience malfunctions and inadvertent errors that threaten the confidentiality, integrity, or availability of ePHI. Thus, cyberattacks, malfunctions, and inadvertent errors can negatively affect the provision of health care, as well as the efficiency and effectiveness of the health care system.
As discussed in greater detail below, in recent years, there has been an alarming growth in the number of breaches affecting 500 or more individuals reported to the Department, the overall number of individuals affected by such breaches, and the rampant escalation of cyberattacks using hacking and ransomware. The Department is concerned by the increasing numbers of breaches and other cybersecurity incidents experienced by regulated entities. We \ [9\]
are also increasingly concerned by the upward trend in the numbers of individuals affected by such incidents and the magnitude of the potential harms from such incidents.\ [10\]
In recognition of those potential harms and the health care sector's importance to the economy and security of the U.S., the President has designated “Healthcare and Public Health” as a critical infrastructure sector \ [11\]
and the Department as the Sector Risk Management Agency (SRMA).\ [12\]
In addition, to address concerns about the increasing level of cybercrime, the President has charged Federal agencies with “establishing and implementing minimum requirements for risk management” and robustly enforcing those requirements and Federal laws to help manage that risk.\ [13\]
We believe that a comprehensive and updated Security Rule is critical to accomplishing these directives and to the Department's effectiveness as the SRMA for the Healthcare and Public Health sector.
In further recognition of these concerns, States have promulgated or are in the process of promulgating regulations that would require the adoption of certain standards or measures for the protection of sensitive information, such as PHI.\ [14\]
While these proposed regulations may contain helpful guidance for regulated entities, none specifically focus on ensuring the security of ePHI and the information systems that create, receive, maintain, or transmit ePHI. Additionally, a patchwork of State-specific laws may create difficulties for regulated entities that are located or operate in multiple States. Several entities, including Federal agencies, have published and maintained guidelines, best practices, methodologies, procedures, and processes for protecting the security of sensitive information, including PHI. Some examples of these resources include the National Institute of Standards and Technology's (NIST's) “Cybersecurity Framework,” \ [15\]
the HHS 405(d) Program's “Health Industry Cybersecurity Practices: Managing Threats and Protecting Patients,” \ [16\]
the Federal Trade Commission's (FTC's) “Start with Security: A Guide for Business,” \ [17\]
and the Department's “Cybersecurity Performance Goals” (CPGs).\ [18\]
We believe that the proliferation of such documents in recent years has been helpful, and we have considered them in the development of this NPRM. However, in light of the increasing number and sophistication of cybersecurity incidents, we do not believe that these documents are sufficiently instructive for regulated entities to help improve their compliance with the Security Rule.
Under its statutory authority to administer and enforce the HIPAA Rules, the Department modifies the HIPAA Rules as needed, but does not modify a standard or implementation specification more than once every 12 months.\ [19\]
The Department makes the determination that such modifications may be needed using information it receives on an ongoing basis—from the Department's Federal advisory committee on HIPAA, the public, regulated entities, media reports, and its own analysis of the state of privacy and security for IIHI. As referenced above, and discussed in greater detail below, while the Department believes that the Security Rule generally continues to accomplish the goals of HIPAA,\ [20\]
we believe that it would be appropriate to consider modifying the Security Rule to address the following:
- Significant changes in technology.
- Changes in breach trends and cyberattacks.
- HHS' Office for Civil Rights' (OCR's) enforcement experience.
- Other guidelines, best practices, methodologies, procedures, and processes for protecting ePHI.
- Court decisions that affect enforcement of the Security Rule.
### B. Applicability
The effective date of a final rule would be 60 days after publication.\ [21\]
Regulated entities would have until the “compliance date” to establish and implement policies, procedures, and practices to achieve compliance with any new or modified standards.
( printed page 901)
Regulated entities would be permitted to comply earlier than the compliance date, but the Department would not take action against them for noncompliance with the proposed changes that occurs before the compliance date. Except as otherwise provided, 45 CFR 160.105 provides that regulated entities must comply with the applicable new or modified standards or implementation specifications no later than 180 days from the effective date of any such change. The Department has previously noted that the 180-day general compliance period for new or modified standards would not apply where a different compliance period is provided in the regulation for one or more provisions.\ [22\]
However, the compliance period cannot be less than the statutory minimum of 180 days.\ [23\]
While we recognize that we are proposing to substantially revise the regulatory text, the Department believes that most of the existing Security Rule's obligations for regulated entities would not be substantially changed by the proposed modifications. Instead, the proposed modifications would explicitly codify those activities that are critical to protecting the security of ePHI as requirements and provide greater detail for such requirements in the regulatory text. For example, regulated entities are already required to conduct an accurate and thorough risk analysis. While not specified in the regulatory text of the Security Rule, an accurate and thorough risk analysis requires a regulated entity to perform an inventory of its technology assets, determine how ePHI moves through its information systems, and identify the locations within its information systems (or components thereof) where ePHI may be created, received, maintained, or transmitted. Applying such an approach protects ePHI across all phases of the data lifecycle consistent with the purpose of the Security Rule. The proposals to require a regulated entity to inventory its technology assets and map the movement of ePHI through its information systems would illuminate considerations to be included in the regulated entity's risk analysis.
As another example, implementing a mechanism to encrypt ePHI is an addressable implementation specification under the standard for access control at 45 CFR 164.312(a)(2)(iv)(2)(iv)). Under the existing Security Rule, a regulated entity must assess whether encryption is a reasonable and appropriate safeguard in its environment, when analyzed with reference to its likely contribution to protecting ePHI, and implement encryption if reasonable and appropriate.\ [24\]
If encryption is not reasonable and appropriate, a regulated entity must document why it would not be reasonable and appropriate for it to implement the safeguard and must implement an equivalent alternative measure if reasonable and appropriate.\ [25\]
As discussed in greater detail below, encryption is built into most software today, and where it is not, there are affordable and easily implemented solutions that can encrypt sensitive information. Thus, it generally would be reasonable and appropriate for regulated entities to implement a mechanism to encrypt ePHI, and regulated entities should already have done so in most circumstances. By expressly requiring regulated entities to encrypt ePHI, with limited exceptions, the Department's proposal would reflect our expectations in the current cybersecurity environment and eliminate the need for regulated entities to perform an analysis of whether encryption is reasonable and appropriate.
Thus, most of the modifications we are proposing would provide regulated entities with greater clarity and specificity regarding how to fulfill their obligations and the Department's expectations.
Accordingly, we do not believe that the proposed rule would pose unique implementation challenges that would justify an extended compliance period (
_i.e.,_
a period longer than the standard 180 days provided in 45 CFR 160.105). Further, the Department believes that adherence to the standard compliance period is necessary to timely address the circumstances described in this NPRM. Thus, the Department proposes to apply the standard compliance date of 180 days after the effective date of a final rule.\ [26\]
To help reduce administrative burdens on regulated entities, the Department proposes to add a provision at 45 CFR 164.318 affording regulated entities a transition period (beyond the 180-day compliance period) to modify business associate contracts (herein referred to as “business associate agreements”) or other written arrangements \ [27\]
that would qualify for the longer transition period, as discussed further below.
The Department seeks comment on the proposed compliance period and transition period.
### C. Table of Abbreviations/Commonly Used Acronyms in This Document
As used in this preamble, the following terms and abbreviations have the meanings noted below.
Term Meaning
--- ---
AI Artificial Intelligence.
ANSI American National Standards Institute.
AR Augmented Reality.
ARRA American Recovery and Reinvestment Act of 2009.
ASTP/ONC Assistant Secretary for Technology Policy and Office of the National Coordinator for Health Information Technology.
CISA Cybersecurity & Infrastructure Security Agency.
CMS Centers for Medicare & Medicaid Services.
CPG Cybersecurity Performance Goal.
Department or HHS Department of Health and Human Services.
EHR Electronic Health Record.
E.O. Executive Order.
ePHI Electronic Protected Health Information.
FDA Food & Drug Administration.
FISMA Federal Information Security Modernization Act.
FTC Federal Trade Commission.
Health IT Health Information Technology.
( printed page 902)
HIPAA Health Insurance Portability and Accountability Act of 1996.
HITECH Act Health Information Technology for Economic and Clinical Health Act of 2009.
ICR Information Collection Request.
IIHI Individually Identifiable Health Information.
IT Information Technology.
MFA Multi-factor Authentication.
NAICS North American Industry Classification System.
NCVHS National Committee on Vital and Health Statistics.
NIST National Institute of Standards and Technology.
NPRM Notice of Proposed Rulemaking.
OCR Office for Civil Rights.
OMB Office of Management and Budget.
ONC Office of the National Coordinator for Health Information Technology.
PHI Protected Health Information.
PRA Paperwork Reduction Act of 1995.
PSAO Pharmacy Services Administration Organizations.
RFA Regulatory Flexibility Act.
RIA Regulatory Impact Analysis.
SBA Small Business Administration.
SRMA Sector Risk Management Agency.
SSA Social Security Act of 1935.
UMRA Unfunded Mandates Reform Act of 1995.
VR Virtual Reality.
## II. Statutory Authority and Regulatory History
### A. Statutory Authority and History
#### 1\. Health Insurance Portability and Accountability Act of 1996 (HIPAA)
In 1996, Congress enacted HIPAA \ [28\]
to reform the health care delivery system to “improve portability and continuity of health insurance coverage in the group and individual markets” \ [29\]
and “to simplify the administration of health insurance.” \ [30\]
Through subtitle F of HIPAA, Congress amended title XI of the Social Security Act of 1935 (SSA) by adding part C, entitled “Administrative Simplification.” \ [31\]
A primary purpose of part C is to improve the Medicare and Medicaid programs and “the efficiency and effectiveness of the health care system, by encouraging the development of a health information system through the establishment of uniform standards and requirements for the electronic transmission of certain health information.” \ [32\]
Congress recognized that the development of a health information system that enabled the electronic transmission of IIHI as required by HIPAA would pose risks to the privacy of confidential health information and viewed individual privacy, confidentiality, and data security as critical to support the shift from a paper-based recordkeeping system for health information to a digital one.\ [33\]
Congress intended for the law to enhance individuals' trust in health care providers, which required that the law provide additional protection for the confidentiality of IIHI. As described by a Member of Congress at the time of the law's passage: “\[t\]his standardization, however, accelerates the creation of large databases containing personally identifiable information. All this information is transmitted over electronic networks. We need to be very careful about how safe and secure that information is from prying eyes. Some of it may be extremely sensitive and could be used in a malicious or discriminatory manner.” \ [34\]
Moreover, Congress considered that health care reform required an approach that would not compromise privacy as health information became more accessible.\ [35\]
Congress applied the Administrative Simplification provisions directly to three types of persons referred to in regulation as covered entities: health plans, health care clearinghouses, and health care providers who transmit information electronically in connection with a transaction for which HHS has adopted a standard.\ [36\]
Under HIPAA, covered entities are required to maintain reasonable and appropriate administrative, physical, and technical safeguards \ [37\]
to: (1) ensure the integrity and confidentiality of information; \ [38\]
(2) protect against any reasonably anticipated threats or hazards to the security or integrity of the information and unauthorized uses or disclosures of the information; \ [39\]
and (3) otherwise ensure compliance with HIPAA by the officers and employees of covered entities.\ [40\]
HIPAA required the Secretary to adopt uniform standards “to enable health information to be exchanged electronically.” \ [41\]
Congress also directed the Secretary to, among other things, adopt standards for the security of IIHI.\ [42\]
The statute also directed the Secretary to adopt initial security standards within 18 months of its
( printed page 903)
enactment.\ [43\]
In adopting security standards for health information, HIPAA requires the Secretary to consider all of the following: \ [44\]
- The technical capabilities of record systems used to maintain health information.
- The costs of security measures.
- Training for persons who have access to health information.
- The value of audit trails in computerized record systems.
- The needs and capabilities of small health care providers and rural health care providers.\ [45\]
Congress contemplated that the Department's rulemaking authorities under HIPAA would not be static. In fact, Congress specifically built in a mechanism to adapt such regulations as technology and health care evolve, directing the Secretary to review and adopt modifications to the Administrative Simplification standards, including the security standards, as determined appropriate, but not more frequently than once every 12 months.\ [46\]
That statutory directive complements the Secretary's general rulemaking authority to make and publish such rules and regulations as may be necessary to the efficient administration of the functions with which the Secretary is charged.\ [47\]
The Secretary may adopt either a standard developed, adopted, or modified by a standard setting organization that relates to a standard that the Secretary is authorized or required to adopt under the Administrative Simplification provisions, or a standard that is different if the different standard will substantially reduce administrative costs to health care providers and health plans.\ [48\]
If no standard has been adopted by any standard setting organization, the Secretary shall rely on the recommendations of the National Committee on Vital and Health Statistics (NCVHS) and consult with Federal and State agencies and private organizations.\ [49\]
#### 2\. Health Information Technology for Economic and Clinical Health (HITECH) Act
On February 17, 2009, Congress enacted the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act), part of the American Recovery and Reinvestment Act of 2009 (ARRA),\ [50\]
promoting the nationwide adoption and standardization of health information technology (health IT) to support the electronic sharing of clinical data. The HITECH Act created financial incentives for health IT use among health care practitioners by providing funding for investing in health IT infrastructure, purchasing certified electronic health records (EHRs), and training on and the dissemination of best practices to integrate health IT.\ [51\]
The Purpose statement of an accompanying House of Representatives report \ [52\]
on the Energy and Commerce Recovery and Reinvestment Act \ [53\]
recognizes that widespread health IT adoption “has the potential to ameliorate many of the quality and efficiency problems endemic to our health care system.” Congress also understood that “\[e\]nsuring the privacy and security of electronic health information is critical to the success” of this immense effort to promote health IT adoption.\ [54\]
As a result, the HITECH Act also introduced substantial changes to the HIPAA regulations by mandating stronger safeguards for the privacy and security of ePHI.\ [55\]
The HITECH Act's security requirements focused on safeguarding an individual's health information while allowing covered entities to rapidly adopt new technologies to improve the quality and efficiency of patient care.\ [56\]
Specifically, the HITECH Act extends the application of the Security Rule's provisions on administrative, physical, and technical safeguards and documentation requirements to business associates of covered entities, making those business associates subject to civil and criminal liability for violations of the Security Rule.\ [57\]
The HITECH Act also requires existing business associate agreements to incorporate new security requirements.\ [58\]
Additionally, the HITECH Act requires the Secretary to regularly issue guidance on the most effective and appropriate technical safeguards.\ [59\]
In enacting the HITECH Act, Congress affirmed that the existing HIPAA Rules were to remain in effect to the extent that they are consistent with the HITECH Act and directed the Secretary to revise the HIPAA Rules as necessary for consistency with the HITECH Act.\ [60\]
Congress confirmed that the new law was not intended to have any effect on authorities already granted under HIPAA to the Department, including part C of title XI of the SSA.\ [61\]
Thus, Congress affirmed the Secretary's ongoing rulemaking authority to modify the Security Rule's standards and implementation specifications as often as every 12 months when appropriate, including to strengthen security protections for IIHI.
In 2021, the HITECH Act was amended to require the HHS Secretary to further encourage regulated entities to bolster their cybersecurity practices.\ [62\]
The amendment requires the Department to consider certain recognized security practices of regulated entities when making determinations relating to certain Security Rule compliance and enforcement activities.\ [63\]
### B. Regulatory History
The Security Rule requires regulated entities to implement administrative, physical, and technical safeguards to
( printed page 904)
protect ePHI.\ [64\]
Specifically, regulated entities must ensure the confidentiality, integrity, and availability of all ePHI they create, receive, maintain, or transmit; \ [65\]
protect against reasonably anticipated threats or hazards to the security or integrity of the information \ [66\]
and reasonably anticipated impermissible uses or disclosures; \ [67\]
and ensure compliance by their workforce.\ [68\]
#### 1\. 1998 Security Rule Notice of Proposed Rulemaking
The Administrative Simplification provisions of HIPAA instructed the Secretary to adopt several standards concerning electronic transmission of health information, including those for the security of health information.\ [69\]
In accordance with these provisions, the Department published the Security and Electronic Signature Standards; Proposed Rule (“1998 Proposed Rule”) on August 12, 1998.\ [70\]
In support of developing the national standards mandated under HIPAA's Administrative Simplification provisions, the Secretary, with significant input from the health care industry, defined a set of principles for guiding choices for the standards to be adopted by the Secretary.\ [71\]
The principles were based on direct specifications in HIPAA and also took the purpose of the law and generally desirable principles into account. Based on this work, the Department proposed that each HIPAA standard should be clear and unambiguous but technology neutral, improve the efficiency and effectiveness of the health care system, meet the needs of covered entities related to ease of use and affordability of adoption, and maintain consistency or alignment with other HIPAA standards adopted by an organization accredited by the American National Standards Institute (ANSI) and using the ANSI process for adopting such standards.\ [72\]
In describing its general approach to the 1998 Proposed Rule, the Department defined the security standard as a set of requirements with implementation features that covered entities must include in their operations to assure the security of individuals' ePHI.\ [73\]
The security standard was based on three basic concepts that were derived from the Administrative Simplification provisions of HIPAA and consistent with the characteristics the Department identified as appropriate for all HIPAA Rules.\ [74\]
First, the standard should be comprehensive and coordinated to address all aspects of security. Second, it should be scalable, so that it could be effectively implemented by covered entities of all types and sizes. Third, it should not be linked to specific technologies, allowing covered entities the flexibility to make use of future technology advancements.\ [75\]
The 1998 Proposed Rule included four categories of requirements that a covered entity would have to address to safeguard the confidentiality, integrity, and availability of ePHI. They were as follows:
- Administrative procedures.
- Physical safeguards.
- Technical security services.
- Technical mechanisms.
The implementation specifications described some of the requirements in greater detail, based on our determination regarding the level of instruction necessary to implement such requirements.\ [76\]
The Department viewed all categories as equally important.\ [77\]
The proposed standard did not address the extent to which a covered entity should implement the specifications.\ [78\]
Instead, the Department proposed to require that each covered entity assess its own security needs and risks and devise, implement, and maintain appropriate security to address its business requirements. The Department believed that this approach would leave a significant amount of flexibility for covered entities and balance the needs of securing health data against risk with the economic cost of doing so.\ [79\]
#### 2\. 2003 Final Rule
The Department issued the final Security Rule \ [80\]
on February 20, 2003 (“2003 Final Rule”). In accordance with the Administrative Simplification provisions of HIPAA, the 2003 Final Rule adopted standards for the security of ePHI to be implemented by covered entities.
The Department reiterated the purposes and guiding principles it articulated in the 1998 Proposed Rule and repeated that the protection of the privacy of information depends in large part on the existence of security measures to protect that information.\ [81\]
The Department noted that there were still no standard measures in the health care industry that address all aspects of the security of ePHI while it is being stored or during the exchange of that information between entities.\ [82\]
The Department explained that the use of the security standards would improve the Medicare and Medicaid programs, other Federal health programs and private health programs, and the effectiveness and efficiency of the health care industry in general by establishing a level of protection for ePHI.\ [83\]
Provisions of the 2003 Final Rule did not mirror the 1998 Proposed Rule; rather, the Department finalized only certain changes. The Department noted, for example, that to maintain consistency with the use of terms as they appear in the statute and other previously released HIPAA Rules (
_i.e.,_
the HIPAA Privacy and Transactions Rules), it was changing some terminology from the 1998 Proposed Rule, replacing the terms “requirement” with “standard” and “implementation feature” with “implementation specification.” \ [84\]
According to the Department, the comments received in response to the 1998 Proposed Rule overwhelmingly validated its basic assumptions that the covered entities were so varied in terms of installed technology, size, resources, and relative risk, that it would be impossible to dictate a specific solution or set of solutions that would be usable by all covered entities.\ [85\]
Similarly, we received numerous comments expressing the view that the security standards should not be overly prescriptive because the speed with which technology is evolving could make specific requirements obsolete and might in fact deter technological progress. Accordingly, the Department framed the standards in the 2003 Final Rule in terms that were as generic as possible and that could generally be met through a variety of approaches or technologies.\ [86\]
The standards, we
( printed page 905)
explained, do not allow organizations to make their own rules, only their own technology choices.\ [87\]
We also recognized that entities could minimize risk through their security practices, but likely could never completely eliminate all risk. In the preamble to the 2003 Final Rule, the Department acknowledged that there is no such thing as a totally secure system that carries no risks to security.\ [88\]
The Department opined that Congress' intent in the use of the word “ensure” in section 1173(d) of the SSA was to set an exceptionally high goal for the security of ePHI. However, we also recognized that Congress anticipated that some trade-offs would be necessary, and that “ensuring” protection did not mean doing so without any regard to the cost.\ [89\]
As such, the Department explained that we expected a covered entity to protect that information to the best of its ability.\ [90\]
Thus, a covered entity would be expected to balance the identifiable risks to and vulnerabilities of ePHI with the cost of various protective measures, while also taking into consideration the size, complexity, and capabilities of the covered entity.\ [91\]
In the 2003 Final Rule, the Department introduced the concept of “addressable” implementation specifications, which it distinguished from “required” implementation specifications. The goal was to provide covered entities with even more flexibility.\ [92\]
While none of the implementation specifications were optional, designating some of the implementation specifications as addressable provided each covered entity with the ability to determine whether certain implementation specifications were reasonable and appropriate safeguards for that entity, based on its risk analysis, risk mitigation strategy, previously implemented security measures, and the cost of implementation.\ [93\]
### 3\. 2009 Delegation of Authority
On October 7, 2003, the Secretary delegated authority for administering and enforcing the Security Rule to the Administrator of the Centers for Medicare & Medicaid Services (CMS).\ [94\]
The Secretary issued a notice on August 4, 2009, superseding the previous delegation and replacing it with a delegation authority to the Director of OCR effective July 27, 2009.\ [95\]
### 4\. 2013 Omnibus Rulemaking
Following the enactment of the HITECH Act, the Department issued an NPRM, entitled “Modifications to the HIPAA Privacy, Security, and Enforcement Rules Under the Health Information Technology for Economic and Clinical Health \[HITECH\] Act” (“2010 Proposed Rule”),\ [96\]
to propose implementation of certain HITECH Act requirements. In the 2010 Proposed Rule, the Department noted that it had not amended the Security Rule since 2003.\ [97\]
We further explained that information gleaned from contact with the public since that time, OCR's enforcement experience, and technical corrections needed to eliminate ambiguity provided the impetus for the Department's actions to propose certain regulatory changes beyond those required by the HITECH Act.\ [98\]
In 2013, the Department issued the final rule “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health \[HITECH\] Act and the Genetic Information Nondiscrimination Act, and Other Modifications to the HIPAA Rules” (“2013 Omnibus Rule”),\ [99\]
which implemented applicable provisions of the HITECH Act to strengthen security protections for individuals' health information maintained in EHRs.
For example, the Department modified the Security Rule to implement the HITECH Act's provisions that extended direct liability for compliance with the Security Rule to business associates.\ [100\]
We explained that before the enactment of the HITECH Act, the Security Rule did not directly apply to business associates of covered entities. The HITECH Act extended the application of the Security Rule's administrative, physical, and technical safeguards requirements, as well as the rule's policies and procedures and documentation requirements, to business associates in the same manner as the requirements apply to covered entities, making those business associates civilly and criminally liable for violations of the Security Rule.\ [101\]
The Department noted that the Security Rule requires a covered entity to establish business associate agreements that obligate business associates to implement administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the ePHI that they create, receive, maintain, or transmit on behalf of the covered entity.\ [102\]
Accordingly, we reasoned that business associates and subcontractors should already have security practices in place that comply with the Security Rule, or require only modest improvement to come into compliance with the Security Rule requirements.\ [103\]
Like the 2003 Final Rule,\ [104\]
the 2013 Omnibus Rule highlighted that the Security Rule was designed to be technology neutral and scalable and reiterated that regulated entities have the flexibility to choose security measures appropriate for their size, resources, and the nature of the security risks they face.\ [105\]
Accordingly, regulated entities have the flexibility to choose appropriate security measures considering their size, capabilities, the costs of the specific security measures, and the operational impact, enabling them to reasonably implement the standards of the Security Rule.
The Department also adopted technical revisions to 45 CFR 164.306(e)) to clarify that regulated entities must review and modify security measures as needed to ensure reasonable and appropriate protection of ePHI, and update documentation of security measures accordingly.\ [106\]
Finally, because the HITECH Act made business associates directly liable for compliance with the Security Rule, the 2013 Omnibus Rule modified the Security Rule to clarify that a covered entity is not required to obtain satisfactory assurance from a business associate that is a subcontractor that the subcontractor will appropriately safeguard its ePHI. Rather, the business
( printed page 906)
associate of the covered entity must obtain the required satisfactory assurances from the subcontractor to protect the security of ePHI.\ [107\]
## III. Justification for This Proposed Rulemaking
HIPAA and the HIPAA Rules promote access to high-quality and effective health care by establishing standards for the security of ePHI. The standards, when implemented appropriately by regulated entities, protect the confidentiality, integrity, and availability of individuals' health information. Such protections promote the electronic transmission of PHI through a national health information system. To ensure access to high-quality health care services, regulated entities must assure their customers (
_e.g.,_
individuals, health care providers, and health plans) of the security of the sensitive and confidential health information the regulated entities electronically create, receive, maintain, or transmit.
As discussed above, the Security Rule carefully balances the benefits of safeguarding against security risks with the burdens of implementing protective measures by permitting regulated entities to consider several factors, including costs and available technology for preventing and mitigating security risks,\ [108\]
when determining which security measures are reasonable and appropriate for protecting the security of individuals' ePHI.\ [109\]
For example, the Security Rule requires that a regulated entity implement policies and procedures to limit physical access to its electronic information systems and the facilities in which they are housed, while ensuring that users who are authorized to access such information systems and facilities are permitted to do so.\ [110\]
The implementation specifications associated with this standard only address the need for operationalized policies and procedures related to specific aspects of physical security.\ [111\]
They do not dictate the specifics of such policies and procedures because we recognize that the nature of the physical safeguards should depend on the type of regulated entity, its size, its level of access to ePHI, and a number of other factors.
Since the Security Rule's promulgation in 2003, the environment in which health care is provided and in which regulated entities operate has changed significantly, including transformative changes in how regulated entities create, receive, maintain, and transmit ePHI. For example, as of 2021, almost 80 percent of physician offices and 96 percent of hospitals had adopted certified EHRs.\ [112\]
The use of health IT, including EHRs (certified or otherwise), has led to enormous advancements in the fields of medicine and public health, not only improving outcomes for individuals, but also assisting in addressing the social, economic, and environmental factors that affect health on an individual and community level.\ [113\]
And the electronic exchange of health information, spurred by HIPAA, the HITECH Act, and the 21st Century Cures Act (“Cures Act”),\ [114\]
has enabled regulated entities and others to more quickly and efficiently share individuals' health information, increasing the quality and efficiency of health care, increasing patient engagement, and reducing administrative burden.\ [115\]
However, the widespread use of health IT systems makes it even more critical for regulated entities, regardless of their size or location, to fully assess the risks and vulnerabilities to ePHI and their information systems and implement strong security measures to address those risks and vulnerabilities.
Experts repeatedly have expressed concern regarding the state of cybersecurity in the health care industry.\ [116\]
For example, in a 2017 report to Congress, experts convened by the Department pronounced, “Now more than ever, all health care delivery organizations \[. . .\] have a greater responsibility to secure their systems, medical devices, and patient data.” \ [117\]
This responsibility has only increased as the delivery of health care and the exchange of PHI have increasingly shifted to cyberspace.
Despite advancements in technology, including health IT, the core requirements of the Security Rule remain relevant and applicable today. In fact, they serve as a foundation for more recently promulgated cybersecurity guidelines, best practices, processes, and procedures. Security management, regular monitoring and review of information system activity, information access management, security awareness and training, contingency planning, encryption, and authentication all continue to be represented in the most well-known cybersecurity frameworks, including the NIST's Cybersecurity Framework,\ [118\]
the HHS 405(d) Program's “Health Industry Cybersecurity Practices: Managing
( printed page 907)
Threats and Protecting Patients,” \ [119\]
and the Department's CPGs.\ [120\]
While these concepts remain highly relevant and applicable, the Department has concerns regarding the sufficiency of the security measures implemented by regulated entities. OCR's experience investigating allegations of Security Rule violations, reports received by OCR of breaches of unsecured PHI, and the results of the audits conducted by OCR in 2016-2017 demonstrate that regulated entities are not consistently complying with the Security Rule's requirements.\ [121\]
Additionally, the Department is concerned about the extent to which regulated entities have updated their security measures to adjust to the changes in the health care environment and their operations, including new and emerging threats to the confidentiality, integrity, and availability of ePHI.
And the Department is not alone in its concerns. NCVHS serves as the Department's advisory body for HIPAA.\ [122\]
Given the increase in cybersecurity incidents affecting the health care sector, NCVHS held a series of public hearings on cybersecurity to better understand how to protect ePHI and individuals. In response to those hearings, NCVHS submitted several recommendations to the Department regarding the importance of strengthening the Security Rule.\ [123\]
As discussed above, HIPAA requires the Secretary to rely on NCVHS' recommendations \ [124\]
with respect to standards promulgated under the statute.
Given the importance of strong security measures, the changed environment and operations for health care, uncertainty expressed by regulated entities regarding their compliance obligations, deficiencies identified by OCR in its investigations of regulated entities, and the recommendations of NCVHS, we believe that it is necessary and appropriate for the Department to propose modifications to clarify and strengthen the Security Rule.
### A. Strong Security Standards Are Essential to Protecting the Confidentiality, Integrity, and Availability of ePHI and Ensuring Quality and Efficiency in the Health Care System
A primary purpose of HIPAA's Administrative Simplification provisions \ [125\]
is to, among other things, “improve \[. . .\] the efficiency and effectiveness of the health care system, by encouraging the development of a health information system through the establishment of uniform standards and requirements for the electronic transmission of certain health information.” \ [126\]
As Congress recognized when it enacted HIPAA, protecting the security of ePHI is essential for accomplishing this goal. Members of Congress acknowledged at that time that the provisions of HIPAA would create electronic databases of PHI, enabling the PHI to be transmitted electronically with both the benefits and risks that accompany such electronic transactions.\ [127\]
Congressional statements leading up to HIPAA's enactment demonstrate Congress' recognition of the potential risks of the shift from paper recordkeeping to electronic: “We need to be very careful about how safe and secure that information is from prying eyes. Some of it may be extremely sensitive and could be used in a malicious or discriminatory manner.” \ [128\]
Accordingly, HIPAA required the establishment of strict security standards for health information.
As discussed above, the Security Rule, as amended by the HITECH Act, specifically requires regulated entities to maintain reasonable and appropriate administrative, physical, and technical safeguards to ensure the confidentiality, integrity, and availability of ePHI; to protect against any reasonably anticipated threats or hazards to the security or integrity of ePHI and unauthorized uses or disclosures of ePHI; and ensure compliance with the Administrative Simplification provisions by officers and workforce members of regulated entities.\ [129\]
It is reasonable to anticipate that regulated entities will need to protect ePHI against cyberattacks and unauthorized uses and disclosures of ePHI by their workforce members. Experts estimate the costs to the U.S. from cyberattacks on health care facilities to be significant.\ [130\]
According to one study, health care data breach costs to affected organizations have increased by more than 50 percent since 2020, making health care data breaches more expensive than data breaches in any other sector, at an average cost of almost $10.1 million per breach.\ [131\]
Yet these costs, though sizeable, do not fully take into account the practical implications of poor or ineffective cybersecurity protocols. A failure to implement adequate security measures may lead to: financial loss; reputational harm for affected individuals and affected regulated entities; privacy loss; and safety concerns.\ [132\]
Additionally, breaches of unsecured PHI may lead to identity theft, fraud, stock manipulation, and competitive disadvantage.\ [133\]
According to a study funded by the Institute for Critical Infrastructure Technology, victims of medical identity theft incur on average costs of $13,500 to recover from that theft.\ [134\]
Unlike financial information, much of an individual's PHI is
( printed page 908)
immutable. For example, an individual's date and location of birth and their health history will not change, even if their address might. In contrast, an individual's passwords, bank account numbers, and other financial information can all be changed. Thus, PHI can continue to be exploited throughout an individual's lifetime, making PHI likely to be far more valuable than an individual's credit card information.\ [135\]
On the surface, the harms that result from a breach of ePHI or a cyberattack on a regulated entity's electronic information systems, as discussed above, are not significantly different than those that would result from a breach of information in another sector. However, the reality is, as discussed above, that the implications of such harms are far greater in the health care sector because of their potential to adversely affect an individual's health or quality of life, or even to cost an individual their life.\ [136\]
As stated by the Health Care Industry Cybersecurity Task Force in its 2017 report on the state of cybersecurity in health care: “The health care system cannot deliver effective and safe care without deeper digital connectivity. If the health care system is connected, but insecure, this connectivity could betray patient safety, subjecting them to unnecessary risk and forcing them to pay unaffordable personal costs.” \ [137\]
In the event of a cybersecurity incident, patients' health, including their lives, may be at risk where such incident creates impediments to the provision of health care, such as interference with the operations of a critical medical device, or to the administrative or clinical operations of a regulated entity, such as preventing the scheduling of appointments or viewing of an individual's health history.\ [138\]
According to a Cybersecurity & Infrastructure Security Agency (CISA) statistical analysis of the effects of a hypothetical cyberattack on a model hospital, a hospital's relative performance will suffer amidst a cyberattack.\ [139\]
The analysis found that the hypothetical cyberattack would lead to hospital strain from inaccessible patient schedules and records, disrupted communication, and delays in processing and communicating test results in time to effectively treat individuals.\ [140\]
While the analysis did not find any deaths directly attributable to the hypothetical attack, it is logical to conclude that deaths—or at least worsened outcomes—are a significant risk where there are disruptions in communications, as well as delays in processing and communicating test results, especially for emergent or acute medical cases. For example, an inability to access an individual's pharmacy records could affect the ability of a pharmacist to identify known interactions between newly prescribed medications and an existing medication list, potentially leading to an individual's injury or death. Other studies have similarly found that cyberattacks can have a substantial effect on access to health care, and potentially mortality.\ [141\]
In fact, a more recent study found that cyberattacks had disproportionately negative effects on in-hospital mortality rates for Black patients who were already admitted to the hospital at the time of the cyberattack.\ [142\]
A recent survey found that 92 percent of surveyed health care organizations had experienced a cyberattack in the past year \ [143\]
and almost three-quarters of the respondents who had experienced a cyberattack reported negative effects on patient care, including delays in tests or procedures, longer stays, and increased mortality rates complications from medical procedures, and patient transfers or diversions to other facilities.\ [144\]
A recent letter from NCVHS referenced anecdotal accounts of patient deaths that have been attributed to ransomware attacks.\ [145\]
For example, in 2019, a ransomware attack may have contributed to a baby's death at an Alabama hospital. A change in the baby's fetal heart rate went unnoticed because the large digital display that normally would have displayed the information was affected by the attack. The baby, born with her umbilical cord wrapped around her neck, suffered severe brain damage and died nine months later.\ [146\]
Cyberattacks can divert both human and machine resources, leading to process slowdowns, cancelled procedures, delayed hospital or unit lockdowns and transfers, increases in wait times for individuals, both increases and decreases in staff utilization, and a decrease in a health care provider's capacity.\ [147\]
A 2020 cyberattack on a large integrated academic health system, attributed to malicious software embedded in an email attachment opened by an employee on their laptop, affected more than 5,000 end-user devices across 1,300 servers and led to revenue losses of more than $63 million.\ [148\]
Though the health care provider's EHR was not infected, it elected to shut the EHR down proactively. Ultimately, the covered entity “experienced 39 days of downtime in outpatient imaging.” \ [149\]
In another example, a ransomware attack on an academic level 1 trauma center caused it to go without access to its EHR for 25 days,\ [150\]
and the attack affected 5,000 computers and destroyed the trauma center's electronic information systems that contained ePHI. The hospital lost access to its EHR, internet, and intranet, which also “removed functionality of hospital phones, \[EHR\] integrated office and surgical scheduling, access to digitized radiology studies, and network account access through local and remote computers.” \ [151\]
These serious incidents and resulting effects demonstrate the importance of planning and preparing for a potential
( printed page 909)
cyberattack or other event that adversely affects a regulated entity's information systems. While such planning and preparation may not prevent all cyberattacks, it can reduce the number of successful incidents and mitigate their effects. In fact, studies have suggested that such preparation may allow for at least close to real-time recovery.\ [152\]
The effects of a cyberattack are not limited to the regulated entity that experiences it and the individuals whose ePHI is compromised. Surveys conducted by various organizations representing health care providers indicate that an overwhelming majority of health care providers in the U.S. were affected by a ransomware attack on a large health care clearinghouse.\ [153\]
A study published in 2023 examined the effects on the of a cyberattack at a neighboring, unaffiliated hospital on a large academic medical center.\ [154\]
The study found that the academic medical center experienced, among other things, significant increases in the number of patients admitted, ambulance arrivals, waiting room times, and patients leaving without being seen. The study's authors concluded that their findings suggested “that health care cyberattacks such as ransomware are associated with greater disruptions to regional hospitals and should be treated as disasters, necessitating coordinated planning and response efforts.” \ [155\]
Thus, implementing reasonable and appropriate security measures better protects not only the regulated entity and its ePHI, but other regulated entities with whom it interacts, and may reduce the effects of cyberattacks and other security incidents that adversely affect the confidentiality, integrity, or availability of ePHI.
As discussed above, several industry organizations have published and maintained compilations of voluntary standards, guidelines, best practices, methodologies, procedures, and processes for protecting the security of sensitive and confidential information, including PHI. Additionally, certain Federal health programs now either require or recommend the adoption of specific criteria that are intended to protect the confidentiality, integrity, and availability of ePHI. For example, the Health IT Certification Program maintained by the Assistant Secretary for Technology Policy and Office of the National Coordinator for Health Information Technology (ASTP/ONC) \ [156\]
sets minimum requirements for certified health IT, including criteria that pertain to cybersecurity.\ [157\]
These criteria are included in the Health IT Certification Program's Health IT Privacy and Security Framework,\ [158\]
which identifies
_when technical capabilities to support_
the privacy and security of electronic health information \ [159\]
must be included in certified health IT products. Additionally, health care providers that participate in certain Federal health programs must use health IT certified to these requirements.\ [160\]
Regulated entities also may want to consider adoption of certified health IT because it could contribute to compliance with the Security Rule. We will continue to work across the Department to ensure the adoption of consistent requirements for Federal programs that support the secure electronic exchange of health information to the extent that such consistency is appropriate. Throughout this preamble, we provide examples of how a regulated entity's participation in other Federal programs that require the use of health IT certified through the ONC Health IT Certification Program, or adoption of other Federal recommendations, such as the HHS CPGs, might support their compliance with the proposals in this NPRM.
Additionally, as discussed above, several organizations have published and maintained compilations of voluntary standards, guidelines, best practices, methodologies, procedures, and processes for protecting the security of sensitive and confidential information, including PHI. These compilations and the State regulations discussed above range from granular \ [161\]
to high-level \ [162\]
and from health care-specific \ [163\]
to industry agnostic.\ [164\]
Despite these differences, these compilations and regulations have a great deal in common with each other—and with the Security Rule, its longevity notwithstanding. In fact, the foundational elements of the Security Rule, promulgated more than 20 years ago, can still be found in cybersecurity compilations published today. They generally either require or recommend administrative, physical, and technical safeguards to identify and mitigate risks and vulnerabilities, implement authentication and access controls, conduct security awareness and training for information system users, and plan for contingencies and incident response.\ [165\]
Additionally, these compilations all require or recommend the designation of a specific individual who is accountable for implementing the requirements or recommendations. And, importantly, they all ultimately address how to maintain the
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confidentiality, integrity, and availability of sensitive and confidential information, including ePHI.
A major distinguishing factor between the content of the Security Rule and these compilations and regulations is the Security Rule's scope. The compilations and regulations are designed to protect various types of data and information systems broadly. In comparison, a defining quality of the Security Rule's requirements is that they focus specifically on the protection of ePHI and the information systems that create, receive, maintain, or transmit ePHI. Thus, while the foundational elements of various cybersecurity compilations and State regulations and the Security Rule may be the same, the Security Rule alone addresses the application of those elements to ePHI and all of the components of information systems that create, receive, maintain, or transmit ePHI. Thus, while the standards of the Security Rule generally align with those of other cybersecurity standards, frameworks, best practices, guidelines, processes, and procedures, the specific implementation specifications of the Security Rule reflect the particular sensitivities of the health care industry, particularly small and rural health care providers, in a way that is necessary to ultimately improve the efficiency and effectiveness of the health care system and avoid imposing unreasonable compliance burdens on regulated entities.
### B. The Health Care Environment Has Changed Since the Security Rule Was Last Revised and Will Continue To Evolve
The health care sector has undergone a dramatic transformation over the last 24 years, and particularly in the past 10 years, spurred at least in part by the Department's implementation of HIPAA, the HITECH Act, and the Cures Act. The industry has shifted from one that generally relied upon a system of paper-based recordkeeping and siloed devices to one that depends on interconnected information systems to maintain and exchange patient records, conduct research, run health care provider facility management systems, and provide patient care.\ [166\]
This shift is largely the result of HIPAA's emphasis on the development and use of standards and the EHR incentive funds made available under the HITECH Act for health care providers.\ [167\]
Data from ASTP/ONC offer clear and convincing evidence of this shift. In 2008, before the enactment of the HITECH Act, less than 10 percent of non-Federal acute hospitals had implemented what was referred to at the time as a “Basic EHR” (
_i.e.,_
an electronic health record).\ [168\]
By 2015, six years after the enactment of the HITECH Act, almost 84 percent had adopted a Basic EHR while 96 percent had adopted a certified EHR.\ [169\]
The transformation was further enabled by the Cures Act, which encouraged the development of a trusted exchange framework for the nationwide exchange of health information and provided penalties for health care providers, health information exchanges and networks, and developers of certified health IT that engage in information blocking.\ [170\]
In 2014, 41 percent of such hospitals routinely had electronic access to clinical information from outside providers or sources when treating a patient.\ [171\]
By 2023, 70 percent of non-Federal acute care hospitals engaged in all domains of interoperable exchange routinely or sometimes, a significant leap forward.\ [172\]
In 2017, only 38 percent of hospitals enabled patients to access their health information using an application and in 2018, 57 percent enabled patient access to their clinical notes in their patient portal; by 2021, 70 percent of hospitals enabled patients to access their health information using an application and 82 percent enabled patients to view their clinical notes in their patient portal.\ [173\]
And just a year later, the percentage of hospitals that supported patient access through applications increased to 86 percent.\ [174\]
Based on this data, it is clear that HIPAA, coupled with the HITECH Act and the Cures Act, has successfully encouraged the development of a nationwide electronic health information system.
Not only is PHI increasingly maintained and transmitted electronically, but treatment is also increasingly provided electronically. The coronavirus disease 2019 (COVID-19) pandemic led to a dramatic increase in the use of telemedicine.\ [175\]
According
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to ONC data, only 15 percent of office-based physicians used any form of telemedicine in 2018-19. In 2021, telemedicine usage increased to 87 percent.\ [176\]
The electronic content generated or transmitted during a telemedicine visit constitutes ePHI, so the increase in telemedicine further increases the amount of PHI that is also ePHI.
It is not only the ePHI maintained in EHRs and other electronic recordkeeping systems that faces security risks. Medical equipment and devices are increasingly connected through one or more networks, which means that any issues affecting the network likely will affect the medical equipment and devices.\ [177\]
And some medical equipment and devices rely on off-the-shelf operating systems, such as Windows, Linux, and similar third-party software; \ [178\]
thus, the medical equipment and devices can experience the same vulnerabilities as personal computing devices. Generally, the U.S. Food & Drug Administration (FDA) does not need to review software patches or configuration updates for off-the-shelf software before a device manufacturer puts them in place because the FDA views most patches and configuration updates as design changes that can be made without prior discussion.\ [179\]
Cybercriminals may use—or target—technology assets, such as software or medical devices used for treating individuals. For example, in 2021, a cyberattack on cloud-based systems supplied by a particular company compromised the ePHI of more than 200,000 individuals and affected the software for linear accelerators used in radiotherapy, leading to disruptions to cancer treatment.\ [180\]
Thus, to protect technology assets used for treatment, the information systems that create, receive, maintain, and transmit ePHI also must be protected. As another example, in 2013, the Mayo Clinic \ [181\]
hired a group of ethical hackers \ [182\]
to identify vulnerabilities in 40 different medical devices.\ [183\]
The hackers were able to gain access to all of the devices, meaning that the devices could all be vulnerable to a cyberattack.\ [184\]
Such attacks may create an opening for a subsequent attack on the device itself or on the regulated entity's information systems that create, receive, maintain, or transmit ePHI, compromising those information systems and the ePHI itself.\ [185\]
It also may lead, intentionally or not, to a loss of device integrity, which could result in the corruption of the device's functionality or the ePHI on the device.\ [186\]
A cyberattack on a medical device may also reduce the ability of the authorized person to use the device (
_e.g.,_
a denial of service attack, which is a type of cyberattack that overloads the device by flooding the network with traffic).\ [187\]
Depending on the device and its use, the result of cyberattacks on a medical device could range from little or no effect to serious injury or death.\ [188\]
According to researchers at Brown University, medical devices are a prime target for cybercriminals. In fact, they believe, “More than just technically feasible, the widespread takedown of medical devices is an imminent threat.” \ [189\]
A 2023 Government Accountability Office report on medical device cybersecurity described the importance of “robust cybersecurity controls to ensure medical device safety and effectiveness” because of “the increasing integration of wireless, internet- and network-connected capabilities, and the electronic exchange of health information.” \ [190\]
The FDA has also acknowledged, “As electronic medical devices become increasingly connected to each other and to other technologies, the ability of connected systems to safely, securely and effectively exchange and use the information becomes critical. \[. . .\] Cybersecurity concerns rise along with the increasing medical device interoperability.” \ [191\]
Accordingly, in 2023, the FDA issued updated guidance for industry and FDA staff on requirements for cybersecurity in medical devices.\ [192\]
And then there are digital health applications. When an application is deployed by a covered entity, an application developer may be a business associate and subject to the Security Rule. An application developer may also meet the HIPAA Rules' definition of “health care provider” \ [193\]
and be a covered entity.\ [194\]
But also, individuals are increasingly interested in accessing their ePHI using applications and transmitting information collected by health and wellness applications to
( printed page 912)
their health care providers.\ [195\]
Such applications may empower individuals to better manage their health and participate in their health care and provide health care providers and researchers with a more holistic view of the individual's health at a particular point in time and over an extended period of time.\ [196\]
This technology, while valuable for understanding an individual's overall health, introduces another potential vulnerability to the security of ePHI and the information systems that create, receive, maintain, or transmit it.
EHRs, networked medical devices, and applications are only the beginning. Artificial intelligence (AI) in health care, particularly for diagnosis and treatment, is in the nascent stages of development, but many are eager to test its promise.\ [197\]
After all, many experts believe that AI promises opportunities to improve patient care, outcomes, and population health, as well as to reduce costs.\ [198\]
The use of AI in health care is increasing and is expected to continue to increase.\ [199\]
A 2023 Healthcare Information and Management Systems Society (HIMSS) survey of health care cybersecurity professionals reported that approximately 50 percent of respondents' organizations permitted the use of generative AI technology.\ [200\]
And other new technologies are expected shortly, as discussed below. For example, according to reports, quantum computing may be available in the near future, which may have ramifications for data privacy and security.\ [201\]
We also know that researchers are exploring methods for storing ePHI in biological material (
_e.g.,_
DNA).\ [202\]
While the promise of these new technologies is exciting, they come with increased risks and vulnerabilities to ePHI and the information systems that create, receive, maintain, or transmit it. As noted by Executive Order (E.O.) 14110, “\[AI\] must be safe and secure. Meeting this goal requires \[. . .\] addressing AI systems' most pressing security risks—including with respect to biotechnology, cybersecurity, critical infrastructure, and other national security dangers—while navigating AI's opacity and complexity.” \ [203\]
For these reasons, the E.O. required the Secretary of HHS, in consultation with the Secretary of Defense and the Secretary of Veterans Affairs, to establish an HHS AI Task Force to develop a strategic plan that includes policies and frameworks on responsible deployment and use of AI and AI-enabled technologies in the health and human services sector, including the incorporation of safety, privacy, and security standards into the software-development lifecycle for the protection of personally identifiable information, such as measures to address AI-enhanced cybersecurity threats in the health and human services sector.\ [204\]
The Department has taken a number of actions to address the use of AI in health care, including establishing an AI Council, appointing a Chief AI Officer,\ [205\]
and taking steps to regulate the use of AI in health care.\ [206\]
Accordingly, regulated entities must be prepared to identify, mitigate, and remediate such risks and vulnerabilities.
While the health care industry has generally shifted from paper record-keeping and non-interoperable electronic devices to an interconnected electronic health care system, it has led to an increasing vulnerability to breaches of unsecured PHI resulting from unauthorized uses and disclosures and cyberattacks. According to an article published by the American Hospital Association Center for Health Innovation, “Health care organizations are particularly vulnerable and targeted by cyberattacks because they possess so much information of high monetary and intelligence value to cyber thieves and nation-state actors.” \ [207\]
In fact, “\[. . .\] on the dark web, PHI is deemed more
( printed page 913)
valuable than credit card data, enabling cybercriminals to extract as much as \[$1,000\] per stolen medical record.” \ [208\]
Before this shift to an interconnected electronic system, lost or misplaced paper records or even a laptop could lead to a breach of unsecured PHI affecting hundreds or thousands of individuals.\ [209\]
While a breach of that size remains significant, unauthorized access to a single workstation today could lead to a breach that affects millions of individuals because of the increase in interconnectivity.\ [210\]
Between 2018 and 2023, the number of breaches of unsecured PHI reported to the Department grew at an alarming rate (100 percent increase), as did the number of individuals affected by such breaches (950 percent increase).\ [211\]
The reports reflect rampant escalation of cyberattacks using hacking (260 percent increase) and ransomware (264 percent increase).\ [212\]
Based on reports made to OCR, in 2022, approximately three-fourths of the breaches of unsecured PHI affecting 500 or more individuals were the result of hacking of electronic equipment or a network server.\ [213\]
In 2023, over 160 million individuals were affected by breaches involving the PHI of 500 or more individuals—a new record. We anticipate that 2024 will surpass that record, particularly in light of the estimate provided by a large covered entity regarding the number of individuals affected by a breach of its subsidiary.\ [214\]
In 2023, the Federal Bureau of Investigation's internet Crime Complaint Center received almost 250 reports of ransomware affecting the Healthcare and Public Health sector, the most of any of the 16 identified infrastructure sectors.\ [215\]
The Healthcare and Public Health sector has been the most targeted critical infrastructure sector since at least as far back as 2015.\ [216\]
Between 2015 and 2019, cyberattacks on health care organizations increased by 125 percent.\ [217\]
And between 2022 and 2023, ransomware attacks against the U.S. health care sector increased 128 percent.\ [218\]
Many people, including regulated entities, inaccurately believe that only large regulated entities that maintain electronic records about millions of individuals are likely to face a cyberattack, and thus that it is less important for smaller regulated entities to invest resources in cybersecurity.\ [219\]
In fact, smaller regulated entities may also be the target of, or adversely affected by, cybercrime, partly because of the interconnectedness of health care and partly because they are less likely to have invested in cybersecurity, making them easier targets.\ [220\]
As explained in a recent national security memorandum, cybercriminals are targeting critical infrastructure (
_i.e.,_
the physical and virtual assets and systems so vital to the Nation that their incapacity or destruction would have a debilitating impact on national security, national economic security, or national public health or safety), and their activities may be tolerated or enabled by other countries.\ [221\]
Thus, it is essential that the Department and regulated entities take steps to safeguard health care infrastructure and ePHI.
External actors are not the only, or even the greatest, threat to the security of ePHI. According to a recent study, insiders were the second leading cause of breaches in the health care sector in 2023, exceeded only by “miscellaneous errors,” such as misdelivery.\ [222\]
For example, a recent settlement resolved an OCR investigation involving the theft and sale of the ePHI of more than 12,000 patients by an employee of a large health care system.\ [223\]
In another example, security guards at a large health care provider were alleged to have used their login credentials to inappropriately access ePHI.\ [224\]
Thus, it is critical that regulated entities improve their cybersecurity posture to protect not only against external threats but also
( printed page 914)
internal ones, and both intentional and accidental breaches.
Emergencies or other occurrences can affect the security of ePHI without an intentional act. For example, in 2024, CrowdStrike released a defective update for its software on computers running Microsoft Windows.\ [225\]
This update affected the ability of regulated entities to access the ePHI of millions of individuals for varying periods of time. During this time, ePHI was unavailable, meaning that one of the key prongs of the security triad of confidentiality, integrity, and availability was affected.\ [226\]
Because of the increased digitization of PHI, it is, for example, essential that covered health care providers engage in thoughtful contingency planning that considers how they will proceed in the event that they are unable to access ePHI in their EHRs. Additionally, threat actors will often seek to take advantage of such incidents. As reported by a large subcontractor of a business associate, less than a week after the outage, the company “observed threat actors leveraging the event to distribute” ransomware.\ [227\]
The environment in which health care is delivered, the way in which it is delivered, and the manner in which related information is collected all mean that regulated entities must consider a different approach to operational continuity and resiliency in the face of such challenges. Additionally, they must be wary of the potential for bad actors to attempt to take advantage of such events.
### C. Regulated Entities' Compliance With the Requirements of the Security Rule Is Inconsistent
Despite the proliferation of cybersecurity standards, guidelines, best practices, methodologies, procedures, and processes and the documented increase in unauthorized uses and disclosures of ePHI, many regulated entities have been slow to strengthen their security measures to protect ePHI and their information systems that create, receive, maintain, or transmit it in this new environment.\ [228\]
Among the reasons for this are the rapid pace of EHR adoption and digitization of health care, increased connectivity and use of cloud-based infrastructures, limited competition and a stable customer base, limited operating margins, and a failure to invest in cybersecurity infrastructure.\ [229\]
For example, regulated entities continue to rely on legacy systems and software that are unsupported by manufacturers, which means that the manufacturers no longer provide security patches or other updates to address security threats and vulnerabilities.\ [230\]
In a 2021 survey of health care cybersecurity professionals, 73 percent reported having legacy operating systems.\ [231\]
This apparent lack of urgency in adopting new, supported operating systems has serious implications for the confidentiality, integrity, and availability of ePHI.
In addition, many regulated entities fail to invest adequate resources in cybersecurity. Far too many regulated entities do not view cybersecurity as a necessary component of their operations that allows them to fulfill their health care missions. Anecdotal evidence suggests that senior management often lacks awareness of cybersecurity, including both threats and methods for protecting against such threats.\ [232\]
“A lack of maturity and effectiveness of the \[information technology\] function is evident when healthcare organizations fail to maintain a current inventory of sensitive and valuable data and where those reside.” \ [233\]
While maintaining an accurate and thorough inventory of technology assets is not currently an explicit requirement of the Security Rule, it is clearly a fundamental component of conducting a risk analysis and many of the other existing requirements.\ [234\]
And yet, based on the Department's experience, many regulated entities are not maintaining such an inventory. At least in part because of senior management's lack of cybersecurity awareness, many fail to invest or fail to invest appropriately in cybersecurity infrastructure.\ [235\]
Given the vulnerability of ePHI and the information systems of regulated entities and the potential effects of cyberattacks on patient safety and the delivery of health care, it is important that regulated entities prioritize such investments.\ [236\]
The security of ePHI also is at risk because, despite our explanation of the Security Rule's structure in 2003,\ [237\]
regulated entities are not fully complying with the standards and implementation specifications. From 2016 to 2017, the Department conducted audits of 166 covered entities and 41 business associates regarding compliance with selected provisions of the HIPAA Rules, including the required implementation specifications for risk analysis \ [238\]
and risk management.\ [239\]
The Department found that most regulated entities failed to implement the Security Rule requirements for risk analysis and risk management, requirements that are fundamental to protecting the confidentiality, integrity, and availability of ePHI.\ [240\]
While most of the audited business associates reported not having experienced any breaches of unsecured PHI, we found that those that
( printed page 915)
had experienced a breach generally engaged in minimal or negligible efforts to address the risk analysis and risk management requirements.\ [241\]
According to the report, at that time only 14 percent of covered entities and 17 percent of business associates were “substantially fulfilling their regulatory responsibilities to safeguard ePHI they \[held\] through risk analysis activities,” \ [242\]
while 94 percent of covered entities and 88 percent of business associates “failed to implement appropriate risk management activities sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level.” \ [243\]
The report specifically noted that the audit results were consistent with the findings of OCR's compliance reviews and complaint investigations.\ [244\]
Recent enforcement actions provide evidence that the results of the 2016-2017 audits were not isolated cases. In 2023, OCR entered into seven resolution agreements with regulated entities after investigations indicated that they had potentially violated the Security Rule, constituting almost half of the total resolution agreements OCR entered into that year.\ [245\]
In each case, OCR's investigation found evidence of multiple potential violations. For example, in one case, a regulated entity did not detect an intrusion into its network until 20 months later when its files were encrypted with ransomware.\ [246\]
OCR's investigation found evidence of potential failures of the regulated entity to conduct a risk analysis or to sufficiently monitor information system activity. OCR also found evidence that the regulated entity may not have had policies and procedures in place to implement the requirements of the Security Rule to protect the confidentiality, integrity, and availability of ePHI.\ [247\]
As another example, an OCR investigation of a large health care system found indications of multiple potential violations of the Security Rule, including failures by the regulated entity to conduct a risk analysis, monitor and safeguard its electronic information systems, and implement policies and procedures to record and examine activity in its electronic information systems containing ePHI.\ [248\]
The regulated entity was not only unable to prevent the cyberattack, but it was unaware the attack had occurred until two years later. This is despite the long-standing requirements of the Security Rule and the obligations imposed on regulated entities for risk analysis and risk management.
Despite the long-standing nature of the Security Rule and the proliferation of guidance documents from NIST, the Department, CISA, FTC, and others, regulated entities continue to fail to implement reasonable and appropriate security measures as required by the Security Rule.\ [249\]
For example, the Security Rule and NIST guidance have addressed encryption for data in transit and at rest for many years.\ [250\]
And yet, in the 2021 survey of health care cybersecurity professionals, only half of the respondents reported having implemented encryption for data in transit across the enterprise.\ [251\]
Similarly, according to its CEO, a large covered entity failed to deploy multi-factor authentication (MFA) throughout its enterprise and experienced a significant breach.\ [252\]
If this is accurate, it would run counter to long-standing provisions in both the Security Rule and NIST guidance; the Security Rule has required the implementation of appropriate access controls since 2003 and NIST recommends similar controls.\ [253\]
As another example, based on OCR's investigation experience, some regulated entities are not developing and implementing compliant response plans for security incidents, including those that are breaches of unsecured ePHI under the Breach Notification Rule. Section 164.308(a)(6)(i) establishes the standard that requires regulated entities to implement policies and procedures to address security incidents, while 45 CFR 164.308(a)(6)(ii)(6)(ii)) includes the implementation specifications for that standard. This requirement, included in the 2003 Final Rule, aligns with the NIST Cybersecurity Framework version 2.0 requirement for incident management.\ [254\]
Similarly, NIST Cybersecurity Framework version 1.1 recommended the execution and maintenance of response processes and procedures to ensure response to detected cybersecurity incidents.\ [255\]
And yet, when OCR investigates the circumstances surrounding breach reports, OCR continues to find evidence that regulated entities have not implemented policies and procedures to detect and respond to security incidents, leading to significant time lapses between a “successful” security incident \ [256\]
and discovery of, and response to, the security incident.\ [257\]
Thus, based on the OCR's experience investigating and enforcing the Security Rule, the Department believes that many regulated entities would benefit from additional instruction in regulatory text regarding their compliance obligations to determine how to select security
( printed page 916)
measures that are reasonable and appropriate for their circumstances.
We are also concerned that recent caselaw has not accurately set forth the steps regulated entities must take to adequately protect the confidentiality, integrity, and availability of ePHI, as required by the statute. Specifically, in the
_University of Texas M.D. Anderson Cancer Center_
_M.D. Anderson_
”), the U.S. Court of Appeals for the Fifth Circuit held, among other things, that the Security Rule does not say anything about how effective a mechanism for encryption must be, nor does it require that an encryption mechanism provide “bulletproof protection” of all systems containing ePHI.\ [258\]
Thus, under the court's interpretation, a regulated entity can meet its obligations under the Security Rule concerning encryption and decryption of ePHI by implementing a mechanism to do so, without regard for the effectiveness of the implementation.\ [259\]
Additionally, the court noted that the requirement for “a mechanism” does not “prohibit a \[regulated\] entity from creating \`a mechanism' by directing employees to sign an \[agreement\] that requires the encryption of portable devices.” \ [260\]
While the Department disagrees with the court's interpretation that merely requiring employees to sign an agreement to encrypt portable devices is sufficient to comply with its Security Rule obligations to implement a mechanism to encrypt and decrypt ePHI, the Department believes that additional clarity is warranted to ensure that regulated entities understand their obligation to have encryption mechanisms in place and deployed throughout the regulated entity's enterprise to ensure the confidentiality, integrity, and availability of ePHI.
Several technical safeguards currently require regulated entities to implement a “mechanism” as part of complying with the associated standard. Given that written policies and procedures alone are insufficient to protect ePHI, and the misinterpretation of what it means to implement a mechanism also could lead to inadequate protection of ePHI, the Department believes that the Security Rule must be revised, consistent with its statutory mandate, as discussed in greater detail above.
### D. It Is Reasonable and Appropriate To Strengthen the Security Rule To Address the Changes in the Health Care Environment and Clarify the Compliance Obligations of Regulated Entities
#### 1\. Congress and the Department Anticipated That Security Standards Safeguards Would Evolve To Address Changes in the Health Care Environment
By requiring that regulated entities maintain reasonable and appropriate safeguards to protect against reasonably anticipated threats or hazards or unauthorized uses or disclosures of ePHI, Congress clearly anticipated that the administrative, physical, and technical safeguards implemented to protect the security of ePHI would need to change in response to changes in the environment in which health care is provided.\ [261\]
As the health care environment and the operations of regulated entities evolve, so must the protections for ePHI and the information systems used to create, receive, maintain, or transmit it. For example, regulated entities must be expected to adopt safeguards that address new risks to the security of ePHI, such as those posed by maintaining ePHI in the cloud; the connection of medical devices and other technology to networks; and the connection of information systems used to create, receive, maintain, or transmit ePHI to the same networks as those do not perform such activities. After all, it is reasonable to anticipate that there will be new threats or hazards to ePHI or efforts by unauthorized persons to use or disclose such ePHI in an increasingly connected environment.
By design, the Security Rule sets a national floor for the security measures that regulated entities are required to implement to protect the confidentiality, integrity, and availability of ePHI. In 2003, the Department opted to frame the standards in terms that were as generic as possible and in a manner that enabled the standards to be met through various approaches or technologies to ensure that regulated entities had the flexibility to determine how best to protect the confidentiality, integrity, and availability of ePHI based on their specific circumstances.\ [262\]
When we extended the Security Rule in 2013 to directly apply to business associates in accordance with the HITECH Act,\ [263\]
the Department acknowledged that some business associates might not have engaged in the formal administrative safeguards required by the Security Rule, and we made it clear that business associates would be expected to do so going forward.\ [264\]
Despite the changes in the health care environment between 2003 and 2013, the Department made minimal changes to the Security Rule at that time because we believed that the compliance obligations of regulated entities were clear and well-understood. In fact, when a commenter recommended that the Department remove the “addressable” designation from the Security Rule because it leads to ambiguity in the rule's application, we declined to do so at that time because we were concerned that it would reduce the rule's scalability and flexibility.\ [265\]
However, as we noted in 2003, the rule's flexibility of approach is primarily provided for in paragraph (b)(2) of 45 CFR 164.306(2)) and in the standards themselves.\ [266\]
The addressability feature merely provided an added level of flexibility \ [267\]
in a way that the Department now believes is inadequate to ensure that regulated entities implement reasonable and appropriate security safeguards.
Changes to the health care environment and the operations of regulated entities have increased the importance of implementing strong security measures to protect ePHI and the information systems that create, receive, maintain, or transmit it. While we recognize the burdens posed by such implementation on regulated entities, there is also a clearly documented increase in the number of breaches of unsecured PHI and instances of cybercriminals accessing ePHI without authorization at regulated entities. The changes to the health care environment, including the increase in breaches and cyberattacks, and operations of regulated entities have made it increasingly likely that unauthorized persons will seek to obtain ePHI and disrupt the U.S. health care system. Additionally, the clearly documented failure of regulated entities to fully implement the policies and procedures required by the Security Rule and apply the required security measures throughout their operations has caused the Department to question whether the existing Security Rule should be revised to clarify and strengthen the obligations of regulated entities and revisit our
( printed page 917)
decision from 2013.\ [268\]
In many cases involving a breach of ePHI that OCR has investigated, a breach may not have occurred, or would have been less widespread and disruptive, had the regulated entities fully implemented the provisions of the Security Rule.\ [269\]
#### 2\. NCVHS Believes That the Security Standards Evolve To Address Changes in the Health Care Environment
The Department is not alone in believing that the Security Rule should be strengthened to address concerns about whether -regulated entities are sufficiently protecting the confidentiality, integrity, and availability of ePHI. An inquiry conducted by NCVHS between July 2021 and September 2023 reached the same conclusion.\ [270\]
During this inquiry, NCVHS listened to the testimony of cybersecurity experts and Department officials. The experts and Department officials “consistently voiced their concerns about the major increase in incidents and, in particular, the widespread lack of robust risk analysis on the part of covered entities and business associates that would lead to prior planning for, and mitigation of, a range of cybersecurity threats.” \ [271\]
In response to this inquiry and consistent with their statutory mandate,\ [272\]
NCVHS transmitted two letters to the Secretary with recommendations for improving cybersecurity practices in the health care industry, including recommendations for modifying the Security Rule.\ [273\]
As part of the explanation for its concerns, NCVHS cited a 2021 survey of acute and ambulatory care organizations that found only 32 percent of those organizations had a comprehensive security program, while only 26 percent of the long-term and post-acute care facilities met the minimum security requirements.\ [274\]
Specifically, NCVHS made the following recommendations for improvements to the Security Rule:
- Eliminate from the addressable implementation specifications the choice not to implement a specification or alternative, and instead require regulated entities to implement the specification or adopt a documented reasonable alternative.\ [275\]
- Include specific minimum cybersecurity hygiene requirements that are reflective of modern industry best practices, including designation of a qualified information security official, elimination of default passwords, adoption of MFA, institution of offline backups, installation of critical patches within a reasonable time, and transparency of impact and vulnerability disclosures.\ [276\]
- Require that regulated entities implement a security program and that they implement standard minimum security controls.\ [277\]
- Require that regulated entities adopt a risk-based approach in their security program.\ [278\]
- Require that regulated entities perform a risk analysis in a manner that conforms with guidance from NIST and CISA.\ [279\]
- Define compensating controls more specifically and provide a wider range of examples that apply to a greater variety of types of entities.\ [280\]
- Reinforce the need for regulated entities to account for AI systems and data within their risk analysis for all and any new technology.\ [281\]
- Establish a consistent floor for cyber incident reporting and harmonize such requirements with incident reporting provisions applicable to health care critical infrastructure actors and health care Federal contractors.\ [282\]
The Department, in drafting this NPRM, relied on the recommendations of NCVHS, OCR's enforcement experience, news reports, and our assessment of the environment. Consistent with NCVHS' recommendation to revisit the Security Rule's classification of some implementation specifications as “addressable,” the Department also believes that it is appropriate to revisit our decision regarding the amount of flexibility regulated entities have in determining reasonable and appropriate safeguards, as described above. Based on OCR's experience in investigations and audits, we believe that regulated entities would benefit from greater specificity in the Security Rule. The Department has provided extensive guidance on questions to consider when adopting and implementing security measures and ways to comply with the Security Rule,\ [283\]
as directed by the HITECH Act. And yet, despite this proliferation of guidance, regulated entities continue not to comply. For example, despite the explanation in 45 CFR 164.306(d)) about addressable implementation specifications and the notable changes in the environment in which health care is provided, we are concerned that some regulated entities proceed as if compliance with an addressable implementation specification is optional—and that where there is an addressable implementation specification, that compliance with the relevant standard is also optional. That interpretation is incorrect and weakens the cybersecurity posture of regulated entities. We believe that compliance with the implementation specifications currently designated as addressable is not—and should not be—optional, particularly in light of the shift to an interconnected and cloud-based environment and a significant increase in the number of breaches of unsecured PHI from both internal and external actors, regardless of the regulated entity's specific circumstances. Thus, we believe that it is necessary to strengthen the Security Rule to reflect the changes in the health care environment and the evolution of
( printed page 918)
technology and to underscore that compliance with all of our proposals, if finalized, is required.
#### 3\. A Strengthened Security Rule Would Continue To Be Flexible and Scalable While Providing Regulated Entities With Greater Clarity
The Security Rule's fundamental flexibility and scalability generally would remain should the proposals in this NPRM be adopted. However, we are proposing to reduce that flexibility to better strengthen protections and address the changed nature of the environment in which health care is provided. The Department is also proposing in this NPRM to strengthen the Security Rule by providing greater clarity regarding the nature of its flexibility and scalability and the Department's expectations, as requested by regulated entities and other stakeholders. In fact, in response to a request for information published in 2022,\ [284\]
several commenters urged the Department to propose regulations that establish a single set of clear standards for regulated entities, raise the floor for security requirements and expectations, and encourage regulated entities to safeguard ePHI while maintaining flexibility and scalability. Commenters also encouraged the Department to rely on commonly available, non-proprietary frameworks that allow regulated entities to adopt critical security measures. We believe that our proposals are consistent with those recommendations.
Under the proposal, regulated entities would retain the ability to determine the security measures that are reasonable and appropriate to fulfill the required standards and implementation specifications, taking into consideration the factors listed at proposed 45 CFR 164.306(b)(2)(2)). In fact, the NPRM, if adopted as proposed, would add to the rule's flexibility and scalability by adding a new factor for regulated entities to consider when determining the reasonable and appropriate security measures.\ [285\]
Additionally, if modifications are adopted as proposed, the Security Rule would remain flexible and scalable by retaining broad standards with which regulated entities could comply in a variety of ways. In 2003, the 13 implementation specifications that the Security Rule requires were considered so basic that no covered entity could effectively protect ePHI without implementing them.\ [286\]
While the Department agrees that these implementation specifications remain essential, we no longer believe that they are sufficient to address the risks to ePHI today. Rather, regulated entities must do more to ensure the confidentiality, integrity, and availability of ePHI today because of the changes in the environment in which health care is provided, how ePHI is maintained, the level of connectivity between information systems, and the technological sophistication of bad actors.
We acknowledged in 2003 and again acknowledge here that “there is no such thing as a totally secure system that carries no risks to security.” \ [287\]
We posited at that time that Congress intended to set an “exceptionally high goal for the security of \[ePHI\],” while also recognizing that securing ePHI did not require that covered entities do so without regard for the cost.\ [288\]
However, we also made clear that a covered entity is required to implement adequate security measures and that cost was but one factor for a covered entity to consider when determining what constituted appropriate security measures.\ [289\]
As we noted, “Cost is not meant to free covered entities from this responsibility.” \ [290\]
In the 2013 Omnibus Rule, we further explained that “\[regulated entities\] have the flexibility to choose security measures appropriate for their size, resources, and the nature of the security risks they face, enabling them to reasonably implement any given Security Rule standard. \[. . .\] Thus, the costs of implementing for \[. . .\] business associates will be proportional to their size and resources.” \ [291\]
We continue to believe that this is the case. Additionally, as discussed above, there is a significant cost associated with breaches and unauthorized access—financial, reputational (for both the individual and the regulated entity), and more. Thus, we believe that the standards and implementation specifications that we propose in this NPRM are the minimum that regulated entities should be doing to protect the security of ePHI and lower the costs associated with breaches and other incidents.
#### 4\. Small and Rural Health Care Providers Must Implement Strong Security Measures To Provide Efficient and Effective Health Care
The statute requires that we consider the “needs and capabilities of small health care providers and rural health care providers (as such providers are defined by the Secretary).” \ [292\]
We recognize that small and rural health care providers may have needs and capabilities that differ from those of other regulated entities. For example, small health care providers and rural health care providers are often located at a greater distance from other health care providers.\ [293\]
It may be more challenging for them to attract and retain clinicians and administrative support staff.\ [294\]
They also face difficulty attracting and retaining security experts and must make difficult decisions regarding investments in competing priorities.\ [295\]
Often, preparation for security incidents or other occurrences that adversely affect the confidentiality, integrity, or availability of ePHI is neglected in favor of other priorities, putting small and rural health care providers at greater risk for such an occurrence.\ [296\]
We continue to believe that it is just as important for small and rural health care providers to implement strong security measures as it is for larger health care providers and other categories of regulated entities. According to experts, “Cybercriminals go after small businesses, especially those in the healthcare industry,
( printed page 919)
because they are easy targets.” \ [297\]
In 2017, 93 percent of small rural and critical access hospitals and 86 percent of physician offices relied on health IT to inform their clinical practice.\ [298\]
And yet, small health care providers are less likely than a larger organization to even have a designated security or compliance officer.\ [299\]
Smaller practices and rural and community facilities also may be more likely to rely on older technologies that are no longer supported by security patches and updates, including medical devices such as insulin pumps and pacemakers in which inaccuracies or errors could affect patient safety.\ [300\]
Thus, small health care providers “are at the greatest risk of a breach. \[. . .\] Smaller, rural practice settings are especially high-risk target areas for a breach.” \ [301\]
According to an expert who speaks to and works with health care providers on IT services and cybersecurity, small health care providers are “more susceptible because they do not have a lot of the tools and security measures necessary to protect themselves.” \ [302\]
For example, a critical access hospital in Colorado recovered from a cyberattack in 2019, but it required “an incredible amount of staff time, many months of recovery efforts, and an enormous financial outlay to restore systems and prevent another attack.” \ [303\]
In fact, the hospital estimates that “it took a full year of a staff person's time to complete the recovery and protect the organization for the future.” \ [304\]
These costs do not include the multiple ransoms paid to the attackers after the first set of keys did not unlock all of the data.\ [305\]
Patients and communities have a critical need for health care providers, including rural hospitals and other rural health care providers, to be resilient and remain operational, which depends in part on the cybersecurity of their electronic information systems. For rural health care providers, especially hospitals, a breach can significantly affect an entire community.\ [306\]
Rural health care providers often are separated by significant distances, which can have real consequences for someone experiencing a medical emergency.\ [307\]
A recent study comparing hospital characteristics and operations of rural and urban hospitals that experienced ransomware attacks between 2016 and 2021 found that rural hospitals experienced large declines in inpatient admissions and Medicare revenue, similar to those experienced by urban hospitals.\ [308\]
The study also found that the decline in volume and revenue of hospital outpatient and emergency room visits was more pronounced among rural facilities.\ [309\]
In fact, in June 2023, a hospital in rural Illinois announced that it would close, in part because a 2021 cyberattack prevented it from submitting claims to health plans for months.\ [310\]
According to a local elected official, the hospital's closure would require some residents to travel approximately 30 minutes for the nearest emergency room and obstetrics services.\ [311\]
Thus, implementing security measures to maintain facility operations is critical to minimize or avoid disruptions to patient care and patient safety activities in such facilities. Consistent with these examples, the Department believes that small and rural health care providers are also viewed as potential targets by cybercriminals, and such providers need to implement strong cybersecurity measures to secure the ePHI in their possession. In fact, in June 2024, the Administration announced a collaboration with the private sector to provide additional cybersecurity resources for rural health care providers in recognition of the importance of protecting the security of ePHI created, received, maintained, or transmitted by such entities.\ [312\]
We believe this collaboration will provide small and rural health care providers with additional support, particularly when coupled with other resources described in greater detail below.\ [313\]
Thus, we believe that small and rural health care providers have both the need to comply with the proposals in this NPRM and the capability of doing so. Additionally, we believe that the NPRM would continue to provide all regulated entities, including small and rural health care providers, the ability to take into account their circumstances when determining which security measures are reasonable and appropriate.\ [314\]
#### 5\. A Strengthened Security Rule Is Critical to an Efficient and Effective Health Care System
While the Security Rule generally continues to accomplish a primary goal of HIPAA,\ [315\]
the Department believes that it is essential to propose modifications to strengthen its protections for the confidentiality, integrity, and availability of ePHI to address the changing health care environment. We also believe it is important to clarify the obligations of regulated entities and emphasize the importance of protecting the confidentiality, integrity, and availability of ePHI. We believe that the proposed revisions would require regulated entities to consider and potentially modify their safeguards more regularly, which would better enable them to quickly respond to changes in the environment and be consistent with cybersecurity best practices. While we do not expect that compliance with the Security Rule will
( printed page 920)
prevent all breaches or interruptions in the confidentiality, integrity, or availability of ePHI, we believe that it will prevent many and enable regulated entities to identify, mitigate, and remediate the damage more quickly if there is a breach or other security incident, thereby reducing harm to individuals and the overall costs of such occurrences to regulated entities and to the U.S. health care system. As such, the proposed modifications would support a primary goal of HIPAA's Administrative Simplification provisions: improving the efficiency and effectiveness of the U.S. health care system by encouraging the development of health information systems through the establishment of uniform standards and requirements for electronic transmission of ePHI, including those for security.\ [316\]
### E. The Secretary Must Develop Standards for the Security of ePHI Because None Have Been Developed by an ANSI-Accredited Standard Setting Organization
HIPAA requires the Secretary to adopt standards that have been developed, adopted, or modified by a standard setting organization accredited by ANSI, except in certain circumstances.\ [317\]
For example, HIPAA permits the Secretary to develop standards where no relevant standards have been developed, adopted, or modified by an ANSI-accredited standard setting organization. In developing, adopting, or modifying a standard, the Secretary is required to consult with standard setting organizations, NCVHS, and with the appropriate Federal and State agencies.\ [318\]
The statutory definition of the term “standard” applies only to standards for electronic transactions and data elements for such transactions that are appropriate for: (1) the financial and administrative transactions described in the statute; and (2) other financial and administrative transactions consistent with the goals of improving the operation of the health care system and reducing administrative costs, as determined appropriate by the Secretary.\ [319\]
Under HIPAA, security is not considered a financial or administrative transaction, or a data element of such transaction.\ [320\]
In the “Health Insurance Reform: Standards for Electronic Transactions” final rule in 2000, we explicitly adopted a broader definition of “standard” because we recognized that the statutory definition only applied to standards for financial and administrative transactions, despite the statute's requirement that the Secretary adopt standards addressing other matters, including privacy and security.\ [321\]
At that time, we explained that we adopted a broader definition of standard to accommodate the varying functions of the specific standards proposed in other HIPAA regulations.\ [322\]
For the same reason, we believe that it is appropriate to continue to rely on the regulatory definition of standard.\ [323\]
As discussed above, in both 1998 and 2003, the Department determined that no comprehensive, scalable, and technology-neutral set of standards exists, and accordingly, we proposed and adopted a new standard.\ [324\]
In 2013, we made only minor modifications to the standards when we complied with explicit directions from Congress to apply the requirements of the Security Rule to business associates, so we did not need to consider whether an ANSI-accredited standard setting organization had adopted a comprehensive set of standards on the security for ePHI that was flexible, scalable, and technology-neutral.\ [325\]
However, because we believe it is appropriate for us to consider modifying the Security Rule at this time for the reasons discussed above, we must again consider whether an ANSI-accredited standards setting organization has developed, adopted, or modified a standard relating to the security of ePHI. The Department continues to believe that any standard must be comprehensive, rather than piecemeal, as recommended by the ANSI Healthcare Informatics Standards Board.\ [326\]
We also continue to agree with the recommendation that the standards should be technology-neutral because security technology continues to evolve to keep pace with the evolution of technology more broadly. Additionally, the Security Rule must remain flexible and scalable to allow for consideration of the wide variety of regulated entities, enabling such entities to determine the reasonable and appropriate security measures for their circumstances by taking into account the factors specified by HIPAA.\ [327\]
We are not aware of any standard setting organizations that are accredited by ANSI that have issued standards for the security of ePHI, let alone standards that are sufficiently comprehensive, flexible, scalable, and technology-neutral to enable regulated entities to take into account the HIPAA factors. For example, NIST has issued numerous publications addressing health care cybersecurity that are considered by NIST to be guidance, rather than standards. In fact, NIST is ANSI-accredited for only one standard.\ [328\]
And with the exception of publications that analyze the Security Rule, NIST's guidance does not specifically address the security of ePHI. CISA has issued cross-sector CPGs, but it is not ANSI-accredited. There may be other organizations that have set standards for the transmission of particular information, such as the secure transmission of images, but adopting such individual standards would not meet the Department's criteria. In this case, adoption of such standard would be far too granular and require the Department to revise the Security Rule at the same interval as the particular standard, which may be irregular. Additionally, given that the Department is limited to modifying each standard or implementation specification no more frequently than once every 12 months, this approach would be inefficient and could lead to a requirement that the Department update the Security Rule more than once a year, depending on when such individual standards or implementation specifications are revised. Even modifying the standards annually would require a significant investment of Department resources, not to mention the investment required of regulated entities to comply with an ever-changing set of requirements.
Additionally, in 2021, Congress amended the HITECH Act to require the Secretary to consider whether a regulated entity has adequately demonstrated that it had in place recognized security practices for a certain period of time.\ [329\]
Congress defined “recognized security practices” to include certain NIST publications; the approaches promulgated under
( printed page 921)
section 405(d) of the Cybersecurity Act of 2015; “and other programs and processes that address cybersecurity and that are developed, recognized, or promulgated through regulations under other statutory authorities.” \ [330\]
However, the HITECH Act amendment did not require the Secretary to accept a regulated entity's implementation of recognized security practices as an alternative to compliance with the Security Rule, nor did it provide that such implementation was sufficient to meet the security objectives of HIPAA or the HITECH Act. Accordingly, it is appropriate for the Department to develop and adopt its own standards to meet the statutory objective of ensuring the security of ePHI. The standards and implementation specifications proposed herein take into consideration not only those promulgated by NIST, but also guidelines, best practices, methodologies, processes, and procedures published by CISA, the HHS 405(d) program, CMS, State governments, and others. The proposals also enable regulated entities to adopt security measures that ensure the confidentiality, integrity, and availability of ePHI; protect against any reasonably anticipated threats or hazards to the security or integrity of ePHI and unauthorized uses or disclosures of such ePHI; ensure compliance with the Security Rule by the workforce members of regulated entities, while also taking into account the technical capabilities of record systems used to maintain ePHI; the costs of such measures; the need for training users who have access to ePHI; the value of audit trails in computerized record systems; and the needs and capabilities of small and rural health care providers.
The Department has consulted with and relied on the recommendations of NCVHS in the formulation of this proposed rule \ [331\]
and intends to continue to engage in these consultations before finalizing the rule.\ [332\]
We also expect to consult with the National Uniform Billing Committee, the National Uniform Claim Committee, the Workgroup for Electronic Data Interchange, and the American Dental Association before finalizing this rule, as required by section 1172(c)(3)(A)(ii) of HIPAA.\ [333\]
## IV. Section-by-Section Description of the Proposed Amendments to the Security Rule
This section contains a description of the proposed amendments to the Security Rule and the Department's rationale for its proposals. As part of this rationale, we often include a discussion of best practices contained in previously published guidance documents issued by the Department, NIST, and other Federal agencies. We request comment on previously published guidance documents that are not discussed herein that were issued by the Department or other Federal agencies and contain best practices but may be relevant or applicable to regulated entities, including the names of and citations for such guidance documents. We do not propose to adopt referenced best practices as the standard or implementation specifications unless otherwise specified in the proposed regulatory text. Rather, we include such discussion to provide regulated entities with context for the aforementioned proposals. We recognize that regulated entities are of varying types and sizes and may be concerned that requiring the adoption of such best practices might not be appropriate for all. However, we request comment on whether we should require implementation of certain aspects of a particular guidance document. If so, please explain which aspect(s) we should require, the rationale, and information about the burden of implementing such aspect(s).
### A. Section 160.103—Definitions
#### 1\. Current Provision
Electronic media are used by many health care organizations to process, transmit, and maintain ePHI. As defined by the Security Rule, the term “electronic media” \ [334\]
encompasses both (1) electronic storage material on which data is or may be electronically recorded; and (2) transmission media used to exchange information already in electronic storage media. It specifically excludes certain transmissions, such as those of paper, via facsimile (“fax”), and voice, via telephone, from being considered transmissions via electronic media if the information being exchanged did not exist in electronic form immediately before the transmission.
#### 2\. Issues To Address
The Department revised the definition of “electronic media” in 2013 by replacing the term “electronic storage media” with “electronic storage material” in recognition that there may be storage material other than “media” that houses electronic data in the future.\ [335\]
At that time, the Department said that a fax machine accepting a hardcopy document for transmission is not a covered transmission even though the document may have originated from printing from an electronic file.\ [336\]
In response to commenter concerns, we also clarified that ePHI maintained, intentionally or otherwise, in a photocopier, fax machine, or other device is subject to the Security Rule and reminded regulated entities that they should be aware of the capabilities of such devices with respect to their ability to maintain ePHI.\ [337\]
Additionally, a regulated entity should consider the appropriateness of implementing security measures that account for such capabilities.\ [338\]
Since 2013, the role technology plays in the storage and transmission of information has changed, as have the types of media used to store and transmit such information. For example, traditional landlines \ [339\]
are rapidly being replaced with electronic communication technologies, such as Voice over internet Protocol (VoIP),\ [340\]
and mobile technologies that use electronic media, such as the internet, intra- and extranets, cellular, and Wi-Fi.\ [341\]
Some current electronic technologies that regulated entities use for remote communications may include communication applications on a smartphone or another computing device, VoIP technologies, technologies that electronically record or transcribe a telehealth session, and messaging services that electronically store audio messages. The definition of electronic media does not account for these changes because it excepts
( printed page 922)
transmissions via fax, and of voice, via telephone, from transmissions via electronic media, nor does the definition take into consideration new and emerging technologies. Accordingly, the Department believes that it is appropriate to reconsider this definition.
#### 3\. Proposals
The Department proposes to modify the definition of “electronic media” as follows. First, the Department proposes to revise paragraph (1) of the definition to clarify that electronic media includes not only media on which data may be recorded, but also media on which data may be maintained or processed.
Generally, data is either at rest, in transit, or in process (
_e.g.,_
being worked on, in use, being modified in memory, or being updated).\ [342\]
After the data is no longer in use, it is either maintained or transmitted. It is especially important for entities to protect data in process because generally, data must be unencrypted to be processed, making this a time when it is particularly vulnerable to a breach or other security incident.\ [343\]
To that end, the Department's proposal would clarify that the definition includes electronic media that is used to record, maintain, or process data.
The Department also proposes to revise paragraph (1) to clarify and update terminology used in a non-exhaustive list of examples of electronic storage material. Additionally, to ensure that the definition includes future technology, the Department proposes to add to the list of examples “any other form of digital memory or storage” on which data may be recorded, maintained, or processed.
As discussed above, traditional landlines and fax machines are rapidly being replaced with electronic communication technologies and mobile technologies that use electronic media. The Security Rule applies when a regulated entity uses such electronic communication technologies. Therefore, regulated entities using telephone systems and fax equipment that transmit ePHI need to apply the Security Rule safeguards to those technologies.\ [344\]
Accordingly, in paragraph (2), we propose to revise the description of “transmission media” to recognize that data is transmitted almost exclusively in electronic form today. The limited exception to this would be data that is handwritten on paper and hand-delivered or mailed, such that the data is never on electronic storage material. Additionally, the Department proposes to include public networks in the examples of transmission media and to remove the sentence that describes transmissions that are not considered transmissions via electronic media. By making these changes, we would reflect technology's evolution since 2013.
We also propose to make a technical correction to paragraph (2) of the definition, consistent with a revision made in the 2013 Omnibus Rule to paragraph (1).\ [345\]
Specifically, the Department proposes to replace the term “electronic storage media” with “electronic storage material” in paragraph (2) to clarify the connection between definitions of electronic storage material and transmission media. We neglected to make this change in 2013 when we replaced “electronic storage media” with “electronic storage material” in paragraph (1), which means that paragraph (2) relies on a term that is no longer defined. This technical correction we propose is consistent with how the Department has interpreted the definition of transmission media and the connection between it and electronic storage material since the change was made in 2013.
#### 4\. Request for Comment
The Department requests comment on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. Whether the proposed modifications accurately capture current use of electronic media.
b. Whether the proposed modifications allow for future technological innovation.
c. Whether there are other types of electronic storage material that the Department should include in the non-exhaustive list of examples.
d. Whether there are other types of transmission media that the Department should include in the non-exhaustive list of examples.
### B. Section 164.304—Definitions
Section 164.304 includes definitions for key regulatory terms in the Security Rule. The Department proposes to add ten new defined terms and to modify the definitions of fifteen existing terms. The proposed new regulatory terms would be: Deploy, Implement, Electronic information system, Multi-factor authentication, Relevant electronic information system, Risk, Technical controls, Technology asset, Threat, and Vulnerability. The definitions we propose to modify are for the following terms: Access, Administrative safeguards, Authentication, Availability, Confidentiality, Information system, Malicious software, Password, Physical safeguards, Security or Security measures, Security incident, Technical safeguards, User, and Workstation. Generally, the Department is proposing to add or modify regulatory terms that would either clarify how regulated entities should apply the standards and implementation specifications or modernize the rule to better account for changes in the environment in which health care is provided.
#### 1\. Clarifying the Definition of “Access”
#### a. Current Provision and Issues To Address
The Security Rule defines the term “access” as the ability or means necessary to perform a set of activities describing how a user may interact with a system resource.\ [346\]
These activities are reading, writing, modifying, communicating data/information, or otherwise using any component of an information system. The definition applies only to the Security Rule, not to the Breach Notification Rule or the Privacy Rule.
The term “access” defines the scope of some key regulatory provisions in the Security Rule. For example, whether a person meets the definition of a “user” is determined based on whether their access to information or a component of the regulated entity's information system is authorized.\ [347\]
The definition
( printed page 923)
of the term “security incident” requires consideration of whether a person attempted to access or accessed information without authorization.\ [348\]
To determine whether a regulated entity complied with the administrative safeguard standard for workforce security, the Department must consider to what extent a regulated entity established policies and procedures for ensuring that workforce members have appropriate access to ePHI.\ [349\]
The current definition is expansive but not fully representative of how users could interact with information today. As discussed above, users create, receive, maintain, and transmit information in more ways now than they did ten years ago. Thus, the Department believes that it is critical for the Department to consider modifying the definition of this term to adequately reflect the current electronic environment.
#### b. Proposal
The Department proposes to expand the list of activities that should be considered under the term by adding the activities of “deleting” and “transmitting.” The Department also proposes to replace “system resource” with “component of an information system” to rely on an already defined term, “information system.” The proposed modification would clarify that the term includes any and all components of an information system and an information system as a whole. Additionally, the Department believes that a component of an information system better describes how the term access applies today because it is inclusive of hardware, software, and people, as opposed to only the inherent capabilities that contribute to performance, such as system memory and hard disk space.
#### 2\. Clarifying the Definition of “Administrative Safeguards”
#### a. Current Provision and Issues To Address
Administrative safeguards are administrative actions, policies, and procedures to manage the selection, development, implementation, and maintenance (including reviewing and modifying) of security measures to protect ePHI.\ [350\]
Administrative safeguards also manage the conduct of the regulated entity's workforce in relation to the protection of ePHI. Under the Security Rule, there are minor inconsistencies in language between the definitions of the types of safeguards, which might lead to uncertainty about how to interpret the terms and lead to unintended consequences. For example, the definitions of “administrative safeguards” and “physical safeguards” use “are,” while the definition of technical safeguards uses “means.” \ [351\]
In addition, the existing definition of “administrative safeguards” does not expressly relate the administrative actions to the policies and procedures addressing the activities covered by the definition, nor does it make clear that the policies and procedures are in addition to the administrative actions. The same is true for the definitions of physical and technical safeguards. Further, the definition of “administrative safeguards” does not expressly mention managing updates and modifications to safeguards.
#### b. Proposal
To address the minor inconsistencies between the definitions of the safeguards and to ensure that each safeguard is afforded an equal weight of importance, the Department proposes similar but minor changes across the definitions. The Department proposes to add the word “related” to the definition here, and below to add the words “and related” when necessary, to more clearly connect the components that make up safeguards. In the case of administrative safeguards, the Department's proposal relates administrative actions to administrative policies and procedures. The Department believes that this change would reduce confusion and improve clarity about compliance obligations. We are proposing a similar change to the definitions of physical safeguards and technical safeguards below. Additionally, we are proposing to clarify that maintenance includes updating and modifying with respect to administrative safeguards.
#### 3\. Clarifying the Definition of “Authentication”
#### a. Current Provision and Issues To Address
The Security Rule defines authentication as corroboration that a person is the one claimed. By limiting the definition of authentication to persons, the current definition neglects to acknowledge the importance to the security of ePHI of authenticating technology assets that are components of a regulated entity's electronic information systems that create, receive, maintain, or transmit ePHI or that otherwise affect the confidentiality, integrity, or availability of ePHI, or that the regulated entity intends to connect to such electronic information systems.\ [352\]
Absent such authentication, a bad actor could add technology assets (
_e.g.,_
software) to a regulated entity's electronic information systems that enable the bad actor to compromise the security of ePHI.
#### b. Proposal
To modernize the definition of authentication to reflect best practices in cybersecurity today, the Department proposes to clarify the definition to mean corroboration that either a person or technology asset is the one they are claiming to be. The modified definition would also improve readability with minor changes in wording. The Department believes as proposed, the revised definition would more accurately reflect the role played by technology assets in electronic information systems today. For example, a covered health care provider permits individuals to access their own PHI using an application that connects to the software that runs the covered health care provider's patient portal. Not only must the individual be authenticated as a user, but the application must be authenticated such that the covered entity's software can verify that the application is what it claims to be. In another example, a portable technology asset for retrieving and storing PHI in the cloud must be authenticated before retrieving data from cloud storage.
#### 4\. Clarifying the Definition of “Availability”
#### a. Current Provision and Issues To Address
“Availability” is defined in the Security Rule as the property that data or information is accessible and usable upon demand by an authorized person. Although not intended, the current definition could be read to limit the scope of availability only to authorized persons. And yet, it is equally important to ensure that authorized technology assets, such as connected medical devices, software, and workstations,
( printed page 924)
have access on demand to ePHI to carry out their functions.
#### b. Proposal
Given the increased connectivity of the health care environment, the Department proposes to clarify the definition of availability by specifying that availability means the property that data or information is accessible and usable upon demand by not only an authorized person, but also an authorized technology asset. In so doing, the Department is not changing the meaning of availability, but rather clarifying its scope.
#### 5\. Clarifying the Definition of “Confidentiality”
#### a. Current Provision and Issues To Address
Similar to the definition of availability, the definition of the term “confidentiality” could be read as limited to the property that data or information is not made available or disclosed to unauthorized persons or processes. Read that way, the definition does not reflect today's health care environment in which data and information may be accessed through any component of an interconnected electronic information system.
#### b. Proposal
The Department proposes to clarify the definition of confidentiality to specify that it means the property that data or information is not made available or disclosed to unauthorized persons, technology assets, or processes.
#### 6\. Adding Definitions of “Deploy” and “Implement”
#### a. Issues To Address
The Security Rule directs regulated entities to implement technical policies and procedures and assumes that such implementation requires the installation and configuration of technical safeguards.\ [353\]
OCR is concerned, based on its investigations and compliance reviews, that some regulated entities may interpret the regulatory requirement to implement technical policies and procedures to mean that a regulated entity is only required to establish written policies and procedures about technical requirements, but need not then apply effective, automated technical policies and procedures to all ePHI throughout the regulated entity's enterprise. For example, in
_M.D. Anderson,_
the court stated that the encryption requirement at 45 CFR 164.312(a)(2)(iv)(2)(iv)) requiring a regulated entity to implement a mechanism to encrypt ePHI does not “require a covered entity to warrant that its mechanism provides bulletproof protection of \`all systems containing ePHI.' Nor does it require covered entities to warrant that all ePHI is always and everywhere \`inaccessible to unauthorized users.' ” \ [354\]
Further, the court added that the requirement does not “say anything about how effective a mechanism must be, how universally it must be enforced, or how impervious to human error or hacker malfeasance it must be.” \ [355\]
Therefore, the Department believes it is necessary to add definitions that distinguish between implementation of the administrative and technical safeguards by separately describing how regulated entities can comply with requirements to implement technical safeguards and install technical solutions.
#### b. Proposal
The Department proposes to define the term “deploy” to identify a specific type of “implementation.” We believe that the new term and definition would help to better describe the compliance obligations for implementation specifications related to the use of technology for securing the confidentiality, integrity, or availability of ePHI. As proposed, the definition would require a regulated entity to ensure that technology is in place, configured for use, and actually in use and operational throughout the regulated entity. The Department's proposed use of the term helps illustrate its purpose and utility in clarifying that policies and procedures, while necessary, are insufficient to meet requirements for technical safeguards.
For example, the Department is proposing to create a new requirement for regulated entities to verify that business associates have deployed technical safeguards—that is, the technology is configured and operational, not only addressed in policies and procedures.\ [356\]
In another example, the Department is proposing new implementation specifications under the access control standard that would require a regulated entity to deploy technical controls for relevant electronic information systems so that the system is configured and applied to limit access to only users and technology assets that have been granted access rights.\ [357\]
In the automatic logoff implementation specification for that same standard, the Department is proposing to replace the requirement to implement electronic procedures for terminating an electronic session with a requirement to deploy technical controls that terminate an electronic session after a period of inactivity.\ [358\]
In each case, the technical controls must not only be configured for use, but they also must be applied to and in effect in all ePHI and relevant electronic information systems.
The Department proposes to define the term “implement” to clarify that a safeguard must be put into place and be in effect throughout the enterprise, as opposed to only some components of a regulated entity's relevant information systems (
_e.g.,_
some laptops or servers) or applied to a subset of ePHI. The Department also proposes the term to further clarify what it means to configure and put technology, technical controls, and related policies and procedures into effect and be in use, operational, and function as expected throughout the regulated entity's enterprise (
_i.e.,_
deploy) as compared to putting into place and making effective administrative or physical safeguards. Further, the Department proposes to expressly clarify that implement also means that a safeguard must function as expected. Under this proposal, if adopted, we would not consider a safeguard to be implemented if it is not functioning in the manner in which it is expected.
For example, a regulated entity's administrative policy requiring it to take action to prevent infections from malicious software is not implemented until it is applied throughout the enterprise, meaning that the entity has ensured that anti-malware protections have been put into place on all relevant electronic information systems that create, receive, maintain, or transmit ePHI or that otherwise affect the confidentiality, integrity, or availability of ePHI throughout the enterprise.
Similarly, to operationalize such a policy, the regulated entity must deploy technology assets and/or technical controls to block such software according to its technical policies and
( printed page 925)
procedures. In this regard, the proposed term “deploy” clarifies that the technology assets or technical control must be put into place, configured, and actually work (
_i.e.,_
function in the manner expected of the technology or technical control) throughout a regulated entity, in addition to the relevant policy and procedures being applied across a regulated entity. To implement a policy and procedure is separate from the implementation of a technology asset or technical control but in both cases, the underlying requirement is application across the enterprise.
#### 7\. Adding a Definition of “Electronic Information System”
#### a. Issues To Address
The current Security Rule includes explicit requirements for regulated entities to protect electronic information systems by implementing policies and procedures to limit physical access to such systems \ [359\]
and by implementing technical policies and procedures for electronic information systems that maintain ePHI to allow access to only persons or technology assets that have been granted access rights pursuant to 45 CFR 164.308(a)(4)(4)).\ [360\]
Further, the physical measures, policies, and procedures that meet the definition of physical safeguards are specifically limited to those that protect regulated entities' electronic information systems and related buildings and equipment.\ [361\]
And yet, the Security Rule does not explicitly define this term. Instead, it assumes that the definition is easily understood to be a subset of information system, a broad term that is not limited by the boundaries of the Security Rule. The Department believes that regulated entities would benefit from additional clarity regarding the definition of this term, given its foundational nature.
#### b. Proposal
The Department proposes to add a definition of “electronic information system” to better distinguish the concept from the broader category of an information system. Accordingly, the Department would limit the definition to an interconnected set of electronic information resources under the same direct management control that shares common functionality. Under this proposal, an electronic information system generally would include technology assets, such as hardware, software, electronic media, data, and information.
#### 8\. Modifying the Definition of “Information System”
#### a. Current Provision and Issues To Address
As discussed above, the Department seeks to clarify the scope of an information system, as compared to an electronic information system. We believe that it would be beneficial to align the common elements of these terms and clarify the relationship between them, given their importance to compliance with requirements of the Security Rule. Additionally, the changes in the environment, such as the shift to cloud-based computing, may raise questions regarding the Department's interpretation of “direct management control.”
#### b. Proposal
Accordingly, the Department proposes to modify the definition of “information system,” to clarify that an information system “generally”, not just “normally,” includes hardware, software, data, communications, and people. The Department believes this proposed modification, combined with the existing broad reference to “resources,” more accurately reflects the typical components of an information system and the full extent of resources that are addressed by the Security Rule. We also propose to remove “applications” from the list of technology assets that are generally included in an information system because applications are a type of software, making the inclusion of applications redundant. This proposed modification would not alter our interpretation that an information system includes applications.
We use this opportunity to affirm that a technology asset may be included as part of the information systems of multiple regulated entities where such regulated entities all have direct management control over the technology asset. For example, both a health care provider and a cloud-based EHR vendor have direct management control over the ePHI in the cloud-based EHR. Accordingly, such ePHI generally is part of both the information system of the health care provider and of the cloud-based EHR vendor. Additionally, the EHR that is used to create, receive, maintain, or transmit ePHI, regardless of whether it is accessed using software installed on the health care provider's workstation(s) or an internet browser, generally is also part of the information system of both entities because both the health care provider and the vendor have direct management control over the EHR.
#### 9\. Modifying the Definition of “Malicious software”
#### a. Current Provision and Issues To Address
Persons seeking unauthorized access to data and information are increasingly sophisticated. Their methods of attempting to gain such access can take many forms and result in a wide array of harms, as discussed above. One of the methods they use is through the introduction of malicious software (also referred to as malware) into an electronic information system. As the sophistication of bad actors has increased, so has the variety of types of malicious software that they use to access electronic information systems. The Security Rule defines malicious software but limits it to software designed to damage or disrupt a system. The regulatory text provides only one example of malicious software in regulatory text—a virus.
#### b. Proposal
The Department proposes to replace the current definition of malicious software with one that would be consistent with how cybersecurity experts define the term today.\ [362\]
Specifically, we propose to define it to mean software or firmware intended to perform an unauthorized action or activity that will have adverse impact on an electronic information system and/or the confidentiality, integrity, or availability of electronic protected health information. This proposal would therefore clarify that malicious software could include either software or firmware and that the negative effects of the malicious software may not be limited to damaging or disrupting a system. Rather, effects of the software could be intended to have any type of adverse impact on an electronic information system and/or the confidentiality, integrity, or availability of ePHI. The Department also proposes to include in regulatory text a non-exhaustive list of examples, such as viruses, worms, Trojan horses, spyware, and some forms of adware, to assist regulated entities in understanding what constitutes malicious software.
( printed page 926)
#### 10\. Adding a Definition of “Multi-Factor Authentication” (MFA)
#### a. Issues To Address
The Security Rule includes several technical safeguard provisions that require regulated entities to identify and authenticate persons accessing information and systems to protect ePHI. Section 164.312(a)(2)(1) includes the standard that requires a regulated entity to implement technical policies and procedures that limit access to ePHI to only those persons or software programs that have been granted access rights, while 45 CFR 164.312(d)(2)(2)), the standard for person or entity authentication, requires a regulated entity to implement procedures to verify that a person seeking access to ePHI is the one claimed.
Historically, regulated entities relied on combinations of usernames and passwords to identify users and authenticate users to the system. We recognize that such combinations are insufficient to secure sensitive information and that more sophisticated mechanisms for doing so have been developed. As a best practice for managing cyber threats, most cybersecurity frameworks, including those discussed above, recommend that organizations adopt solutions that rely on multiple factors to identify and authenticate users. For example, the HHS 405(d) Program's “Health Industry Cybersecurity Practices: Managing Threats and Protecting Patients” \ [363\]
recommends a layered approach to cyber defense (
_i.e.,_
if a first layer is breached, a second exists to prevent a complete breach).\ [364\]
It further provides that MFA as a source of identity and access security control is an important means to control access to infrastructure and conduct proper change management control.\ [365\]
The Department's CPGs \ [366\]
identify MFA as an essential goal and a critical, additional layer of security for the protection of assets and accounts that are directly accessible from the internet.\ [367\]
The Department has also explained in guidance that weak authentication processes leave organizations vulnerable to intrusion, while effective authentication ensures that only authorized entities may access information systems and data.\ [368\]
Additionally, CISA has issued recommendations for implementing MFA, specifically MFA solutions that are phishing resistant to protect against disclosures of authentication data to a bad actor.\ [369\]
#### b. Proposal
The Department proposes to define the term “Multi-factor authentication” to provide regulated entities with a specific level of authentication for accessing relevant electronic information systems.\ [370\]
Regulated entities would be required to apply this proposed definition when implementing the proposed rule's specific requirements for authenticating users' identities through verification of at least two of three categories of factors of information about the user. The proposed categories would be:
- Information known by the user, including but not limited to a password or personal identification number (PIN).
- Item possessed by the user, including but not limited to a token or a smart identification card.
- Personal characteristic of the user, including but not limited to fingerprint, facial recognition, gait, typing cadence, or other biometric or behavioral characteristics.
MFA relies on the user presenting at least two factors. Authentication that relies on multiple instances of the same factor, such as requiring a password and PIN, is not MFA because both factors are “something you know.” \ [371\]
For example, where MFA is deployed, users could seek access by entering a password. However, without the entry of at least a second factor such as a token \ [372\]
or smart identification card, the user is not granted access and the password is useless by itself. Cybercriminals seeking access to MFA-protected information systems require significantly more resources to launch the attack because there are multiple data points required to succeed.\ [373\]
The Department proposes that the personal characteristics that could be used as factors would include both physical characteristics, such as fingerprints or facial identifiers, and behavioral characteristics, such as a user's gait or typing cadence.\ [374\]
#### 11\. Clarifying the Definition of “Password”
#### a. Current Provision and Issues To Address
The Security Rule currently defines “password” as confidential authentication information composed of a string of characters.\ [375\]
The definition provides no further regulatory instruction on what constitutes a “character” for purpose of compliance.
#### b. Proposal
The Department proposes to add examples to the definition to further clarify what constitutes a character, and adds “such as letters, numbers, spaces, and other symbols” to the existing definition. The Department believes that regulatory examples would provide necessary context for regulated entities that deploy safeguards involving passwords.
( printed page 927)
#### 12\. Clarifying the Definition of “Physical Safeguards”
#### a. Current Provision and Issues To Address
“Physical safeguards” encompass the physical measures, policies, and procedures that protect a regulated entity's electronic information systems and related buildings and equipment from natural and environmental hazards, and unauthorized intrusion. As discussed within the definition of administrative safeguards, the Department believes that it is necessary to reduce minor inconsistences in language between the definitions of the types of safeguards. Additionally, the definition of physical safeguards relies on an undefined term (“buildings”), despite the existence of a defined term (“facilities”) that has an equivalent meaning.
#### b. Proposal
The Department proposes to clarify that the policies and procedures referred to in the definition are those that specifically are related to physical measures, and to replace “buildings” with “facilities” because facility is a defined term under the Security Rule and has an equivalent meaning.\ [376\]
The Department intends and has always intended the physical safeguards to apply to any location where a regulated entity might possess ePHI, including the physical premises and interior and exterior of a building, and any location that might affect the confidentiality, integrity, or availability of ePHI. Additionally, given the mobility of technology today, including workstations that may access ePHI, we believe it would be more appropriate to use the term facility to make clear that the physical safeguards are to apply throughout the premises of the regulated entity. For the same reasons discussed above, we also propose to clarify that the physical safeguards serve to protect relevant electronic information systems, as we propose to define the term elsewhere in this NPRM, rather than all electronic information systems. Further, the Department proposes to better standardize the administrative, physical, and technical safeguard requirements by using defined terms where they exist.
#### 13\. Adding a Definition of “Relevant Electronic Information System”
#### a. Issues To Address
The Security Rule requires a regulated entity to ensure the confidentiality, integrity, and availability of all of the ePHI it creates, receives, maintains, or transmits.\ [377\]
To protect the ePHI as required, a regulated entity must also protect the electronic information systems that create, receive, maintain, or transmit ePHI and the electronic information systems that otherwise affect the confidentiality, integrity, or availability of ePHI. The Department believes that regulated entities are not consistently protecting ePHI in a manner that is consistent with their Security Rule obligations and believes that it is necessary to clarify the scope of those obligations. We believe that creating a new defined term for the electronic information systems to which the Security Rule requirements apply will help achieve this goal by ensuring that regulated entities fully understand how their technology assets and the architecture of their electronic information systems affect the confidentiality, integrity, and availability of ePHI.
#### b. Proposal
The Department proposes to add and define the term “relevant electronic information system” to mean an electronic information system that creates, receives, maintains, or transmits ePHI or that otherwise affects the confidentiality, integrity, or availability of ePHI. We believe that distinguishing between a relevant electronic information system and an electronic information system, as proposed, would further clarify the scope of regulated entities' compliance obligations, including the obligation of regulated entities to understand the relationship between their various electronic information systems and the confidentiality, integrity, and availability of ePHI.
The Department believes it is important to clarify that the requirements of the Security Rule do not only apply to electronic information systems that create, receive, maintain, or transmit ePHI. After all, cybercriminals may be able to access ePHI by leveraging vulnerabilities in some electronic information systems that do not themselves create, receive, maintain, or transmit ePHI where such information systems are connected to or otherwise affect electronic information systems that do create, receive, maintain, or transmit ePHI. For example, while a payment processing system used in a covered entity's food and beverage outlets or gift shops may not create, receive, maintain, or transmit ePHI, it may affect the confidentiality, integrity, or availability of ePHI in certain circumstances, such as where such systems are connected to the same network as servers that contain ePHI.\ [378\]
Accordingly, we would interpret an electronic information system as otherwise affecting the confidentiality, integrity, or availability of ePHI if it is insufficiently segregated physically and electronically from an electronic information system that creates, receives, maintains, or transmits ePHI or one that otherwise affects the confidentiality, integrity, or availability of ePHI.
An electronic information system would also fit the category of “otherwise affecting” if it contains information that relates to an electronic information system that creates, receives, maintains, or transmits ePHI or to another electronic information system that otherwise affects the confidentiality, integrity, or availability of ePHI. For example, a compromised electronic information system used to provide administrative functions, such as user authentication or management of storage area network infrastructure, that does not contain ePHI may allow unauthorized access to ePHI (affecting the confidentiality of ePHI) or disruption of storage configuration data (affecting the integrity and availability of ePHI). An electronic information system that is not connected to a covered health care provider's EHR but that maintains user IDs and passwords for the EHR also may not create, receive, maintain, or transmit ePHI; however, the confidentiality, integrity, or availability of the ePHI in the EHR would be affected if an unauthorized person gained access to that electronic information system. And the same is true for an electronic information system that contains the decryption keys for a regulated entity's encryption algorithms. Thus, it is important that administrative, physical, and technical safeguards be implemented not only for electronic information systems that create, receive, maintain, or transmit ePHI, but also for electronic information systems that otherwise affect the confidentiality, integrity, or availability of ePHI.
( printed page 928)
#### 14\. Adding a Definition of “Risk”
#### a. Issues To Address
The Security Rule does not currently include a definition for the term “risk.” The Department considered defining it when it first promulgated the final rule in 2003, but declined to do so because it determined that the term was commonly understood.\ [379\]
However, the Department now believes that the lack of a definition may affect the clarity of some key requirements for regulated entities. Such requirements include conducting a risk analysis to assess the potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI held by the regulated entity \ [380\]
and implementing security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to comply with the general rules at 45 CFR 164.306(a)).\ [381\]
One of the ways NIST defines the term is as “a measure of the extent to which an entity is threatened by a potential circumstance or event, and typically a function of: (i) the adverse impacts that would arise if the circumstance or event occurs; and (ii) the likelihood of occurrence.” \ [382\]
This and other NIST definitions serve as helpful references for the Department when considering how to define the term within the rule.
#### b. Proposal
The Department proposes to define “risk” as the extent to which the confidentiality, integrity, or availability of ePHI is threatened by a potential circumstance or event. The Department believes that defining the term would clarify several existing and proposed provisions of the Security Rule, such as the factors regulated entities must consider when determining the security measures they will implement \ [383\]
and the importance and purpose of conducting the required risk analysis.\ [384\]
#### 15\. Clarifying the Definitions of “Security or Security Measures” and “Security Incident”
#### a. Current Provision and Issues To Address
The Security Rule defines “security or security measures” as encompassing all of the administrative, physical, and technical safeguards in an information system.\ [385\]
The definition implies that the safeguards must be part of the information system, as opposed to something that may be applied or done to a system to protect the confidentiality, integrity, and availability of ePHI.
The rule also defines “security incident” as the attempted or successful unauthorized access, use, disclosure, modification, or destruction of information or interference with system operations in an information system. The existing definition does not make clear that a security incident may result from two types of behaviors—those related to attempted or successful but unauthorized access, use, disclosure, modification, or destruction of information in an information system, and those that are related to the attempted or successful unauthorized interference with system operations in an information system. In other words, a security incident may directly touch upon information in a system or interfere with the operations of the system itself. The Department believes that it is necessary to clearly convey the distinct types of incidents to regulated entities to ensure that regulated entities implement and deploy safeguards that address both concerns.
#### b. Proposal
The Department proposes to modify the definition of “security or security measures” to clarify that security or security measures may not only exist in information systems but may also be applied to information systems.\ [386\]
This clarification would better reflect the multi-layered approach to cybersecurity recommended by experts to address the concerns facing regulated entities today. For example, a regulated entity may determine that it is necessary to apply access controls and encryption mechanisms through an external mechanism, such as added firewall technology,\ [387\]
that is applied to the system, rather than technical controls that are embedded within the system or components of the system. The Department believes that the proposed definition would provide a more complete instruction.
The Department proposes to reorganize the definition of “security incident” into two numbered paragraphs to delineate the two separate categories of security incidents. We also propose to clarify that in both instances, the definition applies when the described action affects an information system and regardless of whether an attempt to affect the information in the system or interfere with system operations is successful or not.
#### 16\. Adding Definitions of “Technical Controls”
#### a. Issues To Address
Throughout the technical safeguards provisions in 45 CFR 164.312, the Department directs regulated entities to implement technical policies and procedures. The court in
_M.D. Anderson_
interpreted technical policies and procedures as written policies and procedures on technical matters.\ [388\]
This interpretation does not reflect the Department's intent for technical safeguards to include policies and procedures that rely on technology or technological solutions for implementation.\ [389\]
We believe that the court's interpretation could have significant consequences for the confidentiality, integrity, and availability of ePHI.
#### b. Proposal
The Department proposes to add and define the term “technical controls” to help regulated entities better understand what we mean by technical safeguards for purposes of complying with the Security Rule. We propose to define technical controls as technical mechanisms contained in the hardware, software, or firmware components of an electronic information system that are primarily implemented and executed by the electronic information system to protect it and the data within the electronic information system. The Department believes that adding this term would better convey the expectation that a regulated entity is
( printed page 929)
required to deploy technical safeguards across its enterprise by, among other things, configuring and using technical mechanisms in the hardware, software, and firmware components of its relevant electronic information systems to protect ePHI and electronic information systems that create, receive, maintain, or transmit ePHI or that otherwise affect the confidentiality, availability, or integrity of ePHI.
#### 17\. Modifying the Definition of “Technical Safeguards”
#### a. Current Provision and Issues To Address
The current definition of “technical safeguards” includes the technology and policy and procedures for its use that protect ePHI and control access to it.\ [390\]
As discussed above, the Department believes that there is an immediate need to modernize and update the definition to better reflect the role technology plays in protecting ePHI and the technical components of information systems, versus the role of policies and procedures. This would complement our effort to clarify the relationship between technology and the implementation of technical policies and procedures.
#### b. Proposal
The Department proposes to modify the definition of “technical safeguards” to expressly include “technical controls.” We also propose to add language that would clarify that the technology, technical controls, and related policies and procedures in this category govern the use of the technology to protect and control access to ePHI. The proposed changes also would improve the consistency of language across the safeguard provisions and rule.
#### 18\. Adding a Definition of “Technology Asset”
#### a. Issues To Address
Throughout the Security Rule, standards and implementation specifications list the components of electronic information systems to which its requirements apply. Based on the Department's enforcement experience, we believe that it would be beneficial to more clearly distinguish between the requirements that apply to all components of an electronic information system and those that only apply to certain components. Additionally, we believe it would be beneficial to distinguish between requirements that apply specifically to each particular component of an electronic information system and those that apply to the electronic information system as a whole.
#### b. Proposal
The Department proposes to define the term “technology asset” to mean the components of an electronic information system, including but not limited to hardware, software, electronic media, information, and data. In so doing, we would clarify which Security Rule requirements apply to all of the components of electronic information systems as opposed to those that apply only to certain components, and which requirements apply to each particular components and which apply to the entire electronic information system.
For example, understanding the risks and vulnerabilities to a regulated entity's ePHI requires a thorough understanding of the components of its electronic information systems, the electronic information systems themselves, how they are connected, and how ePHI moves through those systems. Thus, by requiring a regulated entity to conduct an inventory of its technology assets and to create a network map of its electronic information systems, we clarify that a regulated entity is obligated to consider not only its electronic information systems as a whole, but also the components within those electronic information systems and their functions.
#### 19\. Adding a Definition of “Threat”
#### a. Issues To Address
Addressing threats to the confidentiality, integrity, and availability of ePHI is a key function of the Security Rule, but the rule does not define “threat.” The concept of threat also underlies the Department's proposed definition of “risk” defined above and forms the basis of a key proposed implementation specification associated with the standard for risk analysis.\ [391\]
#### b. Proposal
The Department proposes to define the term “threat” to mean any circumstance or event with the potential to adversely affect the confidentiality, integrity, or availability of ePHI. This proposal is similar to NIST's varying definitions of threat, edited to apply specifically to health care and the type of information addressed by the Security Rule.\ [392\]
Under this proposal, we would construe the term to apply broadly to include threats caused by, or existing because of, a variety of circumstances that specifically could affect the security of ePHI. Hackers, malicious insiders, and malicious software are examples of threat sources.
#### 20\. Clarifying the Definition of “User”
#### a. Current Provision and Issues To Address
The Department first defined the term “person” in the HIPAA Rules as part of the 2003 “Civil Money Penalties: Procedures for Investigations, Imposition of Penalties, and Hearings” interim final rule to distinguish a “natural person” who could testify in the context of administrative proceedings from an “entity” (defined therein as a “legal person”) on whose behalf a person would testify.\ [393\]
Although they were both published in 2003, the interim final rule was published two months after the Security Rule. Thus, when the Security Rule was published in 2003, it was necessary to specify that the term “user” included both natural persons and entities, but we believe that this is no longer the case because the current definition of “person” includes natural persons as well as entities.\ [394\]
#### b. Proposal
The Department proposes to clarify the definition of “User” by removing the reference to an entity.\ [395\]
Because the definition of “person” includes an entity, including entity in the definition of “user” is redundant and could cause confusion. We believe that this is a technical correction because it would not change how the Department has interpreted the term.
#### 21\. Adding a Definition of “Vulnerability”
#### a. Issues To Address
The term “vulnerability” is currently not defined in the Security Rule.
The Department previously explained that although some cyberattacks may be sophisticated and exploit previously unknown vulnerabilities (
_i.e.,_
zero-day attacks), most can be prevented or mitigated by addressing known vulnerabilities.\ [396\]
For example,
( printed page 930)
exploitable vulnerabilities exist across many components of IT infrastructures including, but not limited to, servers, desktops, mobile device operating systems, web software, and firewalls.\ [397\]
To mitigate against intrusions and hacking threats, the Department has recommended that regulated entities install vendor patches, make software updates, and monitor sources of cybersecurity alerts describing new vulnerabilities, such as the NIST National Vulnerability Database \ [398\]
and CISA's Known Exploited Vulnerabilities Catalog.\ [399\]
#### b. Proposal
The Department proposes to define vulnerability by adopting substantially the same definition as NIST (a “weakness in an information system, system security procedures, internal controls, or implementation that could be exploited or triggered by a threat source”) \ [400\]
with minor changes to clarify how it applies to regulated entities and ePHI. The definition, if adopted as proposed, would then form the basis for understanding key assessment and mitigation strategies proposed in this NPRM, such as risk analyses,\ [401\]
patch management,\ [402\]
and vulnerability management and scans.\ [403\]
#### 22\. Clarifying the Definition of “Workstation”
#### a. Current Provision and Issues To Address
The Department currently defines the term “workstation” to mean an electronic computing device and provides the examples of technology that dominated the health care environment in 2003 and 2013, such as a laptop, desktop computer, and other device that performs similar functions, and electronic media stored in its immediate environment.\ [404\]
Workstations are essential for workforce members to perform their assigned functions, such as clinicians entering an individual's health history and treatment plan or billing staff preparing claims. Workstations are one of the key entry points for users to access a regulated entity's information systems. Thus, the Security Rule contains provisions requiring that regulated entities secure not only their information systems, but also individual workstations.\ [405\]
However, as discussed above, the health care environment has changed. It now includes both the physical and virtual environment and is replete with mobile devices and other types of devices that may serve as multi-functional workstations. Clinicians and other workforce members often rely on smart phones, smart watches, tablets, laptops, and even personal digital assistants, among other devices. These devices have proliferated, and so has their ability to perform a wide variety of functions with increasing sophistication. The Department believes that it is necessary to update the definition to reflect the evolved nature of the landscape.
#### b. Proposal
In recognition of this changed environment, the Department proposes to modify the definition of workstation to provide additional examples of what constitutes a workstation. Specifically, we propose to add the examples of a server, virtual device, and a mobile device such as a smart phone or tablet. Virtual devices could include a virtual medical device, virtual server, or virtual desktop computer. The proposed definition also would clarify that technology properly considered as a “workstation” is not limited to the proposed regulatory examples.
#### 23\. Request for Comment
The Department requests comment on all the foregoing proposed definitions, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. Whether any of the proposed definitions would be problematic for regulated entities or result in unintended adverse consequences. If so, please explain.
b. Whether the Department should consider an alternative definition for any terms the Department proposes to define in the rule. If the answer is yes, please propose such an alternative definition and a reference or supporting rationale.
c. Whether the Department should define any additional terms within the rule. If the answer is yes, please propose such additional terms and definitions, along with any reference or supporting rationale.
d. With respect to the definitions of “information system” and “electronic information system,” the extent of a covered entity's direct management control over applications in cloud computing environments, such as a cloud-based EHR system.
e. With respect to the definitions of “information system” and “electronic information system,” the extent of a business associate's direct management control over applications in cloud computing environments, where the business associate is the cloud service provider.
f. Whether defining the term “technical controls” and adding it to the definition of “technical safeguards” would more clearly explain the requirements of 45 CFR 164.312.
g. Whether defining “implement” and “deploy” as we propose would more clearly explain the differences between what is expected of regulated entities with respect to administrative and physical safeguards and technical safeguards. To the extent that the proposals would not clarify the differences, please provide alternative solutions.
### C. Section 164.306—Security Standards: General Rules
#### 1\. Current Provisions
Section 164.306 applies to regulated entities and includes the general rules for security standards. Generally, paragraph (a) codifies HIPAA statutory requirements for safeguarding ePHI.\ [406\]
Under these rules, regulated entities are required to do all of the following:
- Ensure the confidentiality, integrity, and availability of all ePHI the regulated entity creates, receives, maintains, or transmits.\ [407\]
- Protect against reasonably anticipated threats or hazards to the security or integrity of such information.\ [408\]
- Protect against any reasonably anticipated uses or disclosures of such information not permitted by the Privacy Rule.\ [409\]
- Ensure that workforce members comply with the Security Rule.\ [410\]
Paragraph (b) of this section permits regulated entities to determine the most
( printed page 931)
appropriate security measures for protecting ePHI and their information systems. Accordingly, 45 CFR 164.306(b)(1)(1)) permits regulated entities to use any security measures to reasonably and appropriately implement the standards and implementation specifications of the Security Rule, while 45 CFR 164.306(b)(2)(2)) contains the factors that regulated entities are to consider when deciding which security measures to use. This paragraph furthers the aim of HIPAA's requirement for the security standards to take into account certain factors by providing for their consideration by regulated entities.\ [411\]
Accordingly, 45 CFR 164.306(b)(2)(2)) directs regulated entities to take these factors into account when determining the manner in which they will comply with the security standards and implementation specifications.
Section 164.306(c) requires regulated entities to comply with the administrative, physical, and technical safeguard standards in sections 45 CFR 164.308, 164.310, and 164.312 respectively, and with standards for organizational requirements and policies, procedures, and documentation requirements in sections 45 CFR 164.314 and 164.316. This provision is followed by paragraph (d), which explains that regulated entities are required to implement a specific implementation specification if described as “required.” If the implementation specification is described as “addressable,” regulated entities are required to implement the implementation specification if it is reasonable and appropriate to do so; or, if it is not reasonable and appropriate, document why and implement an equivalent alternative measure.
Finally, the maintenance provision at 45 CFR 164.306(e)) requires regulated entities to review and modify security measures implemented under the Security Rule as needed to continue providing reasonable and appropriate protection of ePHI. It also requires regulated entities to update documentation of such security measures in accordance with the requirements for documentation at 45 CFR 164.316(b)(2)(iii)(2)(iii)).
#### 2\. Issues To Address
We believe that we can improve consistency in language between this section and other Security Rule provisions and better align this section with statutory terms and intent. For example, we are concerned that regulated entities are misinterpreting 45 CFR 164.306(a)) to apply the requirements of the Security Rule to only some ePHI, rather than all ePHI. This interpretation could lead to inadequate protection of ePHI and relevant electronic information systems.\ [412\]
We also believe that consistency in language facilitates clear understanding and less ambiguity about how regulated entities must apply Security Rule standards.
Flexibility and scalability are among the Security Rule's defining characteristics, and we intend to preserve those elements to the extent possible. However, we believe that in this era of increased reliance on technology, more sophisticated cyber capabilities, and increasing cyberattacks, it is critical for regulated entities to implement and deploy strong security measures to protect ePHI and related information systems. We are concerned that regulated entities have focused their attention primarily on the cost of security measures, rather than considering the reasonableness and appropriateness of security measures in the context of all of the listed factors, including the probability and criticality of potential risks to ePHI.\ [413\]
Further, the Department believes that providing additional clarity would improve the ability of regulated entities to evaluate security measures for the protection of ePHI and the ability of a security measure to facilitate a regulated entity's recovery from emergencies and to support continued operations. With these proposed modifications, the Department seeks to ensure that regulated entities' reliance on the Security Rule's flexibility and scalability does not come at the expense of adequate security. The current regulation's framework in 45 CFR 164.306(b)) lacks any express factor that would require an evaluation of the effectiveness of the security measures in supporting the resiliency of the regulated entity.
The Department has explained in regulation and guidance the difference between required and addressable implementation specifications. The meaning of “required” is clear. Regarding “addressable,” we previously explained that its purpose is to provide regulated entities flexibility with respect to implementation compliance.\ [414\]
We also previously explained that a regulated entity must assess whether a given addressable implementation specification is a reasonable and appropriate security measure to apply within its environment, and if it is, the regulated entity must implement the addressable implementation specification.\ [415\]
However, the Department remains concerned that regulated entities believe that flexibility overrides the need for them to protect all ePHI and do not uniformly treat addressable implementation specifications as needing to be met if they are reasonable and appropriate. OCR's enforcement experience and interaction with regulated entities causes us to believe that “addressable” is misunderstood to be optional, leading regulated entities to choose not to adopt the implementation specification, even when it would be reasonable and appropriate for them to do so.\ [416\]
In 2022, NCVHS recommended that the Department eliminate the choice to not implement a specification or alternative, and instead require that regulated entities implement the specification or adopt a documented reasonable alternative.\ [417\]
According to a survey referenced by NCVHS, despite private sector and government efforts to address a changing cybersecurity landscape, the majority of health care entities have failed to maintain a comprehensive security program and
( printed page 932)
continue to neglect people and process measures necessary for a comprehensive security program.\ [418\]
NCVHS also pointed to a continued failure of regulated entities to develop adequate incident recovery plans and to assess their vulnerability to cyberattacks grounded in social engineering.\ [419\]
Finally, NCVHS opined that the current structure of the Security Rule is inadequate to protect U.S. health care infrastructure because it does not require regulated entities “to adopt the basic building blocks of good security hygiene, or a documented, reasonable alternative.” \ [420\]
We share NCVHS' concerns and believe that we must squarely confront the problem of regulated entities treating addressable implementation specifications as optional. Relatedly, we also believe that we must consider modifying the Security Rule to set an acceptable minimum level of security specifications. Circumstances have changed sufficiently since 2003 such that we now believe that good cyber hygiene requires regulated entities to implement more than the implementation specifications that we originally mandated.\ [421\]
Indeed, we believe that it requires compliance with all of the standards and implementation specifications we are proposing, with specific, limited exceptions.
We also believe that the current maintenance requirement in 45 CFR 164.306(e)) would benefit from increased specificity in light of the dramatic transformation of the health IT environment discussed above. For example, providing the frequency with which regulated entities must review and update their security measures would improve the security of ePHI and regulated entities' compliance with the Security Rule. The Security Rule's maintenance requirement would be further strengthened by requiring regulated entities to test their security measures to verify their sufficiency, and by clarifying the Department's expectations regarding documentation. Regulated entities' lack of documentation about how they implement security measures makes it difficult for them to know what security measures they have in fact implemented and to demonstrate compliance with the requirements of the Security Rule. Finally, the maintenance requirement in 45 CFR 164.306(e)) is not included in or designated as a Security Rule standard, although it explicitly references the overarching documentation requirements in 45 CFR 164.316(b)(2)(iii)(2)(iii)). Thus, there is overlap between the two sections that may be causing confusion regarding the obligations of regulated entities to maintain security measures.
#### 3\. Proposals
#### a. Section 164.306(a)—General Requirements
The Department proposes to expand the introductory language to the general requirements provision at 45 CFR 164.306(a)) to clarify the extent to which the general requirements apply to the obligations of regulated entities with respect to ePHI that they create, receive, maintain, or transmit.
Under the proposal, the Department would clarify that the general requirements apply to “all” ePHI. Additionally, the Department proposes to move language from paragraph (a)(1) to paragraph (a) to further emphasize that regulated entities must apply the requirements of the Security Rule to protect all of the ePHI they create, receive, maintain, or transmit. We also propose to clarify that “each” regulated entity would be required to apply the obligations in paragraphs (a)(1) through (4) to all ePHI it creates, receives, maintains, or transmits. The Department believes that this proposal would stress to regulated entities that each and every covered entity and business associate would be responsible for ensuring it meets Security Rule requirements with respect to all ePHI.
The Department believes this proposed change would also help address issues raised by current interpretations of the Security Rule that suggest that its plain wording may not require regulated entities to fully implement each security measure to protect all ePHI. Thus, the Department's proposed language would clarify that a security measure must be implemented such that it protects the security of all ePHI and all information systems that affect the confidentiality, integrity, and availability of ePHI.
Additionally, the Department proposes to modify the general requirements of paragraph (a)(2) to require each regulated entity to protect against any reasonably anticipated threats or hazards to the confidentiality, integrity, or availability of all ePHI, instead of to the security or integrity of ePHI. We believe that this proposal would better align this requirement with the general requirement at 45 CFR 164.306(a)(1)(1)), and confidentiality, integrity, and availability are generally considered the three basic elements of security.\ [422\]
Additionally, the Department proposes a minor change to paragraph (a)(3) to refer specifically to ePHI, rather than using a more general term. We believe that both proposals would constitute technical revisions and that neither would alter the meaning of 45 CFR 164.306(a)(2)(2)) or (3)(3)), respectively.
Finally, the Department proposes to modify paragraph (a)(4) so that each regulated entity would be required to ensure that its workforce complies not only with the Security Rule, but also all administrative, physical, and technical safeguards implemented in accordance with this subpart.
These proposals would better align the language of the general requirements in paragraph (a) of 45 CFR 164.306) with the statute \ [423\]
and 45 CFR 164.530(c)).\ [424\]
These proposals are also consistent with our proposals to revise the introductory language for each of the safeguard provisions to clarify the provisions therein would be the minimum regulated entities are to implement,
_i.e.,_
that the security measures required by the Security Rule constitute a floor of protections, not a ceiling.
#### b. Section 164.306(b)—Flexibility of Approach
The Department's proposals generally retain the flexible approach described in paragraph (b). As discussed above, the Security Rule carefully balances the benefits of safeguarding against risks to security and the burdens of implementing protective measures by, for example, enabling regulated entities to take into account specified factors when determining how to implement security measures in a manner that complies with the Security Rule. To acknowledge the rapid evolution of technology and increasing threats, the Department proposes to clarify
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paragraph (b)(1) to provide that regulated entities are to apply reasonable and appropriate security measures to implement the standards and implementation specifications of the Security Rule. This proposal, if adopted, would replace the existing paragraph providing for regulated entities' reasonable and appropriate implementation of standards and implementation specifications, which could be misinterpreted to mean that a regulated entity may determine that implementation itself is unreasonable or inappropriate in some circumstances. That has never been the case. Thus, the proposed modification would clarify that implementation is not optional based on whether a regulated entity believes it is reasonable and appropriate; to the contrary, a regulated entity is required to implement the standards and implementation specifications and must adopt reasonable and appropriate security measures that allow the entity to achieve such implementation. The proposed clarification would comport more precisely with the statute, which requires regulated entities to maintain “reasonable and appropriate” safeguards.\ [425\]
The Department also proposes to add a new element to the list of factors that regulated entities must take into account when deciding whether a particular security measure (
_e.g.,_
a technical control) is reasonable and appropriate for implementing a standard and its associated implementation specifications: the effectiveness of the security measure in supporting the resiliency of the regulated entity. A regulated entity would be required to consider this factor, in addition to the existing factors, for example, when choosing a specific encryption solution that allows the entity to meet the proposed requirement to encrypt ePHI, which will help prevent an unauthorized user from accessing the entity's ePHI; or when developing its security incident plan or disaster recovery plan, which will help ensure that the regulated entity can recover data or reestablish data integrity after a security incident or disaster.
The Department proposes at 45 CFR 164.306(b)(2)(v)(2)(v)) to require a regulated entity to take into account how effectively its application of a particular security measure to achieve compliance with a standard and its associated implementation specifications would support its resiliency in the face of an event that adversely affects the entity. According to NIST, “information system resilience” addresses how well information systems “continue to (i) operate under adverse conditions or stress, even if in a degraded or debilitated state, while maintaining essential operational capabilities; and (ii) recover to an effective operational posture in a time frame consistent with mission needs.” \ [426\]
Recently, in this era of rising cybercrime, NIST described “cyber resiliency” as “the ability to anticipate, withstand, recover from, and adapt to adverse conditions, stresses, attacks, or compromises on systems that use or are enabled by cyber resources.” \ [427\]
Thus, the Department proposes to require a regulated entity to consider the ability of its implementation of a particular security measure to aid it in preventing, withstanding, and recovering from an emergency or other occurrence that affects the confidentiality, integrity, or availability of ePHI, including a successful security incident.
The Department proposes this new requirement to better enable regulated entities to ensure the confidentiality, integrity, and availability of all ePHI that they create, receive, maintain, or transmit. The general rules require regulated entities to not only prevent threats and hazards to the confidentiality and integrity of ePHI, but also to ensure the availability of ePHI, even during a security incident that has the potential to severely hinder the ability of a regulated entity to provide health care or to bring it to a standstill. This new factor would require a regulated entity to consider whether a particular approach to complying with a standard and the associated implementation specifications can help it recover from an emergency or other occurrence, in addition to maintaining operations throughout the event. The Department proposes this factor to complement its proposals to strengthen the standards for security incident procedures \ [428\]
and contingency planning \ [429\]
and proposals for new standards for patch management \ [430\]
and vulnerability management,\ [431\]
discussed in detail below. If finalized, these proposals would help to ensure that regulated entities put in place the necessary measures to implement these standards.
The factors contemplate that regulated entities will regularly evaluate the security measures they have applied to comply with the standards and implementation specifications based on the technology available and known risks and vulnerabilities at the time of the evaluation. The Department expects that when the existing factors are considered with the factor proposed in this NPRM, a regulated entity would be required to consider whether a specific technical control has become sufficiently ubiquitous such that choosing not to adopt it would be unreasonable.
#### c. Section 164.306(c)—Standards and Implementation Specifications
To address the Department's concerns regarding the apparent misunderstanding by regulated entities of “addressable,” we propose to modify 45 CFR 164.306(c)) and (d)) by collapsing the separate paragraphs into one paragraph (c) to address both standards and implementation specifications and to remove the distinction between “addressable” and “required” implementation specifications. Instead, proposed paragraph (c), if adopted, would require regulated entities to comply with both the standards and implementation specifications. The Department believes that eliminating the distinction would make clear to regulated entities what has always been a requirement—that the Security Rule sets a floor for cybersecurity protections and that its flexibility is in allowing them to choose the manner in which they meet the standards and implementation specifications, not whether they meet them. The proposed change also would be consistent with NCVHS' recommendation to require regulated entities to meet certain minimum cybersecurity hygiene requirements.\ [432\]
The Department acknowledges that proposing to remove the addressability distinction is a change from the approach adopted in the 2003 Final Rule. At that time, we explained that the decision to include addressable implementation specifications was made to provide additional flexibility to
( printed page 934)
covered entities.\ [433\]
In this rulemaking, the Department proposes to strengthen protections and address evolving cybersecurity threats. While we acknowledge that this proposal would reduce the Security Rule's flexibility, we believe that it is necessary to do so to achieve HIPAA's purpose of an efficient and effective health care system that relies on the secure electronic exchange of ePHI. Importantly, removing the distinction between required and addressable would not eliminate all of the Security Rule's flexibility and scalability. Instead, it would simply clarify for regulated entities where the floor of protection must lie, and regulated entities must implement solutions that meet that floor, taking into consideration their needs and capabilities. For example, a small or rural health care provider must implement a solution that ensures the protection of ePHI in the manner required by the Security Rule, but the specific solution that it chooses would reflect consideration of its particular circumstances, including available resources. In some cases, a small or rural health care provider might opt to implement a cloud-based EHR or other software solution that could reduce the health care provider's need to separately invest in data storage, backup systems, and IT personnel. And in other circumstances, a small or rural health care provider might choose to contract with a third party to provide IT support, rather than hiring its own workforce members to perform such functions.
The Department also proposes to delete the maintenance provision at 45 CFR 164.306(e)). Instead, as discussed in greater detail below, we propose to clearly delineate maintenance implementation specifications for specific standards, when applicable. We believe this approach would clarify how maintenance requirements relate to specific security measures and would remove any ambiguity about the need for regulated entities to regularly review, test, and modify measures as reasonable and appropriate. We further discuss maintenance provisions below for each safeguard.
#### 4\. Request for Comment
The Department requests comment on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. Whether removing the distinction between required and addressable implementation specifications would result in unintended negative consequences for regulated entities. If so, please explain and provide a recommendation for how the Department should clarify how regulated entities are required to implement the security measures described in the proposed rule.
b. Whether the Department should include other factors in 45 CFR 164.306(b)) for regulated entities to consider when selecting the security measures that they will implement to meet the requirements of the Security Rule. If so, please explain.
c. Whether the factor proposed by the Department at proposed 45 CFR 164.306(b)(2)(v)(2)(v)) would help regulated entities identify reasonable and appropriate security measures.
d. Whether the Department's proposals sufficiently clarify that a regulated entity is expected to modify its security measures in response to changes in the environment in which health care is provided, including, but not limited to, the adoption of new technology, the evolution of existing technology, and the emergence of new threats.
e. Whether the proposals sufficiently take into account the needs and capabilities of small health care providers and rural health care providers, as required by the statute. If not, please explain and include a recommendation for ways that the Department could better account for such needs and capabilities while adequately ensuring the confidentiality, integrity, and availability of ePHI that they create, receive, maintain, or transmit. The recommendations should also take into consideration the effect of the actions taken by small and rural health care providers on the ePHI that is created, received, maintained, or transmitted by other regulated entities with whom small and rural health care providers interact.
### D. Section 164.308—Administrative Safeguards
Section 164.308 of title 45 CFR contains the administrative safeguards that a regulated entity must implement, consistent with the general requirements described in 45 CFR 164.306. All of the standards and implementation specifications found in the Administrative Safeguards section refer to administrative functions, such as policies and procedures that must be in place for the management and execution of security measures.
#### 1\. Current Provisions
#### a. Section 164.308(a)
Section 164.308(a) contains most of the standards and associated implementation specifications that are categorized as administrative safeguards. The standards for administrative safeguards are as follows:
- Security management process.
- Assigned security responsibility.
- Workforce security.
- Information access management.
- Security awareness and training.
- Security incident procedures.
- Contingency plan.
- Evaluation.
The standard for security management process at 45 CFR 164.308(a)(1)(i)(1)(i)) requires regulated entities to implement policies and procedures to prevent, detect, contain, and correct security violations. The Security Rule directs regulated entities as to how they are to comply with the standard for security management process through four implementation specifications. Section 164.308(a)(1)(ii)(A) requires regulated entities to conduct a risk analysis that accurately and thoroughly assesses potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI they hold. The implementation specification for risk management at 45 CFR 164.308(a)(1)(ii)(B)(1)(ii)(B)) requires regulated entities to implement measures to reduce risks and vulnerabilities, such as those identified in the risk analysis, to a reasonable and appropriate level. Under 45 CFR 164.308(a)(1)(ii)(C)(1)(ii)(C)), regulated entities are required to apply appropriate sanctions against workforce members who fail to comply with applicable security policies and procedures, while the implementation specification for information system activity review at 45 CFR 164.308(a)(1)(ii)(D)(1)(ii)(D)) requires regulated entities to implement procedures to regularly review information system activity records.
The standard for assigned security responsibility at 45 CFR 164.308(a)(2)(2)) requires regulated entities to identify a security official who is responsible for the development and implementation of the policies and procedures that are required by this section. There are no implementation specifications associated with this standard.
Section 164.308(a)(3)(i) contains the standard for workforce security and requires regulated entities to implement policies and procedures to ensure that their workforce members have appropriate access to ePHI, which includes preventing workforce members who do not have authorized access from
( printed page 935)
obtaining it. The implementation specifications associated with this standard address the need to implement certain procedures regarding workforce member access to ePHI. Section 164.308(a)(3)(ii)(A) addresses the implementation of procedures for the authorization and/or supervision of workforce members who work with ePHI or in locations where it might be accessed. The implementation specification for workforce clearance procedure at 45 CFR 164.308(a)(3)(ii)(B)(3)(ii)(B)) addresses the implementation of procedures to determine that a workforce member's access to ePHI is appropriate, while 45 CFR 164.308(a)(3)(ii)(C)(3)(ii)(C)) addresses the implementation of procedures for terminating a workforce member's access to ePHI when their employment or similar arrangement ends or as required by the regulated entity's workforce clearance procedures.
Under 45 CFR 164.308(a)(4)(i)(4)(i)), the standard for information access management, a regulated entity is required to implement policies and procedures for authorizing access to ePHI in a manner that is consistent with the requirements of the Privacy Rule, that is, only when such access is appropriate based on the user or recipient's role (
_i.e.,_
“role-based access”). This interpretation is consistent with the Privacy Rule's standard that limits most uses and disclosures of PHI to the “minimum necessary” to accomplish the purpose of the use or disclosure.\ [434\]
The standard for information access management has three implementation specifications: paragraph (a)(4)(ii)(A) requires a health care clearinghouse that is part of a larger organization to implement policies and procedures to protect ePHI from unauthorized access by that organization; paragraph (a)(4)(ii)(B) addresses implementation of policies and procedures for granting access to ePHI, for example, through a workstation, program, or other mechanism; and paragraph (a)(4)(ii)(C) addresses the implementation of policies and procedures that, based on the regulated entity's access authorization policies, establish, document, review, and modify a user's right of access to a workstation, program, or other process.
Section 164.308(a)(5)(i) contains the standard for security awareness and training. This standard requires a regulated entity to implement a security awareness and training program for all workforce members, including management. There are four associated implementation specifications that address the need for regulated entities to implement the following:
- Periodic security updates.\ [435\]
- Procedures for guarding against, detecting, and reporting malicious software.\ [436\]
- Procedures for monitoring log-in attempts and reporting discrepancies.\ [437\]
- Procedures for creating, changing, and safeguarding passwords.\ [438\]
The standard for security incident procedures at 45 CFR 164.308(a)(6)(i)(6)(i)) requires a regulated entity to implement policies and procedures to address security incidents. The one implementation specification associated with this standard, 45 CFR 164.308(a)(6)(ii)(6)(ii)), requires regulated entities to identify and respond to suspected or known security incidents; to mitigate, to the extent practicable, harmful effects of security incidents that are known to the regulated entity; and to document security incidents and their outcomes.
Under the standard for contingency planning at 45 CFR 164.308(a)(7)(i)(7)(i)), a regulated entity is required to establish, and implement as needed, policies and procedures for responding to an emergency or other occurrence that damages systems that contain ePHI. The standard includes five implementation specifications at 45 CFR 164.308(a)(7)(ii)(7)(ii)). The first, paragraph (a)(7)(ii)(A), requires a regulated entity to establish and implement procedures to create and maintain exact copies of ePHI that are retrievable.\ [439\]
Paragraph (a)(7)(ii)(B) requires a regulated entity to establish, and implement as needed, procedures to restore any lost data.\ [440\]
Paragraph (a)(7)(ii)(C) requires a regulated entity to establish, and implement as needed, procedures to enable continuation of critical business processes for protecting the security of ePHI while the regulated entity is operating in emergency mode. Paragraph (a)(7)(ii)(D) addresses the implementation of procedures for periodic testing and revision of contingency plans, and paragraph (a)(7)(ii)(E) addresses the assessment of the relative criticality of specific applications and data in support of other contingency plan components.
The standard for evaluation at 45 CFR 164.308(a)(8)(8)) requires a regulated entity to periodically perform a technical and nontechnical evaluation that establishes the extent to which the regulated entity's security policies and procedures meet the requirements of the Security Rule. The initial evaluation is to be based upon the standards implemented under the Security Rule, while subsequent evaluations are to be conducted in response to environmental or operational changes affecting the security of ePHI.
#### b. Section 164.308(b)
Section 164.308(b) contains the administrative safeguards that apply to the relationships between regulated entities. Specifically, 45 CFR 164.308(b)(1)(1)) permits a covered entity to engage a business associate to create, receive, maintain, or transmit ePHI on the covered entity's behalf when it obtains satisfactory assurances (consistent with the organizational requirements for business associate agreements or other arrangements in 45 CFR 164.314(a))) that the business associate will appropriately safeguard the ePHI. Similarly, under 45 CFR 164.308(b)(2)(2)), a business associate may retain a subcontractor to create, receive, maintain, or transmit ePHI on its behalf if the business associate obtains satisfactory assurances through a business associate agreement or other arrangement that the subcontractor will appropriately safeguard the information. Section 164.308(b)(3) requires that the contract or other arrangement be in writing.\ [441\]
#### 2\. Issues To Address
The Security Rule administrative standards are comprehensive, but our experience has demonstrated that they have been misunderstood by some regulated entities, especially regarding how compliance with the standards and implementation specifications must be integrated with the general requirements in 45 CFR 164.306, including the requirement in 45 CFR 164.306(e)) that a regulated entity must review and modify security measures. Section 164.306 does not explicitly reference specific security measures, and we are concerned that recent caselaw has highlighted conditions that may cause regulated entities to misinterpret regulatory text that connects the maintenance provision at 45 CFR 164.306(e)) with the documentation requirements in 45 CFR 164.316 and the administrative safeguards. Through OCR's educational and enforcement efforts, we also have observed inadequacies in compliance with security management processes. For example, some regulated entities have
( printed page 936)
incorrectly interpreted the standards to not require implementing administrative safeguards, such as risk analyses, for all relevant electronic information systems. Some regulated entities have not documented in writing their policies, procedures, plans, and analyses.\ [442\]
As discussed above, many mistakenly treated “addressable” implementation standards as optional.\ [443\]
Enforcement experience has shown that regulated entities generally do not perform all elements of the risk management process that are fundamental to protecting the confidentiality, integrity, and availability of ePHI and to cybersecurity more broadly.
In addition, since the Security Rule was issued in 2003 and revised in 2013, newer, more protective security technology has become widely available to regulated entities, and best practices for securing electronic information have evolved. NIST has published numerous guides, including its recent Cybersecurity Framework 2.0, providing resources for establishing and implementing policies and practices to better manage cybersecurity risks.\ [444\]
OCR is drawing upon its enforcement experience, as well as best practices, guidelines, processes, and procedures for improving cybersecurity to propose changes to these standards to better protect ePHI that a regulated entity creates, receives, maintains, or transmits. We believe that these proposals would help ensure that regulated entities implement compliance activities that are consistent with recommendations made by NIST, the HHS 405(d) program, and standards setting bodies regarding cybersecurity.
Because business associates are directly liable for compliance with the Security Rule, in our 2013 Security Rule revisions we did not require covered entities to implement any additional safeguards to ensure that their business associate is in fact in compliance.\ [445\]
However, OCR has learned through its enforcement experience that many covered entities have entrusted ePHI to business associates that are not employing appropriate safeguards. Some business associates have such market power that covered entities may believe they have no alternative to using their services, even if they have concerns about the safeguards employed by the business associate. The Department is concerned by the breaches experienced by business associates and the effects of such breaches on the confidentiality, integrity, and availability of ePHI.\ [446\]
#### 3\. Proposals
#### a. Section 164.308—Administrative Safeguards
Throughout this section, the Department proposes to add explicit maintenance requirements to certain standards to address concerns that regulated entities may be misinterpreting the regulatory text that connects the maintenance provision at 45 CFR 164.306(e)) with the administrative safeguards. These proposals would clarify that a regulated entity is required to maintain certain security measures, and that where a regulated entity is required to maintain a particular security measure, it is required to review and test such measure on a specified cadence, and to modify the measure as reasonable and appropriate. Testing of particular security measures, such as technical controls or policies and procedures, would include verifying that the security measures work as designed and that workforce members know how to implement them. For example, written policies and procedures can be tested through various methods including, but not limited to: simulating security events that mimic real-world attacks to assess how effectively employees follow incident response and security procedures; conducting knowledge assessments after training on policies and procedures; and reviewing system logs and access records to evaluate whether policies and procedures governing access to ePHI are being followed. We would expect a regulated entity to take the results of the required tests into consideration when determining whether it is reasonable and appropriate to modify its security measures, as well as the actions that would be expected of a regulated entity that is similarly situated based on the results of such tests.
We also propose to modify certain administrative safeguards to clarify the obligations of a regulated entity to ensure the confidentiality, integrity, and availability of ePHI by securing its relevant electronic information systems—that is, its electronic information systems that create, receive, maintain, or transmit ePHI and those that otherwise affect its confidentiality, integrity, or availability—and the technology assets in its relevant electronic information systems.
#### b. Section 164.308(a)
The Department proposes to modify the general language at 45 CFR 164.308(a)) to clarify the connection between the general rules for security standards at 45 CFR 164.306, the standards for policies and procedures and documentation requirements at 45 CFR 164.316, and the standards for the administrative safeguards under 45 CFR 164.308(a)). We also propose to clarify that regulated entities would be required to implement all of the administrative safeguards of the Security Rule to protect the confidentiality, integrity, or availability of all ePHI that they create, receive, maintain, or transmit. Thus, when read together, proposed 45 CFR 164.308(a)) and 164.316(a)) would require that a regulated entity implement and document, in writing, its implementation of the administrative safeguards required by the Security Rule. These requirements set the baseline for administrative safeguards. Nothing in this NPRM would prevent a regulated entity from implementing additional administrative safeguards, provided that those additional safeguards do not conflict with any requirements in the Security Rule.
The proposed changes are discussed in greater detail below.
#### c. Section 164.308(a)(1)(i)—Standard: Technology Asset Inventory
We propose to modify 45 CFR 164.308(a)(1)(1)) by elevating to standard-level status the existing implementation specifications for the standard for security management process at 45 CFR 164.308(a)(1)(ii)(A)(1)(ii)(A)) through (D)(1)(ii)(D)), and deleting the existing standard. Doing so would highlight the importance of these elements and permit us to add implementation specifications that detail our expectations for compliance with those elements. We believe that providing more specificity in our requirements would help regulated entities better understand their compliance responsibilities for
( printed page 937)
safeguarding ePHI. These proposals are consistent with current guidance, as described below.
In place of the existing standard for security management process, we propose a standard at 45 CFR 164.308(a)(1)(i)(1)(i)) that would require a regulated entity to conduct and maintain an accurate and thorough written technology asset inventory and a network map of its electronic information systems and all technology assets that may affect the confidentiality, integrity, or availability of ePHI. The inventory forms the foundation for a fulsome and accurate risk analysis. A regulated entity must identify its information systems that create, receive, maintain, or transmit ePHI and all technology assets, as we propose to define them in 45 CFR 164.304, that may affect ePHI in such information systems in order to secure them. Regulated entities cannot understand the risks to the confidentiality, integrity, and availability of their ePHI without a complete understanding of these assets. We believe that this proposal would clarify compliance expectations and provide increased protections for the confidentiality, integrity, and availability of ePHI. Consistent with practices previously highlighted in guidance, regulated entities would be required by this proposal to conduct and maintain an accurate and thorough written inventory of technology assets.
The standard would also require each regulated entity to determine the movement of ePHI through, into, and out of its information systems and to describe such movement in a network map. A regulated entity's network map would reflect where its technology assets are, for example, physically located at the regulated entity's worksite, or accessed through the cloud. As another example, a covered entity might determine that ePHI is created, received, maintained, or transmitted by one or more offshore business associates (
_i.e.,_
persons that are located outside of the U.S.) for such services as claims processing, call center staffing, and technical support, activities that inherently involve ePHI. The technology assets used by the business associate to create, receive, maintain, or transmit ePHI are not a part of the covered entity's electronic information system, but do affect the confidentiality, integrity, or availability of ePHI and so would be required to be included in the network map of the covered entity.\ [447\]
Such assets would be considered part of the business associate's electronic information systems and therefore would need to be included in both its technology asset inventory and network map. Any technology assets used by the covered entity to create, receive, maintain, or transmit ePHI to the business associate would need to be accounted for in both its technology asset inventory and network map. Such technology assets would not be part of the business associate's technology asset inventory, but would need to be included on its network map.
This proposed standard aligns with the Department's enhanced CPG for Asset Inventory, which requires that a regulated entity identify assets to more rapidly detect and respond to potential risks and vulnerabilities,\ [448\]
and is consistent with NCVHS' recommendation to require regulated entities to identify where all PHI is stored and to collect data on applications and systems used by the organization to create a systems inventory.\ [449\]
In 2003, the Department elected not to require regulated entities to conduct an inventory because we believed that regulated entities would understand that such an inventory is a vital component of the risk analysis, making it redundant of other requirements of the Security Rule.\ [450\]
The Department and NIST have provided extensive guidance, described below, about how to conduct such inventories as part of compliance with 45 CFR 164.308. However, nearly 20 years of enforcement experience indicates that regulated entities routinely disregard this part of the process. OCR's investigations frequently find that organizations lack sufficient understanding of where all the ePHI entrusted to their care is located.\ [451\]
Understanding one's environment—particularly how ePHI is created and enters an organization, how ePHI flows through an organization, and how ePHI leaves an organization—is crucial to understanding the risks ePHI is exposed to throughout an organization.\ [452\]
According to the NIST Cybersecurity Framework 2.0, having a comprehensive understanding of the organization's assets (
_e.g.,_
data, hardware, software, systems, facilities, services, people), suppliers, and related cybersecurity risks enables a regulated entity to prioritize its efforts consistent with its risk management strategy and its mission needs.\ [453\]
The proposed standard would be accompanied by three implementation specifications. Under the proposed implementation specification for inventory at proposed 45 CFR 164.308(a)(1)(ii)(A)(1)(ii)(A)), the regulated entity would be required to establish a written inventory that contains the regulated entity's technology assets. Technology assets are components of an electronic information system, including but not limited to hardware, software, electronic media, information, and data. The written inventory would be required to include technology assets that create, receive, maintain, or transmit ePHI and those that do not but that may affect the confidentiality, integrity, or availability of ePHI.\ [454\]
It would also be required to include the identification, version, person accountable for, and location of each of the assets or information system components.\ [455\]
The proposed implementation specification for network map at proposed 45 CFR 164.308(a)(1)(ii)(B)(1)(ii)(B)) would require a regulated entity to develop a network map that illustrates the movement of ePHI throughout its electronic information systems, including but not limited to how ePHI enters and exits such information systems, and is accessed from outside of such information systems.
Under the proposed implementation specification for maintenance at proposed 45 CFR 164.308(a)(1)(ii)(C)(1)(ii)(C)), a regulated entity would be required to review and update the written inventory of technology assets and the network map in the following circumstances: (1) on an ongoing basis, but at least once every 12 months; and (2) when there is a change in the regulated entity's environment or operations that may affect ePHI. Such a change in the
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regulated entity's environment or operations would include, but would not be limited to, the adoption of new technology assets; the upgrading, updating, or patching of technology assets; newly recognized threats to the confidentiality, integrity, or availability of ePHI; a sale, transfer, merger, or consolidation of all or part of the regulated entity with another person; a security incident that affects the confidentiality, integrity, and availability of ePHI; and relevant changes in Federal, State, Tribal, or territorial law. For example, a dissolution or bankruptcy of the regulated entity would require the regulated entity to review and update its inventory and network map. For another example, if a State implemented regulations specifying cybersecurity requirements for all hospitals, these proposed specifications would require a regulated entity in that State to review and update its inventory and network map considering implementation of the State regulations by the regulated entity or other persons whose activities may affect movement of ePHI throughout its electronic information systems.\ [456\]
The proposed standard is consistent with the NIST Cybersecurity Framework Identify function, Asset Management (ID.AM) category, which describes inventorying hardware and software and mapping communication and data flows to create and maintain an asset inventory that can be used in a risk analysis process. For example, the Cybersecurity Framework recommends that when creating an asset inventory, organizations should include all of the following, as applicable:
- Hardware assets that comprise physical elements, including electronic devices and media, that make up an organization's networks and systems. This may include mobile devices, servers, peripherals ( _e.g.,_
printers, USB hubs), workstations, removable media, firewalls, and routers.
- Software assets that are programs and applications that run on an organization's electronic devices. Well-known software assets include anti-malicious software tools, operating systems, databases, email, administrative and financial records systems, electronic medical/health record systems, and clinical decision support tools, including those that rely on AI. Though lesser known, there are other programs important to IT operations and security such as backup solutions, and other administrative tools that also should be included in an organization's inventory.
- Data assets that include ePHI that an organization creates, receives, maintains, or transmits on its network, electronic devices, and media. How ePHI is used and flows through an organization is important to consider as an organization conducts its risk analysis.\ [457\]
Where multiple persons have control over a technology asset, all persons that have control should include the asset in both their technology asset inventories and on their network maps. For example, where a covered entity contracts with a cloud-based EHR vendor, both the covered entity and the EHR vendor have control over the ePHI in the EHR. Thus, the ePHI in the EHR and the EHR should be included in the technology asset inventories and network maps of both the covered entity and the cloud-based EHR vendor. Where the technology assets are controlled entirely by another person, such as the servers controlled by a cloud-based provider of data backup services, the technology assets would not be considered part of a health care provider's electronic information systems, and therefore would not have to be included in its technology asset inventory. However, the data backup provider would have to be included in the health care provider's network map.
When creating or maintaining a technology asset inventory that can aid in identifying risks to ePHI, regulated entities should consider their technology assets that may not create, receive, maintain or transmit ePHI, but that may affect technology assets that do so.\ [458\]
Assets within an organization that do not create, receive, maintain, or transmit ePHI may still present opportunities for intruders to enter the regulated entity's electronic information systems, which could lead to risks to the confidentiality, integrity, or availability of an organization's ePHI. For example, consider a smart device that is connected to the internet (
_e.g.,_
connected to the Internet of Things \ [459\]
(IoT)) and provides access to facilities for maintenance personnel to control and monitor an organization's heating, ventilation, and air conditioning (HVAC). Although it may not maintain or process ePHI, such a device potentially can present serious risks to the security of ePHI in an organization's information systems. Unpatched IoT devices with known vulnerabilities, such as weak or unchanged default passwords installed on a network without firewalls, network segmentation, or other techniques that deny or impede an intruder's lateral movement, can provide an intruder with access to an organization's relevant electronic information systems. The intruder may then leverage this access to conduct reconnaissance and further penetrate an organization's network and potentially compromise ePHI.
The risks and deficiencies OCR has observed in its enforcement experience persuades us that we must consider adding an express requirement for a regulated entity to conduct an accurate and thorough written inventory of its technology assets and create a network map.
#### d. Section 164.308(a)(2)(i)—Standard: Risk Analysis
After a regulated entity conducts a written inventory of its technology assets and creates its network map, it is critical for it to identify the potential risks and vulnerabilities to its ePHI. Conducting a risk analysis is necessary to adequately protect the confidentiality, integrity, and availability of ePHI because it provides the basis for determining the manner in which the regulated entity will comply with and carry out the other standards and implementation specifications in the Security Rule.\ [460\]
Basic questions that a regulated entity would consider when conducting a risk analysis that is compliant with the Security Rule include: \ [461\]
- Have you identified all the ePHI that you create, receive, maintain, or transmit?
- What are the external sources of ePHI? For example, do vendors or consultants create, receive, maintain, or transmit ePHI?
- What are the human, natural, and environmental threats to information systems that contain ePHI?
( printed page 939)
- What are the risks posed by legacy devices, including any risks that would be posed by replacing legacy devices with new ones?
There are numerous methods of performing a risk analysis, and there is no single method or “best practice” that guarantees compliance with the Security Rule.\ [462\]
The Department has issued multiple guidance documents and tools for regulated entities to help them implement risk analyses,\ [463\]
and several versions of its Security Risk Assessment Tool, a desktop application that walks users through the process of conducting a risk assessment.\ [464\]
NIST has published numerous guides for risk assessment over the past two decades,\ [465\]
in addition to reference materials it has developed in collaboration with the Department, including a toolkit and a crosswalk between the Security Rule to NIST Cybersecurity Framework,\ [466\]
and “how to” guides on risk analysis.\ [467\]
In February 2024, NIST released a new guide that provides resources for implementing a Security Rule risk analysis.\ [468\]
Consistent with previous Department guidance, the guide describes key elements in a comprehensive risk assessment process, that include the following:
- Prepare for the assessment by conducting a technology asset inventory.\ [469\]
Determine whether ePHI is transmitted to external third parties, such as cloud service providers or others. The regulated entity can also examine how access to ePHI is controlled and whether ePHI is encrypted at rest and in transit. The scope of a risk assessment should include both the physical boundaries of a regulated entity's location and a logical boundary that includes any devices or media that contain ePHI, including electronic networks through which ePHI is transmitted, regardless of its location.
- Identify reasonably anticipated threats. The list of threat events and threat sources should include reasonably anticipated and probable human and natural incidents that can negatively affect the regulated entity's ability to protect ePHI. The information gathered for the technology asset inventory should be used to identify reasonably anticipated threats to ePHI.
- Identify potential vulnerabilities and predisposing conditions. For any of the various threats identified above to result in a significant risk, each needs a vulnerability or predisposing condition that can be exploited. While it is necessary to review threats and vulnerabilities as unique elements, they are often considered at the same time. Organizations should consider a given loss scenario and evaluate both, such as what threat sources might initiate which threat events or what vulnerabilities or predisposing conditions those threat sources might exploit to cause an adverse effect. From this, the regulated entity should develop a list of vulnerabilities ( _i.e.,_
flaws or weaknesses) that could be exploited by potential threat sources.
- Determine the likelihood that a threat would exploit a vulnerability. For each threat event/threat source identified, a regulated entity should consider: the likelihood that the threat would occur and the likelihood that an occurred threat would exploit an identified vulnerability and result in an adverse effect. A regulated entity might consider assigning a likelihood value ( _e.g.,_
“very low,” “low,” “moderate,” “high,” or “very high”) to each threat/vulnerability pairing. As an example, the regulated entity may determine that the likelihood of a phishing attack occurring is very high and that the likelihood of the event exploiting a human vulnerability is moderate, resulting in an overall likelihood rating of high.
- Determine the impact of a threat exploiting a vulnerability. As with likelihood determination, a regulated entity may choose to express this effect in qualitative terms or use any other scale that the entity chooses. When selecting an impact rating, the regulated entity may consider how the threat event can affect the loss or degradation of the confidentiality, integrity, or availability of ePHI. Some tangible impacts can be measured quantitatively in terms of lost revenue, the cost of repairing the system, or the level of effort required to correct problems caused by a successful threat action. Other impacts cannot be measured in specific units ( _e.g.,_
the loss of public confidence, the loss of credibility, or damage to an organization's interests), but they can be qualitatively described.
- Determine the level of risk to ePHI while considering the information gathered and determinations made during the previous steps. The level of risk is determined by analyzing the values assigned to the overall likelihood of threat occurrence and the resulting impact of threat occurrence.
- Document the risk assessment results. Once the risk assessment has been completed as described above, the results of the risk assessment should be documented. Principally, the regulated entity should document all threat/vulnerability pairs ( _i.e.,_
a scenario in which an identified threat can exploit a vulnerability) applicable to the organization, the likelihood and impact calculations, and the overall risk to ePHI for the threat/vulnerability pair. Regulated entities should consider sharing the risk assessment results with organizational leadership, whose review can be crucial to the organization's ongoing risk management.
The Department has also published guidance that explains the differences between a risk analysis and a gap analysis, and the use of both in an entity's risk management program.\ [470\]
While a risk analysis is a comprehensive identification of risks and vulnerabilities to all ePHI, a gap analysis typically provides a partial assessment of an entity's enterprise and is often used to provide a high-level overview of what safeguards are in place (or missing) and may also be used to review a regulated entity's compliance with particular standards and implementation specifications of the Security Rule.
Other NIST guidance on conducting risk assessments explains that the result of a risk analysis is a determination of risk posed to the regulated entity's ePHI and related information systems.
\ [471\]
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Consistent with the discussion above, a key step is determining the risk level posed to such ePHI by threats and vulnerabilities and how critical it is to address and mitigate the identified risk. In general, the descriptive words “very high” or “critical” are used to indicate that a threat event could be expected to have multiple severe or catastrophic adverse effects on organizational operations, organizational assets, individuals, other organizations, or the country.\ [472\]
A “high” risk would indicate that a threat event could be expected to have a severe or catastrophic adverse effect on the same, while a “moderate” risk could indicate that the threat event could have a serious adverse effect on the same. Risks that are “low” and “very low” could be expected to have a limited and negligible effect, respectively, on organizational operations or assets, individuals, other organizations, or the country.
The Department believes that determinations of risk level and criticality may vary based on the specific type of regulated entity and the regulated entity's specific circumstances. For example, a health care provider must consider the higher levels of risks to physical and technical security that are created by regular entry and exit of individuals seeking health care and other members of the public into its facilities, creating potentially numerous avenues for access to ePHI through technology assets; in contrast, a health plan that generally does not permit physical entry by individuals into its office building may determine that the risks to ePHI from physical entry by individuals or other members of the public is low because its workforce members do not generally physically interact with the public. As another example, a vulnerability permitting unauthenticated remote code execution on a device connected to a regulated entity's relevant electronic information systems would likely constitute either a high or critical risk. However, should such a device not have the ability to connect to the network, the risk might be low or moderate because the likelihood of triggering a network vulnerability on a non-networked device is low, even though the impact of such trigger might be high. Thus, it is essential that a regulated entity consider its specific circumstances when assessing the criticality of a risk and to address such risks in a manner that is appropriate to its specific facts and circumstances.\ [473\]
In yet another example, a regulated entity in possession of legacy devices or devices that are nearing the end of their lifespan should assess the risks associated with continued use of such devices as part of its risk analysis and ensure that replacement of such devices and/or the implementation of compensating controls are included in its risk management plan.
Despite our having made available an abundance of free and widely-publicized guidance tools, OCR unfortunately has learned through its compliance and enforcement activities that regulated entities often do not perform compliant risk analyses. As discussed above, in 2016 and 2017, the Department conducted audits of 166 covered entities and 41 business associates for their compliance with selected provisions of the HIPAA Rules.\ [474\]
These audits confirmed that only small percentages of covered entities (14 percent) and business associates (17 percent) were substantially fulfilling their regulatory responsibilities to safeguard ePHI they hold through risk analysis activities. Entities generally failed to:
- Identify and assess the risks to all of the ePHI in their possession or even develop and implement policies and procedures for conducting a risk analysis.
- Identify threats and vulnerabilities to consider their potential likelihoods and effects, and to rate the risk to ePHI.
- Review and periodically update a risk analysis in response to changes in the environment and/or operations, security incidents, or occurrence of a significant event.
- Conduct risk analyses consistent with policies and procedures.
Failing to document any efforts to develop, maintain, and update policies and procedures for conducting risk analyses was common. For example, health care providers commonly submitted documentation of some security activities performed by a third-party security vendor, without submitting documentation of any risk analysis that served as the basis of such activities.\ [475\]
Many regulated entities used and relied on outside persons to manage or perform risk analyses for their organizations; however, these outside persons frequently failed to meet the requirements of the Security Rule. Regulated entities also frequently and incorrectly assumed that a purchased security product satisfied all of the Security Rule's requirements.
The responsibility to maintain an appropriate risk analysis rests with the regulated entity. Accordingly, it is essential that regulated entities understand and comply with risk analysis requirements to appropriately safeguard PHI.
Numerous OCR investigations reflect the failure of regulated entities to develop and implement holistic risk analysis programs. For example, OCR's investigation of a health system in the aftermath of a ransomware attack found evidence of potential failures to: conduct a compliant risk analysis to determine the potential risks and vulnerabilities to ePHI in its systems; implement a contingency plan to respond to emergencies, like a ransomware attack, that damage systems that contain ePHI; and implement policies and procedures to allow only authorized users access to ePHI.\ [476\]
In another recently concluded investigation involving a large medical center, the covered entity reported that over a seven-month period, one of its employees inappropriately accessed the ePHI of more than 12,000 patients and then sold certain patient information to an identity theft ring.\ [477\]
OCR's investigation indicated potential violations of the requirement to conduct an accurate and thorough risk analysis of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of all of the ePHI held by the medical center, as well as the requirement at 45 CFR 164.308(a)(1)(ii)(D)(1)(ii)(D)) to implement procedures to regularly review records of information system activity, such as audit logs, access reports, and security incident tracking.
In another case, the OCR settled a ransomware cyberattack investigation with a business associate.\ [478\]
The cyberattack affected the ePHI of over
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200,000 individuals when the business associate's network server was infected with ransomware. It took the company more than 18 months to detect the intrusion, and they only did so when the ransomware was used by the intruder to encrypt the company's files. Among other factors, OCR's investigation found evidence of potential failures to conduct an accurate and thorough risk analysis and to implement procedures to regularly review records of information system activity, such as audit logs, access reports, and security incident tracking reports.
Given the compliance deficiencies that OCR regularly sees—those cited as examples and what OCR has observed more broadly—we believe that stronger requirements coupled with greater specificity regarding the components of a risk analysis would help and encourage regulated entities to appropriately perform such activities. Accordingly, the Department proposes to elevate the requirement to conduct a risk analysis from an implementation specification at 45 CFR 164.308(a)(1)(ii)(A)(1)(ii)(A)) to a standard at proposed 45 CFR 164.308(a)(2)(i)(2)(i)). Under the proposal, and consistent with NCVHS' recommendations,\ [479\]
a regulated entity would be required to conduct an accurate and comprehensive written assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of all ePHI created, received, maintained, or transmitted by the regulated entity.
The Department proposes eight implementation specifications for the risk analysis standard, consistent with previously issued guidance described above. The proposed implementation specification for a written assessment at proposed paragraph (a)(2)(ii)(A) would require the regulated entity, at a minimum, to perform and document all of the following: \ [480\]
- Review the technology asset inventory and the network map to identify where ePHI may be created, received, maintained, or transmitted within its information systems.\ [481\]
- Identify all reasonably anticipated threats to the confidentiality, integrity, and availability of ePHI that it creates, receives, maintains, or transmits.\ [482\]
- Identify potential vulnerabilities and predisposing conditions to the regulated entity's relevant electronic information systems—that is, its electronic information systems that create, receive, maintain, or transmit ePHI or that otherwise affect the confidentiality, integrity, or availability of ePHI.\ [483\]
- Create an assessment and documentation of the security measures it uses to ensure that the measures protect the confidentiality, integrity, and availability of the ePHI created, received, maintained, or transmitted by the regulated entity.\ [484\]
- Make a reasonable determination of the likelihood that each identified threat would exploit the identified vulnerabilities.\ [485\]
For example, a regulated entity located on the west coast could consult actuarial tables to reasonably determine the likelihood that an earthquake would affect access to electrical power to maintain its relevant electronic information systems.
- Make a reasonable determination of the potential impact of each identified threat should it successfully exploit the identified vulnerabilities.\ [486\]
For example, the regulated entity described above could make a reasonable determination of how and the extent to which the lack of electrical power caused by an earthquake would affect the availability and integrity of ePHI in its relevant electronic information system.
- Create an assessment of risk level for each identified threat and vulnerability.\ [487\]
- Create an assessment of risks to ePHI posed by entering into or continuing a business associate agreement or other written arrangement with any prospective or current business associate, respectively, based on the written verification obtained from the prospective or current business associate.\ [488\]
Under the proposed implementation specification for maintenance at proposed 45 CFR 164.308(a)(2)(ii)(B)(2)(ii)(B)), a regulated entity additionally would be required to review, verify, and update the written assessment on an ongoing basis, but in any event no less frequently than at least once every 12 months, and in response to a change in the regulated entity's environment or operations that may affect ePHI. As discussed above, a change in the regulated entity's environment or operations that may affect ePHI would include, but would not be limited to, the adoption of new technology assets; the upgrading, updating, or patching of technology assets; newly recognized threats to the confidentiality, integrity, or availability of ePHI; a sale, transfer, merger, or consolidation of all or part of the regulated entity with another person; a security incident that affects the confidentiality, integrity, or availability of ePHI; and relevant changes in Federal, State, Tribal, or territorial law.
#### e. Section 164.308(a)(3)(i)—Standard: Evaluation
The Department proposes to redesignate the existing evaluation standard at 45 CFR 164.308(a)(8)(8)) as 45 CFR 164.308(a)(3)(i)(3)(i)) and to revise the redesignated evaluation standard to require the technical and nontechnical evaluation(s) to be in writing and performed to determine whether change in the regulated entity's environment or operations may affect the confidentiality, integrity, or availability of ePHI. Evaluating the effects of a potential change on a regulated entity's environment or operations, including the effects on the confidentiality, integrity, and availability of ePHI, is a critical step in the change control process. An evaluation serves a similar purpose to a risk analysis. However, while a risk analysis looks at the entirety of a regulated entity's enterprise regularly and in response to a change in the regulated entity's environment or operations, an evaluation looks at a specific change that a regulated entity intends to make before the change is made. Thus, this proposal, if adopted, would ensure that a regulated entity proactively considers whether any risks or vulnerabilities to ePHI or its relevant electronic information systems will be introduced by changes it intends to make to its environment or operations and responds by implementing appropriate safeguards in a timely fashion.\ [489\]
We also propose to delete the requirement that the evaluation be performed “based initially on the standards implemented under this rule” because an evaluation is performed to assess the effect(s) of a planned change on the environment, which can be observed when those effects are compared to the environment reflected in the risk analysis. Additionally, the Department proposes to add two implementation specifications at
( printed page 942)
proposed 45 CFR 164.308(a)(3)(ii)(3)(ii)). The proposed implementation specification for performance at proposed 45 CFR 164.308(a)(3)(ii)(A)(3)(ii)(A)) would require that a regulated entity conduct the evaluation within a reasonable period of time before making a change to its environment or operations, while the proposed implementation specification for response at proposed 45 CFR 164.308(a)(3)(ii)(B)(3)(ii)(B)) would require a regulated entity to respond to the evaluation in accordance with its risk management plan.
A change in the regulated entity's environment or operations would include, but would not be limited to, the adoption of new technology assets; the upgrading, updating, or patching of technology assets; newly recognized threats to the confidentiality, integrity, or availability of ePHI; a sale, transfer, merger or consolidation of all or part of the regulated entity with another person; a security incident that affects the confidentiality, integrity, or availability of ePHI; and relevant changes in Federal, State, Tribal, and territorial law.
NIST guidance provides descriptions of key activities and sample questions that would help regulated entities meet this evaluation standard.\ [490\]
They include:
- Determine whether internal or external evaluation is most appropriate. Which staff has the technical experience and expertise to evaluate the systems? If an outside vendor is used, what factors should be considered when selecting the vendor, such as credentials and experience?
- Develop standards and measurements for reviewing all standards and implementation specifications of the Security Rule. Have management, operational, and technical issues been considered? Do the elements of each evaluation procedure ( _e.g.,_
questions, statements, or other components) address individual, measurable security safeguards for ePHI?
- Conduct an evaluation. Has the process been formally communicated to those who have been assigned roles and responsibilities in the evaluation process? Has the organization explored the use of automated tools to support the process?
- Document results, including: each evaluation finding and remediation options, recommendations, and decisions; known gaps between identified risks, mitigating security controls, and any acceptance of risk, including justification; developed security program priorities and established targets for continuous improvement; use of evaluation results to inform security changes to protect ePHI; communication of evaluation results, metrics, and/or measurements to relevant organizational personnel.
- Repeat evaluations periodically. Establish the frequency of evaluations, repeating evaluations when environmental and operational changes that affect the security of ePHI are made ( _e.g.,_
if new technology is adopted or if there are newly recognized risks to the confidentiality, integrity, or availability of ePHI).
Despite the existing standard and the availability of guidance, many regulated entities do not evaluate how changes in their environment, such as a merger or acquisition or implementation of new technology, may affect the security of ePHI. In some instances, regulated entities assert that they have done so, but have no documentation of the purported evaluation. The Department believes that this proposal, if adopted, would clarify our expectations for implementing these safeguards.
#### f. Section 164.308(a)(4)(i)—Standard: Patch Management
As described in Department guidance, regulated entities can defend themselves from common cyberattacks, but hackers continue to target the health care industry in search of ways to access valuable ePHI.\ [491\]
Accordingly, timely implementation of patches for known vulnerabilities is crucial to maintaining the security of ePHI. Many cyberattacks could be prevented or substantially mitigated if regulated entities implemented activities to manage the implementation of patches, updates, and upgrades to comply with the Security Rule's requirements for risk management, which can deter one of the common types of attacks: exploitation of known vulnerabilities. If an attack is successful, the intruder often will encrypt a regulated entity's ePHI to hold it for ransom, or exfiltrate the data for future purposes including identity theft or blackmail. Cyberattacks are especially concerning in the health care sector because they can disrupt the provision of health care services. Exploitable vulnerabilities can exist in many parts of a regulated entity's information systems, but often, known vulnerabilities can be mitigated by applying vendor patches, updating software or system configurations, or upgrading to a newer version of the product. If a patch, update, or upgrade is unavailable, vendors often suggest actions to take, that is, compensating controls, to mitigate a newly discovered vulnerability. Such actions could include modifications of configuration files or disabling of affected services. Regulated entities should pay careful attention to cybersecurity alerts describing newly discovered vulnerabilities. These alerts often include information on mitigation activities and patching.
Risk management processes that are compliant with the Security Rule include identifying and mitigating risks and vulnerabilities that unpatched software poses to an organization's ePHI. Mitigation activities could include installing patches if patches are available and patching is reasonable and appropriate. In situations where patches are not available (
_e.g.,_
obsolete or unsupported software) or testing or other concerns weigh against patching as a mitigation solution,\ [492\]
regulated entities should implement reasonable compensating controls to reduce the risk of identified vulnerabilities to a reasonable and appropriate level (
_e.g.,_
restricting network access or disabling network services to reduce vulnerabilities that could be exploited via network access). Security vulnerabilities may be present in many types of software, including databases, EHRs, operating systems, email, and device firmware. Each type of program would have its own unique set of vulnerabilities and challenges for applying patches, but identifying and mitigating the risks unpatched software
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poses to ePHI is important to ensuring that ePHI is protected.\ [493\]
Although older applications or devices may no longer be supported with patches for new vulnerabilities, regulated entities must still take appropriate action if a newly discovered vulnerability affects an older application or device. If an obsolete, unsupported system cannot be upgraded or replaced, additional safeguards should be implemented or existing safeguards enhanced to mitigate known vulnerabilities until upgrade or replacement can occur (
_e.g.,_
increase access restrictions, remove or restrict network access, disable unnecessary features or services).\ [494\]
Patches can be applied to software and firmware on all types of devices—telephones, computers, servers, routers, and more. Installation of vendor-recommended patches is typically a routine process. However, regulated entities should be prepared if issues arise as a result of applying patches. Software and hardware are often interconnected and dependent on the functionality and output of other information systems or components of other information systems. When certain changes are made, including the installation of a patch, software dependent on the changed application may not perform as expected because settings or data may be affected. Thus, in complex environments, patch management plays a crucial role in the safe and correct implementation of these changes.\ [495\]
Enterprise patch management is the process of identifying, prioritizing, acquiring, installing, and verifying the installation of patches, updates, and upgrades throughout an organization.\ [496\]
NIST has issued a series of guidance documents that regulated entities can use to design their own patch management processes as part of their risk management plans.
Consistent with previously issued guidance, the discussion above, and recommendations from NCVHS,\ [497\]
the Department proposes a new standard for patch management at proposed 45 CFR 164.308(a)(4)(i)(4)(i)) that would require a regulated entity to implement written policies and procedures for applying patches and updating the configurations of its relevant electronic information systems. This proposed standard would ensure that a regulated entity is aware of its liability for appropriately safeguarding ePHI by installing patches, updates, and upgrades throughout its relevant electronic information systems.
The Department proposes six implementation specifications at proposed 45 CFR 164.308(a)(4)(ii)(4)(ii)) that would be associated with the proposed standard for patch management. The proposed implementation specification for policies and procedures at proposed paragraph (a)(4)(ii)(A) would require a regulated entity to establish written policies and procedures for identifying, prioritizing, acquiring, installing, evaluating, and verifying the timely installation of patches, updates, and upgrades throughout its electronic information systems that create, receive, maintain, or transmit ePHI or that otherwise affect the confidentiality, integrity, or availability of ePHI. Under the proposed implementation specification for maintenance at proposed paragraph (a)(4)(ii)(B), a regulated entity would be required to review its patch management written policies and procedures at least once every 12 months and modify them as reasonable and appropriate based on that review. The proposed implementation specification for application at proposed paragraph (a)(4)(ii)(C) would require a regulated entity to patch, update, and upgrade the configurations of its relevant electronic information systems in accordance with its written policies and procedures and based on the results of: the regulated entity's risk analysis that would be required by proposed 45 CFR 164.308(a)(2)(2)), the vulnerability scans that would be required under proposed 45 CFR 164.312(h)(2)(i)(2)(i)), the monitoring of authoritative sources that would be required under proposed 45 CFR 164.312(h)(2)(ii)(2)(ii)), and penetration tests proposed at 45 CFR 164.312(h)(2)(iii)(2)(iii)). The proposal would require that such actions be taken within a reasonable and appropriate period of time, except to the extent that an exception in proposed paragraph (h)(2)(ii)(D) applies. Specifically, a reasonable and appropriate period of time to patch, update, or upgrade the configuration of a relevant electronic information system would be within 15 calendar days of identifying the need to address a critical risk where a patch, update, or upgrade is available; or, where a patch, update, or upgrade is not available, within 15 calendar days of a patch, update, or upgrade becoming available. The proposal would require that, within 30 calendar days of identifying the need to address a high risk,\ [498\]
a regulated entity patch, update, or upgrade the configuration of a relevant electronic information system where a patch, update, or upgrade is available; or, where a patch, update, or upgrade is not available, within 30 calendar days of a patch, update, or upgrade becoming available. For all other patches, updates, or upgrades to the configurations of relevant electronic information systems, a reasonable and appropriate period of time would be determined by the regulated entity's written policies and procedures for identifying, prioritizing, acquiring, installing, evaluating, and verifying the timely installation of patches, updates, and upgrades.
For the proposed exceptions to apply, we propose in proposed paragraph (a)(4)(ii)(D) that a regulated entity would be required to document that an exception applies and that all other applicable conditions are met. The first proposed exception in proposed 45 CFR 164.308(a)(4)(ii)(D)(4)(ii)(D))(
_1_) would be for when a patch, update, or upgrade to the configuration of a relevant electronic information system is not available to address a risk identified in the regulated entity's risk analysis. The second proposed exception would be in proposed 45 CFR 164.308(a)(4)(ii)(D)(4)(ii)(D))(
_2_) for when the only available patch, update, or upgrade would adversely affect the confidentiality, integrity, or availability of ePHI. The Department anticipates that this proposed exception would apply when a regulated entity tests a patch, update, or upgrade and determines that it would adversely affect the confidentiality, integrity, or availability of ePHI or where there are reports from government sources or persons with appropriate knowledge of an experience with generally accepted cybersecurity principles and methods for ensuring the confidentiality, integrity, and availability of ePHI indicating that the patch, update, or
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upgrade is likely to adversely affect the confidentiality, integrity, or availability of ePHI.
In proposed paragraph (a)(4)(ii)(E), the Department proposes to require a regulated entity document in real-time the existence of the applicable exception and to implement reasonable and appropriate compensating controls. Similarly, in proposed paragraph (a)(4)(ii)(F), we propose that, where an exception applies, a regulated entity would be required to implement reasonable and appropriate security measures as compensating controls to address the identified risk according to the timeliness requirements in proposed 45 CFR 164.308(a)(5)(ii)(D)(5)(ii)(D)) until such time as a patch, update, or upgrade that does not adversely affect the confidentiality, integrity, or availability of ePHI becomes available.
This proposed standard aligns with the Department's enhanced CPG for Cybersecurity Mitigation by quickly requiring a regulated entity to prioritize and mitigate vulnerabilities discovered by vulnerability scanning and penetration testing.\ [499\]
#### g. Section 164.308(a)(5)(i)—Standard: Risk Management
The Department proposes to elevate the implementation specification for risk management to a standard at proposed 45 CFR 164.308(a)(5)(i)(5)(i)). This proposed standard would require a regulated entity to establish and implement a plan for reducing the risks identified through its risk analysis activities. Specifically, it would require a regulated entity to implement security measures sufficient to reduce risks and vulnerabilities to all ePHI to a reasonable and appropriate level. What would constitute a reasonable and appropriate level depends on the regulated entity's specific circumstances, including but not limited to its size, needs and capabilities, risk profile, the ability of security measures to reduce or eliminate a particular identified risk or vulnerability, and the ubiquity of such security measures. We also propose four implementation specifications that would require regulated entities to engage in activities that are consistent with previously issued guidance described below.
Under the proposed implementation specification for planning at proposed paragraph (a)(5)(ii)(A), a regulated entity would be required to establish and implement a written risk management plan for reducing risks to all ePHI, including, but not limited to, those risks identified by the regulated entity's risk analysis,\ [500\]
to a reasonable and appropriate level. Proposed paragraph (a)(5)(i)(B) contains the proposed implementation specification for maintenance and would require the regulated entity to review the written risk management plan at least once every 12 months, and as reasonable and appropriate in response to changes in its risk analysis. The Department would interpret “reasonable and appropriate” in both paragraphs as requiring the regulated entity to take into account not only its specific circumstances, but also the criticality of the risks identified. We propose an implementation specification for priorities at proposed 45 CFR 164.308(a)(5)(ii)(C)(5)(ii)(C)) that would require a regulated entity's written risk management plan to prioritize the risks identified in the regulated entity's risk analysis based on the risk levels determined by that analysis. Finally, in the proposed implementation specification for implementation at proposed 45 CFR 164.308(a)(5)(ii)(D)(5)(ii)(D)), we propose to require that a regulated entity implement security measures in a timely manner to address the risks identified in the regulated entity's risk analysis in accordance with the priorities established under paragraph (a)(5)(ii)(C). The proposed risk management standard aligns with the Department's essential CPG to Mitigate Known Vulnerabilities.\ [501\]
The Department previously issued guidance on risk management, including links to NIST resources, that is consistent with what we propose in this NPRM.\ [502\]
We encourage regulated entities to refer to similar NIST guidance for descriptions of risk management activities.\ [503\]
The results of a risk analysis, performed in accordance with the proposed standard for risk analysis, generally provide the regulated entity with a list of applicable “threat/vulnerability pairs” as well as the overall “risk rating” of each pair to the confidentiality, integrity, and availability of ePHI.\ [504\]
For example, some threat/vulnerability pairs may result in a risk rating of moderate or high level of risk to ePHI, while other pairs may result in a risk rating of low level of risk. The regulated entity would need to determine what risk rating poses an unacceptable level of risk to ePHI and address any threat/vulnerability pairs that indicate a risk rating above the organization's risk tolerance.\ [505\]
Under this proposed standard, the regulated entity would be required to reduce the risks to its ePHI to a level that is reasonable and appropriate for its specific circumstances. Ultimately, the regulated entity's risk assessment processes should inform its decisions about the manner in which it will implement security measures to comply with the Security Rule's standards and implementation specifications.\ [506\]
Additionally, each regulated entity would be required to document the security controls it has implemented because it has determined them to be reasonable and appropriate, including analyses, decisions, and the rationale for decisions made to refine or adjust the security controls.\ [507\]
As stated by NIST, “the documentation and retention of risk assessment and risk management activities” is “important for future risk management efforts.” \ [508\]
In general, risk management activities “should be performed with regular frequency to examine past decisions, reevaluate risk likelihood and impact levels, and assess the effectiveness of past remediation efforts.” \ [509\]
Risk management plans should address risk appetite, risk tolerance, workforce duties, responsible parties, the frequency of risk management, and required documentation.\ [510\]
#### h. Section 164.308(a)(6)(i)—Standard: Sanction Policy
Consistent with other proposals to elevate certain critical implementation specifications to standards, we propose to elevate the implementation specification for sanction policy at 45 CFR 164.308(a)(ii)(C)(ii)(C)) to a standard for sanction policy at proposed 45 CFR 164.308(a)(6)(i)(6)(i)). We propose this standard because applying appropriate sanctions against workforce members who fail to comply with security requirements, and thus imperil the
( printed page 945)
security of ePHI, serves as an important tool for improving compliance by other workforce members with the regulated entity's safeguards for ePHI. While the Department does not propose to modify the language of the standard, we are proposing three implementation specifications that are consistent with guidance that was previously issued by the Department.
Specifically, under the proposed implementation specification for policies and procedures at proposed 45 CFR 164.308(a)(6)(ii)(A)(6)(ii)(A)), a regulated entity would be required to establish written policies and procedures for sanctioning workforce members who fail to comply with the regulated entity's security policies and procedures. The proposed implementation specification for modifications at paragraph (a)(6)(ii)(B) would require a regulated entity to review its written sanctions policies and procedures at least once every 12 months, and, based on that review, modify such policies and procedures as reasonable and appropriate. The proposed implementation specification for application at proposed paragraph (a)(6)(ii)(C) would direct a regulated entity to apply appropriate sanctions against workforce members who fail to comply with such security policies and procedures and to document when it sanctions a workforce member and the circumstances in which it applies such sanctions.
The policy choices represented in this NPRM are informed by the compliance challenges OCR has observed through its enforcement activities. These challenges demonstrate that regulated entities would benefit from greater precision and clarity about their legal obligations in the proposed standard. Additionally, according to a recent survey of IT and IT security practitioners in healthcare, careless users were the top cause of data loss and exfiltration, while accidental loss was the second highest cause. Thirty-one percent of respondents indicated that the data loss or exfiltration was caused by a failure of workforce members to follow organizational policies.\ [511\]
As described in existing Department guidance, an organization's sanction policies can be an important tool for supporting accountability and improving cybersecurity and data protection.\ [512\]
Sanction policies can be used to address the intentional actions of malicious insiders, such as a workforce member that accesses the ePHI of a public figure or steals ePHI to sell as part of an identity-theft ring, as well as the failure of workforce members to comply with policies and procedures, such as failing to secure data on a network server or investigate a potential security incident.
Sanction policies that are appropriately applied can improve a regulated entity's general compliance with the HIPAA Rules. Imposing consequences on workforce members who violate a regulated entity's policies and procedures implemented as required by the Security Rule or the HIPAA Rules generally can be effective in creating a culture of HIPAA compliance and improved cybersecurity. Knowledge that there is a negative consequence to noncompliance enhances the likelihood of compliance.\ [513\]
Training workforce members on a regulated entity's sanction policy can also promote compliance and greater cybersecurity vigilance by informing workforce members in advance which actions are prohibited and punishable.\ [514\]
A sanction policy that clearly communicates a regulated entity's expectations should ensure that workforce members understand their individual compliance obligations and consequences of noncompliance.
Regulated entities have the flexibility to implement the standard in a manner consistent with numerous factors, including but not limited to their size, degree of risk, and environment. The HIPAA Rules do not require regulated entities to impose any specific penalty for any particular violation, nor do they require regulated entities to implement any particular methodology for sanctioning workforce members. Rather, in any particular case, each regulated entity must determine the type, cause, and severity of sanctions imposed based upon its policies and the relative severity of the violation.\ [515\]
A regulated entity may structure its sanction policies in the manner most suitable to its organization. As described in previously issued guidance materials from the Department and NIST, regulated entities should consider the following when drafting or revising their sanction policies:
- Documenting or implementing sanction policies pursuant to a formal process.\ [516\]
- Requiring workforce members to affirmatively acknowledge that a violation of the organization's HIPAA policies or procedures may result in sanctions.\ [517\]
- Documenting the sanction process, including the personnel involved, the procedural steps, the time-period, the reason for the sanction(s), and the final outcome of an investigation.\ [518\]
- Creating sanctions that are “appropriate to the nature of the violation.” \ [519\]
- Creating sanctions that “vary depending on factors such as the severity of the violation, whether the violation was intentional or unintentional, and whether the violation indicated a pattern or practice of improper use or disclosure of \[PHI\].” \ [520\]
- Creating sanctions that “range from a warning to termination.” \ [521\]
- Providing examples “of potential violations of policy and procedures.” \ [522\]
Generally, it is important for a regulated entity to consider whether its sanction policies align with its general disciplinary policies, and how the individuals or departments involved in the sanction processes can work in concert, when appropriate. Regulated entities may also want to consider how sanction policies can be fairly and consistently applied throughout the organization, to all workforce members, including management.\ [523\]
The deterrent effect of penalizing noncompliance and misconduct paired with clear communications about the consequences of noncompliance can promote greater compliance with the HIPAA Rules through accountability, understanding, and transparency.
( printed page 946)
#### i. Section 164.308(a)(7)(i)—Standard: Information System Activity Review
As described in previously issued HHS guidance, review of activity in its relevant electronic information systems and their components, including workstations,\ [524\]
enables a regulated entity to determine if any ePHI has been used or disclosed in an inappropriate manner.\ [525\]
The procedures should be customized to meet the regulated entity's risk management strategy and consider the capabilities of all information systems with ePHI.\ [526\]
These activities should also promote continual awareness of any information system activity that could suggest a security incident.\ [527\]
Detecting and preventing data leakage initiated by malicious authorized users is a significant challenge.\ [528\]
Identifying potential malicious activity in relevant electronic information systems, including in workstations and other components, as soon as possible is key to preventing or mitigating the impact of such activity.\ [529\]
To identify potential suspicious activity, organizations should consider an insider's interactions with information systems and their components. A regulated entity can detect anomalous user behavior or indicators of misuse by either a trusted employee or third-party vendor who has access to critical systems, workstations and other system components, and data.\ [530\]
To minimize this risk, an organization may employ safeguards that detect suspicious user activities, such as traffic to an unauthorized website, downloading data to an external device (
_e.g.,_
thumb drive), or access to a network server by an unauthorized mobile device. Maintaining audit controls (
_e.g.,_
system event logs, application audit logs) and regularly reviewing audit logs, access reports, and security incident tracking reports are important security measures that can assist in detecting and identifying suspicious activity or unusual patterns of data access.\ [531\]
Regulated entities should regularly review activity in their relevant electronic information systems (including the components of such systems) for potential concerns and consider ways to automate such reviews.\ [532\]
Additionally, regulated entities are responsible for establishing and implementing appropriate standard operating procedures, including determining the types of audit trail data and monitoring procedures that would be needed to derive exception reports.\ [533\]
They also must activate the necessary review processes and maintain auditing and logging activity.\ [534\]
Department and NIST guidance advise regulated entities to consider many questions when establishing their policies and procedures for reviewing activity in their relevant electronic information systems review.\ [535\]
These include:
- What logs or reports are generated by the information systems?
- Is there a policy that establishes what reviews will be conducted?
- Are there corresponding procedures that describe the specifics of the reviews?
- Who is responsible for the overall process and results?
- How often will review results be analyzed?
- Where will audit information reside ( _e.g.,_
separate server)? Will it be stored external to the organization (
_e.g.,_
cloud service provider)?
Compliance challenges observed through OCR's enforcement activities suggest that regulated entities would benefit from an expanded standard to provide more details on compliance expectations. Investigations of reported breaches of unsecured PHI discussed above as examples of risk analysis failures also identified a potential failure by the regulated entities to conduct appropriate information system activity review.\ [536\]
In an investigation involving a large health care provider, the ePHI of more than 12,000 patients was sold to an identity theft ring by employees who, for six months, inappropriately accessed patient account information.\ [537\]
Compliance with the requirement to implement procedures to regularly review records of activity in relevant electronic information systems, such as audit logs, access reports, and security incident tracking, could have identified and mitigated these disclosures.\ [538\]
Similarly, a business associate experienced an intrusion into its systems that it failed to notice for over 20 months. Eventually, the ePHI of more than 200,000 individuals associated with several covered entities was encrypted in a ransomware cyberattack.\ [539\]
Among other factors, OCR's investigation indicated that the business associate potentially failed to implement procedures for regularly reviewing records of activity in its relevant electronic information system, such as audit logs, access reports, and security incident tracking reports.\ [540\]
Consistent with previously issued guidance and based on OCR's enforcement experience, the Department proposes to elevate the existing implementation specification for information system activity review to a standard and to redesignate it as proposed 45 CFR 164.308(a)(7)(i)(7)(i)). The purpose of the proposal is to impose specific requirements on a regulated entity to review the activity occurring in its relevant electronic information systems, including the activity occurring in the components of such systems. By virtue of these proposed requirements, we would specify actions that a regulated entity is required to take to ensure that only appropriate users access ePHI and that it responds quickly to any suspicious activity in its relevant electronic information systems, including in components thereof, such as workstations that connect to or otherwise access its relevant electronic information systems. We also propose to revise the language to provide regulated entities with additional direction regarding their review of suspicious activities. The proposed standard, if adopted, would require a regulated entity to implement written policies and procedures for regularly reviewing
( printed page 947)
records of activity in its relevant electronic information systems.
The Department proposes five implementation specifications for the proposed standard for information system activity review. The proposed implementation specification for policies and procedures at proposed 45 CFR 164.308(a)(7)(ii)(A)(7)(ii)(A)) would require a regulated entity to establish written policies and procedures for retaining and reviewing records of activity in the regulated entity's relevant electronic information systems by persons and technology assets. Such written policies and procedures should require review of activity in the regulated entity's relevant electronic information systems as a whole, as well as the system's components, including but not limited to any workstations. They should also include information on the frequency for reviewing such records. The frequency of review may vary based on the specific type of record being reviewed and the information it contains. According to the proposed implementation specification for scope at proposed 45 CFR 164.308(a)(7)(ii)(B)(7)(ii)(B)), records of activity in the regulated entity's relevant electronic information systems by persons and technology assets would include, but would not be limited to, audit trails, event logs, firewall logs, system logs, data backup logs, access reports, anti-malware logs, and security incident tracking reports. The proposed implementation specification for records review at proposed 45 CFR 164.308(a)(7)(ii)(C)(7)(ii)(C)) would require a regulated entity to review records of activity in its relevant electronic information systems by persons and technology assets as often as reasonable and appropriate for the type of report or log. They would also be required to document such review. A proposed implementation specification for record retention at proposed 45 CFR 164.308(a)(7)(ii)(D)(7)(ii)(D)) would require a regulated entity to retain records of activity in its relevant electronic information systems by persons and technology assets. Under the proposal, the regulated entity would be required to retain such records for an amount of time that is reasonable and appropriate for the specific type of report or log. For example, it may be reasonable and appropriate to retain audit trails for a different amount of time than security incident tracking reports because of the type of information they contain and their purpose. The proposed implementation specification for response at proposed 45 CFR 164.308(a)(7)(ii)(E)(7)(ii)(E)) would require a regulated entity to respond to a suspected or known security incident identified during the review of activity in its relevant electronic information systems, including any components thereof, such as workstations, in accordance with the regulated entity's security incident plan.\ [541\]
Finally, the proposed implementation specification for maintenance at proposed 45 CFR 164.308(a)(7)(ii)(F)(7)(ii)(F)) would require a regulated entity to review and test its written policies and procedures for reviewing activity in its relevant electronic information systems at least once every 12 months. The regulated entity would be expected to modify such policies and procedures as reasonable and appropriate, based on the results of that review.
Consider a large regulated entity that may have thousands of workforce members accessing various networks and relevant electronic information systems, generating large amounts of log and audit data. Given the size, complexity, and capabilities of entities of such size, a reasonable and appropriate process for reviewing activity may include the adoption of an automated solution that performs rules-based enterprise log aggregation and analysis to identify anomalous or suspicious patterns of behavior in the regulated entity's relevant electronic information systems and the components thereof, including but not limited to workstations, in real-time and sends alerts of potential security incidents to a workforce member or team for further review and action. By contrast, for a small regulated entity, it might be reasonable and appropriate to have designated staff that manually review log files and audit trails multiple times per week.
#### j. Section 164.308(a)(8)—Standard: Assigned Security Responsibility
The Department proposes to redesignate the standard for assigned security responsibility at 45 CFR 164.308(a)(2)(2)) as proposed 45 CFR 164.308(a)(8)(8)). OCR's enforcement experience demonstrates that, in practice, many regulated entities follow informal policies and procedures that are not documented, and have not documented the identification of the Security Official in writing.
Based on OCR's enforcement experience, and consistent with existing guidance, we propose to modify the standard to specify that a regulated entity must identify in writing the Security Official who is responsible for the establishment and implementation of the policies and procedures, whether written or otherwise, and deployment of technical controls. These proposals are consistent with our general intention in this NPRM to propose to clarify that policies and procedures required by the Security Rule should be reduced to writing and to distinguish between the implementation of written policies and procedures and the deployment of technical controls.
As we previously explained in guidance,\ [542\]
the purpose of this standard is to identify who would be operationally responsible for assuring that the regulated entity complies with the Security Rule. It is comparable to the Privacy Rule standard for personnel designations at 45 CFR 164.530(a)(1)(1)), which requires all covered entities to designate a Privacy Official. The Security Official and Privacy Official can, but need not be, the same person. While one workforce member must be designated as having overall responsibility, other workforce members may be assigned specific security responsibilities (
_e.g.,_
facility security, network security). When making this decision, regulated entities should consider basic questions, such as: Has the organization agreed upon, and clearly identified and documented, the responsibilities of the Security Official? How are the roles and responsibilities of the Security Official crafted to reflect the size, complexity, and technical capabilities of the organization?
NIST guidance urges the regulated entity to select a workforce member who is able to assess the effectiveness of security to serve as the point of contact for security policy, implementation, and monitoring.\ [543\]
It further recommends that a regulated entity should document the responsibilities in a job description and communicate this assigned role to the entire organization. NIST provides additional sample items for consideration by a regulated entity organizing its security practices, including identifying the workforce members in the organization who oversee the development and communication of security policies and procedures, direct IT security purchasing and investment, and ensure that security concerns have been addressed in system implementation. NIST also offers that a regulated entity should ask whether the security official has adequate access and communications with senior officials in the organization and whether there is a
( printed page 948)
complete job description that accurately reflects assigned security duties and responsibilities.
#### k. Section 164.308(a)(9)(i)—Standard: Workforce Security
The purpose of the workforce security standard is to ensure that workforce members only have access to ePHI that they need to perform their assigned functions and are prevented from accessing ePHI that they are not authorized to access to perform such functions. The proposed changes to the standard and implementation specifications would clarify the actions required of a regulated entity to assure such limits.
Individuals have been harmed in the past by the failure of regulated entities to comply with the Security Rule requirements for workforce security. For example, a former employee of a large covered entity was able to access their former worksite and workstation using still-active credentials for more than a week after their employment was terminated.\ [544\]
OCR's investigation found evidence of a potential failure to terminate the former employee's access to PHI, which enabled the former employee to download the ePHI of nearly 500 individuals, including their names, addresses, dates of birth, race/ethnicity, gender, and sexually transmitted infection test results onto a USB drive. This type of real-world experience and OCR's observations more broadly inform the changes proposed in this NPRM.
Moreover, this proposal is consistent with guidance issued by HHS and NIST for implementing this standard and associated implementation specifications. For example, in guidance issued in 2005, we explained that regulated entities must identify workforce members who need access to ePHI to carry out their duties.\ [545\]
For each workforce member or job function, the regulated entity must identify the ePHI that is needed, when it is needed, and make reasonable efforts to control access to the ePHI, a concept generally referred to as role-based access (
_i.e.,_
authorizing access to ePHI only when such access is appropriate based on the workforce member's role).\ [546\]
This also includes identification of the computer systems and applications that provide access to the ePHI. A regulated entity must provide only the minimum necessary access to ePHI that is required for a workforce member to do their job.\ [547\]
As described in HHS guidance, access authorization is the process of determining whether a particular user (or a computer system) has the right, consistent with their function, to carry out a certain activity, such as reading a file or running a program.\ [548\]
Implementation may vary among regulated entities, depending on the size and complexity of their workforce, and their electronic information systems that contain ePHI. For example, in a small medical practice, all staff members may need to access all ePHI in their information systems because each staff member may perform multiple functions. In this case, the regulated entity would document the reasons for implementing policies and procedures that permit this type of global access. If the documented rationale is reasonable and appropriate, this may be an acceptable approach. The implementation specification provision for authorization and/or supervision provides the necessary checks and balances to ensure that all members of the workforce have appropriate access (or, in some cases, no access) to ePHI.
NIST guidance provides descriptions of key activities and sample questions for regulated entities implementing this implementation specification.\ [549\]
To implement procedures for the authorization and/or supervision of workforce members who work with ePHI or in locations where it might be accessed, the guidance advises regulated entities to consider whether chains of command and lines of authority have been established, as well as the identity and roles of supervisors. A regulated entity also should establish clear job descriptions and responsibilities, which includes defining roles and responsibilities for all job functions; assigning appropriate levels of security oversight, training, and access; and identifying in writing who has the business need and who has been granted permission to view, alter, retrieve, and store ePHI and at what times, under what circumstances, and for what purposes.\ [550\]
To determine the most reasonable and appropriate authorization and/or supervision procedures, a regulated entity must be able to answer some basic questions about existing policies and procedures. For example, are detailed job descriptions used to determine what level of access the person holding the position should have to ePHI? Who has or should have the authority to determine who can access ePHI,
_e.g.,_
supervisors or managers? Are there written job descriptions that are correlated with appropriate levels of access to ePHI? Are these job descriptions reviewed and updated on a regular basis? Have workforce members been provided copies of their job descriptions and informed of the access granted to them, as well as the conditions by which this access can be used? As noted above, a smaller regulated entity may address compliance by implementing a simpler approach, but it is still liable for ensuring that workforce members only have access to ePHI that they need to perform their assigned functions.\ [551\]
NIST also recommends establishing criteria and procedures for hiring and assigning tasks and ensuring that these requirements are included as part of the personnel hiring process.\ [552\]
In its guidance, NIST provides questions and suggestions for regulated entities to consider with respect to these criteria, procedures, and requirements. NIST guidance also describes this implementation specification as calling for regulated entities to implement appropriate screening of persons who would have access to ePHI, and a procedure for obtaining clearance from appropriate offices or workforce members where access is provided or terminated.\ [553\]
Similarly, the Department's guidance on workforce clearance procedures states that the clearance process must establish the procedures to verify that a workforce member would in fact have the appropriate access for their job function.\ [554\]
A regulated entity may choose to perform this type of screening procedure separate from, or as a part of, the authorization and/or supervision procedure. Sample questions for
( printed page 949)
regulated entities to consider include the following: Are there existing procedures for determining that the appropriate workforce members have access to the necessary information? Are the procedures used consistently within the organization when determining access of related workforce job functions? NIST guidance describes this implementation specification as calling for regulated entities to implement appropriate screening of persons who would have access to ePHI, and a procedure for obtaining clearance from appropriate offices or workforce members where access is provided or terminated.\ [555\]
We issued guidance in 2017 addressing termination procedures.\ [556\]
Data breaches caused by current and former workforce members are a recurring issue across many industries, including the health care industry. Effective identity and access management policies and controls are essential to reduce the risks posed by these types of insider threats. Identity and access management can include many processes, but, most commonly, it would include the processes by which appropriate access to data is granted and terminated by creating and managing user accounts. Ensuring that user accounts are terminated—and in a timely manner—so that former workforce members do not have access to data, is one important way identity and access management can help reduce risks posed by insider threats. Additionally, effective termination procedures also reduce the risk that inactive user accounts (
_e.g.,_
user accounts that are not being used or are inactive but are not fully terminated or disabled) could be used by a current or former workforce member with malicious motives to get access to ePHI. The Department's guidance also offers tips to prevent unauthorized access to PHI by former workforce members, such as having standard procedures of all action items to be completed when an individual leaves.\ [557\]
Guidance that we issued in 2019 further explains that “security is a dynamic process.” \ [558\]
Good security practices entail continuous awareness, assessment, and action in the face of changing circumstances. The information users can and should be allowed to access may change over time; organizations should recognize this in their policies and procedures and in their implementation of those policies and procedures. For example, if a user is promoted, demoted, or transfers to a different department, a user's need to access data may change. In such situations, the user's data access privileges should be re-evaluated and, as needed, modified to match the new role, if needed.\ [559\]
As described in other HHS guidance, these procedures should also address the complexity of the organization and the sophistication of its relevant electronic information systems.\ [560\]
NIST guidance provides additional descriptions of key activities and sample questions for regulated entities to consider when implementing this standard and associated implementation specifications.\ [561\]
Regulated entities should establish a standard set of procedures that should be followed to recover access control devices (
_e.g.,_
identification badges, keys, access cards) when employment ends and, likewise, they should timely deactivate computer access (
_e.g.,_
disable user IDs and passwords) and facility access (
_e.g.,_
change facility security codes/PINs). Sample questions for implementation include the following: Are there separate procedures for voluntary termination (
_e.g.,_
retirement, promotion, transfer, change of employment) versus involuntary termination (
_e.g.,_
termination for cause, reduction in force, involuntary transfer, criminal or disciplinary actions)? Is there a standard checklist for all action items that should be completed when a workforce member leaves (
_e.g.,_
return of all access devices, deactivation of accounts, and delivery of any needed data solely under the workforce member's control)? Do other organizations need to be notified to deactivate accounts to which that the workforce member had access in the performance of their employment duties?
However, regulated entities often do not establish or implement written procedures, nor, even in instances where they have established or implemented them, have they done so in an appropriate fashion to protect ePHI from improper access by current or former workforce members.
Consistent with the guidance described above and other proposals in this NPRM, the Department proposes to redesignate the workforce security standard at 45 CFR 164.308(a)(3)(i)(3)(i)) as proposed 45 CFR 164.308(a)(9)(i)(9)(i)), to add a paragraph heading to clarify the organization of the regulatory text, and to modify the regulatory text clarify that a regulated entity must implement written policies and procedures ensuring that workforce members have appropriate access to ePHI and to relevant electronic information systems. The regulated entity must also implement written policies and procedures preventing workforce members from accessing ePHI and relevant electronic information systems if they are not authorized to do so. The modifications we propose to the implementation specification for authorization and/or supervision would clarify that a regulated entity is required to establish and implement written procedures for the authorization and/or supervision of workforce members who access ePHI or relevant electronic information systems or who work in facilities where ePHI or relevant electronic information systems might be accessed.\ [562\]
We propose similar modifications to the implementation specification for workforce clearance procedure, which would require a regulated entity to establish and implement written procedures to determine that the access of a workforce member to ePHI or relevant electronic information systems is appropriate, in accordance with written policies and procedures for granting and revising access to ePHI and relevant electronic information systems as required by proposed 45 CFR 164.308(a)(10)(ii)(B)(10)(ii)(B)).\ [563\]
Additionally, we propose several clarifications to the implementation specification for termination procedures. Specifically, the proposed implementation specification for modification and termination procedures at proposed 45 CFR 164.308(a)(9)(ii)(C)(9)(ii)(C)) would require procedures for terminating a workforce member's access to ePHI and relevant electronic information systems, and to facilities where ePHI or relevant electronic information systems might be accessed. Proposed paragraph (a)(9)(ii)(C)(
_1_) would require a regulated entity to establish and implement written procedures for terminating a workforce member's access to ePHI and relevant electronic information systems,
( printed page 950)
and to locations where ePHI or relevant electronic information systems might be accessed. Proposed paragraph (a)(9)(ii)(C)(
_2_) would require that the workforce member's access be terminated as soon as possible, but no later than one hour after the workforce member's employment or other arrangement ends. A proposed implementation specification for notification at proposed 45 CFR 164.308(a)(9)(ii)(D)(9)(ii)(D)) would require a regulated entity to establish and implement written procedures for notifying another regulated entity of a change in, or termination of, a workforce member's authorization to access ePHI or relevant electronic information systems. Proposed paragraph (a)(9)(ii)(D)(
_1_) would require the regulated entity to establish and implement written procedures for notifying another regulated entity after a change in or termination of a workforce member's authorization to access ePHI or relevant electronic information systems that are maintained by such other regulated entity where the workforce member is or was authorized to access such ePHI or relevant electronic information systems by the regulated entity making the notification. Proposed paragraph (a)(9)(ii)(D)(
_2_) would require the notice to be provided as soon as possible, but no later than 24 hours after the workforce member's authorization to access ePHI or relevant electronic information systems is changed or terminated. Finally, a proposed new implementation specification for maintenance at proposed 45 CFR 164.308(a)(9)(ii)(E)(9)(ii)(E)) would require a regulated entity to review and test its written workforce security policies and procedures at least once every 12 months and to modify them as reasonable and appropriate.\ [564\]
The proposed implementation specifications for termination procedures and notification implementation align with the Department's essential CPG for Revoke Credentials for Departing Workforce Members, Including Employees, Contractors, Affiliates, and Volunteers by requiring a regulated entity to promptly remove access following a change in or termination of a user's authorization to access ePHI.\ [565\]
#### l. Section 164.308(a)(10)(i)—Standard: Information Access Management
The purpose of the standard for information access management is to protect ePHI by reducing the risk that other persons or technology assets may access the information for their own reasons. Existing HHS guidance explains that restricting access to only those persons and entities with a need for access is a basic tenet of security.\ [566\]
By implementing this standard, the risk of inappropriate disclosure, alteration, or destruction of ePHI is minimized. A regulated entity must determine those persons and technology assets that need access to ePHI within its environment. The implementation specifications associated with the standard on information access management are closely related to those associated with the standard for workforce security.\ [567\]
Compliance with the proposed and existing standards for information access management should support a regulated entity's compliance with the Privacy Rule's minimum necessary requirements, which requires a regulated entity to evaluate its practices and enhance safeguards as needed to limit unnecessary or inappropriate access to and disclosure of PHI.\ [568\]
OCR's enforcement experience demonstrates that many regulated entities have not adequately implemented this standard. Thus, we believe it is necessary to consider strengthening the requirement. For example, on one occasion, a large covered entity's failure to implement its written policies and procedures to ensure that employees only had access to ePHI that they had proper authorization or authority to access enabled an employee to access the ePHI of more than 24,000 individuals.\ [569\]
This failure also enabled other employees to inappropriately access the ePHI of a celebrity.\ [570\]
To ensure that regulated entities implement recommendations and best practices for securing ePHI, we propose to require in the standard for information access management and associated implementation specifications that a regulated entity must establish and implement written policies and procedures for authorizing access to ePHI and relevant electronic information systems that are consistent with the Privacy Rule. The Department also proposes to redesignate the standard at 45 CFR 164.308(a)(4)(i)(4)(i)) as proposed 45 CFR 164.308(a)(10)(i)(10)(i)) and to add a paragraph heading to clarify the organization of the regulatory text. Additionally, the Department proposes to modify three of the associated existing implementation specifications and to add three new implementation specifications as follows.
Specifically, the Department proposes to redesignate the implementation specification for isolating health care clearinghouse functions as proposed 45 CFR 164.308(a)(10)(ii)(A)(10)(ii)(A)) and to modify it to require a health care clearinghouse that is part of a larger organization to establish and implement written policies and procedures that protect the ePHI and relevant electronic information systems of the clearinghouse from unauthorized access by the larger organization.
The existing implementation specification for isolating health care clearinghouse functions only applies in the situation where a health care clearinghouse is part of a larger organization. This would remain true under the proposal to revise this implementation specification, if adopted. In these situations, the health care clearinghouse is responsible for protecting the ePHI that it is creating, receiving, maintaining, and transmitting. As discussed in NIST guidance, if a health care clearinghouse is part of a larger organization, the clearinghouse must implement policies and procedures that protect the ePHI of the clearinghouse from unauthorized access by the larger organization.\ [571\]
This necessarily includes its relevant electronic information systems. First, the regulated entity must determine
( printed page 951)
whether any of its components constitute a health care clearinghouse under the Security Rule.\ [572\]
If no health care clearinghouse functions exist within the organization, the regulated entity should document this finding. If a health care clearinghouse does exist within the organization, the regulated entity must implement procedures that are consistent with the Privacy Rule.\ [573\]
Questions for regulated entities to consider include: If health care clearinghouse functions are performed, are policies and procedures implemented to protect ePHI from the other functions of the larger organization? Does the health care clearinghouse share hardware or software with a larger organization of which it is a part? Does the health care clearinghouse share staff or physical space with staff from a larger organization? Has a separate network or subsystem been established for the health care clearinghouse, if reasonable and appropriate? Has staff of the health care clearinghouse been trained to safeguard ePHI from disclosure to the larger organization, if required for compliance with the Privacy Rule? \ [574\]
Regulated entities should also consider whether additional technical safeguards are needed to separate ePHI in electronic information systems used by the health care clearinghouse to protect against unauthorized access by the larger organization.
We also propose to redesignate the implementation specification for access authorization as proposed 45 CFR 164.308(a)(10)(ii)(B)(10)(ii)(B)) and to modify it to emphasize that a regulated entity must establish and implement written policies and procedures for granting and revising access to ePHI and the regulated entity's relevant electronic information systems as necessary and appropriate for each prospective user and technology asset to carry out their assigned function(s) (
_i.e.,_
role-based access policies). Additionally, we propose to redesignate the implementation specification for access establishment and modification as 45 CFR 164.308(a)(10)(ii)(D)(10)(ii)(D)) and to modify the heading to “Access determination and modification.” We also propose to modify this implementation specification to require a regulated entity to establish and implement written policies and procedures that, based on its access authorization policies, establish, document, review, and modify the access of each user and technology asset to specific components of the regulated entity's relevant electronic information systems. Such written policies and procedures would be required to be based upon the regulated entity's policies for authorizing access. Under this proposal, and consistent with the existing implementation specification,\ [575\]
the regulated entity would be required to establish standards for granting access to ePHI and relevant electronic information systems and provide formal authorization from the appropriate authority before granting access to ePHI or relevant electronic information systems. Regulated entities should regularly review personnel access to ePHI and relevant electronic information systems to ensure that access is still authorized and needed, and modify personnel access to ePHI and electronic information systems, as needed, based on review activities.
The existing implementation specification for access authorization calls for the regulated entity to implement policies and procedures for granting access to ePHI, for example, through components of its information system.\ [576\]
The Department's proposal to revise this implementation specification would provide greater specificity than our existing requirements, and echo NIST guidance on this topic. Specifically, NIST guidance \ [577\]
describes the key steps for developing policies and procedures for granting access to ePHI as follows:
- Decide and document procedures for how access to ePHI would be granted to workforce members within the organization.
- Select the basis for restricting access to ePHI. Select an access control method ( _e.g.,_
identity-based, role based, or other reasonable and appropriate means of access).
- Decide and document how access to ePHI would be granted for privileged functions.
- Ensure that there is a list of personnel with authority to approve user requests to access ePHI and systems with ePHI.
- Identify authorized users with access to ePHI, including data owners and data custodians.
- Consider whether multiple access control methods are needed to protect ePHI according to the results of the risk assessment.
- Determine whether direct access to ePHI would ever be appropriate for individuals external to the organization ( _e.g.,_
business partners or patients seeking access to their own ePHI).
Other questions that a regulated entity should consider when establishing such policies and procedures include: Have appropriate authorization and clearance procedures, as specified in the standard for workforce security,\ [578\]
been performed prior to granting access? Do the organization's systems have the capacity to set access controls? Are there additional access control requirements for users who would be accessing privileged functions? Have organizational personnel been explicitly authorized to approve user requests to access ePHI and/or systems with ePHI?
The Department proposes three additional implementation specifications for authentication management, maintenance, and network segmentation. These specifications clarify the Department's expectations for compliance and are consistent with NIST guidance. We believe that the proposed additions would assist regulated entities in their efforts to prevent or mitigate attacks by malicious internal and external actors. For the implementation specification on authentication management at proposed 45 CFR 164.308(a)(10)(ii)(C)(10)(ii)(C)), we propose to require a regulated entity to establish and implement written policies and procedures for verifying the identities of users and technology assets before accessing the regulated entity's relevant electronic information systems, including written policies and procedures for implementing MFA technical controls.\ [579\]
The proposed implementation specification for network segmentation at proposed 45 CFR 164.308(a)(10)(ii)(E)(10)(ii)(E)) would require a regulated entity to establish and implement written policies and procedures that ensure that its relevant electronic information systems are segmented to limit access to ePHI to authorized workstations.
Finally, to address the Department's general concerns regarding the ongoing failure of many regulated entities to regularly review and revise their policies and procedures, the proposed implementation specification for maintenance at proposed 45 CFR
( printed page 952)
164.308(a)(10)(ii)(F) would require a regulated entity to review the written policies and procedures required by this standard at least once every 12 months and to modify them as reasonable and appropriate.
#### m. Section 164.308(a)(11)(i)—Standard: Security Awareness Training
A covered entity's workforce is its frontline not only in patient care and patient service, but also in safeguarding the privacy and security of PHI.\ [580\]
The health care sector's risk landscape continues to grow with the increasing number of interconnected, smart devices of all types, the increased use of interconnected medical record and billing systems, and the increased use of applications and cloud computing. This standard reflects the fact that training on data security for workforce members is essential for protecting an organization against cyberattacks.
An organization's training program should be an ongoing, evolving process and flexible enough to educate workforce members on new cybersecurity threats and how to respond to them. As such, regulated entities should consider how often to train workforce members on security issues, given the risks and threats to their enterprises, and how often to send security updates to their workforce members. Many regulated entities have determined that twice-annual training and monthly security updates are necessary, given their risks analyses.
Regulated entities should apply security updates and reminders to quickly communicate new and emerging cybersecurity threats to workforce members such as new social engineering ploys (
_e.g.,_
fake tech support requests and new phishing scams) and malicious software attacks including new ransomware variants. Entities need to address what type of training to provide to workforce members on security issues, given the risks and threats to their enterprises. Computer-based training, classroom training, monthly newsletters, posters, email alerts, and team discussions are all tools that different organizations use to fulfill their training requirements. Entities must also address how to document that training to workforce members was provided, including dates and types of training, training materials, and evidence of workforce participation.
HHS has issued many types of training materials on securing PHI.\ [581\]
NIST has also provided detailed guidance for developing and implementing workforce training programs.\ [582\]
Despite this existing guidance, regulated entities often fail to provide appropriate training to adequately safeguard ePHI. For example, in one investigation, OCR investigators found evidence that not only had an ambulance company potentially failed to conduct a risk analysis, it also potentially failed to implement a security training program or to train any of its employees.\ [583\]
Such failures can contribute to breaches of individuals' unsecured ePHI.
To ensure security awareness training compliance, a regulated entity needs to regularly educate its workforce members on the evolving technological threats to ePHI, how to use the technology that the regulated entity has adopted and implemented, and the specific procedures workforce members must follow to ensure that the ePHI remains protected. Additionally, while many educational programs for clinicians provide general training on the HIPAA Rules, the curriculums vary widely. Without providing its own training on the Security Rule, a regulated entity cannot ensure that the training its workforce received elsewhere meets the required standards.
Given the failure of regulated entities to implement the security awareness and training standard and consistent with existing guidance, the Department proposes to provide more detailed requirements for security awareness training. Specifically, the Department proposes to rename and redesignate the standard for security awareness and training at 45 CFR 164.308(a)(5)(i)(5)(i)) as the standard for security awareness training at proposed 45 CFR 164.308(a)(11)(i)(11)(i)) and to add a paragraph heading to clarify the organization of the regulatory text. The proposed standard would require a regulated entity to implement security awareness training for all workforce members on protection of ePHI and information systems as necessary and appropriate for the members of the workforce to carry out their assigned function(s) (
_i.e.,_
role-based training). The proposals to revise this standard would also align with the Department's essential CPG for Basic Cybersecurity Training because they would require a regulated entity to educate users on how to access ePHI and electronic information systems in a manner that protects the confidentiality, integrity, and availability of ePHI.\ [584\]
Additionally, the proposals would align with the essential CPG for Email Security by requiring a regulated entity to train workforce members to guard against, detect, and report suspected or known security incidents, including, but not limited to, malicious software and social engineering.\ [585\]
We propose four implementation specifications for the proposed security awareness training standard. The proposed implementation specification for training at 45 CFR 164.308(a)(11)(ii)(A)(11)(ii)(A)) would require a regulated entity to establish and implement security awareness training for all workforce members that addresses the following:
- The written policies and procedures required by the Security Rule, as necessary and appropriate for the workforce members to carry out their assigned functions.\ [586\]
- Guarding against, detecting, and reporting suspected or known security incidents, including but not limited to malicious software and social engineering.\ [587\]
- The written policies and procedures for accessing the regulated entity's electronic information systems, including, but not limited to, safeguarding passwords, setting unique passwords of sufficient strength to ensure the confidentiality, integrity, and availability of ePHI, and establishing limitations on sharing passwords. Consistent with the recommendation from NCVHS, such policies and procedures should ensure that the regulated entity does not employ default passwords and should prevent workforce members from sharing of credentials.\ [588\]
We do not propose that passwords be required to meet a particular standard because best practices for password configuration may change over time; however, we believe that it is essential for a regulated
( printed page 953)
entity to educate its workforce members on best practices for setting passwords and to ensure that its workforce members implement such best practices.
The Department proposes to replace the implementation specification for periodic security updates \ [589\]
with one addressing the timing and frequency of security awareness training at proposed 45 CFR 164.308(a)(11)(ii)(B)(11)(ii)(B)). Specifically, we propose to require a regulated entity to provide such training to each member of the regulated entity's workforce by the compliance date for this rulemaking, if finalized, and at least once every 12 months thereafter.\ [590\]
For example, under this proposal, workforce members would receive security awareness training on the protection of ePHI and on the regulated entity's Security Rule policies and procedures that is based on their specific role at least once a year. A regulated entity would be required to provide role-based security awareness training to a new workforce member within a reasonable period of time, but no later than 30 days after the workforce member first has access to the regulated entity's relevant electronic information systems.\ [591\]
We also propose to require that the regulated entity provide such training.\ [592\]
For example, if the entity implements a new EHR system, it would be required to also train its workforce, as appropriate, on measures to guard against security incidents related to the installation, maintenance and/or use of the system.
Additionally, the Department proposes at proposed 45 CFR 164.308(a)(11)(ii)(C)(11)(ii)(C)) an implementation specification for ongoing education. This would require a regulated entity to provide its workforce members with ongoing reminders of their security responsibilities and notice of relevant threats, including but not limited to, new and emerging malicious software and social engineering. Lastly, we propose a new implementation specification for documentation at proposed 45 CFR 164.308(a)(11)(ii)(D)(11)(ii)(D)) that would require a regulated entity to document that it has provided training and ongoing reminders to its workforce members.
#### n. Section 164.308(a)(12)(i)—Standard: Security Incident Procedures
Addressing security incidents is an integral part of an overall security program. While a regulated entity will never be able to prevent all security incidents, implementing the Security Rule standards would reduce the amount and negative consequences of security incidents it encounters. Even regulated entities with detailed security policies and procedures and advanced technology may experience security incidents, but through sufficient planning and continued monitoring generally can mitigate the negative effects of such incidents on regulated entities, and, ultimately, individuals. The security incident procedures standard is intended to help ensure that a regulated entity conducts such planning and monitoring to allow it to mitigate such negative effects.
The Department has also provided guidance that a regulated entity can use to devise its security incident plans. The policies and procedures a regulated entity establishes to prepare for and respond to security incidents can pay dividends with faster recovery times and reduced compromises of ePHI.\ [593\]
A well thought-out, well-tested security incident response plan is integral to ensuring the confidentiality, integrity, and availability of a regulated entity's ePHI. A timely response to a security incident can be one of the best ways to prevent, mitigate, and recover from future cyberattacks. For example, responding to a single intrusion or inappropriate access can prevent a pattern of repeated malicious actions. It is extremely important that a regulated entity analyzes an incident to establish what has occurred and its root cause. Doing so will enable the regulated entity to use that information to update its security incident response plans. The Department has previously issued guidance addressing such activities as forming a security incident response team, identifying and responding to security incidents, mitigating harmful effects of and documenting a security incident, and breach reporting.\ [594\]
NIST also offers guidance for addressing security incidents.\ [595\]
It describes four key activities with detailed descriptions and sample questions:
- Determine the goals of an incident response.
- Develop and deploy an incident response team or other reasonable and appropriate response mechanism.
- Develop and implement policy and procedures to respond to and report security incidents.
- Incorporate post-incident analysis into updates and revisions.
NIST has also issued comprehensive guidelines for incident handling, particularly for analyzing incident related data and determining the appropriate response to each incident.\ [596\]
For example, the NIST Cybersecurity Framework addresses these activities as part of the core function of “\[respond—a\]ctions regarding a detected cybersecurity incident are taken.” \ [597\]
“Respond” supports the ability of the regulated entity “to contain the effects of cybersecurity incidents. Outcomes within this Function \[include\] incident management, analysis, mitigation, reporting, and communication.” \ [598\]
Despite this existing guidance, OCR's enforcement experience indicates that many regulated entities have not met the existing standard, so we believe that additional specificity regarding their obligations and liability for incident response is warranted. Accordingly, the Department proposes to redesignate the standard for security incident procedures as 45 CFR 164.308(a)(12)(i)(12)(i)), to add a paragraph heading to clarify the organization of the regulatory text, and to modify the regulatory text to clarify that a regulated entity would be required to implement written policies and procedures to “respond to,” rather than “address,” security incidents. Additionally, we propose to clarify expectations by adding an implementation specification for planning and testing at proposed 45 CFR 164.308(a)(12)(ii)(A)(12)(ii)(A))(
) that would require a regulated entity to establish written security incident response plan(s) and procedures documenting how workforce members are to report suspected or known security incidents and how the regulated entity will respond to suspected or known security incidents.\ [599\]
Internal reporting is an essential component of security incident procedures.\ [600\]
Plans and procedures for
( printed page 954)
reporting of suspected or known security incidents may address to whom, when, and how such incidents are to be reported. The recipient(s) and the content of such reports, according to such plans and procedures, may vary based on the type of incident and the role of the workforce member making the report. We do not propose to dictate the form, format, or content of such report. Rather, we believe that regulated entities would be best situated to identify the point(s) of contact for their organization (
_e.g.,_
Chief Information Security Officer, IT security team, business associate engaged to support incident response activities for the regulated entity) for such reports and the type of information they need to determine how to respond to the suspected or known security incident.
The proposal to require a regulated entity to establish written security incident response plans and procedures for how it will respond to suspected or known security incidents would align with the enhanced CPG for Third Party Incident Reporting because it would address the procedures for how and when a business associate would report to a covered entity or another business associate known or suspected security incidents, as required by proposed 45 CFR 164.314(a)(2)(i)(C)(2)(i)(C)).\ [601\]
Under proposed 45 CFR 164.308(a)(12)(ii)(A)(12)(ii)(A))(
_2_) and (
_3_), the regulated entity would be required to implement written procedures for testing and revising the security incident response plan(s) and then, using those written procedures, review and test its security incident response plans at least once every 12 months and document the results of such tests. The regulated entity would also be required to modify the plan(s) and procedures as reasonable and appropriate, based on the results of such tests and the regulated entity's circumstances.
This proposal, if finalized, would include requirements that align with the Department's essential CPG for Basic Incident Planning and Preparedness to have effective responses to and recovery from security incidents.\ [602\]
It also aligns with the Department's enhanced CPG for Centralized Incident Planning and Preparedness by requiring a regulated entity to maintain, revise, and test security incident response plans.\ [603\]
Additionally, the Department proposes to redesignate the implementation specification for response and reporting at 45 CFR 164.308(a)(6)(ii)(6)(ii)) as 45 CFR 164.308(a)(12)(ii)(B)(12)(ii)(B)) and to rename it “Response.” We also propose to modify the existing implementation specification by separating it into two paragraphs: one at paragraph (a)(12)(ii)(B)(
_1_) for identifying and responding to suspected or known security incidents, and the other at paragraph (a)(12)(ii)(B)(
_2_) for mitigating, to the extent practicable, the harmful effects of suspected or known security incidents. The Department also proposes to add three additional paragraphs to this implementation specification. Proposed 45 CFR 164.308(a)(12)(ii)(B)(12)(ii)(B))(
_3_) would require a regulated entity to identify and remediate, to the extent practicable, the root cause(s) of suspected or known security incidents, while proposed 45 CFR 164.308(a)(12)(ii)(B)(12)(ii)(B))(
) would require the regulated entity to eradicate the security incidents that are suspected or known to the regulated entity. We would expect eradication to include the removal of malicious software, inappropriate materials, and any other components of the incident from the regulated entity's relevant electronic information systems.\ [604\]
Finally, proposed 45 CFR 164.308(a)(12)(ii)(B)(12)(ii)(B))(
_5_) would require a regulated entity to develop and maintain documentation of investigations, analyses, mitigation, and remediation for security incidents that are suspected or known. For example, verbal reports of a suspected or known security incident would be required to be documented in writing. Under proposed 45 CFR 164.316(b)(1)(1)), if finalized, a regulated entity would be required to maintain such documentation for six years from the date of its creation or the date when it last was in effect, whichever is later. These proposals are consistent with existing guidance described above and with other proposals or existing regulatory standards to secure health information.\ [605\]
#### o. Section 164.308(a)(13)(i)—Standard: Contingency Plan
The purpose of any contingency plan is to allow an organization to return to its daily operations as quickly as possible after an unforeseen event.\ [606\]
The contingency plan protects resources, minimizes customer inconvenience, and identifies key staff, assigning specific responsibilities in the context of the recovery. Contingency plans are critical to protecting the availability, integrity, and security of data during unexpected adverse events. Contingency plans should consider not only how to respond to disasters such as fires and floods, but also how to respond to cyberattacks. Cyberattacks using malicious software, such as ransomware, may render an organization's data unreadable or unusable. In the event data is compromised by a cyberattack, restoring the data from backups may be the only option for recovering the data and restoring normal business operations. For example, the faulty software update by CrowdStrike made it impossible for health care systems worldwide to use their Windows-based systems.\ [607\]
There were many instances where surgical procedures and health care appointments were cancelled, schedules upended, and pharmacies were unable to fill prescriptions. Regulated entities need to make and implement contingency plans they would use when such events occur to enable themselves to get back to their core functions of providing or paying for health care.
The Department and NIST have issued extensive guidance on contingency planning, including detailed descriptions of key activities, sample questions for regulated entities to consider when standing up a contingency plan, and information on how the results of the risk analysis feed into contingency plans.\ [608\]
Unfortunately, many regulated entities have not implemented the required
( printed page 955)
planning and then have been unable to fully recover from ransomware attacks that bring down electronic systems that create, receive, maintain, or transmit ePHI. For example, a large health system that experienced a ransomware attack had to shut down services at multiple locations and encountered difficulties restoring those services. OCR's investigation indicated a potential failure to, among other things, implement contingency plans.\ [609\]
Such planning is crucial for maintaining the resilience of a regulated entity's health IT.
To address these inadequacies in compliance and to protect the confidentiality, integrity, and availability of ePHI, the Department proposes to redesignate the standard for a contingency plan at 45 CFR 164.308(a)(7)(i)(7)(i)) as proposed 45 CFR 164.308(a)(13)(i)(13)(i)), to add a paragraph heading to clarify the organization of the regulatory text, and to modify the regulatory text to clarify it. The modified standard, as proposed, would require a regulated entity to establish (and implement as needed) a written contingency plan, consisting of written policies and procedures for responding to an emergency or other occurrence, including, but not limited to, fire, vandalism, system failure, natural disaster, or security incident, that adversely affects relevant electronic information systems.
The Department proposes a new implementation specification for criticality analysis at proposed 45 CFR 164.308(a)(13)(ii)(A)(13)(ii)(A)). This would require a regulated entity to perform and document an assessment of the relative criticality of its relevant electronic information systems and technology assets in its relevant electronic information systems. The proposal would not limit this analysis to electronic information systems that create, receive, maintain, or transmit ePHI because other electronic information systems and/or technology assets may be crucial to ensuring the confidentiality, integrity, or availability of ePHI, providing patient care, and supporting other business needs. A prioritized list of specific relevant electronic information systems and technology assets in those electronic information systems would help a regulated entity to determine their criticality and the order of restoration.\ [610\]
Under this proposal, the implementation specification for establishing and implementing a data backup plan would be redesignated as proposed 45 CFR 164.308(a)(13)(ii)(B)(13)(ii)(B)) and renamed “Data backups.” It would also be modified to clarify that the procedures to create and maintain exact retrievable copies of ePHI must be in writing, and to also require such procedures to include verifying that the ePHI has been copied accurately. For example, the ability to access ePHI from a remote location in the event of a total failure should be reflected in the procedures specified for data backups.
The proposed implementation specification for backing up information systems at proposed paragraph (a)(13)(ii)(C) would require a regulated entity to establish and implement written procedures to create and maintain backups of its relevant electronic information systems, including verifying the success of such backups. Establishing such procedures would ensure that the ePHI in relevant electronic information systems is both protected and available.
Additionally, the Department proposes to redesignate the implementation specification for disaster recovering planning as paragraph (a)(13)(ii)(D). We propose to clarify that a regulated entity would be required to establish (and implement as needed) written procedures to restore both its critical relevant electronic information systems and data within 72 hours of the loss, and to restore the loss of other relevant electronic information systems and data in accordance with its criticality analysis.\ [611\]
The Department proposes to clarify the implementation specification for emergency mode operation planning, redesignated as proposed 45 CFR 164.308(a)(13)(ii)(E)(13)(ii)(E)), by clarifying that procedures must be written. We also propose to redesignate the implementation specification for testing and revision procedures as paragraph (a)(13)(ii)(F) and to clarify that procedures for testing and revising of the required contingency plans must be established in writing. We propose to require a regulated entity to review and implement its procedures for testing contingency plans at least once every 12 months, to document the results of such tests, and to modify those plans as reasonable and appropriate based on the results of those tests.
#### p. Section 164.308(a)(14)—Standard: Compliance Audit
The final standard we propose under 45 CFR 164.308(a)) is a new standard for compliance audits at proposed 45 CFR 164.308(a)(14)(14)). For this proposed standard, the Department proposes to require regulated entities to perform and document an audit of their compliance with each standard and implementation specification of the Security Rule at least once every 12 months.
While the Security Rule does not currently require regulated entities to conduct internal or third-party compliance audits, such activities are important components of a robust cybersecurity program. The Government Accountability Office has published guidance on conducting cybersecurity performance audits for Federal agencies.\ [612\]
Audits are typically conducted independently from information security management, and the function generally reports to the governing body of the regulated entity. This independence can provide an objective view of the regulated entity's policies and practices. According to the Institute of Internal Auditors, an internal audit provides “\[i\]ndependent and objective assurance and advice on all matters related to the achievement of objectives.” \ [613\]
An internal audit may be conducted by a business associate of a covered entity or a subcontractor of a business associate. These activities provide regulated entities with confidence in the effectiveness of their risk management plan. Thus, we believe that this proposal would aid a regulated entity in ensuring compliance with the Security Rule, and ultimately, protecting ePHI. We do not propose to specify whether the compliance audit should be performed by the regulated entity or an external party.\ [614\]
( printed page 956)
#### q. Section 164.308(b)(1) and (2)—Standard: Business Associate Contracts and Other Arrangements
Vendor management and identification of risks in a supply chain are essential to controlling the introduction of new threats and risks to a regulated entity.\ [615\]
NIST guidance explains that regulated entities, are permitted to include more stringent cybersecurity measures in business associate agreements than those required by the Security Rule.\ [616\]
Such requirements would need to be agreed upon by both parties to the business associate agreement.\ [617\]
The guidance also recommends establishing a process for measuring contract performance and terminating the contract if security requirements are not being met. Important considerations include: Is there a process for reporting security incidents related to the agreement? Are additional assurances of protections for ePHI from the business associate necessary? If so, where would such additional assurances be documented (
_e.g.,_
in the business associate agreement, service-level agreement, or other documentation) and how would they be met (
_e.g.,_
providing documentation of implemented safeguards, audits, certifications)?
The Security Rule requires a regulated entity to protect the confidentiality, integrity, and availability of all ePHI that it creates, receives, maintains, or transmits.\ [618\]
It also requires a regulated entity to obtain written satisfactory assurances that its business associate will appropriately safeguard ePHI before allowing the business associate to create, receive, maintain, or transmit ePHI on its behalf.\ [619\]
However, the Security Rule does not require a regulated entity to verify that entities that create, receive, maintain, or transmit ePHI on its behalf are in fact taking the necessary steps to protect such ePHI. The lack of such a requirement may leave a gap in protections from risks to ePHI related to regulated entities' vendors and supply chains. Accordingly, the Department proposes several modifications to the Security Rule to provide greater assurance that business associates and their subcontractors are protecting ePHI because a subcontractor to a business associate is also a business associate. The Department proposes to redesignate 45 CFR 164.308(b)(1)(1)) and (2)(2)) as proposed 45 CFR 164.308(b)(1)(i)(1)(i)) and (ii)(1)(ii)), respectively. Additionally, we propose to make a technical correction to the standard for business associate contracts and other arrangements for organizational clarity, separating proposed paragraph (b)(1)(i) into paragraphs (b)(1)(i)(A) and (B). We believe this is a non-substantive change that would have no effects on any regulatory, recordkeeping, or reporting requirement, nor would it change the Department's interpretation of any regulation. We also propose to modify both to require a regulated entity to verify that the business associate has deployed the technical safeguards required by 45 CFR 164.312\ [620\]
in addition to obtaining satisfactory assurances that its business associate would comply with the Security Rule.\ [621\]
To assist regulated entities in complying with the new standard, we propose to redesignate the implementation specifications at 45 CFR 164.308(b)(3)(3)) as 45 CFR 164.308(b)(2)(2)) and propose to add an implementation specification for written verification at proposed 45 CFR 164.308(b)(2)(ii)(2)(ii)) that would require the regulated entity to obtain written verification from the business associate that the business associate has deployed the required technical safeguards.\ [622\]
The Department proposes to require that the regulated entity obtain this written verification documenting the business associate's deployment of the required technical safeguards at least once every 12 months.\ [623\]
Additionally, we propose that the verification include a written analysis of the business associate's relevant electronic information systems.\ [624\]
The written analysis would be required to be performed by a person with appropriate knowledge of and experience with generally accepted cybersecurity principles and methods for ensuring the confidentiality, integrity, and availability of ePHI to verify the business associate's compliance with each standard and implementation specification in 45 CFR 164.312.\ [625\]
We also propose to require that the written verification be accompanied by a written certification by a person who has the authority to act on behalf of the business associate that the analysis has been performed and is accurate.\ [626\]
The proposal would permit the parties to determine the appropriate person to perform the analysis and how that person is engaged or compensated. This person may be a member of the covered entity's or business associate's workforce or an external party.
This proposed new requirement that a regulated entity obtain written verification from its business associates that they have deployed technical safeguards combined with the existing requirement to obtain written satisfactory assurances that they safeguard ePHI, aligns with the Department's essential CPG for Vendor/Supplier Cybersecurity Requirements.\ [627\]
This CPG calls for regulated entities to identify, assess, and mitigate risks to ePHI used by or disclosed to business associates.\ [628\]
#### r. Section 164.308(b)(3)—Standard: Delegation To Business Associate
Based on the OCR's investigations and enforcement experience, we believe that some regulated entities are not aware that they retain compliance responsibility for implementing requirements of the Security Rule, even when they have delegated the functions of designated security official to a business associate. Therefore, the Department proposes a new standard for delegation to a business associate at proposed 45 CFR 164.308(b)(3)(3)). The proposed standard would clarify that a regulated entity may permit a business associate to serve as its designated security official.\ [629\]
However, a regulated entity that delegates actions, activities, or assessments required by the Security Rule to a business associate remains liable for compliance with all the applicable provisions of the Security Rule.\ [630\]
#### 4\. Request for Comment
The Department requests comment on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular. For any proposed timeframe that a commenter believes is not appropriate, we request comment and explanation on a more appropriate timeframe.
( printed page 957)
a. Whether the Department should require a regulated entity to implement any additional administrative safeguards. If so, please explain.
b. Whether the Department should not require a regulated entity to implement any of the existing or proposed standards for implementation specifications. If so, please explain.
c. Whether there are additional implementation specifications that should be adopted for any of the standards for administrative safeguards.
d. Whether the Department should provide any exceptions to the administrative safeguards or related implementation specifications. If so, please explain when and why any exceptions should apply.
e. Whether once every 12 months is the appropriate frequency between reviews of policies, procedures, and other activities required by the other standards for administrative safeguards.
f. Whether there are any special considerations for business associates and business associate agreements that the Department should be aware of with respect to administrative safeguards.
g. Whether there are any requirements for business associates and business associate agreements that the Department should include in administrative safeguards that it did not propose.
h. Whether the Department should require covered entities to report to their business associates (or business associates to their subcontractors) the activation of the covered entities' (or business associates') contingency plans. If so, please explain the appropriate circumstances of and the appropriate amount of time for such notification.
i. Whether once every 12 months is an appropriate length of time in which a covered entity must verify and document that a business associate has deployed technical safeguards pursuant to the requirements.
j. Whether the Department should require covered entities to obtain satisfactory assurances and verify that a business associate has implemented physical or other safeguards in addition to deploying technical safeguards before permitting it to create, receive, maintain, or transmit ePHI on its behalf.
k. Whether on an ongoing basis, but at least once every 12 months and when there is a change to a regulated entity's environment or operations that affects ePHI, is the appropriate frequency for updating the technology asset inventory and network map?
l. Whether on an ongoing basis, but at least once every 12 months and when there is a change to the regulated entity's environment or operations that affects ePHI, is the appropriate frequency for performing a risk analysis?
m. Whether there are additional events for which the Department should require a regulated entity to update its risk analysis. If so, please explain.
n. Whether the Department should include or exclude any specific circumstances from its explanation of environmental or operational changes when determining whether review or update of the written inventory of technology assets and network map or review of the risk analysis written assessment is warranted.
o. Whether the proposed requirement in the standard for evaluation, to perform a written technical and nontechnical evaluation within a reasonable period of time before making a change in the regulated entity's environment or operations pursuant to the requirements, is sufficiently clear. If not, how should the Department clarify it? For example, should the Department require a specific amount of time, and if so, what length of time?
p. Whether at least once every 12 months is the appropriate frequency for reviewing and updating written policies and procedures for patch management, sanctions policies and procedures information system activity review, workforce security, and information access management.
q. Whether as reasonable and appropriate in response to changes in the risk analysis, but at least once every 12 months, is the appropriate frequency for reviews of a regulated entity's written risk management plan.
r. Whether the proposed frequency for security awareness training is appropriate.
s. Whether the proposed substance of the security awareness training is appropriate, and any recommendations for additional required content.
t. Whether the proposed timelines for applying patches, updates, and upgrades are appropriate.
u. Whether the Department should set a time limit for applying patches, updates, and upgrades to configurations of relevant electronic information systems to address moderate and low risks. If so, please explain and provide a recommendation.
v. Whether the amount of time regulated entities currently retain records of information system activity varies by the type of record, and for how long such records are retained.
w. Whether the Department should specify the length of time for which records of information system activity should be retained. If so, please explain.
x. Whether the Department should require that a regulated entity notify other regulated entities of the termination of a workforce member's access to ePHI in less than 24 hours after the workforce member's termination. If so, please explain what would be an appropriate period of time (
_e.g.,_
three business hours, 12 hours).
y. Whether at least once every 12 months is the appropriate frequency for testing security incident response plans, documenting the results, and revising such plans.
z. Whether it is reasonable and appropriate to require that regulated entities restore loss of critical relevant electronic information systems and data in 72 hours or less.
aa. Whether the Department should require a regulated entity to restore all of its relevant electronic information systems and data within 72 hours?
bb. Whether the Department should require some regulated entities to restore their relevant electronic information systems and data in less than 72 hours? If so, please explain.
cc. Whether at least once every 12 months is the appropriate frequency for the testing of contingency plans?
dd. Whether annual auditing of a regulated entity's compliance with the Security Rule is appropriate.
ee. Whether the Department should specify the level of detail or standard required for the annual compliance audit. If so, please explain.
ff. Whether the Department should require a regulated entity to obtain written verification of their business associates' implementation of the administrative and physical safeguards that are required by the Security Rule, in addition to the proposed requirement to obtain verification of implementation of the technical safeguards. If so, please explain.
gg. Whether there are other requirements for which the Department should require that the person performing them have a specific level or type of expertise. If so, please explain.
### E. Section 164.310—Physical Safeguards
#### 1\. Current Provisions
A person with physical access to electronic media or a regulated entity's electronic information systems that create, receive, maintain, or transmit or that otherwise affect the confidentiality, integrity, and availability of ePHI might have the opportunity to change the configurations of its relevant electronic information systems, install malicious software or otherwise adversely affect technology assets in its relevant
( printed page 958)
electronic information systems, change information, or access ePHI or other sensitive information.\ [631\]
Any of these actions has the potential to adversely affect the confidentiality, integrity, or availability of ePHI, which means that physical safeguards for electronic media and a regulated entity's relevant electronic information systems are critical to protecting the security of ePHI. Thus, the physical safeguards standards address the essential requirements for regulated entities to apply to limit physical access to their relevant electronic information systems to only authorized workforce members. As discussed above, ePHI is increasingly transmitted using interconnected systems that rely on cloud computing. The shift to a cloud-based infrastructure may increase regulated entities' reliance on business associates to maintain and access ePHI stored in the cloud.\ [632\]
Additionally, the shift to cloud computing enables regulated entities' workforce members to access ePHI and relevant electronic information systems from a greater number of locations. Accordingly, regulated entities must appropriately expand and/or ensure that applied physical safeguards take into account these new arrangements.
Section 164.310 includes the four standards with which a regulated entity must comply to physically secure relevant electronic information systems and the premises where they are located. These standards require regulated entities to implement physical safeguards for facility access controls, workstation use, workstation security, and device and media controls in a manner that conforms with 45 CFR 164.306(c)), the general compliance provision for the security standards.
As discussed above in greater detail, physical safeguards encompass the physical measures, and related policies and procedures, to protect relevant electronic information systems and related buildings and equipment from natural and environmental hazards, and unauthorized intrusion.\ [633\]
The standard for facility access controls applies to protect the physical premises, while the standards for workstation use, workstation security, and device and media controls are aimed at protecting the electronic information systems and electronic media that create, receive, maintain, or transmit ePHI or that otherwise affect its confidentiality, integrity, and availability.
The standard for facility access controls at 45 CFR 164.310(a)(1)(1)) requires a regulated entity to implement policies and procedures that limit physical access to electronic information systems and facilities that contain those systems. Section 164.310(a)(1) also requires a regulated entity to ensure its policies and procedures allow persons who are properly authorized to access its facilities.
Under 45 CFR 164.310(a)(2)(2)), a regulated entity must implement the standard for facility access controls in accordance with four implementation specifications. The implementation specification for contingency operations addresses the establishment (and implementation as needed) of procedures that allow for facility access in support of the restoration of lost data under a disaster recovery plan and emergency mode operations.\ [634\]
Section 164.310(a)(2)(ii) contains the specification for a facility security plan and addresses the implementation of policies and procedures to safeguard facilities and equipment in such facilities from unauthorized physical access, tampering, and theft. The implementation of procedures for role-based access control, including for visitors and for access to software programs for testing and revision is addressed in 45 CFR 164.310(a)(2)(iii)(2)(iii)), while 45 CFR 164.310(a)(2)(iv)(2)(iv)) addresses the implementation of policies and procedures for the documentation of repairs and modifications to physical security components of a facility, such as hardware, walls, doors, and locks.
Section 164.310(b) requires a regulated entity to implement policies and procedures specifying proper workstation functions, the manner in which those functions are to be performed, and the physical attributes of the environment for where specific workstations or classes of workstation used for accessing ePHI.\ [635\]
This standard is not accompanied by standalone implementation specifications, compared to the standards for facility access controls at 45 CFR 164.310(a)) and device and media controls at 45 CFR 164.310(d)). Section 164.310(c), the standard for workstation security, also is not accompanied by standalone addressable or required implementation specifications, but it does require a regulated entity to implement physical safeguards that restrict all workstations, such as a laptop or desktop computer or any other device that performs similar functions, that access ePHI to authorized users.\ [636\]
Device and media controls can help regulated entities respond to and recover from security incidents and breaches.\ [637\]
Proper understanding of and implementation of such controls may enable regulated entities to quickly determine which devices and electronic media may be implicated in an actual or suspected security incident, or breach, and respond accordingly.\ [638\]
For example, if cybercriminals gained access to an organization's network by exploiting a vulnerability present in a particular electronic device, a robust and accurate inventory and tracking process could identify how many devices are affected and where they are located. With this information, a regulated entity should be able to make more effective use of its resources and respond more effectively to an actual or suspected security incident or breach involving such devices. Thus, it is important for regulated entities to implement the device and media controls required under 45 CFR 164.310(d)). Accordingly, the standard for device and media controls at 45 CFR 164.310(d)), requires a regulated entity to implement policies and procedures to govern how hardware and electronic media containing ePHI are received or removed from a facility and within a facility. Section 164.310(d)(2) includes two required and two addressable implementation specifications. Paragraphs (d)(2)(i) and (ii) on disposal and media re-use, respectively require a regulated entity to implement policies and procedures that address the final disposition of ePHI and the hardware or electronic media on which it is stored, and the removal of ePHI before the electronic media is re-used. Section 164.308(d)(2)(iii) addresses the
( printed page 959)
maintenance of a record of the movement of hardware and electronic media and any person responsible for such hardware or electronic media, while the provision on data backup and storage at 45 CFR 164.310(d)(2)(iv)(2)(iv)) addresses the creation of a retrievable, exact copy of ePHI before moving the equipment.
#### 2\. Issues To Address
The Department has concerns regarding the effectiveness of the language used in the physical safeguards in 45 CFR 164.310 for the same reasons discussed in the context of 45 CFR 164.306 and 164.316. For example, while 45 CFR 164.310 contemplates that a regulated entity must implement the standards and implementation specifications required under 45 CFR 164.310 in accordance with the general documentation and maintenance requirements found in 45 CFR 164.306 and 164.316, at least one court has stated that compliance obligations are limited to the plain words of regulatory text and that a requirement to “implement” does not mean that a requirement must be in place throughout the regulated entity's enterprise.\ [639\]
Additionally, the standards for facility access controls, workstation use, and device and media controls all require a regulated entity to implement policies and procedures, while the standard for workstation security requires regulated entities to implement physical safeguards. The differences in regulatory text among these provisions could be interpreted to mean that a regulated entity's obligations differ depending on whether a provision requires it to implement only policies and procedures or whether the provision requires the implementation of something more. This may confuse regulated entities and lead some to believe that less comprehensive protection is needed for ePHI subject only to policies and procedures.
The Department believes that the current Security Rule provides a clear path for regulated entities to protect the confidentiality, integrity, and availability of ePHI. However, as discussed above, we also believe recent caselaw has created confusion about the steps regulated entities must take to adequately protect the confidentiality, integrity, and availability of ePHI, as required by the statute. Further, the conditions highlighted by caselaw may also cause regulated entities to misinterpret the regulatory text that connects the current maintenance requirement at 45 CFR 164.306(e)), the documentation requirement at 45 CFR 164.316, and the requirement to implement physical safeguards. For example, regulated entities may be confused about how 45 CFR 164.316 requires a regulated entity to document the policies and procedures for specific physical safeguard in 45 CFR 164.310 (or across any other safeguard). In this case, the regulated entity also might not apply the implementation specifications to retain, make available, and review documentation of how it has operationalized the physical safeguard. Failing to connect these provisions would lead to inadequate protection of ePHI and/or an inability to demonstrate compliance with the Security Rule.
Our experience enforcing the Security Rule provides examples of the types of breaches that can occur because of absent or insufficient physical safeguards:
- An investigation of a large health system indicated potential failures to implement policies and procedures and facility access controls to limit physical access to the electronic information systems housed within a large data support center. While the health system did have video surveillance, the investigation found indications that laptops were stored in an interior room that was unlocked and the facility did not have an alarm system.\ [640\]
- A large university hospital experienced a breach of unsecured PHI when it lost an unencrypted flash drive and unencrypted laptop. The Department's investigation found that the covered entity may have failed to use device and media controls, which might have prevented the loss of these devices.\ [641\]
Given the increased portability of devices, media, workstations, and information systems, such components may often be located outside of a regulated entity's physical location. For example, OCR has investigated several incidents involving portable electronic media and mobile workstations that were removed from the regulated entity's physical environment and subsequently lost. As a result, the Department believes that we should more broadly construe the physical environment where ePHI is stored and accessed because it is essential that regulated entities have policies and procedures in place to address the portability of components of their information systems, as well as the ability of workforce members to access such information systems offsite using portable workstations.
Additionally, the standard for device and media controls at 45 CFR 164.310(d)(1)(1)) applies only to devices and media, rather than all technology assets that may be components of a regulated entity's relevant electronic information systems. The Department is concerned that a regulated entity may have other types of technology assets that may either create, receive, maintain, or transmit ePHI or otherwise affect its confidentiality, integrity, or availability and that can be removed from, brought to, or moved within its facilities. The confidentiality, integrity, or availability of the regulated entity's ePHI could be negatively affected in the absence of written policies and procedures governing the movement of such technology assets.
Finally, we believe that it is important to address several issues in the standards and implementation specifications for the physical safeguards that are also addressed in other proposals: addressing the Department's expectations regarding implementation specifications; \ [642\]
memorializing policies and procedures in writing; documenting the implementation of the aforementioned policies and procedures; reviewing such policies and procedures on a regular cadence; modifying such policies and procedures when reasonable and appropriate; \ [643\]
and clarifying the scope of the electronic information systems and their components that regulated entities are expected to consider when establishing their policies and procedures.\ [644\]
#### 3\. Proposals
The Department proposes to retain the four standards that comprise the Security Rule's physical safeguards required by 45 CFR 164.306 and codified in 45 CFR 164.310. However, we propose several modifications to 45 CFR 164.310 to address the issues identified above.
#### a. Section 164.310—Physical Safeguards
The Department proposes to expand the introductory language at 45 CFR
( printed page 960)
164.310 to clarify that the Security Rule requires that physical safeguards be applied to all ePHI in the possession of the regulated entity, that is, throughout the regulated entity's facilities. The Department also proposes to expand this section to expressly require a regulated entity to implement physical safeguards in accordance with not only 45 CFR 164.306, but also 45 CFR 164.316 to connect the overarching documentation requirements.
Consistent with the proposals to revise the general requirements in 45 CFR 164.306(c)) and (d)), the Department proposes to remove any distinction between addressable and required implementation specifications in this section such that all specifications would be required. Also consistent with changes proposed elsewhere in this NPRM, the Department proposes to modify all four physical safeguard standards to require that the requisite policies and procedures be in writing \ [645\]
and implemented throughout the enterprise.\ [646\]
Under this proposal, a regulated entity that could not produce a written policy describing how it will implement a required physical safeguard and demonstrate that the safeguard is in effect and operational throughout the enterprise would not be in compliance with the standard. Consistent with our proposals to require that regulated entities maintain their administrative safeguards, the Department also proposes to require a regulated entity to maintain its security measures by reviewing and testing the required security measures at least once every 12 months, and by modifying the same as reasonable and appropriate. Additionally, we propose to modify certain standards and implementation specifications to ensure that regulated entities understand their obligations to ensure the confidentiality, integrity, and availability of ePHI by implementing physical safeguards to protect their relevant electronic information systems and/or the technology assets in their relevant electronic information systems.
#### b. Section 164.310(a)(1)—Standard: Facility Access Controls
The Department proposes to modify the standard for facility access controls at 45 CFR 164.310(a)(1)(1)) to clarify that the policies and procedures required by this standard must be in writing and address physical access to all of a regulated entity's relevant electronic information systems and the facility or facilities in which these systems are housed and to add a paragraph to clarify the organization of the regulatory text. The Department also proposes to modify the implementation specifications associated with the standard for facility access controls. Specifically, we propose to modify the implementation specifications for contingency operations, facility security plan, and access control and validation procedures at 45 CFR 164.310(a)(2)(i)(2)(i)) through (iii)(2)(iii)) to clarify that we expect a regulated entity to not only establish and implement policies and procedures, but also that we expect them to be in writing.
The Department's proposal would also require that the procedures for contingency operations proposed at 45 CFR 164.310(a)(2)(i)(2)(i)) support the regulated entity's contingency plan, instead of the current requirement specifying that the procedures support the restoration of lost data under the disaster recovery plan and emergency mode operations plan in the event of an emergency.\ [647\]
This proposal would align the implementation specification for contingency operations with the standard for contingency planning at proposed 45 CFR 164.308(a)(13)(i)(13)(i)) by specifically ensuring that the written policies and procedures support the required contingency plan. It also would avoid duplicating the implementation specification for disaster recovery planning at proposed 45 CFR 164.308(a)(13)(ii)(D)(13)(ii)(D)), which would require a regulated entity to address the restoration of lost data and systems in the disaster recovery plan component of its contingency plan. We propose to modify 45 CFR 164.310(a)(2)(ii)(2)(ii)) to clarify that the written policies and procedures that constitute the facility security plan must apply to all of the regulated entity's facilities and equipment contained within those facilities. The Department proposes to retitle the implementation specification for access control and validation procedures at 45 CFR 164.310(a)(2)(iii)(2)(iii)) as “Access management and validation procedures” and to require regulated entities to establish and implement written procedures to both authorize and manage a person's role-based access to facilities.
In the implementation specification for maintenance records, the Department proposes at 45 CFR 164.310(a)(2)(iv)(2)(iv)), to change the provision heading to “Physical maintenance records” and to add security cameras to the list of examples of physical security components about which a regulated entity is required to implement written policies and procedures to document repairs and modifications. Both proposals are consistent with and recognize the evolution of the role that technology plays in managing and granting physical access to facilities.
Consistent with our proposals to add maintenance requirements where we believe it is necessary for regulated entities to review, test, and modify their security measures on a particular cadence, we also propose to add an implementation specification for maintenance at proposed 45 CFR 164.310(a)(2)(v)(2)(v)). The maintenance provision would require that, for each facility, a regulated entity review and test its written policies and procedures at least once every 12 months, and to modify those policies and procedures as reasonable and appropriate based on that review.
#### c. Section 164.310(b)(1)—Standard: Workstation Use and Section 164.310(c)—Standard: Workstation Security
Further, in the standards for workstation use and workstation security at 45 CFR 164.310(b)) (redesignated as proposed 45 CFR 164.310(b)(1)(1)) and (c)), respectively), the Department proposes several changes that would recognize the increasingly mobile nature of ePHI and workstations that connect to the information systems of regulated entities. The purpose of these proposals is to ensure that regulated entities properly consider physical safeguards for all workstations, including those that are mobile, and not only those that are located in regulated entities' facilities. The Department also proposes to modify both standards to clarify the organization of the regulatory text. The Department proposes to modify the standard for workstation use to clarify that policies and procedures established by a regulated entity to govern the use of workstations be in writing and address all workstations that access ePHI or the regulated entity's relevant electronic information systems. These proposed changes are consistent with the Department's longstanding expectations and other proposals in this NPRM described above. In 45 CFR 164.310(b)(2)(i)(C)(2)(i)(C)), the Department proposes to require a regulated entity to establish and implement written policies and procedures that, among other things, specify the physical attributes of workstation surroundings, including the removal of workstations from a facility and the movement of workstations within and outside of a facility. This proposal is consistent with
( printed page 961)
the proposed revision to the definition of “workstation” discussed above. Additionally, we propose to add an implementation specification for maintenance at proposed 45 CFR 164.310(b)(2)(ii)(2)(ii)) to require that a regulated entity review and test its written policies and procedures at least once every 12 months, and to modify those policies and procedures as reasonable and appropriate based on that review.
Relatedly, the Department proposes to modify the standard for workstation security at 45 CFR 164.310(c)) to require a regulated entity to implement physical safeguards for workstations that access ePHI or relevant electronic information systems to comply with its written policies and procedures for workstation use. This proposal would also make clear that such physical safeguards must be modified in response to any modifications to the written policies and procedures for workstation use. As part of their policies and procedures for workstation security, the Department encourages regulated entities to consider, among other things, whether there are workstations located in public areas or other areas that are more vulnerable to theft, unauthorized use, or unauthorized viewing; whether such devices should be relocated; the physical security controls for workstations that are in use (
_e.g.,_
cable locks, privacy screens, secured rooms, cameras) and whether they are easy to use; and whether there are additional physical security controls that could reasonably be put into place.\ [648\]
Additionally, consistent with the Department's proposal to require that a regulated entity provide role-based security awareness training on its Security Rule policies and procedures,\ [649\]
the Department expects that such training would address the physical safeguards it has implemented, particularly those policies and procedures for mobile devices that are used to create, receive, maintain, or transmit ePHI or that otherwise affect the confidentiality, integrity, or availability of ePHI.
#### d. Section 164.310(d)(1)—Standard: Technology Asset Controls
The Department proposes to modify the standard at 45 CFR 164.310(d)(1)(1)) by changing the heading to “Technology asset controls” from “Device and media controls,” and replacing “hardware and electronic media” in 45 CFR 164.310(d)(1)(1)) and (2)(2)) with “technology assets.” We believe that this modification would more accurately capture the various categories of components of a regulated entity's relevant electronic information systems that may be received in, removed from, or moved within a facility and that also affect the confidentiality, integrity, or availability of ePHI. Thus, we believe that this modification would provide regulated entities with a clearer understanding of their compliance obligations with respect to the physical safeguards that should be implemented to protect ePHI when technology assets are received by, removed from, or moved within a facility. While we are not proposing other significant changes to 45 CFR 164.310(d)(1)(1)) at this time, we remind regulated entities to consider the appropriateness of the policies and procedures they have implemented with respect to the movement of technology assets that maintain ePHI into and out of their facilities and the movement of these items within their facilities. The processes a regulated entity chooses to implement to govern the movement of technology assets may vary based on the type of technology asset.\ [650\]
For example, once installed, a server or desktop computer may not need to be moved for the entirety of its lifecycle within the regulated entity, while portable electronic devices and media, such as smartphones, tablets, and USB flash drives are designed to be mobile and may move frequently into, out of, and within a regulated entity's facilities.\ [651\]
Thus, the regulated entity's policies and procedures must account for these differences.\ [652\]
Further, we note that the proposed definition of workstation includes mobile devices. Mobile devices that serve as workstations are subject to the requirements in this paragraph and those in paragraphs (b) and (c).
The Department also proposes to modify the standard at 45 CFR 164.310(d)(1)(1)) to clarify the organization of regulatory text and to clarify its longstanding expectations that policies and procedures must be in writing and to replace “contain” with “maintain,” consistent with terminology used throughout the HIPAA Rules. The Department believes that having written policies for the disposal of ePHI and the technology assets on which it is stored and for the removal of ePHI from electronic media such that the ePHI cannot be recovered continues to be important to ensuring the physical safety of ePHI. Improper disposal of technology assets puts the ePHI stored in or on such assets at risk for a potential breach, and as discussed elsewhere, data breaches can result in substantial costs to regulated entities and the individuals affected by the breach. We also propose in the related implementation specifications at 45 CFR 164.310(d)(2)(i)(2)(i)) and (ii)(2)(ii)) to require that written policies and procedures for disposal of ePHI and sanitization of electronic media be tied to current standards for sanitizing electronic media before the media are made available for re-use.\ [653\]
For example, photocopiers today are often connected to the same network as workstations and generally store the information, including ePHI, transmitted to them. This capability is a significant change from photocopier capabilities that existed when the Security Rule was first issued in 2003. Under this proposal, a regulated entity would be required to include in its written policies and procedures for disposing of ePHI, and the technology assets on which it is maintained, policies and procedures addressing ePHI maintained on photocopiers, consistent with the current standards for disposing and removing ePHI from electronic media.\ [654\]
We have previously explained in guidance that a regulated entity should consider all of the following as part of its risk analysis:
- Disposal of hardware and software, and the documentation of such disposal.
- Destruction of ePHI in such a manner that it cannot be recreated.
- Secure removal of ePHI that was previously stored on hardware or electronic media such that it cannot be accessed and reused.
- The identification of all removable media and their use ( _e.g.,_
CDs/DVDs, USB flash drives).
( printed page 962)
- The removal of all ePHI from reusable media before the media are reused.\ [655\]
Our guidance describes these considerations in greater detail. For example, regulated entities should consider how to address the replacement of technology assets, including devices and media.\ [656\]
Technology assets that need to be replaced should be decommissioned, meaning that they are taken out of service before the final disposition of such assets.\ [657\]
Steps a regulated entity should consider as part of its decommissioning process include: ensuring technology assets are securely erased and then either securely destroyed or recycled; ensuring that the regulated entity's technology asset inventory is updated to accurately reflect the status of decommissioned technology assets or technology assets slated to be decommissioned; and ensuring that privacy is protected through proper migration to another electronic information system or total destruction of the ePHI.\ [658\]
The Department proposes to remove the implementation specifications for accountability and data backup and storage at 45 CFR 164.310(d)(2)(iii)(2)(iii)) and (iv)(2)(iv)). We believe that the accountability provisions would be subsumed and replaced by the proposed standard for technology asset inventory at proposed 45 CFR 164.308(a)(1)(i)(1)(i)). Thus, when the proposed new standard and implementation specifications are read together, the written policies and procedures that govern the receipt and removal of technology assets that maintain ePHI into and out of a facility, and the movement of these assets within the facility, should include tracking relevant information in the technology asset inventory. Similarly, we are proposing to delete the specification for data backup and storage because it is redundant to the administrative safeguard on data backups at proposed 45 CFR 164.308(a)(13)(ii)(B)(13)(ii)(B)).
As referenced above, in place of the implementation specifications we are proposing to delete, the Department proposes a new implementation specification at proposed 45 CFR 164.310(d)(2)(iii)(2)(iii)) that would require a regulated entity to review and test the written policies and procedures related to the implementation specifications for technology assets at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate. Such environmental or operational changes may range from new and emerging threats to the confidentiality, integrity, or availability of ePHI (
_e.g.,_
a new virus) to the adoption of new technology assets by the regulated entity (
_e.g.,_
a new operating system, new types of workstations). Given the constant evolution of IT and methods for restoring data that has been disposed of or was on electronic media that has been sanitized, the Department believes that it is essential for a regulated entity to at least consider the reasonableness and appropriateness of its policies and procedures for disposal and electronic media sanitation, not only annually, but also in the face of any environmental or operational changes. We expect that pursuant to our proposals to strengthen the standard for risk analysis, a regulated entity would be able to identify such environmental and operational changes before they occur.
#### 4\. Request for Comment
The Department requests comment on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. Whether every 12 months is an appropriate frequency for review of a regulated entity's written policies and procedures for physical safeguards. If not, please explain.
b. Whether the written policies and procedures for physical safeguards should be reviewed at different intervals, based on the specific standard or implementation specification. If so, please explain.
c. Whether the Department should include additional examples in regulatory text at proposed 45 CFR 164.310(a)(2)(iv)(2)(iv)) of physical components of a facility related to security for which there should be written policies and procedures to document repairs and modifications.
d. Whether the standard at proposed 45 CFR 164.310(d)(1)(1)) and its associated implementation specifications at paragraph (d)(2) should apply to technology assets that do not maintain ePHI, but do access the regulated entity's relevant electronic information systems.
### F. Section 164.312—Technical Safeguards
#### 1\. Current Provisions
Section 164.312 includes five standards for technical safeguards, which are the requirements concerning the implementation of technology and technical policies and procedures to protect the confidentiality, integrity, and availability of ePHI and related information systems. A regulated entity must comply with the standards for technical safeguards in accordance with 45 CFR 164.306(c)), the provision that describes the general rules for the security standards.
Under 45 CFR 164.312(a)(1)(1)), a regulated entity is required to establish policies and procedures for electronic information systems to allow access only to those persons or software programs that have been granted access rights as specified in 45 CFR 164.308(a)(4)(4)). Regulated entities may comply with this standard by implementing a combination of access control methods and technical controls, consistent with the implementation specifications for this standard. The Security Rule does not identify a specific access control method or technology to implement. Regardless of the technology or information system used, access controls should be appropriate for the workforce member's role and/or function.\ [659\]
For example, a workforce member responsible for monitoring and administering information systems with ePHI, such as an administrator or a superuser,\ [660\]
should only have access to ePHI as appropriate for their role and/or job function.
The implementation specifications that provide instructions for satisfying the access control standard are found at 45 CFR 164.312(a)(2)(2)). Two are required and two are addressable.\ [661\]
The implementation specifications address unique user identifiers,\ [662\]
emergency access procedures,\ [663\]
automatic logoff,\ [664\]
and encryption and decryption.\ [665\]
The implementation
( printed page 963)
specification for unique user identification requires a regulated entity to assign unique identifiers to users to facilitate the identification of specific users of an information system.\ [666\]
By assigning a unique identifier to each user, a regulated entity can track the specific activity of that user when they are logged into an information system and hold the user accountable for functions they perform in the information system when they access that system.
Under the implementation specification for emergency access procedures, a regulated entity is required to establish procedures, such as documented operational practices and instructions to workforce members, for obtaining access to necessary ePHI during an emergency and to implement such procedures as needed.\ [667\]
In accordance with this implementation specification, a regulated entity must identify the types of situations in which its normal procedures for accessing an information system or application that contains ePHI may not work and establish procedures for obtaining access in those situations.\ [668\]
These procedures must be established prior to an emergency to instruct workforce members on possible ways to gain access to needed ePHI where, for example, the electrical system has been severely damaged or rendered inoperative, or where a software update fails and prevents the regulated entity from accessing ePHI in its EHR.
The implementation specification for automatic logoff associated with the standard for access control addresses the need for a regulated entity to, when reasonable and appropriate, implement electronic procedures that terminate an electronic session after a period of inactivity.\ [669\]
Automatic logoff is an effective way to prevent unauthorized users from accessing ePHI on a workstation when it is left unattended for a period of time.\ [670\]
While many applications have configuration settings that automatically log a user out of the system after a period of inactivity, some systems have more limited capabilities and may activate a screen saver that is password protected.\ [671\]
The implementation specification under the standard for access control addresses encryption and decryption and requires regulated entities, when it is reasonable and appropriate, to implement a mechanism to encrypt and decrypt ePHI.\ [672\]
Encrypting data, including ePHI, reduces the likelihood that anyone other than the party that has the key to the encryption algorithm would be able to decrypt (
_i.e.,_
translate) the data and convert it into plain, comprehensible text.\ [673\]
The standard for audit controls requires a regulated entity to implement hardware, software, and/or procedural mechanisms that record and examine activity in electronic information systems that contain or use ePHI. Most electronic information systems provide some level of audit controls with a reporting method, such as audit reports.\ [674\]
These controls are useful for recording and examining information system activity, especially when determining whether a security violation has occurred.\ [675\]
The Security Rule does not identify data that must be gathered by the audit controls or how often the audit reports should be reviewed.\ [676\]
Instead, a regulated entity must consider its risk analysis and organizational factors, such as current technical infrastructure and hardware and software security capabilities, to determine reasonable and appropriate audit controls for information systems that contain or use ePHI.\ [677\]
The audit controls standard has no implementation specifications.
Section 164.312(c)(1), the standard for integrity, requires a regulated entity to implement policies and procedures to protect ePHI from improper alteration or destruction. The integrity of data can be compromised by both technical and non-technical sources. Workforce members or business associates may make accidental or intentional changes that improperly alter or destroy ePHI. Data can also be altered or destroyed without human intervention, such as by electronic media errors or failures.\ [678\]
The purpose of this standard is to establish and implement policies and procedures for protecting ePHI from being compromised regardless of the source. Improperly altered or destroyed ePHI can result in clinical quality problems for a covered entity, including patient safety issues.\ [679\]
Section 164.312(c)(2) contains the addressable implementation specification for the integrity standard that requires a regulated entity, when reasonable and appropriate, to implement electronic mechanisms to corroborate that ePHI has not been altered or destroyed in an unauthorized manner. To determine which electronic mechanisms should be implemented to ensure the integrity of ePHI, a regulated entity must consider the various risks to the integrity of ePHI identified during the risk analysis. Once a regulated entity has identified risks to the integrity of its data, it must identify security measures that will reduce the risks.\ [680\]
The standard for person or entity authentication at 45 CFR 164.312(d)) requires a regulated entity to establish policies and procedures for verifying that a person seeking access to ePHI is the one claimed. This standard addresses technical controls for ensuring access is allowed only to those persons or software programs that have been granted access rights under the administrative safeguard for information access management at 45 CFR 164.308(a)(4)(4)). This standard has no implementation specifications.
Under the standard for transmission security at 45 CFR 164.312(e)(1)(1)), a regulated entity is required to implement technical security measures to guard against unauthorized access to ePHI when transmitted electronically, such as through the internet. A regulated entity must identify the available and appropriate means to protect ePHI as it is transmitted, select appropriate solutions, and document its decisions.\ [681\]
The two addressable implementation specifications for the transmission security standards are under 45 CFR 164.312(e)(2)(2)). The implementation specification for integrity controls requires a regulated entity, when it is reasonable and appropriate, to implement security measures to ensure that electronically transmitted ePHI is not improperly modified without detection until the ePHI has been disposed.\ [682\]
The implementation specification for encryption requires a regulated entity, when it is reasonable and appropriate, to implement a mechanism to encrypt ePHI.
( printed page 964)
#### 2\. Issues To Address
While the intention of 45 CFR 164.312 is for regulated entities to develop and put into place technical controls, the Department is aware that regulated entities have not always achieved the degree of protection for ePHI that we intended. Absent a definition of “implement,” some regulated entities might interpret the term to mean something other than implementing technical controls to ensure the confidentiality, integrity, and availability of ePHI. This misinterpretation may leave ePHI partially unprotected because regulated entities may not implement safeguards throughout their enterprise. As discussed above with respect to both the administrative and physical safeguards, the Department is also concerned that regulated entities are not making the connection between the maintenance requirement at 45 CFR 164.306(d)) and the requirement to implement technical safeguards, and therefore, are not reviewing or updating their policies and procedures for technical safeguards. Additionally, the Department believes that regulated entities may not be recognizing that their obligations under the Security Rule to protect ePHI are not limited to protecting electronic information systems that create, receive, maintain, or transmit ePHI, but necessarily include other electronic information systems that affect the confidentiality, integrity, or availability of ePHI.
While the Security Rule relies on a flexible and scalable approach to compliance, the health care industry's shift to a digital environment has substantially increased both the risk to ePHI and the prevalence of technological solutions for addressing those risks. Additionally, the cost of such solutions has, in many cases, decreased over time, as is often the case with technology. For example, when the original Security Rule was published, tools to encrypt ePHI had limited availability, were more costly, and were not user-friendly, particularly for small health care providers.\ [683\]
By contrast, in 2024, the technical ability to encrypt data may be seamless in many applications, inexpensive, and widely available in commercial software and hardware products.\ [684\]
Where an encryption solution is not integrated into an application, software, or hardware, third-party solutions are often available.\ [685\]
Thus, we do not believe that it is appropriate for such provisions to be “addressable.” \ [686\]
Based on its own investigations and compliance reviews, news reports, and published studies, the Department is aware that many regulated entities have failed to implement adequate technical controls, or, in some cases, any technical controls. For example:
- A large health system that operates in multiple States experienced a massive data breach resulting from a hacking incident. OCR's investigation found indications of potential failures to sufficiently monitor its activity in its information systems that was insufficient to protect against a cyberattack, implement an authentication process to safeguard its ePHI, and have security measures in place to protect ePHI from unauthorized access when it was being transmitted electronically.\ [687\]
- A Rhode Island nonprofit health system experienced a data breach resulting from the theft of a laptop. OCR's investigation found indications of potential failures to encrypt ePHI, despite the entity's determination to implement encryption, and a lack of device and media controls.\ [688\]
- At a large covered entity, workforce members used their log-in credentials to access medical records maintained in the entity's EHR without a job-related purpose.\ [689\]
OCR's investigation found evidence of potential violations of the requirement to implement reasonable and appropriate policies and procedures to comply with the standards, implementation specifications, or other requirements of the Security Rule.\ [690\]
- At another covered entity, the potential failure to implement hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use ePHI, among other things, enabled a workforce member to sell the ePHI of more than 12,000 individuals.\ [691\]
Some investigations have found indications that regulated entities may implement technical controls that address some, but not all, users of and technology assets in a relevant electronic information system, such as software, hardware, and persons involved in the development, configuration, and implementation of technical controls.\ [692\]
And other investigations have suggested that the potential failure of a regulated entity to have security measures in place to protect ePHI from unauthorized access when it is transmitted electronically has resulted in increased risk and breaches of ePHI.\ [693\]
Common network segmentation practices would have substantially reduced the risk to the security ePHI and could have prevented such breaches.
Beyond the health care sector, threat actors have been able to gain access to networks by compromising user accounts and taking advantage of insufficient network segregation. For example, the 2014 Home Depot breach involved the compromise of a third-party vendor's username and password to enter Home Depot's network, which allowed hackers to obtain elevated rights to navigate to self-checkout point-of-sale system.\ [694\]
The Department is concerned about the potential effects of such incidents in health care, where they would jeopardize the confidentiality, integrity, and availability of ePHI.
Finally, consistent with the concerns expressed above about the implications of recent caselaw and the uncertainty it might cause among regulated entities assessing whether they have adequately protected their ePHI, the Department is concerned that the existing Security Rule may not provide sufficient instruction to regulated entities about
( printed page 965)
how they must maintain specific security measures.
#### 3\. Proposals
The Department retains the requirements for technical safeguards generally and proposes additions and modifications to the existing standards and implementation specifications.
#### a. Section 164.312—Technical Safeguards
The Department proposes to expand the primary provision at 45 CFR 164.312 to clarify that regulated entities as a general matter must implement and document the implementation of technical safeguards adopted for compliance with the Security Rule. This proposal would clarify that the requirement to implement and document technical safeguards would apply to all technical safeguards, including technical controls, implemented by a regulated entity to protect the confidentiality, integrity, and availability of all ePHI it creates, receives, maintains, or transmits.
As noted above, the current provision at 45 CFR 164.312 does not reference the documentation requirements in 45 CFR 164.316. Therefore, for clarity, we propose to explicitly require in 45 CFR 164.312 that documentation of technical safeguards conforms to the requirements in 45 CFR 164.316. This proposed change would clarify that a regulated entity must document the policies and procedures required to comply with this rule and how entities considered the flexibility factors in 45 CFR 164.306(b)). It would also clarify that a regulated entity must document each action, activity, and assessment required by the Security Rule. The Department considers the documentation requirements and other provisions of 45 CFR 164.316 to apply to all of the safeguards, including the technical safeguards, and this proposal is intended to remove any potential uncertainty among regulated entities. Additionally, we propose to add maintenance requirements separately to the implementation specifications for particular technical safeguards in 45 CFR 164.312, as discussed below and consistent with our proposals to add similar requirements to particular administrative and physical safeguards.
Additionally, as discussed above, the Department proposes to remove the distinction between required and addressable implementation specifications and make all implementation specifications required, with specific, limited exceptions. Also as discussed above, we propose to modify certain standards and implementation specifications to clarify that the technical safeguards apply to ensure the confidentiality, integrity, and availability of ePHI, which requires a regulated entity to implement the technical safeguards in or on all relevant electronic information systems. These proposals are discussed in greater detail below.
#### b. Section 164.312(a)(1)—Standard: Access Control
The Department proposes to clarify the standard for access control at 45 CFR 164.312(a)(1)(1)) by requiring a regulated entity to deploy technical controls in relevant electronic information systems to allow access only to those users and technology assets that have been granted access rights. This proposed modification would ensure that a regulated entity deploys technical controls, rather than solely ensuring that it implements technical policies and procedures, consistent with our proposals to define “deploy” and “implement.” \ [695\]
Thus, the proposal would clarify that a regulated entity is not expected to merely establish a policy and procedure, but must also put into place, ensure the operation of, and verify the continued operation of, technical controls for access to its relevant electronic information systems such that the failure to have such technical control in operation throughout its enterprise would be a violation of the new proposed standard. Additionally, the Department's proposal would clarify that access controls would apply to persons with authorized access and to technology assets.
Access controls are one of the key mechanisms by which a regulated entity protects ePHI. Such technical controls ensure that access to the regulated entity's electronic information systems is limited to only users and technology assets that have been granted access rights under the policies and procedures adopted in accordance with the standard for information access management under 45 CFR 164.308.\ [696\]
The Security Rule does not identify a specific type of access control method or technology to deploy, nor are we proposing to do so in this rule.\ [697\]
As discussed above, access rights should be role-based and the technical controls should assist the regulated entity in implementing such policies and procedures. For example, workforce members responsible for monitoring and administering a regulated entity's relevant electronic information systems, such as someone responsible for cybersecurity or providing technical support to users, must only have access to ePHI and to the regulated entity's relevant electronic information systems as appropriate for their role and job function.
We also propose at 45 CFR 164.312(a)(1)(1)) to add a paragraph heading to clarify the organization of the regulatory text.
The Department proposes to modify the existing implementation specifications under the standard for access control and to add five new implementation specifications. Additionally, we propose to redesignate the implementation specification for encryption and decryption as a standard.
We propose to modify the implementation specification for unique user identification at 45 CFR 164.312(a)(2)(i)(2)(i)) by renaming the implementation specification as “Unique identification” and adding a requirement to assign a unique identifier for tracking each technology asset. These proposed modifications would clarify for regulated entities that the purpose of this requirement is to enable a regulated entity to identify and track unauthorized activity in its relevant electronic information systems. Such unauthorized activity may include activity by unauthorized persons or technology assets. It may also include activity by persons who are authorized to access the regulated entity's relevant information systems but who access ePHI that they do not need to access for their job or function.
The Department also proposes to expand the types of identifiers a regulated entity may assign to users and technology assets beyond names to include numbers and/or other identifiers and to clarify that a unique identifier must be assigned to each user and technology asset in the regulated entity's relevant electronic information systems. This proposed modification would better meet the goals of this implementation specification by requiring a regulated entity to be able to discern and track activities among all users and technology assets, regardless of whether that user or technology asset is a person, hardware, software program, or device. The proposed implementation specification for unique identification aligns with the Department's essential CPG for Unique Credentials, which calls for regulated entities to use unique credentials to
( printed page 966)
help detect and track anomalous activities.\ [698\]
Additionally, we propose to add an implementation specification at proposed 45 CFR 164.312(a)(2)(ii)(2)(ii)) for administrative and increased access privileges. Access controls should enable an authorized user to access the minimum necessary information needed to perform their job functions.\ [699\]
Rights and/or privileges should be granted to authorized users based on the policies and procedures required under the administrative safeguard for information access management.\ [700\]
For example, a workforce member who has certain role-based administrative access privileges should have separate user identities for non-administrative access privileges and administrative access privileges. Separating a single workforce member's user identities based on access privilege substantially limits the risk that an intruder will be able to access ePHI through a workforce member's user identity when they are using the administrative access privileges.\ [701\]
A regulated entity may be able to improve the control and review of the use of administrative access privileges, such as through a privileged access management system, to understand how privileged accounts are used within its environment and help detect and prevent the misuse of privileged accounts.\ [702\]
The proposed implementation specification would require a regulated entity to separate the unique user identities required by the implementation specification for unique user identification based on the type of access privileges used by a specific unique user. For example, the adoption of health IT that is certified through the ONC Health IT Certification Program as having the technical capability to establish user permissions for accessing, and performing actions with, electronic health information based on unique identifiers may contribute to a regulated entity's compliance with the proposed new implementation specification for administrative and increased access privileges, should the proposal be finalized.\ [703\]
This proposed new implementation specification aligns with the Department's essential CPG for Separate User and Privileged Accounts by addressing the separation of privileged or administrator access rights from common user accounts.\ [704\]
Additionally, the Department proposes to redesignate the implementation specification for emergency access procedures at 45 CFR 164.312(a)(2)(ii)(2)(ii)) as proposed 45 CFR 164.312(a)(2)(iii)(2)(iii)) and to modify it to require a regulated entity to establish both written procedures and technical procedures for obtaining necessary ePHI during an emergency and to implement them as needed. For example, we note that the adoption of health IT that is certified through the ONC Health IT Certification Program as having the technical capability to permit an identified set of users to access electronic health information during an emergency may contribute to a regulated entity's compliance with the proposed implementation specification for emergency access procedures, should the proposal be finalized.\ [705\]
Under the Department's proposal, the implementation specification for automatic logoff at 45 CFR 164.312(a)(2)(iii)(2)(iii)) would be redesignated as proposed 45 CFR 164.312(a)(2)(iv)(2)(iv)) and modified to require a regulated entity to deploy technical controls that terminate an electronic session after a period of inactivity. Deploying a mechanism to automatically terminate an electronic session after a period of inactivity reduces the risk of unauthorized access when a user forgets or is unable to terminate their session.\ [706\]
Failure to deploy automatic logoff not only increases the risk of unauthorized access and potential alteration or destruction of ePHI; it also impedes an organization's ability to properly investigate such unauthorized access because it would appear to originate from an authorized user.\ [707\]
The Department proposes that the period of inactivity be both predetermined and reasonable and appropriate. When determining the length of the period of inactivity, a regulated entity should consider the access privileges of a given user or technology asset, the system(s) being accessed, the environment in which the system access occurs, and other appropriate factors in determining a reasonable and appropriate time of inactivity before session termination. For example, in an emergency setting, a user may not have time to manually log out of a system. User identities with administrative and other high-level access that present a greater risk to the confidentiality, integrity, and availability of ePHI should have appropriately shorter periods of inactivity because of the increased risk. While many applications have configuration settings for automatic logoff,\ [708\]
a regulated entity must determine whether the default automatic logoff is reasonable and appropriate and make modifications if it is not. For example, the adoption of health IT that is certified through the ONC Health IT Certification Program as having the technical capability to automatically stop a user's access to health information after inactivity for a predetermined period and require a user to re-enter their credentials to resume or regain access may contribute to a regulated entity's compliance with the proposed implementation specification for automatic logoff, should the proposal be finalized.\ [709\]
Additionally, we propose to add an implementation specification for log-in attempts at proposed 45 CFR 164.312(a)(2)(v)(2)(v)). The proposal would require a regulated entity to deploy technical controls that disable or suspend the access of a user or technology asset to relevant electronic information systems after a certain number of unsuccessful authentication attempts. Although incorrectly keying in a known password by the intended user may occur infrequently, a repeated and persistent failure is a strong indication of an attempt at unauthorized access. For example, brute force attacks are attempts to gain unauthorized access by guessing the password many times in a row.\ [710\]
Technical controls that limit the number of incorrect log-in attempts by disabling or suspending the access of a user or technology asset to relevant electronic information systems are appropriate to address unsuccessful login attempts.\ [711\]
The proposal would require a regulated entity to determine the number of unsuccessful authentication attempts that would trigger disabling or suspending access to relevant electronic information system. The number should
( printed page 967)
be reasonable and appropriate for the type of user or technology asset, the electronic information system or technology asset to which access is sought, and the type of information maintained on such information system or technology asset. For example, a regulated entity may determine that any authentication failure of an administrative privileged access account should disable the account because of the level of risk compared to an authentication failure of a non-administrative privileged account. The Department does not propose to define disable or suspend and relies upon the industry understanding that disabling a user's access would require intervention to restore the capability to use the user identity, while a suspension may prevent additional log-in attempts for a temporary, limited period of time.
Consistent with NCVHS' recommendation and existing guidance, the Department also proposes to add an implementation specification for network segmentation at 45 CFR 164.312(a)(2)(vi)(2)(vi)) that would require a regulated entity to deploy technical controls to segment its relevant electronic information systems in a reasonable and appropriate manner.\ [712\]
Under this proposal, a regulated entity with multiple, distinct electronic information systems would be required to separate relevant electronic information systems using reasonable and appropriate technical controls. Network segmentation is a physical or virtual division of a network into multiple segments, creating boundaries between the operational and IT networks to reduce risks, such as threats caused by phishing attacks.\ [713\]
For example, where a regulated entity operates both a point-of-sale system and an EHR on the same network, the EHR could be compromised through a successful attack by an intruder moving laterally (
_i.e.,_
within the same network) from a previously compromised point-of-sale system because the intruder's movements were not impeded by network segmentation. Accordingly, we believe that it is appropriate to require regulated entities to deploy technical controls to segment the networks to which their relevant electronic information systems are connected.\ [714\]
What constitutes reasonable and appropriate network segmentation depends on the regulated entity's risk analysis and how it has implemented its network(s) and relevant electronic information systems. This proposed new implementation specification aligns with the Department's enhanced CPG for Network Segmentation because where the CPG is implemented, an intruder's ability to freely move within a regulated entity's network and protect ePHI is minimized.\ [715\]
The proposed implementation specification for data controls at proposed 45 CFR 164.312(a)(2)(vii)(2)(vii)) would require a regulated entity to deploy technical controls to allow access to ePHI based on the regulated entity's policies and procedures for granting users and technology assets access relevant electronic information systems as specified in proposed 45 CFR 164.308(a)(10)(10)). This implementation specification would require a regulated entity to have in place technical controls that distinguish between users and technology assets, that are permitted to access the regulated entity's relevant electronic information systems and those that are not permitted to do so and would require that the controls permit or disallow access accordingly.
Properly deployed network-based solutions can limit the ability of a hacker to gain access to an organization's network or impede the ability of a hacker already in the network from accessing other electronic information systems—especially systems containing sensitive data.\ [716\]
Access controls could include role-based access, user-based access, or any other access control mechanisms the organization deems appropriate.\ [717\]
Access controls need not be limited to computer systems—firewalls, network segmentation, and network access control solutions are effective means of limiting access to relevant electronic information systems.\ [718\]
Additionally, we propose to add an implementation specification for maintenance at proposed 45 CFR 164.312(a)(2)(viii)(2)(viii)). Under this proposal, a regulated entity would be expressly required to review and test the effectiveness of the procedures and technical controls required by the implementation specifications associated with the standard for access control at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
#### c. Section 164.312(b)(1)—Standard: Encryption and Decryption
Encryption can reduce the risks and costs of unauthorized access to ePHI.\ [719\]
For example, if a hacker gains access to unsecured ePHI on a network server or if a device containing unsecured ePHI is stolen, a breach of PHI will be presumed and reportable under the Breach Notification Rule.\ [720\]
The Breach Notification Rule applies to unsecured PHI, which is PHI that is not rendered unusable, unreadable, or indecipherable to unauthorized persons through the use of a technology or methodology specified by the Secretary in guidance issued under the HITECH Act.\ [721\]
The Department's guidance on rendering unsecured PHI unusable, unreadable, or indecipherable to persons who are not authorized to access such PHI states that ePHI at rest (
_i.e.,_
stored in an information system or electronic media) is considered secured if it is encrypted in a manner consistent with NIST Special Publication 800-111 \ [722\]
(“SP 800-111”). The ePHI encrypted in a manner consistent with SP 800-111 is not considered unsecured PHI and therefore qualifies for what is commonly known as the Breach Notification safe harbor, meaning that it is not subject to the requirements of the Breach Notification Rule.\ [723\]
Thus, by encrypting ePHI in a manner consistent with the Secretary's guidance, a regulated entity may not only fulfill its encryption obligation under the Security Rule, but also make use of the
( printed page 968)
Breach Notification Rule's safe-harbor provision.\ [724\]
As the use of mobile computing devices (
_e.g.,_
laptops, smartphones, tablets) has become more pervasive, the risks to sensitive data stored on such devices also have increased.\ [725\]
And while in 2003 and even in 2013, encryption might have been out of reach for many regulated entities because of cost or a similar reason,\ [726\]
today, encryption solutions are generally considered to be widely accessible. The cost of such solutions has decreased significantly, as has the difficulty in implementing such solutions. In fact, many applications have encryption solutions embedded in them.\ [727\]
Once enabled, a device's encryption solution can protect stored sensitive data, including ePHI, from unauthorized access in the event the device is lost or stolen. The same is true for most software today.\ [728\]
Thus, while encryption of a particular regulated entity's ePHI might not have been reasonable and appropriate in 2003 or 2013, the Department believes encryption generally is reasonable and appropriate today.\ [729\]
Because the prevalence of encryption solutions has increased, as has their affordability and the role they play in protecting information, including ePHI, the Department believes it is appropriate to consider requiring encryption and elevating it from an implementation specification to a standard to increase its visibility and prominence. Based on this and consistent with NCVHS' recommendation, the Department proposes to redesignate the implementation specification for encryption and decryption at 45 CFR 164.312(a)(2)(iv)(2)(iv)) as a standard at proposed 45 CFR 164.312(b)(1)(1)).\ [730\]
The proposed standard would incorporate the requirements of two implementation specifications that address encryption—the one addressed here and the one at 45 CFR 164.312(e)(2)(ii)(2)(ii)).\ [731\]
The Department proposes that the new standard would require a regulated entity to configure and implement technical controls to encrypt and decrypt all ePHI in a manner that is consistent with prevailing cryptographic standards. This proposed new standard aligns with the Department's essential CPG for Strong Encryption by calling for regulated entities to deploy encryption to protect ePHI and with the recommendation of NCVHS.\ [732\]
We also note that the adoption of health IT that is certified through the ONC Health IT Certification Program as having the technical capability to encrypt and decrypt electronic health information, using an encryption algorithm that meets certain requirements, may contribute to a regulated entity's compliance with the proposed standard for encryption and decryption, should the proposal be finalized.\ [733\]
Under the proposal, a regulated entity would need to ensure that an encryption solution that it adopts meets prevailing cryptographic standards prior to using it. The Department uses the phrase “prevailing cryptographic standards” to refer to widely accepted standards for encryption and decryption that are recommended by authoritative sources and that ensure the confidentiality, integrity, and availability of ePHI at the time the regulated entity performs its risk analysis and establishes or modifies its risk management plan. The Department would expect a regulated entity to deploy updated encryption solutions as prevailing cryptographic standards evolve, consistent with both of the proposed requirements discussed above: (1) to review, verify, and update its risk analysis in response to changes in its environment that may affect ePHI; and (2) to review and modify, as reasonable and appropriate, its risk management plan in response to changes in its risk analysis. Thus, a regulated entity using an encryption algorithm that is known to be insecure would not be in compliance with the proposed requirement to deploy an encryption algorithm that meets prevailing cryptographic standards. We are not proposing to define prevailing cryptographic standards in regulatory text at this time.
The Department proposes to add one implementation specification for the proposed standard for encryption and decryption. Specifically, proposed 45 CFR 164.312(b)(2)(2)) would require regulated entities to encrypt all ePHI at rest and in transit, with limited exceptions.\ [734\]
Thus, a regulated entity would be required to encrypt all ePHI it maintains, as well as all ePHI it transmits, unless an exception applies, and the following conditions are met:
- Each exception applies only to the ePHI directly affected by the circumstances described in the specific exception.
- Each exception applies only to the extent that the regulated entity documents its understanding that the exception applies to the scenario in which the regulated entity relies upon the exception and why or how the exception applies, and that any additional applicable conditions are met.
The first proposed exception at proposed 45 CFR 164.312(b)(3)(i)(3)(i)) would apply to a technology asset currently used by a regulated entity that does not support encryption according to prevailing cryptographic standards. Because the requirements for encryption under the Security Rule today are addressable, a regulated entity may be in compliance with the encryption requirement without actual encryption of ePHI if encryption is not reasonable and appropriate, provided that the entity meets certain conditions. Additionally, technology assets in use today may rely on cryptographic standards that are no longer accepted industry practice. The Department recognizes that it may take some time for a regulated entity to adopt compliant technology assets. Thus, we propose this exception for such technology assets that do not support encryption consistent with prevailing cryptographic standards in limited circumstances. Specifically, to meet this exception, a regulated entity would be required to establish a written plan to migrate ePHI to technology assets that support encryption consistent with prevailing cryptographic standards and to implement such plan. The regulated entity would be required to establish and implement the written plan within
( printed page 969)
a reasonable and appropriate period of time. For example, it would not be reasonable or appropriate for a regulated entity to establish a plan to migrate ePHI on a single flash drive within 30 days and not complete migration of that ePHI for a period of a year because migrating ePHI from a flash drive to a more secure medium is a simple and quick process that the regulated entity already determined could be completed within 30 days. Thus, a year would be an unreasonably long period to leave ePHI insufficiently encrypted, particularly after a need to migrate the ePHI has been established. In such circumstances, the regulated entity would not be complying with the requirements of this proposed exception.
The second proposed exception at proposed 45 CFR 164.312(b)(3)(ii)(3)(ii)) would be available for ePHI transmitted in response to an individual request, pursuant to 45 CFR 164.524, to receive their ePHI in an unencrypted manner. Unencrypted manners for an individual to receive their ePHI may include some types of text messaging, instant messaging, and other applications on a smartphone or another computing device that are capable of making an access request and receiving ePHI.\ [735\]
This exception for individual access requests under 45 CFR 164.524 would not apply when the individual would receive their ePHI using technology controlled by the regulated entity, such as a patient portal \ [736\]
or other technology for the transmission of ePHI (
_e.g.,_
API technology).\ [737\]
Such email or messaging technologies are considered to be among a covered entity's technology assets because they are components of a covered entity's relevant electronic information systems, and the requirement to encrypt ePHI would apply.
Under the right of access, an individual who is the subject of PHI has the right to inspect and request a copy of PHI about them in a designated record set, subject to certain exceptions. A regulated entity is required to provide such access in the form and format requested by the individual, if it is readily producible in such form and format. Thus, if an individual requests that the regulated entity provide them access in a manner that does not support encryption, a regulated entity is generally required to do so if it does not jeopardize the security of the regulated entity's information systems. For the exception to apply, a regulated entity would be required to have informed the individual of the risks associated with the transmission, receipt, and storage of unencrypted ePHI when the individual requests unencrypted access and to document that the individual has been informed of such risks.\ [738\]
Consistent with the information blocking regulations, the information provided by regulated entities that are also actors must: focus on any current privacy and/or security risks posed by the technology or the third-party developer of the technology; be factually accurate, unbiased, objective, and not unfair or deceptive; and be provided in a non-discriminatory manner.\ [739\]
For example, a regulated entity that is an actor must provide information to individuals about the privacy and security risks of all mobile health applications in the same manner.
We are not proposing to require that the documentation be in any particular form or format. Rather, the required information could be on a standard form, chart note, or checkbox, as examples. The Department does not propose to apply this exception to ePHI transmitted in other forms or formats, such as on a CD or other physical device used to maintain and transmit ePHI. The proposal would not absolve a regulated entity from compliance with other applicable laws or regulations, including the information blocking regulations.\ [740\]
We recognize that emergencies or other occurrences may render it infeasible to encrypt ePHI. Thus, the third proposed exception at 45 CFR 164.312(b)(3)(iii)(3)(iii)) would apply to certain circumstances in which encryption is infeasible. Such circumstances would be limited to when there is emergency or other occurrence that adversely affects a regulated entity's relevant electronic information systems. For the proposed exception to apply, a regulated entity would be required to implement reasonable and appropriate compensating controls in accordance with and determined by its contingency plan.\ [741\]
The Department would expect this proposed exception to be applicable for a limited period of time and only when encryption is infeasible. As noted above, the proposed exception to encryption would narrowly apply only when a regulated entity's relevant electronic information system is adversely affected by the emergency or other occurrence. The proposed exception would no longer be applicable at such time encryption becomes feasible, regardless of whether the emergency or other occurrence continues.
The fourth proposed set of exceptions at proposed 45 CFR 164.312(b)(3)(iv)(3)(iv)) would be for ePHI that is created, received, maintained, or transmitted by a medical device (
_i.e.,_
a “device” within the meaning of section 201(h) of the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. 321(h)) that is authorized by the FDA for marketing. We propose three separate exceptions for devices that are authorized by the FDA for marketing pursuant to: a submission received before March 29, 2023; a submission received on or after March 29, 2023, where the device is no longer supported by its manufacturer; or a submission received on or after March 29, 2023, where the device is supported by its manufacturer. Where a device has been authorized by the FDA for marketing pursuant to a submission received before March 29, 2023, we propose that the exception at proposed 45 CFR 164.312(b)(3)(iv)(A)(3)(iv)(A)) would be available only where the regulated entity deploys in a timely manner any updates or patches required or recommended by the manufacturer of the device. We also propose a similar exception at proposed 45 CFR 164.312(b)(3)(iv)(B)(3)(iv)(B)) for devices authorized by the FDA for marketing pursuant to a submission received on or
( printed page 970)
after March 29, 2023, where the device is no longer supported by its manufacturer, provided that the regulated entity has deployed any updates or patches required or recommended by the manufacturer.
We recognize that, to comply with this proposal, some regulated entities may incur costs for replacing legacy medical devices (
_i.e.,_
medical devices that cannot be reasonably protected against current cybersecurity threats).\ [742\]
We also recognize that legacy devices can pose significant risks to the confidentiality, integrity, and availability of ePHI.\ [743\]
By limiting these exceptions to devices that have been updated and/or patched while they were supported by their manufacturer, we believe that this proposal would balance the interest in encouraging regulated entities to dispense with legacy devices with the cost of replacing such devices. Additionally, the Department believes that regulated entities should already have plans to replace legacy devices that cannot be made cybersecure because of their existing Security Rule obligations. We also recognize that at some point, most, if not all, devices will likely become legacy devices and that there may be legitimate reasons not to immediately replace them when the manufacturer ceases to provide support. In such cases, it will continue to be important for regulated entities to plan for how to address their ongoing Security Rule obligations.
Finally, we propose an exception, proposed 45 CFR 164.312(b)(3)(iv)(C)(3)(iv)(C)), that would be available for a device authorized by the FDA for marketing pursuant to a submission received on or after March 29, 2023, where the device is supported by its manufacturer. We understand that the FDA considers security during the review of medical device marketing submissions, including those for software that is approved as a medical device, and works with device manufacturers to ensure that appropriate cybersecurity protections are built into such devices, pursuant to FDA's authority under the Consolidated Appropriations Act, 2023.\ [744\]
Thus, we do not believe it would be necessary or appropriate for the Security Rule to require encryption for an FDA-authorized medical device that has been authorized by the FDA for marketing pursuant to a submission received on or after March 29, 2023 where the device continues to be supported by its manufacturer.
Where a proposed exception applies to the proposed encryption requirement, the Department also proposes to require that a regulated entity implement alternative measures and compensating controls. Specifically, we propose at proposed 45 CFR 164.312(b)(4)(i)(4)(i)) to require a regulated entity to document the existence of an applicable exception and implement reasonable and appropriate compensating controls. Under the proposal, we would require documentation to occur in real-time, meaning when the criteria for the exception exist and at the time compensating controls are implemented. For example, a regulated entity disclosing ePHI to an individual by unencrypted email in accordance with the right of access would be required to document in accordance with the proposed 45 CFR 164.312(b)(4)(i)(4)(i)) that: (1) before the disclosure, the individual has requested to receive ePHI by unencrypted email or unencrypted messaging technology; and (2) before the disclosure, the regulated entity informed the individual of the risks associated with transmission of unencrypted ePHI. The exception would not apply where such individual requests to receive access to their ePHI pursuant to 45 CFR 164.524 via email or messaging technologies implemented by the covered entity.
At proposed 45 CFR 164.312(b)(4)(i)(4)(i)), the Department proposes to require that where a proposed exception applies, a regulated entity would also be required to implement an alternative measure or measures that are reasonable and appropriate compensating controls under proposed 45 CFR 164.312(b)(4)(ii)(4)(ii)). Compensating controls would be implemented in the place of encryption to protect ePHI from unauthorized access.\ [745\]
The Department does not propose to require that compensating controls be limited to technical controls. Rather, a regulated entity should consider the nature of the exception, operating environment, and other appropriate circumstances to determine what controls are reasonable and appropriate and implement compensating controls effective for those circumstances. For example, a regulated entity may use physical access controls, such as physically limiting access to a device, in combination with other controls to compensate for the absence of encryption.
Proposed paragraph (b)(4)(ii)(A) would require that if the regulated entity has determined that an exception applies, it must secure ePHI by implementing reasonable and appropriate compensating controls that are reviewed and approved by the regulated entity's designated Security Official. Because exceptions are a departure from the Security Rule framework, the Department proposes to ensure appropriate focus and review by the Security Official of the controls chosen to compensate for the absence of encryption.
With respect to the exception at proposed 45 CFR 164.312(b)(3)(iv)(C)(3)(iv)(C)), the Department proposes at paragraph (b)(4)(ii)(B) to presume that a regulated entity had implemented reasonable and appropriate compensating controls where the regulated entity has deployed the security measures prescribed and as instructed by the FDA-authorized label for the device. This would include any updates, including patches recommended or required by the manufacturer of the device. The proposed language recognizes that while the device's label may not specifically require deployment of an encryption solution, it may provide for a specific compensating control and the manner in which that control is to be implemented. While not required, a regulated entity would be permitted to implement additional alternative security measures and compensating controls in accordance with best practices and/or its risk analysis.
Finally, at proposed paragraph (b)(4)(ii)(C), the Department proposes to require that the regulated entity's Security Official review and document the implementation and effectiveness of the compensating controls during any period in which such compensating controls are in use to continue securing ePHI and relevant electronic
( printed page 971)
information systems. While regulated entities should review deployed compensating controls on a routine basis, the Department proposes to require a regulated entity to periodically review the implementation and effectiveness of compensating controls to ensure the continued protection of ePHI.\ [746\]
For example, if a regulated entity's plan to migrate ePHI from hardware that does not support encryption changes such that the use of the unencrypted hardware continues for a longer period of time, the regulated entity should review implemented compensating controls to ensure ongoing effectiveness and whether new compensating controls should be deployed. We propose to require the designated Security Office conduct such review at least once every 12 months or in response to environmental or operational changes, whichever is more frequent. Additionally, the Department proposes to require that the review be documented in writing and signed. If the regulated entity's Security Official review determines that certain compensating controls are no longer effective, the Department expects that the regulated entity would adopt new compensating controls that are effective to continue to meet the applicable exception. For example, a regulated entity would be expected to update any compensating controls for use of an FDA-authorized medical device when and as instructed by the manufacturer of the device.
We also propose to add an implementation specification for maintenance at proposed 45 CFR 164.312(b)(5)(5)). Under this proposal, a regulated entity would be expressly required to review and test the effectiveness of the technical controls required by the standard for encryption at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate. This proposal is consistent with others in this NPRM that would require regulated entities to maintain specified administrative, physical, and technical safeguards.
#### d. Section 164.312(c)(1)—Standard: Configuration Management
The Department believes that the failure to configure technical controls appropriately and to establish and maintain secure baselines for relevant electronic information systems and technology assets in its relevant electronic information systems presents an opportunity for cyberattack and compromise of ePHI.\ [747\]
Accordingly, we propose to add a standard for configuration management at proposed 45 CFR 164.312(c)(1)(1)). The proposed standard would require a regulated entity to establish and deploy technical controls for securing relevant electronic information systems and technology assets in its relevant electronic information systems, including workstations, in a consistent manner. Under this proposal, a regulated entity also would be required to establish a baseline (
_i.e.,_
minimum) level of security for each relevant electronic information system and technology asset in its relevant electronic information systems and to maintain such information systems and technology assets according to those secure baselines. Consistent with our proposals regarding risk analysis and risk management planning, the Department intends for a regulated entity to establish its security baseline and to maintain that baseline even when technology changes. For example, a regulated entity that uses software to access ePHI would be required to update the software with patches as reasonable and appropriate. But where a developer ceases to support a software, it would be reasonable and appropriate for the regulated entity to take steps to either replace it or to otherwise ensure that its level of security remains consistent with the regulated entity's established baseline. Under this proposal, if finalized, the Department would expect a regulated entity to continually monitor its relevant electronic information systems and technology assets in its relevant electronic information systems to ensure that the secure baselines established by the regulated entity are maintained and take appropriate actions when a relevant electronic information system or technology asset in a relevant electronic information system fails to meet the established baselines. A regulated entity's secure baselines would be determined based on its risk analysis and use of security settings that are consistent across its relevant electronic information systems and technology assets in its relevant electronic information systems. For example, the risk analysis may determine that a manufacturer's default settings for a particular technology asset are insufficient. Accordingly, the regulated entity may establish the baseline for settings that should be applied to the particular asset and similar technologies across the regulated entity's enterprise. This proposed standard aligns with the Department's enhanced CPG for Configuration Management, which calls for regulated entities to define secure device and system settings. It also aligns with the enhanced CPG for Detect and Respond to Relevant Threats and Tactics, Techniques, and Procedures by calling for regulated entities to include malware protection in their security baseline to detect threats and protect electronic information systems.\ [748\]
Additionally, the proposed standard also aligns with the Department's essential CPG for Email Security, which addresses the reduction of risks from email-based threats.\ [749\]
The Department proposes five implementation specifications for the proposed standard for configuration management.\ [750\]
Under the proposed implementation specification for anti-malware protection at proposed 45 CFR 164.312(c)(2)(i)(2)(i)), a regulated entity would be required to deploy technology assets and/or technical controls that protect all of the technology assets in its relevant electronic information systems against malicious software, such as viruses and ransomware. Anti-malware software, especially when used in combination with other technical controls such as intrusion detection/prevention solutions, can also help prevent, detect, and contain cyberattacks.\ [751\]
This protection would be applied to all of a regulated entity's technology assets in its relevant electronic information systems. When determining how to fulfill this proposed obligation, regulated entities may consider deploying tools such as anti-malware and endpoint detection and response (EDR) solutions. Anti-malware tools generally scan a regulated entity's electronic information systems to
( printed page 972)
identify malicious software.\ [752\]
Such tools may also quarantine malicious software if identified. As explained by the Office of Management and Budget, “EDR combines real-time continuous monitoring and collection of endpoint data \[. . .\] with rules-based automated response and analysis capabilities.” \ [753\]
We propose a new implementation specification for software removal at proposed 45 CFR 164.312(c)(2)(ii)(2)(ii)) to require a regulated entity to remove extraneous software from the regulated entity's relevant electronic information systems. Software is extraneous if it is unnecessary for the regulated entity's operations. It can be a target for attack, and older applications may no longer be supported with patches for new vulnerabilities.\ [754\]
Removal of unnecessary software reduces an avenue of attack. The Department is not proposing to specify what would constitute necessary and unnecessary software. Rather, we intend that the regulated entity would consider removal of unwanted or unused software, for example, default software added by a computer manufacturer or reseller where such software may open an avenue for unnecessary risk because the regulated entity does not intend to use it. Accordingly, the proposal would require a regulated entity to consider all software on its relevant electronic information systems and any potential avenue of risk and address the risk through software removal where such software is unnecessary for the regulated entity's operations.
The proposed implementation specification for configuration at proposed 45 CFR 164.312(c)(2)(iii)(2)(iii)) would require a regulated entity to configure and secure operating systems and software in a manner consistent with the regulated entity's risk analysis. Generally, a regulated entity's risk analysis should guide its implementation of appropriate technical controls to reduce the risk to ePHI.\ [755\]
Requiring operating systems and software to be maintained in a secure manner would reduce exploitable vulnerabilities.\ [756\]
Often, known vulnerabilities can be mitigated by applying vendor patches or upgrading to a newer version.\ [757\]
Under the proposed implementation specification for network ports at proposed 45 CFR 164.312(c)(2)(iv)(2)(iv)), a regulated entity would be required to disable network ports in accordance with the regulated entity's risk analysis.\ [758\]
Successful ransomware deployment often depends on the exploitation of technical vulnerabilities such as unsecured ports.\ [759\]
The proposal to require network ports to be disabled in accordance with the risk analysis would reduce exploitable vulnerabilities.\ [760\]
Lastly, the proposed implementation specification for maintenance at proposed 45 CFR 164.312(c)(2)(v)(2)(v)) would expressly require a regulated entity to review and test the effectiveness of the technical controls required by the other implementation specifications associated with the standard for configuration management at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
#### e. Section 164.312(d)(1)—Standard: Audit Trail and System Log Controls
Audit controls are crucial technical safeguards that are useful for recording and examining activity in electronic information systems, especially when determining whether a security violation occurred.\ [761\]
A regulated entity must consider its risk analysis and organizational factors, such as current technical infrastructure, hardware, and software security capabilities, to determine reasonable and appropriate audit controls.\ [762\]
However, based on OCR's enforcement experience, we believe that regulated entities' understanding of and compliance with this standard could be improved by providing more specificity.
Accordingly, the Department proposes to redesignate the standard for audit controls at 45 CFR 164.312(b)) as proposed 45 CFR 164.312(d)(1)(1)), rename it as the standard for audit trail and system log controls, and to add a paragraph heading to clarify the organization of the regulatory text. We also propose to modify it to require a regulated entity to deploy either or both technology assets and technical controls that record and identify activity in the regulated entity's relevant electronic information systems. The proposal would replace “procedural mechanisms” with “technical controls,” to match the general focus on technical controls in 45 CFR 164.312 and would recognize that a regulated entity may be able to meet the requirements of the standard by deploying either or both technology assets (
_e.g.,_
software) or technical controls. Under the proposal, a regulated entity would be required to collect sufficient information to understand what a specific activity in its relevant electronic information systems is, such that the regulated entity would be better able to address activity that presents a risk to the confidentiality, integrity, or availability of ePHI. For example, a regulated entity should understand that a given activity in a relevant electronic information system is an attempt to access a portable workstation without authorization. The proposal also would modify the limitation on the regulated entity's obligation to record and identify activity in its relevant electronic information systems. Thus, the proposal would require a regulated entity to record and identify any activity that could present a risk to ePHI, meaning activity in all of its relevant electronic information systems, not only in its electronic information systems that create, receive, maintain, or transmit ePHI. In so doing, the Department would also require a regulated entity to record and identify activity in its electronic information systems that may affect the confidentiality, integrity, or availability of ePHI. This redesignated standard, as proposed, aligns more closely with the Department's enhanced CPG for Centralized Log Collection by addressing the deployment of technical controls to record and identify activity in all electronic information systems.\ [763\]
Additionally, as an example, we note that adoption of health IT certified through the ONC Health IT Certification Program may contribute to a regulated entity's compliance with the proposed standard for audit trail and system log controls where such health IT meets the criteria for auditing actions on health information and recording actions related to electronic health information and audit log status.\ [764\]
( printed page 973)
The Department proposes four implementation specifications under this proposed standard that are intended to improve the effectiveness of audit controls deployed by a regulated entity. The proposed implementation specification for monitoring and identifying activity at proposed 45 CFR 164.312(d)(2)(i)(2)(i)) would require a regulated entity to deploy technology assets and/or technical controls that monitor in real-time (
_i.e.,_
contemporaneously) all activity occurring in a regulated entity's relevant electronic information systems and identify indications of unauthorized persons and unauthorized activity, as determined by the regulated entity's risk analysis. As proposed, the technology assets and/or technical controls also would be required to alert workforce members of such indications in accordance with the regulated entity's policies and procedures for information system activity review at proposed 45 CFR 164.308(a)(7)(7)). Unauthorized activity may include actions by technology assets or persons that have not been authorized to access the regulated entity's ePHI or relevant electronic information systems. It may also include actions by authorized users or technology assets that are inconsistent with the regulated entity's policies and procedures for information access management at proposed 45 CFR 164.308(a)(10)(10)). The Department proposes that monitoring be continual and conducted in real-time because asynchronous review would allow for the compromise of ePHI for the period of time between the unauthorized activity and its discovery. OCR's enforcement experience has shown that some regulated entities are potentially failing to implement appropriate audit controls or to review information system activity in a timely manner, which may have contributed to a reportable breach.\ [765\]
A regulated entity would be required, under the proposed implementation specification for recording activity at proposed 45 CFR 164.312(d)(2)(ii)(2)(ii)), to deploy technology assets and/or technical controls that record in real-time all activity in the regulated entity's relevant electronic information systems.\ [766\]
While technical assets and/or technical controls deployed in accordance with proposed 45 CFR 164.312(d)(2)(i)(2)(i)) would monitor activity in its relevant electronic information systems, recording such activity would enable a regulated entity to assess any activity to better understand the activity's effects. The proposed implementation specification at proposed 45 CFR 164.312(d)(2)(iii)(2)(iii)) would require a regulated entity to deploy technology assets and/or technical controls to retain records of all activity in its relevant electronic information systems as determined by the regulated entity's policies and procedures for information system activity review at 45 CFR 164.308(a)(7)(ii)(A)(7)(ii)(A)). The proposed implementation specification for scope of activity at proposed 45 CFR 164.312(d)(2)(iv)(2)(iv)) would clarify what would constitute activity to be monitored and recorded in the regulated entity's relevant electronic information systems as required by the proposed implementation specifications at proposed 45 CFR 164.312(d)(2)(i)(2)(i)) and (ii)(2)(ii)). Specifically, the Department proposes that such activities would include, but would not be limited to, creating, accessing, receiving, transmitting, modifying, copying, or deleting ePHI; and creating, accessing, receiving, transmitting, modifying, copying, or deleting relevant electronic information systems and the information (
_i.e.,_
not only ePHI) therein.
We also propose to add an implementation specification for maintenance at proposed 45 CFR 164.312(d)(2)(iv)(2)(iv)). Under this proposal, a regulated entity would be expressly required to review and test the effectiveness of the technology assets and/or technical controls required by the respective implementation specifications of this section at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
#### f. Section 164.312(e)—Standard: Integrity
Improper alteration or destruction of ePHI, even unintentionally, can result in clinical quality problems, including patient safety issues, for a covered entity.\ [767\]
Workforce members or business associates may make accidental or intentional changes that improperly alter or destroy ePHI.\ [768\]
Data can also be altered or destroyed without human intervention, such as by electronic media errors or failures.\ [769\]
It is important to protect ePHI from being compromised, regardless of the source.\ [770\]
The current standard for integrity at 45 CFR 164.312(c)(1)(1)) requires implementation of policies and procedures, rather than actual deployment of technical controls, to ensure integrity of ePHI. To improve the effectiveness of this standard, the Department proposes to redesignate it as proposed 45 CFR 164.312(e)) and modify it for clarity. Under the proposal, a regulated entity would be required to deploy technical controls to protect ePHI from improper alteration or destruction when at rest and in transit and to review and test the effectiveness of such technical controls at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate. For example, the adoption of health IT that is certified through the ONC Health IT Certification Program as having the technical capability to verify that the electronically exchanged health information contained within the health IT has not been altered, using a hashing algorithm that meets certain requirements, may contribute to a regulated entity's compliance with the proposed standard for integrity.\ [771\]
The Department proposes to remove the implementation specification at 45 CFR 164.312(c)(2)(2)) because technical controls to corroborate that ePHI has not been altered or destroyed in an unauthorized manner are commonly built into hardware and protocols today. Thus, it is unnecessary to require a regulated entity to specifically deploy such controls.
#### g. Section 164.312(f)(1)—Standard: Authentication
Authentication ensures that a person is in fact who they claim to be before being allowed access to ePHI by providing proof of identity.\ [772\]
The Department proposes to redesignate the standard for person or entity authentication at 45 CFR 164.312(d)) as 45 CFR 164.312(f)(1)(1)) to rename it “Authentication” to reflect its broad purpose, and to add a paragraph heading to clarify the organization of the regulatory text. Additionally, consistent with our proposals to define
( printed page 974)
“implement” and “deploy,” we propose to replace the requirement for a regulated entity to implement procedures with a requirement to deploy technical controls. Also, consistent with our proposals to clarify that a regulated entity's obligations to ensure the confidentiality, integrity, and availability extend to all of its relevant electronic information systems, we propose to clarify that the regulated entity is to deploy technical controls to verify that a person seeking access to the regulated entity's relevant electronic information systems is the one claimed. The Department also proposes to modify the existing standard to clarify that a regulated entity would be required to deploy technical controls to verify that a technology asset seeking access to the regulated entity's relevant electronic information systems is the one claimed. Thus, the proposed standard for authentication would require a regulated entity to deploy technical controls to verify that a person or technology asset seeking access to ePHI and/or the regulated entity's relevant electronic information systems is, in fact, the person or technology asset that the person or asset claims to be. We also propose to remove the reference to an entity because entity is included within the definition of person.
The Department proposes four implementation specifications under this standard. Consistent with NCVHS' recommendation to eliminate the use of default passwords, the proposed implementation specification for information access management policies at proposed 45 CFR 164.312(f)(2)(i)(2)(i)) would require a regulated entity to deploy technical controls in accordance with its information access management policies and procedures, including technical controls that require users to adopt unique passwords.\ [773\]
Among other things, this proposal would ensure that regulated entities change default passwords. Such unique passwords would be required to be consistent with current recommendations of authoritative sources. The Department does not propose to define authoritative sources and defers to best practices for setting and maintaining passwords of sufficient strength to ensure the confidentiality, integrity, and availability of ePHI. Under this proposal, a regulated entity would need to require its workforce members to change any default passwords to unique passwords that are consistent with current authoritative source recommendations for unique passwords, as well as prevent the sharing of passwords among workforce members. Default passwords, typically factory-set passwords, may be discovered in common product documentation and used by attackers to gain access to relevant electronic information systems.\ [774\]
Thus, the Department believes that it is crucial for the security of ePHI that a regulated entity eliminate the use of default passwords.
In addition to proposing the elimination of default passwords, the Department proposes a specific requirement for a regulated entity to deploy MFA in the implementation specification for MFA at proposed 45 CFR 164.312(f)(2)(ii)(2)(ii)). We propose to expressly require MFA, as recommended by NCVHS, because it increases security by ensuring that a compromise of a single credential does not allow access to unauthorized users.\ [775\]
MFA is an effective way to reduce the risk of brute force attacks and to increase the cost of such attack, making such an attack less appealing to intruders.\ [776\]
Further, deployment of MFA aligns with the Department's essential CPGs for Email Security and Multifactor Authentication because use of MFA would be applicable to email access and protect assets connected to the internet.\ [777\]
Accordingly, proposed 45 CFR 164.312(f)(2)(ii)(A)(2)(ii)(A)) would require a regulated entity to deploy MFA to all technology assets in its relevant electronic information systems to verify that the person seeking access to its relevant electronic information system is the user that the person claims to be. A regulated entity should deploy MFA to all technology assets in its relevant electronic information systems in a manner consistent with its risk analysis. MFA allows for the use of different categories of factors as described earlier. A decision by a regulated entity to use specific factors during specific circumstances where MFA is deployed will be dependent upon the risks to ePHI identified by the regulated entity and the ability of technology to use such factors to authenticate specific users. For example, certain behavioral characteristics may not satisfy current standards for MFA; however, the Department anticipates that it may be reasonable and appropriate in the future for a regulated entity to adopt a solution where users provide such characteristics as one of the factors. Additionally, a regulated entity may identify varying levels of risk posed by its technology assets and elect to deploy MFA in different ways to address the risk posed by each asset. For example, consistent with its risk analysis, a regulated entity may choose to deploy a single sign-on (SSO) authentication solution using MFA to allow users to access multiple local applications, while also requiring users to authenticate using MFA to access certain cloud-based services.
This proposed implementation specification generally is consistent with ASTP/ONC's “Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability” (HTI-2) NPRM's proposed revisions to the MFA criterion requiring certified health IT to support authentication, through multiple elements, of the user's identity, according to today's standards such as those recommended by NIST, and enable user to configure, enable, and disable the MFA capabilities.\ [778\]
Adoption of health IT that is certified through the ONC Health IT Certification Program as meeting the proposed MFA criterion, should the proposal be finalized, may contribute to a regulated entity's compliance with the proposed implementation specification for MFA in this NPRM.
Under proposed 45 CFR 164.312(f)(2)(ii)(B)(2)(ii)(B)), a regulated entity would be required to deploy MFA for any action that would change a user's privileges to the regulated entity's relevant electronic information systems in a manner that would alter the user's ability to affect the confidentiality, integrity, or availability of ePHI. These modified privileges may provide a user with a level of access inconsistent with a regulated entity's policies and procedures and increase the risk to ePHI by affording a user who does not need to have access to certain systems or information the opportunity to remove security measures deployed to protect ePHI. Because a user may affect the confidentiality, integrity, or availability of ePHI by accessing a relevant electronic information system, a regulated entity would be expected to
( printed page 975)
deploy MFA for changed privileges in both types of systems.
Similar to the proposed standard for encryption, the Department proposes three exceptions at proposed 45 CFR 164.312(f)(2)(iii)(2)(iii)) to the proposed specific requirement to implement MFA. The first proposed exception at proposed 45 CFR 164.312(f)(2)(iii)(A)(2)(iii)(A)) would be for a technology asset that does not support MFA but is currently in use by a regulated entity. Because the requirements for authentication under the existing Security Rule today do not expressly refer to MFA, a regulated entity that is not using MFA to meet the requirement to authenticate user identities may argue that it is in compliance with the authentication standard without using MFA. The Department recognizes that it may take some time for a regulated entity to adopt compliant software or hardware, and thus we propose an exception where such software or hardware does not support MFA. To meet this exception, a regulated entity would be required to establish a written plan to migrate ePHI to technology assets that supports MFA and to actually migrate the ePHI to such technology assets in accordance with the written plan. Accordingly, a regulated entity would be required to establish the plan, implement the plan, and actually migrate ePHI to technology assets that supports MFA within a reasonable and appropriate period of time. For example, it would not be reasonable and appropriate for a regulated entity to establish a plan to migrate to a new practice management system that supports MFA and fail to take any steps to perform the migration for an entire year. Applying the standard flexibly and at scale, a reasonable and appropriate timeframe for a system with 5,000 users may be different than one for a solo practitioner; however, both entities would be expected to progress to completion.
We recognize that emergencies or other occurrences may render it infeasible for a regulated entity to use MFA, so we propose a second exception for when MFA is infeasible during an emergency or other occurrence that adversely affects the regulated entity's relevant electronic information systems or the confidentiality, integrity, or availability of ePHI.\ [779\]
For the proposed exception to apply, a regulated entity would be required to implement reasonable and appropriate compensating controls in accordance with its contingency plan \ [780\]
and emergency access procedures.\ [781\]
For example, if an optical scanner used by a regulated entity as one of the required factors for MFA is rendered inoperable (
_e.g.,_
is temporarily broken or adversely affected by a cyberattack), a compensating control may be to temporarily allow users to log in with their user name and a unique password, rather than with a PIN and retinal scan. The Department would make this proposed exception applicable only for the limited period of time in which MFA is infeasible for the regulated entity during the emergency or other occurrence, regardless of whether the emergency or other occurrence continues.
At proposed 45 CFR 164.312(f)(2)(iii)(C)(2)(iii)(C)), we propose three exceptions that would be for a technology asset in use that is a device within the meaning of section 201(h) of the Food, Drug, and Cosmetic Act that has been authorized for marketing by the FDA. The first would be for a device authorized by the FDA for marketing pursuant to a submission received before March 29, 2023, while the second would be for a device authorized by the FDA for marketing pursuant to a submission received on or after March 29, 2023, that is no longer supported by its manufacturer. In both cases, the exception would only apply where, the regulated entity has deployed any updates or patches required or recommended by the manufacturer of the device. Similar to our proposal for exceptions to encryption at proposed 45 CFR 164.312(b)(3)(iv)(A)(3)(iv)(A)) and (B)(3)(iv)(B)), we recognize that some regulated entities may incur costs of replacing legacy devices because of the limitations on the proposed exception to MFA where a device was submitted to the FDA for authorization before March 29, 2023 or a device submitted for authorization on or after that date that is no longer supported by its manufacturer.\ [782\]
However, as discussed above, such devices can pose significant risks to the confidentiality, integrity, and availability of ePHI.\ [783\]
By limiting these exceptions to devices that have been updated and/or patched while they were supported by their manufacturer, we believe that this proposal would balance the interest in encouraging regulated entities to dispense with legacy devices with the cost of replacing such devices. Additionally, the Department believes that regulated entities should already have plans to replace legacy devices that cannot be made cybersecure because of their existing Security Rule obligations. As discussed above, we also recognize that at some point, most, if not all, devices will likely become legacy devices and that there may be legitimate reasons not to immediately replace them when the manufacturer ceases to provide support. In such cases, it will continue to be important for regulated entities to plan for how to address their ongoing Security Rule obligations.
The third proposed exception to MFA at 45 CFR 164.312(f)(2)(iii)(C)(2)(iii)(C))(
) for devices authorized by the FDA for marketing would be available for those devices authorized for marketing by the FDA pursuant to a submission received on or after March 29, 2023, where they are supported by their manufacturer. We understand that the FDA considers security during the review of medical device marketing submissions and works with device manufacturers to ensure that appropriate cybersecurity protections are built into such devices, pursuant to FDA's authority under the Consolidated Appropriations Act, 2023.\ [784\]
Thus, we do not believe it would be necessary or appropriate for the Security Rule to require MFA for an FDA-authorized medical device that has been authorized by FDA for marketing pursuant to a submission received on or after March 29, 2023, where the device continues to be supported by its manufacturer. However, these devices may continue to be used by a regulated entity when they are no longer supported, consistent with the proposed exception for legacy devices that were approved pursuant to a submission received on or after March 29, 2023, as described above.
Where a proposed exception would apply to the proposed MFA requirement, the Department proposes to require that a regulated entity implement alternative measures and compensating controls.\ [785\]
Specifically, when a regulated entity seeks to comply with the Security Rule by meeting one of the proposed exceptions to the proposed MFA requirement, the Department proposes to require a regulated entity to document both the existence of the criteria demonstrating that the proposed exception would apply and the rationale for why the proposed exception would apply.
( printed page 976)
Additionally, the proposal would require a regulated entity to implement reasonable and appropriate compensating controls, as described at proposed paragraph (f)(2)(iv)(B).
The proposed requirements for reasonable and appropriate compensating controls are explained under proposed 45 CFR 164.312(f)(2)(iv)(B)(2)(iv)(B)). Compensating controls are implemented in the place of MFA to protect ePHI.\ [786\]
The Department does not propose to require that compensating controls be technical controls. Rather, a regulated entity should consider the nature of the exception, operating environment, and other appropriate circumstances to determine what controls are reasonable and appropriate and implement compensating controls effective for those circumstances. For example, if a software program does not support MFA, deploying a firewall or increasing the sensitivity of an existing firewall protecting that software may in some circumstances constitute a reasonable and appropriate compensating control.\ [787\]
In some instances, physical safeguards may serve as reasonable and appropriate compensating controls. For example, limiting access to certain components of a relevant electronic information system to workforce members who meet certain requirements may be a reasonable and appropriate compensating control under some circumstances. In most cases, it would be reasonable and appropriate for a regulated entity to implement multiple compensating controls to ensure that the affected electronic information system is secured.
The Department proposes at proposed 45 CFR 164.312(f)(2)(iv)(B)(2)(iv)(B))(
_1_) that, to comply with an exception at paragraph (f)(2)(iii)(A) or (B) or (f)(2)(iii)(C)(
_1_) or (
_2_), the regulated entity would be required to secure the relevant electronic information system with reasonable and appropriate compensating controls that have been reviewed, approved, and signed by the regulated entity's Security Official. Because exceptions are a departure from the designed Security Rule framework, the Department intends to ensure appropriate review by the Security Official of controls selected by the regulated entity to compensate for the absence of MFA. Merely because a regulated entity's Security Official has reviewed, approved, and signed off on compensating controls does not mean that those controls are effective. The regulated entity would also be required to give due consideration to the circumstances surrounding the exception and implement compensating controls effective for those specific circumstances.
With respect to the exception at proposed 45 CFR 164.312(f)(2)(iii)(C)(2)(iii)(C))(
_3_), the Department proposes at proposed 45 CFR 164.312(f)(2)(iv)(B)(2)(iv)(B))(
_2_) to presume that a regulated entity had implemented reasonable and appropriate compensating controls where the regulated entity has implemented the security measures prescribed and as instructed by the FDA-authorized label for the device. The proposed language recognizes that while the device's label may not specifically require deployment of an MFA solution, it may provide for a specific compensating control and the manner in which that control is to be implemented. This would include any updates, such as patches, recommended or required by the manufacturer of the device. While not required, a regulated entity would be permitted to implement additional alternative security measures and compensating controls in accordance with best practices and/or its risk analysis.
Additionally, the Department proposes at 45 CFR 164.312(f)(2)(iv)(B)(2)(iv)(B))(
) that during any period in which compensating controls are in use, the regulated entity's Security Official would be required to review the effectiveness of the compensating controls at securing its relevant electronic information systems. While regulated entities should review implemented compensating controls on a routine basis, the Department intends for a regulated entity to periodically review the implementation and effectiveness of implemented compensating controls to ensure the continued protection of ePHI.\ [788\]
For example, if a regulated entity's plan to migrate ePHI from hardware that does not support MFA changes such that the use of the non-MFA hardware continues for a longer period of time, the regulated entity should review implemented compensating controls to ensure ongoing effectiveness and whether new compensating controls should be implemented. We are proposing to require that the review be conducted at least once every 12 months or in response to an environmental or operational change, whichever is more frequent, and that the review be documented. Additionally, the Department proposes to require that the review be documented. If the regulated entity's Security Official review determines that certain compensating controls are no longer effective, the Department would expect the regulated entity to adopt other compensating controls that are effective to continue to meet the applicable proposed exception.
As an example of how proposed 45 CFR 164.312(f)(2)(iii)(2)(iii)) would operate in concert with proposed 45 CFR 164.312(f)(2)(iv)(2)(iv)), a regulated entity experiencing an emergency that adversely affects a relevant electronic information system and renders MFA infeasible would be required to document the following:
- The regulated entity has experienced an emergency that has adversely affected a relevant electronic information system, including the nature of the emergency and the specific circumstances that adversely affected the specific electronic information system.
- MFA has been rendered infeasible with respect to the specific relevant electronic information system adversely affected by the emergency.
- The regulated entity has put in place reasonable and appropriate compensating controls in accordance with the regulated entity's emergency access procedures and contingency plan.
As part of its documentation, a regulated entity would need to include the controls that have been deployed, a record of the fact that the compensating controls are in use, and a record indicating that the compensating controls have been reviewed and approved by the regulated entity's Security Official. Proposed 45 CFR 164.312(f)(2)(iv)(B)(2)(iv)(B))(
_3_) would require the Security Official to review and document the effectiveness of the compensating controls at least once every 12 months or in response to an environmental or operational change, whichever is more frequent. A determination regarding the effectiveness of the technical controls would be based on their ability to secure the regulated entity's ePHI and its relevant electronic information systems.
Last, we propose to add an implementation specification for maintenance at proposed 45 CFR 164.312(f)(2)(v)(2)(v)). Under this proposal, a regulated entity would be expressly required to review and test the effectiveness of the technical controls required by this standard at least once every 12 months or in response to
( printed page 977)
environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
#### h. Section 164.312(g)—Standard: Transmission Security
Transmission security protects against the interception of ePHI in the communications networks used by regulated entities to transmit ePHI.\ [789\]
The Department proposes to redesignate the standard for transmission security as proposed 45 CFR 164.312(g)) and to modify the standard consistent with other proposals made elsewhere in this NPRM, as described below. Specifically, we propose to clarify the existing standard by requiring a regulated entity to deploy technical controls to guard against unauthorized access to ePHI in transmission over an electronic communications network. For example, adoption of health IT that is certified through the ONC Health IT Certification Program as having the technical capability to establish a trusted connection using encrypted and integrity message protection or a trusted connection for transport and deploying such capability may contribute to a regulated entity's compliance with the proposed standard for transmission security.\ [790\]
These proposed changes are consistent with the Department's proposals to replace “implement” with “deploy” in the context of technical safeguards to differentiate between implementation of a written policy or procedure and deployment of technical controls.
Consistent with our proposals to require that regulated entities maintain their technical controls, we also propose to require a regulated entity to review and test the effectiveness of its technical controls for guarding against unauthorized access to ePHI that is being transmitted over an electronic communications network. We propose that such review and testing occur at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify such technical controls as reasonable and appropriate.
The Department also proposes to remove the implementation specification for integrity controls at 45 CFR 164.312(e)(2)(i)(2)(i)) because these requirements are incorporated in the standard for integrity at proposed 45 CFR 164.312(e)), discussed above. A regulated entity would continue to be required to review the current methods used to transmit ePHI and then deploy appropriate solutions to protect ePHI from improper alteration or destruction.\ [791\]
#### i. Section 164.312(h)(1)—Standard: Vulnerability Management
Hackers can penetrate a regulated entity's network and gain access to ePHI by exploiting publicly known vulnerabilities.\ [792\]
Exploitable vulnerabilities can exist in many parts of the technology infrastructure of a regulated entity's relevant electronic information systems (
_e.g.,_
server, desktop, and mobile device operating systems; application, database, and web software; router, firewall, and other device firmware).\ [793\]
A regulated entity can identify technical vulnerabilities in multiple, complementary ways, including:
- Subscribing to CISA alerts \ [794\]
and bulletins.\ [795\]
- Subscribing to alerts from the HHS Health Sector Cybersecurity Coordination Center.\ [796\]
- Participating in an information sharing and analysis center (ISAC) or information sharing and analysis organization (ISAO).
- Implementing a vulnerability management program that includes using a vulnerability scanner to detect vulnerabilities such as obsolete software and missing patches.
- Periodically conducting penetration tests to identify weaknesses that could be exploited by an attacker.
Additionally, CISA has compiled a database of free cybersecurity services and tools, some provided directly by CISA and others provided by private and public sector organizations.\ [797\]
For example, public and private critical infrastructure organizations may avail themselves of CISA's Cyber Hygiene Services.\ [798\]
These services are available at no cost to such organizations and can help regulated entities reduce their risk level, identify vulnerabilities that could otherwise go unmanaged and increase the accuracy and effectiveness of their response activities, among other benefits, putting them in a better place to make risk-informed decisions. CISA's Cyber Hygiene Services include both vulnerability scanning and web application scanning. CISA also has compiled a specific suite of tools and services for high-risk communities.\ [799\]
To address the potential for a bad actor to exploit publicly known vulnerabilities, and consistent with NCVHS' recommendation, the Department proposes to add a new standard for vulnerability management at 45 CFR 164.312(h)(1)(1)).\ [800\]
The proposed standard would require a regulated entity to deploy technical controls to identify and address technical vulnerabilities in the regulated entity's relevant electronic information systems. The deployment of technical controls should be consistent with the regulated entity's patch management policies and procedures at proposed 45 CFR 164.308(a)(4)(4)). This proposed standard aligns with the Department's enhanced CPGs for Cybersecurity Testing and Third Party Vulnerability Disclosure by calling for regulated entities to employ multiple processes to discover technical vulnerabilities, including vulnerabilities in workstations and in technology assets provided by vendors and service providers.\ [801\]
For example, a regulated entity should include a device owned by a person other than the regulated entity (
_e.g.,_
the medical device manufacturer) in its vulnerability management activities where the device is deployed on the regulated entity's network. The regulated entity should also include all workstations (
_e.g.,_
desktop computers, mobile devices) that are part of its relevant electronic information systems in its vulnerability management activities.
To implement this proposed standard, we propose four implementation specifications. Proposed 45 CFR 164.312(h)(2)(i)(A)(2)(i)(A)) would require a regulated entity to conduct automated scans of the regulated entity's relevant electronic information systems, including all of the components of such relevant electronic information systems (
_e.g.,_
workstations, private networks) to identify technical vulnerabilities. Vulnerability scans detect vulnerabilities such as obsolete software
( printed page 978)
and missing patches.\ [802\]
Once identified, assessed, and prioritized, appropriate measures need to be implemented to mitigate these vulnerabilities (
_e.g.,_
apply patches, harden systems, retire equipment).\ [803\]
Under the proposal, the scans would be required to be conducted in accordance with the regulated entity's risk analysis under proposed 45 CFR 164.308(a)(2)(2)) and no less frequently than once every six months.
Relatedly, proposed 45 CFR 164.312(h)(2)(i)(B)(2)(i)(B)) would add an implementation specification for maintenance of the technology assets that conduct the required automated vulnerability scans. Under this proposal, a regulated entity would be expressly required to review and test the effectiveness of the technology asset(s) that conducts the automated vulnerability scans that would be required by the proposed implementation specification at proposed 45 CFR 164.312(h)(2)(i)(A)(2)(i)(A)) at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
Identification of a known vulnerability in a relevant electronic information system or a component thereof is a necessary precursor for a regulated entity to take action to mitigate the vulnerability. A 2019 study on vulnerability and patch management found that 48 percent of respondents reported that their organizations had at least one breach in the preceding two years. Of those, 60 percent said that the breaches could have occurred because an available patch for a known vulnerability had not been applied.\ [804\]
Accordingly, the Department also proposes a new implementation specification for monitoring at proposed 45 CFR 164.312(h)(2)(ii)(2)(ii)) to require that a regulated entity monitor authoritative sources for known vulnerabilities on an ongoing basis and take action to remediate identified vulnerabilities in accordance with the regulated entity's patch management program.\ [805\]
The Department expects such monitoring to be conducted on an ongoing basis and is not proposing to specify a minimum time interval for reviewing sources. We are also not proposing to prescribe the specific sources of known vulnerabilities because such sources may change over time and the vulnerabilities for which regulated entities may be monitoring may vary greatly among regulated entities. We propose to require that the sources used must be authoritative. Examples of authoritative sources of known vulnerabilities would include NIST's National Vulnerability Database \ [806\]
and CISA's Known Exploited Vulnerabilities Catalog.\ [807\]
The proposed implementation specification for penetration testing at 45 CFR 164.312(h)(2)(iii)(2)(iii)) would require a regulated entity to conduct periodic testing of the regulated entity's relevant electronic information systems for vulnerabilities, commonly referred to as penetration testing. Penetration tests identify vulnerabilities in the security features of an application, system, or network by mimicking real-world attacks \ [808\]
and are an effective way to identify weaknesses that could be exploited by an attacker.\ [809\]
The proposal would require such testing to be conducted by qualified person(s). We propose to describe a qualified person as a person with appropriate knowledge of and experience with generally accepted cybersecurity principles and methods for ensuring the confidentiality, integrity, and availability of ePHI. We believe that within the cybersecurity industry, it is understood that a person who is qualified to conduct such penetration testing is an individual who has a combination of one or more qualifying credentials, skills, or experiences to perform “ethical hacking” or “offensive security” of information systems. The proposal would require a regulated entity to conduct such testing at least once every 12 months, or in accordance with the regulated entity's risk analysis,\ [810\]
whichever is more frequent.
Lastly, we are proposing a new implementation specification for patch and update installation at 45 CFR 164.312(h)(2)(iv)(2)(iv)) to require a regulated entity to configure and implement technical controls to install software patches and critical updates in a timely manner in accordance with the regulated entity's patch management program.\ [811\]
The proposed standard for patch management, an administrative safeguard discussed above, would require a regulated entity to establish and implement written policies and procedures for applying patches and updating relevant electronic information system configurations, while this proposal would require the regulated entity to implement technical controls to implement those written policies and procedures. In other words, proposed 45 CFR 164.312(h)(2)(iv)(2)(iv)) addresses the technical controls to effectuate a regulated entity's patch management plan. Applying patches for technology assets, including workstations, is an effective mechanism to mitigate known vulnerabilities and limit the risk of exploitation.\ [812\]
Although older applications or devices may no longer be supported with patches for new vulnerabilities, regulated entities still must take appropriate action if a newly discovered vulnerability affects an older application or device. If an obsolete, unsupported system cannot be upgraded or replaced, additional safeguards should be implemented or existing safeguards enhanced to mitigate known vulnerabilities until upgrade or replacement can occur (
_e.g.,_
increase access restrictions, remove or restrict network access, disable unnecessary features or services).\ [813\]
Deployment of such technical controls would help to ensure that a regulated entity's relevant electronic information systems are updated as quickly as possible after a vulnerability has been identified and a patch released.
The proposed standard for patch management, discussed above, would work in tandem with the proposed standard for vulnerability management to ensure that regulated entities substantially reduce the risk to ePHI from known vulnerabilities.\ [814\]
Together, these proposals would clarify that a regulated entity is required to affirmatively seek out information about known vulnerabilities, assess the risks to the confidentiality, integrity, and availability of ePHI, and implement effective mechanisms through both policies and procedures and technical controls to reduce the risk, as well the actual occurrence, of breaches resulting from known vulnerabilities. For example, known vulnerabilities should be readily identified by a regulated entity through monitoring of
( printed page 979)
authoritative sources for known vulnerabilities, such as those referenced above, and remediating any identified vulnerabilities. When a vulnerability is discovered, a regulated entity, through its patch management program, should have in place a policy and procedure for applying any available patches or implementing reasonable and appropriate compensating controls if a patch is not available. Remediation may be as simple as applying a vendor-offered software patch or, in the case of software no longer supported by a vendor, designing and implementing reasonable and appropriate compensating controls to reduce the risk of the vulnerability. The policies and procedures required by the proposed standard for patch management in proposed 45 CFR 164.308(a)(4)(i)(4)(i)) also would be implemented in part by the proposed implementation specifications associated with the proposed standard for vulnerability management. Those proposed implementation specifications would require the deployment of technical controls to ensure the patch management program is carried out, automated vulnerability scans, and penetration testing, all of which may identify when a patch or compensating control has not been put in place. The Department envisions that the full implementation of all of the proposed standards and implementation specifications would effectively reduce the risk to ePHI.
#### j. Section 164.312(i)(1)—Standard: Data Backup and Recovery
The Security Rule requires regulated entities to regularly create copies of ePHI to ensure that it can be restored in the event of a loss or disruption.\ [815\]
However, OCR's enforcement experience indicates that regulated entities could benefit from a more specific standard. Consistent with the proposed standard for contingency planning at 45 CFR 164.308(a)(13)(ii)(B)(13)(ii)(B)), the Department proposes to add a standard for a new technical safeguard for data backup and recovery. This new standard would require a regulated entity to deploy technical controls to create and maintain exact retrievable copies of ePHI. The proposed changes would remove the existing implementation specification for this activity from the physical safeguards section and place it within technical safeguards. The Department also proposes to modify the language of the existing requirement by removing the limitation that it applies before moving equipment, so that it applies broadly and comprehensively. Elevating data backup and recovery to a standard would also increase the prominence of this requirement and highlight the liability of regulated entities for creating the capacity to restore systems after a data breach.
The Department proposes four new implementation specifications for the data backup and recovery standard. The first, 45 CFR 164.312(i)(2)(i)(2)(i)), would require a regulated entity to create copies of ePHI in a manner that ensures that such copies are no more than 48 hours older than the ePHI maintained in the regulated entity's relevant electronic information systems and in accordance with the policies and procedures required by proposed 45 CFR 164.308(a)(13)(ii)(B)(13)(ii)(B)). The second, 45 CFR 164.312(i)(2)(ii)(2)(ii)), would require a regulated entity to deploy technical controls that, in real-time, monitor, and alert workforce members about, any failures and error conditions of the backups required by the first implementation specification. The third, 45 CFR 164.312(i)(2)(iii)(2)(iii)), would require a regulated entity to deploy technical controls that record the success, failure, and any error conditions of backups required. The fourth, 45 CFR 164.312(i)(2)(iv)(2)(iv)), would require a regulated entity to test the effectiveness of its backups and document the results at least monthly. Specifically, a regulated entity would be required to restore a representative sample of backed up ePHI (after the ePHI is backed up as required by paragraph (i)(2)(i)) and document the results of such test restorations at least monthly. Such tests should include verifying regulated entity's ability to access ePHI from a remote location.
These activities are included in NIST guidance for Security Rule compliance,\ [816\]
which directs regulated entities to consider the following questions: Is the frequency of backups appropriate for the environment? Are backup logs reviewed and data restoration tests conducted to ensure the integrity of data backups? Is at least one copy of the data backup stored offline to protect against corruption due to ransomware or other similar attacks? The potential need for these requirements also has been indicated through the rising number of ransomware attacks and the high number of individuals affected in such incidents. The Department believes these new implementation specifications, if finalized, would provide additional instruction for regulated entities about conducting data backups and enhance the ability of regulated entities to avoid costly work stoppages and interruptions in the delivery of health care when data becomes unavailable because of a disaster, security incident, or other emergency. We believe enhanced measures for data backup would reduce the need to pay ransom to hackers to recover compromised data.
#### k. Section 164.312(j)—Standard: Information Systems Backup and Recovery
The Department also proposes to add a new standard for backup and recovery of relevant electronic information systems at proposed 45 CFR 164.312(j)). This proposed standard would require a regulated entity to deploy technical controls to create and maintain backups of relevant electronic information systems. It would also require a regulated entity to review and test the effectiveness of such technical controls at least once every six months or in response to environmental or operational changes, whichever is more frequent, and modify them as reasonable and appropriate. The Department would not require a regulated entity to test every relevant electronic information system; rather, the requirement to test the effectiveness of the controls would permit a regulated entity to review the relevant log files and to test a representative sample of the backup of its relevant electronic information systems.
This proposed standard would reduce potential gaps in the data that needs to be backed up and recovered, to ensure that regulated entities address compliance across relevant electronic information systems. It is crucial to a regulated entity's recovery from an emergency or other occurrence, including a security incident, that adversely affects its relevant electronic information systems to create and maintain backups of such information systems that comprise the infrastructure that maintains and supports the confidentiality, integrity, and availability of ePHI. The Department would expect that the extent of this activity would be affected by the size and complexity of the relevant electronic information systems used by a regulated entity. It is also consistent with NIST guidance, which directs regulated entities to consider whether backups or images of operating systems, devices, software, and configuration files necessary to support the
( printed page 980)
confidentiality, integrity, and availability of ePHI.\ [817\]
#### 4\. Request for Comment
The Department requests comments on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. Whether there are additional technical safeguards that the Department should require regulated entities to implement.
b. Whether there are additional implementation specifications that should be adopted for any of the proposed or existing technical safeguards.
c. Whether the Department should extend the standard for encryption and decryption and associated implementation specifications to require encryption of all relevant electronic information systems.
d. Whether there should be exceptions to any of the proposed or existing technical safeguards or related implementation specifications, in addition to those proposed for encryption and decryption and MFA. For example, are there any proposed or existing standards or implementation specifications with which small or rural regulated entities would have substantial difficulty complying? If so, please explain the type of regulated entities that would be adversely affected by the requirement, the nature of the compliance difficulty, and any alternative or compensating measures that such entities are implementing now or could implement in the event of such requirement to address the risk to ePHI posed by the specific standard or implementation specification.
e. Whether the exceptions the Department has proposed to the standard for encryption or decryption are appropriate. If not, please explain.
f. Data about the frequency and number of requests regulated entities receive pursuant to the individual right of access at 45 CFR 164.524 where an individual requests that the regulated entity transmit to the individual or a third party a copy of the individual's ePHI via unencrypted email or other unencrypted messaging technologies. Please confirm that these are requests made pursuant to the individual right of access, rather than other types of communications, such as appointment reminders or requests made pursuant to a valid authorization.
g. Whether the Department should provide any additional exceptions to standard for encryption or decryption. If so, please explain.
h. Whether there are additional criteria or parameters for encryption that regulated entities would find helpful. If yes, please explain and provide examples.
i. Whether the Department should require review of compensating controls implemented to comply with an exception to the encryption and decryption standard more frequently than once every 12 months where there are no environmental or operational changes.
j. With respect to the exception to the standard for encryption and decryption for certain requests made pursuant to the individual right of access, whether there are forms and formats the Department should include or exclude from the exception (
_e.g.,_
portable document format (PDF)). If so, please explain.
k. Resources that regulated entities have identified to help inform individuals about the risks associated with the unencrypted transmission of ePHI, and whether the Department should compile and publish a list of such resources.
l. Whether the Department should define in regulation or guidance what constitutes a prevailing cryptographic standard. If so, please explain.
m. Whether the Department should specify the deployment of a particular form or manner of encryption, such as the use of particular algorithms, protocols, or compliance standards. If so, please explain.
n. Whether the Department should specify how much time regulated entities have to implement encryption for technology assets that do not support encryption. If so, please explain.
o. Whether the Department should provide more detailed requirements for network segmentation, such as the type(s) of technologies that should be segmented and how to determine whether certain technologies should be segmented. If so, please explain.
p. Whether the exceptions the Department has proposed to the implementation specification for MFA are appropriate. If not, please explain.
q. Whether the Department should provide additional exceptions to the implementation specification for MFA. If so, please explain.
r. Whether the Department should require a regulated entity to review its compensating controls adopted to comply with the exceptions to the implementation specification for MFA more frequently than once every 12 months.
s. The costs and burdens for regulated entities to implement MFA.
t. Whether the Department should require regulated entities to deploy an endpoint detection and response (EDR), security information and event management (SIEM), or other specific solution.
u. Whether once every six months is the appropriate frequency for the automated vulnerability scans required under the implementation specification for vulnerability management. If not, please explain.
v. Whether the Department should define in regulation or guidance what constitutes an authoritative source of known vulnerabilities. If so, please explain.
w. Whether once every 12 months is the appropriate frequency for the penetration testing required under the implementation specification for vulnerability management. If not, please explain.
x. For regulated entities that have conducted penetration tests, the amount of time and costs of such tests.
### G. Section 164.314—Organizational Requirements
#### 1\. Section 164.314(a)(1)—Standard: Business Associate Contracts or Other Arrangements
#### a. Current Provisions
The first standard in 45 CFR 164.314 contains the requirements for business associate agreements and other arrangements. The associated implementation specifications at 45 CFR 164.314(a)(2)(2)) require that a business associate agreement include provisions compelling a business associate to do all of the following: (1) comply with the requirements of the Security Rule; \ [818\]
(2) ensure that any subcontractors that create, receive, maintain, or transmit ePHI on behalf of the business associate agree to comply with the applicable requirements of the Security Rule by also entering into a business associate agreement; \ [819\]
and (3) report to the covered entity any security incident of which it becomes aware, including breaches of unsecured PHI as required by the Breach Notification Rule.\ [820\]
Under 45 CFR 164.314(a)(2)(ii)(2)(ii)), a covered entity that is a governmental entity is in compliance with the requirements of this section if it has in place an arrangement with a business associate that is also a governmental entity where the arrangement meets the
( printed page 981)
analogous requirements of the Privacy Rule at 45 CFR 164.504(e)(3)(3)).\ [821\]
Additionally, 45 CFR 164.314(a)(2)(iii)(2)(iii)) requires that a business associate and its subcontractor enter into a business associate agreement that meets the same requirements as those that apply to a business associate agreement between a covered entity and business associate.
As described above, a business associate agreement must include a provision that requires a business associate to report to the covered entity any known security incident. The term “security incident” includes both attempted and successful unauthorized events in an information system.\ [822\]
The Security Rule does not prescribe the timing and frequency with which a business associate reports a security incident to the covered entity (or subcontractor to a business associate).\ [823\]
Instead, regulated entities may determine the appropriate timing and frequency as part of their business associate agreement, consistent with the requirements of the Breach Notification Rule.\ [824\]
Depending on the size of the regulated entity, the number of security incidents it experiences may vary, ranging from the occasional incident experienced by a small regulated entity to more than 1,000 per hour for a large regulated entity.\ [825\]
Given that such incidents may have little to no effect if the regulated entity's electronic information systems are able to deter it, it may not be necessary for a business associate to report the security incidents immediately to a covered entity (or a subcontractor to a business associate).
Additionally, as discussed above, regulated entities are required to establish, and implement as needed, a contingency plan \ [826\]
that includes the policies and procedures for responding to an emergency or other occurrence that damages systems that contain ePHI. Such emergencies or other occurrences could include a fire, vandalism, system failure, or a natural disaster.\ [827\]
The Department believes that, in some instances, a security incident would also be an emergency or other occurrence that could require a regulated entity to activate its contingency plan.\ [828\]
As the Department previously explained, a contingency plan is the only way to protect the confidentiality, integrity, and availability of ePHI during unexpected events that may expose ePHI because the usual security measures may be disabled, ignored, or not observed.\ [829\]
#### b. Issues To Address
In recent years, there has been an increase in the number and types of emergencies or other occurrences that cause damage to systems that contain ePHI and may require a regulated entity to activate its contingency plan. For example, we have experienced an increase in extreme weather events over the last 40 years as a result of the changing climate.\ [830\]
Additionally, as discussed in greater detail above, there has been a significant increase in the number of breaches of unsecured PHI reported to the Department over the last five years.\ [831\]
And increasingly, ePHI is created, received, maintained, and transmitted using cloud-based software that may be located in a remote location, which means that covered entities more frequently rely on business associates to access ePHI.\ [832\]
Not only could the covered entity's ability to access ePHI or the relevant electronic information systems of the business associate that are affected by such an event, but the incident could also have repercussions for the covered entity's ePHI or its relevant electronic information systems. For example, a business associate's relevant electronic information systems may become infected with malicious software that spreads across devices connected to a network (
_e.g.,_
the NotPetya malware.\ [833\]
) If the covered entity is also connected to the same network, providing prompt notice to the covered entity of the security incident and activation of its contingency plan could enable the covered entity to prevent or mitigate damage to the covered entity's relevant electronic information systems.
When considered altogether, these developments mean that a regulated entity is more likely to experience an emergency or other occurrence that damages systems that contain ePHI than it was in either 2003 \ [834\]
or 2013.\ [835\]
Unfortunately, based on the Department's experience, neither the increased risk nor the Security Rule's requirement that a business associate notify a covered entity (or that a subcontractor notify a business associate) of any security incident, including breaches of unsecured PHI, has been sufficient to encourage prompt notifications by a business associate to the covered entity (or of a subcontractor to a business associate) that its ability to
( printed page 982)
access ePHI or the electronic information systems that create, receive, maintain, or transmit ePHI may be affected. This lack of prompt notification delays a covered entity (or business associate) from responding and protecting its ePHI and electronic information systems accordingly.
#### c. Proposal
To address these risk trends and deficiencies in protections, the Department proposes to add an implementation specification at proposed 45 CFR 164.314(a)(2)(i)(D)(2)(i)(D)) that would require a business associate agreement to include a provision for a business associate to report to the covered entity activation of its contingency plan that would be required under 45 CFR 164.308(a)(13)(13)) without unreasonable delay, but no later than 24 hours after activation.\ [836\]
This proposal, if finalized, would not alter the business associate's breach reporting obligations under the Breach Notification Rule.\ [837\]
The Department believes that it is necessary to notify the covered entity in a timely manner of the contingency plan activation because of the downstream implications for such activation. Receiving such prompt notice could enable the covered entity to take the necessary steps to protect its own relevant electronic information systems, as well as to implement its own contingency plan if necessary and appropriate (
_e.g.,_
enable the covered entity to access a remote or offline backup of its ePHI if necessary to ensure that patient care is unaffected—or to reduce the effect on patient care as much as possible). For example, in 2020, a software company was the target of an attack that used software containing malware to infiltrate the electronic information systems of subsequent users of the software. This allowed cybercriminals to gain access to several government systems and thousands of private systems worldwide.\ [838\]
Requiring a business associate to provide prompt notice to the covered entity when the business associate activates its contingency plan could enable regulated entities to maintain individuals' confidence in their commitment to protecting the confidentiality, integrity, and availability of ePHI in the event of an emergency or other occurrence that adversely affects relevant electronic information systems.\ [839\]
Additionally, the modified standard would align with the enhanced CPG for Third Party Incident Reporting because this proposal would require a business associate to both report to a covered entity or another business associate activation of its contingency plan within 24 hours of such activation and report known or suspected security incidents.\ [840\]
As discussed above, the Department proposes to require a regulated entity to activate its contingency plan to respond to an emergency or other occurrence that adversely affects relevant electronic information systems.\ [841\]
The Department believes that regulated entities activate their contingency plans infrequently because such plans are only activated when there is an emergency or other occurrence that rises to a level beyond a security incident that is thwarted or other event that does not adversely affect the confidentiality, integrity, or availability of ePHI. Thus, the need to make the proposed notification would also arise infrequently.
For example, a business associate may not be required to notify a covered entity within a certain time after a relevant electronic information system receives a basic internet command such as a ping,\ [842\]
which happens frequently. This is because a ping in and of itself generally does not adversely affect relevant electronic information systems when it is blocked by firewall policies, and thus does not require activation of the regulated entity's contingency plan. Instead, the business associate would be required to provide such notice in instances where internet commands received by the business associate indicate potential malicious activity, such as a denial of service attack, leading to activation of its contingency plan because of an event that adversely affects the business associate's relevant electronic information systems that create, receive, maintain, or transmit ePHI or adversely affects the confidentiality, integrity, or availability of its ePHI. However, in both such instances, a business associate would still be required to provide notice to the covered entity of the ping as a security incident in accordance with the business associate agreement.\ [843\]
The proposal itself would only require that the business associate notify the covered entity of its activation of the contingency plan; it does not include any specific requirements with respect to the form, content, or manner of the notice. Instead, we propose to permit the covered entity and business associate to negotiate such terms and include them in their business associate agreement if they so choose.
We recognize that when such an emergency or other occurrence transpires, the focus of the affected regulated entity must be on activating its contingency plan and restoring access to ePHI and the affected relevant electronic information systems. Similarly, when the contingency plan activation is in response to a successful security incident,\ [844\]
it may take some time to investigate and determine the cause of the security incident. Thus, this proposal would not require reporting on the cause of the contingency plan activation; it would require reporting solely on the fact that it has activated the plan. Accordingly, we believe that 24 hours would provide a business associate with sufficient time to do all of the following: determine that there is an emergency or other occurrence adversely affecting the business associate's relevant electronic information systems; determine that it needs to activate its contingency plan; identify any covered entities that need to be notified; and notify such covered entities.
This proposed requirement to provide notice without unreasonable delay, but no later than 24 hours after a
( printed page 983)
contingency plan is activated, would also apply when a business associate that is a governmental entity enters into an arrangement with a covered entity that is also a governmental entity where such arrangement meets the requirements of the Privacy Rule at 45 CFR 164.504(e)(3)(3)) in accordance with 45 CFR 164.314(a)(2)(ii)(2)(ii)) and when a business associate enters into a business associate agreement with a subcontractor in accordance with 45 CFR 164.314(a)(2)(iii)(2)(iii)) to notify its business associate when it has activated its contingency plan.
Additionally, the Department proposes conforming changes to the references of 45 CFR 164.308(b)) throughout 45 CFR 164.314 consistent with proposals made to modify 45 CFR 164.308(b)). The Department does not intend these to be substantive changes, but rather an alignment with the proposed structural modifications in 45 CFR 164.308(b)).
As discussed above, the Department proposes to remove the term “required” from the implementation specification at 45 CFR 164.314(a)(2)(2)) consistent with its proposal to eliminate the distinction between addressable and required implementation specifications. We also propose a few miscellaneous non-substantive corrections to update citations in the standard at 45 CFR 164.314(a)(1)(i)(1)(i)) and (a)(2)(iii)(2)(iii)). We do not believe that these technical amendments would add or change any regulatory, recordkeeping, or reporting requirements, nor would they change the Department's interpretation of any regulation.
#### 2\. Section 164.314(b)(1)—Standard: Requirements for Group Health Plans
#### a. Current Provision
The second standard in 45 CFR 164.314 requires that, except when ePHI disclosed to a plan sponsor is summary health information \ [845\]
or enrollment or disenrollment information,\ [846\]
group health plan \ [847\]
documents must provide that the plan sponsor will reasonably and appropriately safeguard ePHI created, received, maintained, or transmitted to or by the plan sponsor on behalf of the group health plan. Section 164.314(b)(2) requires that the plan documents of a group health plan must be amended to incorporate provisions to require the plan sponsor to:
- Implement reasonable and appropriate administrative, physical, and technical safeguards to protect the confidentiality, integrity, and availability of the ePHI that it creates, receives, maintains, or transmits on behalf of the group health plan.\ [848\]
- Ensure that the separation between the group health plan and plan sponsor required by the Privacy Rule at 45 CFR 164.504(f)(2)(iii) \ [849\]
is supported by reasonable and appropriate security measures.\ [850\]
- Ensure that any agent to whom it provides ePHI, agrees to implement reasonable and appropriate security measures to protect the information.\ [851\]
- Report to the group health plan any security incident of which it becomes aware.\ [852\]
#### b. Issues To Address
Plan sponsors are not directly liable for compliance with the Security Rule because they are not regulated entities,
_i.e.,_
covered entities or business associates under HIPAA. Therefore, plan sponsors' obligations to apply safeguards to ensure the confidentiality, integrity, and availability of ePHI are limited to the requirements set forth in the plan documents of its group health plan. While 45 CFR 164.314(b)) generally requires that plan documents call for the implementation of Security Rule-like safeguards, the current provision does not specifically require the group health plan to require the plan sponsor or any agent to whom it provides ePHI to comply with the requirements of the Security Rule. Given the concerns we have regarding Security Rule compliance generally by regulated entities, the Department is also concerned that group health plans have not sufficiently ensured that plan documents require that plan sponsors reasonably and appropriately safeguard ePHI created, received, maintained, or transmitted to or by the plan sponsor on behalf of the group health plan. Additionally, the Department is concerned that group health plans may not be monitoring plan sponsors to ensure that ePHI is disclosed to a plan sponsor only if the plan sponsor voluntarily agrees to use and disclose the information only as permitted or required by the regulations.\ [853\]
Plan sponsors may perform certain functions that are integrally related to, or similar to, the administrative functions of group health plans, and in carrying out these functions, need access to ePHI held by the group health plan. For example, plan sponsors may perform plan administration functions on behalf of the group health plan which are specified in plan documents. The increase in cybercrime and other emergencies adversely affecting electronic information systems is not limited to regulated entities or to the health care sector; plan sponsors are experiencing similar increases in events that require the activation of contingency plans.\ [854\]
And plan sponsors may not be reasonably and appropriately protecting the confidentiality, integrity, and availability of ePHI absent an express requirement that plan documents obligate a plan sponsor to implement the security measures in the Security Rule. Additionally, regulated entities may not have the ability to determine whether alternate security measures will accomplish the same result because they do not have access to the information systems of plan sponsors, nor would it be appropriate for them to have such access.
Additionally, the Department believes that prompt notification by a plan sponsor to the group health plan that the ability of the plan sponsor or the group health plan to access ePHI or relevant electronic information systems may be affected by a security incident is important for the same reasons discussed above in 45 CFR 164.314(a)). This lack of prompt notification delays a group health plan from responding and protecting its ePHI and relevant electronic information systems accordingly.
#### c. Proposal
The Department proposes to modify the implementation specifications at 45 CFR 164.314(b)(2)(i)(2)(i)) through (iii)(2)(iii)) to address concerns that group health plans may not recognize that reasonable and appropriate safeguarding of ePHI requires the implementation of security measures that are the same as, or at least equivalent to, the security measures in the Security Rule. First, we propose to rename the implementation specifications as “Safeguard implementation,” “Separation,” and
( printed page 984)
“Agents,” respectively. We also propose to modify all three implementation specifications to require that plan documents of the group health plan would obligate a plan sponsor or any agent to whom it provides ePHI to implement the administrative, physical, and technical safeguards of the Security Rule. The Department recognizes that plan sponsors may need access to ePHI in certain situations, such as when they perform functions that are integrally related to, or similar to, those performed by group health plans, and we believe that such information must be protected by plan sponsors in the same manner in which it is protected by group health plans and other regulated entities.\ [855\]
The security measures we are proposing in this NPRM are consistent with the CISA Cross-Sector CPGs,\ [856\]
and thus should be consistent with measures plan sponsors are implementing to protect their own electronic information systems, regardless of the obligations imposed on them by plan documents. For example, the Department seeks to ensure that plan sponsors are implementing administrative safeguards, such as performing a risk analysis,\ [857\]
to protect the confidentiality, integrity, and availability of all ePHI in its information systems; documenting required policies and procedures; and documenting implementation of such administrative safeguards, including the required policies and procedures.\ [858\]
Thus, requiring plan sponsors to implement the same security measures that regulated entities are implementing would maintain confidence in the commitment of plan sponsors to protecting the confidentiality, integrity, and availability of ePHI in light of the increasing cybersecurity threats as discussed above.
Additionally, the Department proposes to rename the implementation specification at 45 CFR 164.314(b)(2)(iv)(2)(iv)) as “Security incident awareness.”
Similar to the discussion above, the Department proposes to add a new implementation specification for contingency plan activation at proposed 45 CFR 164.314(b)(2)(v)(2)(v)) that would require plan documents to include a provision requiring a plan sponsor to report to the group health plan without unreasonable delay, but no later than 24 hours after activation of its contingency plan.\ [859\]
As discussed above, the Department believes that a group health plan needs to be notified in a timely manner when a plan sponsor activates its contingency plan because of the potential implications on the ability of a group health plan to protect the confidentiality, integrity, and availability of ePHI in its relevant electronic information systems. Accordingly, we believe that 24 hours would provide a plan sponsor sufficient time to do all of the following: determine that there is an emergency or other occurrence adversely affecting the plan sponsor's relevant electronic information systems; determine that it needs to activate its contingency plan; activate its contingency plan; identify any group health plans that need to be notified; and notify such group health plans.
Similarly, as discussed above, we propose to permit the group health plan and plan sponsor to negotiate the form, content, or manner of the notice and include them in their plan documents if they so choose.
The Department believes that requiring a plan sponsor to provide prompt notice to the group health plan when the plan sponsor activates its contingency plan would enable group health plans and plan sponsors to maintain individuals' confidence in their commitment to protecting the confidentiality, integrity, and availability of ePHI.
Additionally, consistent with our proposal to revise 45 CFR 164.306, the Department proposes to remove the term “required” from the implementation specification at 45 CFR 164.314(b)(2)(2)) consistent with our overall proposal to eliminate the distinction between “required” and “addressable” implementation specifications. However, a regulated entity would still be required to comply with all standards and implementation specifications as applicable to its situation, as proposed in 45 CFR 164.306(c)).
#### 3\. Request for Comment
The Department requests comment on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. How group health plans currently ensure that plan sponsors implement reasonable and appropriate administrative, physical, and technical safeguards to protect the confidentiality, integrity, and availability of ePHI.
b. Whether it is appropriate for group health plans to require plan sponsors to implement the administrative, physical, and technical safeguards of the Security Rule. If not, please explain and provide alternatives for how the Department should ensure the confidentiality, integrity, and availability of ePHI when it is disclosed to plan sponsors.
c. Whether business associates currently notify covered entities (or subcontractors notify business associates) upon activation of their contingency plans, and if so, the manner and timing of such notice.
d. Whether plan sponsors currently notify group health plans upon activation of their contingency plans, and if so, the manner and timing of such notice.
e. Whether it would be appropriate to require a business associate to notify a covered entity (or a subcontractor to notify a business associate) within 24 hours of activating its contingency plan. If not, please explain why and what would be an appropriate amount of time for such notification.
f. Whether it would be appropriate to require a plan sponsor to notify a group health plan within 24 hours of activating its contingency plan. If not, please explain why and what would be an appropriate amount of time for such notification.
g. The manner, timing, frequency, and process used by business associates to report security incidents to a covered entity (or subcontractors to business associates).
h. The manner, timing, frequency, and process used by a plan sponsor to report security incidents to a group health plan.
### H. Section 164.316—Documentation Requirements
#### 1\. Current Provisions
Section 164.316(a) requires a regulated entity to implement reasonable and appropriate policies and procedures that comply with the Security Rule, taking into account the size, complexity, and capabilities of the regulated entity; \ [860\]
the regulated entity's technical infrastructure, hardware, and software capabilities; \ [861\]
the costs of security measures; \ [862\]
and the probability and criticality of
( printed page 985)
potential risks to ePHI.\ [863\]
Such policies and procedures must be consistent with the other requirements of the Security Rule. A regulated entity is permitted to change its policies and procedures, but it must document and implement such change in accordance with the Security Rule.
The standard and implementation specifications for documentation are in 45 CFR 164.316(b)). Paragraph (b)(1) requires a regulated entity to maintain the policies and procedures it implements to comply with the Security Rule in written form. Additionally, where the Security Rule requires an action, activity, or assessment to be documented, the regulated entity must maintain a written record of the action, activity, or assessment. In both cases, the written record may be electronic. Paragraph (b)(2) includes the current implementation specifications for the documentation standard. Such documentation must be retained for the later of either: (1) six years from its creation, or (2) the date it was last effective. Additionally, it must be available to those responsible for implementing the documented policies and procedures. Finally, regulated entities must periodically review their documentation and update it as needed in response to environmental or operational changes affecting the security of ePHI.
#### 2\. Issues To Address
Although this section currently addresses policies and procedures and documentation, it does not require or include standards to govern how regulated entities must implement, maintain, and document implementation of all security measures. Implementing, maintaining, and documenting implementation of all security measures is important to ensure that regulated entities make well-reasoned decisions about implementing the requirements of this rule. Just as the Department believes that it is necessary to consider expanding the definition of “security measures” to better reflect that security measures should be multi-layered, we also believe that it is necessary to consider providing a more complete instruction concerning how regulated entities must implement, maintain, and document their implementation of the required security measures.
Additionally, OCR's own experience in investigations and audits leads us to believe that many regulated entities may not be documenting their security measures or their implementation of those measures.\ [864\]
It is critical for a regulated entity to commit to writing the security measures required by the Security Rule to ensure consistent implementation and compliance with the Security Rule. Verbal instructions may be forgotten or misconstrued, and what the regulated entity believes to be common knowledge may not be or may be relayed incorrectly between workforce members.
Additionally, based on OCR's enforcement experience, the Department believes that regulated entities may not be periodically reviewing and updating their documentation when they modify their security measures in response to environmental or operational changes affecting the security of their ePHI. Given the constant evolution of technology and the everchanging behavior of cybercriminals in response to technological evolution, the Department believes that regular review of cybersecurity-related security measures is essential for protecting the confidentiality, integrity, and availability of ePHI and relevant electronic information systems.
#### 3\. Proposals
As discussed above, the Department has proposed to revise other provisions of the Security Rule to clarify the differences between administrative and technical safeguards and between policies and procedures on the one hand and technical controls on the other hand. We have also proposed to revise other provisions of the Security Rule to clarify that a regulated entity is required to implement and maintain its administrative, physical, and technical safeguards, including its policies and procedures. These proposals clarify that such maintenance requires the review, testing, and modification of the regulated entity's security measures on a regular cadence, meaning that the regulated entity's security measures can be modified at any time. Given these proposals, the Department believes that we must also propose to revise 45 CFR 164.316 to delete the standard for policies and procedures and to modify the Security Rule's documentation requirements. Accordingly, the Department proposes to rename this section as “Documentation Requirements” and to redesignate the documentation standard as paragraph (a). We also propose to require that a regulated entity document how it considered the factors in 45 CFR 164.306(b)) in the development of its written policies and procedures.
We also propose to modify the documentation standard to clarify that all required written documentation may be in electronic form. Additionally, we propose to modify the standard's two paragraphs. Specifically, the Department proposes at proposed 45 CFR 164.316(a)(1)(1)) to require that a regulated entity document the policies and procedures it has implemented to comply with the Security Rule, and as part of that documentation, explain how it considered the factors at 45 CFR 164.306(b)) in the development of its policies and procedures. Relatedly, we also propose to modify 45 CFR 164.316(a)(2)(2)) to require a regulated entity to document all of the actions, activities, and assessments required by the Security Rule. The Department believes that both proposals would help to address two common problems observed in Security Rule investigations: a failure by the regulated entity to document its policies and procedures and a failure to document actions, activities, and assessments taken to comply with the Security Rule. Without such documentation, it is challenging for a regulated entity to assess and ensure its own compliance. Accordingly, we believe that our proposals to require a regulated entity to document its implementation of the Security Rule requirements would aid both the regulated entity and the Department.
Consistent with our proposal to redesignate the documentation standard as 45 CFR 164.316(a)), we propose to redesignate the implementation specifications for documentation time limits, availability, and updates as proposed at 45 CFR 164.316(b)(1)(1)) through (3)(3)), respectively. Under proposed 45 CFR 164.316(b)(3)(3)), the Department proposes to require a regulated entity to update its documentation at least once every 12 months and within a reasonable and appropriate period of time after a security measure is modified.\ [865\]
( printed page 986)
discussed above, the Department recognizes that the health care environment has changed in a way that necessitates thorough and frequent review of and updates to documentation. By proposing to specify how often documentation must be updated, the Department would clarify that we expect regulated entities to review and update their documentation at regular intervals, in addition to doing so in response any changes to a security measure. Cybersecurity and data protection is an evolving process, which makes formal, updated, and detailed documentation imperative for data protection. By reviewing and updating its documentation, including its written policies and procedures, at least annually and in response to changes to its security measures, a regulated entity should have a full understanding of its implemented security measures and be able to determine which measures should be updated to protect the confidentiality, integrity, and availability of ePHI.
As discussed above and consistent with the proposed changes to 45 CFR 164.306, the Department is proposing to remove the term “required” from 45 CFR 164.316(b)(1)(1)) through (3)(3)).
#### 4\. Request for Comment
The Department requests comment on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following consideration in particular:
a. Whether it would be appropriate to require regulated entities to review and update documentation for security measures at least once every 12 months. If not, please explain.
b. Whether it is clear that 45 CFR 164.316 provides regulated entities with directions on when and how they are to document all security measures across all safeguard requirements. If not, please explain.
c. Whether it is feasible for regulated entities to document all of the actions, activities, and assessments required by the Security Rule as proposed at 45 CFR 164.316(a)(2)(2)). If not, please explain.
### I. Section 164.318—Transition Provisions
#### 1\. Current Provisions and Issues To Address
Section 164.318 established the compliance dates for the initial implementation of the security standards for health plans, health care clearinghouses, and health care providers in 2005 and 2006.\ [866\]
Covered entities have been required to comply with the security standards for almost 20 years, and the initial implementation of the security standards is no longer applicable. Because of this, the Department believes that these provisions are no longer necessary.
#### 2\. Proposal
The Department proposes to remove the information in 45 CFR 164.318 and replace the language with provisions for transitioning to the revised Security Rule, should the proposals included in this NPRM be adopted.
The Department understands that regulated entities may be concerned with the anticipated administrative burden and cost of revising their business associate agreements or other written arrangements to comply with a revised Security Rule. For example, a regulated entity would need to update its business associate agreements to add a provision specifying that the business associate will report to the covered entity \ [867\]
that it activated its contingency plan no later than 24 hours after activation of such plan.\ [868\]
A regulated entity may have existing contracts that are not set to terminate or expire until after the compliance date for a final rule modifying the Security Rule, and we understand that a six-month compliance period may not provide enough time to reopen and renegotiate all contracts, in addition to ensuring that all regulated entities are compliant with the revised Security Rule. Accordingly, the Department proposes to relieve some of the burden on regulated entities by adding a specified period of transition for certain existing contracts.
The Department's authority to provide a transition period is expressed in 45 CFR 160.104(c), which allows the Secretary to establish the compliance date for any modified standard or implementation specification, considering the extent of the modification and the time needed to comply with the modification.\ [869\]
Given these considerations, to allow regulated entities enough time to update thousands of existing business associate agreements or other written arrangements, the Department proposes to provide additional time to update the contracts required by 45 CFR 164.314(a)(1)(1)).
Specifically, the Department proposes to add new transition provisions under 45 CFR 164.318 to allow regulated entities to continue to operate under certain existing business associate agreements or other written arrangements until the earlier of: (1) the date such contract or other arrangement either is renewed on or after the compliance date of the final rule; or (2) a year after the effective date of the final rule. The additional transition period would be available to regulated entities if both of the following conditions are met: (1) prior to the publication date of the final rule, the covered entity or business associate had an existing business associate agreement or other written arrangement with a business associate or subcontractor, respectively, that complied with the Security Rule prior to the effective date of a final rule revising the Security Rule; and (2) such contract or arrangement would not be renewed or modified between the effective date and the compliance date of the final rule.
Under the proposed transition provisions, a business associate would be permitted to create, receive, maintain, or transmit ePHI pursuant to an existing business associate agreement or other written arrangement with another regulated entity that does not require the regulated entity to obtain satisfactory assurances that meet the requirements of the revised Security Rule for up to one year after the revised Security Rule becomes effective, assuming that a final Security Rule is published; and that the agreement is compliant with the Security Rule at the time the final rule is published and that it is not renewed or modified between the effective and compliance dates.\ [870\]
The transition provisions would also allow for the business associate to create, receive, maintain, or transmit ePHI on behalf of another regulated entity where the existing business associate agreement does not require that the regulated entity verify that the
( printed page 987)
business associate has deployed technical safeguards in accordance with the Security Rule under the same circumstances as those described above.\ [871\]
During the transition period, the Department proposes to allow a business associate to create, receive, maintain, or transmit ePHI pursuant to a business associate agreement or other written arrangement with another regulated entity without including in the agreement that the business associate will: (1) comply with the revised Security Rule; \ [872\]
(2) ensure that any subcontractors that create, receive, maintain, or transmit ePHI on behalf of the business associate agree to comply with the revised Security Rule by entering into a business associate agreement or other arrangement that meets the requirements of the revised rule; \ [873\]
and (3) report to the covered entity \ [874\]
activation of its contingency plan.\ [875\]
Additionally, the Department intends that, in cases where a contract renews automatically without any change in terms or other action by the parties (also known as “evergreen contracts”), such contracts would be eligible for the extension if they automatically renew between the effective and compliance dates. Thus, regulated entities with an evergreen contract will be deemed to be in compliance with the Security Rule's requirements for business associate agreements or other written arrangements and such deemed compliance would not terminate when these contracts automatically renew. These transition provisions would apply to written contracts or other written arrangements as specified above.
These transition provisions would apply only to the requirement to amend contracts or other arrangements with business associates, and they would not affect any other compliance obligations under the Security Rule. For example, beginning on the compliance date of the final rule, assuming a final rule is published and that it is finalized as proposed, a business associate would be required to implement and document its implementation of the administrative, physical, and technical safeguards required by a revised Security Rule, except with respect to 45 CFR 164.308(b)) and 164.314(a)), even if the business associate's contract with the covered entity \ [876\]
has not yet been amended.
Given the possibility of a similar burden on group health plans and plan sponsors to update plan documents by the compliance date, the Department is considering, but not proposing, a similar transition provision for plan documents. We are not proposing such provisions at this time because, unlike business associates, plan sponsors do not have independent obligations under the Security Rule. Instead, the obligations of plan sponsors are based entirely on the content of the plan documents. Accordingly, if the plan documents are not updated, plan sponsors are not obligated to comply with the requirements of the Security Rule because they are not regulated entities.
In particular, the Department is considering, but not proposing at this time, adding a new paragraph (d) introductory text under 45 CFR 164.318, with the heading “Standard: Effect of prior plan documents for group health plans,” stating that notwithstanding any other provisions of the subpart, a group health plan may allow a plan sponsor to create, receive, maintain, or transmit electronic protected health information pursuant to a written plan document with such group health plan that does not comply with § 164.314(b), only in accordance with paragraph (d)(1). The Department is also considering adding a new paragraph (d)(1) under 45 CFR 164.318, with the heading “Implementation specification: Plan documents for group health plans,” stating that the requirements of paragraph (b) apply to the plan document between a group health plan and a plan sponsor in the same manner as such requirements apply to written contracts or other arrangements between a covered entity and a business associate.
Similarly, the Department is considering, but not proposing at this time, adding a new paragraph (d)(2) under 45 CFR 164.318, with the heading “Group health plan responsibilities,” stating that nothing in the section shall alter the requirements of a group health plan or plan sponsor to comply with the applicable provisions of the part other than § 164.314(b).
#### 3\. Request for Comment
The Department requests comment on the foregoing proposals, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. Whether the Department's proposal to provide regulated entities with additional time to revise business associate agreements or other written contracts is appropriate. If not, please explain.
b. Whether the Department should also provide group health plans and plan sponsors additional time to revise plan documents by adding a transition provision to grandfather certain existing plan documents for a specified period of time.
c. Whether the Department should consider additional constraints or specificity for a new paragraph (d) to allow group health plans more time to comply with the Security Rule requirements for plan documents.
### J. Section 164.320—Severability
The Department intends that, if any provisions of this subpart, including the provisions of this NPRM, if finalized, were held to be invalid or unenforceable facially, or as applied to any person, plaintiff, or stayed pending further judicial or agency action, such provision shall be severable from other provisions of this subpart, and from other rules and regulations currently in effect, and not affect the remainder of this subpart. It is also our intent that, unless such provision shall be held to be utterly invalid or unenforceable, it shall be construed to give the provision maximum effect to the provision permitted by law, including in the application of the provision to other persons not similarly situated or to other dissimilar circumstances from those where the provision may be held to be invalid or unenforceable.
The provisions of this subpart, including the proposals of this NPRM, are intended to operate independently of each other, even if multiple provisions serve the same or similar general purpose(s) or policy goal(s). Where a provision is necessarily dependent on another, the context generally makes that clear, such as by cross-reference to a particular standard, requirement, or implementation specification. Where a provision that is dependent on one that is stayed or held invalid or unenforceable, as described in the preceding paragraph, is included in paragraph or section within 45 CFR part 160 or 164, we intend that other provisions of such paragraph(s) or section(s) that operate independently of said provision would remain in effect.
The Department intends the individual standards in 45 CFR 164.308, 164.310, 164.312, 164.314, and 164.316 to apply separately to govern how a regulated entity must protect the security of all ePHI it creates, receives,
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maintains, or transmits. Accordingly, if finalized, this provision would provide that if any one or several standards in 45 CFR 164.308, 164.310, 164.312, 164.314, and 164.316 are deemed invalid by a court, or non-applicable to a particular person or circumstance, all remaining standards shall be unaffected and shall remain in force, and any remaining component of the adjudicated provision, not invalid or found to be unenforceable or inapplicable, shall be considered by the Department to be still in effect.
For example, the standard for risk analysis proposed in 45 CFR 164.308(a)(2)(2)) would protect ePHI from risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI, while the modified standard for workforce security proposed in 45 CFR 164.308(a)(9)(9)) would protect ePHI from inappropriate access by a regulated entity's workforce. An invalidated standard for workforce security would not render the entire rule unworkable because a regulated entity could still meet the requirement to conduct the risk analysis without regard to whether the entity meets the requirements included in the standard for workforce security. Similarly, were a court to invalidate the Department's proposal in 45 CFR 164.310(a)(1)(1)) requiring that implemented policies and procedures to limit physical access to relevant electronic information systems and the facility or facilities in which they are housed be in writing, a regulated entity could still meet a requirement to implement the policies and procedures. Similar considerations apply to the proposal for written policies and procedures in proposed 45 CFR 164.316(a)), and to proposals that are deemed inapplicable to certain persons or circumstances.
Further, the Department believes it is necessary to clarify how regulated entities would continue to apply implementation specifications in the event a court invalidates or deems inapplicable a governing standard over a specific implementation specification, or if a court invalidates or deems inapplicable one or several implementation specifications without taking adverse action on the governing standard. The Department does not interpret that this severability proposal, if finalized, would apply to implementation specifications in the same manner as it would apply to standards. Because the implementation specifications are regulatory instructions on how a regulated entity is to comply with a particular standard, if any standard is stricken, all implementation specifications underneath are similarly stricken. Conversely, the Department does not intend for the overarching standard to be affected by a court's decision to invalidate or make a determination of non-applicability to particular person or circumstance all implementation specifications under a particular standard. The Security Rule would still retain its flexible and scalable approach, and, therefore, a regulated entity could use any reasonable and appropriate security measure to implement the standard consistent with 45 CFR 164.306(b)), even if all implementation specifications under the standard are stricken.
If a court invalidates or deems inapplicable less than all implementation specifications under a specific standard (
_i.e.,_
only one or several), the ability of a regulated entity to execute the remaining implementation specification(s) depends on whether the remaining implementation specifications are dependent on one another or operate together to impose requirements on regulated entities. For example, several proposed implementation specifications under the standard for facility access controls at 45 CFR 164.310(a)(1)(1)) would require a regulated entity to both establish and implement written procedures pertaining to specific requirements such as contingency operations, facility security planning and access control and validation, and then subsequently review the written policies and procedures every 12 months. Should a court invalidate or deem inapplicable the implementation specification to establish and implement written policies procedures, the secondary specification requiring review of said procedures would also become invalid.
The Department believes that each definition is independent of all other definitions.
This list of examples is not intended to be exhaustive. The absence from this list of any particular provision should not be construed to mean that the Department considers that provision to be not severable from other parts of the rule.
To ensure that our intent for severability of provisions is clear in the CFR, the Department proposes to add a section on severability at 45 CFR 164.320. Proposed 45 CFR 164.320 would state our intent that if any provision of this subpart is held to be invalid or unenforceable, it shall be construed to give maximum effect to the provision permitted by law unless the holding shall be one of utter invalidity or unenforceability, in which case the provision shall be severable from this subpart and shall not affect the remainder thereof or the application of the provision to other persons not similarly situated or to other dissimilar circumstances.
The Department requests comment on the foregoing proposal, including any benefits, drawbacks, or unintended consequences.
### K. New and Emerging Technologies Request for Information
Technology is constantly evolving, able to perform increasingly complex tasks, including those with the potential to improve health care and communication between individuals and care providers. These new and evolved technologies will continue to transform health care in a variety of ways, including providing regulated entities with new tools for faster and more accurate diagnoses, effective treatments, and more efficient administration.
As a regulated entity considers the application of new technologies or the use of existing tools in innovative ways, it also must consider whether these technologies create, receive, maintain, or transmit ePHI, and, if so, how to secure them. The Security Rule was designed to be technology-neutral for this very reason and continues to provide the foundation for ensuring the confidentiality, integrity, and availability of all ePHI as technology changes.\ [877\]
As a result, while the technology may be new or developing, securing ePHI involved with the technology can be successfully executed through compliance with the Security Rule.
Before implementing new and emerging technologies, a regulated entity must conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI.\ [878\]
It must then implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level.\ [879\]
Such administrative, physical, and technical safeguards apply to all instances of ePHI maintained or transmitted by the regulated entity, regardless of the technology used. Below, we discuss some examples of new technologies, such as quantum computing, AI, and virtual and augmented reality (VR and AR), and
( printed page 989)
how the Security Rule would apply in each case.
#### 1\. Quantum Computing
Several Federal agencies have considered the potential benefits and drawbacks of quantum information science,\ [880\]
that is, the study of “the impacts of quantum physics properties on information science. Those properties can increase computational power and speed significantly over classical computers, provide precision measurements; enhance sensing capabilities; and increase the accuracy of position, navigation, and timing services.” \ [881\]
According to NIST, “In recent years, there has been a substantial amount of research on quantum computers—machines that exploit quantum mechanical phenomena to solve mathematical problems that are difficult or intractable for conventional computers.” \ [882\]
However, the increase in computational capability threatens the security of asymmetric cryptography,\ [883\]
which is critical to encryption solutions, a key protection for ePHI and other sensitive information today. Scientists warn that when such quantum computers are built, they will have the ability to break many of the systems for asymmetric cryptography that are in use today.\ [884\]
Thus, experts anticipate that quantum computing will adversely affect the confidentiality and integrity of digital communications.\ [885\]
“The goal of post-quantum cryptography (also called quantum-resistant cryptography) is to develop cryptographic systems that are secure against both quantum and classical computers, and can interoperate with existing communications protocols and networks.” \ [886\]
A recent National Security Memorandum affirmed that “alongside its potential benefits, quantum computing also poses significant risks to the economic and national security of the United States. . . . \[including the potential to break\] much of the public-key cryptography used on digital systems across the United States and around the world.” \ [887\]
Accordingly, the White House has directed Federal agencies to take specific steps to “mitigate the threat of \[cryptanalytically relevant quantum computers\] through a timely and equitable transition of the Nation's cryptographic systems to interoperable quantum-resistant cryptography.” \ [888\]
NCVHS examined these security issues and provided recommendations to the Department for applying the safeguards of the HIPAA Rules to potential quantum computing threats. Specifically, NCVHS declared that incorporation of recent Administration guidance for Federal agencies “on vulnerable cryptographic systems is necessary to strengthen the Technical Safeguards within the Security Rule.” \ [889\]
This joint guidance, developed by NIST, CISA, and NSA, encourages “the early planning for migration to post-quantum cryptographic standards by developing a Quantum-Readiness Road map.” \ [890\]
It also recommends that organizations prepare a cryptographic inventory, discuss post-quantum roadmaps with technology vendors, consider their supply chain's readiness for quantum computing, and consider the responsibilities of their technology vendors with respect to preparing for quantum readiness.\ [891\]
The Department encourages regulated entities to incorporate these activities as part of their ongoing risk management programs. For example, the steps presented in the joint guidance—surveying the environment for potential risks and vulnerabilities that endanger ePHI, identifying workforce members with responsibility for addressing them, inventorying quantum-vulnerable systems, including that inventory in its risk analysis and risk management, and working with technology vendors to ensure their readiness—are all activities that already are required by the administrative safeguards of the Security Rule.
We believe these obligations would be clarified by the proposals in this NPRM. For example, the Department proposes to require that a regulated entity not only conduct an accurate assessment of potential risks and vulnerabilities to the confidentiality, integrity, and availability of the ePHI it creates, receives, maintains, or transmits, but would add an express requirement that the assessment be comprehensive and in writing. We also propose to specify that the required assessment include, among other things, identification of all reasonably anticipated threats and potential vulnerabilities and predisposing conditions, making a reasonable determination and documentation of the likelihood that each identified threat will exploit the identified vulnerabilities, and performing a written assessment of the risk level for each identified threat and vulnerability. Under the NPRM, a regulated entity would be expected to, as part of the risk analysis, consider whether quantum computing poses a reasonably anticipated threat to the confidentiality, integrity, or availability of its ePHI and whether there is a vulnerability or predisposing condition that corresponds to that threat, and to document those considerations; make a reasonable determination and document the likelihood that the threat will exploit the identified vulnerabilities; and assign a risk level to the identified threat and vulnerability.
#### 2\. Artificial Intelligence (AI)
Section 238(g) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 defined AI to include the following: \ [892\]
- Any artificial system that performs tasks under varying and unpredictable circumstances without significant human oversight, or that can learn from experience and improve performance when exposed to data sets.
- An artificial system developed in computer software, physical hardware, or other context that solves tasks requiring human-like perception,
( printed page 990)
cognition, planning, learning, communication, or physical action.
- An artificial system designed to think or act like a human, including cognitive architectures and neural networks.
- A set of techniques, including machine learning, that is designed to approximate a cognitive task.
- An artificial system designed to act rationally, including an intelligent software agent or embodied robot that achieves goals using perception, planning, reasoning, learning, communicating, decision making, and acting.
AI requires enormous amounts of data to develop, but it also has enormous potential benefits. The Department has previously stated that these “technologies have the potential to drive innovation, increase market competition, and vastly improve care for patients and populations.” \ [893\]
According to experts, “\[. . .\]AI is unlocking new possibilities by advancing medicine in entirely unimaginable ways and solving some of the grand global healthcare challenges.” \ [894\]
And FDA agrees: “AI technologies are transforming health care by producing diagnostic, therapeutic, and prognostic medical recommendations, or decisions, in some cases independently, informed by the vast amount of data generated during the delivery of health care.” \ [895\]
In medical devices, areas for AI application include:
- Image acquisition and processing
- Early disease detection
- More accurate diagnosis, prognosis, and risk assessment
- Identification of new patterns in human physiology and disease progression
- Development of personalized diagnostics
- Therapeutic treatment response monitoring \ [896\]
For example, clinicians are using AI to distill large volumes of EHR information about a complex patient into a summarized note that they can use to consider diagnoses and treatment. AI also has been used for aid in the detection of diabetic retinopathy, screening for breast and lung cancer, and classification of skin conditions.\ [897\]
Others are using ambient AI scribes, a technology that uses microphones to transcribe encounters with patients in real-time.\ [898\]
This tool creates clinical documentation that clinicians can later edit, which can lead to improved interactions with patients and reduced time on documentation.\ [899\]
Newer AI tools may search medical records for relevant information regarding common conditions and other risk factors \ [900\]
or offer relevant questions for clinicians to pose to make an accurate diagnosis.\ [901\]
Unfortunately, AI can also be used to harm individuals, both intentionally and unintentionally. Bad actors are using generative AI to threaten the privacy and security of ePHI more effectively through phishing and other social engineering. As explained by NCVHS, “AI tools can create mass scale \[cyberattacks\] that are highly effective and major threats to ePHI.” \ [902\]
Experts anticipate that AI “will ultimately pioneer the malicious use of \[. . .\] ‘Offensive AI’—highly sophisticated and malicious attack code—\[that\] will be able to mutate itself as it learns about its environment, and to expertly compromise systems with minimal chance of detection.” \ [903\]
Such experts are concerned about the level of destruction that will lie in its wake and compare it to an arms race that can only escalate.\ [904\]
Indeed, it seems likely that regulated entities will need to invest in AI to defend against malicious use of AI in the future.\ [905\]
After assessing current and potential AI threats, NCVHS recommended that the Department clarify how the HIPAA Rules apply to AI.\ [906\]
We agree with their assessment and recommendation. Specifically, ePHI, including ePHI in AI training data, prediction models, and algorithm data that is maintained by a regulated entity for covered functions is protected by the HIPAA Rules and all applicable standards and specifications.\ [907\]
For example, generative AI tools have produced in their output the names and personal information of persons included in the tools' sources of training data.\ [908\]
Similar uses of generative AI by regulated entities, including the training of AI models on patient data, could result in impermissible uses and disclosures, including exposure to bad actors that can exploit the information.\ [909\]
As part of its risk analysis and risk management activities, a regulated entity must consider the risk associated with different uses and data.\ [910\]
Accordingly, we expect that a regulated entity interested in using AI would include the use of such tools in its risk analyses and associated risk management activities. The regulated entity's risk analysis must include consideration of, among other things, the type and amount of ePHI accessed by the AI tool, to whom the data is disclosed, and to whom the output is provided. The NIST AI Risk Management Framework is a helpful resource for regulated entities to better
( printed page 991)
understand, measure, and manage risks, effects, and harms of AI.\ [911\]
The Security Rule requires a regulated entity to conduct repeated risk analyses that consider any changes to its environment or operations, such as updates or changes in technology or clinical administration, and to apply all reasonable updated protections to safeguard ePHI.\ [912\]
Accordingly, as technology such as AI evolves, the Department would expect a regulated entity to perform a risk analysis to consider the effects of such changes on the confidentiality, integrity, and availability of ePHI. As NCVHS observed, “\[I\]t is important to conduct risk analyses on AI throughout the life cycle of the system.” \ [913\]
We believe the proposals in this NPRM would clarify our expectations for when and how regulated entities need to consider, prepare for, and address such changes. For example, the Department proposes to expressly require that a regulated entity develop a written inventory of its technology assets. Under this proposal, the Department would expect that AI software used to create, receive, maintain, or transmit ePHI or that interacts with ePHI, including where ePHI is used to train the AI software, would be listed as part of its technology asset inventory, which feeds into the regulated entity's risk analysis. Making AI safe and secure with respect to ePHI requires efforts in a variety of areas—biotechnology, cybersecurity, critical infrastructure—to address risks.\ [914\]
The Federal Government seeks to ensure that the collection, use, and retention of ePHI is lawful and secure, and that it mitigates privacy and confidentiality risks. Across the administration, Federal agencies are considering potential uses for AI, as well as their benefits and risks, consistent with E.O. 11410 and its principles to advance and govern the development and use of AI.\ [915\]
These principles include making AI safe and secure and protecting privacy and civil liberties. For example, the Department finalized regulations earlier this year that improve transparency by health IT developers of certified health IT, including those that are business associates, that supply a particular type of AI—predictive decision support interventions (DSIs).\ [916\]
Specifically, the regulations require such health IT developers to provide greater transparency about the design, development, training, evaluation, and use of such predictive DSIs.\ [917\]
This approach promotes responsible AI and makes it possible for covered entities to access a consistent, baseline set of information about the algorithms they use to support their decision making and to assess such algorithms for fairness, appropriateness, validity, effectiveness, and safety.\ [918\]
Additionally, the Department proposes to require that regulated entities monitor authoritative sources for known vulnerabilities and to remediate such vulnerabilities in accordance with their patch management program. We also propose to require that patches, updates, and upgrades that address critical and high risks be applied promptly. Together, these proposals would support the rapid response to vulnerabilities that will be necessary as AI becomes more prevalent. Thus, the Department believes that the adoption of the cybersecurity best practices proposed in this NPRM is an important first step to ensuring that AI tools are deployed by regulated entities in a manner that protects the confidentiality, integrity, and availability of ePHI.
#### 3\. Virtual and Augmented Reality (VR and AR)
Research on VR and AR technologies is widespread and has produced numerous applications in the health care fields. Such technologies are being used in medical education and patient care, including AR-assisted surgeries, VR-based pain management therapies, and immersive patient education tools.\ [919\]
Additionally, innovators are working on ways to incorporate AI with VR and AR for improved diagnostics and treatment planning.\ [920\]
However, as with quantum computing and AI, VR and AR technologies raise new privacy and security concerns. VR and AR involve the use of diverse technologies and the collection of a wide array of sensitive information, including comprehensive biometric data.\ [921\]
According to experts, “\[. . .\] VR and AR present distinct security challenges, encompassing typical vulnerabilities associated with electronic devices, as well as potential risks of physical harm and leakage of highly sensitive data.” \ [922\]
VR, like any connected computing device, “is susceptible to standard cybersecurity concerns and various types of cyberthreats, necessitating proactive anticipation.” \ [923\]
These cybersecurity risks, such as hacking, social engineering, malicious software, and ransomware, can be mitigated through holistic risk analysis and risk management, consistent with the Security Rule administrative standards in 45 CFR 164.308. In addition, patch management,\ [924\]
access control,\ [925\]
authentication,\ [926\]
and appropriate business associate agreements \ [927\]
are examples of some of the required safeguards that would apply to VR and AR systems.
We believe the proposals in this NPRM to clarify these safeguards would substantially improve the ability of regulated entities to address these cybersecurity risks. For example, the Department proposes to require that a regulated entity obtains from a business associate written verification that the business associate has deployed the technical safeguards required by the Security Rule, including a written analysis of the business associate's information systems from a person with
( printed page 992)
appropriate knowledge of and experience with generally accepted cybersecurity principles and methods for ensuring the confidentiality, integrity, and availability of ePHI verifying compliance with the requirements of 45 CFR 164.312 and a written certification that the analysis has been performed and is accurate. Under this proposal, a regulated entity would be required to obtain such verification from a business associate-developer of VR/AR software, ensuring that ePHI that is created, received, maintained, or transmitted using the VR/AR software is protected to the same extent as ePHI that is created, received, maintained, or transmitted using other technology assets that are components of the regulated entity's relevant electronic information systems.
Many regulated entities are piloting innovative technologies. Such entities generally have separate departments that research, develop, test, and deploy such technologies.\ [928\]
Regulated entities might consider integrating workforce members with expertise in security and privacy into their technology development groups to ensure that privacy and security, including the Security Rule-required safeguards, are embedded into the design of new and emerging technologies.\ [929\]
Doing so can help improve security “while boosting quality, efficiency, and productivity.” \ [930\]
#### 4\. Request for Comment
The Department requests comment on the foregoing discussion of how the Security Rule protects ePHI used in new and developing technologies, including any benefits, drawbacks, or unintended consequences. We also request comment on the following considerations in particular:
a. Whether the Department's understanding of how the Security Rule applies to new technologies involving ePHI is not comprehensive and if so, what issues should also be considered.
b. Whether there are technologies that currently or in the future may harm the security and privacy of ePHI in ways that the Security Rule could not mitigate without modification, and if so, what modifications would be required.
c. Whether there are additional policy or technical tools that the Department may use to address the security of ePHI in new technologies.
## V. Regulatory Impact Analysis
### A. Executive Order 12866 and Related Executive Orders on Regulatory Review
The Department of Health and Human Services (HHS or “Department”) has examined the effects of this proposed rule under Executive Order (E.O.) 12866, Regulatory Planning and Review,\ [931\] E.O. 13563, Improving Regulation and Regulatory Review,\ [932\] E.O. 14094, Modernizing Regulatory Review,\ [933\]
the Regulatory Flexibility Act \ [934\]
(RFA), the Unfunded Mandates Reform Act of 1995 \ [935\]
(UMRA), and E.O. 13132 on Federalism.\ [936\]
E.O.s 12866 and 13563 direct the Department to assess all costs and benefits of available regulatory alternatives and, when regulation is necessary, to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive effects; and equity). The proposed rule meets the criteria as significant under section 3(f)(1) of E.O. 12866, as amended by E.O. 14094.
The RFA requires us to analyze regulatory options that would minimize any significant effect of a rule on small entities. As discussed in greater detail below, this analysis concludes, and the Secretary certifies, that the notice of proposed rulemaking (NPRM), if adopted, would not result in a significant economic effect on a substantial number of small entities.
The UMRA (section 202(a)) generally requires us to prepare a written statement, which includes an assessment of anticipated costs and benefits, before proposing “any rule that includes any Federal mandate that may result in the expenditure by State, local, and Tribal governments, in the aggregate, or by the private sector, of $100,000,000 or more (adjusted annually for inflation) in any 1 year.” \ [937\]
The current threshold after adjustment for inflation is $183 million, using the most current (2024) Implicit Price Deflator for the Gross Domestic Product. UMRA does not address the total cost of a rule. Rather, it addresses certain categories of cost, mainly Federal mandate costs resulting from imposing enforceable duties on State, local, or Tribal governments or the private sector; or increasing the stringency of conditions in, or decreasing the funding of, State, local, or Tribal governments under entitlement programs.
This proposed rule, if adopted, would impose mandates that would result in the expenditure by State, local, and Tribal governments, in the aggregate, or by the private sector, of more than $183 million in any one year. The impact analysis in this proposed rule addresses such effects both qualitatively and quantitatively. Each covered entity and business associate (collectively, “regulated entity”), including government entities that meet the definition of covered entity (
_e.g.,_
State Medicaid agencies), would be required to: conduct a Security Rule compliance audit; report to covered entities or business associates, as applicable, upon activation of their contingency plan; deploy multi-factor authentication (MFA) in and penetration testing of relevant electronic information systems; complete network segmentation; disable unused ports and remove extraneous software; update cybersecurity policies and procedures; revise business associate agreements; and update workforce training. Business associates would be required to conduct an analysis and provide verification of their compliance with technical safeguards and covered entities would be required to obtain verification from business associates (and business associates from their subcontractors). Additionally, group health plans would need to revise plan documents to require plan sponsors to comply with administrative, physical, and technical safeguards according to the Security Rule standards. Finally, through contractual language, health plan sponsors would need to enhance safeguards for electronic protected health information (ePHI) according to the Security Rule standards. Costs for all regulated entities to change their policies and procedures alone would increase costs above the UMRA threshold in one year, and costs of health plan sponsors would increase total costs further. Although Medicaid makes Federal matching funds available for States for certain administrative costs, these are limited to costs specific to operating the Medicaid program. There are no Federal funds directed at Health Insurance Portability and Accountability Act of 1996 (HIPAA) compliance activities.
The Department believes that pursuant to Subtitle E of the Small Business Regulatory Enforcement
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Fairness Act of 1996,\ [938\]
the Office of Management and Budget's (OMB's) Office of Information and Regulatory Affairs would be likely to determine that when finalized, this rule meets the criteria set forth in 5 U.S.C. 804(2) because it is projected to have an annualized effect on the economy of more than $100,000,000.
The Justification for this Rulemaking and Summary of Proposed Rule Provisions section at the beginning of this preamble contain a summary of this rule and describe the reasons it is needed. We present a detailed analysis below.
#### 1\. Summary of Costs and Benefits
The Department identified ten categories of quantifiable costs arising from these proposals that would apply to all regulated entities: (1) conducting a Security Rule compliance audit; (2) obtaining written verification from their business associates or subcontractors that the business associates or subcontractors, respectively, have conducted the required verification of compliance with technical safeguards; (3) notifying other regulated entities when workforce members' access to ePHI is terminated; (4) completing network segmentation; (5) disabling ports and removing extraneous software; (6) deploying MFA; (7) deploying penetration testing; (8) updating policies and procedures; (9) updating workforce training programs; and (10) revising business associate agreements. Additionally, group health plans would be required to update plan documents to require health plan sponsors' compliance with the administrative, physical, and technical safeguards according to the Security Rule and notification of group health plans when health plan sponsors activate their contingency plan. Business associates would have additional obligations to verify compliance with technical safeguards and provide it in writing to covered entities (and subcontractors to business associates) and to notify covered entities upon activation of their contingency plans. Finally, although plan sponsors are not directly subject to the HIPAA Rules, by virtue of the plan document requirements, the Department estimates that certain group health plan sponsors (
_e.g.,_
employers that provide group health benefits) would likely incur some quantifiable costs to improve safeguards for their electronic information systems that affect the confidentiality, integrity, or availability of ePHI and to notify group health plans upon activation of plan sponsors' contingency plan.
The Department estimates that the first-year costs attributable to this proposed rule total approximately $9 billion. These costs are associated with regulated entities and health plan sponsors engaging in the regulatory actions described above. For years two through five, estimated annual costs of approximately $6 billion are attributable to costs of recurring compliance activities. Table 1 reports the present value and annualized estimates of the costs of this proposed rule covering a 5-year time horizon. Using a 2 percent discount rate, the Department estimates that this proposed rule would result in annualized costs of $6.8 billion for regulated entities and health plan sponsors combined.
Costs Primary <br> estimate Year dollars Discount rate Period <br> covered
--- --- --- --- ---
Present Value $34 2023 Undiscounted 2026-2030
Present Value 32 2023 2% 2026-2030
Annualized 7 2023 2% 2026-2030
a<br> Figures are rounded.
Table 1—Accounting Table, Costs of the Proposed Rule, $ Billions
As a result of the proposed changes in this NPRM, the enhanced security posture of regulated entities would likely reduce the number of breaches of ePHI and mitigate the effects of breaches that nonetheless occur. The Department has partially quantified these effects and presents them in a break-even analysis. The break-even analysis estimates that if the proposed changes in the NPRM reduce the number of individuals affected by breaches by 7 to 16 percent, the revised Security Rule would pay for itself. Alternatively, the same cost savings may be achieved by lowering the cost per affected individual's ePHI by 7 percent ($35) to 16 percent ($82), respectively.
The changes to the Security Rule would likely result in important benefits and some costs that the Department is unable to fully quantify at this time. As explained further below, unquantified benefits include reductions in reputational, financial, and legal harm from breaches of individuals' ePHI, reductions in disruptions to health care delivery, increased confidence among parties to health care business transactions, and improved quality of health care.
Benefits a
---
Would benefit individuals by shielding them from unwanted disclosure of their ePHI and resulting reputational, financial, and legal harms from ePHI misuse.
Would reduce reputational damage to regulated entities resulting from breaches.
Would increase confidence among parties to health care business transactions that ePHI is protected to a higher degree than previously.
Would reduce risk of breaches of ePHI by health plan sponsors.
Would help to prevent health care cost increases to recoup financial losses from responding to breaches.
Would help guard against potential data loss.
Would help minimize potential disruption of service for individuals served by any of the affected entities.
a<br> Some of the items in this list represent differing perspectives on the same effect. In such cases, if more thorough quantification became feasible, we would take steps to avoid double-counting when summing the quantitative estimates.
Table 2—Potential Non-Quantified Benefits
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The Department also recognizes that there may be some costs that are not readily quantifiable, notably, actions that regulated entities may take to comply with existing requirements more fully as a result of proposed clarifications. For example, this would include completing a technology asset inventory, which is a baseline expectation for the existing requirement of conducting a risk assessment; documenting completion of existing requirements; adding more specificity to the required contingency plan, such as designating staff roles with specific responsibilities when a contingency occurs; testing safeguards as part of reviewing and updating policies and procedures and technical controls; and deploying encryption for ePHI in a more concerted manner (including documenting provision of notification in response to individuals' access requests for transmission of ePHI in an unencrypted manner and has been informed of the risks associated with the transmission, receipt, and storage of unencrypted ePHI). These activities are specified in the NPRM, but they would be more in the nature of clarifications to and increased specificity of existing requirements. Because the degree of additional effort by regulated entities to meet these requirements would be dependent on multiple factors and likely to be highly variable, the additional cost is difficult to quantify.
We acknowledge that there may be a small burden associated with documenting that an individual was informed of the risks of unencrypted transmission of ePHI; however, we believe there are few requests that fall into this category. Because we do not have a basis to make an estimate, we have requested data on potential burdens associated with this proposed exception to the proposed standard for encryption in the preamble discussion of 45 CFR 164.312.
The cost of complying with the exceptions to encryption and MFA for medical devices authorized by the U.S. Food & Drug Administration for marketing may depend in part on the extent to which a regulated entity relies on legacy devices because the regulated entity may be required to adopt compensating controls. New devices are likely to have encryption and MFA built into them, not requiring compensating controls. The Department is unable to estimate the range of costs to adopt compensating controls for legacy devices because there is no reliable data to accurately assess the extent to which legacy devices are used in the United States.\ [939\]
The Department requests comment on the number of legacy devices in use and the costs of applying compensating controls to such devices.
#### 2\. Baseline Conditions
The Security Rule, in conjunction with the Privacy and Breach Notification Rules, protects the privacy and security of individuals' PHI, that is, individually identifiable health information (IIHI). The Security Rule's protections are limited to ePHI, while the Privacy and Breach Notification Rules protect both electronic and non-electronic PHI. The Security Rule establishes standards to protect individuals' ePHI and requires reasonable and appropriate administrative, physical, and technical safeguards. The Security Rule specifies a series of administrative, physical, and technical security requirements that must be performed or implemented for regulated entities to safeguard ePHI. Specifically, entities regulated by the Security Rule must: (1) ensure the confidentiality, integrity, and availability of all ePHI they create, receive, maintain, or transmit; (2) protect against reasonably anticipated threats to the security and integrity of the information; (3) protect against reasonably anticipated impermissible uses or disclosures; and (4) ensure compliance by their workforce. A major goal of the Security Rule is protecting the security of individuals' health information while allowing for the development of a health information system to improve the efficiency and effectiveness of the health care system.
The Administrative Simplification provisions of HIPAA (title II) provide the Secretary of HHS with the authority to publish standards for the privacy and security of health information. The Department first proposed standards for the security of ePHI on August 12, 1998, and published a final rule on February 20, 2003. The Department modified the Security Rule in 2013. Recently, as the preamble to this NPRM discusses, changes in the health care environment and insufficient compliance by regulated entities with the existing Security Rule require the modifications proposed here.
For purposes of this Regulatory Impact Analysis (RIA), the proposed rule adopts the list of covered entities (with an updated count) and certain cost assumptions identified in the Department's Information Collection Request (ICR) associated with the HIPAA Privacy Rule to Support Reproductive Health Care Privacy (“2024 ICR”).\ [940\]
The Department also relies on certain estimates and assumptions from the 1998 Proposed Rule \ [941\]
that remain relevant, the 2003 Final Rule,\ [942\]
and the 2013 Omnibus Rule,\ [943\]
as referenced in the analysis that follows.
The Department quantitatively analyzes and monetizes the effect that this proposed rule would have on the actions of regulated entities to: conduct a Security Rule compliance audit; provide or obtain verification of business associates' compliance with technical safeguards; notify other regulated entities when workforce members' access to ePHI is altered or terminated; notify covered entities or business associates, as applicable, upon activation of a contingency plan; complete network segmentation; disable unused ports and remove extraneous software; deploy MFA and penetration testing; update health plan documents; update policies and procedures; update workforce training; and revise business associate agreements. The Department also quantitatively analyzes the effects on group health plan sponsors for ensuring that safeguards for their relevant electronic information systems meet Security Rule standards and notifying group health plans upon activation of the plan sponsors' contingency plans.
Additionally, the Department quantitatively analyzes the benefits of the proposed modifications to regulated entities due to an expected reduction in costs of remediation of breaches and risk of breaches by regulated entities.
The Department analyzes the remaining benefits and costs qualitatively because many of the proposed modifications are clarifications of existing requirements and predicting other concrete actions that such a diverse scope of regulated entities might take in response to this rule is inherently uncertain.
#### Analytic Assumptions
The Department bases its assumptions for calculating estimated costs and benefits on several publicly available datasets, including data from the U.S. Census Bureau (“Census”), the U.S. Department of Labor's (DOL) Bureau of Labor Statistics, the Small Business Administration (SBA), and the Department's Centers for Medicare &
( printed page 995)
Medicaid Services (CMS) and Agency for Healthcare Research and Quality (AHRQ). For the purposes of this analysis, the Department assumes that employee benefits plus indirect costs equal approximately 100 percent of pre-tax wages and adjusts the hourly wage rates by multiplying by two, for a fully loaded hourly wage rate. The Department adopts this as the estimate of the hourly value of time for changes in time use for on-the-job activities.
Implementing the proposals likely would require regulated entities to engage workforce members or consultants for certain activities. The Department assumes that an information security analyst would perform most of the activities proposed in the NPRM, consistent with the existing Security Rule requirements. The Department expects that a computer and information systems manager would revise policies and procedures, a training and development specialist would revise the necessary workforce training, a lawyer would revise business associate agreements, and a compensation and benefits manager would revise health plan documents for plan sponsors. To the extent that these assumptions affect the Department's estimate of costs, the Department solicits comment on its assumptions, particularly assumptions in which the Department identifies the level of workforce member (
_e.g.,_
analyst, manager, licensed professional) that would be engaged in activities and the amount of time that particular types of workforce members spend conducting activities related to this RIA as further described below. Table 3 lists pay rates for occupations referenced in the cost estimates for the NPRM.
Occupation code and title Fully loaded<br> hourly wage 2023 Average<br> hourly wage
--- --- ---
15-1212 Information Security Analysts $119.94 $59.97
13-1151 Training and Development Specialists 69.20 34.60
11-3111 Compensation and Benefits Manager 145.14 72.57
11-3021 Computer and Information Systems Managers 173.76 86.88
23-1011 Lawyers 169.68 84.84
13-1111 Management Analysts 111.08 55.54
43-0000 Office and Administrative Support Occupations 46.10 23.05
Table 3—Occupational Pay Rates 944
The Department
assumes that most regulated entities would be able to incorporate changes to their workforce training into existing cybersecurity awareness training programs and Security Rule training rather than conduct a separate training because the total time frame for compliance from date of publication of a final rule would be 240 days.\ [945\]
#### Regulated Entities Affected
The changes proposed in this NPRM would apply to covered entities (
_i.e.,_
health care providers that conduct covered electronic transactions, health plans, and health care clearinghouses) and their business associates (including subcontractors). The Department estimates the number of covered entities to be 822,600 business establishments (see table 4). By calculating costs for establishments, rather than firms,\ [946\]
some burdens may be overestimated because certain costs would be borne by a parent organization rather than each separate facility. Similarly, benefits and transfers would be overestimated because entity assumptions flow through to those quantifications. However, decisions about the level of an organization that is responsible for implementing certain requirements likely varies across the health care industry. The Department requests data on the extent to which certain burdens are borne by each facility versus an umbrella organization.
According to Census data,\ [947\]
there are 954 Direct Health and Medical Insurance Carrier firms out of a total 5,822 Insurance Carrier firms, such that health and medical insurance firms make up approximately 16.4 percent of insurance firms \[= 954/5,822\].\ [948\]
Also, according to Census data, there are 2,506 Third Party Administration of Insurance and Pension Funds firms and 8,375 establishments. This category also includes clearinghouses. The Department assumes that 16.4 percent of these firms service health and medical insurance because that is equivalent to the share of insurance firms that are health and medical. As a result, the Department estimates that 411 firms categorized as Third Party Administrators are affected by the proposals in this NPRM \[= 2,506 × .164\]. Similarly, the Department estimates that 1,374 associated establishments would be affected by the proposals in this NPRM \[= 8,375 total establishments × .164\]. Most of these are business associates. Based on data from the Department's HIPAA audits and experience administering the HIPAA Rules, we are aware of approximately 36 clearinghouses. See table 4 below.
There were 56,289 community pharmacies, including 19,261 pharmacy and drug store firms, operating in the U.S. in 2023.\ [949\]
Small pharmacies generally use pharmacy services administration organizations (PSAOs) to provide administrative services, such as conducting negotiations. Based on information from industry, the Department estimates that the proposed rule would affect fewer than 10 PSAOs and we include this within the estimated 1 million business associates affected by the proposals in this NPRM.\ [950\]
The Department assumes that
( printed page 996)
costs affecting pharmacies are incurred at each pharmacy and drug store establishment and each PSAO.
Covered Entities
---
NAICS code Type of entity Firms Establishments Small business<br> administration <br> (SBA) <br> <br> size threshold c<br> <br> (million)
--- --- --- --- ---
524114 Health and Medical Insurance Carriers 954 5,552 $47
524292 Clearinghouses a 36 36 47
622 Hospitals 3,095 7,465 47
446110 Pharmacies b 31,671 56,289 37.5
6211-6213 Office of Drs. & Other Professionals 429,476 527,951 9-16
6215 Medical Diagnostic Laboratories & Imaging 8,714 19,477 19-41.5
6214 Outpatient Care 26,084 54,642 19-47
6219 Other Ambulatory Care 10,547 16,114 20.5-40
623 Skilled Nursing & Residential Facilities 42,421 95,175 16-34
6216 Home Health Agencies 27,433 38,040 19
532283 Home Health Equipment Rental 488 1,859 41
Total 580,9198 822,600
a<br> This North American Industry Classification System (NAICS) category includes clearinghouses and is titled “Third Party Administration of Insurance and Pension Funds.” The number of clearinghouses is based on the Department's research.
b<br> Number of pharmacies is taken from industry statistics.
c _See_<br> “Table of Small Business Size Standards,” U.S. Small Business Administration (Mar. 17, 2023), <br> _https://www.sba.gov/sites/sbagov/files/2023-06/Table%20of%20Size%20Standards\_Effective%20March%2017%2C%202023%20%282%29.pdf._<br> The SBA size thresholds are discussed in Section V.C. Regulatory Flexibility Act—Small Entity Analysis of this NPRM.
Table 4—Estimated Number, Type, and Size Threshold of Covered Entities
The Department also estimated the percentage of rural and urban health care providers by matching health care provider data from CMS,\ [951\]
Health Resources & Services Administration,\ [952\]
and the Statistics of U.S. Businesses (SUSB) \ [953\]
with county population data from the U.S. Census Bureau.\ [954\]
We determined whether a health care provider was rural or urban based on OMB's standards for delineating metropolitan and micropolitan statistical areas.\ [955\]
Consistent with OMB's standard, we considered a county to be rural if it has fewer than 50,000 inhabitants.\ [956\]
This includes micropolitan areas (towns and cities between 10,000 and 49,999) and counties outside of metropolitan statistical areas and micropolitan areas. Based on this analysis, we estimate that 7-8 percent of health care providers operate in rural areas.
#### Estimated Number and Type of Business Associates
The Department adopts the estimate of approximately 1,000,000 business associates (including subcontractors) as stated in the 2024 ICR and the 2013 “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health \[HITECH\] Act and the Genetic Information Nondiscrimination Act, and Other Modifications to the HIPAA Rules” final rule.\ [957\]
We considered whether to increase this figure in our updates but did not do so because many business associates serve multiple covered entities. We lack sufficient data to estimate the number of such businesses more precisely, but we believe that the number of business associates is highly dynamic and dependent on multiple market factors, including expansion and consolidation among various lines of business, changing laws and legal interpretations, and emerging technologies. We include subcontractors of business associates within our estimate because they are business associates of business associates.
The Department welcomes comments on the number or type(s) of regulated entities that would be affected by the proposals in this proposed rule and the extent to which they may experience costs or other burdens not already accounted for in the cost estimates. The Department also requests comment on the number of health plan documents that would need to be revised, if any. The Department additionally requests detailed comment on any situations, other than those identified here, in which covered entities or business associates would be affected by the proposals in this rulemaking.
#### Health Plan Sponsors
Within this NPRM, the Department is for the first time including estimates of health plan sponsors' potential costs of compliance with specific
( printed page 997)
administrative, physical, and technical safeguards of the Security Rule. The Department relied on data from AHRQ and the U.S. Census to estimate the number of firms offering group health plans (1.9 million),\ [958\]
and multiplied that by the percentage that offer at least one self-insured plan to calculate the number of plan sponsors that would be likely to receive ePHI and be subject to the requirements of 45 CFR 164.314(b)) \[1,943,484 × .382 = 742,411\]. We solicit comments on whether group health plans or third-party administrators address any Security Rule requirements for plan sponsors, so the plan sponsors would not have an additional burden or would have a smaller burden than estimated below.
#### Individuals Affected
The number of individuals potentially affected by the proposed changes to the Security Rule includes most of the United States population (approximately 337 million), specifically those who have received any health care in the past seven years and whose ePHI is likely created, received, maintained, or transmitted by a regulated entity. Statistics about the number of individuals affected by breaches of PHI provide insight into known instances where safeguards were breached, although the effects of the Security Rule extend farther than that, to all ePHI. Data from the 2022 Annual Report to Congress on Breaches of Unsecured Protected Health Information for Calendar Year 2022 \ [959\]
revealed nearly 42 million individuals affected by breaches of PHI in that year. Third-party sources reported approximately 133 million individuals affected by health care breaches in 2023.\ [960\]
According to UnitedHealth Group, the 2024 breach of its clearinghouse subsidiary Change Healthcare may have affected approximately one-third of the U.S. population, or 112 million individuals.\ [961\]
The Department believes that the range of individuals potentially affected by the proposed regulatory changes would be from 42 million to 337 million.
#### HIPAA Breach Data
The Department has reported HIPAA/HITECH breach data annually since 2009. Table 5 shows the data as reported to Congress for the past five years. We relied on this data, combined with breach cost data from industry sources, to analyze the potential savings of the NPRM.
Year Small breaches<br> (fewer than 500 affected <br> individuals) Large breaches<br> (500+ affected <br> individuals) Total
--- --- --- ---
Breach count Affected<br> individuals Breach count Affected<br> individuals Breach count Affected<br> individuals
--- --- --- --- --- ---
2018 63,098 296,948 302 12,196,601 63,400 12,493,549
2019 62,771 284,812 408 38,732,966 63,179 39,017,778
2020 66,509 312,723 656 37,641,403 67,165 37,954,126
2021 63,571 319,215 609 37,182,558 64,180 37,501,773
2022 63,966 257,105 626 41,747,613 64,592 42,004,718
Table 5—Breaches of PHI
#### 3\. Costs of the Proposed Rule
Below, the Department provides the basis for its estimated quantifiable costs resulting from the proposed changes to specific provisions of the Security Rule. Many of the estimates are based on assumptions formed through OCR's experience with compliance and enforcement and accounts from stakeholders. For each cost, the Department provides its main estimate, as well as additional high and low estimates for some costs to account for any uncertainty in the compliance approach of regulated entities.
All estimates in this section are based on subject matter expertise. The Department requests information or data points from commenters to further refine its estimates and assumptions.
#### a. Costs Associated With Conducting a Security Rule Compliance Audit
The Department estimates that all regulated entities would need to conduct a Security Rule Compliance Audit because this would be a new requirement under proposed 45 CFR 164.308(a)(14)(14)). Although some regulated entities have mistakenly conducted such an audit in lieu of a risk analysis, the Department believes that costs for the compliance audit as a separate requirement should be attributed to the proposed changes in the NPRM. Further, because this would be an annual requirement, the Department is including this as a recurring cost. The Department estimates that regulated entities would need an average of 2 hours of labor by an information systems analyst to conduct the compliance audit, based on the assumption that regulated entities have already documented Security Rule compliance activities as currently required. This would result in total estimated costs of $437,205,288 \[= 1,822,600 regulated entities × 2 hours × $119.94\]. The respective low and high estimates would be 0.25 and 2.5 hours of information systems analyst labor, resulting in respective total estimated costs of $54,650,6611 \[= 1,822,600 regulated entities × 0.25 hours × $119.94\] and $546,506,610 \[= 1,822,600 regulated entities × 2.5 hours × $119.94\].
( printed page 998)
#### b. Estimated Costs From Adding a Requirement for Business Associates to Analyze Compliance With Technical Safeguards
For proposed 45 CFR 164.308(b)), the Department estimates that business associates that handle ePHI would need to spend an average of 2 hours (with a low estimate of 0.25 hours and high estimate of 2.5 hours) analyzing how their cybersecurity measures comply with the proposed requirements for technical safeguards and producing a verification report for covered entities at the hourly wage rate of an information security analyst. This estimate assumes that business associates have already documented existing safeguards, policies, and procedures, so that the costs attributable to the new requirement are incremental and would total approximately $239,880,000 \[1 million business associates × 2 hours × $119.94\], with a low estimate of $29,985,000 \[1 million business associates × 0.25 hours × $119.94\] and high estimate of $299,850,000 \[1 million business associates × 2.5 hours × $119.94\].
#### c. Costs Arising From Covered Entities and Business Associates Obtaining Verification From Business Associates of Compliance With Technical Safeguards
Under 45 CFR 164.308(b)), the Department further estimates that each covered entity would need to spend an average of 30 minutes (with 15 minutes as a low estimate and 90 minutes as a high estimate) requesting and obtaining compliance reports from its business associates about their deployment of technical safeguards required by the Security Rule at the hourly wage of an information security analyst. This assumes that in most instances, business associates would produce the required verification for covered entities without being prompted by a request because they would be required to do so by the Security Rule, as proposed in the NPRM. It further assumes that covered entities have readily available means of contacting business associates, such as via email, and that the contact could be a single email draft sent in a batch. The average time burden per entity depends on verification frequency, likely influenced by entities' average number of business associates and how frequently entities change business associates. The low estimate assumes that entities verify less frequently, whereas the high estimate assumes entities verify more frequently. At the wage rate of an information security analyst, this would result in estimated total costs for covered entities of $49,331,322 \[= 822,600 covered entities × 0.5 hours × $119.94\], with a low estimate of $24,665,661 \[= 822,600 covered entities × 0.25 hours × $119.94\] and high estimate of $147,993,966 \[= 822,600 covered entities × 1.5 hours × $119.94\].
The proposed requirement to obtain verification of compliance with technical safeguards also would apply to business associates with respect to their subcontractors. However, we believe that a much smaller number of business associates rely on subcontractors compared to the number of covered entities that rely on business associates to conduct activities on their behalf. Thus, we estimate that, on average, business associates would need 5 minutes annually to obtain verification from their subcontractors that the subcontractors have complied with technical safeguards as required by the Security Rule. The estimate includes only the time needed for business associates to send a mass email to subcontractors because we have already addressed the burden on business associates of producing the verification in the previous section and that estimate includes burdens on subcontractors. The high estimate for this activity would be an average of 15 minutes per business associate, and a low estimate would be for business associates to 2 minutes on this activity. At the wage rate of an information security analyst, this would add estimated total costs for business associates of $9,995,000 \[= 1,000,000 business associates × 0.083 hours × $119.94\], with a high estimate of $29,985,000 \[= 1,000,000 business associates × .25 hours × $119.94\].
#### d. Cost Related to Notification of Termination or Change of Workforce Members' Access to ePHI
The Department estimates that regulated entities are likely to incur additional costs to implement a process to notify other regulated entities when a workforce member's access to ePHI is terminated or changed under proposed 45 CFR 164.308(a)(9)(ii)(9)(ii)). This estimate assumes that notifications will take an average of 1 hour annually per regulated entity. This results in new estimated costs totaling $84,021,860 \[= 1,822,600 regulated entities × 1 hour × $46.10\].\ [962\]
#### e. Cost Related to Regulated Entities Deploying Multi-Factor Authentication
The Department estimates that, on average, regulated entities would have an information security analyst spend 1.5 hours deploying MFA, as specifically required under proposed 45 CFR 164.312(f)(2)(ii)(2)(ii)). This would be a one-time, first-year burden that includes an average of 30 minutes for a regulated entity to select an MFA solution that allows them to meet the requirements of the proposal without creating workflow disruptions or delays. This estimate would vary depending on how prevalent MFA is in the industry when and if the requirements of the NPRM are finalized. As a widely accepted information security practice, the Department believes that many large entities have already deployed MFA and the costs range from zero to only a few dollars per user. The low estimate would be 01 hours on average (assuming that many entities already have some form of MFA), and the high estimate would be 1.75 hours (assuming that few entities have MFA). At the loaded wage rate of an information security analyst, the total estimated cost would be $327,903,966 \[= 1,822,600 regulated entities × 1.5 hours × $119.94\], with a low estimated total of $218,602,644 \[= 1,822,600 regulated entities × 1 hour × $119.94\] and a high estimated total of $382,554,627 \[= 1,822,600 regulated entities × 1.75 hours × $119.94\]. The Department applies this cost in the first year only because minimal additional labor is needed to maintain this safeguard once it has been deployed.
#### f. Costs Related to Network Segmentation
The Department believes that most large regulated entities and many medium-sized regulated entities have segmented their information networks to some degree; however, additional actions may be needed to more fully protect ePHI as required under proposed 45 CFR 164.312(a)(2)(vi)(2)(vi)). Further, small entities may not have been aware of the importance of segmenting networks or taken steps to segment their networks. The Department estimates that each regulated entity would spend an average of 4.5 hours to set up network segmentation in the first year of compliance with a final rule (with a low estimate of 4 hours and a high estimate of 5 hours) at the hourly wage of an information security analyst. The Department further assumes that in the following years, the burden to maintain the segmented network would be minimal and incorporated into the maintenance requirements. The total first year estimated cost of the network segmentation requirement would be $983,711,898 \[= 1,822,600 regulated entities × 4.5 hours × $119.94\] with a low estimated total of $874,410,576 \[= 1,822,600 regulated entities × 4 hours ×\
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$119.94\] and a high estimate of $1,093,013,220 \[= 1,822,600 regulated entities × 5 hours × $119.94\].
#### g. Cost Related to Disabling Ports and Removing Extraneous Software
The Department believes that large regulated entities have already disabled unused network ports and removed extraneous software as part of existing configuration requirements. However, the Department believes that small and medium-sized regulated entities are less likely to have performed these actions and thus would incur a new burden to implement these aspects of configuration management proposed at 45 CFR 164.312(c)(2)(ii)(2)(ii)) and (iv)(2)(iv)). The Department estimates that 629,796 establishments are owned by small and medium-sized covered entities,\ [963\]
which is approximately 76.56 percent of all covered entities \[= 629,796/822,600\]. The Department applies that percentage to the estimated number of business associates \[= 0.7656 × 1,000,000\] to arrive at the estimated number of regulated entities with quantifiably increased burdens from these proposed requirements to disable unused ports and remove extraneous software. We estimate that for these 1,395,396 regulated entities \[= 629,796 covered entities + 765,600 business associates\], an average annual burden of 30 minutes would be needed at the wage rate of an information security analyst to make needed changes to configuration management, specifically disabling unused ports and removing extraneous software. This would result in estimated total cost increases of $83,681,898 \[= 1,395,3960 regulated entities × 0.5 hours × $119.94\], with a low estimate of $41,840,949 \[= 1,395,396 regulated entities × 0.25 hours × $119.94\] based on an estimated annual burden of 15 minutes per affected entity and a high estimate of $109,301,322 \[= 1,822,600 regulated entities × 0.50 hours × $119.94\] based on an estimated annual burden of 30 minutes for all regulated entities.
#### h. Costs Related to Regulated Entities Conducting Penetration Testing
The Department estimates that each regulated entity would spend an average of 3 hours conducting penetration testing (with a low estimate of 2 hours and a high estimate of 10 hours) at the hourly wage of an information security analyst. The Department expects that there might be a high degree of variability between entities depending on their size and technological sophistication. Large entities have more endpoints to test, and thus have greater exposure. The Department also believes there is room for significant variability in the effort that regulated entities may apply to this activity. At the wage rate of an information security analyst, this would result in estimated total annual costs for regulated entities of $655,807,932 \[= 1,822,600 regulated entities × 3 hours × $119.94\], with a low estimated total of $437,205,288 \[= 1,822,600 regulated entities × 2 hours × $119.94\] and high estimated total of $2,186,026,440 \[= 1,822,600 regulated entities × 10 hours × $119.94\].
#### i. Costs Arising From Reporting Contingency Plan Activation
The Department estimates that business associates would need to notify other regulated entities in the event that they activate their contingency plan once business associate agreements are revised according to proposed 45 CFR 164.314(a)(2)(i)(D)(2)(i)(D)). The Department believes this is unlikely to occur more frequently than once per year and that the time to do so would be minimal because the proposed requirement does not specify the means or scope of such notification. The Department estimates that business associates would need an average of 30 minutes (with 15 minutes as a low estimate and 45 minutes as a high estimate) to report to other regulated entities, as applicable, when their contingency plan is activated at the wage rate of an information security analyst for a total annual cost of $59,970,000 \[= 1,000,000 business associates × 0.5 hours × $119.94\], with a low estimated total of $29,985,000\[= 1,000,000 business associates × 0.25 hours × $119.94\] and high estimated total of $89,955,000 \[= 1,000,000 business associates × 0.75 hours × $119.94\].
#### j. Revised Health Plan Documents
The Department estimates that health care insurers and third-party administrators would need to revise health plan documents to reflect that health plan sponsors that receive ePHI (that is not limited to summary health information or disenrollment information) are protecting ePHI with the administrative, physical, and technical safeguards detailed in the Security Rule, as proposed. These 6,162 entities collectively would be responsible for updating approximately 742,411 health plan documents at the wage rate of a compensation and benefits manager. The Department's estimate assumes that on average each plan document requires 30 minutes to update for a total estimated cost of $53,876,766 \[1742,411 × 0.5 hours × $145.14\]. The Department has attributed these costs solely to health plans and not health plan sponsors because the health plan is the regulated entity.
#### k. Estimated Costs for Developing New or Modified Policies and Procedures
The Department anticipates that regulated entities would need to develop new or modified policies and procedures for the proposed new requirements to obtain or provide verification of business associates' compliance with the Security Rule's requirements for technical safeguards, conducting a Security Rule compliance audit, and reporting the activation of a contingency plan, as well as other proposed changes, depending on the regulated entities' existing policies and procedures. The Department estimates that the costs associated with developing such policies and procedures would be the labor of a computer and information systems manager for an average of 3.5 hours (with 2.5 hours as a low estimate and 6 hours as a high estimate, depending on the number of entities with written policies and procedures, and their degree of specificity). This would result in total annual costs of $1,108,432,416 \[= 1,822,600 regulated entities × 3.5 hours × $173.76\], with a low estimated total of $791,737,440 \[= 1,822,600 regulated entities × 2.5 hours × $173.76\] and high estimated total of $1,900,169,856 \[= 1,822,600 regulated entities × 6 hours × $173.76\]. The existing rule requires updates to policies and procedures in response to environmental or operational changes affecting the security of the ePHI, and as a result, the Department is estimating additional costs for new policies related to this proposed rule as an incremental increase.
#### l. Costs Associated With Training Workforce Members
The Department anticipates that regulated entities would be able to incorporate new content into existing Security Rule training programs and that the costs associated with doing so would be attributed to the labor of a training specialist for an estimated 2 hours for total annual costs of $252,247,840 \[= 1,822,600 regulated entities × 2 hours × $69.20\]. The low estimate for this activity is $126,123,920 \[= 1,822,600 regulated entities × 1 hour × $69.20\], and the high estimate is $378,371,760 \[= 1,822,600 regulated entities × 3 hours × $69.20\]. Many of the changes in the NPRM require the
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adoption of standard cybersecurity practices as applied specifically to address the confidentiality, integrity, and availability of ePHI, so we expect that an information security analyst would be familiar with this content. These estimated costs would address any required revisions to training for workforce members within the first year of compliance with a final rule. Any further recurring component is likely to be implemented into regularly scheduled employee training and thus would not be directly attributable to the proposals in this NPRM.
#### m. Revising Business Associate Agreements
The NPRM proposes to provide a transition period in proposed 45 CFR 164.318 for regulated entities to revise business associate agreements to comply with the proposed changes to the requirements of the Security Rule. The proposed transition period would allow regulated entities to revise existing agreements by the earlier of the contract renewal date that falls after the compliance date of a final rule, or within one year of the rule's effective date. For a large share of existing agreements, this would allow regulated entities to complete the revisions on a rolling basis according to the dates they are renewed. The Department estimates that 1,822,600 \ [964\]
business associate agreements would need to be revised if this NPRM is adopted and that, on average, the portion of this activity that results from the rule's modifications would take an hour of a lawyer's time for each regulated entity. This would result in annual costs of $309,258,768 \[= 1,822,600 regulated entities × 1 hour × $169.68\]. The Department recognizes that this estimate may not fully account for all revised business associate agreements. However, the Department believes that in some instances, one hour of time is more than would be needed. We also believe it is likely that, for some regulated entities, a professional other than a lawyer would be responsible for the revised agreements at a lower hourly wage. For some large business associates, the Department believes that a single agreement is used for most of its customers. The Department's estimates assume that most agreements would be revised within the first year and accounts for all of them within that time period. This would be considered a one-time cost; in other words, it is not carried over into future years. As with all the estimates in this NPRM, the Department invites comments about the assumptions underlying the proposed cost projections.
#### n. Plan Sponsors' Obligations
Proposed 45 CFR 164.314(b)(2)(2)) would mandate that group health plan documents require their health plan sponsors who receive ePHI that is not limited to summary health information or enrollment or disenrollment information to deploy the administrative, physical, and technical safeguards for ePHI required by the Security Rule and notify their group health plans upon activation of the plan sponsors' contingency plan. Currently, plan documents must require such health plan sponsors to have safeguards in place, but not necessarily the safeguards specified in the Security Rule.\ [965\]
The Department estimates that an additional 52.42 hours of labor would be needed for each affected health plan sponsor to bring its security safeguards for ePHI into compliance with the Security Rule standards and to notify group health plans when its contingency plan is activated, over and above the actions attributable to safeguards already in place for ePHI and for sponsors' electronic information systems generally. The Security Rule compliance activities attributed to group health plan sponsors are shown in table 7, below.
Most compliance activities would be performed by a workforce member at the hourly wage rate of an information security analyst ($119.94), while documentation of maintenance would be performed at the rate of a management analyst ($111.08) and notification of termination or change of workforce members' access to ePHI would be performed by an office administrative assistant ($46.10). This would result in estimated total first year costs for health plan sponsors of $4,658,781,219 as shown in detail in table 7.
#### o. Total Quantifiable Costs
The Department summarizes in tables 6 and 7 the estimated costs that regulated entities (approximately $4,655 million) and plan sponsors (approximately $4,659 million), respectively, would experience in the first year of implementing the proposed regulatory changes. The Department anticipates that these costs would be for the following activities: conducting a Security Rule compliance audit; obtaining verification of business associates' and subcontractors' compliance with technical safeguards; providing verification of business associates' compliance with technical safeguards; providing notification of termination or change of workforce members' access to ePHI; deploying MFA and penetration testing; segmenting networks; disabling unused ports; removing extraneous software; notifying covered entities or business associates, as applicable, upon activation of a contingency plan; and updating health plan documents, policies and procedures, workforce training, and business associate agreements. These costs would also include health plan sponsors deploying safeguards for their relevant electronic information systems to meet Security Rule standards and notifying group health plans upon activation of a plan sponsor's contingency plan.
Compliance activities Burden hours<br> × frequency Respondents Wage rate Total annual<br> cost <br> (millions)
--- --- --- --- ---
Security Rule Compliance Audit 2 × 1 1,822,600 Regulated Entities $119.94 $437
BA Verification of Technical Safeguards 2 × 1 1,000,000 Business Associates 119.94 240
Obtain BA Compliance Verification .5 × 1 822,600 Covered Entities 119.94 49
Obtain Subcontractors' Compliance Verification .083 × 1 1,000,000 Business Associates 119.94 10
Notification of Workforce Members' Termination of access to ePHI 1 × 1 1,822,600 Regulated Entities 46.10 84
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Multi-factor Authentication 1.5 × 1 1,822,600 Regulated Entities $119.94 $328
Network Segmentation 4.5 × 1 1,822,600 Regulated Entities 119.94 984
Configuration Management .5 × 1 1,395,396 Regulated Entities 119.94 84
Penetration Testing 3 × 1 1,822,600 Regulated Entities 119.94 656
Notification of Contingency Plan Activation .5 × 1 1,000,000 Business Associates 119.94 60
Update Health Plan Documents .5 × 120 3,102,851 Health Plan Documents 145.14 54
Update Policies and Procedures 3.5 × 1 1,822,600 Regulated Entities 173.76 1,108
Update Workforce Training 2 × 1 1,822,600 Regulated Entities 69.20 252
Revise Business Associate Agreements 1 × 1 1,822,600 Regulated Entities 169.68 309
Total Annual Cost Burden 4,655
a<br> These represent first year estimated costs and are rounded.
Table 6—First Year Cost Estimates for Regulated Entities' Proposed Compliance Obligations
The Department presents the estimated cost of health plan sponsors' compliance with the proposed new requirements in table 7 below.
Compliance activities Burden hours × frequency Respondents Wage rate Total annual cost<br> (millions)
--- --- --- --- ---
Risk Analysis—Documentation 5 × 1 742,411 Plan Sponsors $119.94 $445
Information System Activity Review—Documentation .75 × 12 742,411 Plan Sponsors 119.94 801
Ongoing Education .17 × 12 742,411 Plan Sponsors 119.94 178
Security Incidents (other than breaches)—Documentation 2 × 12 742,411 Plan Sponsors 119.94 2,137
Contingency Plan—Testing and Revision 2 × 1 742,411 Plan Sponsors 119.94 178
Contingency Plan—Criticality Analysis .5 × 1 742,411 Plan Sponsors 119.94 45
Notification of Workforce Members' Termination of ePHI Access .25 × 1 742,411 Plan Sponsors 46.10 9
Maintenance Records .5 × 12 742,411 Plan Sponsors 111.08 495
Multi-factor Authentication 1.5 × 1 742,411 Plan Sponsors 119.94 133
Configuration Management .5 × 1 742,411 Plan Sponsors 119.94 45
Penetration Testing 2 × 1 742,411 Plan Sponsors 119.94 178
Notification of Contingency Plan Activation .17 × 1 742,411 Plan Sponsors 119.94 15
Total Annual Cost Burden 4,659
a<br> These represent first year estimated costs and are rounded.
Table 7—First Year Cost Estimates of Health Plan Sponsors' Proposed Compliance Obligations
Together, regulated entities' and affected health plan sponsors' estimated first year costs of compliance with the proposals in the NPRM would be approximately 9,314 million (or $9 billion).
#### p. Costs Borne by the Department
The covered entities that are operated by the Department would be affected by the changes in a similar manner to other covered entities, and such costs have been factored into the estimates above. The Department has not identified other costs to the Department related to the changes in the NPRM. A reduction in the number of large breaches (affecting 500 or more individuals per incident) would benefit the Department by enabling it to focus its resources on a smaller number of breach investigations, and potentially resolve such investigations more quickly.
#### 4\. Benefits of the Proposed Rule
#### a. Quantitative Analysis of Benefits
A key goal of strengthening the cybersecurity posture of regulated entities is to reduce the number and severity of security incidents, including breaches of ePHI. The Department believes that compliance with the proposed changes, which align with industry guidelines and best practices, would benefit regulated entities by reducing the cost of breaches. Although the costs of implementing the proposed cybersecurity measures would be significant, the costs of responding to breaches of ePHI are much higher. According to industry data, the average cost of a health care breach in 2023 rose to $10.93 million, the highest among all industries studied,\ [966\]
and the per record cost of a breach involving personally identifiable information (across all industries) was $183.\ [967\]
These costs include detection and investigation activities, notification activities, post-breach response activities, and activities attempting to minimize the loss of business. Thus, the benefits of the proposed rule would be to reduce the harms of health care breaches described in the preamble. The Department believes that implementing the changes in the NPRM would reduce both the incidence of breaches in health care and the costs of mitigating breaches when they occur.
The Department also analyzed the potential cost savings of proposals that
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correspond to major factors affecting the costs of large breaches as identified in published reports.\ [968\]
The Department estimates that, at a minimum, performing the following actions would quantifiably reduce costs: (1) encryption; (2) penetration testing; (3) requiring MFA and notification of termination of access to ePHI; (4) increasing employee training; and (5) reducing noncompliance with regulations. These factors would account for an estimated 23.6 percent decrease in large breach costs.\ [969\]
For health care breaches, this corresponds to an estimated cost savings of $2.6 million per large breach in high incidence years, and $2.1 million per large breach in low incidence years.
#### Non-Quantitative Analysis of Benefits
A fundamental benefit of the proposed rule would be to decrease the effects of breaches on individuals who are the subjects of ePHI, namely patients and health plan members. Breaches of ePHI may cause harm to individuals in many ways, including loss of reputation and personal dignity and financial and medical fraud, which may result in false debts, impaired credit, and even health threats from misuse of health insurance credentials by another individual. “\[H\]ealthcare data, which includes medical histories and personal identification, can last a lifetime. The information collected can be used for ransom, to commit tax frauds, to provide supporting disability documentation, to send fake bills to insurance providers, to obtain healthcare, prescription drugs, medical treatment, and to obtain government benefits like Medicare and Medicaid.” \ [970\]
Hackers can use stolen personal, medical, and financial data to take out a bank loan in the victim's name and change direct deposit information in payroll systems, allowing them to steal wages as well.\ [971\]
In addition, medical identity fraud can impact the victim's credit score and health insurance premiums, and may result in unexpected legal fees.\ [972\]
Medical identity fraud also enables thieves to obtain medical treatment using the victim's stolen ePHI. This can lead to the thief's medical conditions being incorporated into the victim's medical records and impacting the victim's ability to receive appropriate medical treatment based on accurate records in the future, or any care at all depending on whether the thief has exhausted the victim's insurance benefits.\ [973\]
Overall, recovering compromised ePHI and addressing the consequences of breached information can be a long and arduous process that can cost victims large amounts of time, energy, and money.\ [974\]
Breaches of ePHI maintained by health care systems can also pose a threat to the medical well-being of affected individuals. Cyberattacks on health care organizations can include the deployment of malware that compromises the function of both internal and external medical devices. Such software can alter the dosages of sensitive medicines or shut down devices while they are in use, thus affecting patient care.\ [975\]
Some of the medical devices that are vulnerable to malicious software attacks include insulin pumps and cardiac implant devices.\ [976\]
The consequences of a cyberattack on such a medical device can be fatal.
Cyberattacks on relevant electronic information systems also hinder the efficiency of hospitals and limit the quality of care provided to patients. Breaches of relevant electronic information systems negatively affect the routine functions of health care organizations. They can affect the availability of ePHI and relevant electronic information systems and redirect critical resources from patient care to addressing the cybersecurity attack. A 2020 cyberattack on a large covered entity disrupted communication and clinician access to medical records, including to individualized chemotherapy plan templates and tools for communicating during treatment preparation and delivery.\ [977\]
In the first week following the attack, the hospital's ability to provide critical outpatient care was reduced by 40 percent and infusion visit volume decreased by 52 percent. Many patients had to be transferred to other sites to minimize delays in receiving critical medications. The effects of this data breach are not unique to this provider. There is evidence that cyberattacks on health care organizations decrease the number of patients they are able to treat in a given day and staff utilization.\ [978\]
Decreases in efficiency and number of treated patients also cause health care facilities to lose revenue because of their inability to provide care during a cybersecurity event.
Similar to the effects of breaches of ePHI on individuals, health care organizations and facilities also experience reputational and financial impacts because of cybersecurity attacks. Hospitals can lose the community's trust and be subject to lawsuits from individuals whose data was compromised.\ [979\]
Organizations that experience cybersecurity attacks can experience reputational harm and other monetary costs, such as those associated with providing breach notifications, paying fines to regulators and damages to individuals, and providing credit monitoring and identity theft-related services.\ [980\]
The harm to an organization's reputation is difficult to quantify, but it can also affect the quality of care administered to individuals.\ [981\]
Privacy and security of ePHI are paramount to individuals feeling safe and at ease sharing their IIHI with clinicians. Security breaches can negatively impact a patient's confidence in a health care organization if they believe their information and privacy may be compromised. This can cause them to delay seeking treatment or
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withhold information from health care practitioners, ultimately compromising the decision-making capacity of their health care provider to administer the best quality of care.\ [982\]
Decreasing the number and scope of health care breaches would reduce the harms of such breaches and would be a significant benefit of the proposals in the NPRM.
#### 5\. Comparison of Benefits and Costs
Key inputs to the estimation of costs of this proposed rule include the numbers of regulated entities and health plan sponsors. The Department has not previously quantified the costs of Security Rule compliance for health plan sponsors because the existing requirements are for plan documents to require such sponsors to implement administrative, physical, and technical safeguards, but not necessarily to comply with the specific requirements of the Security Rule. Therefore, the proposed requirement to comply with the proposed changes to the Security Rule, along with the number of affected plan sponsors (approximately 740,000), results in a significant increase in overall cost estimates compared to the existing rule. The benefits of improved security for ePHI accrue to individuals, regulated entities, and health plan sponsors and are significant. The Department has discussed the benefits above.
The Department seeks to reduce the risk and mitigate the effects of breaches of ePHI and related information systems through the proposals included in this NPRM. Because the frequency and magnitude of cybersecurity events are inherently difficult to predict, we chose to conduct a break-even analysis in lieu of a cost savings analysis. The Department solicits comments with any information and data on the incidence and negative consequences of cybersecurity breaches.
Department examined two different data points: the annual number of individuals affected by health care breaches, and the annual number of large breaches. Additionally, the Department considered a high and a low baseline based on the number of breaches and affected individuals per year. The Department calculated the high baseline as the average of the three highest values in the 6 years of available data (2018 to 2023, shown in table 8), and the low baseline as the average of the three lowest values.
Breach years Affected individuals<br> <br> for large breaches a Cost b<br> per record 983
--- --- ---
2018 12,493,549 $488
2019 38,732,966 504
2020 37,641,403 476
2021 37,182,558 502
2022 41,747,613 477
2023 113,173,613 463
Number of large breaches<br> (500+ individuals) Cost per breach
2018 302 12,012,809
2019 408 7,582,508
2020 656 8,273,537
2021 609 10,241,897
2022 626 10,468,138
2023 725 10,930,000
a<br> The numbers of affected individuals and numbers of large breaches are contained in the Reports to Congress on Breaches of Unsecured Protected Health Information for years 2018-2022, <br> _https://www.hhs.gov/hipaa/for-professionals/compliance-enforcement/reports-congress/index.html._<br> Data for 2023 is contained in OCR's breach portal, “Breach Portal: Notice to the Secretary of HHS Breach of Unsecured Protected Health Information,” Office for Civil Rights, U.S. Department of Health and Human Services, <br> _https://ocrportal.hhs.gov/ocr/breach/breach\_report.jsf._
b<br> The cost per record and cost per breach are based on estimates for health care breaches from the annual IBM Security and Ponemon Institute Costs of a Data Breach Reports for years 2018-2023. <br> _See_<br> “Cost of a Data Breach Report 2023,” IBM Security, p. 10, 13 (July 24, 2023), <br> _available at https://www.ibm.com/reports/data-breach._<br> Because only general breach costs were available for the 2020-2023 period, the Department adjusted those by multiplying them by the average of the ratios of health care-specific to overall breach costs for the years for which both data points were available (2018, $408/$148 and 2019, $429/$150). All dollar values were converted to 2023 dollars using the seasonally adjusted GDP Implicit Price Deflator, <br> _https://fred.stlouisfed.org/series/GDPDEF/._
Table 8—Data on Breaches of
The high baseline used 669 breaches and a total of 71 million individuals affected, and the low baseline used 440 breaches and 29 million individuals affected.\ [984\]
The high baseline represents years with higher incidence of breaches, whereas the low baseline represents years with lower incidence.
For each data point, the Department calculated the number of breaches or affected individuals by which the affected universe would have to decrease for the proposed rule to fully offset the annualized costs of regulated entities.\ [985\]
Table 9 and the discussion that follows analyses the costs and cost savings based on the number of individuals affected by breaches in a year and the cost per individual's ePHI or medical record.
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Baseline Affected<br> individuals Regulated<br> entities NPRM <br> costs Unit cost<br> (per individual <br> record) Break-even<br> threshold <br> (NPRM cost ÷ <br> unit cost) Percent<br> decrease <br> (threshold ÷ <br> affected) × 100
--- --- --- --- --- ---
High 64,551,397 $2,251,258,305 $498 4,521,423 7
Low 29,006,854 16.4
Table 9—Break-Even Thresholds by Number of Affected Individuals
The analysis in table 9 suggests that this NPRM would break even (cost savings would match monetized costs incurred) if the number of affected individuals is reduced by approximately 4.5 million. In years with a high incidence of breaches, this would be a reduction of approximately 7 percent, and in low-incidence years this would be a decrease of 16.4 percent. Thus, if the proposed changes in the NPRM reduce the number of affected individuals by 7 to 16 percent, the rule would pay for itself. Alternatively, the same cost savings may be achieved by lowering the cost per affected individual's ePHI by 7 percent ($35) and 16 percent ($82), respectively.
Table 10 analyzes the potential cost savings for regulated entities based on the annual number of large breaches of ePHI and the cost per breach, as shown below.
Baseline Breaches NPRM cost for<br> regulated <br> entities Unit cost<br> (per breach) Break-even<br> threshold <br> (NPRM cost ÷ <br> unit cost) Percent<br> decrease <br> (threshold ÷ <br> breaches) × 100
--- --- --- --- --- ---
High 669 $2,251,258,305 $11,136,982 202 30.1
Low 440 58.9
Table 10—Break-Even Thresholds by Number of Large Breaches
In table 10, the Department assumes that the average cost per breach in industry reports ($11.1 million, calculated as the average of the three highest values in table 9, adjusted for inflation) refers to large breaches of ePHI . The analysis in table 10 suggests that the NPRM would break even if the annual number of large breaches is reduced by approximately 202. In high-incidence years, this would be a reduction of approximately 30 percent, and in low-incidence years, this would be a decrease of 59 percent. Alternatively, the same cost savings may be achieved by lowering the cost per breach by 30 percent ($3.4 million) and 9 percent ($6.6 million), respectively.
### B. Regulatory Alternatives to the Proposed Rule
The Department welcomes public comment on any benefits or drawbacks of the following alternatives it considered, but did not propose, while developing this proposed rule. We also request comment on whether the Department should reconsider any of the alternatives considered, and if so, why.
#### No Changes to the Security Rule
We considered not proposing revisions to the Security Rule. However, the Department believes that not revising the Security Rule would result in continued increases in both the number and size of breaches. Such increases would result in an exponential increase in costs as shown in table 8 above. If the modifications to the Security Rule result in even modest improvements to the security of ePHI, the reduction in the number and/or size of breaches would reduce the overall costs associated with breaches, including the costs of mitigating harm resulting from such breaches.
#### Email Security
The Department considered proposing a separate standard for regulated entities to secure email transmissions. In the Department's Cybersecurity Performance Goals,\ [986\]
the Department identifies email security as an essential goal for reducing risk from common email-based threats such as email spoofing, phishing, and fraud. Therein, the Department points to basic email protection controls identified in the Health Industry Cybersecurity Practices, such as spam/virus checking and real-time deny lists, as well as strategies that may be deployed across small, medium, and large organizations, including MFA for email access, email encryption, workforce education, and advance tooling (
_e.g.,_
URL click protection via analytics, attachment sandboxing).\ [987\]
The Department is aware of the threat that email poses to the information systems of regulated entities and to the confidentiality, integrity, and availability of ePHI.\ [988\]
However, the Department believes that it is important that the Security Rule remain technology-neutral and that the security measures we propose in this NPRM apply to a regulated entity's information systems broadly, including email programs. For example, in this NPRM, the Department proposes to require regulated entities to encrypt all ePHI at rest and in transit and proposes a transmission security standard in which regulated entities would be required to deploy technical controls to guard against unauthorized access to ePHI that is being transmitted over an electronic communications network.\ [989\]
Therefore, the Department believes it is unnecessary to promulgate a separate standard for email security. Because the other technical controls, such as encryption and MFA, are already incorporated into the requirements that would protect relevant electronic information systems, the Department believes that adopting a separate secure email standard would duplicate costs without creating a net benefit.
( printed page 1005)
Additionally, the Department considered whether to heighten the existing expectation \ [990\]
for regulated entities to inform individuals before transmitting ePHI to the individual via unencrypted email in response to a request for access under 45 CFR 164.524 by this means. We considered whether to require such notification for different types of requests, such as different categories of PHI (
_e.g.,_
billing, lab results, etc.), determining whether the individual had already received such notice, or providing notification upon each disclosure. Instead, the Department has proposed to clarify that notification must be provided for each request made by the individual under the individual right of access at 45 CFR 164.524 for their ePHI to be transmitted via unsecure email. We believe that requiring a regulated entity to determine whether the individual had already received such notification would be more burdensome than incorporating the notification into the access request process, and instead, have proposed. We estimate that this could increase burdens for providing access via unsecure means by approximately one minute per request of this type. We lack data to estimate the number of requests for access via unsecure means.
#### Small and Rural Health Care Providers
Consistent with the requirement that the Secretary adopt security standards that take into account the needs and capabilities of small health care providers and rural health care providers,\ [991\]
the Department considered excepting small and rural health care providers from the requirement to perform penetration testing at proposed 45 CFR 164.308(h)(2)(iii)(2)(iii)) to lower anticipated costs of the rule for such providers. The Department estimates that approximately 90 percent of providers are small (based on revenue). Thus, the estimated cost reduction from this exemption (as compared to the proposed requirement for all regulated entities), would be approximately $266,389,139 \[822,600 × .9 × 3 hours × $119.94 wage of an information security analyst\] annually. While the Department is aware of the cost implications of this requirement for small and rural health care providers, we also believe that penetration testing is a critical component of managing vulnerability to cyberthreats across the health care sector. Additionally, we believe that setting different requirements for cybersecurity for small and rural health care providers would lead such health care providers to believe that they can limit their investment in cybersecurity. Given that a significant amount of health care is provided by small and rural health care providers, limiting their investment in cybersecurity would create a sizable gap in security protections. Such a gap has the potential to increase such providers' attractiveness to cybercriminals.
The Department also considered proposing to permit small and rural health care providers to adopt alternate compensating controls, in lieu of the specified implementation specifications, to meet certain standards. After careful consideration, the Department concluded that it potentially could be just as costly to identify and adopt compensating controls that are reasonable and appropriate for small and rural health care practices. Small and rural health care providers would likely need to either hire personnel or contract with cybersecurity experts to identify potential compensating controls that would meet the relevant standard and provide implementation support. Accordingly, the Department declines to put forward such proposals at this time.
#### The Federal Information Security Modernization Act
The Department considered the requirements of the Federal Information Security Modernization Act (FISMA) \ [992\]
and whether compliance with FISMA by Federal agencies that are also regulated entities would be comparable to meeting the proposals in this NPRM. FISMA requires each Federal agency to develop, document, and implement an agency-wide program to provide information security for the information and information systems that support the operations and assets of the agency, including those provided or managed by another agency, contractor, or other source.\ [993\]
After careful consideration, the Department does not believe that a regulated entity's compliance with FISMA would necessarily ensure compliance with all applicable proposed requirements in this NPRM because FISMA's requirements and the Security Rule's requirements are designed to serve different purposes. FISMA primarily focuses on securing Federal information systems, while the Security Rule applies specifically to ePHI. This NPRM contains specific proposed requirements, not found in FISMA, which are tailored to ensure the confidentiality, integrity, and availability of ePHI. Therefore, although the Department believes that FISMA requirements are consistent with those in the Security Rule and the proposals in this NPRM, we decline to propose that compliance with FISMA requirements would be a comparable alternative to compliance with the proposals in this NPRM. Instead, we believe that FISMA requirements complement the Security Rule and the proposed requirements and will facilitate the ability of regulated entities that are also subject to FISMA to fulfill their compliance with the HIPAA Rules.
#### Modifications to the Definition of “Information System”
The Department considered proposing additional modifications to the definition of “information system.” The Security Rule currently defines the term “information system” as an interconnected set of information resources under the same direct management control that shares common functionality and includes hardware, software, information, data, applications, communications, and people.\ [994\]
This definition is based on the definition of “general support system” or “system” in the appendix to the 1996 version of OMB Circular A-130, Security of Federal Automated Information Systems.\ [995\]
We considered proposing to remove the phrase “under the same direct management control” as a potential way to clarify the application of the definition to cloud-based computing. Cloud computing applications play an important role in health care today. For example, many health care providers have implemented cloud-based electronic health records (EHRs) and practice management systems. These applications are used to create, receive, maintain, and transmit ePHI, and as such, should be included as components of a covered entity's relevant electronic information system, a term which is based upon the term “information system.” After careful consideration, we have decided to retain the phrase “under the same direct
( printed page 1006)
management control” and instead clarify in the preamble how the definition of “information system” applies in cloud computing environments. The Department also requests comment on the definition of “information system” and the extent of control a regulated entity has with respect to applications in cloud computing environments.
We also considered proposing to adopt the definition of “information system” in the Paperwork Reduction Act of 1995 (PRA) and the current operative version of OMB Circular A-130.\ [996\]
The PRA and OMB Circular A-130 define “information system” as “a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information.” The Department declined to adopt this definition because the existing definition in the Security Rule based on the definition of “system” in the 1996 version of OMB Circular A-130 more accurately reflects the typical components of an information system and the full extent of resources that are addressed by the Security Rule. Additionally, the definition of “information system” in the PRA and current operative version of OMB Circular A-130 contains some terms that are defined by the HIPAA Rules and some that are not. As a result, adopting this definition would require the Department to propose definitions to such additional terms and to ensure that the manner in which the terms with existing definitions are used is consistent with those existing definitions, and we are concerned that such change could cause significant confusion for regulated entities.
We do not believe that either of the alternative definitions considered would have generated a quantifiable change in costs because the alternatives would be clarifications to existing requirements and would not have changed the scope of the Security Rule's applicability.
#### Exception From Multi-Factor Authentication (MFA) Requirement
The Department considered proposing an exception to the MFA authentication requirement that would permit regulated entities in the future to adopt other technologies, in lieu of MFA, that might offer a more secure method of authenticating user identity.\ [997\]
Based on discussions with cybersecurity experts, the Department believes that MFA is likely to remain the most secure method for authenticating user identity in future years. It may take different forms, but it will still, at its core, meet the definition of MFA proposed in this NPRM for the foreseeable future.\ [998\]
While the Department acknowledges that technology will continue to evolve, we are unable to predict when and whether future technology will address identity verification and exceed the level of protection offered by MFA. This uncertainty renders us unable to articulate requirements specific enough to justify a purposeful exception. Because of the uncertainty surrounding new technologies, we are also unable to estimate costs of adopting this alternative. Our current view is that proposing and codifying such an exception would be premature, but we will revisit the proposed specific requirement for MFA, if adopted, and reconsider the need for an exception should a more secure technology emerge.
#### Transition for Business Associates and Group Health Plans
The Department considered requiring regulated entities to comply with all of the proposals in this NPRM by the compliance date, rather than proposing transition provisions for existing business associate agreements or other contractual arrangements. Had the Department taken that approach, we would have proposed that regulated entities update all existing business associate agreements by the proposed compliance date to comply with all applicable proposed requirements in this NPRM. While the Department believes that many of the proposals in this NPRM are consistent with the Security Rule as it currently exists, we are also concerned that too many regulated entities are not currently compliant with the Security Rule. Given the demonstrable increase in breaches, we believe that it is more important for regulated entities to first improve their cybersecurity posture by coming into compliance with all applicable proposed requirements in this NPRM, if adopted. Upon doing so, the Department anticipates that regulated entities will be better positioned to evaluate their contractual needs and to modify existing business associate agreements. For this reason, the Department has proposed the transition provisions in proposed 45 CFR 164.318. Not allowing for a transition period could have an opportunity cost whereby regulated entities spend their limited time revising business associate agreements instead of enhancing their cybersecurity posture. The Department believes that this could result in duplicative costs because some regulated entities may identify the need for additional changes to business associate agreements after they have fully evaluated their changed cybersecurity needs. The Department estimates that small regulated entities may be more likely to experience that outcome without a transition period, and thus the alternative of no transition period would cause a potential one-time increase in costs of $278,332,891 \[(1,822,600 regulated entities × .9) × 1 hour × $169.68 lawyer hourly wage\].
Relatedly, the Department considered proposing similar transition provisions for group health plans and plan sponsors that would provide these entities with additional time to update plan documents to align with new proposed requirements in this NPRM, if adopted. However, the Department believes that affected plans and plan sponsors would be able to complete any necessary updates by the proposed compliance date. The Department believes that updating plan documents is not as complex a task as evaluating potential new contractual needs to meet business associate obligations. Additionally, plan sponsors do not have Security Rule obligations independent of plan documents, and thus would not be obligated to implement the requirements proposed in this NPRM absent updates to the plan documents. The result of a transition period for updating plan documents would be merely to delay compliance with the changed Security Rule requirements, and therefore, delay improvements to their cybersecurity posture, not to reduce costs. Accordingly, we are not proposing such transition provisions in this NPRM.
### C. Regulatory Flexibility Act—Small Entity Analysis
The Department has examined the economic implications of this proposed rule as required by the RFA. If a rule has a significant economic impact on a substantial number of small entities, the RFA requires agencies to analyze regulatory options that would reduce the economic effect of the rule on small entities. As discussed in greater detail below, this analysis concludes, and the Secretary proposes to certify, that the proposed rule, if finalized, would not
( printed page 1007)
result in a significant economic effect on a substantial number of small entities.
For purposes of the RFA, small entities include small businesses, nonprofit organizations, and small governmental jurisdictions. The Act defines “small entities” as (1) a proprietary firm meeting the size standards of the SBA, (2) a nonprofit organization that is not dominant in its field, and (3) a small government jurisdiction of less than 50,000 population. The Department has determined that roughly 90 percent or more of all health care providers meet the SBA size standard for a small business as shown in table 4 or are a nonprofit organization. Therefore, the Department estimates that there would be 740,348 small entities affected by the proposals in this proposed rule.\ [999\]
The SBA size standard for health care providers ranges between a maximum of $9 million and $47 million in annual receipts, depending upon the type of entity, as shown in table 4, above.\ [1000\]
With respect to health insurers, the SBA size standard is a maximum of $47 million in annual receipts, and for pharmacy benefits and clearinghouses it is $45.5 million.\ [1001\]
While some insurers are classified as nonprofit, it is possible they are dominant in their market. For example, a number of Blue Cross/Blue Shield insurers are organized as nonprofit entities; and yet, they dominate the health insurance market in the States where they are licensed.\ [1002\]
With respect to business associates, they provide a wide range of services for covered entities, including computer infrastructure, clearinghouse activities, leased office equipment, and professional services, such as legal, accounting, business planning, and marketing. The SBA size thresholds for these industries ranges from $15.5 million for lawyers to $47 million for clearinghouses.\ [1003\]
For the reasons stated below, the Department does not expect that the cost of compliance would be significant for small entities. Nor does the Department expect that the cost of compliance would fall disproportionately on small entities. Although many of the regulated entities affected by the proposals in this proposed rule are small entities, they would not bear a disproportionate cost burden compared to the other entities subject to the rule. The projected total costs are discussed in detail in the RIA. The Department does not view this as a substantial burden because the result of the changes would be annualized costs per regulated entity of approximately $1,235 \= $2.3 billion \[ [1004\]\
/1,822,600 regulated entities\]. The per-entity costs represent the costs per establishment. As a result, smaller entities' costs are lower because they have fewer establishments. Larger regulated entities (
_i.e.,_
firms) that have multiple facilities (
_i.e.,_
establishments) would experience higher costs than the average cost per establishment because each firm would need to apply the proposals to all of their establishments. In the context of the RFA, HHS generally considers an economic impact exceeding 3 percent of annual revenue to be significant, and 5 percent or more of the affected small entities within an identified industry to represent a substantial number.
More than 5 percent of the small covered entities listed under the NAICS codes in table 4 are one-establishment firms with fewer than five employees,\ [1005\]
so the analysis must determine how the effects of the quantified costs on one-establishment firms compare to their revenues. As explained above, the cost for a one-establishment firm is $1,235, so only small firms whose revenues are below $41,167 \[=$1,235/0.03\] would experience an effect exceeding 3 percent.
Among the NAICS codes for health care providers, the small firms with the lowest revenues are one-establishment HMO \[Health Maintenance Organization\] Medical Centers (NAICS 621491) with fewer than five employees, which had an estimated average yearly revenue in 2021 of $108,000. Residential Intellectual and Developmental Disability Facilities (NAICS 623210) had the second lowest revenues for one-establishment firms with fewer than five employees, with $180,000. Offices of Mental Health Practitioners (NAICS 621330) have the third lowest revenues for one-establishment firms with fewer than five employees, with $189,000. Thus, the Department believes that almost all regulated entities have annual revenues that exceed these amounts.
The Department acknowledges that there may be very small firms—namely firms without employees—whose revenues are below $41,167. We believe that such firms would comply with the regulation by purchasing services from software and web-hosting companies whose costs may increase as a result of the proposed changes. Such software and web-hosting companies would be business associates, and thus costs to them are already accounted for. We believe that, to the extent that these business associates decide to recover their minor cost increases by raising the prices of the services sold to non-employer firms, these incremental costs passed through to their small-firm customers would be negligible because they will be spread among many non-employer firms.
The Department has separately analyzed the effects of the NPRM on health plan sponsors and does not view the projected costs as a significant burden because the proposed changes would result in annualized costs per plan sponsor of approximately $6,133 \[=$4,552,995,816/742,411 health plan sponsors\]. The quantified impact of $6,133 per health plan sponsor would only apply to those sponsors whose annual revenue is $204,433 or less.\ [1006\]
The Department believes there are few, if any, group health plan sponsors with annual revenues below this amount because the average revenue of a U.S. business with 1-4 employees is $387,000 \ [1007\]
and employers with 0-1 employees are unlikely to sponsor a group health plan.
Accordingly, the Department believes that this proposed rule, if adopted, would be unlikely to affect a substantial
( printed page 1008)
number of small entities that meet the RFA threshold. Thus, this analysis concludes, and the Secretary proposes to certify, that the NPRM would not result in a significant economic effect on a substantial number of small entities.
HIPAA requires the Department to consider the needs and capabilities of small and rural health care providers.\ [1008\]
As we explained in our 2003 analysis of the effect of the Security Rule on small and rural health care providers, the scalability provisions preclude the need to precisely define those categories.\ [1009\]
We have long considered the effect of our rules on small businesses in the Small Entity Analysis discussed above. However, because of the breadth of changes proposed in this NPRM, the Department has considered more closely how it would affect rural health care providers. There are approximately 2,000 rural hospitals,\ [1010\]
comprising nearly 30 percent of all hospitals \[= 2,057/7,465\],\ [1011\]
and the Department estimates approximately 7 to 8 percent of all health care providers operate in rural areas (counties or micropolitan areas with fewer than 50,000 inhabitants). See Regulated Entities Affected in Section V.A.2. Baseline Conditions, above.
Because rural health care providers are more likely to be small businesses, they would be affected in a manner similar to small entities, as demonstrated in the Small Entity Analysis above. Likewise, to the extent that Tribal health care providers are in rural areas, which many are,\ [1012\]
our analysis of the effects on rural health care providers generally also applies. However, Tribal health providers have the benefit of access to centralized supportive services for health IT and EHR adoption, which other rural providers may lack.\ [1013\]
A primary barrier to both adoption of health information technology (health IT) and deployment of cybersecurity safeguards in rural communities is limited access to high-speed internet. Rural health care providers, such as hospitals, have adopted EHRs at a lower rate than non-rural hospitals,\ [1014\]
and thus may also have fewer electronic information systems that are subject to the Security Rule requirements, which could ease some burdens of compliance. However, as EHR adoption has increased in rural hospitals,\ [1015\]
so too have the risks of cybersecurity attacks.\ [1016\]
Rural health care providers are more likely to have limited resources to update legacy information technology (IT) systems, implement new or changed regulatory requirements, and respond to large breaches. Additionally, the health IT workforce is more limited in rural areas, which may affect the ability of rural health care providers to access in-person technical assistance. Because most rural hospitals are “located more than 35 miles from another hospital,” responding to cyberattacks may be more challenging.\ [1017\]
We request comment on the burdens these proposals would impose on rural health care providers, including rural hospitals.
Rural health care providers and other regulated entities can avail themselves of grants and incentives to improve broadband access and adoption of health IT.\ [1018\]
For cybersecurity in particular, the White House, in partnership with private companies, announced the availability of direct assistance to rural health care providers on cybersecurity in the form of grants, discounts, and technical advice.\ [1019\]
Additionally, CISA has compiled a list of free services and tools available to regulated entities from private and public sector entities. CISA also has published, in partnership with the Joint Cyber Defense Collaborative, a list of cybersecurity resources especially focused on high-risk communities.\ [1020\]
And the Advanced Research Projects Agency for Health announced plans to invest $50 million to develop an autonomous solution for addressing cyberthreats to assist hospitals in defending their information systems.\ [1021\]
Cybersecurity is as essential for small and rural health care providers and their business associates, as it is for large and urban regulated entities. The seamless flow of data and increased connectivity means that threats to one health care provider do not affect only that one health care provider, regardless of size or location. The effects on patient care may be greater in rural environments where fewer alternatives exist if care is delayed or denied as a result of a cyberattack or malfunction.\ [1022\]
As discussed in the preamble, the factors described at 45 CFR 164.306(b)(2)(2)) provide the flexibility for small and rural providers, in particular, to adopt security measures that are reasonable and appropriate for their circumstances.
### D. Executive Order 13132—Federalism
As required by E.O. 13132 on Federalism,\ [1023\]
the Department has examined the provisions in the proposed regulation for their effects on the relationship between the Federal Government and the States. E.O. 13132 establishes certain requirements that an agency must meet when it promulgates a proposed rule (and subsequent final rule) that imposes substantial direct requirement costs on State and local governments, preempts State law, or otherwise has federalism implications. In the Department's view, the proposed rule would not have any federalism implications.
The federalism implications of the Security Rule were also assessed as required by E.O. 13132 and published as part of the preambles to the final rules on February 20, 2003 \ [1024\]
and January
( printed page 1009)
25, 2013.\ [1025\]
Regarding preemption, HIPAA dictates the relationship between State law and HIPAA regulatory requirements.\ [1026\]
The Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act) provides that the HIPAA preemption provisions shall apply to the HITECH Act provisions and requirements.\ [1027\]
As explained by the House report that accompanied the American Recovery and Reinvestment Act of 2009, the HITECH Act would not only apply HIPAA's preemption provisions to the HITECH Act requirements, but it would also “preserve the HIPAA privacy and security standards to the extent that they are consistent with” the HITECH Act.\ [1028\]
A requirement, standard, or implementation specification adopted in accordance with HIPAA and the HIPAA Rules supersedes any contrary provision of State law, subject to certain exceptions.\ [1029\]
Specifically, State law would be preempted under the Security Rule only when (1) a regulated entity finds it impossible to comply with both State and Federal requirements; or (2) the provision of State law stands as an obstacle to accomplishing and executing the purposes and objectives of the Administrative Simplification provisions or the HITECH Act.\ [1030\]
Although a few States (
_e.g.,_
California and New York) have promulgated or are in the process of promulgating regulations pertaining to cybersecurity in health care that may be more stringent than the Security Rule, the Department believes that a regulated entity could comply with both sets of requirements by adhering to the more stringent standard. Thus, in such cases, the State law would not be an obstacle to the accomplishment and execution of HIPAA or the HITECH Act.
The proposed modifications to the Security Rule would further the Congressional intent to improve the Medicare and Medicaid programs by the development of health information systems that are private and secure. The Department's proposals promote the safety, efficiency, and effectiveness of the health care system by refining the security standards established by Congress and implemented in the 2003 and 2013 Final Rules. The statute contemplated that the security measures adopted by all regulated entities, including State and local governments, would evolve over time in accordance with the security risks they face, and the NPRM proposals are in the nature of enhancing these existing requirements. Thus, the Department does not believe that the rule would impose substantial direct compliance costs on State and local governments that are not required by statute.
The Department anticipates that the most significant direct costs on State and local governments would be for conducting a Security Rule compliance audit; notifying covered entities or business associates, as applicable, upon activation of a contingency plan; notifying covered entities of changes or termination of workforce members' access to ePHI; deploying MFA; removing extraneous software; and penetration testing; providing or obtaining verification of business associates' compliance with technical safeguards; updating health plan documents; updating policies and procedures; and updating workforce training. However, the costs involved can be attributed to the statutory requirements of the Administrative Simplification provisions of HIPAA and would be similar in kind to those borne by non-government-operated regulated entities, which the proposed RIA above addresses in detail.
In considering the principles in and requirements of E.O. 13132, the Department believes that these proposed modifications to the Security Rule would not significantly affect the rights, roles, and responsibilities of the States and requests comment on this analysis.
### E. Assessment of Federal Regulation and Policies on Families
Section 654 of the Treasury and General Government Appropriations Act of 1999 \ [1031\]
requires Federal departments and agencies to determine whether a proposed policy or regulation could affect family well-being. If the determination is affirmative, then the Department or agency must prepare an impact assessment to address criteria specified in the law. This proposed rule is expected to strengthen family well-being because it would ensure a baseline of security measures for individuals' PHI, and medical information and decisions based on that information are at the heart of family decision making. If finalized, the provisions in this proposed rule may be carried out only by the Federal Government because it would modify Federal law on cybersecurity in health care, ensuring that American families have confidence that the privacy of their PHI is secured by consistent safeguards, regardless of the State where they are located when health care is provided. Such health care privacy and is vital for individuals who seek or access health care.
### F. Paperwork Reduction Act of 1995
Under the PRA,\ [1032\]
agencies are required to submit to OMB for review and approval any reporting or recordkeeping requirements inherent in a proposed or final rule and are required to publish such proposed requirements for public comment. To fairly evaluate whether an information collection should be approved by the OMB, section 3506(c)(2)(A) of the PRA requires that the Department solicit comment on the following issues:
1\. Whether the information collection is necessary and useful to carry out the proper functions of the agency.
2\. The accuracy of the agency's estimate of the information collection burden.
3\. The quality, utility, and clarity of the information to be collected.
4\. Recommendations to minimize the information collection burden on the affected public, including automated collection techniques.
The PRA requires consideration of the time, effort, and financial resources necessary to meet the information collection requirements referenced in this section. The Department solicits public comments on its assumptions and burden estimates in this NPRM as summarized below.
In this RIA, the Department proposes to revise certain information collection requirements associated with this NPRM and, as such, would revise the information collection last prepared in 2024 and approved under OMB control #0945-0003.\ [1033\]
The proposed revisions to the information collection describe all new and adjusted information
( printed page 1010)
collection requirements for regulated entities pursuant to the implementing regulation for HIPAA at 45 CFR parts 160 and 164, the HIPAA Privacy, Security, Breach Notification, and Enforcement Rules (“HIPAA Rules”).
The estimated annual labor burden presented by the regulatory modifications is 77,067,552 burden hours at a first-year cost of $9,314,106,174. These figures, respectively, represent the sum of 37,781,637 new burden hours at a cost of $4,655,324,954 for compliance by regulated entities and 39,285,915 new burden hours at a cost of $4,658,781,219 for compliance by health plan sponsors.
The overall total burden for respondents to comply with the information collection requirements of all of the HIPAA Privacy, Security, and Breach Notification Rules, including new burdens presented by proposed program changes, is estimated to be 925,144,023 burden hours at a cost of $109,085,104,674, plus $163,499,411 in capital costs for a total estimated annual burden of $109,248,604,085, after the effective date of the final rule. This estimate is based on a total of 1,202,562,864 responses for a total of 2,565,011 respondents. The total burden for the HIPAA Rules, including the changes proposed in this NPRM, would result in a decrease of 28,838,213 burden hours and a cost increase of $1,911,898,144, in comparison to the baseline in the ICR associated with the 2024 Privacy Rule to Support Reproductive Health Care Privacy.\ [1034\]
This is the result of multiples changes, such as decreasing burden hours for some existing requirements, increasing the estimated number of covered entities, adding new Security Rule requirements, and expanding the pool of respondents for the Security Rule by adding requirements for health plan sponsors.
Details describing the burden analysis for the proposals associated with this RIA are presented below and explained further in the ICR associated with the NPRM.
#### 1\. Explanation of Estimated Annualized Burden Hours
Below is a summary of the significant program changes and adjustments proposed since the approved 2024 ICR; because the ICR addresses regulatory burdens associated with the full suite of HIPAA Rules, the changes and adjustments include updated data and estimates for some provisions of the HIPAA Rules that are not affected by this proposed rule. These program changes and adjustments form the bases for the burden estimates presented in the ICR associated with this NPRM.
#### Adjusted Estimated Annual Burdens of Compliance
(1) Updating the number of covered entities.
(2) Updating hourly wage rates.
(3) Adjusting downward the number of estimated requests for an exception to Federal preemption of State law to the prior baseline of 1 request per year.
(4) Adjusting downward the estimated hourly burden for regulated entities to report security incidents (not breaches) from 20 hours per monthly report to 10 hours per monthly report.
(5) Updating the number of research disclosures.
#### New Burdens Resulting From Program Changes
In addition to the adjustments above, the Department proposes to add new annual estimated burdens as a result of program changes, as follows:
(1) A burden of 2 hours for each regulated entity to conduct a Security Rule compliance audit.
(2) A burden of 2 hours for each business associate (including each subcontractor) to provide verification of compliance with technical safeguards.
(3) A burden of .5 hours for each covered entity to obtain verification of business associates' compliance with technical safeguards.
(4) A burden of .083 hours for each business associate to obtain verification of subcontractors' compliance with technical safeguards.
(5) A burden of 1 hour for each regulated entity to provide notification to other regulated entities of workforce members' termination of access to ePHI.
(6) A burden of 1.5 hours for each regulated entity to deploy MFA.
(7) A burden of 4.5 hours for each regulated entity to perform network segmentation.
(8) A burden of .5 hours for approximately 76.56 percent of regulated entities to disable unused ports and remove extraneous software.
(9) A burden of 3 hours for each regulated entity to conduct penetration testing.
(10) A burden of .5 hours for each regulated entity to notify covered entities or business associates, as applicable, upon activation of a contingency plan.
(11) A burden of .5 hours for each insurer and third-party administrator to update health plan documents.
(12) A burden of 2 hours for each regulated entity to update the content of its cybersecurity awareness and Security Rule training program.
(13) A burden of 3.5 hours for each regulated entity to update its policies and procedures.
(14) A burden of 1 hour for each regulated entity to update business associate agreements.
(15) A burden of 52.92 hours for each health plan sponsor to modify safeguards for its relevant electronic information systems to meet Security Rule standards.
# List of Subjects
### 45 CFR Part 160
- Administrative practice and procedure
- Computer technology
- Electronic information system
- Electronic transactions
- Employer benefit plan
- Group health plan
- Health
- Health care
- Health facilities
- Health insurance
- Health professions
- Health records
- Hospitals
- Investigations
- Medicaid
- Medical Research
- Medicare
- Penalties
- Preemption
- Privacy
- Public health
- Reporting and recordkeeping requirements
- Security
### 45 CFR Part 164
- Administrative practice and procedure
- Computer technology
- Drug abuse
- Electronic information system
- Electronic transactions
- Employer benefit plan
- Group health plan
- Health
- Health care
- Health facilities
- Health insurance
- Health professions
- Health records
- Hospitals
- Medicaid
- Medical research
- Medicare
- Privacy
- Public health
- Reporting and recordkeeping requirements
- Security
## Proposed Rule
For the reasons stated in the preamble, the Department of Health and Human Services proposes to amend 45 CFR subtitle A, subchapter C, parts 160 and 164 as set forth below:
# PART 160—GENERAL ADMINISTRATIVE REQUIREMENTS
1\. The authority citation for part 160 continues to read as follows:
Authority:42 U.S.C. 1302(a); 42 U.S.C. 1320d-1320d-9; sec. 264, Pub. L. 104-191, 110 Stat. 2033-2034 ( 42 U.S.C. 1320d-2 (note)); 5 U.S.C. 552; secs. 13400-13424, Pub. L. 111-5, 123 Stat. 258-279; and sec. 1104 of Pub. L. 111-148, 124 Stat. 146-154.
2\. Amend § 160.103 by revising the definition of “Electronic media” to read as follows:
§ 160.103
Definitions.
\\* \\* \\* \\* \*
_Electronic media_
means:
(1) Electronic storage material on which data may be recorded, maintained, or processed. This includes, but is not limited to, hard drives,
( printed page 1011)
removable media, magnetic tape, optical disk, and any other form of digital memory or storage.
(2) Transmission media used to exchange information already in electronic storage material. Transmission media includes, but is not limited to, the internet, extranet or intranet, leased lines, dial-up lines, private and public networks, and the physical movement of removable/transportable electronic storage material.
\\* \\* \\* \\* \*
# PART 164—SECURITY AND PRIVACY
1\. The authority citation for part 164 continues to read as follows:
Authority: 42 U.S.C. 1302(a); 42 U.S.C. 1320d-1320d-9; sec. 264, Pub. L. 104-191, 110 Stat. 2033-2034 ( 42 U.S.C. 1320d-2(note)); and secs. 13400-13424, Pub. L. 111-5, 123 Stat. 258-279.
2\. Revise and republish subpart C to read as follows:
# Subpart C—Security Standards for the Protection of Electronic Protected Health Information
164.302Applicability.164.304Definitions.164.306Security standards: General rules.164.308Administrative safeguards.164.310Physical safeguards.164.312Technical safeguards.164.314Organizational requirements.164.316Documentation requirements.164.318Transition provisions.164.320Severability.
Appendix A to Subpart C of Part 164—Security Standards: Matrix
Authority: 42 U.S.C. 1320d-2 and 1320d-4; 42 U.S.C. 17931.
§ 164.302
Applicability.
A covered entity or business associate must comply with the applicable standards, implementation specifications, and requirements of this subpart with respect to electronic protected health information of a covered entity.
§ 164.304
Definitions.
As used in this subpart, the following terms have the following meanings:
_Access_
means the ability or the means necessary to read, write, modify, delete, transmit, or communicate data/information or otherwise use any component of an information system. (This definition applies to “access” as used in this subpart, not as used in subpart D or E of this part.)
_Administrative safeguards_
are administrative actions and related policies and procedures to manage the selection, development, implementation, and maintenance (including updating and modifying) of security measures to protect electronic protected health information, and to manage the conduct of the covered entity's or business associate's workforce in relation to the protection of that information.
_Authentication_
means the corroboration that a person or technology asset is the one they are claiming to be.
_Availability_
means the property that data or information is accessible and useable upon demand by an authorized person or technology asset.
_Confidentiality_
means the property that data or information is not made available or disclosed to unauthorized persons, technology assets, or processes.
_Deploy_
means to configure technology for use and implement such technology.
_Electronic information system_
means interconnected set of electronic information resources under the same direct management control that shares common functionality. An electronic information system generally includes technology assets, such as hardware, software, electronic media, information, and data.
_Encryption_
means the use of an algorithmic process to transform data into a form in which there is a low probability of assigning meaning without use of a confidential process or key.
_Facility_
means the physical premises and the interior and exterior of a building(s).
_Implement_
means to put into effect and be in use, operational, and function as expected throughout the covered entity or business associate.
_Information system_
means an interconnected set of information resources under the same direct management control that shares common functionality. An information system generally includes hardware, software, information, data, communications, and people.
_Integrity_
means the property that data or information have not been altered or destroyed in an unauthorized manner.
_Malicious software_
means software or firmware intended to perform an unauthorized action or activity that will have adverse impact on an electronic information system and/or the confidentiality, integrity, or availability of electronic protected health information. Examples include but are not limited to viruses, worms, Trojan horses, spyware, and some forms of adware.
_Multi-factor authentication_
means authentication of the user's identity through verification of at least two of the following three categories:
(1) Information known by the user, including but not limited to a password or personal identification number (PIN).
(2) Item possessed by the user, including but not limited to a token or a smart identification card.
(3) Personal characteristic of the user, including but not limited to fingerprint, facial recognition, gait, typing cadence, or other biometric or behavioral characteristics.
_Password_
means confidential authentication information composed of a string of characters, such as letters, numbers, spaces, and other symbols.
_Physical safeguards_
are physical measures and related policies and procedures to protect a covered entity's or business associate's relevant electronic information systems, and related facilities and equipment, from natural and environmental hazards and unauthorized intrusion.
_Relevant electronic information system_
means an electronic information system that creates, receives, maintains, or transmits electronic protected health information or that otherwise affects the confidentiality, integrity, or availability of electronic protected health information.
_Risk_
means the extent to which the confidentiality, integrity, or availability of electronic protected health information is threatened by a potential circumstance or event.
_Security_
_security measures_
encompass all of the administrative, physical, and technical safeguards in or applied to an information system.
_Security incident_
means any of the following:
(1) The attempted or successful unauthorized access, use, disclosure, modification, or destruction of information in an information system.
(2) The attempted or successful unauthorized interference with system operations in an information system.
_Technical controls_
means the technical mechanisms contained in the hardware, software, or firmware components of an electronic information system that are primarily implemented and executed by the electronic information system to protect the information system and data therein.
_Technical safeguards_
means the technology, technical controls, and related policies and procedures governing the use of the technology that protects and controls access to electronic protected health information.
_Technology asset_
means the components of an electronic information system, including but not
( printed page 1012)
limited to hardware, software, electronic media, information, and data.
_Threat_
means any circumstance or event with the potential to adversely affect the confidentiality, integrity, or availability of electronic protected health information.
_User_
means a person with authorized access.
_Vulnerability_
means a flaw or weakness in an information system, information system security procedures, design, implementation, or technical controls that could be intentionally exploited or accidentally triggered by a threat.
_Workstation_
means an electronic computing device and electronic media stored in its immediate environment. Workstation includes but is not limited to the following types of devices: a server, desktop computer, laptop computer, virtual device, and mobile device such as a smart phone or tablet.
§ 164.306
Security standards: General rules.
_General requirements._
Each covered entity and business associate must do the following with respect to all electronic protected health information it creates, receives, maintains, or transmits:
(1) Ensure the confidentiality, integrity, and availability of the electronic protected health information.
(2) Protect against any reasonably anticipated threats or hazards to the confidentiality, integrity, or availability of the electronic protected health information.
(3) Protect against any reasonably anticipated uses or disclosures of the electronic protected health information that are not permitted or required under subpart E of this part.
(4) Ensure compliance by its workforce with this subpart and all administrative, physical, and technical safeguards implemented in accordance with this subpart.
_Flexibility of approach._
(1) Covered entities and business associates may use any reasonable and appropriate security measures that allow the covered entity or business associate to implement the standards and implementation specifications as specified in this subpart.
(2) In deciding which security measures to use, a covered entity or business associate must take into account all of the following factors:
(i) The size, complexity, and capabilities of the covered entity or business associate.
(ii) The covered entity's or the business associate's technical infrastructure, hardware, and software security capabilities.
(iii) The costs of security measures.
(iv) The probability and criticality of potential risks to electronic protected health information.
(v) The effectiveness of the security measure in supporting the resiliency of the covered entity or business associate.
_Standards and implementation specifications._
A covered entity or business associate must comply with the applicable standards, including their implementation specifications, as provided in this subpart.
§ 164.308
Administrative safeguards.
(a) A covered entity or business associate must, in accordance with §§ 164.306 and 164.316, implement all of the following administrative safeguards to protect the confidentiality, integrity, and availability of all electronic protected health information that it creates, receives, maintains, or transmits:
_Standard: Technology asset inventory_
_General._
Conduct and maintain an accurate and thorough written inventory and a network map of the covered entity's or business associate's electronic information systems and all technology assets that may affect the confidentiality, integrity, or availability of electronic protected health information.
_Implementation specifications_
_Inventory._
Develop a written inventory of the covered entity's or business associate's technology assets that contains the identification, version, person accountable, and location of each technology asset.
_Network map._
Develop a network map that illustrates the movement of electronic protected health information throughout the covered entity's or business associate's electronic information systems, including but not limited to how electronic protected health information enters and exits such information systems, and is accessed from outside of such information systems.
_Maintenance._
Review and update the written inventory of technology assets required by paragraph (a)(1)(ii)(A) of this section and the network map required by paragraph (a)(1)(ii)(B) of this section in the following circumstances:
_1_) On an ongoing basis, but at least once every 12 months.
_2_) When there is a change in the covered entity's or business associate's environment or operations that may affect electronic protected health information, including but not limited to the adoption of new technology assets; the upgrading, updating, or patching of technology assets; newly recognized threats to the confidentiality, integrity, or availability of electronic protected health information; a sale, transfer, merger, or consolidation of all or part of the covered entity or business associate with another person; a security incident that affects the confidentiality, integrity, and availability of electronic protected health information; and relevant changes in Federal, State, Tribal, or territorial law.
_Standard: Risk analysis_
_General._
Conduct an accurate and comprehensive written assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of all electronic protected health information created, received, maintained, or transmitted by the covered entity or business associate.
_Implementation specifications_
_Assessment._
The written assessment must include, at a minimum, all of the following:
_1_) A review of the technology asset inventory required by paragraph (a)(1)(ii)(A) of this section and the network map required by paragraph (a)(1)(ii)(B) of this section to identify where electronic protected health information may be created, received, maintained, or transmitted within the covered entity's or business associate's electronic information systems.
_2_) Identification of all reasonably anticipated threats to the confidentiality, integrity, and availability of electronic protected health information that the covered entity or business associate creates, receives, maintains, or transmits.
_3_) Identification of potential vulnerabilities and predisposing conditions to the covered entity's or business associate's relevant electronic information systems.
_4_) An assessment and documentation of the security measures the covered entity or business associate uses to ensure the confidentiality, integrity, and availability of the electronic protected health information created, received, maintained, or transmitted by the covered entity or business associate.
_5_) A reasonable determination of the likelihood that each threat identified in accordance with paragraph (a)(2)(ii)(A)(
_2_) of this section will exploit the vulnerabilities identified in accordance with paragraph (a)(2)(ii)(A)(
_3_) of this section.
_6_) A reasonable determination of the potential impact of each threat identified in accordance with paragraph (a)(2)(ii)(A)(
_2_) of this section successfully exploiting the vulnerabilities identified in accordance with paragraph (a)(2)(ii)(A)(
_3_) of this section.
( printed page 1013)
_7_) An assessment of risk level for each threat identified in accordance with paragraph (a)(2)(ii)(A)(
_2_) of this section and vulnerability identified in accordance with paragraph (a)(2)(ii)(A)(
_3_) of this section, based on the determinations made in accordance with paragraphs (a)(2)(ii)(A)(
_5_) and (
_6_) of this section.
_8_) An assessment of the risks to electronic protected health information posed by entering into or continuing a business associate contract or other written arrangement with any prospective or current business associate, respectively, based on the written verification obtained from the prospective or current business associate in accordance with paragraph (b)(1) of this section.
_Maintenance._
Review, verify, and update the written assessment on an ongoing basis, but at least once every 12 months and, in accordance with paragraph (a)(1)(ii)(C)(
_2_) of this section, in response to a change in the covered entity's or business associate's environment or operations that may affect electronic protected health information.
_Standard: Evaluation_
_General._
Perform a written technical and nontechnical evaluation to determine whether a change in the covered entity's or business associate's environment or operations may affect the confidentiality, integrity, or availability of electronic protected health information.
_Implementation specifications_
_Performance._
Perform a written technical and nontechnical evaluation within a reasonable period of time before making a change in the covered entity's or business associate's environment or operations as described in paragraph (a)(1)(ii)(C)(
_2_) of this section.
_Response._
Respond to the written technical and nontechnical evaluation in accordance with the covered entity's or business associate's risk management plan required by paragraph (a)(5)(ii)(A) of this section.
_Standard: Patch management_
_General._
Implement written policies and procedures for applying patches and updating the configuration(s) of the covered entity's or business associate's relevant electronic information systems.
_Implementation specifications_
_Policies and procedures._
Establish written policies and procedures for identifying, prioritizing, acquiring, installing, evaluating, and verifying the timely installation of patches, updates, and upgrades throughout the covered entity's or business associate's relevant electronic information systems.
_Maintenance._
Review and test written policies and procedures required by paragraph (a)(4)(ii)(A) of this section at least once every 12 months, and modify such policies and procedures as reasonable and appropriate.
_Application._
Patch, update, and upgrade the configurations of relevant electronic information systems in accordance with the written policies and procedures required by paragraph (a)(4)(ii)(A) of this section and based on the results of the covered entity's or business associate's risk analysis required by paragraph (a)(2) of this section, the vulnerability scans required by § 164.312(h)(2)(i), the monitoring of authoritative sources required by § 164.312(h)(2)(ii), and penetration tests required by § 164.312(h)(2)(iii), within a reasonable and appropriate period of time, as follows, except to the extent that an exception at paragraph (a)(4)(ii)(D) of this section applies:
_1_) Within 15 calendar days of identifying the need to patch, update, or upgrade the configuration of a relevant electronic information system to address a critical risk in accordance with this paragraph (a)(4)(ii)(C), where a patch, update, or upgrade is available; or, where a patch, update, or upgrade is not available, within 15 calendar days of a patch, update, or upgrade becoming available.
_2_) Within 30 calendar days of identifying the need to patch, update, or upgrade the configuration of a relevant electronic information system to address a high risk in accordance with this paragraph (a)(4)(ii)(C), where a patch, update, or upgrade is available; or, where a patch, update, or upgrade is not available, within 30 calendar days of a patch, update, or upgrade becoming available.
_3_) As determined by and documented in the covered entity's or business associate's policies and procedures under paragraph (a)(4)(ii)(A) of this section for all other patches, updates, and upgrades to the configuration of a relevant electronic information system.
_Exceptions._
This paragraph (a)(4)(ii)(D) applies only to the extent that a covered entity or business associate documents that an exception in this paragraph (a)(4)(ii)(D) applies and that all other applicable conditions are met.
_1_) A patch, update, or upgrade to the configuration of a relevant electronic information system is not available to address a risk identified in the risk analysis under paragraph (a)(2) of this section.
_2_) The only available patch, update, or upgrade would adversely affect the confidentiality, integrity, or availability of electronic protected health information.
_Alternative measures._
Where an exception at paragraph (a)(4)(ii)(D) of this section applies, a covered entity or business associate must document in real-time the existence of an applicable exception and implement reasonable and appropriate compensating controls in accordance with paragraph (a)(4)(ii)(F) of this section.
_Compensating controls._
To the extent that a covered entity or business associate determines that an exception at paragraph (a)(4)(ii)(D) of this section applies, a covered entity or business associate must implement reasonable and appropriate security measures to address the identified risk in a timely manner as required by paragraph (a)(5)(ii)(D) of this section until a patch, update, or upgrade that does not adversely affect the confidentiality, integrity, or availability of electronic protected health information becomes available.
_Standard: Risk management_
_General._
Implement security measures sufficient to reduce risks and vulnerabilities to all electronic protected health information to a reasonable and appropriate level.
_Implementation specifications_
_Planning._
Establish and implement a written risk management plan for reducing risks to all electronic protected health information, including but not limited to those risks identified by the risk analysis under paragraph (a)(2)(ii)(A) of this section, to a reasonable and appropriate level.
_Maintenance._
Review the written risk management plan required by paragraph (a)(5)(ii)(A) of this section at least once every 12 months and as reasonable and appropriate in response to changes in the risk analysis made in accordance with paragraph (a)(2)(ii)(B) of this section, and modify as reasonable and appropriate.
_Priorities._
The written risk management plan must prioritize the risks identified in the risk analysis required by paragraph (a)(2)(ii)(A) of this section, based on the risk levels determined by such risk analysis.
_Implementation._
Implement security measures in a timely manner to address the risks identified in the covered entity's or business associate's risk analysis in accordance with the priorities established under paragraph (a)(5)(ii)(C) of this section.
_Standard: Sanction policy_
_General._
Apply appropriate sanctions against workforce members who fail to comply with the security policies and
( printed page 1014)
procedures of the covered entity or business associate.
_Implementation specifications_
_Policies and procedures._
Establish written policies and procedures for sanctioning workforce members who fail to comply with the security policies and procedures of the covered entity or business associate.
_Modifications._
Review written sanctions policies and procedures at least once every 12 months, and modify as reasonable and appropriate.
_Application._
Apply and document appropriate sanctions against workforce members who fail to comply with the security policies and procedures of the covered entity or business associate in accordance with the written policies and procedures for sanctioning workforce members required by paragraph (a)(6)(ii)(A) of this section.
_Standard: Information system activity review_
_General._
Implement written policies and procedures for regularly reviewing records of activity in the covered entity's or business associate's relevant electronic information systems.
_Implementation specifications_
_Policies and procedures._
Establish written policies and procedures for retaining and reviewing records of activity in the covered entity's or business associate's relevant electronic information systems by persons and technology assets, including the frequency for reviewing such records.
_Scope._
Records of activity in the covered entity's or business associate's relevant electronic information systems by persons and/or technology assets include but are not limited to audit trails, event logs, firewall logs, system logs, data backup logs, access reports, anti-malware logs, and security incident tracking reports.
_Record review._
Review records of activity in a covered entity's or business associate's relevant electronic information systems by persons and technology assets as often as reasonable and appropriate for the type of report or log and document such review.
_Record retention._
Retain records of activity in the covered entity's or business associate's relevant electronic information systems by persons and technology assets for a period of time that is reasonable and appropriate for the type of report or log.
_Response._
Where a suspected or known security incident is identified during the review required by paragraph (a)(7)(ii)(C) of this section, respond in accordance with the covered entity's or business associate's security incident response plan required by paragraph (a)(12)(ii)(A)(
_1_) of this section.
_Maintenance._
Review and test the written policies and procedures required by paragraph (a)(7)(ii)(A) of this section at least once every 12 months and modify as reasonable and appropriate.
_Standard: Assigned security responsibility._
In writing, identify the security official who is responsible for the development and implementation of the policies and procedures, written or otherwise, and deployment of technical controls required by this subpart for the covered entity or business associate.
_Standard: Workforce security_
_General._
Implement written policies and procedures to ensure that all members of its workforce have appropriate access to electronic protected health information and relevant electronic information systems, and to prevent those workforce members who are not authorized to have access from obtaining access to electronic protected health information and relevant electronic information systems.
_Implementation specifications_
_Authorization and/or supervision._
Establish and implement written procedures for the authorization and/or supervision of workforce members who access electronic protected health information or relevant electronic information systems, or who work in facilities where electronic protected health information or relevant electronic information systems might be accessed.
_Workforce clearance procedure._
Establish and implement written procedures to determine that the access of a workforce member to electronic protected health information or relevant electronic information systems is appropriate in accordance with paragraph (a)(10)(ii)(B) of this section.
_Modification and termination procedures._
_1_) Establish and implement written procedures, in accordance with paragraph (a)(9)(ii)(C)(
_2_) of this section, to terminate a workforce member's access to electronic protected health information and relevant electronic information systems, and to facilities where electronic protected health information or relevant electronic information systems might be accessed.
_2_) A workforce member's access must be terminated as soon as possible but no later than one hour after the employment of, or other arrangement with, a workforce member ends.
_Notification._
_1_) Establish and implement written procedures, in accordance with paragraph (a)(9)(ii)(D)(
_2_) of this section, to notify another covered entity or business associate of a change in or termination of access where the workforce member is or was authorized to access such electronic protected health information or relevant electronic information systems by the covered entity or business associate making the notification.
_2_) Notification must occur as soon as possible but no later than 24 hours after a change in or termination of a workforce member's authorization to access electronic protected health information or relevant electronic information systems maintained by such other covered entity or business associate.
_Maintenance._
Review and test written policies and procedures required under paragraph (a)(9)(ii)(A) through (D) of this section at least once every 12 months, and modify as reasonable and appropriate.
_Standard: Information access management_
_General._
Establish and implement written policies and procedures for authorizing access to electronic protected health information and relevant electronic information systems that are consistent with the applicable requirements of subpart E of this part.
_Implementation specifications_
_Isolating health care clearinghouse functions._
If a health care clearinghouse is part of a larger organization, the clearinghouse must establish and implement written policies and procedures that protect the electronic protected health information and relevant electronic information systems of the clearinghouse from unauthorized access by the larger organization.
_Access authorization._
Establish and implement written policies and procedures for granting and revising access to electronic protected health information and relevant electronic information systems as necessary and appropriate for each prospective user and technology asset to carry out their assigned function(s).
_Authentication management._
Establish and implement written policies and procedures for verifying the identities of users and technology assets prior to accessing the covered entity's or business associate's relevant electronic information systems, including written policies and procedures for implementing multi-factor authentication technical controls required by § 164.312(f)(2)(ii) through (v).
_Access determination and modification._
Establish and implement written policies and procedures that, based upon the covered entity's or the business associate's access authorization policies, determine, document, review, and modify the access of each user and technology asset to specific components
( printed page 1015)
of the covered entity's or business associate's relevant electronic information systems.
_Network segmentation._
Establish and implement written policies and procedures that ensure that a covered entity's or business associate's relevant electronic information systems are segmented to limit access to electronic protected health information to authorized workstations.
_Maintenance._
Review and test the written policies and procedures required by this paragraph (a)(10)(ii) at least once every 12 months, and modify as reasonable and appropriate.
_Standard: Security awareness training_
_General._
Implement security awareness training for all workforce members on protection of electronic protected health information and information systems as necessary and appropriate for the members of the workforce to carry out their assigned function(s).
_Implementation specifications_
_Training._
A covered entity or business associate must develop and implement security awareness training for all workforce members that addresses all of the following:
_1_) The written policies and procedures with respect to electronic protected health information required by this subpart as necessary and appropriate for the workforce members to carry out their assigned functions.
_2_) Guarding against, detecting, and reporting suspected or known security incidents, including but not limited to, malicious software and social engineering.
_3_) The written policies and procedures for accessing the covered entity's or business associate's relevant electronic information systems, including but not limited to: safeguarding passwords; setting unique passwords of sufficient strength to ensure the confidentiality, integrity, and availability of electronic protected health information; and limitations on sharing passwords.
_Timing._
A covered entity or business associate must provide security awareness training as follows:
_1_) As required by paragraph (a)(11)(ii)(A) of this section, to each member of its workforce by no later than the compliance date, and at least once every 12 months thereafter.
_2_) As required by paragraph (a)(11)(ii)(A) of this section, to each new member of its workforce within a reasonable period of time but no later than 30 days after the person first has access to the covered entity's or business associate's relevant electronic information systems.
_3_) On a material change to the policies or procedures required by this subpart, to each member of its workforce whose functions are affected by such change, within a reasonable period of time but no later than 30 days after the material change occurs.
_Ongoing education._
A covered entity or business associate must provide its workforce members ongoing reminders of their security responsibilities and notifications of relevant threats, including but not limited to new and emerging malicious software and social engineering.
_Documentation._
A covered entity or business associate must document that the training required by paragraph (a)(11)(ii)(A) of this section and ongoing reminders required by paragraph (a)(11)(ii)(C) of this section have been provided.
_Standard: Security incident procedures_
_General._
Implement written policies and procedures to respond to security incidents.
_Implementation specifications_
_Planning and testing._
_1_) Establish written security incident response plan(s) and procedures documenting how workforce members are to report suspected or known security incidents and how the covered entity or business associate will respond to suspected or known security incidents in accordance with paragraph (a)(12)(ii)(B) of this section.
_2_) Implement written procedures for testing and revising security incident response plan(s) required by paragraph (a)(12)(ii)(A)(
_1_) of this section.
_3_) Review and test security incident response plan(s) and procedures required by paragraph (a)(12)(ii)(A)(
_1_) of this section at least once every 12 months, document the results of such tests, and modify security incident response plan(s) and procedures as reasonable and appropriate.
_Response._
_1_) Identify and respond to suspected or known security incidents.
_2_) Mitigate, to the extent practicable, harmful effects of security incidents that are suspected or known to the covered entity or business associate.
_3_) Identify and remediate, to the extent practicable, the root cause(s) of security incidents that are suspected or known to the covered entity or business associate.
_4_) Eradicate the security incidents that are suspected or known to the covered entity or business associate.
_5_) For suspected and known security incidents, develop and maintain documentation of investigations, analyses, mitigation, and remediation.
_Standard: Contingency plan_
_General._
Establish and implement as needed a written contingency plan, consisting of written policies and procedures for responding to an emergency or other occurrence—including but not limited to fire, vandalism, system failure, natural disaster, or security incident—that adversely affects relevant electronic information systems.
_Implementation specifications_
_Criticality analysis._
Perform and document an assessment of the relative criticality of the covered entity's or business associate's relevant electronic information systems and technology assets in its relevant electronic information systems.
_Data backups._
Establish and implement written procedures to create and maintain exact retrievable copies of electronic protected health information, including verification that the electronic protected health information has been copied accurately.
_Information systems backups._
Establish and implement written procedures to create and maintain backups of the covered entity's or business associate's relevant electronic information systems, including verification of success of backups.
_Disaster recovery plan._
_1_) Establish (and implement as needed) written procedures to restore loss of the covered entity's or business associate's critical relevant electronic information systems and data within 72 hours of the loss.
_2_) Establish (and implement as needed) written procedures to restore loss of the covered entity's or business associate's other relevant electronic information systems and data in accordance with the criticality analysis required by paragraph (a)(13)(ii)(A) of this section.
_Emergency mode operation plan._
Establish (and implement as needed) written procedures to enable continuation of critical business processes for protection of the security of electronic protected health information while operating in emergency mode.
_Testing and revision procedures._
_1_) Establish written procedures for testing and revising contingency plans as required by this paragraph (a)(13) in accordance with paragraph (a)(13)(ii)(F)(
_2_) of this section.
_2_) Review and test contingency plans required by this paragraph (a)(13) at least once every 12 months, document the results of such tests, and modify such contingency plans as reasonable and appropriate in accordance with the results of those tests.
( printed page 1016)
_Standard: Compliance audit._
Perform and document an audit at least once every 12 months of the covered entity's or business associate's compliance with each standard and implementation specification in this subpart.
(b)(1)
_Standard: Business associate contracts and other arrangements._
(i)(A) A covered entity may permit a business associate to create, receive, maintain, or transmit electronic protected health information on the covered entity's behalf only if the covered entity obtains satisfactory assurances, in accordance with § 164.314(a), that the business associate will comply with this subpart and verifies that the business associate has deployed technical safeguards in accordance with the requirements of § 164.312.
(B) A covered entity is not required to obtain such satisfactory assurances or verification from a business associate that is a subcontractor.
(ii) A business associate may permit a business associate that is a subcontractor to create, receive, maintain, or transmit electronic protected health information on its behalf only if the business associate obtains satisfactory assurances, in accordance with § 164.314(a), that the subcontractor will comply with the requirements of this subpart and verifies that the business associate that is a subcontractor has deployed technical safeguards in accordance with the requirements of § 164.312.
_Implementation specifications_
_Written contract or other arrangement._
Document the satisfactory assurances required by paragraph (b)(1)(i) or (ii) of this section through a written contract or other arrangement with the business associate that meets the applicable requirements of § 164.314(a).
_Written verification._
Obtain written verification from the business associate at least once every 12 months that the business associate has deployed the technical safeguards as required by § 164.312 through both of the following:
(A) A written analysis of the business associate's relevant electronic information systems by a person with appropriate knowledge of and experience with generally accepted cybersecurity principles and methods for ensuring the confidentiality, integrity, and availability of electronic protected health information to verify compliance with each standard and implementation specification in § 164.312.
(B) A written certification that the analysis has been performed and is accurate by a person who has the authority to act on behalf of the business associate.
_Standard: Delegation to business associate._
(i) A covered entity or business associate may permit a business associate to serve as their designated security official.
(ii) A covered entity or business associate that delegates actions, activities, or assessments required by this subpart to a business associate remains liable for compliance with all applicable provisions of this subpart.
§ 164.310
Physical safeguards.
Each covered entity and business associate must, in accordance with §§ 164.306 and 164.316, implement all of the following physical safeguards to protect the confidentiality, integrity, and availability of all electronic protected health information that it creates, receives, maintains, or transmits:
_Standard: Facility access controls_
_General._
Establish and implement written policies and procedures to limit physical access to all of its relevant electronic information systems and the facility or facilities in which they are housed, while ensuring that properly authorized access is allowed.
_Implementation specifications_
_Contingency operations._
Establish (and implement as needed) written procedures that allow facility access in support of the covered entity's or business associate's contingency plan required by § 164.308(a)(13).
_Facility security plan._
Establish and implement written policies and procedures to safeguard all facilities and the equipment therein from unauthorized physical access, tampering, and theft.
_Access management and validation procedures._
Establish and implement written procedures to authorize and manage a person's access to facilities based on their role or function, including visitor management.
_Physical maintenance records._
Establish and implement written policies and procedures to document repairs and modifications to the physical components of a facility that are related to security, including but not limited to hardware, walls, doors, locks, and security cameras.
_Maintenance._
For each facility, review and test the written policies and procedures required by this paragraph (a)(2) at least once every 12 months, and modify such policies and procedures as reasonable and appropriate.
_Standard: Workstation use_
_General._
Establish and implement written policies and procedures that govern the use of workstations that access electronic protected health information or the covered entity's or business associate's relevant electronic information systems.
_Implementation specifications_
_Policies and procedures._
The written policies and procedures must specify all of the following with respect to a workstation that accesses electronic protected health information or the covered entity's or business associate's relevant electronic information systems:
(A) The functions for which a workstation may be used.
(B) The manner in which a workstation may be used to perform those functions.
(C) The physical attributes of the surroundings of a specific workstation or class of workstation that can access electronic protected health information, including the removal of such workstations from a facility and the movement of such workstations within and outside of a facility.
_Maintenance._
Review and test written policies and procedures at least once every 12 months, and modify as reasonable and appropriate.
_Standard: Workstation security._
Implement and modify physical safeguards for all workstations that access electronic protected health information or relevant electronic information systems, to address the written policies and procedures for workstation use required by paragraph (b) of this section and restrict access to authorized users.
_Standard: Technology asset controls_
_General._
Establish and implement written policies and procedures that govern the receipt and removal of technology assets that maintain electronic protected health information into and out of a facility, and the movement of these assets within the facility.
_Implementation specifications_
_Disposal._
Establish and implement written policies and procedures for disposal of electronic protected health information and the technology assets on which it is maintained based on current standards for disposing of such technology assets.
_Media sanitization._
Establish and implement written procedures for removal of electronic protected health information from electronic media such that the electronic protected health information cannot be recovered, based on current standards for sanitizing electronic media before the media are made available for re-use.
_Maintenance._
Review and test the written policies and procedures required by paragraphs (d)(2)(i) and (ii)
( printed page 1017)
of this section at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
§ 164.312
Technical safeguards.
Each covered entity or business associate must, in accordance with §§ 164.306 and 164.316, implement all of the following technical safeguards, including technical controls, to protect the confidentiality, integrity, and availability of all electronic protected health information that it creates, receives, maintains, or transmits:
_Standard: Access control_
_General._
Deploy technical controls in relevant electronic information systems to allow access only to users and technology assets that have been granted access rights.
_Implementation specifications_
_Unique identification._
Assign a unique name, number, and/or other identifier for tracking each user and technology asset in the covered entity or business associate's relevant electronic information systems.
_Administrative and increased access privileges._
Separate user identities from identities used for administrative and other increased access privileges.
_Emergency access procedure._
Establish (and implement as needed) written and technical procedures for obtaining necessary electronic protected health information during an emergency.
_Automatic logoff._
Deploy technical controls that terminate an electronic session after a predetermined time of inactivity that is reasonable and appropriate.
_Log-in attempts._
Deploy technical controls that disable or suspend the access of a user or technology asset to relevant electronic information systems after a reasonable and appropriate predetermined number of unsuccessful authentication attempts.
_Network segmentation._
Deploy technical controls to ensure that the covered entity's or business associate's relevant electronic information systems are segmented in a reasonable and appropriate manner.
_Data controls._
Deploy technical controls to allow access to electronic protected health information only to those users and technology assets that have been granted access rights to the covered entity's or business associate's relevant electronic information systems as specified in § 164.308(a)(10).
(viii)
_Maintenance._
Review and test the effectiveness of the procedures and technical controls required by this paragraph (a)(2) at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Standard: Encryption and decryption_
_General._
Deploy technical controls to encrypt and decrypt electronic protected health information using encryption that meets prevailing cryptographic standards.
_Implementation specification._
Encrypt all electronic protected health information at rest and in transit, except to the extent that an exception at paragraph (b)(3) of this section applies.
_Exceptions._
This paragraph (b)(3) applies only to the electronic protected health information directly affected by one or more of the following exceptions and only to the extent that the covered entity or business associate documents that an exception applies and that all other applicable conditions are met.
(i) The technology asset in use does not support encryption of the electronic protected health information consistent with prevailing cryptographic standards, and the covered entity or business associate establishes and implements a written plan to migrate electronic protected health information to a technology asset that supports encryption consistent with prevailing cryptographic standards within a reasonable and appropriate period of time.
(ii) An individual requests pursuant to § 164.524 to receive their electronic protected health information in an unencrypted manner and has been informed of the risks associated with the transmission, receipt, and storage of unencrypted electronic protected health information. This exception does not apply where such individual will receive their electronic protected health information pursuant to § 164.524 and the technology used by the individual to receive the electronic protected health information is controlled by the covered entity or its business associate.
(iii) During an emergency or other occurrence that adversely affects the covered entity's or business associate's relevant electronic information systems in which encryption is infeasible, and the covered entity or business associate implements reasonable and appropriate compensating controls in accordance with and determined by the covered entity's or business associate's contingency plan under § 164.308(a)(13).
(iv) The technology asset in use is a device under section 201(h) of the Food, Drug, and Cosmetic Act, 21 U.S.C. 321(h) that has been authorized for marketing by the Food and Drug Administration, as follows:
(A) Pursuant to a submission received before March 29, 2023, provided that the covered entity or business associate deploys in a timely manner any updates or patches required or recommended by the manufacturer of the device.
(B) Pursuant to a submission received on or after March 29, 2023, where the device is no longer supported by its manufacturer, provided that the covered entity or business associate has deployed any updates or patches required or recommended by the manufacturer of the device.
(C) Pursuant to a submission received on or after March 29, 2023, where the device is supported by its manufacturer.
_Alternative measures_
_Alternative measures._
Where an exception at paragraph (b)(3) of this section applies, a covered entity or business associate must document in real-time the existence of an applicable exception and implement reasonable and appropriate compensating controls in accordance with paragraph (b)(4)(ii) of this section.
_Compensating controls._
(A) To the extent that a covered entity or business associate determines that an exception at paragraph (b)(3)(i), (ii), or (iii) or (b)(3)(iv)(A) or (B) of this section applies, the covered entity or business associate must secure such electronic protected health information by implementing reasonable and appropriate compensating controls reviewed and approved by the covered entity's or business associate's designated Security Official.
(B) To the extent that a covered entity or business associate determines that an exception at paragraph (b)(3)(iv)(C) of this section applies, the covered entity or business associate shall be presumed to have implemented reasonable and appropriate compensating controls where the covered entity or business associate has deployed the security measures prescribed and as instructed by the authorized label for the device, including any updates or patches recommended or required by the manufacturer of the device.
(C) To the extent that a covered entity or business associate is implementing compensating controls under this paragraph (b)(4)(ii), the implementation and effectiveness of compensating controls must be reviewed, documented, and signed by the designated Security Official at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, to continue securing electronic protected health information and relevant electronic information systems.
( printed page 1018)
_Maintenance._
Review and test the effectiveness of the technical controls required by this paragraph (b) at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Standard: Configuration management_
_General._
Establish and deploy technical controls for securing the covered entity's or business associate's relevant electronic information systems and technology assets in its relevant electronic information systems, including workstations, in a consistent manner, and maintain such electronic information systems and technology assets according to the covered entity's or business associate's established secure baselines.
_Implementation specifications_
_Anti-malware protection._
Deploy technology assets and/or technical controls that protect all of the covered entity's or business associate's technology assets in its relevant electronic information systems against malicious software, including but not limited to viruses and ransomware.
_Software removal._
Remove extraneous software from the covered entity's or business associate's relevant electronic information systems.
_Configuration._
Configure and secure operating system(s) and software consistent with the covered entity's or business associate's risk analysis under § 164.308(a)(2).
_Network ports._
Disable network ports in accordance with the covered entity's or business associate's risk analysis under § 164.308(a)(2).
_Maintenance._
Review and test the effectiveness of the technical controls required by this paragraph (c) at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Standard: Audit trail and system log controls_
_General._
Deploy technology assets and/or technical controls that record and identify activity in the covered entity's or business associate's relevant electronic information systems.
_Implementation specifications_
_Monitor and identify._
The covered entity or business associate must deploy technology assets and/or technical controls that monitor in real-time all activity in its relevant electronic information systems, identify indications of unauthorized persons or unauthorized activity as determined by the covered entity's or business associate's risk analysis under § 164.308(a)(2), and alert workforce members of such indications in accordance with the policies and procedures required by § 164.308(a)(7).
_Record._
The covered entity or business associate must deploy technology assets and/or technical controls that record in real-time all activity in its relevant electronic information systems.
_Retain._
The covered entity or business associate must deploy technology assets and/or technical controls to retain records of all activity in its relevant electronic information systems as determined by the covered entity's or business associate's policies and procedures for information system activity review at § 164.308(a)(7)(ii)(A).
_Scope._
Activity includes creating, accessing, receiving, transmitting, modifying, copying, or deleting any of the following:
(A) Electronic protected health information.
(B) Relevant electronic information systems and the information therein.
_Maintenance._
Review and test the effectiveness of the technology assets and/or technical controls required by this paragraph (d) at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Standard: Integrity._
Deploy technical controls to protect electronic protected health information from improper alteration or destruction, both at rest and in transit; and review and test the effectiveness of such technical controls at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Standard: Authentication_
_General._
Deploy technical controls to verify that a person or technology asset seeking access to electronic protected health information and/or the covered entity's or business associate's relevant electronic information systems is the one claimed.
_Implementation specifications_
_Information access management policies._
Deploy technical controls in accordance with the covered entity's or business associate's information access management policies and procedures under § 164.308(a)(10), including technical controls that require users to adopt unique passwords that are consistent with the current recommendations of authoritative sources.
_Multi-factor authentication._
(A) Deploy multi-factor authentication to all technology assets in the covered entity's or business associate's relevant electronic information systems to verify that a person seeking access to the relevant electronic information system(s) is the user that the person claims to be.
(B) Deploy multi-factor authentication for any action that would change a user's privileges to the covered entity's or business associate's relevant electronic information systems in a manner that would alter the user's ability to affect the confidentiality, integrity, or availability of electronic protected health information.
_Exceptions._
Deployment of multi-factor authentication is not required in any of the following circumstances.
(A) The technology asset in use does not support multi-factor authentication, and the covered entity or business associate establishes and implements a written plan to migrate electronic protected health information to a technology asset that supports multi-factor authentication within a reasonable and appropriate period of time.
(B) During an emergency or other occurrence that adversely affects the covered entity's or business associate's relevant electronic information systems or the confidentiality, integrity, or availability of electronic protected health information in which multi-factor authentication is infeasible and the covered entity or business associate implements reasonable and appropriate compensating controls in accordance with its emergency access procedures under paragraph (a)(2)(iii) of this section and the covered entity's or business associate's contingency plan under § 164.308(a)(13).
(C) The technology asset in use is a device under section 201(h) of the Food, Drug, and Cosmetic Act, 21 U.S.C. 321(h) that has been authorized for marketing by the Food and Drug Administration, as follows:
_1_) Pursuant to a submission received before March 29, 2023, provided that the covered entity or business associate has deployed any updates or patches required or recommended by the manufacturer of the device.
_2_) Pursuant to a submission received on or after March 29, 2023, where the device is no longer supported by its manufacturer, provided that the covered entity or business associate has deployed any updates or patches required or recommended by the manufacturer of the device.
_3_) Pursuant to a submission received on or after March 29, 2023, where the device is supported by its manufacturer.
_Alternative measures_
_Alternative measures._
Where an exception at paragraph (f)(2)(iii) of this
( printed page 1019)
section applies, a covered entity or business associate must document in real-time the existence of an applicable exception and implement reasonable and appropriate compensating controls as required by paragraph (f)(2)(iv)(B) of this section.
_Compensating controls._
_1_) To the extent that a covered entity or business associate determines that an exception at paragraph (f)(2)(iii)(A) or (B) or (f)(2)(iii)(C)(
_1_) or (
_2_) of this section applies, the covered entity or business associate must secure its relevant electronic information systems by implementing reasonable and appropriate compensating controls reviewed, approved, and signed by the covered entity's or business associate's designated Security Official.
_2_) To the extent that a covered entity or business associate determines that an exception at paragraph (f)(2)(iii)(C)(
_3_) of this section applies, the covered entity or business associate shall be presumed to have implemented reasonable and appropriate compensating controls where the covered entity or business associate has deployed the security measures prescribed and as instructed by the authorized label for the device, including any updates or patches recommended or required by the manufacturer of the device.
_3_) To the extent that a covered entity or business associate is implementing compensating controls under this paragraph (f)(2)(iv)(B), the effectiveness of compensating controls must be reviewed and documented by the designated Security Official at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, to continue securing electronic protected health information and its relevant electronic information systems.
_Maintenance._
Review and test the effectiveness of the technical controls required by this paragraph (f) at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Standard: Transmission security._
Deploy technical controls to guard against unauthorized access to electronic protected health information that is being transmitted over an electronic communications network; and review and test the effectiveness of such technical controls at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Standard: Vulnerability management_
_General._
Deploy technical controls in accordance with the covered entity's or business associate's patch management policies and procedures required by § 164.308(a)(4)(ii)(A) to identify and address technical vulnerabilities in the covered entity's or business associate's relevant electronic information systems.
_Implementation specifications_
_Vulnerability scanning._
(A) Conduct automated vulnerability scans to identify technical vulnerabilities in the covered entity's or business associate's relevant electronic information systems in accordance with the covered entity's or business associate's risk analysis required by § 164.308(a)(2) or at least once every six months, whichever is more frequent.
(B) Review and test the effectiveness of the technology asset(s) that conducts the automated vulnerability scans required by paragraph (h)(2)(i)(A) of this section at least once every 12 months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
_Monitoring._
Monitor authoritative sources for known vulnerabilities on an ongoing basis and remediate such vulnerabilities in accordance with the covered entity's or business associate's patch management program under § 164.308(a)(4).
_Penetration testing._
Perform penetration testing of the covered entity's or business associate's relevant electronic information systems by a qualified person.
(A) A qualified person is a person with appropriate knowledge of and experience with generally accepted cybersecurity principles and methods for ensuring the confidentiality, integrity, and availability of electronic protected health information.
(B) Penetration testing must be performed at least once every 12 months or in accordance with the covered entity's or business associate's risk analysis required by § 164.308(a)(2), whichever is more frequent.
_Patch and update installation._
Deploy technical controls in accordance with the covered entity's or business associate's patch management program under § 164.308(a)(4) to ensure timely installation of software patches and critical updates as reasonable and appropriate.
_Standard: Data backup and recovery_
_General._
Deploy technical controls to create and maintain exact retrievable copies of electronic protected health information.
_Implementation specifications_
_Data backup._
Create backups of electronic protected health information in accordance with the policies and procedures required by § 164.308(a)(13)(ii)(B) and with such frequency to ensure retrievable copies of electronic protected health information are no more than 48 hours older than the electronic protected health information maintained in the covered entity or business associate's relevant electronic information systems.
_Monitor and identify._
Deploy technical controls that, in real-time, monitor, and alert workforce members about, any failures and error conditions of the backups required by paragraph (i)(2)(i) of this section.
_Record._
Deploy technical controls that record the success, failure, and any error conditions of backups required by paragraph (i)(2)(i) of this section.
_Testing._
Restore a representative sample of electronic protected health information backed up as required by paragraph (i)(2)(i) of this section, and document the results of such test restorations at least monthly.
_Standard: Information systems backup and recovery._
Deploy technical controls to create and maintain backups of relevant electronic information systems; and review and test the effectiveness of such technical controls at least once every six months or in response to environmental or operational changes, whichever is more frequent, and modify as reasonable and appropriate.
§ 164.314
Organizational requirements.
(a)(1)
_Standard: Business associate contracts or other arrangements._
The contract or other arrangement required by § 164.308(b)(2) must meet the requirements of paragraph (a)(2)(i), (ii), or (iii) of this section, as applicable.
_Implementation specifications_
_Business associate contracts._
The contract must provide that the business associate will do all of the following:
(A) Comply with the applicable requirements of this subpart.
(B) In accordance with § 164.308(b)(1)(ii), ensure that any subcontractors that create, receive, maintain, or transmit electronic protected health information on behalf of the business associate agree to comply with the applicable requirements of this subpart by entering into a contract or other arrangement that complies with this section.
(C) Report to the covered entity any security incident of which it becomes aware, including breaches of unsecured electronic protected health information as required by § 164.410.
(D) Report to the covered entity activation of its contingency plan under § 164.308(a)(13) without unreasonable
( printed page 1020)
delay, and in no case later than 24 hours after activation of the contingency plan.
_Other arrangements._
The covered entity is in compliance with paragraph (a)(1) of this section if it has another arrangement in place that meets the requirements of § 164.504(e)(3).
_Business associate contracts with subcontractors._
The requirements of paragraphs (a)(2)(i) and (ii) of this section apply to the contract or other arrangement between a business associate and a subcontractor required by § 164.308(b)(1)(ii) in the same manner as such requirements apply to contracts or other arrangements between a covered entity and business associate.
(b)(1)
_Standard: Requirements for group health plans._
Except when the only electronic protected health information disclosed to a plan sponsor is disclosed pursuant to § 164.504(f)(1)(ii) or (iii), or as authorized under § 164.508, a group health plan must ensure that its plan documents provide that the plan sponsor will reasonably and appropriately safeguard electronic protected health information created, received, maintained, or transmitted to or by the plan sponsor on behalf of the group health plan.
_Implementation specifications._
The plan documents of the group health plan must be amended to incorporate provisions to require the plan sponsor to do all of the following:
_Safeguard implementation._
Implement the administrative, physical, and technical safeguards that covered entities and business associates are required to implement under §§ 164.308(a), 164.310, and 164.312.
_Separation._
Ensure that the adequate separation required by § 164.504(f)(2)(iii) is supported by the administrative, physical, and technical safeguards implemented in accordance with paragraph (b)(2)(i) of this section.
_Agents._
Ensure that any agent to whom it provides this information agrees to implement the administrative, physical, and technical safeguards in accordance with paragraph (b)(2)(i) of this section.
_Security incident awareness._
Report to the group health plan any security incident of which it becomes aware.
_Contingency plan activation._
Report to the group health plan activation of its contingency plan, adopted in accordance with § 164.308(a)(13) as required by paragraph (b)(2)(i) of this section, without unreasonable delay and in no case later than 24 hours after activation of the contingency plan.
§ 164.316
Documentation requirements.
_Standard: Documentation._
A covered entity or business associate must do all of the following in written form, which may be electronic, taking into consideration the factors in § 164.306(b):
(1) Document the policies and procedures required to comply with this subpart and how the covered entity or business associate considered the factors at § 164.306(b) in the development of such policies and procedures.
(2) Document each action, activity, or assessment required by this subpart.
_Implementation specifications_
_Time limit._
Retain the documentation required by paragraph (a) of this section for 6 years from the date of its creation or the date when it last was in effect, whichever is later.
_Availability._
Make documentation available to those persons responsible for implementing the procedures to which the documentation pertains.
_Updates._
Review and update documentation at least once every 12 months and within a reasonable and appropriate period of time after a security measure is modified.
§ 164.318
Transition provisions.
_Standard: Effect of prior contracts or other arrangements with business associates._
Notwithstanding any other provisions of this subpart, a covered entity, or business associate with respect to a subcontractor, may allow a business associate to create, receive, maintain, or transmit electronic protected health information pursuant to a written contract or other arrangement with such business associate that does not comply with §§ 164.308(b) and 164.314(a), only in accordance with paragraph (b) of this section.
_Implementation specification: Deemed compliance_
_Qualification._
Notwithstanding other sections of this subpart, a covered entity, or business associate with respect to a subcontractor, is deemed to be in compliance with the documentation and contract requirements of §§ 164.308(b) and 164.314(a), with respect to a particular business associate relationship for the time period set forth in paragraph (b)(2) of this section, if both of the following apply:
(i) Prior to \[DATE OF PUBLICATION OF THE FINAL RULE IN THE\
**Federal Register**\
\], such covered entity, or business associate with respect to a subcontractor, has entered into and is operating pursuant to a written contract or other written arrangement with the business associate that complies with the applicable provisions of §§ 164.308(b) and 164.314(a) that were in effect on such date.
(ii) The contract or other arrangement is not renewed or modified from \[DATE 60 DAYS AFTER DATE OF PUBLICATION OF THE FINAL RULE IN THE\
**Federal Register**\
\], until \[DATE 240 DAYS AFTER DATE OF PUBLICATION OF THE FINAL RULE IN THE\
**Federal Register**\
_Limited deemed compliance period._
A prior contract or other arrangement that meets the qualification requirements at paragraph (b)(1) of this section shall be deemed compliant until the earlier of the following dates:
(i) The date such contract or other arrangement is renewed on or after \[DATE 240 DAYS AFTER DATE OF PUBLICATION OF THE FINAL RULE IN THE\
**Federal Register**\
(ii) \[DATE 1 YEAR AND 60 DAYS AFTER DATE OF PUBLICATION OF THE FINAL RULE IN THE\
**Federal Register**\
_Covered entity and business associate responsibilities._
Nothing in this section shall alter the requirements of a covered entity or business associate to comply with applicable provisions of this part other than §§ 164.308(b) and 164.314(a).
§ 164.320
Severability.
If any provision of this subpart is held to be invalid or unenforceable by its terms, or as applied to any person or circumstance, or stayed pending further agency action, it shall be construed so as to give it maximum effect permitted by law, unless such holding shall be one of utter invalidity or unenforceability, in which event such provision shall be severable from this subpart and shall not affect the remainder thereof or the application of such provision to other persons not similarly situated or to other dissimilar circumstances.
( printed page 1021)
## Appendix A to Subpart C of Part 164—Security Standards: Matrix
Standards Sections Implementation specifications
--- --- ---
**Administrative Safeguards**
Technology asset inventory 164.308(a)(1) Inventory.
Network map.
Maintenance.
Risk analysis 164.308(a)(2) Assessment
Maintenance.
Evaluation 164.308(a)(3) Performance
Response.
Patch Management 164.308(a)(4) Policies and procedures.
Maintenance.
Application.
Exceptions.
Alternative measures.
Compensating controls.
Risk management 164.308(a)(5) Planning.
Maintenance.
Priorities.
Implementation.
Sanction policy 164.308(a)(6) Policies and procedures.
Modifications.
Application.
Information system activity review 164.308(a)(7) Policies and procedures.
Scope.
Record review.
Record retention.
Response.
Maintenance.
Assigned security responsibility 164.308(a)(8)
Workforce security 164.308(a)(9) Authorization and/or supervision.
Workforce clearance procedure.
Modification and termination procedures.
Notification.
Maintenance.
Information access management 164.308(a)(10) Isolating health care clearinghouse functions.
Access authorization.
Authentication management.
Access determination and modification.
Network segmentation.
Maintenance.
Security awareness training 164.308(a)(11) Training.
Timing.
Ongoing education.
Documentation.
Security incident procedures 163.308(a)(12) Planning and testing.
Response.
Contingency plan 163.308(a)(13) Criticality analysis.
Data backups.
Information systems backups.
Disaster recovery plan.
Emergency mode operation plan.
Testing and revision procedures.
Compliance audit 164.308(a)(14)
Business associate contracts and other arrangements 164.308(b)(1) Written contract or other arrangement.
Written verification.
Delegation to business associate 164.308(b)(3)
**Physical Safeguards**
Facility access controls 164.310(a) Contingency operations.
Facility security plan.
Access management and validation procedures.
Physical maintenance records.
Maintenance.
Workstation use 164.310(b) Policies and procedures.
Maintenance.
Workstation security 164.310(c)
Technology asset controls 164.310(d) Disposal.
Media sanitization.
Maintenance.
( printed page 1022)
**Technical Safeguards**
Access control 164.312(a) Unique identification.
Administrative and increased access privileges.
Emergency access procedure.
Automatic logoff.
Log-in attempts.
Network segmentation.
Data controls.
Maintenance.
Encryption and decryption 164.312(b) Implementation specification.
Exceptions.
Alternative measures.
Compensating controls.
Maintenance.
Configuration management 164.312(c) Anti-malware protection.
Software removal.
Configuration.
Network ports.
Maintenance.
Audit trail and system log controls 164.312(d) Monitor and identify.
Record.
Retain.
Scope.
Maintenance.
Integrity 164.312(e)
Authentication 164.312(f) Information access management policies.
Multi-factor authentication.
Exceptions.
Alternative measures.
Compensating controls.
Maintenance.
Transmission security 164.312(g)
Vulnerability management 164.312(h) Vulnerability scanning.
Monitoring.
Penetration testing.
Patch and update installation.
Data backup and recovery 164.312(i) Data backup
Monitor and identify.
Record.
Testing.
Information systems backup and recovery 164.312(j)
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HIPAA Cybersecurity Requirements and Best Practices - FireMon
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https://www.firemon.com/blog/hipaa-security-compliance/
|
healthcare cybersecurity HIPAA
|
Yes (reduced from 19594 to 15646 chars)
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The Health Insurance Portability and Accountability Act (HIPAA) mandates a stringent framework for protecting sensitive patient information. These standards form the foundation of cybersecurity measures within the healthcare sector, ensuring compliance, mitigating risks, and safeguarding patient trust. Understanding these requirements is critical for healthcare organizations to meet regulatory obligations and secure sensitive data effectively.
This post will outline HIPAA cybersecurity requirements, explore best practices, and provide a checklist to help your enterprise ensure compliance.
**Key Highlights:**
- By implementing HIPAA cybersecurity requirements, including administrative, physical, and technical safeguards, healthcare organizations can effectively protect electronic protected health information (ePHI) and ensure regulatory compliance.
- Conducting regular risk assessments and employee training programs helps healthcare organizations proactively identify vulnerabilities and foster a culture of compliance, reducing the risk of data breaches.
- Maintaining thorough documentation and conducting ongoing security audits enable organizations to demonstrate compliance, address potential gaps, and avoid costly penalties associated with HIPAA violations.
## What Are HIPAA Security Standards?
HIPAA security standards, established under the HIPAA Security Rule, mandate that covered entities and business associates implement administrative, physical, and technical safeguards to ensure the confidentiality, integrity, and availability of electronic protected health information (ePHI).
## Why HIPAA Compliance Is Important for Health Organizations
Failure to comply with standards set out in the HIPAA framework can have serious consequences for healthcare organizations:
- **Legal Penalties**: Non-compliance with HIPAA regulations can lead to significant financial penalties. These fines range from $100 to $50,000 per violation, depending on the severity and whether the violation was due to willful neglect. For organizations, this can quickly add up, with annual caps of $1.5 million for repeat violations. Legal ramifications extend beyond fines, as severe cases may involve civil or criminal litigation, further complicating an organization’s operations.
- **Data Breaches**: A failure to implement proper security measures increases the potential for data breaches. When sensitive patient data is exposed, it can lead to severe consequences, including identity theft, loss of patient trust, and the erosion of relationships with stakeholders. Breaches also attract regulatory scrutiny, compounding the costs and damages associated with remediation efforts. Learn more about safeguarding sensitive data in our article on data privacy.
- **Operational Disruptions**: Non-compliance often triggers regulatory audits, which can disrupt day-to-day operations. These reviews require significant time and resources to address findings and implement corrective actions. In severe cases, healthcare organizations may be temporarily or permanently barred from operations until compliance is achieved, causing interruptions to patient care and service delivery.
- **Reputational Damage**: Organizations found to be non-compliant with HIPAA regulations risk their reputation. News of data breaches or regulatory penalties spreads quickly, eroding public trust and confidence. Patients may choose to take their business elsewhere, and partners may sever ties, leading to long-term reputational harm.
- **Financial Losses**: Beyond fines, legal fees, and operational disruptions, organizations face additional financial losses because of lost business and the costs of implementing remedial measures. For many healthcare providers, the financial burden of non-compliance can be devastating, affecting their ability to invest in other critical areas, such as technology and patient care.
## Key HIPAA Security Requirements
To maintain compliance, healthcare organizations must adhere to specific HIPAA cybersecurity requirements. These include administrative, physical, and technical safeguards, along with regular threat analysis and workforce training.
### Administrative Safeguards
Administrative safeguards form the backbone of a healthcare organization’s HIPAA strategy. These measures involve assigning a dedicated security officer responsible for overseeing compliance efforts. This individual ensures that all policies and procedures are developed, implemented, and regularly updated to align with regulatory requirements. Regular assessment of processes is another critical component, allowing organizations to identify potential vulnerabilities and take proactive steps to mitigate them.
By focusing on these safeguards, healthcare entities can create a structured framework for managing HIPAA compliance effectively. Explore our solutions for conducting security audits.
### Physical Safeguards
Physical safeguards are essential for securing the physical access to systems and facilities where ePHI is stored. Healthcare organizations must implement robust access control measures, such as locks, keycards, and surveillance systems, to prevent unauthorized personnel from accessing sensitive data.
Facilities and equipment should protect against environmental hazards, such as fire or water damage. Proper disposal protocols for devices and media containing patient data are also crucial, ensuring that sensitive information is irretrievably destroyed when no longer needed.
### Technical Safeguards
Technical safeguards focus on the technological measures required to protect sensitive data. Encryption is a vital tool for ensuring that data remains secure during transmission and storage, rendering it inaccessible to unauthorized individuals. Access controls, including unique user IDs and strong password policies, restrict system access to authorized personnel.
Audit controls are equally important, enabling organizations to track and monitor all activities involving ePHI. These measures collectively provide a comprehensive defense against cyber threats and data breaches. Learn how these safeguards support healthcare network security.
### Risk Analysis and Management
Analysis and management are ongoing processes that play a critical role in HIPAA compliance. Organizations must conduct regular risk assessments to identify potential threats to patient information.
Once identified, these vulnerabilities should be evaluated based on their likelihood and impact, allowing organizations to prioritize mitigation strategies. Effective management ensures that resources are allocated efficiently, reducing the likelihood of breaches and other security incidents.
### Workforce Training and Management
Workforce training and management are essential for ensuring that all employees understand their roles and responsibilities under HIPAA. Regular training sessions should cover key topics, such as data privacy, security protocols, and incident response procedures.
By fostering a culture of compliance, organizations can minimize human error, which is often a significant factor in data breaches. Clear policies and disciplinary measures should be in place to address non-compliance and reinforce the importance of adhering to HIPAA standards.
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## 5 HIPAA Best Practices for Security Teams
### 1\. Conduct Risk Analysis and Management
Regularly conducting risk analysis is a foundational best practice for ensuring HIPAA compliance. This process involves systematically identifying and evaluating potential threats to ePHI. Organizations should document their findings and develop targeted strategies to mitigate liability. By staying proactive, security teams can address vulnerabilities before they result in data breaches or other security incidents. Check out our strategies for continuous compliance.
### 2\. Implement Technical and Physical Safeguards
Implementing robust technical and physical safeguards is essential to protect patient data from unauthorized access and environmental threats. Encryption technologies should be deployed to secure data during storage and transmission, ensuring that sensitive information remains confidential even if intercepted.
Firewalls, intrusion detection systems, and access controls provide additional layers of defense against cyber threats. Physical safeguards, such as workstation and device security, controlled access to facilities, and server rooms, are equally critical for maintaining security.
### 3\. Train Employees on HIPAA Regulations
Employee training is a key component of a strong HIPAA compliance program. All staff members, from administrative personnel to IT teams, should understand their responsibilities regarding data privacy and security. Training programs should include real-world scenarios and emphasize the importance of safeguarding ePHI. Regular updates to training materials ensure employees remain informed about new regulations and emerging threats.
### 4\. Develop and Enforce Policies and Procedures
Clear and enforceable policies provide a framework for handling ePHI securely and consistently. Organizations should develop comprehensive policies covering data access, usage, and disposal. These policies should be regularly reviewed and updated to address changes in technology, regulations, or organizational structure. Enforcing these policies through monitoring and disciplinary actions reinforces their importance and ensures compliance across the workforce.
### 5\. Monitor and Audit Compliance
Continuous monitoring and auditing are crucial for maintaining a HIPAA-compliant system. Organizations should use advanced monitoring tools to track access to ePHI and detect suspicious activities in real time. Regular audits help identify gaps in compliance and provide opportunities for improvement. By maintaining a vigilant approach, security teams can ensure that their systems and practices remain aligned with HIPAA data security requirements.
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HHS Proposes Strengthened HIPAA Security Rule
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https://www.hipaajournal.com/hhs-strengthened-hipaa-security-rule/
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healthcare cybersecurity HIPAA
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# HHS Proposes Strengthened HIPAA Security Rule
The White House has cleared the HIPAA Security Rule update proposed by the U.S. Department of Health and Human Services. A draft version of the Notice of Proposed Rulemaking (NMPR) was published on Friday and is due to be added to the Federal Register on January 6, 2025. The HHS is seeking comments on the proposed rule from HIPAA-regulated entities, healthcare industry stakeholders, and the public. The comment period will be open for 60 days following the date of publication of the NMPR in the Federal Register.
This is the first major update to the HIPAA Security Rule in over a decade and follows the January 2023 publication of the HHS Healthcare and Public Health Sector Cybersecurity Performance Goals. The purpose of the voluntary goals is to encourage healthcare organizations to enhance cybersecurity but as the HHS explained in its December 2023 Healthcare Sector Cybersecurity concept paper, voluntary goals alone would be unlikely to be sufficient to drive the behavioral changes needed across the sector to enhance cybersecurity.
The purpose of the original HIPAA Security Rule was to ensure that healthcare organizations implement security policies, procedures and safeguards to ensure the confidentiality, integrity, and availability of electronic health information. The Security Rule was written to be technology agnostic to ensure it would remain relevant for years without requiring regular updates to account for technological advancements. The Security Rule was also written to be flexible to ensure it was applicable to organizations of different types and sizes. As such, the HIPAA Security Rule does not specify the technologies that should be used to secure ePHI, and many of the implementation specifications in the original Security Rule are addressable rather than required elements.
Since the HIPAA Security Rule was enacted, there have been considerable advances in technology and cybersecurity, and there is now a pressing need to improve cybersecurity due to the massive increase in cyberattacks on the healthcare and public health sector. “Cyberattacks continue to impact the health care sector, with rampant escalation in ransomware and hacking causing significant increases in the number of large breaches reported to OCR annually. The number of people affected every year has skyrocketed exponentially, a number we expect to grow even bigger this year with the Change Healthcare breach, the largest breach in our health care system in U.S. history,” said OCR Director Melanie Fontes Rainer. “This proposed rule to upgrade the HIPAA Security Rule addresses current and future cybersecurity threats. It would require updates to existing cybersecurity safeguards to reflect advances in technology and cybersecurity, and help ensure that doctors, health plans, and others providing health care meet their obligations to protect the security of individuals’ protected health information across the nation.”
In the past five years, OCR has seen a 102% increase in reports of large data breaches (500 or more records), while the number of individuals impacted by those data breaches has increased by a staggering 1002%. The massive increase in victims of data breaches is largely due to an 89% increase in hacking incidents and a 102% increase in ransomware incidents since 2019. In 2023, 167 million individuals were affected by healthcare data breaches and this year the total is higher still. As of 30 November 2024, more than 180 million individuals have had their personal and protected health information exposed or impermissibly disclosed in large healthcare data breaches.
The 393-page proposed HIPAA Security Rule update – _The HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information_ – includes specific measures that must be implemented by HIPAA-covered entities (healthcare providers, health plans, healthcare clearinghouses) and their business associates to strengthen cybersecurity protection for individuals protected health information.
OCR investigates all large healthcare data breaches, and those investigations and past audits have highlighted common deficiencies in HIPAA Security Rule compliance, especially the risk analysis requirement. The proposed rule addresses these common areas of noncompliance, as well as changes to the environment where healthcare is provided since the original Security Rule was published, the latest cybersecurity guidelines, best practices, methodologies, procedures, and processes to improve protections against external and internal threats, and court decisions that have affected enforcement of the HIPAA Security Rule.
## Key Requirements of the Proposed HIPAA Security Rule Update
The proposed HIPAA Security Rule update revises definitions and implementation specifications to reflect changes in technology and terminology and removes the distinction between required and addressable implementation specifications, which will all be required, with limited exceptions. All Security Rule policies, procedures, plans, and analyses must be documented by HIPAA-regulated entities, and the update adds specific compliance time periods for many of the existing Security Rule requirements.
**Technology asset inventory and network map** – The development and revision of a technology asset inventory and network map illustrating the movement of ePHI throughout the regulated entity’s electronic information systems on an ongoing basis, but at least every 12 months and following any change to the regulated entity’s environment or operations that may affect ePHI.
**Risk analysis** – Greater specificity for conducting a risk analysis, which must include a review of the technology asset inventory and network map, the identification of all reasonably anticipated threats to the confidentiality, integrity, and availability of ePHI, the identification of potential vulnerabilities and predisposing conditions to the regulated entity’s relevant electronic information systems, and an assessment of the risk level for each identified threat and vulnerability, based on the likelihood that each identified threat will exploit the identified vulnerabilities.
**Annual Security Rule compliance audits** – HIPAA-regulated entities will be required to conduct a HIPAA Security Rule compliance audit at least every 12 months.
**Contingency planning and security incident response** – Establish written procedures for restoring electronic information systems and data within 72 hours; conduct an analysis of the relative criticality of electronic information systems and technology assets to establish the restoration priority; establish written security incident response plans and procedures on how workforce members can report potential or known security incidents; establish written procedures on how the entity will respond; implement written procedures for testing and revising incident response plans.
**Enhanced security measures** – with limited exceptions, HIPAA-regulated entities would be required to implement the following security measures:
- Encryption of all ePHI at rest and in transit
- Multi-factor authentication
- Network segmentation
- Vulnerability scanning at least every 6 months
- Penetration tests at least every 12 months
- Anti-malware protection
- Removal of extraneous software from relevant electronic information systems
- Disable network ports in accordance with the regulated entity’s risk analysis.
- Separate technical controls for backup and recovery of ePHI and relevant electronic information systems.
- Review and test the effectiveness of certain security measures at least once every 12 months
**Notification Requirements** – Require notification of certain regulated entities within 24 hours when a workforce member’s access to ePHI or certain electronic information systems is changed or terminated. Business associates must notify covered entities when they have implemented their contingency plans without unnecessary delay and no later than 24 hours after the contingency plan has been implemented.
**Annual verification of business associates’ and contractors’ technical safeguards** – At least every 12 months, business associates must have a subject matter expert verify that they have deployed the technical safeguards required by the Security Rule to protect ePHI. The same applies to business associates’ contractors for their business associates.
**Group health plans must stipulate that health plan sponsors must implement Security Rule safeguards** – Group health plans must include in their plan documents requirements for their group health plan sponsors that they must comply with the administrative, physical, and technical safeguards of the Security Rule; ensure any agent’s provided with ePHI implement administrative, physical, and technical safeguards of the Security Rule, and that they must notify their group health plans upon activation of their contingency plans without unreasonable delay, but no later than 24 hours after activation.
The proposed Security Rule update will be added to the Federal Register before President Trump is inaugurated; however, it will be down to the Trump-Vance administration to decide whether or not to move forward with the Security Rule update. There is bipartisan support for increased cybersecurity requirements for the healthcare sector, although progress may be slow. President Trump is keen to eliminate rather than introduce new regulations and recently stated that ten old regulations will need to be removed for every new one implemented. Anne Neuberger, Deputy National Security Advisor for Cyber and Emerging Technologies, said the estimated cost of implementation of the Security Rule update will be $9 billion in the first year, plus $6 billion over the following four years.
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HIPAA to be updated with cybersecurity regulations, White House says
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https://therecord.media/hipaa-cybersecurity-regulations-update
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healthcare cybersecurity HIPAA
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# HIPAA to be updated with cybersecurity regulations, White House says
New cybersecurity rules covering how healthcare institutions protect user data will be proposed under the Health Insurance Portability and Accountability Act (HIPAA), according to a White House official.
“The security rule \[under HIPAA\] was first published in 2003 and it was last revised in 2013, so this is the first update to this 20-year rule in over a decade, and it will require entities who maintain healthcare data to do things like encrypt that data so if attacked, it cannot be leaked on the web and endanger individuals,” Anne Neuberger, deputy national security adviser for cyber and emerging technology, told reporters Friday.
The Department of Health and Human Services (HHS) will publish a draft of the updated rules in the Federal Register for public comment, Neuberger said.
Healthcare entities also will have to monitor their networks for threats and do compliance checks to see whether they are abiding by the new HIPAA rules, according to Neuberger, who added that the White House believes the implementation cost of the proposed rule for the healthcare industry would be about $9 billion in the first year and $6 billion annually for years two to five.
“The cost of not acting is not only high, it also endangers critical infrastructure and patient safety, and it carries other harmful consequences,” she explained.
HIPAA was initially signed into law in 1996 and governs how healthcare data is shared by hospitals, insurers and patients. Neuberger said the new rules would add “clarity and specificity” about cybersecurity to HIPAA.
The White House decided to embark on the effort in recent months due to a five-year increase in healthcare data breaches capped by a 2024 that saw two of the most significant healthcare incidents in U.S. history with the ransomware attacks on Change Healthcare and the Ascension hospital network.
Neuberger argued that while the average cost of a healthcare breach in 2023 was $10.1 million, organizations like Ascension and Change Healthcare are facing potentially disastrous losses. The parent company of Change Healthcare, UnitedHealth Group, estimated that the February incident cost the company upwards of $850 million.
“Since 2019, large breaches caused by hacking and ransomware have increased 89% and 102% and I must say, in this job, one of the most concerning and really troubling things we deal with is hacking of hospitals, hacking of healthcare data,” she said.
“We see hospitals forced to operate manually. We see American sensitive healthcare data, sensitive mental health data, sensitive procedures, being leaked on the dark web with the opportunity to blackmail individuals with that.”
One year ago, HHS added cybersecurity rules for healthcare institutions that deal with the Medicare and Medicaid programs, ostensibly tying federal payments to baseline standards. At the time, HHS floated the idea of adding cybersecurity measures to HIPAA — with one concept centering around increasing civil monetary penalties for HIPAA violations like breaches.
The White House moves have been backed by members of Congress who are exasperated by the continued shutdown of hospitals from ransomware and the nationwide implications of the Change Healthcare breach — which the company said exposed the information of more than 100 million people.
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Financial Services Cybersecurity: 2024 Performance in Banking ...
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https://www.picussecurity.com/resource/blog/financial-services-cybersecurity-performance-2024
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financial services security
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# Financial Services Cybersecurity: 2024 Performance in Banking, Financial Services, and Insurance (BFSI)
## Prevention, Detection, and Alert Scores in Financial Services
Cybersecurity operations in the **financial services** sector are developing rapidly, and it is bringing challenges and improvement opportunities together. Based on the **Picus Blue Report 2024**, this blog post discusses the finance sector's threat prevention and detection capabilities, identifying gaps and suggesting critical areas for improvement. The BFSI industry, which deals with highly sensitive financial data, has achieved significant effectiveness scores in prevention, among other sectors. However, areas such as the widening gap between log scores and actionable alerts and the vulnerability to advanced threats like ransomware remain concerning and require further analysis and improvement.
## Cybersecurity Gaps and Gains in Financial Services for 2024
According to the McKinsey 2023 Cybersecurity in Financial Services repor t, only 31% of financial organizations feel confident in their ability to meet emerging cybersecurity challenges but still need to prove their security readiness to avoid incidents. The question that follows this statistic is, "Is this level of confidence being validated?" Although organizations in finance have confidence in being threat-centric, it is important to validate their risk to ensure an improved security posture. The Blue Report shows that 3 out of 10 financial organizations still face problems with prevention.
In 2024, the BFSI sector showed a slight increase in **prevention effectiveness**, with the score moving from **67% to 68% on the Blue Report**. While this is a positive improvement, it is not enough to make cybersecurity and risk leaders confident in this field because of the increasing sophistication of cyberattacks targeting financial institutions.
Financial institutions manage highly sensitive data, making robust prevention mechanisms critical. Even though it is encouraging to see the sector improve in this field, the small gains are not enough to fight against the growing number of sophisticated cyber threats, particularly those from state-sponsored groups and advanced persistent threats (APTs).
Graph 1. Prevention Effectiveness Score by Industry
### Better Logging or Better Alerting? Which to Pick for Financial Services
An important factor driving expectations for improved detection effectiveness is the increased investment in the finance IT sector. According to Gartner's 2023 Global Security and Risk Management forecast, end-user spending on security is projected to reach $215 billion in 2024, a 14.3% rise from 2023. This is reflected in a steady increase in security budgets as a share of overall IT spending, growing from 8.6% in 2020 to 11.6% today. For CISOs and security leaders, the challenge is how to translate this increased investment into better prevention and detection capabilities, ensuring teams are empowered to effectively reduce cyber risks. Given the need and speed of digital transformation in financial firms, it would not be wrong to say that the rate of increase in investment in cybersecurity will be higher.
The expected output detection posture that naturally occurs after increasing investments is to improve and move forward, but despite the current increasing budgets, when we look at the statistics in Blue Report 2024, despite the improvement in the logging score, the decrease in the alert system score that enables SOC teams to receive information about potential critical threats is a big problem for leaders managing budgets. With most boardrooms now recognizing the importance of investing in cybersecurity, we expect further growth in the budget increases mentioned, and it will result in an increasing need for security leaders to demonstrate the effectiveness of their security controls, deliver continual improvements, and achieve the best return from budgets by validating their exposures.
The BFSI sector has made **substantial improvements in logging capabilities**, increasing its log score from **34% in 2023 to 50% in 2024**. This improvement reflects dedicated attention to logging security events and ensuring real-time monitoring of potential cybersecurity threats for financial services. While recording and logging everything is valuable for any post-incident evaluation or system improvement, the decline in the alert score is still a major concern. Despite improved logging, the BFSI sector has experienced a **significant drop in alert scores, from 18% to 6%**. This underlines a widening gap between detecting threats and responding to them effectively. Critical threats could go unnoticed without proper alerts, exposing financial organizations.
Alerts that are not generated by comprehensive logging will cause visibility problems, causing SOC teams to not quickly identify incidents and take appropriate action to respond to and mitigate the threat. Financial organizations should consider continuously improving their detection posture, so the ultimate goal should be to collect the right log and then generate meaningful alerts that do not overwhelm the SOC.
Graph 2. Log Score by Industry
Another research by Picus Labs, Red Report 2024, also reveals a 333% increase in malware that targets and disables security controls. Dr. Suleyman Ozarslan, Picus Security Co-founder and VP of Picus Labs, characterizes these threats as hunter-killer submarines since this malware is ultra-evasive and highly aggressive. The Picus Labs team found another key finding in the Picus Blue Report 2024, which was that **40% of tested environments** were vulnerable to domain admin access. When we consider the drastic shift in adversaries' ability to identify and neutralize advanced enterprise defenses, it means a critical threat that could go undetected if the log-alert gap isn't closed in BFSI organizations.
Graph 3. Alert Score by Industry
### The Growing Threat of Ransomware in Financial Services
Ransomware remains a top concern for financial institutions, and the **Picus Blue Report 2024** revealed that **BlackByte ransomware** was the most difficult to defend against, with only a **17% prevention rate**.
**Sophos' State of Ransomware in Financial Services 2023** report indicates that ransomware incidents in financial services are among the **most costly** cyberattacks, with attacks becoming increasingly **sophisticated** and more complex to detect, echoing what Picus Labs found in Picus Red Report 2024 after analyzing more than 600,000 real-world malware samples.
Graph 4. Least Prevented Ransomware Group
### Key Recommendations for Financial Services Cybersecurity
More spending does not translate into enhanced security posture. To enhance threat detection and prevention, **financial institutions** should focus on:
1. **Implement** **Continuous Threat Exposure Management (CTEM)** **:** Adopt a holistic approach to cybersecurity that helps security teams focus on the exposures that will impact risk reduction most effectively.
2. **Start alert and log validation:** Simulate real-world threats to address major log and alert management challenges and transform SOC processes for proactively tackling advanced threats.
3. **Rationalize cybersecurity spending:** Validate security controls to ensure all devices are secure. Maximize ROI on security investments through exposure validation before new investments.
4. **Know your risk level:** By **simulating real-world attack scenarios**, BFSI organizations can identify vulnerabilities before they are exploited, ensuring the security of financial transactions. Continuously validate your risk with real-world simulations prioritized within your regulatory and business context.
The BFSI sector has made significant progress in logging and prevention, but the growing gap between logging and detection remains a significant concern. As threats become more complex, financial institutions must prioritize investments in exposure validation and continuous threat exposure management to strengthen their prevention and detection capabilities.
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Information Technology (IT) and Cybersecurity FDIC.gov
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https://www.fdic.gov/banker-resource-center/information-technology-it-and-cybersecurity
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financial services security
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## **Laws and Regulations**
Key laws and regulations that pertain to FDIC-supervised institutions; note that other laws and regulations also may apply.
- Appendix A to Part 364 — Interagency Guidelines Establishing Standards for Safety and Soundness provide operational and managerial standards that address internal controls and information systems
- Appendix B to Part 364 — Interagency Guidelines Establishing Information Security Standards address administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information
- Section 304.3(d) — Reports addresses requirements for regulatory notification of certain service provider relationships
- Computer-Security Incident Notification Final Rule establishes notification requirements for significant computer-security incidents for banking organizations and their bank service providers. FDIC-supervised banks can comply with the rule by reporting an incident to their case manager or to any member of an FDIC examination team if the event occurs during an examination. If a bank is unable to access its supervisory team contacts, the bank may notify the FDIC by email at: incident@fdic.gov.
- Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice, Supplement A to Appendix B, describes elements of a response program, including customer notification procedures
- The Bank Service Company Act (PDF)") establishes FDIC regulation and examination authority over certain service providers. Section 7(c)(2) requires institutions to notify the FDIC within 30 days of service relationships with third parties that provide certain services as defined in Section 3 ( Notification of Performance of Bank Services (PDF)") form).
## **IT Examination Resources**
IT examination ratings, procedures, and work programs.
- Information Technology Risk Examination (InTREx) Program outlines risk-focused examination procedures used to assess IT and cybersecurity risks
- Uniform Rating System for Information Technology (PDF)") describes the internal rating system used by federal and state regulators to uniformly assess financial institution and service provider risks introduced by IT
- Federal Financial Institutions Examination Council (FFIEC) Information Technology (IT) Examination Handbook provides guidance to examiners for evaluating financial institution and service provider risk management processes
## **Supervisory Resources**
Frequently asked questions, advisories, statements of policy, and other information issued by the FDIC alone, or on an interagency basis, provided to promote safe-and-sound operations.
- Cybersecurity
- FFIEC Cybersecurity Resource Guide for Financial Institutions (PDF)") provides updated references and ransomware-specific resources
- Heightened Cybersecurity Risk Considerations (PDF)") focuses on risk management principles that can reduce the risk of a cyber-attack and minimize business disruptions for the financial services industry and other critical business sectors
- FFIEC Encourages Standardized Approach to Assessing Cybersecurity Preparedness emphasizes the benefits of using a standardized approach to assess and improve cybersecurity preparedness.
- Cyber Insurance and Its Potential Role in Risk Management Programs (PDF)") provides awareness of the potential role of cyber insurance in financial institutions’ risk management programs.
- FFIEC Cybersecurity Assessment Tool assists institutions with identifying cybersecurity risks and determining preparedness
- Frequently Asked Questions (PDF)") provide information related to the FFIEC Cybersecurity Assessment Tool
- IT Security
- FFIEC Joint Statement on Risk Management for Cloud Computing Services addresses the use of cloud computing services and security risk management principles in the financial services sector.
- FFIEC Joint Statement on Destructive Malware (PDF)") alerts financial institutions to specific risk mitigation techniques related to destructive malware
- FFIEC Joint Statement on Compromised Credentials (PDF)") alerts financial institutions to specific risk mitigation techniques related to cyber attacks that compromise credentials
- Vulnerability Alerts: GNU Bourne-Again Shell (Bash) Vulnerability (PDF)") and OpenSSL “Heartbleed” Vulnerability (PDF)") advise of material security vulnerabilities
- Distributed Denial of Service (DDoS) Attacks (PDF)") outlines the risks posed by continued DDoS attacks on public-facing web sites
- Guidance on Mitigating Risk Posed by Information Stored on Photocopiers, Fax Machines and Printers provides information about the risk associated with sensitive information stored on these devices
- Guidance on the Security Risks of VoIP addresses the delivery of traditional telephone voice communications over the Internet
- Guidance on Mitigating Risks from Spyware provides recommendations to prevent and detect spyware on bank computers and outlines practices that customers can use to ensure security of the online banking relationship
- Guidance on How Financial Institutions Can Protect Against Pharming Attacks describes the practice of “pharming,” how it occurs, and potential preventative approaches
- Guidance on Developing an Effective Computer Software Evaluation Program to Assure Quality and Regulatory Compliance discusses due diligence when selecting computer software or a service provider
- FFIEC Guidance on Risk Management of Free and Open Source Software is a supplement to the FFIEC Development and Acquisition handbook
- Interagency Informational Brochure on Internet “Phishing” Scams helps consumers identify and combat “phishing” scams
- Guidance on the Risks Associated With Instant Messaging includes information about how risks associated with publicly available instant messaging can be mitigated
- Guidance on Developing an Effective Computer Virus Protection Program provides information on the risks associated with computer viruses and how these risks can be mitigated
- Guidance on Safeguarding Customers Against E-Mail and Internet-Related Fraudulent Schemes describes how financial institutions can assist in protecting their customers
- Guidance on Developing an Effective Software Patch Management Program provides information about how to mitigate risks from commercial software vulnerabilities
- Guidance on the Risks Associated with Weblinking outlines useful risk-management techniques for institutions that develop and maintain their own websites, as well as for those that use third-party service providers for that function
- Managing Risks Associated with Wireless Technology and Wireless Customer Access addresses the potential compromise of customer information and risk mitigation
- Guidance on Identity Theft and Pretext Calling provides a summary of federal laws for these topics, discusses steps to protect customer information, and highlights the importance of consumer education
- Protecting Internet Domain Names alerts bank management to potential domain name-related problems
- Risks to Financial Institutions Involving Client/Server Computer Systems outlines fundamental controls associated with the client/server environment
- Authentication
- Authentication and Access to Financial Institution Services and Systems (PDF)") sets forth examples of effective authentication and access risk management principles and practices for financial institution systems and digital banking services.
- Identity Theft
- Supervisory Policy on Identity Theft describes steps that can be taken to detect and prevent identity theft and mitigate the effects in order to protect consumers and help ensure institutions’ safe-and-sound operations
- Frequently Asked Questions provide responses relating to identity theft red flags, address discrepancies, and change of address requests
- FDIC Study Supplement on “Account-Hijacking” Identity Theft identifies trends in identity theft in general and account hijacking in particular
- Third-Party Relationships
- Third-Party Risk Management, A Guide for Community Banks (PDF)") helps community banks implement third-party risk management programs
- Interagency Guidance on Third-Party Relationships: Risk Management provides sound principles that support a risk-based approach to third-party risk management.
- Conducting Due Diligence on Financial Technology Companies: A Guide for Community Banks (PDF)") helps community banks conduct due diligence when considering relationships with financial technology (fintech) companies.
- Technology Service Provider Contracts describes examiner observations about gaps in financial institutions’ contracts with service providers that may impact business continuity and incident response plans
- Payments
- Statement on Cybersecurity of Interbank Messaging and Wholesale Payment Networks (PDF)") advises institutions to actively manage the risks associated with these services
- Clarification of Supervisory Approach to Institutions Establishing Account Relationships with Third-Party Payment Processors and related guidance on payment processor relationships to address risk management principles, potential risks, and the facilitation of payment processing services
- Statement on ATM and Card Authorization Systems (PDF)") describes risks related to cyber-attacks
- Risk Management of Remote Deposit Capture (PDF)") addresses risk identification, assessment, and mitigation, and the measurement and monitoring of residual risk exposure
- Business Continuity Management
- Sound Practices to Strengthen Operational Resilience provides a comprehensive approach that banks may use to strengthen and maintain their operational resilience.
- Statement on Pandemic Planning (PDF)") highlights the importance of business continuity planning to help minimize the disruption of services
- Major Disaster Examiner Guidance (PDF)") outlines supervisory practices used to assess the financial condition of insured depository institutions affected by a disaster that results in the President declaring an area a major disaster with individual assistance
- Lessons Learned from Hurricane Katrina is a compilation of experiences that may be helpful in preparing for a catastrophic event
- Interim Sponsorship Policy for Government Emergency Telecommunications Service (GETS) Cards describes circumstances under which qualifying private sector financial institutions may request federal sponsorship in the Cybersecurity and Infrastructure Security Agency’s Government Emergency Telecommunications Service (GETS)
## **Other Resources**
Supplemental information related to safe-and-sound banking operations.
- FFIEC Industry Outreach Website provides resource materials on current issues in the financial industry, including Information Technology and Cybersecurity
- FFIEC Cybersecurity Awareness Website provides resources to increase awareness of cybersecurity risks and to assess and mitigate cybersecurity risks
- NIST Cybersecurity Framework Website provides information on a voluntary cybersecurity framework developed by the National Institute of Standards and Technology
- Technology Outsourcing: Informational Tools for Community Bankers provides resources for selecting service providers, drafting contract terms, and providing oversight for multiple service providers
## **Technical Assistance Video Program**
The Technical Assistance Video Program is a series of educational videos designed to provide useful information to bank directors, officers, and employees on areas of supervisory focus and regulatory changes. These videos are available on the FDIC’s YouTube channel.
- Cybersecurity Awareness for Board Members provides background information on cybersecurity and discusses the board’s role in overseeing their bank’s cybersecurity efforts.
- Cybersecurity Awareness for Bank Officers discusses the important role bank officers have in designing and maintaining information security programs in a dynamic and evolving cyber threat environment.
- Information Technology provides information for bank directors and trustees regarding oversight of a bank’s information technology program and FDIC information technology examinations.
- Cyber Challenge: A Community Bank Cyber Exercise encourages community financial institutions to discuss operational risk issues and the potential impact of information technology disruptions on common banking functions.
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The Importance of Security Automation in Financial Services
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https://www.bitlyft.com/resources/the-importance-of-security-automation-in-financial-services
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financial services security
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# The Importance of Security Automation in Financial Services
## The Importance of Security Automation in Financial Services
As cyber threats evolve, financial services organizations must adopt security automation to protect sensitive data, streamline operations, and stay compliant with regulations. Automation enables financial institutions to detect, respond to, and mitigate security threats in real-time, reducing human error and improving operational efficiency. By leveraging automated systems, financial services can proactively manage risks while focusing on core business functions.
## Proactive Threat Detection and Rapid Response
Security automation allows financial institutions to continuously monitor their networks for suspicious activity, triggering instant alerts and automated responses. This rapid response minimizes the impact of cyberattacks and ensures that threats are neutralized before they escalate. Automation eliminates the delays associated with manual processes, giving institutions a critical edge in their cybersecurity strategy.
## Did You Know?
> Did you know that financial institutions using automated security systems reduce their response times to threats by up to 80%, significantly limiting the impact of cyberattacks?
## Compliance and Operational Efficiency
Automated security tools also help financial services meet compliance requirements by generating detailed reports and audit logs. Automation reduces the manual workload on security teams, allowing them to focus on higher-level tasks such as strategic planning and risk management. With automated incident management, financial institutions can ensure uninterrupted operations and enhanced customer trust.
## Enhancing Financial Security with BitLyft AIR®
BitLyft AIR® provides advanced security automation solutions that enable financial institutions to manage threats efficiently and stay compliant with regulations. From real-time threat detection to automated incident response, BitLyft AIR® enhances security and ensures operational resilience. Learn more about how BitLyft AIR® can support your financial services at BitLyft AIR® Security Automation.
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11 Cyber-Security Compliance Regulations for Financial Services
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https://www.metomic.io/resource-centre/financial-services-compliance-regulations
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financial services security
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### **TL;DR:**
Financial services face unprecedented regulatory scrutiny, with over 75% of European compliance leaders reporting a 35% rise in their compliance workload in the past year (Dun & Bradstreet, Aug 2024). In the UK, 36% of firms received penalties for non-compliance in 2023 (Davies, July 2024). Regulatory shifts like the FCA's Consumer Duty have driven 63% of financial institutions to overhaul customer service models. To stay competitive, organizations must implement efficient KYC processes, strengthen AML safeguards, and enhance data protection through technology-driven compliance solutions.
## What Are the Core Compliance Regulations in Financial Services?
Financial institutions operate under strict regulatory frameworks to prevent financial crime, safeguard consumer data, and promote transparency. Key global regulations include:
- **GDPR** – European regulation governing personal data processing and protection
- **AML Directives** – Laws requiring firms to detect and report suspicious financial activities
- **KYC Requirements** – Mandates verifying clients' identities to prevent fraud and money laundering
- **Basel III** – Guidelines for capital reserves and market liquidity requirements
- **FCA Standards** – UK-focused oversight ensuring fair financial practices and consumer protection
## Why Is Compliance Essential in Financial Services?
Failing to comply with regulations can lead to severe financial, reputational, and operational consequences:
- Hefty fines from regulators and enforcement agencies
- Loss of customer trust due to perceived negligence
- Increased regulatory audits and operational delays
A 2024 report found that 62% of UK consumers are less likely to trust a financial provider after a compliance breach (EY, March 2024).
## How Are Financial Institutions Overcoming Regulatory Pressures?
To navigate increasingly complex compliance obligations, firms are:
- Automating compliance processes using AI-powered regulatory technology
- Upskilling teams to keep pace with evolving compliance requirements
- Working with third-party compliance advisors to ensure accuracy and completeness
With 48% of financial firms planning to increase compliance technology budgets in 2025 (PwC, Jan 2025), automation is becoming a key lever in effective risk management.
### Key points:
- Financial services organisations must comply with many cyber security-related regulations to protect sensitive customer data and maintain trust.
- Failing to comply with these regulations can lead to severe consequences, including fines, legal action, and reputational damage.
- There are many different regulations and **emerging threats** that financial institutions need to be aware of, depending on their location and the type of data they handle.
- Some best practices for maintaining compliance include conducting regular audits, having a dedicated compliance team, and investing in **data security software for finance companies, such as Metomic**.
**Operating within a highly regulated industry, financial services organisations must ensure they are complying with all the relevant regulations for their business.**
**Positive Technologies** report that Q3 2023 saw twice as many unique cyber incidents than the same quarter in 2022, within the financial services sector. Data leaks and disruption of processes came out as the top attacks seen across the industry.
Banks, insurance companies, and other financial institutions must take steps to protect sensitive customer data, but this isn’t the only reason compliance standards exist. There is also the added factor that any instability within the financial sector can lead to wide scale disruption across the economy too.
## What Are the 11 Cyber Security Compliance Regulations Financial Services Need to Know?
There are plenty of regulations financial services companies will need to adhere to, in order to function effectively, and mitigate the cyber risks to their business, including:
### 1\. How Does PCI DSS Compliance Impact Financial Organizations?
**PCI DSS 4.0** was founded by the major credit card companies in order to ensure that all companies handling such data do so in a secure environment.
This regulation requires companies to secure cardholder data by implementing features such as strong **access control** measures and firewalls, to ensure they are protecting cardholder data. Non-compliance can result in fines, increased transaction costs, and suspension of card payment acceptance.
### 2\. What Requirements Does the Gramm-Leach-Bliley Act (GLBA) Impose?
Financial companies in the US need to adhere to **GLBA** in order to protect sensitive financial information. Organisations must carry out risk assessments, implement comprehensive information security measures, and monitor their ecosystems for security risks. Without these essential processes, teams may find themselves facing regulatory penalties.
### 3\. How Does the Sarbanes-Oxley Act (SOX) Affect Financial Reporting?
**SOX** has been in place in the US since 2002, aiming to protect investors by improving the accuracy and reliability of corporate disclosures. Key compliance factors include financial controls, data accuracy, and accountability through auditing. As SOX applies specifically to investors, if an organisation is found to be non-compliant, it can result in a loss of investor confidence, and even imprisonment for the executives responsible.
### 4\. What Security Standards Does the Federal Financial Institutions Examination Council (FFIEC) Mandate?
FFIEC applies to the security of financial institutions’ tech systems. Organisations must enforce **multi-factor authentication (MFA)**, and have comprehensive incident response planning in place. Without these, companies can face an increased vulnerability to cyber attacks, as well as sanctions, and reputational damage.
### 5\. How Does the Dodd-Frank Act Strengthen Financial Regulation?
As a response to the 2008 financial crisis, Dodd-Frank addresses various aspects of financial regulation in US businesses. Risk management and an increased transparency in financial transactions should be priorities for organisations who must comply. If businesses don’t comply, it could lead to legal action, and the potential for financial instability.
### 6\. What Responsibilities Do Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) Regulations Create?
Another US regulation, BSA and AML regulations focus on detecting and preventing money laundering. To enforce this, due diligence and suspicious activity reporting are crucial, and non-compliance can lead to legal consequences, and an increased risk of financial crime.
### 7\. What Cybersecurity Requirements Does NYDFS Part 500 Establish?
Specific to financial institutions in New York, **NYDFS Part 500** protects organisations and their businesses within the city. It requires companies to establish a cybersecurity program and implement policies for data governance, as well as incident response planning. There are legal consequences and reputational damage for those that are negligent.
### 8\. How Does the Revised Payment Service Directive (PSD2) Enhance Payment Security?
This regulation aims to secure electronic payments within the EU, requiring organisations to enforce customer authentication for electronic payments, and implementation of secure communication channels. Non-compliance can lead to service disruptions and penalties for unauthorised transactions.
### 9\. What Security Standards Do Monetary Authority of Singapore Regulations (MAS) Require?
Singapore’s monetary authority imposes regulations in order to strengthen cybersecurity measures in financial institutions. Organisations must establish comprehensive cybersecurity procedures and ensure swift reporting of incidents to the MAS. If businesses are found to be non-compliant, they can be fined or face a suspension of their licenses.
### 10\. How Does the Federal Trade Commission (FTC) Safeguards Rule Protect Consumer Data?
The FTC Safeguards Rule puts a focus on protecting consumer information. Businesses must conduct regular risk assessments, and have dedicated individuals for safeguarding customer data. Without these in place, businesses can face reputational damage, penalties, and legal actions by affected consumers.
Compliance with these regulations is critical for financial institutions to maintain trust, protect sensitive data, and avoid legal and financial repercussions. Non-compliance can lead to severe consequences that impact both the institution and its stakeholders.
### 11\. What New Requirements Does the Digital Operational Resilience Act (DORA) Introduce?
**The Digital Operational Resilience Act (DORA)**, enacted as Regulation (EU) 2022/2554 is a new EU regulation aimed at ensuring the operational resilience of financial services organisations against digital threats. This regulation requires financial institutions to implement robust risk management practices for information and communications technology (ICT), including regular testing, incident reporting, and third-party risk management.
DORA mandates that companies are prepared to handle severe operational disruptions, ensuring business continuity and protecting against cyber threats. Non-compliance with DORA can result in substantial fines, regulatory scrutiny, and potential disruptions to services.
## What is financial cybersecurity compliance?
Financial cybersecurity compliance means abiding by the financial regulations set by authorities to secure the data within an organisation.
It can include data protection, securing transactions via encryption, planning for incident responses, and establishing compliance reporting to be able to audit your efforts.
## Why do financial services organisations have compliance regulations?
Organisations working within the financial services sector must comply with strict regulations to ensure that sensitive data such as bank details, credit card numbers, or transaction histories, are not accessed by unauthorised users. Regulations are often put in place by authorities such as governments who are looking to ensure the integrity of financial systems and keep customers protected.
There are many risks associated with storing financial information. For instance, cyber attacks can lead to the loss of sensitive financial data, putting customers at risk of identity fraud, and financial losses. If attacks are carried out across an entire organisation, customers can lose the ability to access their finances, leading to instability in the market.
Cyber attacks can also compromise intellectual property and company plans such as upcoming acquisitions, leading organisations to lose a competitive advantage in the marketplace.
Due to the widespread effects a cyberattack can have, **compliance** regulations are particularly important in the financial sector, resulting in penalties, legal battles, and reputational damage that may be insurmountable.
## Are there different regulations depending on where an organisation is located?
Yes, where an organisation is geographically based will have an impact on the regulations they need to abide by. For instance, PCI DSS is a global standard that will need to be followed, whereas the Securities and Exchange Commission (SEC) in the US will have their own requirements for financial institutions based there.
Organisations will need to be aware of the regulations they must adhere to, and the implications if they are unable to comply.
## Are there any further regulations on the horizon?
The SEC is planning on **introducing 25 new rules** in 2024, while businesses adhering to PCI DSS will need to prepare for Version 4.0 by March 2024.
To stay informed about upcoming regulations, organisations can engage with industry associations, follow updates from relevant regulatory bodies, and consult compliance experts to prepare for any new regulatory requirements that may impact their operations.
## How can financial services maintain compliance?
As the financial sector handles sensitive data on a daily basis, they are required to be proactive when it comes to compliance, allowing them ample time to prepare for any upcoming regulatory changes.
**Best practices for ensuring compliance include:**
1. Conducting **regular data security audits** of existing processes and policies, ensuring that data protection practices are still valid and efficient
2. Having a dedicated internal or external legal, privacy, or compliance team to stay up to date with the latest regulations
3. Investing in compliance or **data security software** that can enable your team to automate processes, and to streamline reporting, allowing you to run audits quickly and efficiently
4. Ensuring processes are in place to mitigate compliance risks, and ensure regulations are adhered to
5. Training your workforce to be aware of compliance standards, and providing support, should they need it
Without these practices in place, financial services organisations may not be able to fully comply with regulatory requirements, and may incur fines or penalties for non-compliance.
## Report: The State of Data Security in Financial Services
In our 2024 ‘ **The State of Data Security in Financial Services**’ report, we dissect our own proprietary data to understand how financial services companies are navigating data security. You'll find:
- The pivotal data types that hold significance for Financial Service Companies
- A comprehensive understanding of the risks posed by stale data and effective management strategies
- Compelling reasons why financial institutions should prioritise attention to access controls
## How Can Metomic Strengthen Your Compliance Program?
Metomic helps businesses maintain compliance with financial regulations in a number of ways:
### 1\. Data Discovery and Classification
Financial organisations use Metomic to accurately identify and classify sensitive data, such as PII, across SaaS, cloud, and GenAI productivity tools\- a critical component of compliance with data protection regulations.
### 2\. Granular Access Controls
Limiting the amount of access to sensitive data is key to minimising data exposure. Metomic helps teams **implement access controls** to ensure only authorised users can see confidential information.
### 3\. Real-time Monitoring and Reporting
With real-time monitoring and reporting capabilities, organisations can identify data sharing and user interactions within the company’s ecosystem.
### 4\. Custom Security Actionable Workflows
Setting tailored data protection policies allows Metomic users to enforce custom rules throughout the organisation, aligning the company to the nuanced demands of the financial industry.
Metomic’s **data security solution** can enhance a financial services organisation’s compliance posture and help to build a resilient framework for protecting sensitive data.
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Banking & Financial Data Security Compliance: 12 Best Practices
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https://www.syteca.com/en/blog/banking-and-financial-cyber-security-compliance
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financial services security
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Financial data has always been a prime target for cybercriminals due to its high value. Therefore, banks, loan services, credit unions, and investment and brokerage firms are highly vulnerable to cyberattacks. Moreover, security incidents in the financial sector are extremely costly (surpassed only by the healthcare industry), with the average total cost of a data breach reaching $6.08 million in 2024.
For efficient data security in the banking industry, you need to ensure proper compliance with the relevant cybersecurity standards, laws, and regulations, both local and international. In this article, we distill the main requirements and recommendations for the finance industry into twelve efficient best practices your organization can follow to ensure cybersecurity compliance.
## Why does cybersecurity compliance matter for finance?
Banks and financial institutions must constantly adjust their usual work processes and security controls to frequent cybersecurity landscape changes. With factors like teleworking, AI attacks, and the shift to the cloud, cybersecurity is becoming increasingly critical.
Financial institutions work with highly sensitive data such as personally identifiable information (PII) and financial records. Cybercriminals can compromise this data, use it for financial fraud, monetize it, or commit other malicious acts for their own benefit.
Following manufacturing at the top, finance is the second-most attacked industry, according to the X-Force Threat Intelligence Index 2024 by IBM Security.
To ensure secure operations and the proper protection of sensitive data, local and international regulatory bodies have established security compliance requirements for financial organizations.
Cybersecurity requirements for financial services companies can help you determine:
**1\. What should be protected** What pain points to pay attention to when building an organization’s cybersecurity strategy
**2\. How to improve cybersecurity** What practices and technologies to implement for better protection of the organization’s IT infrastructure and data.
Consequences of cybersecurity compliance and non-compliance
Pros of compliance
- Clear view of the most critical data and systems
- Better understanding of deployed cybersecurity tools and practices
- Enhanced protection of valuable information
- Timely response to cybersecurity incidents
Cons of non-compliance
- Operational disruptions
- Reputational damage
- Lawsuits and criminal responsibility
- Fines for non-compliance
- Financial losses caused by cybersecurity incidents
Fines for non-compliance can be extensive: the maximum GDPR penalty can reach up to €20 million (~$22 million), or up to 4% of the organization’s total global turnover of the preceding fiscal year, whichever is higher. For example, in 2024, Ireland’s Data Protection Commission (DPC) fined LinkedIn €310 million (~$335 million) for GDPR violations.
_What can you do to make sure your organization stays compliant?_
Organizations typically have to comply with more than one set of requirements. There are obligatory and advisory financial data security regulationsas well as international, federal, and regional laws. By following the requirements of all applicable banking cybersecurity regulations, laws, and standards, financial institutions can build advanced strategies to achieve the required level of cybersecurity.
It’s easy to get lost trying to find out which IT standards, regulations, and local laws are relevant to an organization. So what should financial industry players focus on?
In the next section, we’ll examine some of the key cybersecurity standards, laws, and regulations for banks and other financial institutions.
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## Key cybersecurity requirements for financial services companies
Compliance requirements have different purposes and different operational and jurisdictional areas for organizations operating within the financial sector. Let’s take a look at the major ones, starting with global cybersecurity standards.
### Global cybersecurity standards
There are three major international security standards in banking for financial institutions:
**PCI DSS**
A standard specifying requirements for handling and protecting credit card data.
Mandatory for organizations that process credit card data.
Penalties range from $5,000 to $100,000 per month.
**ISO/IEC 27001**
A standard for reducing security risks and protecting information systems.
Mandatory in some countries.
No penalties.
**SWIFT CSP**
A framework that helps financial institutions fortify their defenses against cyberattacks.
Mandatory and advisory requirements for SWIFT users.
No penalties.
#### PCI DSS
Any organization, institution, merchant, and payment solution provider must comply with the Payment Card Industry Data Security Standard (PCI DSS). This standard specifies requirements for storing, processing, and transferring payment card data. The goal of the standard is to reduce cases of credit card fraud and protect cardholder data.
#### ISO/IEC 27001
The International Organization for Standardization/International Electrotechnical Commission (ISO/IEC) 27001 standard is part of the large ISO/IEC 27000 family of cybersecurity standards. The 27001 standard provides recommendations and proper procedures for managing security risks, concerning financial information in particular. Although the standard is not mandatory, it’s highly recommended for financial institutions to pass the ISO 27001 certification audit.
#### SWIFT CSP
Any financial organization using SWIFT services must comply with SWIFT Customer Security Programme (SWIFT CSP)requirements. This framework specifies requirements for ensuring proper access management, incident response, and data security in financial services and banking.
In addition to global cybersecurity requirements, there are also country-specific ones.
### Local guidelines, laws, and directives
Some requirements vary from region to region. Let’s explore the most well-known:
**SOX**
A law mandating certain practices in financial record-keeping and reporting for corporations.
Mandatory in the US.
Penalties up to $5 million, imprisonment for up to 20 years.
**GLBA**
A law requiring financial institutions to protect customer data and notify customers about how their data is handled.
Mandatory in the US.
Penalties up to $100,000 per violation, imprisonment for up to 5 years.
**FINRA**
An organization governing the protection of customer data and promoting controls for detecting and mitigating cyber threats.
Mandatory for all brokers in the US.
Non-compliance can result in fines, suspensions, and imprisonment.
**PSD 2**
A directive regulating electronic payments, customer data security, and customer authentication.
Mandatory in the EU.
Penalties up to €20 million (~$22 million) or 4% of annual revenue (whichever is greater).
**BSA**
A law requiring financial institutions to detect and prevent money laundering and other financial crimes.
Mandatory in the US.
Penalties up to $250,000, imprisonment for up to 5 years.
**NIS2**
A directive aimed at strengthening cybersecurity across critical EU entities, including banks and other financial institutions.
Mandatory for organizations operating or providing services in the EU.
Penalties up to €10 million (~$10.9 million) or 2% of annual revenue (whichever is higher), along with potential management liability.
**DORA**
A regulation enhancing the operational resilience of financial institutions by requiring them to implement strict cybersecurity measures.
Mandatory for financial entities operating in the EU.
Penalties up to 2% of the organization’s total annual worldwide turnover or 1% of the average daily global turnover in the previous year, paid daily for up to half a year until compliance is achieved.
#### SOX
The Sarbanes Oxley Act (SOX) contains recommended practices that can prevent organizations from processing fraudulent financial transactions. In particular, it specifies what financial records should be stored, for how long, and how they need to be protected. This law is applicable to all public companies registered by the US Securities and Exchange Commission (SEC).
#### GLBA
The Gramm–Leach–Bliley Act (GLBA) is a US law that governs the way financial institutions handle customers’ private data. In particular, it requires companies to establish strict data access policies and provide customers with full information on how their data is stored, processed, and secured.
#### FINRA
The Financial Industry Regulatory Authority (FINRA) is an organization that provides guidelines and sets requirements for US broker-dealers. KeyFINRA requirements include maintaining written data protection policies to prevent the compromise of consumer data. FINRA also sets rules for detecting and mitigating cyber threats.
#### PSD 2
The Payment Services Directive (PSD 2) regulates electronic payments within the European Union. This EU directive contains requirements for the way electronic payments are initiated and processed and sets strict rules for the protection of consumers’ private data.
#### BSA
The Bank Secrecy Act (BSA), also known as the Currency and Foreign Transactions Reporting Act, is a US law that requires financial institutions to prevent and notify authorities about money laundering, terrorist financing, and tax evasion. BSA also requires banks to have incident response plans addressing cyber-related crimes.
#### NIS2
The Directive on the Security of Network and Information Systems 2 (NIS2) aims to strengthen the security of critical EU infrastructures. The Directive sets cybersecurity requirements for organizations vital for the EU economy across many industries, including banking and other financial institutions.
#### DORA
The Digital Operational Resilience Act (DORA) is a European Union regulation designed to strengthen the financial sector’s ability to withstand, respond to, and recover from ICT-related disruptions and cyber threats. DORA establishes uniform requirements for ICT risk management, incident reporting, and oversight of third-party service providers.
_Make sure you know your local cybersecurity laws and standards, as some states and municipalities may have their own, such as the New York Department of Financial Services (NYDFS) Cybersecurity Regulation and the California Consumer Privacy Act (CCPA)._
Industry-specific cybersecurity requirements are not the only ones that financial institutions should consider.
Learn more about
NIS2 Compliance with Syteca
### Other requirements to consider
In addition to industry-specific laws, regulations, and cybersecurity standards for the financial industry, there are other requirements that banks and financial institutions should pay special attention to. In particular, guidance from the National Institute of Standards and Technology and the General Data Protection Regulation is quite helpful for securing sensitive data, ensuring flawless operations, and avoiding expensive fines.
**NIST**
NIST is a US government organization that puts out a set of security standards and recommendations on cybersecurity risk management, data protection, threat detection, and incident response.
Mandatory for all federal entities in the US.
No penalties for non-governmental organizations.
**GDPR**
A security regulation governing the handling and protection of EU residents’ personal data.
Mandatory for financial services organizations processing personal data of EU residents.
Penalties up to €20 million (≈ $22 million) or 4% of annual turnover (whichever is greater).
#### NIST
The National Institute of Standards and Technology (NIST) is a US government agency that develops and oversees a variety of information security standards, including NIST 800-53. NIST has recommendations on cybersecurity risk management, data protection, threat detection, and incident response. While targeted mostly at federal institutions, NIST recommendations can be followed by any organization that wants to ensure a high level of security for its sensitive assets.
#### GDPR
The General Data Protection Regulation (GDPR) is a data privacy framework that sets rules for collecting, storing, transferring, and processing the personal data of EU residents. Compliance with GDPR requirements is mandatory for any organization that processes the private data of EU residents, no matter where such an organization is registered and operates.
Organizations can use specialized GDPR compliance software to meet the requirements of this regulation. There are laws similar to the GDPR outside the EU, such as the UK-GDPR and CCPA.
While there are various differences and peculiarities between them, major data privacy and cybersecurity requirements still have common ground. In the next section, we’ll show you the best practices in cybersecurity for meeting compliance.
## 12 cybersecurity compliance best practices for financial institutions
We’ve compiled a set of twelve best practices that cover the most prevalent requirements and will help improve your organization’s security.
### 1\. Regularly assess risks and audit your cybersecurity
_Keep your finger on the pulse of your banking information security._
First and foremost, you must inventory your organization’s security posture and identify potential threats. The GLBA Safeguards Rule, for example, requires financial institutions to conduct periodic written risk assessments. By doing this, you will get full visibility throughout your IT infrastructure and be able to identify internal and external risks to the security of your systems and data.
Start with identifying vulnerabilities that could compromise sensitive data: potential insider threats, cyberattacks, and third-party-related risks. Make sure to consider risks stemming from information systems as well as data processing, storage, and exchange.
Based on the risks you identify, assess the sufficiency of your cybersecurity tools to respond to cyberattacks and system failures.
### 2\. Establish a cybersecurity policy
_Strive for coherence._
A cybersecurity policy is what coordinates an organization’s cybersecurity movement. Serving as an objective guide, your cybersecurity policy should explicitly define all the measures and tools your company has adopted, or must adopt, to protect your valuable assets from cyber threats. Having a written cybersecurity policy makes it easier for banks to establish an effective cybersecurity routine and maintain proper data security in the long term.
For the best results, implement a hierarchical cybersecurity policy with strict agreement between practices, standards, and procedures. Be diligent about keeping all records of current policy requirements and recommendations up to date, and make sure your employees are aware of and follow your cybersecurity policy.
### 3\. Appoint a data protection officer
_Hire a security expert._
The GLBA, GDPR, PCI DSS, and other regulations and standards require organizations to appoint a data protection officer (DPO). Hiring a professional, experienced DPO is a win-win solution: on the one hand, you’ll be one step closer to compliance; on the other hand, having a professional DPO increases your organization’s resilience to data security threats. If having a full-time in-house specialist isn’t financially viable for your organization, you might also consider using the services of a DPO consultant.
A DPO can give your organization valuable data protection advice and recommendations on implementing proper security controls, as well as ensure timely notifications of any cybersecurity incidents to all stakeholders and relevant authorities.
When looking for a DPO, pay special attention to expertise in data protection and cybersecurity compliancefor banks. Knowledge of how financial organizations operate is also a plus. Assist your DPO when needed, and remember: to make it work, your company must be open to change.
### 4\. Secure your network
_Build a fortress no one can break._
Protecting your environment is a must for your organization’s cybersecurity compliance. For example, the SWIFT Customer Security Controls Framework (CSCF) recommends restricting internet access to sensitive systems to reduce the possible attack surface. You can also segment your main network into smaller subnetworks and segregate the most critical assets from the rest of the IT environment to make them less vulnerable. Be sure to also deploy fundamental security measures such as firewalls.
The more advanced your security is, the less likely a breach of any of its components becomes. To achieve this, you can take the layered security approach — that is, using multiple strategies at different levels of security, including systems, networks, applications, processes, and data management.
### 5\. Encrypt valuable data
_Data can only be compromised if it can be read._
Encryption is an efficient way to secure your data and is required by ISO/IEC 27001, GLBA, GDPR, PCI DSS, and NIS2, among other standards and regulations. First, it’s recommended to encrypt critical records and information on your customers and clients: personally identifiable information (PII), income levels, collections history, credit score, etc. Information security in the banking sector also involves encrypting financial transaction data such as payment histories, deposit balances, purchases, and account numbers.
To protect your data in full, look for cybersecurity solutions for financial services that allow you to encrypt data both in storage and in transit. This way, you can significantly minimize the risk of a devastating data breach.
To preserve the privacy of PII, you can also implement pseudonymization during user activity monitoring.
### 6\. Limit access to critical assets
_Prohibit access unless necessary._
By reducing the number of people with access to sensitive information, you can considerably minimize the risk of a security breach. Implementing the principle of least privilege ensures that the people in your organization are only given the access rights necessary to carry out their job duties.
This is where privileged access management (PAM) solutions can come in handy.
Learn more about
Privileged Access Management with Syteca
### 7\. Verify user identities
_Make sure your users are who they claim to be._
Unsecured user authentication can lead to unauthorized access, which in turn can expose you to data theft, malware, fraud, and other negative outcomes. That’s why it’s critical to follow the basic principles of zero trust and always verify user identities. One way of doing this is by using multi-factor authentication (MFA), which is a requirement of the majority of cybersecurity standards and regulations in the financial sector.
### 8\. Establish secure password management
Credential compromise is one of the main security breach vectors. To combat this, NIST Special Publication 800-63, PCI DSS, the GDPR, and other standards and regulations give recommendations and requirements for creating password policies. Deploying a dedicated password management solution allows you to automate and optimize password handling in your organization.
### 9\. Continuously monitor user activity
_Watch and record users’ actions._
User activity monitoring plays a crucial role in detecting and preventing both insider and outsider threats. It’s also the key requirement of many cybersecurity policies, including PCI DSS and SOX. By observing and analyzing user behavior within your network, you can proactively detect suspicious activity and spot early signs of an attack in progress. And in the event a cybersecurity incident does occur, you will have all the evidence of the crime. Therefore, it’s crucial to implement PCI DSS or SOX management software that provides user activity monitoring capabilities.
### 10\. Manage third-party risks
_Don’t trust outsiders accessing your systems._
Third parties are often granted more access rights than they need. Yet, a mistake made by a third party can result in anything from a minor service crash to a major data breach. In fact, 15% of all data breaches in 2024 involved a third party, which is a 68% increase from 2023, according to the 2024 Data Breach Investigations Report by Verizon.
For this reason, financial institutions and banks must monitor and manage their third-party vendors closely and carefully. You should also ensure your subcontractors comply with the same cybersecurity requirements that you do by adding a corresponding requirement to your service-level agreement.
### 11\. Build an incident response plan
_What will you do if your security is breached?_
Alongside a strong cybersecurity policy, every financial institution should have a well-thought-out incident response plan (IRP). This document should provide clear response scenarios for cybersecurity incidents that could happen in your organization. A written IRP will serve as a guideline and help direct your security team’s actions in critical situations.
An IRP should specify what is considered a cybersecurity incident and what actions must be taken if one occurs, what to do to restore lost data or affected systems, and other possible details that will help you mitigate the consequences of an incident. It should also clearly describe the roles within your incident response team and state who to notify first in case of an incident.
### 12\. Report security incidents in a timely manner
_Never conceal an incident._
Most bank security compliance requirements compel organizations to notify governing institutions and involved parties about any data breaches. Notification terms can vary from _within 72 hours_, as set by the GDPR, to _as soon as possible_, as requested by the GLBA. To report a problem quickly, you have to detect it fast. For this, you need an efficient incident response tool.
Consider describing the reporting procedure in your incident response plan, as it’s one of the most important compliance requirements.
Learn more about
Incident Response with Syteca
## How to maintain cybersecurity compliance in the financial sector with Syteca
Syteca is a comprehensive cybersecurity platform that can help financial institutions secure their IT environments against insider threats.
Syteca’s feature-rich toolset allows your organization to protect sensitive financial data and meet the requirements of industry-specific cybersecurity standards, laws, and regulations. Here’s how:
Cybersecurity compliance for financial organizations with Syteca
Privileged access management
Granularly manage access rights for regular users, privileged accounts, and third-party vendors to ensure the principle of least privilege.
Workforce password management
Efficiently manage employee credentials in your organization, perform automatic password rotation, provide users with one-time passwords, and limit the time period for which access is given.
Privileged account discovery
Detect unmanaged privileged accounts to minimize blind spots in your IT environment.
Identity management
Verify user identities with two-factor authentication (2FA), securely authenticate employees, and distinguish users of shared accounts.
User activity monitoring
Monitor user actions involving sensitive financial information and record them in a comprehensive screen capture recording format accompanied by insightful metadata.
User activity alerts
Proactively detect potential security threats with real-time notifications on suspicious events and enable your security team to take swift response actions.
Automated incident response
Automatic response actions include displaying a warning message to a user, blocking their session, terminating a particular process, and blocking unapproved USB devices.
User activity reports
Generate comprehensive reports on specific monitored data. Get insights into your employees’ productivity, active and idle time, websites visited, etc.
Syteca can help you comply with PCI DSS, SOX, SWIFT CSP, GLBA, DORA, NIS2, and more.
## Conclusion
Banking and finance is one of the most strictly regulated sectors, as banks and financial institutions work closely with customers’ private information, social security data, and financial records. To reduce cybersecurity risks and properly protect sensitive information, make sure your organization meets the requirements of the relevant laws, regulations, and cybersecurity standards we have mentioned in this article.
You can make use of these twelve best practices for banking and finance cybersecurity compliance to protect your organization’s most critical data and systems. Syteca’s access management, user activity monitoring, alerting, and reporting capabilities can ensure cybersecurity compliance, data protection, and timely detection and response to cybersecurity incidents in your organization.
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What is Critical Infrastructure Protection (CIP)? - Darktrace
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https://www.darktrace.com/cyber-ai-glossary/critical-infrastructure-protection-cip
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critical infrastructure protection
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## What is Critical Infrastructure?
Critical infrastructure refers to the fundamental facilities and systems that serve as the backbone for a nation's economy, security, and health. These include, but are not limited to, sectors such as energy (including electrical grids and gas pipelines), water systems, nuclear resources, aviation, and food and agriculture systems. These infrastructures are essential for the functioning of a society and economy, and their incapacitation or destruction would have a debilitating impact on national security, economic security, public health, or safety.
## What is Critical Infrastructure Protection?
Critical Infrastructure Cybersecurity refers to the measures and practices aimed at protecting the essential systems and assets that are vital for the functioning of a society and economy. This includes industries such as agriculture, energy, food, and transportation, which rely heavily on systems like Supervisory Control and Data Acquisition (SCADA) and Industrial Control Systems (ICS). These infrastructures are critical because their disruption could have severe consequences, including cyber threats, natural disasters, and terrorist attacks.
Critical Infrastructure Protection (CIP) involves securing these systems to ensure their continued operation and to protect them against potential threats. Common CIP solutions include SCADA for securing critical infrastructure and Operational Technology (OT) for overall infrastructure protection. Effective CIP strategies are essential to maintain the safety and functionality of critical sectors, ensuring that essential services like electricity, water, and transportation remain uninterrupted.
## Why Is Critical Infrastructure Protection (CIP) Important?
Critical Infrastructure Protection (CIP) is crucial for several reasons:
1. **Ensuring Access to Essential Services**: Protecting critical infrastructure is vital for providing services such as drinking water, electricity, and food. Disruptions in these services can have immediate and severe impacts on public health and safety.
2. **Protecting High-Value Industries**: Industries such as chemicals, communications, emergency services, healthcare, information technology, and transportation are vital to the economy. A successful cyberattack on these sectors could lead to devastating consequences for organizations and pose significant threats to global economies and communities.
3. **Mitigating Diverse Threats**: Critical infrastructure is vulnerable to a wide range of threats, including cyberattacks, natural disasters, and equipment failures. Recognizing and mitigating these risks is essential to ensure the integrity and reliability of these systems.
4. **Economic Security**: The stability of national and global economies depends on the reliable operation of critical infrastructure. Disruptions can lead to significant economic losses and long-term impacts on economic stability.
5. **Collaborative Efforts**: Successfully protecting critical infrastructure requires strong partnerships between government agencies and commercial entities. These collaborations help implement and manage effective protection measures and ensure a comprehensive approach to security.
6. **National Security**: Many critical infrastructures are integral to national security. Protecting these assets from both physical and cyber threats is essential to maintain national defense and public safety.
7. **Resilience Against Climate Change**: With the increasing frequency and intensity of natural disasters due to climate change, it is more important than ever to protect critical infrastructure from extreme weather events to ensure continuity and resilience.
## The Challenges to Critical Infrastructure Protection (CIP)
In the context of our increasingly interconnected world, critical infrastructure faces a range of cybersecurity threats:
**Sophisticated Cyberattacks**: Adversaries target critical infrastructure networks, including those of governments and third-party vendors, with advanced cyberattacks. These can disrupt essential services, extract sensitive intellectual property, and lay groundwork for future attacks.
**Scope of Targets**: Cybersecurity attacks on critical infrastructure can affect various sectors, from energy systems and nuclear resources to water systems, aviation, and agriculture.
**Evolving Threat Landscape**: Cyber threats are continually evolving, becoming more sophisticated, and spreading more rapidly, making it difficult for organizations to keep pace.
**Manual Processes**: Traditionally, the monitoring of cybersecurity threats and the evaluation of security controls have been manual processes. This approach often leads to a lack of visibility and delayed responses to emerging threats.
**Need for Efficient Intelligence Gathering**: To effectively counter these threats, governments and agencies require efficient methods for collecting and analyzing cyber threat intelligence. This intelligence is crucial for developing effective security strategies and policies.
**Lack of Visibility**: Many organizations responsible for protecting national security struggle with limited visibility into the cybersecurity posture of critical infrastructure, hindering their ability to make informed decisions.
## Examples of Critical Infrastructure
### 1\. The Energy Services Sector
The energy sector is crucial as it powers the entire U.S. economy. Cyber-attacks, like the 2015 hack into Ukraine's power grid using BlackEnergy 3 malware, demonstrate the vulnerabilities of energy grids. To prevent such attacks, industrial power grids in the U.S. are often isolated from the internet, relying on physical security to avoid disruptions. Enhancing utility cybersecurity is essential to protect against cyber threats and ensure the continuous operation of these critical systems.
### 2\. The Dams Sector
This sector controls vital water resources, including hydroelectric power and water supply systems. The 2016 cyber-attack on the Rye Brook Dam in New York highlights the potential risks faced by this sector, underlining the importance of robust cybersecurity measures in protecting water control systems.
### 3\. The Financial Services Sector
The financial sector is a prime target for cybercriminals, as evidenced by the massive Equifax breach affecting nearly half of the U.S. population. Protecting this sector is critical for maintaining economic stability and safeguarding personal financial information. Implementing robust financial services cybersecurity measures is essential to defend against such threats and ensure the security of financial data.
### 4\. The Nuclear Reactors, Materials, and Waste Sector
This sector, encompassing nuclear power plants and medical isotope production, is a major target for cyberattacks. Breaches can lead to significant national security risks and public safety concerns, as seen in the breach of a U.S. nuclear facility’s business records.
### 5\. The Food and Agriculture Sector
Almost entirely privately owned, this sector is crucial for the nation's food supply. The increasing use of connected devices introduces new vulnerabilities, as shown by the Farm Bureau survey indicating a lack of preparedness for cyber breaches.
### 6\. The Water and Wastewater Systems Sector
Essential for public health, this sector faced a significant attack in 2016 when hackers took control of a U.S. water authority company’s cellular routers, causing substantial financial loss. The sector continues to be vulnerable to new types of cyberattacks.
### 7\. The Healthcare and Public Health Sector
This sector, rich in sensitive data, is frequently targeted by hackers. The abundance of Personal Identifiable Information (PII) within healthcare organizations makes it a prime target, necessitating proactive healthcare cybersecurity measures.
### 8\. The Emergency Services Sector
Comprising police, fire, and rescue services, this sector is increasingly falling victim to ransomware attacks, disrupting critical services on which citizens rely daily.
### 9\. The Transportation Systems Sector
Responsible for moving people and goods nationally and internationally, this sector faces growing cyber threats, as seen in the malware attack on San Francisco’s light rail system. The rise of “smart” cities increases the vulnerability of this sector.
### 10\. The Government Facilities Sector
This sector includes a wide range of government buildings and is often targeted by cybercriminals, as shown by the 2011 cyberattacks on Pacific Northwest Laboratory (PNNL) and Thomas Jefferson National Laboratory.
## Does NIS2 apply to Critical Infrastructure?
Yes, NIS2 does apply to critical infrastructure. The NIS2 (Network and Information Systems Directive 2) builds on the requirements of the original NIS Directive, aiming to protect critical infrastructure and organizations within the EU from cyber threats. It mandates that EU member states implement specific cybersecurity strategies, establish competent authorities, and introduce incident reporting mechanisms. NIS2 has also expanded the range of service providers required to comply with its provisions, ensuring that all essential service providers, including those in critical infrastructure sectors such as healthcare, digital infrastructure, transport, water supply, and energy, are covered and protected from cyber threats.
## How does Operational Technology (OT) Relate to Critical Infrastructure?
Operational technology (OT) is deeply related to critical infrastructure. It encompasses the hardware and software systems used to control and monitor physical processes in various critical infrastructure sectors such as power plants, water treatment facilities, and transportation systems. These systems are essential for the safety and well-being of communities, as they ensure the smooth and secure operation of vital services and utilities.
Any disruption or compromise in these operational technology systems can lead to significant consequences, impacting the functionality of critical infrastructure and potentially causing widespread harm. Therefore, securing OT is a crucial aspect of maintaining the integrity, resilience, and reliability of critical infrastructure.
Here is a six-part strategy designed to enhance the security and resilience of operational technology against contemporary threat vectors.
1. Increase monitoring of integrated IT/OT areas and catalog all network assets.
2. Evaluate vulnerabilities and overall security status of OT.
3. Create a comprehensive security strategy for OT.
4. Regularly update and maintain OT systems.
5. Formulate and practice an incident response plan for OT.
6. Bridge the gap between IT and OT security practices.
## Best Practices for Critical Infrastructure Protection (CIP)?
### Vulnerability Assessments and Risk Analysis
Effective defense of critical infrastructure starts with comprehensive vulnerability assessments and risk analysis. This involves:
**Evaluating Network Systems and Assets**: Conducting thorough assessments to identify potential security weaknesses that could be exploited by cyber threats.
**Risk Analysis**: Determining the impact and likelihood of vulnerabilities being exploited, enabling the development of strategic defense plans to mitigate significant risks.
### Proactive Incident Response Planning
Developing a proactive incident response plan is vital for effective protection against cyber threats. Key elements of this plan include:
**Incident Response Protocols**: Outlining procedures for incident analysis, containment, eradication, and recovery.
**Roles and Responsibilities**: Clearly defining the responsibilities of team members in the event of a cyber incident.
**Communication Protocols**: Establishing effective communication strategies for incident management.
### Network Segmentation and Access Control
Enhancing network security through segmentation and access control is critical for reducing cyber vulnerabilities. This involves:
**Network Segmentation**: Dividing networks into smaller sections to contain attacks and prevent lateral movements within the network.
**Access Control Measures**: Implementing robust controls to ensure only authorized individuals have access to critical infrastructure assets.
### Employee Training and Awareness Programs
Implementing comprehensive employee training and awareness programs is essential to fortify the human element of cybersecurity. These programs should focus on:
**Skill Development**: Educating employees on identifying and mitigating cyber threats.
**Awareness Building**: Enhancing understanding of the importance of cybersecurity in protecting critical infrastructure.
**Collaborative Efforts**: Encouraging partnerships between private and public sectors to strengthen overall security posture.
### Continuous Monitoring and Threat Intelligence
Continuous monitoring and staying abreast of the latest cyber threat intelligence are key to proactively defending critical infrastructure. This includes:
**Vigilant Monitoring**: Keeping a constant watch on systems to identify vulnerabilities and potential attacks quickly.
**Threat Intelligence Gathering**: Staying informed about evolving cyber threats to tailor security practices accordingly.
**Collaboration with Authorities**: Working closely with government agencies and regulatory bodies to ensure comprehensive protection.
## What’s a Rich Text element?
The rich text element allows you to create and format headings, paragraphs, blockquotes, images, and video all in one place instead of having to add and format them individually. Just double-click and easily create content.
### Static and dynamic content editing
A rich text element can be used with static or dynamic content. For static content, just drop it into any page and begin editing. For dynamic content, add a rich text field to any collection and then connect a rich text element to that field in the settings panel. Voila!
#### How to customize formatting for each rich text
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Protecting the cybersecurity of critical infrastructures and their supply ...
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https://iccwbo.org/news-publications/policies-reports/protecting-the-cybersecurity-of-critical-infrastructures-and-their-supply-chains/
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critical infrastructure protection
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Critical infrastructure and essential services form the backbone of every country’s development, cutting across the domains of energy, water, heating, transportation, finance and communication to name a few. Disruptions to these infrastructures can have profound consequences on public safety, economic stability, and national security, underscoring the imperative for robust protection measures.
At its core, this paper emphasises the indispensable role of critical infrastructures and essential services in sustaining societal functions and economic activities. ICC analyses the multifaceted challenges inherent to their protection and navigates through these challenges, offering a coherent strategy for resilience founded on international and multistakeholder collaboration.
## **Who is behind the cyber threats targeting critical infrastructures?**
Cyberthreats to critical infrastructure and essential services come from diverse actors, ranging from states to cybercriminal organisations, each motivated by distinct objectives. These threats encompass sophisticated malware, supply chain attacks, and physical intrusions, posing significant risks to public safety and economic stability. The potential cascading impacts of these threats highlight the need for robust protection measures.
## What are the challenges in protecting critical infrastructures from cyber threats?
One of the key challenges lies in defining critical infrastructure and essential services. Various sectors are considered critical in different jurisdictions. The concept of essential services is dynamic and evolving as digital technologies advance.
Moreover, the interdependence of these services with other infrastructures further complicates their protection, requiring a nuanced approach.
**Global business losses from cyberattacks on supply chains are set to soar from $45 billion in 2023 to $138 billion by 2031.**
**Source: Cybersecurity Ventures**
Similarly, despite the existence of cybersecurity frameworks, implementation remains a challenge, particularly in aligning standards across jurisdictions and sectors.
Public-private collaboration is essential in this endeavour but is hindered by differing regulatory frameworks and responsibilities. Securing supply chains is also crucial, given the varying ownership models and regulatory landscapes globally.
## What is needed to safeguard critical infrastructures from cyber threats?
To address these challenges, a comprehensive approach is needed:
- **Transnational agreements:** Establish baseline cybersecurity standards across supply chains, reducing complexity and enhancing resilience.
- **Coordinated efforts:** Requirement to mitigate cyber threats, combat criminal groups and state-sponsored actors.
- **Incentivise cybersecurity investment:** balancing economic profitability with public investment is crucial to ensure the resilience of essential services and critical infrastructure.
In conclusion, safeguarding critical infrastructure and essential services requires a coordinated, multifaceted approach involving:
- international cooperation
- policy enhancements, and
- public-private partnerships.
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Critical infrastructure protection: Top 7 emerging threats - Rocket.Chat
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https://www.rocket.chat/blog/critical-infrastructure-protection
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critical infrastructure protection
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## **Introduction**
Critical infrastructure **protection is necessary** because society is becoming more and more dependent on complex systems to maintain services like energy, transportation, water supply, healthcare, and communication.
These systems are often exposed to risks such as supply chain vulnerabilities, cyberattacks, and the effects of climate change.
**_In addition to the growing issue of extreme weather events endangering the integrity of these systems, recent studies show a_** **_140% increase_** **_in cyberattacks targeting critical facilities._**
**This article explores the top 7 rising threats to critical infrastructure protection** and proposes actionable preparedness measures to increase our critical systems' protection and cyber resilience.
## **Top emerging threats to critical infrastructure protection (And how to tackle them)**
By implementing these methods, organizations can strengthen their **defenses against the dangers of cyberattacks.**
### **1\. Cyber attacks on critical infrastructure**
**With increasing interconnectivity, cybercriminals are exploiting vulnerabilities** in operational technology systems. This often leads to severe disruptions and potential national security risks.
_According to Check Point Research, the_ _three highly targeted_ _sectors were healthcare (1,999 assaults per week), government/military (2,084 attacks per week), and education/research (3,341 attacks per week)._
#### **Preparation strategies**
1. **Implement multi-layered cybersecurity defenses**
- Use firewalls, intrusion detection systems, and regular vulnerability assessments to create a strong **defense against cyber threats**.
- **Example:** The Cybersecurity and Infrastructure Security Agency (CISA) recommends a defense-in-depth strategy for critical infrastructure protection.
2. **Conduct employee training on cybersecurity awareness**
- Regular training sessions can help employees recognize and avoid **phishing and social engineering attacks**.
- **Example:** A recent study found that organizations with regular cybersecurity training programs experienced 70% fewer successful phishing attacks.
1. **Establish and test an incident response plan**
- Develop a comprehensive incident response plan that outlines the steps to take in the event of a cyber breach.
- **Example:** The National Institute of Standards and Technology (NIST) provides guidelines for creating and maintaining an effective incident response plan.
### **2\. Climate-related disasters**
**The increasing intensity and frequency of events such as hurricanes, floods, wildfires, and heat waves** are challenging the resilience of infrastructure systems worldwide as a result of climate change.
_The recent State of the Climate report mentioned that the three hottest days ever recorded occurred_ _in July 2024_ _._
#### **Preparation strategies**
1. **Invest in climate-resilient infrastructure materials and designs**
- Use materials and designs that can **withstand extreme weather conditions**, such as flood barriers, fire-resistant building materials, and elevated structures.
- **Example:** The Netherlands has invested heavily in flood defenses, including the Delta Works, a series of construction projects designed to protect the country from the sea.
2. **Conduct a climate risk assessment**
- Identify vulnerable areas within your infrastructure **by observing climate change**.
- **Example:** New York City conducted a comprehensive climate risk assessment to **identify areas at risk of flooding and implemented measures for critical infrastructure protection**.
3. **Develop and test emergency response plans**
- Create detailed emergency response plans for natural disasters, including evacuation protocols and communication plans.
- **Example:** Japan's rigorous earthquake and tsunami preparedness plans, which include regular drills and public education campaigns, have proven effective in mitigating the impact of such disasters.
### **3\. Supply chain disruptions**
Recent events like geopolitical tensions have worsened the global supply chain.
_In the first half of 2024,_ **_supply chain disruptions_** _increased by 30%_ **_compared to the same period in 2023_** _. This rise was driven by factors such as factory fires, labor disruptions, and extreme weather events._
#### **Preparation strategies**
1. **Diversify suppliers** some text
- Reduce dependency on a single region or provider, especially for essential components, by sourcing from multiple suppliers.
- **Example:** For instance, Dow Chemical employs a dual sourcing strategy for critical raw materials, ensuring backup options are available if one supplier faces issues.
2. **Maintain an inventory of critical supplies**
- Keep a buffer stock of critical supplies to mitigate the impact of supply chain delays.
- **Example:** Automotive manufacturers have started maintaining higher inventory levels of semiconductor chips to avoid production halts due to supply shortages.
3. **Use supply chain monitoring tools**
- Implement real-time monitoring tools to track disruptions and enable faster response.
- **Example:** A study by TraceX Technologies found that companies using real-time monitoring experienced improved operational efficiency with unforeseen delays.
### **4\. Insider threats**
Insider threats, such as sabotage, data theft, and unauthorized access by employees or contractors, pose risks to critical infrastructure protection.
_In 2024,_ _83% of organizations_ _reported experiencing at least one insider attack, a significant increase from previous years._
#### **Preparation strategies**
1. **Implement strict access control measures**
- Conduct thorough background checks for employees and contractors to **identify risks before granting access to sensitive information**.
- **Example:** Many organizations now use comprehensive background screening processes to vet new hires and contractors.
2. **Use role-based access controls**
- Limit employees' access to only the information and systems necessary for their job functions.
- **Example:** Implementing role-based access controls (RBAC) ensures that employees can only access data relevant to their roles.
3. **Monitor for unusual activity**
- Use advanced monitoring tools to detect unusual activities, such as large data downloads or login attempts from unusual location
- **Example: User and Entity Behavior Analytics** (UEBA) tools can help identify anomalies in user behavior.
### **5\. Physical attacks and terrorism**
**Physical threats**, such as vandalism, **terrorism, and sabotage**, continue to pose risks to critical infrastructure protection, disrupt essential services, and pose serious safety hazards.
_The 2024 Paris Olympics faced_ _multiple security threats_ _, including planned attacks that were thwarted by coordinated security efforts._
#### **Preparation strategies**
1. **Strengthen physical security measures**
- Implement comprehensive security systems, including surveillance cameras, access control systems, and perimeter fencing to deter and detect unauthorized access.
- **Example:** London Underground has enhanced its **security protocols by integrating advanced CCTV systems and deploying security personnel at key locations to monitor activities**.
2. **Coordinate with local law enforcement and emergency responders**
- Develop quick-response protocols in collaboration with local law enforcement and emergency responders.
- **Example:** Critical infrastructure facilities conduct joint training exercises with local police and fire departments to improve response times and coordination during emergencies.
3. **Conduct regular drills and simulations**
- Regularly conduct drills and simulations to prepare staff for potential security threats or evacuation scenarios.
- **Example:** The energy sector frequently conducts security **drills to simulate attacks on power plants**, ensuring that staff are well-prepared to handle real-life threats.
### **6\. Aging infrastructure**
**Aging infrastructure creates a risk to critical systems**, particularly in developed countries where many facilities are operating beyond their intended lifespan.
_The_ _average age_ _of a U.S. bridge is 44 years, while pipes average 45 years, and dams average 57 years._
#### **Preparation strategies**
1. **Conduct regular inspections and proactive maintenance**
- Regularly inspect infrastructure to identify and address vulnerabilities before they lead to failures.
- **Example:** The American Society of Civil Engineers (ASCE) recommends routine inspections and maintenance to extend the lifespan of critical infrastructure.
2. **Invest in modernization projects**
- Replace outdated systems with newer, more resilient technologies to improve reliability and efficiency.
- **Example:** The Bipartisan Infrastructure Law includes funding for modernization projects, such as the replacement of lead pipes and the upgrade of public transit systems.
3. **Apply predictive maintenance techniques**
- Use sensors and IoT devices to monitor infrastructure health and detect issues early.
- **Example:** Smart grid technology is being used to monitor the health of electrical grids, enabling utilities to predict and prevent outages.
### **7\. Geopolitical instability**
Geopolitical tensions and conflicts can affect global supply chains, energy supplies, and the overall security environment, **posing risks to critical infrastructure protection**.
_Geopolitical instability was cited as the top threat to global economic growth in_ _2024 by 67%_ _of executives in a recent McKinsey Global Survey._
#### **Preparation strategies**
1. **Develop contingency plans for geopolitical disruptions**
- Create plans that include alternative sources for essential resources to ensure continuity of operations during geopolitical crises.
- **Example:** Companies in the semiconductor industry have started diversifying their supply chains to reduce dependency on any single region, particularly in response to tensions between China and Taiwan.
2. **Use threat intelligence tools**
- Implement tools to monitor geopolitical risks in real time and adjust operations accordingly.
- **Example:** Many multinational corporations use geopolitical risk assessment platforms to stay informed about potential threats and make proactive adjustments to their strategies.
3. **Consider relocating critical infrastructure or securing access routes**
- Evaluate the feasibility of relocating critical infrastructure away from conflict zones or securing key access routes to minimize exposure.
- **Example:** Energy companies often invest in securing alternative routes for oil and gas pipelines to ensure supply continuity in the event of regional conflicts.
## **6 ways Rocket.Chat ensures maximum critical infrastructure protection**
Here’s how Rocket.Chat can deliver foolproof critical infrastructure protection:
1. **Encrypted communication:** The platform uses end-to-end encryption to ensure that all communications are secure and private.
2. **Role-based access control:** By **implementing RBAC, Rocket.Chat** ensures that users only have access to the information and systems necessary for their roles.
3. **Multi-channel communication:** It supports multi-channel communication, allowing teams to coordinate quickly and efficiently across various platforms.
4. **Integration with existing systems:** The tool can be seamlessly integrated with existing Business Continuity Management (BCM) and **security systems**.
5. **Geolocation-based messaging:** Geolocation-based secure messaging allows for targeted communication based on users' location.
6. **Audit logs:** Rocket.Chat’s comprehensive audit logs provide a **detailed record of all communications and actions**.
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The Importance of Critical Infrastructure Security
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https://security.gallagher.com/en-US/Blog/the-importance-of-critical-infrastructure-security
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critical infrastructure protection
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In an age where electricity is as vital as the air we breathe and water is crucial in the heat of the summer, the continuity of critical infrastructure is non-negotiable.
Critical infrastructure is the backbone of our modern world, from power grids to healthcare and transportation, and it faces a growing threat with a 140% surge in cyberattacks that led to physical consequences as well as increasing physical security threats. Plus, with growing extreme weather events the resilience of critical infrastructure all over the world is more crucial than ever.
In this blog we explore the significance of critical infrastructure security in today's world and how to safeguard these sites from cyberattacks and physical threats with a layered approach to critical infrastructure protection (CIP).
## What is critical infrastructure?
Critical infrastructure includes all the assets, systems, facilities, and networks that are essential to the proper functioning of a society’s economy, national public health or safety, security.
Whether it is supplying the power we use in our homes or offices, treating the water we drink, delivering fuel for our vehicles, or housing the national government representatives that run our countries; critical infrastructure, also referred to as critical national infrastructure, are the essential services that underpin our society and keep our nation running.
## How many critical infrastructure sectors are there?
In the United States there are 16 critical infrastructure sectors including:
- Chemical Sector
- Commercial Facilities Sector
- Communications Sector
- Critical Manufacturing Sector
- Dams Sector
- Defense Industrial Base Sector
- Emergency Services Sector
- Energy Sector
- Financial Services Sector
- Food and Agriculture Sector
- Government Facilities Sector
- Healthcare and Public Health Sector
- Information Technology Sector
- Nuclear Reactors, Materials, and Waste Sector
- Transportation Systems Sector
- Water and Wastewater Systems
## Why is critical infrastructure important?
Securing critical infrastructure is vital to ensuring continuous access to services like drinking water, electricity, and food. Any disruption or damage to the operation of these services can have devastating and far-reaching impacts across many aspects of our daily lives, posing a serious threat to global economies and livelihoods.
## Best practices for implementing critical infrastructure security measures
Implementing critical infrastructure security requires a comprehensive and proactive approach that addresses various security aspects. These sites can benefit from a layered approach to CIP.
Layered security allows a site to put multiple security levels in place and increase the complexity the closer you get to higher risk assets. By doing this, it reduces the possibility of a security threat being realized through delaying intruders and providing security personnel more time to detect unauthorized entry.
No single security solution will stop every attack, every time, so when protecting high-risk sites, a layered approach incorporating critical infrastructure solutions is best practice.
### Critical infrastructure perimeter protection
Perimeter security is the first line of defense for any organization. It can provide detection and deterrence, alerting the business and emergency services to potential security threats while delaying and preventing any loss or damage due to theft, vandalism, or other criminal acts. A robust perimeter security system is essential to protect your site from criminal threats, especially in critical and high security sectors.
For example, The Oman Electricity Transmission Company (OETC), based in Muscat, Oman, faced challenges in securing its 90 remote grid stations from unauthorized intrusions. To address these issues, OETC implemented Gallagher's perimeter security solutions, including energized pulse fencing and the Z20 Disturbance Sensor for continuous gate monitoring. This combined with CCTV, automated lighting, and remote monitoring integrations has successfully deterred unauthorized entries and enhanced safety. As a result, OETC has improved asset protection, reduced security costs, and increased operational efficiency.
### Critical infrastructure access control
Robust access control is an essential component of a comprehensive physical security strategy for critical infrastructure protection. These measures are specifically designed to prevent or mitigate the threat to people, information, and assets. A critical infrastructure access control system should protect against unauthorized access, maintain integrity and availability, and provide evidence of access.
Access control solutions provide a foundation for creating layered security protection and achieve much more than just allowing access via electronic credentials. This technology can provide a complete record of who entered a facility, which areas they accessed, and the duration of their stay, thereby enhancing critical infrastructure security.
One example of this is utilizing an access control system to manage user privileges and assigning different access permission for employees. Entry control points can be easily established to only allow authorized individuals initial access to a facility or within specific areas. The rule of least privilege ensures that users are given the minimum levels of access or permissions needed to perform their job and can be a fundamental layer in protecting high-value assets or data, while reinforcing critical infrastructure protection.
High security zones within an access solution often have a dual authority rule where two authorized people must be authenticated at the same time before access is granted. A no alone zone can be used for areas where there must be two people present and if they don’t leave within the allocated grace period an alarm will be generated. In more capable critical infrastructure access control systems, that rule can be modified to require at least one person of a supervisor role to be present.
### The importance of cybersecurity in critical infrastructure security
A crucial layer in every physical access control strategy, is cybersecurity. Unfortunately, cyber-attacks are becoming increasingly prevalent and as such are a very real threat to every organization, although especially consequential for critical sites. When it comes to the protection of your critical infrastructure site, cybersecurity is one of the most important things you can invest in.
Gallagher’s critical infrastructure security solutions are highly specialized and designed to meet the needs of critical sites with some of today's highest security requirements. A significant component of this design is having cybersecurity protection built-in at every stage. End-to-end encryption and authentication, external and internal vulnerability testing, system hardening and configuration advice, fully trained and certified installers all help to ensure your critical infrastructure security system is as cyber secure as possible.
The Gallagher Personal Identity Verification (PIV) solution is purpose built and approved for use across federal government sites in the United States. As a unique end-to-end solution, it has suitability to any environment that requires high assurance authentication to computer network resources. Compliant with the latest Federal Information Processing Standards (FIPS) 201-3, the products and software that make up the Gallagher PIV solution are designed from inception to be as cyber secure as possible through product development that encompasses authentication, encryption, tamper defense, and redundancies.
Ensuring the security of critical infrastructure is paramount for the stability of modern society and the importance of a layered security approach in protecting these sites cannot be overstated. Protecting essential systems, such as power grids, water supplies, and communication systems, is vital to maintain the continuity of services that billions rely on daily.
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What are the Biggest Challenges to Federal Cybersecurity? (High ...
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https://www.gao.gov/blog/what-are-biggest-challenges-federal-cybersecurity-high-risk-update
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government cybersecurity
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## **Challenge 1: National Cybersecurity Strategy isn’t as strong as it could be**
Last year, the White House issued a National Cybersecurity Strategy outlining steps the government is taking to address the longstanding cybersecurity challenges facing the country. But how will the government know if its strategy is working? When we looked at the strategy, we found it needed outcome-oriented performance measures for various cybersecurity initiatives.
In addition, the federal government needs to take action to ensure it is monitoring the global supply chain, confirm it has the highly skilled cyber workforce it needs, and address risk associated with emerging technologies—such as artificial intelligence. The government and the private sector are at risk when emerging threats aren’t addressed.
We saw such an attack around January 2019 after a network breach at SolarWinds. The Texas-based network management software company was widely used by the government to monitor network activities and manage network devices on federal systems. A Russian-led attack on SolarWinds resulted in one of the most widespread and sophisticated hacking campaigns ever conducted against the U.S.
We’ve made nearly 400 recommendations to strengthen the National Cybersecurity Strategy and agencies’ ability to perform effective oversight. As of May, 170 of our recommendations have not been acted on.
## **Challenge 2: Agencies remain limited in their ability to improve the security of federal systems and information**
Federal agencies rely extensively on computerized information systems to conduct day-to-day business, including interactions with the public. Many of these systems house important taxpayer information—including Social Security numbers, income information, tax filing information, loan data, and more.
Ineffective security controls could not only leave these systems vulnerable to attack, but also delay the response to attacks. For example, in December 2021, a vulnerability in a piece of open-source software known as “Log4j” was reported. Log4j is used to collect and manage information about system activities and is used in millions of federal and private information systems. A 2013 update of Log4j was intended to make data storage and retrieval easier. But in November 2021 (8 years later), a security engineer reported a vulnerability in the feature. Federal agencies were directed to address this vulnerability. Even though there hasn’t been a known Log4j-based attack on federal IT, the weakness was deemed an “endemic vulnerability”—meaning that vulnerabilities will remain in systems for years despite actions to address them.
We’ve reported on federal efforts to help agencies address weaknesses like these so that systems and information are more secure. We’ve made more than 800 recommendations to improve efforts. But 221 of these recommendations have not been implemented, as of May. Doing so can greatly enhance the federal response to cyber incidents.
## **Challenge 3: Critical infrastructure sectors remain vulnerable to disruptive attacks**
A ransomware attack on Change Healthcare, a health payment processor, made headlines. The attack shut down operations, resulting in nearly $874 million in financial losses and widespread disruptions for providers and patient care. Medical procedures were delayed and patients were unable to access medications.
Health care is just one of our 16 critical infrastructure sectors that is vulnerable to cyberattacks. All of these sectors rely heavily on IT systems to operate.
## Image
Attacks on critical infrastructure sectors continue to grow and could seriously harm human safety, national security, the environment, and the economy. The federal government has taken some steps to address the challenges with protecting these systems from cyberattacks. But we see persistent shortcomings in these efforts. For example:
- In January, we reported that the federal agencies responsible for the four sectors that have reported almost half of all ransomware attacks—health care and public health, critical manufacturing, energy, and transportation—had not determined whether their actions to prevent future attacks include leading practices.
- In March, we reported on the challenges agencies face when collaborating with the Cybersecurity and Infrastructure Security Agency (CISA) on mitigating cyber risks in their sectors. These challenges included sharing information about potential threats.
- Last December, we highlighted challenges reported by nonfederal entities in accessing the support they need from the federal government to address vulnerabilities.
We’ve made 126 recommendations to better protect the cybersecurity of critical infrastructure. Action is still needed on 64 of them.
## **Challenge 4: Efforts to protect your personal privacy face limitations**
In March, AT&T reported that some of its data—which included sensitive personal information such as Social Security numbers and passcodes—had been released onto the dark web. As many as 7.6 million current and approximately 65.4 million former AT&T account holders were affected.
Attacks like these are becoming more common. At the same time, we found that federal agencies are limited in their ability to help prevent and respond to them. In 2022, we reported about the risks posed by the increasing collection and use of personal information from consumers. For example, companies collect personal and transactional data to create consumer scores, which are used to predict how consumers will behave in the future.
While collection and use of personal data increases, there’s still no comprehensive U.S. internet privacy law about companies’ collection, use, or sale of your data. This leaves consumers like you with limited assurances that your privacy will be protected.
Data the government collects about you is also at risk. In August 2023, we reported on how the IRS monitors access to sensitive taxpayer information. We found that IRS didn’t have a comprehensive inventory of the systems that store this information, limiting its ability to protect data.
On the topic of protecting privacy and sensitive data, we have made nearly 250 recommendations—112 still require action.
## **What needs to happen next?**
Our new report provides an update on the federal government’s progress with addressing cybersecurity challenges and our recommendations to tackle them. In total, we’ve identified 567 recommendations that still need action.
Until actions are taken and our recommendations are implemented, the federal government, the national critical infrastructure, and the personal information of U.S. citizens will be increasingly susceptible to a multitude of cyber-related threats.
- GAO’s fact-based, nonpartisan information helps Congress and federal agencies improve government. The WatchBlog lets us contextualize GAO’s work a little more for the public. Check out more of our posts at GAO.gov/blog.
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CISA loses nearly all top officials as purge continues
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https://www.cybersecuritydive.com/news/cisa-senior-official-departures/748992/
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Virtually all of the top officials at the Cybersecurity and Infrastructure Security Agency (CISA) have departed the agency or will do so this month, according to an email obtained by Cybersecurity Dive, further widening a growing void in expertise and leadership at the government’s lead cyber defense force at a time when tensions with foreign adversaries are escalating.
Five of CISA’s six operational divisions and six of its 10 regional offices will have lost top leaders by the end of the month, the agency’s new deputy director, Madhu Gottumukkala, informed employees in an email on Thursday.
Steve Harris, the acting head of the Infrastructure Security Division, left on May 16, and Trent Frazier, the acting head of the Stakeholder Engagement Division, left on May 2, Gottumukkala wrote, while Vince Delaurentis, the No. 2 official in the Emergency Communications Division, is leaving on May 30. Gottumukkala also confirmed the previously reported departures of Matt Hartman, the No. 2 official in the Cybersecurity Division, and Boyden Rohner, the head of the Integrated Operations Division.
The exits of these leaders could undermine the efficiency and strategic clarity of CISA’s partnerships with critical infrastructure operators, private security firms, foreign allies, state governments and local emergency managers, experts say.
The leaders of CISA’s field teams who are leaving soon or have recently left are Region 2 Director John Durkin, Region 4 Director Jay Gamble, Region 5 Director Alex Joves and Deputy Director Kathy Young, Region 6 Director Rob Russell, Region 7 Director Phil Kirk, and Region 10 Director Patrick Massey.
These regional supervisors and the teams who report to them have played an important role in expanding CISA’s nationwide presence, improving its partners’ awareness of the services it offers and boosting its reputation as a reliable source of expertise and support.
“With these significant number of senior departures, several of which are leaders who have been here since the days of US-CERT, there’s a lot of anxiety around when the cuts and departures will finally stop and we can move forward as an agency,” said one CISA employee, who requested anonymity to discuss internal tensions.
Many of CISA’s administrative officials are also leaving. Chief strategy officer Val Cofield and chief financial officer Tarek Abboushi will leave on May 30, while chief contracting officer Juan Arratia left on May 16 and chief human capital officer Blair Duncan left on May 2.
“CISA is doubling down and fulfilling its statutory mission to secure the nation’s critical infrastructure and strengthen our collective cyber defense,” Bridget Bean, the agency’s executive director, said in a statement. “We were created to be the cybersecurity agency for the nation, and we have the right team in place to fulfill that mission and ensure that we are prepared for a range of cyber threats from our adversaries."
The Washington Post first reported some details of the CISA departures.
### **Anxiety grows over CISA’s future**
Gottumukkala, who assumed the duties of acting director from Bean upon his arrival on May 19, told employees that he has been “inspired by the critical work this agency does every day” during his first week on the job. But inside and outside of CISA, the recent exits have fueled already-significant anxieties about the future of the agency.
“It feels like the wrong people are leaving,” said a second CISA employee, who insisted on anonymity to speak freely. “All of these departures make it feel like people are leaving the mission and creating a vacuum.”
Suzanne Spaulding, who led CISA’s predecessor wing inside the Department of Homeland Security from 2011 to 2017, said it was “sad and maddening to see so much expertise and institutional knowledge pushed out the door.”
“The loss of these leaders,” Spaulding said, “including leaders across the country who work every day with the owners and operators of critical infrastructure, will leave the nation less secure and resilient.
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**CMMC Level 2 Self Assessments are operational in SPRS effective 28 Feb 25.**
# About CMMC
Cybersecurity is a top priority for the Department of Defense (DoD). The defense industrial base (DIB) faces increasingly frequent, and complex cyberattacks. To strengthen DIB cybersecurity and better safeguard DoD information, the DoD developed the Cybersecurity Maturity Model Certification (CMMC) Program to assess existing DoD cybersecurity requirements.
## Overview of the CMMC Program
The CMMC Program aligns with the DoD’s existing information security requirements for the DIB. It is designed to enforce the protection of sensitive unclassified information shared by the Department with its contractors and subcontractors. The program provides the DoD with increased assurance that contractors and subcontractors are meeting the cybersecurity requirements for nonfederal systems processing controlled unclassified information.
Key features of the CMMC Program:
- **Tiered Model**: CMMC requires companies entrusted with sensitive unclassified DoD information to implement cybersecurity standards at progressively advanced levels, depending on the type and sensitivity of the information. The program also outlines the process for requiring protection of information flowed down to subcontractors.
- **Assessment Requirement**: CMMC assessments allow the DoD to verify DIB implementation of existing cybersecurity standards.
- **Implementation through Contracts**: DoD contractors and subcontractors handling sensitive unclassified DoD information must achieve a specific CMMC level as a condition of contract award.
## Protected Information
The CMMC model is designed to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) shared with defense contractors and subcontractors during contract performance.
- **Federal Contract Information (FCI)**: As defined in section 4.1901 of the Federal Acquisition Regulation (FAR), FCI is “information, not intended for public release, that is provided by or generated for the Government under a contract to develop or deliver a product or service to the Government, excluding information provided by the Government to the public (such as that on public websites) or simple transactional information, such as that necessary to process payments.”
- **Controlled Unclassified Information (CUI)**: As outlined in Title 32 CFR 2002.4(h), CUI is “information the Government creates or possesses, or that an entity creates or possesses for or on behalf of the Government, that a law, regulation, or Government-wide policy requires or permits an agency to handle using safeguarding or dissemination controls.” For more information regarding specific CUI categories and subcategories, see the DoD CUI Registry website.
## Overview of Assessments
The CMMC Program provides assessments at three levels, each incorporating security requirements from existing regulations and guidelines.
#### Level 1: Basic Safeguarding of FCI
- **Requirements**: Annual self-assessment and annual affirmation of compliance with the 15 security requirements in FAR clause 52.204-21.
#### Level 2: Broad Protection of CUI
- **Requirements**:
1. Either a self-assessment or a C3PAO assessment every three years, as specified in the solicitation.
- Decided by the type of information processed, transmitted, or stored on the contractor or subcontractor information systems.
2. Annual affirmation, verify compliance with the 110 security requirements in NIST SP 800-171 Revision 2.
#### Level 3: Higher-Level Protection of CUI Against Advanced Persistent Threats
- **Requirements**:
1. Achieve CMMC Status of Final Level 2.
2. Undergo an assessment every three years by the Defense Contract Management Agency’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
3. Provide an annual affirmation verifying compliance with the 24 identified requirements from NIST SP 800-172.
CMMC Status Source & Number of Security Reqts. Assessment Reqts. Plan of Action & Milestones (POA&M) Reqts. Affirmation Reqts.
--- --- --- --- ---
**Level 1**<br>**(Self)** - 15 required by FAR clause 52.204-21 - Conducted by Organization Seeking Assessment (OSA) annually<br>- Results entered into the Supplier Performance Risk System (SPRS) - Not permitted - After each assessment<br>- Entered into SPRS
**Level 2**<br>**(Self)** - 110 NIST SP 800-171 R2 required by DFARS clause 252.204-7012 - Conducted by OSA every 3 years<br>- Results entered into SPRS<br>- CMMC Status will be valid for three years from the CMMC Status Date as defined in § 170.4 - Permitted as defined in § 170.21(a)(2) and must be closed out within 180 days<br>- Final CMMC Status will be valid for three years from the Conditional CMMC Status Date - After each assessment and annually thereafter<br>- Assessment will lapse upon failure to annually affirm<br>- Entered into SPRS
**Level 2**<br>**(C3PAO)** - 110 NIST SP 800-171 R2 required by DFARS clause 252.204-7012 - Conducted by C3PAO every 3 years<br>- Results entered into CMMC Enterprise Mission Assurance Support Service (eMASS)<br>- CMMC Status will be valid for three years from the CMMC Status Date as defined in § 170.4 - Permitted as defined in § 170.21(a)(2) and must be closed out within 180 days<br>- Final CMMC Status will be valid for three years from the Conditional CMMC Status Date - After each assessment and annually thereafter<br>- Assessment will lapse upon failure to annually affirm<br>- Entered into SPRS
**Level 3**<br>**(DIBCAC)** - 110 NIST SP 800-171 R2 required by DFARS clause 252.204-7012<br>- 24 selected from NIST SP 800-172 Feb2021, as detailed in table 1 to § 170.14(c)(4) - Pre-requisite CMMC Status of Level 2 (C3PAO) for the same CMMC Assessment Scope, for each Level 3 certification assessment<br>- Conducted by DIBCAC every 3 years<br>- Results entered into CMMC eMASS<br>- CMMC Status will be valid for three years from the CMMC Status Date as defined in § 170.4 - Permitted as defined in § 170.21(a)(3) and must be closed out within 180 days<br>- Final CMMC Status will be valid for three years from the Conditional CMMC Status Date - After each assessment and annually thereafter<br>- Assessment will lapse upon failure to annually affirm<br>- Level 2 (C3PAO) affirmation must also continue to be completed annually<br>- Entered into SPRS
## CMMC Post-Assessment Remediation: Plans of Actions and Milestones
The CMMC Program allows limited use of Plans of Action and Milestones (POA&Ms).
- **Level 1**: POA&Ms are not permitted.
- **Level 2 and Level 3**: Refer to §170.21 of the 32 CFR CMMC Program final rule for POA&M requirements, including critical requirements that cannot be included in a POA&M.
A POA&M closeout assessment is a CMMC assessment that evaluates only the NOT MET requirements identified in the initial assessment. The closing of a POA&M must be confirmed by a POA&M closeout assessment within 180 days of the Conditional CMMC Status Date. If the POA&M is not successfully closed out within this timeframe, the Conditional CMMC Status for the information system will expire.
- **Level 2 Self-Assessment**: The POA&M closeout self-assessment shall be performed by the OSA in the same manner as the initial self-assessment.
- **Level 2 Certification Assessment**: The POA&M closeout certification assessment must be performed by an authorized or accredited C3PAO.
- **Level 3 Certification Assessment**: The POA&M closeout certification assessment will be performed by DCMA DIBCAC.
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A Comprehensive Guide to ICS Protection Rockwell Automation UK
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https://www.rockwellautomation.com/en-us/company/news/blogs/what-is-ics-security.html
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industrial control systems security
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# A Comprehensive Guide to ICS Protection
The essentials of ICS security
The security of our critical infrastructure has never been more vital. At the heart of this concern, lies a crucial question: What is ICS security? Industrial Control System (ICS) security is the frontline defense protecting the systems that manage our power grids, water treatment facilities, manufacturing plants, and other essential industrial processes. As cyber threats evolve and target these critical systems with growing sophistication, understanding ICS security has become paramount for businesses, governments, and security professionals alike.
Whether you’re a seasoned professional in the industrial sector or new to the world of operational technology, this article will provide valuable insights into safeguarding the backbone of our modern industrial landscape. Join us as we delve into the intricacies of ICS security and discover why it’s a critical component in maintaining the safety, reliability, and resilience of our industrial infrastructure.
Learn More
What is an Industrial Control System?
Industrial Control Systems (ICS) are the backbone of modern industrial operations, serving as the nervous system for critical infrastructure and manufacturing processes. These systems encompass a wide range of technologies and equipment designed to monitor, control, and automate industrial processes across various sectors.
What is ICS security?
ICS security
, short for Industrial Control System security, is a specialized branch of cybersecurity that helps protect the critical systems that control and monitor industrial processes. Also known as Operational Technology (OT) security, it safeguards a wide range of industrial infrastructure including:
- Supervisory Control and Data Acquisition (SCADA) Systems that monitor and control processes across geographically dispersed locations, often in industries like power generation, water treatment, and oil and gas.
- Programmable Logic Controllers (PLCs) that automate specific tasks within an industrial process, such as controlling assembly lines or robotic arms.
- Distributed Control Systems (DCS) that manage complex industrial processes across interconnected controllers and sensors commonly found in refineries, chemical plants, and manufacturing facilities.
- Human-Machine Interfaces (HMIs) that interact with and control industrial processes.
Evolution in ICS Security
Traditionally, ICS operated in isolated environments, separate from corporate IT networks. However, the drive for efficiency and real-time data access has led to increased connectivity between ICS and IT networks. This convergence, often referred to as IT/OT integration, has brought significant benefits but also introduced new cybersecurity challenges.
The Industrial Internet of Things (IIoT) is further transforming ICS landscapes, enabling smart factories and predictive maintenance but also expanding the potential attack surface for cyber threats.
Key Components of ICS Security Include:
- Asset Inventory: Maintaining a comprehensive list of all devices and systems within the ICS environment.
- Vulnerability Management: Identifying, assessing, and mitigating vulnerabilities in ICS components.
- Network Segmentation: Isolating critical systems from less secure networks.
- Endpoint Protection: Securing individual devices within the ICS network.
- Patch Management: Safely updating software and firmware to address known vulnerabilities.
ICS security encompasses a range of practices and technologies designed to defend these systems from cyber threats to sustain industrial operations' integrity, availability, and safety. This doesn’t only help protect the digital systems themselves but also the physical infrastructure they control.
Industries Relying on ICS Security
- Energy and Utilities (power generation, water treatment)
- Manufacturing (automotive, food and beverage, pharmaceuticals)
- Transportation (railways, air traffic control)
- Oil and Gas (refineries, pipelines)
- Chemical Processing
- Mining and Metals
Importance of ICS Security
- Given the critical nature of the processes controlled by ICS, sustaining their security is paramount. A breach in an ICS could lead to:
- Production stoppages
- Equipment damage
- Environmental disasters
- Public safety risks
- Significant financial losses
Understanding the unique characteristics and requirements of Industrial Control Systems is crucial for developing effective ICS security strategies. As these systems become more connected and digitally dependent, the need for robust, specialized security measures becomes increasingly critical.
Examples of Real-World ICS Security Threats and Attacks
There were over 48,000 exposed ICS services
in the US in 2024. An example of an ICS security attack over the last year is with the Cyber Army of Russia Reborn (CARR). This nation-state organization gained unauthorized access via Telegram, tampered with the HMIs, and overflowed water storage tanks in Muleshoe, Texas. Causing downtime and damage.
Why Do We Need ICS Security?
The need for robust ICS security has never been more critical. As industrial systems become increasingly connected to corporate networks and the internet, they’ve become attractive targets for cybercriminals and state-affiliated threat actors. Consider these alarming statistics:
- According to the U.S. Cybersecurity and Infrastructure Security Agency (CISA), there was a 30% increase in cyber incidents targeting critical infrastructure sectors in 2023 compared to the previous year.
- The National Institute of Standards and Technology (NIST) reported that vulnerabilities in Industrial Control Systems increased by 44% in 2020.
- A report from the U.S. Government Accountability Office (GAO) found that the number of cybersecurity incidents reported by federal agencies increased by more than 1,300 percent from 2006 to 2015.
- The World Economic Forum’s Global Risks Report 2021 ranks cyberattacks on critical infrastructure as the 5th highest risk by likelihood and 8th by impact.
Potential Consequences of ICS Breaches
The impact of a successful attack on an ICS can be severe and far-reaching:
- Safety Risks: In 2021, a hacker attempted to poison the water supply in Oldsmar, Florida, by increasing the levels of sodium hydroxide in the water treatment system. While this attempt was thwarted, it highlights the potential for physical harm to the public.
- Economic Losses: The 2017 NotPetya attack, which affected numerous companies including shipping giant Maersk, resulted in estimated global damages of $10 billion.
- Environmental Damage: In 2000, a disgruntled former employee hacked into the control systems of a sewage treatment plant in Maroochy Shire, Australia, causing millions of liters of raw sewage to spill into local parks and rivers.
- National Security Threats: The 2015 attack on Ukraine’s power grid, attributed to Russian hackers, left 230,000 people without electricity for up to six hours, demonstrating the potential for ICS attacks to disrupt critical national infrastructure.
- Reputational Damage: In 2014, a German steel mill suffered significant damage when a cyberattack prevented the proper shutdown of a blast furnace. Beyond the immediate physical and financial impact, such incidents can severely damage a company’s reputation and customer trust.
These examples underscore the critical need for robust ICS security measures. As industrial systems become more interconnected and digitally dependent, the potential consequences of breaches grow more severe, making ICS security an imperative for organizations across all industrial sectors.
Financial Impact of Breaches in ICS Security
The Cyber Threat Snapshot from the Committee of Homeland Security
revealed that the average cost of a data breach in the US was $9.36 million—nearly double the global average.
Downtime is critical for businesses but can vary by industry. According to a recent study, Manufacturing spaces could be upwards of $260,000 per hour. Here are three key ways that you can calculate downtime based on industry:
- Manufacturing downtime = (Hourly labor cost + hourly overhead cost + hourly production cost) x downtime duration
- Wastewater treatment downtime = (Regulatory fines + environmental cleanup costs + labor costs + equipment repair/replacement + potential public health costs)
- Energy downtime = (Lost electricity sales + equipment repair/replacement + labor costs + regulatory fines + potential safety/environment costs)
Demonstrating ROI of Security Investments
While security is an investment, there are a few trackable metrics that can help you demonstrate ROI to your stakeholders:
- Reduction in Security Incidents: Monitor the number of successful and attempted cyberattacks, malware infections, and unauthorized access attempts.
- Improved Uptime: Track the percentage of uptime for critical systems and measure the reduction in unplanned downtime.
- Compliance with Regulations: Document compliance with industry standards and regulations to avoid fines and demonstrate due diligence.
- Risk Reduction: While difficult to quantify directly, emphasize the value of reducing the likelihood and impact of potential breaches. Use risk assessment frameworks to demonstrate the decrease in risk exposure.
How to Address Fear of Disrupting Critical Processes
Security doesn't have to mean downtime. There are a few ways to implement security measures strategically to help minimize disruption:
- Roll out security controls in phases based on priority from your OT security team
- Use virtual patching or compensating controls to address vulnerabilities without taking systems offline.
- Divide the network into isolated segments to limit the impact of the breach
- Implement backup systems to take over if one system needs to go offline
- Align your testing and update with the operations teams so there is no conflict with required uptime
How Does ICS Security Differ from IT Security?
Your ICS is the backbone of your company’s operations. They manage everything from power grids to manufacturing lines—and their smooth operation directly impacts your bottom line. While IT security focuses on data and networks, ICS security focuses on securing the physical processes that the systems control.
Unique Challenges of ICS Devices ICS environments often include legacy systems and specialized devices that pose unique security challenges:
- Many ICS devices run outdated operating systems (e.g., Windows XP) that no longer receive security updates.
- Embedded systems like PLCs (Programmable Logic Controllers) and RTUs (Remote Terminal Units) often lack built-in security features.
- ICS components typically have long lifecycles (15-20 years), making frequent updates or replacements impractical.
Differing Risk Priorities
The risk priorities in ICS and IT environments are fundamentally different:
- IT Security prioritizes: 1) Confidentiality, 2) Integrity, 3) Availability
- ICS Security prioritizes: 1) Safety, 2) Availability, 3) Integrity, 4) Confidentiality
This difference stems from the potential physical consequences of ICS breaches, which can include equipment damage, environmental disasters, or even loss of life.
Incident Detection and Response Detecting and responding to security incidents in ICS environments requires a different approach:
- ICS networks often have predictable traffic patterns, making anomaly detection more straightforward but requiring specialized knowledge to interpret.
- Response actions in ICS must be carefully planned to avoid disrupting critical processes. Unlike IT systems, you can’t simply shut down an ICS component if a threat is detected.
Requirement for Specialized Knowledge Effective ICS security requires a unique skill set:
- Deep understanding of industrial processes and control systems
- Knowledge of specialized protocols (e.g., Modbus, DNP3, OPC)
- Familiarity with regulatory requirements specific to industrial sectors (e.g., NERC CIP for power utilities)
This table provides a clear, side-by-side comparison of key differences between IT and ICS security.
By understanding these fundamental differences, organizations can develop more effective strategies for securing their industrial control systems, recognizing that a one-size-fits-all approach borrowed from IT security is insufficient for the unique challenges of the ICS environment.
How Do We Achieve ICS Security?
Securing Industrial Control Systems requires a comprehensive, strategic approach that addresses the unique challenges of the OT environment while leveraging best practices from IT security. Here’s how organizations can effectively achieve ICS security.
Setting Goals and Designing a Security Program
1. Assess Current State: Conduct a thorough inventory of all ICS assets and evaluate existing security measures.
2. Define Objectives: Set clear, measurable security goals aligned with industry standards (e.g., NIST Cybersecurity Framework, IEC 62443).
3. Develop Policies and Procedures: Create comprehensive security policies tailored to your ICS environment.
4. Implement Controls: Deploy technical, administrative, and physical controls to help protect your ICS assets.
5. Continuous Monitoring and Improvement: Regularly assess and update your security program to address emerging threats.
Integrating IT and OT for a Unified Security Approach
1. Bridge the Knowledge Gap: Facilitate knowledge sharing between IT and OT teams to build mutual understanding.
2. Establish Joint Governance: Create a cross-functional team to oversee ICS security initiatives.
3. Develop Integrated Processes: Align IT and OT security processes while respecting the unique requirements of each domain.
4. Implement Compatible Technologies: Choose security solutions that can operate effectively in both IT and OT environments.
5. Foster a Unified Security Culture: Promote a security-aware culture that spans both IT and OT personnel.
Choosing a Security Platform Over Individual Tools
Adopting an integrated security platform offers several advantages over implementing multiple point solutions:
- Comprehensive Visibility: A unified platform provides a holistic view of your entire ICS environment.
- Streamlined Management: Centralized management reduces complexity and improves efficiency.
- Consistent Policy Enforcement: Implement uniform security policies across your ICS landscape.
- Improved Incident Response: Correlate data from multiple sources for faster, more effective threat detection and response.
- Cost-Effective: Reduce total cost of ownership compared to maintaining multiple disparate tools.
- Scalability: Easily expand security coverage as your ICS environment grows or evolves.
ICS Security Framework
This framework provides a visual representation of how various security components work together to create a robust ICS security program.
By following these strategies and implementing a comprehensive security platform, organizations can significantly enhance their ICS security posture. Remember, achieving ICS security is an ongoing process that requires continuous attention, updates, and improvements to stay ahead of evolving threats and changing industrial landscapes.
The Critical Role of ICS Security in Today’s Connected World
Industrial Control System (ICS) security is not just a technical necessity—it’s a critical component of operational resilience and public safety in our increasingly connected world. As we’ve explored, ICS security:
- Helps protect the critical systems that control and monitor industrial processes across various sectors, from energy and utilities to manufacturing and transportation.
- Differs significantly from traditional IT security, with unique challenges stemming from legacy systems, specialized devices, and the prioritization of safety and availability.
- Requires a comprehensive approach that integrates asset management, vulnerability assessment, network segmentation, and continuous monitoring.
- Demands collaboration between IT and OT teams to create a unified security strategy that addresses the complexities of modern industrial environments.
- Plays a crucial role in safeguarding against cyber threats that could lead to production stoppages, equipment damage, environmental disasters, or even public safety risks.
Navigating ICS Security in the Age of IoT and Smart Manufacturing
While smart manufacturing is transforming industrial operations, it also introduces new security challenges. Connecting more systems and devices to the network expands the attack surface and makes ICS environments more vulnerable to cyberthreats.
As industrial systems become more interconnected and digitally dependent, the importance of robust ICS security measures cannot be overstated. It’s not just about protecting data—it’s about protecting data integrity, preventing unauthorized access, and ensuring the continued operation of the critical infrastructure that underpins our society and economy.
How to Fortify Your Industrial Control Systems Now
The landscape of ICS security is complex and ever-evolving, but you don’t have to navigate it alone. Take the first step towards strengthening your industrial cybersecurity posture:
- Assess Your Current State: Conduct a thorough inventory of your ICS assets and evaluate your existing security measures. Identify any gaps or vulnerabilities in your current approach.
- Educate Your Team: Verify that both your IT and OT personnel understand the unique challenges and importance of ICS security. Consider investing in specialized training programs.
- Develop a Roadmap: Create a comprehensive plan for enhancing your ICS security, including short-term wins and long-term strategic goals.
- Seek Expert Guidance: ICS security requires specialized knowledge and experience. Don’t hesitate to consult with professionals who can provide tailored advice and solutions for your specific industrial environment.
- Explore Unified Solutions: Consider how an integrated security platform could streamline your efforts and provide comprehensive protection across your ICS landscape.
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What Is Industrial Control System (ICS) Cyber Security?
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https://www.esecurityplanet.com/cloud/industrial-control-systems-cyber-security/
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industrial control systems security
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Yes (reduced from 30291 to 24783 chars)
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## What is an Industrial Control System (ICS)?
An industrial control system (ICS) refers to a broad set of control systems and associated instrumentation used for industrial process control. These systems are integral to the smooth operation of industries such as manufacturing, power generation, oil and gas, water management, and more. An ICS consists of hardware and software systems that monitor and control industrial equipment and processes.
ICS ranges from fully automated systems to manual operations with varying degrees of control and complexity. These systems can be simple, like managing a single machine, or complex, like overseeing the operation of an entire manufacturing plant. ICS integrates multiple technologies to ensure continuous and efficient industrial operations.
### What are the Key Components of ICS?
Industrial control systems (ICS) are essential for automating and controlling industrial processes. These systems ensure that industrial operations are efficient, safe, and reliable. Key components of ICS include:
**Supervisory Control and Data Acquisition (SCADA) Systems**
SCADA systems collect data from sensors and control systems in real-time. They provide an interface for operators to monitor and control processes remotely. SCADA systems also allow for data logging and trend analysis to enhance decision-making.
**Programmable Logic Controllers (PLCs)**
PLCs are specialized industrial computers used to automate machinery and processes. They interpret sensor input signals and make decisions based on programmed logic, controlling actuators and other devices to achieve desired outcomes.
**Distributed Control Systems (DCS)**
A DCS is used for large, complex industrial operations like power plants and refineries. It distributes control functions across multiple controllers, reducing the risk of a single point of failure. DCS integrates both hardware and software for process control and monitoring.
**Human-Machine Interface (HMI)**
The HMI is the interface through which operators interact with the control system. It provides graphical representations of processes and equipment, allowing operators to control machinery, view system status, and monitor alarms in real time.
**Sensors and Actuators**
- **Sensors:** These devices collect data from the physical environment, such as temperature, pressure, and flow rate. Sensors feed this data to the PLCs or DCS, allowing the system to make control decisions.
- **Actuators:** Actuators convert control signals into physical actions, such as opening a valve or adjusting a motor speed. They are responsible for executing the commands issued by the control system.
**Remote Terminal Units (RTUs)**
RTUs are field devices that interface with sensors and actuators in remote locations. They communicate with the central control system, allowing data collection and remote control over long distances.
**Industrial Networks**
Communication networks are crucial for connecting all components of an ICS. These networks enable data exchange between PLCs, RTUs, SCADA systems, and HMIs. Industrial networks include wired and wireless technologies such as Ethernet, Modbus, and Profibus.
**Security Solutions**
ICS systems are vulnerable to cyberattacks, so security solutions, including firewalls, intrusion detection systems, and encryption protocols, are vital to protect these critical infrastructures from unauthorized access and malicious activities.
**Control Room and Operator Workstations**
These are physical spaces where operators monitor and control industrial processes. The workstations provide access to the HMI, SCADA, and other system components, offering a central point for managing the entire industrial operation.
These key components work together to provide reliable, automated control of industrial processes, ensuring safety, efficiency, and productivity.
### Industrial Control System (ICS) Standards
Ensuring the security and reliability of industrial control systems involves adherence to industry standards designed to maintain safety and functionality. Several key ICS standards focus on protecting these critical systems from cyberthreats:
- **IEC 62443:** Developed by the International Electrotechnical Commission (IEC), this standard outlines security measures for automation and control systems.
- **NIST SP 800-82:** The National Institute of Standards and Technology (NIST) guidelines focused on securing ICS environments.
- **ISO/IEC 27001:** An international standard on managing information security, including within industrial contexts.
These standards provide frameworks for ensuring security throughout the lifecycle of an ICS, from design to operation, maintenance, and decommissioning.
## What is the Importance of Cybersecurity in an Industrial Control System (ICS)?
The potential for cyberattacks increases with industrial control systems becoming more interconnected through the Internet of Things (IoT) and cloud-based systems. Cybersecurity for industrial control systems is vital to prevent unauthorized access, data manipulation, and system disruption.
One recent example that underscores this importance is the 2021 Colonial Pipeline ransomware attack. This ICS attack disrupted fuel flow across the eastern United States, leading to shortages and financial losses. The breach occurred due to a cyber vulnerability within the ICS network, which hackers exploited to hold the system hostage for ransom.
The consequences of cyberattacks on ICS are far-reaching, from environmental disasters to halting production lines. Given the potential impact, ICS cyber security is paramount for industrial sectors.
## How Does ICS Security Work?
ICS cybersecurity involves safeguarding the communication and data flow between ICS components, preventing unauthorized access, and ensuring the integrity and availability of critical infrastructure. It comprises several layers of security measures, including:
- **Network segmentation:** Isolating critical control systems from business and external networks.
- **Intrusion detection and prevention systems (IDPS):** Monitoring network traffic for suspicious activity.
- **Role-based access control (RBAC):** Restricting system access based on user roles and responsibilities.
- **Encryption and secure communication protocols:** Protecting data in transit between ICS components.
- **Patch management:** Keeping software and firmware up to date to close security gaps.
Combined with ongoing monitoring and incident response planning, these mechanisms form the backbone of industrial control cybersecurity strategies.
## Top 10 ICS Threats to Watch Out For
Industrial control systems (ICS) face a constantly evolving landscape of cyberthreats, many of which can have severe consequences for operational safety, reliability, and security. These threats exploit vulnerabilities in both technology and human factors, making it critical for organizations to stay vigilant and proactive. The following are some of the most significant threats ICS environments face today:
### Malware & Ransomware
Malware and ransomware attacks specifically target ICS to disrupt industrial operations, encrypt critical data, or cause widespread damage to the system. Ransomware can cripple essential functions until a ransom is paid, while malware may lead to unauthorized control or surveillance of the system.
**Impact:** Disruption of critical processes, financial losses, and potential safety hazards in industries like energy, manufacturing, and transportation.
### Phishing Attacks
Phishing campaigns exploit human error by tricking employees or contractors into clicking on malicious links or attachments. These attacks can grant attackers access to ICS networks through compromised credentials or infected devices.
**Impact:** Unauthorized network access, data theft, or the spread of malware within the ICS infrastructure.
### Advanced Persistent Threats (APTs)
APTs are sophisticated, long-term attacks designed to infiltrate ICS networks and remain undetected for extended periods. These attackers often seek to gather sensitive information, manipulate system operations, or sabotage infrastructure by gaining deep access to critical systems.
**Impact:** Extensive data theft, espionage, or significant operational disruption when attackers eventually activate their malicious objectives.
### Insider Threats
Employees, contractors, or vendors with legitimate access to ICS systems can pose a serious security risk if they intentionally or unintentionally misuse their access. Insider threats are especially dangerous because they already bypass many traditional security barriers.
**Impact:** Sabotage, theft of proprietary information, or unintentional errors leading to system vulnerabilities.
### Denial-of-Service (DoS) Attacks
DoS attacks aim to overwhelm ICS networks or devices with excessive traffic, rendering the system inoperable. These attacks can halt industrial processes, disrupt communications, or take systems offline completely.
**Impact:** Downtime in critical infrastructure, loss of control over industrial processes, and potential damage to equipment.
### Supply Chain Attacks
Supply chain attacks target third-party vendors and service providers interacting with ICS environments. By compromising these external entities, attackers can access ICS networks indirectly, bypassing traditional security controls.
**Impact:** Widespread exposure to vulnerabilities, potentially affecting multiple organizations relying on the same suppliers or vendors.
### Remote Access Vulnerabilities
ICS systems often require remote access for monitoring and maintenance, but attackers can exploit weak authentication methods or insecure remote access points. These vulnerabilities may allow unauthorized individuals to control critical industrial processes from remote locations.
**Impact:** Unauthorized system manipulation leads to operational disruptions or safety hazards.
### Firmware Manipulation
Attackers can manipulate firmware in ICS components, such as controllers and sensors, by inserting malicious code to compromise operations. Firmware manipulation is particularly dangerous because it often remains undetected until significant damage occurs.
**Impact:** Sabotage of system functionality, unauthorized control over devices, and potentially catastrophic failures in industrial operations.
### Weak Encryption
Inadequate encryption or the complete absence of it in communication between ICS components can allow attackers to intercept sensitive information, such as control commands or operational data. This can lead to unauthorized actions within the system.
**Impact:** Intercepted data, manipulation of system commands, or unauthorized system control.
### Zero-Day Vulnerabilities
Zero-day vulnerabilities refer to unknown or newly discovered flaws in ICS software or hardware that have not yet been patched. Attackers exploit these weaknesses before developers can release security updates, making them particularly dangerous.
**Impact:** Unpatched systems are left vulnerable to exploitation, which can lead to significant breaches or operational damage.
Industrial control systems’ growing complexity and interconnectivity have made them attractive targets for cybercriminals and nation-state actors. Addressing these threats requires a multi-layered security approach, including employee training, robust access controls, network segmentation, frequent patching, and ongoing monitoring to detect and respond to potential attacks. Staying vigilant and adopting industry standards can help mitigate these evolving cyberthreats and ensure ICS environments’ continued safety and functionality.
## How to Secure an ICS from Cyberattacks?
Securing an ICS from cyberattacks requires a comprehensive strategy that addresses various vulnerabilities and strengthens defenses. Here are key strategies for improving ICS cybersecurity:
- **Conduct a Risk Assessment:** Regularly evaluate potential risks to your ICS to identify vulnerabilities and threats. Understanding your risk landscape helps prioritize security measures.
- **Implement Network Segmentation:** Ensure ICS networks are isolated from business IT networks. This separation reduces the risk of lateral movement by attackers and protects critical control systems from broader network threats. For insights into network security threats and strategies to mitigate them, you can refer to this network security threats guide.
- **Use Multi-Factor Authentication (MFA):** Enhance login security across ICS platforms by requiring multiple verification forms. MFA adds an extra layer of protection against unauthorized access.
- **Establish Access Controls:** Limit access to ICS systems to only those personnel whose roles require it. Implement role-based access controls to ensure users can only access the data and systems necessary for their duties.
- **Keep Systems Up to Date:** Apply security patches and updates as soon as they become available. Keeping systems current helps to close vulnerabilities that attackers could exploit.
- **Develop an Incident Response Plan:** Prepare for quick response and recovery in case of a cyberattack. An effective incident response plan ensures that your team can efficiently manage and mitigate the impact of security breaches.
## ICS Security Best Practices
To safeguard your industrial control systems (ICS) from cyberthreats, follow these key best practices:
- **Regular audits and vulnerability assessments:** Conduct routine reviews to identify system weaknesses and potential attack vectors.
- **Continuous network monitoring:** Implement real-time monitoring tools to detect and alert any suspicious activity within the network.
- **Cybersecurity awareness training:** Educate employees about cybersecurity risks and teach them how to spot potential threats.
- **Enforce strong password policies:** Use complex, unique passwords and update them regularly to strengthen system security.
- **Deploy endpoint protection:** Install antivirus, anti-malware, and firewall solutions on all ICS devices to block malicious access.
- **Backup critical data:** Frequently back up essential system data to ensure quick recovery during an attack.
By adhering to these practices, you can effectively enhance the security of your ICS environment and reduce potential risks.
## Emerging Trends in ICS Security
As industrial control systems (ICS) continue to evolve, so do the methods for protecting them. With the rise of more sophisticated cyberthreats, new trends are emerging to strengthen ICS security. Key developments include:
### AI & Machine Learning
Automated threat detection and response are becoming increasingly prevalent, allowing ICS networks to identify and neutralize potential security risks without human intervention quickly.
### Behavioral Analytics
By analyzing typical user behavior, this technology detects deviations that may signal insider threats or malicious activity, providing an early warning system for potential breaches.
### Zero-Trust Architecture
This approach ensures strict access controls, where no user or device is trusted by default—even within the network. Every access request is verified, reducing the risk of internal vulnerabilities.
### Cloud-Based ICS Security
As more industrial systems leverage cloud infrastructure for remote monitoring and control, securing these cloud environments becomes critical, requiring advanced encryption and access controls.
### Blockchain Technology
Blockchain is gaining traction for securing data exchanges between ICS devices by offering tamper-proof, decentralized records that prevent unauthorized alterations or hacks.
### Quantum Cryptography
Future-proofing ICS security, quantum encryption techniques offer unprecedented levels of data protection, ensuring that even the most advanced hacking methods cannot breach secure communications.
These emerging cybersecurity trends underscore the ongoing evolution of ICS security, helping industries adapt to technological advancements while safeguarding their critical infrastructure from modern cyber threats.
## Bottom Line: Securing Industrial Control Systems
Securing industrial control systems is a critical task that demands continuous vigilance, the latest technologies, and strict adherence to industry standards. As cyberthreats evolve and become more sophisticated, businesses must prioritize ICS cyber security to safeguard their critical infrastructure. Understanding the components of ICS, implementing best practices, and staying abreast of emerging trends are essential steps in this process.
**Staying informed and proactive in your security approach will help defend against cyberattacks and ensure the resilience of your industrial control systems. Explore this network security guide for comprehensive strategies and insights into maintaining robust network security, including protecting your ICS.**
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What Is SIEM? Microsoft Security
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https://www.microsoft.com/en-us/security/business/security-101/what-is-siem
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SIEM security monitoring
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# What is SIEM?
## Introduction to SIEM
One essential component of effective cybersecurity is a security information and event management (SIEM) solution. These types of solutions collect, aggregate, and analyze large volumes of data from organization-wide applications, devices, servers, and users in real time. By consolidating this vast array of data into a single, unified platform, SIEM solutions provide a comprehensive view of an organization's security posture, empowering security operation centers (SOC) to detect, investigate, and respond to security incidents swiftly and effectively. SIEM solutions can help organizations of all sizes:
- Gain visibility into their security posture by centralizing and analyzing data from disparate sources.
- Detect and identify potential security breaches and threats in real time, minimizing the risk of compromise.
- Investigate and triage security incidents efficiently, reducing the time and resources required for resolution.
- Comply with regulatory and industry-specific security standards and frameworks.
## Key takeaways
- SIEM solutions enhance threat detection and incident response by aggregating and analyzing data from various sources.
- Centralized visibility and compliance management help security teams protect their organization from a growing attack surface.
- The key components of a SIEM solution are log management, event correlation, continuous monitoring, and incident response.
- Over time, SIEM solutions have incorporated AI and automation to improve security team efficiency and effectiveness.
- SIEM solutions can also be integrated with other tools, like extended detection and response.
## History and evolution of SIEM
As networks grew in the 1990s and more companies connected to the internet, firewalls became less effective at detecting and blocking threats. Security professionals needed a better way to gather, correlate, and prioritize alerts from various systems across the network. To address this need, security vendors combined security information management (SIM) and security event management (SEM) to create SIEM solutions.
**Early days of SIEM**
The early iterations of SIEM solutions emerged in the early 2000s, primarily focusing on log management and compliance reporting. These solutions centralized alerts from across the network, saving SOCs valuable time, but, unfortunately, they weren’t very scalable. Security teams relied heavily on manual processes, making it difficult to correlate data effectively.
**Evolution and advancements**
As cyberthreats became more sophisticated, SIEM solutions evolved to include real-time monitoring, advanced analytics, and machine learning capabilities. This shift allowed organizations to detect anomalies and respond to threats faster than ever before.
**Current state of SIEM technology** Today, SIEM solutions incorporate AI for cybersecurity and machine learning to enhance their analytical capabilities. Modern SIEM platforms not only provide security monitoring but also integrate with security orchestration, automation and response (SOAR) solutions to help teams automate certain tasks and coordinate their response to incidents.
## Key components of SIEM
A robust SIEM solution is built on several key components that work together to provide comprehensive security monitoring.
**Log management**
SIEM systems collect and analyze logs from across the entire organization, including servers, network devices, firewalls, other security solutions, and cloud applications. The goal of this data collection is to uncover anomalies that indicate a potential threat. Many SIEM solutions also ingest threat intelligence feeds, which allow security teams to identify and block emerging cyberthreats.
**Event correlation** SIEM solutions are effective because they bring together data from multiple systems across an enterprise. They analyze that data and look for patterns across different entities. For example, if there’s evidence of a compromised account and also unusual network traffic, a SIEM might identify that these two events are related and generate an alert for security teams to further investigate. Event correlation helps detect activity that seems benign on its own, but when combined with other activity, can be an indicator of compromise.
**Incident response and monitoring**
To detect threats early and minimize damage, SIEM solutions monitor digital and on-premises systems continuously. Analysis is displayed in a central dashboard, and the SIEM solution will also send alerts to security analysts based on pre-defined rules.
Many SIEM solutions also include automated response capabilities. In certain instances, the SIEM can take action automatically based on rules defined by the SOC. For example, if the SIEM solution detects possible malware, it could take steps to isolate the infected system based on predefined rules. Automation helps accelerate response and frees up security analysts to focus on more complex tasks and issues.
## How SIEM works
The key to an effective SIEM system is data. SIEM solutions continuously gather data from various sources, including firewalls, cloud apps, security systems, and endpoints. The aggregated data is then normalized to standard formats and parsed to extract relevant information. Using algorithms and correlation rules, the SIEM is able to identify patterns and anomalies in the normalized data and surface potential threats. A centralized dashboard and alerts help security analysts identify events that require further investigation.
BENEFITS
## Benefits of SIEM
SIEM tools offer many benefits that can help strengthen an organization’s overall security posture.
### Expanded visibility
With people working from anywhere and IT infrastructure spread across multiple clouds, there are now many more entryways for a bad actor to attack an organization. To protect their companies, security professionals need to monitor all those possible attack vectors, which is nearly impossible to do manually. A SIEM simplifies this by bringing data and insights from across the enterprise into a single portal.
### Enhanced threat detection
Because threat actors often move across apps, devices, and users, it can be difficult to detect them. SIEM solutions help uncover these stealth attackers by aggregating, analyzing, and correlating data from across the entire environment. This helps SOCs quickly identify and respond to multidomain threats.
### Improved SOC efficiency
A SIEM solution cuts down significantly on the amount of manual work in a modern SOC. Centralized dashboards and event correlation help teams pinpoint serious incidents quickly. Reports and SOAR integration make communication between security team members easier, allowing them to work together efficiently to respond to threats.
### Centralized investigations
By unifying log files and other security data, a SIEM provides a single location for security analysts to conduct investigations into potential incidents. They can re-create past events and dig into new ones using analysis from across the entire organization.
### Efficient response
Effective collaboration and comprehensive investigations make it easier for security teams to quickly respond to security incidents. Many SIEM solutions also offer AI-powered automation that can quickly address certain types of incidents, allowing humans to focus on more complex issues.
### Regulatory compliance support
With real-time audits and reporting capabilities, a SIEM solution provides organizations with the necessary tools to meet regulatory compliance requirements, reducing the risk of penalties and reputational damage with customers and the community.
## Keys to successful SIEM implementations
To get the most out of a SIEM solution, it’s important to carefully plan your implementation.
1. Clearly outline what you want to achieve with the SIEM, such as compliance reporting, threat detection, or incident response and develop specific use cases tailored to your organization’s needs.
2. Evaluate different SIEM solutions based on your requirements, scalability, budget and how well it will integrate with existing tools and technologies.
3. Identify and prioritize data sources to feed into the SIEM and set up the necessary permissions to these data sources. It’s best to start with broad data collection and gradually refine it based on what’s most relevant.
4. Standardize data formats from different sources to make it easier to analyze.
5. Establish log retention and security policies based on regulatory requirements and organizational needs.
6. Develop clear workflows for incident detection, analysis, and response.
7. Determine which actions you want to automate and define clear rules and steps.
8. Provide ongoing training for staff on how to use the SIEM solution effectively and understand its outputs.
9. Regularly review and adjust rules, alerts, and dashboards based on evolving threats and organizational changes.
## SIEM use cases
Security teams use SIEM solutions for a wide variety of applications.
**Threat detection and response**
The most common use case for a SIEM solution is threat detection and response. A SIEM can help a security team uncover and respond to even some of the most complex threats, such as insider threats, advanced persistent threats, and multidomain attacks.
**Compliance management** SOCs often use a SIEM solution to help them stay compliant with regional regulations like the Health Insurance Portability and Accountability Act (HIPAA) in the United States and the General Data Protection Regulation (GDPR) in the European Union. Because a SIEM system automatically collects data from across the organization, it can help teams identify issues quickly. They can also use a SIEM to generate compliance reports tailored to specific regulations.
**Forensic Analysis** To effectively respond to a security incident, SOCs need to understand the full scope of the attack, including motivations and tactics. A SIEM solution provides reporting and analysis to help teams determine the attack path and identify all the affected assets.
## Emerging trends in SIEM
To effectively analyze an ever-increasing volume of data, many SIEM solutions incorporate AI, machine learning, and user behavior and entity analytics (UEBA) to enhance threat detection capabilities and reduce false positives. Advances in AI technology and cybersecurity analytics will continue to allow SIEM solutions to improve complex analysis and support more data types.
One of the biggest security challenges that organizations face is managing multiple, disparate security solutions, all with their own interfaces, tools, and insights. Robust SIEM solutions simplify security by incorporating other tools like extended detection and response (XDR). XDR solutions monitor and protect endpoints, users, apps, and clouds. Integrating all these solutions into a single unified SecOps platform will give teams comprehensive security management in one place.
## SIEM solutions
When choosing a SIEM solution, it’s important to consider scalability, ease of use, and integration capabilities. Many SIEM solutions, like Microsoft Sentinel, include built-in data connectors, so that organizations can integrate it with their existing apps and services. Microsoft Sentinel is also included in a unified SecOps platform that combines XDR. SOAR, and SIEM capabilities.
### What is a SIEM vs SOC?
A SIEM is a platform that collects, aggregates, and analyzes security-related data from various sources within an organization's IT infrastructure. It provides a centralized view of security events and helps organizations detect, investigate, and respond to security incidents. A SOC is a team of security professionals who monitor and analyze security events, investigate security incidents, and respond to security threats. A SIEM is the technology used by a SOC to collect, analyze, and respond to security events.
### Is a SIEM a firewall?
No, a SIEM is not a firewall. A firewall is a network security device that controls incoming and outgoing network traffic based on a set of rules. A SIEM collects, aggregates, and analyzes security-related data from various sources and helps organizations detect, investigate, and respond to security incidents.
### What is a SIEM solution?
A SIEM solution is security software that gives organizations a bird’s-eye-view of activity across their entire network so they can respond to threats faster—before business is disrupted.
SIEM software, tools and services detect and block security threats with real-time analysis. They collect data from a range of sources, identify activity that deviates from the norm, and take appropriate action.
### How has SIEM improved in recent years?
SIEM solutions have seen significant improvements in recent years due to advancements in technology and the evolving landscape of cybersecurity threats. Here are some key areas of enhancement:
01. Enhanced analytics: Modern SIEMs use advanced analytics, including machine learning and AI, to detect anomalies and identify potential threats more accurately and quickly.
02. Integration with cloud services: With the rise of cloud computing, SIEM solutions have improved their capabilities to collect and analyze data from various cloud environments, making them more versatile.
03. Automation and orchestration: Many SIEMs now include automation features that streamline incident response processes, allowing for quicker mitigation of threats and reducing the manual workload for security teams.
04. User behavior and entity analytics: Improved UEBA capabilities help organizations detect insider threats and account or device compromise by analyzing user and entity behavior patterns.
05. Real-time monitoring: Enhanced real-time data collection and analysis allows organizations to respond to incidents as they happen, rather than after the fact.
06. Scalability: SIEM solutions have become more scalable, accommodating the growing volume of data generated by organizations and ensuring they can handle increasing loads without sacrificing performance.
07. Better reporting and compliance: Enhanced reporting features help organizations meet regulatory requirements more easily and provide clearer insights into security posture.
08. Threat intelligence integration: Many SIEMs now integrate with threat intelligence feeds, providing contextual information about emerging threats and vulnerabilities.
09. User-friendly interfaces: Modern SIEMs often come with more intuitive dashboards and user interfaces, making it easier for security teams to navigate and analyze data.
10. Community and ecosystem collaboration: Greater collaboration among security vendors and the creation of ecosystems allow for better integration with other security tools, enhancing overall security operations.
These advancements help organizations better detect, respond to, and manage security incidents, making SIEM a critical component of modern cybersecurity strategies.
### What is the difference between SIEM and SOAR?
SIEM and SOAR technologies both play significant roles in cybersecurity.
Simply put, SIEM helps organizations make sense of the data collected from applications, devices, networks, and servers by identifying, categorizing, and analyzing incidents and events.
SOAR stands for security orchestration, automation and response and describes software that addresses threat and vulnerability management, security incident response, and security operations (SecOps) automation.
SOAR helps security teams prioritize threats and alerts created by SIEM by automating incident response workflows. It also helps find and resolve critical threats faster with extensive cross-domain automation. SOAR surfaces real threats from massive amounts of data and resolves incidents faster.
### What is the difference between SIEM vs XDR?
Extended detection and response, or XDR for short, is an emerging approach to cybersecurity to improve threat detection and response with deep context into specific resources.
XDR platforms help:
- Investigate attacks with understanding into specific resources, across platforms and clouds—unified across endpoints, users, applications, IoT, and cloud workloads.
- Protect resources and harden posture to guard against threats like ransomware and phishing.
- Respond to threats faster using auto-remediation.
SIEM solutions provide a comprehensive SecOps command-and-control experience across the entire enterprise.
SIEM platforms help:
- Manage security operations from your bird's-eye view of the estate.
- Collect and analyze data from your entire organization to detect, investigate, and respond to incidents that cross silos.
- Enhance SecOps efficiency with customizable detections, analytics, and built-in automation.
A strategy that includes both broad visibility across the entire digital estate and depth of knowledge into specific threats, combining SIEM and XDR solutions, helps SecOps teams overcome their daily challenges.
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SIEM Cyber Security Capabilities, 4 Common Challenges & Solutions
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https://www.cynet.com/siem/siem-cyber-security-capabilities-4-common-challenges-solutions/
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SIEM security monitoring
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Yes (reduced from 20305 to 17534 chars)
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In this article
- Why Is SIEM Important for Cyber Security?
- Key Cybersecurity Capabilities of SIEM Solutions
- SIEM Security Challenges and How to Overcome Them
- Overcoming SIEM Challenges by Integrating XDR
- Security Automation with Cynet
# SIEM Cyber Security Capabilities, 4 Common Challenges & Solutions
## What Is SIEM?
Security Information and Event Management (SIEM) systems provide real-time analysis of security alerts generated by applications and network hardware. SIEM software collects and aggregates log data generated throughout the organization’s technology infrastructure, from host systems and applications to network and security devices such as firewalls and antivirus filters.
SIEM solutions are critical for comprehensive threat detection, as they centralize the security data collected from various sources, allowing for faster identification, analysis, and response to potential security events. By integrating outputs from multiple products, SIEMs provide a unified approach to understanding and managing threats, enhancing the security posture of an organization.
## Why Is SIEM Important for Cyber Security?
### Threat Detection and Prevention
SIEMs play an essential role in threat detection by constantly monitoring data for signs of unusual activity that could indicate a security threat. This continuous monitoring ensures that all events are analyzed, providing security teams with the ability to detect malicious activity early and mitigate potential threats promptly.
SIEM’s sophisticated analytics tools and integrated threat intelligence helps organizations detect advanced threats and prioritize security events based on their potential impact.
### Incident Response Efficiency
With SIEM, organizations can dramatically improve the efficiency of their incident response activities. The centralized dashboard provided by SIEM systems offers immediate insights, supporting quick decision-making during a critical security event. This results in a more coordinated and timely response, reducing potential damages.
Additionally, SIEMs automate much of the incident response process by pre-establishing workflows and response scenarios. This automation ensures that all team members are aware of their tasks and can operate quickly and within a structured framework.
### Regulatory Compliance
SIEM solutions also ease the burden of compliance with regulations such as GDPR, HIPAA, and PCI DSS. By consolidating and securing logs of all network and application activity, SIEMs create a clear, immutable trail of evidence that can be analyzed to ensure compliance with various standards and provide the data necessary for internal and external audits.
Most SIEMs are also equipped with features specifically designed to assist with compliance management, such as predefined reports for common regulatory requirements. These tools significantly reduce the time and effort required to prepare for audits by automatically generating necessary documentation and reports.
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- Full-Featured EDR and NGAV
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## Key Cybersecurity Capabilities of SIEM Solutions
Here are the primary cybersecurity features and capabilities SIEM solutions provide.
### Real-Time Event Correlation
One of the most impactful features of SIEM systems is real-time event correlation, which automatically links related records to identify patterns that may indicate a security threat. This capability allows security teams to quickly detect complex threats that are not identifiable through a single event or log entry.
Real-time correlation expedites the detection of suspicious activities that could unfold over minutes, hours, or days, ensuring threats are recognized as soon as they develop.
### Alerting and Notifications
SIEM systems provide automated alerting and notification mechanisms to inform security personnel of critical incidents as they occur. This feature ensures that potential threats are promptly addressed before they can cause significant damage. Alerts can be customized based on severity, type, or other criteria to ensure that they capture truly threatening activities without overwhelming the staff with false positives.
SIEMs can also escalate alerts automatically to ensure that high-priority security incidents are communicated to the right personnel or management without delay. This improves the speed and efficiency of response efforts.
### Threat Intelligence Integration
Integration with threat intelligence feeds is another crucial feature of SIEM systems, enhancing the detection of new and emerging threats. These feeds provide contextual data about known bad actors, vulnerabilities, and attack methodologies, enriching the internal data with external threat intelligence. This integration helps organizations stay ahead of attackers.
Threat intelligence feeds also assist in fine-tuning SIEM rules and alerts based on the latest threat landscape, allowing for more accurate threat detection and fewer false positives. This proactive approach provides organizations with a dynamic defense posture, significantly enhancing their ability to counter sophisticated cyber threats.
### User Access Monitoring
SIEM systems enhance security by monitoring and controlling access to sensitive systems and information. They track and log all access events, which helps organizations detect unauthorized attempts to gain access to critical resources. Monitoring privileged users is particularly important as these accounts can alter system settings or access sensitive data, making them a prime target for attackers.
In addition to access monitoring, SIEMs can enforce user access policies and regulations, automatically alerting administrators of policy violations. This tight control over user activities helps prevent data breaches and ensures that all users comply with the organization’s security policies.
### User and Entity Behavior Analytics (UEBA)
UEBA is a feature within advanced SIEM systems that utilizes machine learning and statistical models to establish baseline normal behavior for users and entities within the network. By continuously comparing new behavior against this baseline, UEBA can identify activities that deviate from the norm, potentially indicating malicious intent or a compromised account.
Additionally, UEBA can detect anomalies in data access and usage that traditional security tools might overlook, such as lateral movements or data exfiltration attempts by already authenticated users. This capability makes UEBA a vital component in the detection of insider threats and advanced persistent threats (APTs), where unauthorized activities blend in with regular operations.
Tips From the Expert
**1\. Tailor SIEM Deployment to Your Environment:**
Customize your SIEM to align with your unique network architecture, application landscape, and business processes. This ensures the system monitors the most relevant data sources and provides actionable insights.
**2\. Integrate with Endpoint and Network Security Tools:**
Enhance your SIEM’s capabilities by integrating it with EDR and NDR tools. This provides a more comprehensive view of threats across all layers of your IT infrastructure, improving detection accuracy.
**3\. Regularly Update and Tune Correlation Rules:**
Keep your SIEM’s correlation rules up-to-date by refining them based on new threat intelligence and past incident data. This ongoing tuning helps reduce false positives and ensures the SIEM adapts to emerging threats.
**4\. Leverage Machine Learning for Advanced Threat Detection:**
Incorporate machine learning algorithms within your SIEM to improve anomaly detection and reduce false positives. Machine learning can identify patterns and behaviors that traditional rule-based systems might miss.
**5\. Implement Role-Based Access Controls:**
Enforce strict RBAC within your SIEM to ensure only authorized personnel can view, modify, or respond to security alerts. This minimizes the risk of insider threats and protects sensitive security data.
**Eyal Gruner is the Co-Founder and Board Director** at Cynet. He served as the company’s CEO for nine years, guiding its growth from the very beginning. He is also Co-Founder and former CEO of BugSec, Israel’s leading cyber consultancy, and Versafe, acquired by F5 Networks. Gruner began his career at age 15 by hacking into his bank’s ATM to show the weakness of their security and has been recognized in Google’s security Hall of Fame.
## SIEM Security Challenges and How to Overcome Them
While SIEM is a critical component of most security stacks, it also raises challenges for security teams. Here are the primary challenges and how your organization can address them.
### 1\. Noise in Event Data
SIEM platforms typically process vast amounts of log data, which can lead to significant noise, i.e., large volumes of non-threat-related data that obscure actual security threats. This noise complicates the threat detection process, potentially causing critical warnings to be overlooked among false positives.
**Overcoming the challenge:**
- **Implement advanced filtering:** Apply more refined filtering rules to discard irrelevant or redundant log entries before they are processed. This approach reduces the volume of data to analyze, making it easier to spot genuine threats.
- **Leverage machine learning:** Utilize machine learning algorithms to better identify patterns and anomalies within the data, which can help distinguish between normal activities and potential security threats. This can increase the accuracy of threat detection and reduce false positives.
### 2\. Blind Spots in Data Sources
SIEM’s effectiveness depends on the comprehensiveness of the data it analyzes. Blind spots in data collection can occur if certain network segments, systems, or applications are not adequately covered by the SIEM’s data collection framework. This may arise due to technical limitations, architectural complexities, or oversight in the deployment phase.
**Overcoming the challenge:**
- **Comprehensive integration:** Ensure all potential data sources are integrated into the SIEM system, including cloud services, remote endpoints, and third-party applications. This creates a more complete view of the security landscape.
- **Regular audits and updates:** Conduct regular audits to identify any new or previously overlooked data sources. Keep the SIEM configuration updated to include these sources to maintain visibility across the entire network.
### 3\. Ineffective Correlation Rules
In SIEM systems, correlation rules determine how different events are linked to detect multi-stage attacks and subtle anomalies. However, if these rules are not well defined or maintained, they may either fail to detect actual threats or generate an overwhelming number of false positives. This could lead to crucial alerts being ignored or valuable resources wasted on investigating non-issues.
**Overcoming the challenge:**
- **Continuous rule optimization:** Regularly review and update correlation rules to adapt to the evolving threat landscape and organizational changes. This includes removing outdated rules and adjusting others to improve accuracy.
- **Customize rules based on context:** Develop context-aware correlation rules that take into account the specific environment, such as the type of business, typical network traffic patterns, and known safe behaviors.
### 4\. Alert Fatigue
Alert fatigue occurs when security teams are overwhelmed by a high volume of alerts, many of which may be false positives. This can lead to slower response times, overlooked alerts, and increased risk of missing actual threats. Constant exposure to large numbers of alerts can desensitize staff to notifications, reducing their attentiveness and effectiveness.
**Overcoming the challenge:**
- **Prioritize and classify alerts:** Implement a tiered alert system that classifies alerts by severity and potential impact. This allows teams to focus on the most critical issues first, reducing the cognitive load and improving response times.
- **Enhance alert management with automation:** Use automation to handle low-priority alerts and routine tasks, freeing up security personnel to concentrate on more complex and serious threats. Automated response protocols can also help mitigate threats faster.
## Overcoming SIEM Challenges by Integrating XDR
Extended Detection and Response (XDR) solutions can significantly enhance SIEM capabilities by providing a more holistic approach to threat detection and response. By integrating XDR, organizations can consolidate data from various security products into a single platform, offering a unified view that helps identify and respond to sophisticated attacks more efficiently.
XDR’s ability to correlate data across different security layers—endpoint, network, cloud, and applications—complements SIEM’s log management capabilities, providing deeper insights and more accurate threat detection.
XDR systems often include more advanced analytical tools and machine learning capabilities than traditional SIEM solutions. These features can help reduce false positives and enhance threat detection by learning from security events and adapting over time. In addition, integrating XDR with SIEM can alleviate alert fatigue by leveraging XDR’s ability to filter out irrelevant data and prioritize threats based on their severity and impact.
## Security Automation with Cynet
Cynet provides the world’s first Autonomous Breach Protection platform that natively integrates endpoint, network and user attack prevention/detection of XDR with log management and analysis of CLM and automated investigation and remediation capabilities of SOAR, backed by a 24/7 world-class MDR service.
End to end, fully automated breach protection is now within reach of any organization, regardless of security team size and skill level. Most smaller businesses find that Centralized Log Management (CLM) is fully sufficient for their needs while far more affordable and usable than SIEM solutions.
### XDR Layer: End-to-End Prevention & Detection
- **Endpoint protection**—multilayered protection against malware, ransomware, exploits and fileless attacks.
- **Network protection**—protecting against scanning attacks, MITM, lateral movement and data exfiltration.
- **User protection**—preset behavior rules coupled with dynamic behavior profiling to detect malicious anomalies.
- **Deception**—wide array of network, user, file decoys to lure advanced attackers into revealing their hidden presence.
### CLM Layer: Log Management and Analysis
- **Ingest log data**—collect all pertinent log data to uncover threats across your environment
- **Data visualization**—advanced, targeted data queries pinpoint precursors to cyberattacks and perform forensic analysis
- **Threat hunting**—uncover evidence of compromised endpoints, systems, and data such as anomalous privileged account activity and anomalous outbound traffic
- **Regulatory compliance**—generate reports for FISMA, GLBA, HIPAA, SOX, and PCI DSS, for example, that regulatory bodies require.
### SOAR Layer: Response Automation
- **Investigation**—automated root cause and impact analysis.
- **Findings**—actionable conclusions on the attack’s origin and its affected entities.
- **Remediation**—elimination of malicious presence, activity and infrastructure across user, network and endpoint attacks.
- **Visualization**—intuitive flow layout of the attack and the automated response flow.
### MDR Layer: Expert Monitoring and Oversight
- **Alert monitoring**—First line of defense against incoming alerts, prioritizing and notifying customers on critical events.
- **Attack investigation**—Detailed analysis reports on the attacks that targeted the customer.
- **Proactive threat hunting**—Search for malicious artifacts and IoC within the customer’s environment.
- **Incident response guidance**—Remote assistance in isolation and removal of malicious infrastructure, presence and activity.
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The 14 Best Vulnerability Scanning Tools in 2025 - FireMon
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https://www.firemon.com/blog/vulnerability-scanning/
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vulnerability assessment tools
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With the rise in cyber threats, vulnerability assessment tools have become an essential component of network security. These tools allow organizations to identify, assess, and address potential security weaknesses in their IT infrastructure before they can be exploited.
This guide explores fourteen of the best vulnerability scanning tools available today, examining their features, ideal use cases, and pricing to help businesses choose the right solution.
## **Why Is It Important to Scan Your Network for Vulnerabilities?**
Vulnerability scanning is essential for protecting your IT infrastructure against increasingly sophisticated cyberattacks. These tools provide proactive insights to help prevent:
- **Ransomware Attacks:** Identify and remediate vulnerabilities before they can be exploited, reducing the risk of ransomware incidents that are projected to exceed $20 billion in global costs by the end of 2024.
- **Cloud Misconfigurations:** Detect and correct cloud-based security gaps, a leading cause of nearly half of all cyberattacks targeting businesses.
- **Data Breaches:** Pinpoint unpatched software and misconfigurations that could expose sensitive data to malicious actors.
- **Compliance Violations:** Ensure adherence to industry regulations like PCI DSS and GDPR through automated scanning and reporting.
- **Operational Downtime:** Avoid costly disruptions by closing gaps in your network’s protection before they lead to incidents that impact business continuity.
- **Human Error:** Reduce errors from misconfigurations or oversight with automated scans and actionable recommendations.
## See How FireMon Can Protect Your Global Hybrid Environment
## **Top 14 Vulnerability Scanning Tools**
The following is an overview of the 14 best vulnerability scanning tools that enhance cybersecurity and provide essential protection for enterprise networks.
### **1\. FireMon**
FireMon enhances vulnerability scanning by integrating real-time policy monitoring and attack surface management. It empowers organizations to detect and prioritize vulnerabilities across hybrid and multi-cloud environments. With its intuitive dashboards and API integration, FireMon enables seamless automation and ensures effective remediation while maintaining compliance.
### **2\. Tenable Nessus**
Tenable Nessus is a cornerstone of vulnerability scanning, known for its extensive plugin library and real-time updates. It enables organizations to conduct over 100,000 vulnerability checks across on-premises, cloud environments, and containers. This comprehensive scanning capability helps security teams identify and deal with potential exposures before they can be exploited.
### **3\. Qualys VMDR**
Qualys VMDR (Vulnerability Management, Detection, and Response) combines vulnerability scanning with AI-driven risk prioritization, making it an essential tool for enterprises managing large IT infrastructures. Its automated compliance checks and detailed reporting streamline vulnerability management workflows, helping businesses maintain secure and compliant environments.
### **4\. Rapid7 InsightVM**
Rapid7 InsightVM ties directly to vulnerability scanning by offering risk-based scoring and dynamic dashboards to visualize your security posture in real time. By integrating with SIEMs and IT automation tools, InsightVM simplifies the vulnerability remediation process, allowing businesses to handle their most critical risks efficiently.
### **5\. Acunetix**
Acunetix focuses on web application vulnerability scanning, identifying security issues such as SQL injection and cross-site scripting (XSS). Its ability to integrate with CI/CD pipelines ensures that vulnerabilities in web applications are detected and corrected during development, making it ideal for DevSecOps teams.
### **6\. Nmap**
Nmap (Network Mapper) supports vulnerability scanning by providing a lightweight, flexible tool for discovering open ports, running services, and potential misconfigurations across a network. Its customizable scripting engine allows security professionals to tailor scans, uncover vulnerabilities, and prioritize mitigation efforts effectively.
### **7\. Wiz Vulnerability Management**
Wiz specializes in vulnerability scanning for cloud-native environments, using AI-powered insights to detect misconfigurations and security gaps in multi-cloud infrastructures. Its ability to integrate with DevOps pipelines ensures that weaknesses are identified and mitigated early in the development lifecycle.
### **8\. Palo Alto Networks Prisma Cloud**
Palo Alto Networks Prisma Cloud brings vulnerability scanning to cloud-native applications, including containerized environments and serverless functions. With its automated compliance monitoring and integration with Kubernetes, Prisma Cloud helps organizations identify and address risks before they can compromise their environments.
### **9\. Fortinet FortiScan**
Fortinet FortiScan delivers comprehensive vulnerability scanning across hybrid and on-premises environments. With its real-time threat intelligence and automated patch management, it ensures that organizations can quickly identify and rectify network issues to maintain a strong posture.
### **10\. Fortra BeSecure**
Fortra BeSecure ties its scanning capabilities to compliance-focused vulnerability management, offering tools to identify risks and generate detailed reports aligned with frameworks like PCI DSS and HIPAA. Its continuous monitoring helps organizations stay ahead of emerging threats and maintain regulatory compliance.
### **11\. Cisco Vulnerability Management**
Cisco Vulnerability Management integrates real-time vulnerability scanning with automated patching across network devices. Designed for organizations already using Cisco’s ecosystem, it provides detailed insights into network vulnerabilities and ensures seamless remediation to enhance network security.
### **12\. Intruder**
Intruder simplifies vulnerability scanning by automating the identification of risks across networks, endpoints, and web applications. Its user-friendly interface and integration with collaboration tools make it ideal for small to medium-sized businesses seeking an accessible solution for consistent vulnerability management.
### **13\. VMware Carbon Black**
VMware Carbon Black supports endpoint vulnerability scanning with real-time detection and AI-driven prioritization of risks. Focusing on endpoint security it helps organizations quickly flag anomalies to prevent potential breaches.
### **14\. Splunk Enterprise Security**
Splunk Enterprise Security enhances vulnerability scanning by aggregating data from third-party scanners and applying advanced analytics to uncover hidden risks. Its machine learning capabilities provide actionable insights, helping organizations identify patterns and vulnerabilities across complex IT environments.
## **Streamline Your Vulnerability Assessments with FireMon**
Investing in the best vulnerability scanning tools is no longer optional; it’s a necessity for businesses looking to stay ahead of cyber threats. Tools like FireMon provide advanced capabilities for identifying and addressing vulnerabilities, ensuring your organization maintains a strong security posture.
Book a demo today and take the first step in securing your infrastructure by exploring FireMon’s comprehensive vulnerability scanning software **.**
## **Frequently Asked Questions**
### **What Are Vulnerability Scanning Tools?**
A vulnerability scanning tool is a software solutions that identify weaknesses in IT infrastructure, such as misconfigurations, outdated software, or exposed endpoints. They provide actionable insights that allow businesses to secure networks and applications proactively.
### **What Are the Benefits of Vulnerability Scanning?**
These tools reduce risks by identifying vulnerabilities before attackers can exploit them. They also help organizations maintain compliance with regulatory frameworks, prevent operational downtime, and provide visibility into IT assets for better decision-making.
### **How Often Should You Conduct a Vulnerability Scan?**
The frequency of conducting a scan for vulnerabilities depends on your organization’s risk profile. High-risk environments, such as those managing sensitive data, should be scanned weekly, while standard systems may require monthly or quarterly assessments. Regular scans ensure consistent security hygiene.
### **What Are the Different Types of Assessment Tools?**
Assessment tools come in various forms, each tailored to cover specific aspects of an organization’s IT environment. These tools are designed to identify and mitigate cyber threats across networks, endpoints, cloud infrastructures, and data storage, ensuring comprehensive security coverage. Here are the four main types of assessment tools:
- **Data-Based Scanners**: These tools analyze stored information to uncover vulnerabilities related to unencrypted data, improper access controls, or mismanagement of sensitive information. They play an essential role in protecting data integrity and confidentiality.
- **Network-Based Scanners**: These tools focus on identifying vulnerabilities in network devices, configurations, and protocols. They scan for issues such as open ports, unsecured services, and misconfigurations that could expose the network to attacks.
- **Host-Based Scanners**: These scanners assess individual operating systems and endpoints, detecting vulnerabilities in installed software, missing patches, and potential misconfigurations. They are essential for securing servers, workstations, and devices connected to the network.
- **Cloud-Based Scanners**: Designed specifically for cloud environments, these tools identify security gaps such as misconfigured permissions, unprotected cloud storage, and outdated applications within cloud deployments. They ensure compliance with cloud security standards.
### **What Key Features Are Important when Evaluating Vulnerability Scan Tools?**
Key features to evaluate in vulnerability scanning tools include comprehensive asset coverage, real-time detection, risk prioritization, integration with existing systems, and detailed remediation reports. Look for automation, scalability, regulatory compliance support, a user-friendly interface, and strong vendor support with regular updates to ensure effective and adaptable vulnerability management.
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Top OSS Vulnerability Scanning Tools [By Category] - Wiz
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https://www.wiz.io/academy/oss-vulnerability-scanners
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vulnerability assessment tools
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## Key considerations for vulnerability scanners
When choosing a vulnerability scanner, it’s important to consider several critical factors. These factors not only determine how effective vulnerability detection is but also impact how easily vulnerability scanning can be integrated into DevOps workflows and CI pipelines like GitLab CI, Jenkins, and Azure DevOps.
For example, keep the following in mind:
- To develop secure-by-design apps, DevSecOps teams need vulnerability scanners that automatically trigger a scan as part of the build process whenever code is committed. This enables near-instantaneous vulnerability detection, an important part of shift-left testing.
- Stakeholders should consider how exhaustively the tool scans and correlates critical vulnerabilities across workloads. An ideal tool offers various types of vulnerability scans, including cloud infrastructure, network, application, and host scans. Such a tool will provide a holistic view of configurations and seemingly innocuous combinations that actually put your stack at risk of cyberattacks.
- The scanner should deploy agentlessly, reducing the complexity and overhead associated with using it. It should also integrate with vulnerability management solutions to facilitate ongoing management throughout the vulnerability lifecycle.
- The scanner must accurately detect and prioritize vulnerabilities according to criteria like vulnerability severity, asset exposure, and criticality to business operations.
[**AWS Vulnerability Management Best Practices \[Cheat Sheet\]** \\
This 8-page cheat sheet breaks down the critical steps to fortifying your AWS security posture. From asset discovery and agentless scanning to risk-based prioritization and patch management, it covers the essential strategies needed to safeguard your AWS workloads.](https://www.wiz.io/lp/aws-vulnerability-management-best-practices-cheat-sheet) Download Cheat Sheet
[](https://www.wiz.io/lp/aws-vulnerability-management-best-practices-cheat-sheet)
## Top open-source vulnerability scanning tools
Though it's best to have a vulnerability scanner capable of scanning multiple components of your stack, most scanners out there tend to focus on a single layer. Here are our top-rated picks listed by type—based on the layer they secure:
Tool Type: Tool Name: Capability: Strength Limitation
Network vulnerability scanners Aircrack-ng Monitoring wireless networks Seamless packet injection May take hours or days to effectively detect and exploit vulnerabilities |
Network vulnerability scanners Masscan Network troubleshooting and security auditing Fast scans Must be integrated with vulnerability management tools for comprehensive vulnerability insights |
Application vulnerability scanners Arachni Web app security testing Customizable and distributed scans Cannot effectively detect vulnerabilities related to business logic (e.g., authorization bypass) |
Application vulnerability scanners Burp Suite Web application scanning and testing Enables active and passive scans Lacks automated scans, making real-time vulnerability detection impossible |
Container vulnerability scanners Clair Static container vulnerability scanning Can be customized to suit various use cases without forking Lacks runtime scanning capabilities; can only analyze images at rest |
Container vulnerability scanners Anchore Engine Container vulnerability scanning and compliance management Can be integrated into CI pipelines for automated scans Focuses on popular OS and software packages; may overlook vulnerabilities in custom-built apps |
Code vulnerability scanners KICS IaC code scanning and compliance assessment Vulnerability risk scores Offers static scans only; may generate false negatives |
Code vulnerability scanners Gitleaks Git code scanning Git history and version scanning Its regex scans may result in false positives |
Endpoint vulnerability scanners Lynis Endpoint security auditing and hardening Highly extensible Ideal for Unix-based operating systems only |
Endpoint vulnerability scanners OSSEC Endpoint vulnerability scanning and compliance checks Host-based intrusion detection Requires extensive manual tuning to reduce false positives |
### Network vulnerability scanners
Network vulnerability scanners assess LANs, servers, and systems for security risks, such as outdated software, misconfigurations, suspicious traffic patterns, and open ports.
**Aircrack-ng**
Aircrack-ng is a suite of tools designed mainly for monitoring, attacking, and cracking 802.11 wireless networks. It sniffs packets and captures hashes, collecting insights needed to crack WEP and WPA/WPA2 pre-shared key (PSK) passwords. This in turn lets you know how easily attackers can decrypt your network traffic and packets.
Aircrack supports various attack techniques like deauthentication, packet injection, brute force, replay, and dictionary-based password cracking attacks. It comes pre-installed in Kali Linux and can be accessed by typing the following command in the terminal:
```break-all !rounded-none
aircrack-ng --help
You'll then receive an output displaying various Aircrack-ng commands you can deploy for your vulnerability scans.
**How Aircrack-ng works**
You can use any of the tools within Aircrack-ng to conduct a wide range of scans. For instance, you can scan the network using `airodump-ng` to find suspicious activity or rogue access points.
**Masscan**
Known for its remarkable speed and scalability, Masscan is a lightweight network security vulnerability scanner and reconnaissance tool. It’s ideal for scanning IP addresses, open ports, and other network components.
**How Masscan works**
You can use Masscan to detect rogue services, firewall outage/tampering, or misconfigured devices that could result in sensitive data exposure.
For example, you can find misconfigurations by scanning your entire network (Hello, fast scans!), focusing on commonly exploited ports like 80, 22, and 443. Masscan then outputs a report showing all misconfigurations detected—e.g., open port 21 (showing that the unencrypted FTP is being used) or weak authentication and authorization in port 22 (creating potential for brute force attacks and remote code execution).
### Application vulnerability scanners
Application scanners are automated tools that find insecure configurations, outdated libraries, and code vulnerabilities in software applications.
**Arachni**
Arachni is a modular web app vulnerability scanner and security testing tool designed to uncover code and input validation vulnerabilities like SQL injection, cross-site request forgery (CSRF), and file inclusion weaknesses.
**How Arachni works**
You can use Arachni to scan apps or websites with PINs or credit card numbers collected during transactions. First, you’ll need to set up Arachni on your servers and provide authentication credentials to enable it to crawl your website to identify user input fields for collecting sensitive customer data (e.g., login services, payment dashboards, and checkout processes).
**Burp Suite CE**
Burp Suite comprises a set of tools for identifying and exploiting web app vulnerabilities. It has an advanced crawler for identifying input fields, forms, and links. Its Interception proxy enables the detection of proxy-based attacks like CSRF and its Intruder tool allows for pen testing via parameter manipulation and brute force attacks.
**How Burp Suite works**
Burp Suite works like a man-in-the-middle, intercepting packets moving from client to server and analyzing them for security vulnerabilities. To get started, install Burp Suite CE and add 127.0.0.1:8080 to your browser. Then, navigate the target website as a typical user or threat actor would, enabling Burp Suite to capture HTTP requests and responses to detect malicious packets or inputs. You can also test for password vulnerabilities by using Intruder to perform brute-force scans against login pages.
### Container vulnerability scanners
Container vulnerability scanners check for security gaps and misconfigurations that attackers can exploit in containers.
**Clair**
Clair is a scanner that conducts static vulnerability analysis of containers and container images. It’s often deployed to work with built-in container vulnerability scanners available in common container registries like AWS, ECR, and Quay.
**How Clair works**
Clair works by continuously importing CVE data from pre-configured databases like the National Vulnerability Database (NVD). To use Clair, create a docker-compose file containing a Clair container (for the API) and a PostgreSQL container (for CVE data storage).
**2\. Anchore Engine**
Anchore Engine is a command-line vulnerability scanner for detecting security weaknesses and compliance issues in containers within CI pipelines.
**How Anchore Engine works**
Anchore Engine works by first fetching a container image from a pre-configured registry, then generating a software bill of materials (SBOM), indexing all components of the image. Afterwards, it compares the indexed components—e.g., software packages—to a vulnerability database, correlating the software risks with known vulnerabilities.
### Code vulnerability scanners
Code vulnerability scanners are designed to identify potential vulnerabilities in source code and binary files throughout the software development lifecycle.
**1.KICS**
Keeping Infrastructure as Code Secure (KICS) is an infrastructure as code (IaC) security scanner for detecting vulnerabilities in IaC tools—like Terraform, Docker, Ansible—before code is shipped.
**How KICS works**
KICS comes with robust built-in and customizable policy templates that enable it to scan IaC files for misconfigurations, vulnerabilities, and compliance violations. It covers a wide range of compliance standards, such as GDPR, PCI DSS, and HIPAA, and enforces security best practices. KICS parses IaC files, extracts relevant metadata, and matches the data against the CIS’s library of built-in custom rules.
**2\. Gitleaks**
Gitleaks is a code scanner for identifying hard-coded secrets, such as passwords, private keys, API keys, and tokens in code repos before they are exploited by attackers.
**How Gitleaks works**
Gitleaks can scan code before or after it is committed to Git. If you’ve written some code and need to be sure it contains no secrets or vulnerabilities before pushing it to Git, you’d run the following command:
```break-all !rounded-none
gitleaks protect .
This will trigger Gitleaks to run a regex scan on the code file, comparing patterns within your code to a set of predefined patterns for detecting common secrets. You can also configure Gitleaks to automatically scan your code or repos for secrets every time code changes are made. Once it finds a matching pattern, Gitleaks alerts you, pinpointing the problematic part of the code.
### Endpoint vulnerability scanners
Endpoint vulnerability scanners detect software, OS, and configuration weaknesses on endpoint devices such as desktops, mobile devices, and servers.
**1.Lynis**
Lynis is a lightweight endpoint security auditing tool for Unix-based systems. It can be used to run continuous or scheduled scans to facilitate ongoing security posture management.
**How Lynis works**
Lynis assesses endpoints for system/network configuration, file permission, and authentication settings issues. To get Lynis to assess your endpoints for security risks, install it through the source code or package manager. Then run the audit command to scan your device remotely, locally, or to a Docker container.
**2\. OSSEC**
OSSEC is a host-based intrusion detection system (HIDS) for monitoring and auditing endpoints. OSSEC detects endpoint security risks like suspicious activities, rootkits, malware, unauthorized access, and policy violations.
**How OSSEC works**
OSSEC works via agentless and agent-based deployments. It collects data from operating systems, servers, firewalls, routers, and intrusion prevention systems (IPS). It then uses predefined rules and detection signatures to detect known vulnerabilities, attack patterns, and policy violations in endpoint devices.
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What is Security Orchestration, Automation, and Response (SOAR)?
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https://www.balbix.com/insights/what-is-security-orchestration-automation-and-response-soar/
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security automation SOAR
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# What is Security Orchestration, Automation, and Response (SOAR)?
Security teams are drowning in alerts. From endpoint anomalies and phishing attempts to threat intel feeds and SIEM events, the volume of data to ingest, correlate, and act on is overwhelming—and often impossible to manage manually. That’s where SOAR comes in.
**Security Orchestration, Automation, and Response (SOAR)** platforms help streamline detection-to-response workflows by connecting tools, automating tasks, and codifying incident response. While SIEMs focus on data collection and analysis, SOARs are designed for action.
Here’s a technical look at what SOAR is, how it works, and how it fits into modern security operations.
## What is SOAR?
SOAR, a term popularized by Gartner, refers to a category of platforms designed to streamline and automate security operations. SOAR stands for Security Orchestration, Automation, and Response. While the acronym remains widely used, some vendors now refer to this space as ‘security automation’ or ‘security operations platforms’ to reflect evolving capabilities.
SOAR performs three core functions:
- **Orchestration** – Connecting your existing tools ( SIEMs, EDR, ticketing systems, threat intel sources) and enabling inter-tool communication.
- **Automation** – Executing predefined tasks (e.g., enrichment, triage, containment) without human input.
- **Response** – Enabling consistent, documented, and often automated actions based on incident context and severity.
SOAR platforms provide structured workflows and decision logic to drive repeatable, auditable processes at speed and scale.
## What Is the Difference Between Security Automation and Orchestration?
Automation and orchestration are often used interchangeably in security operations, but they refer to distinct layers of functionality.
**Automation** is the execution of individual tasks without human intervention. For example, enriching an IP address with whois data or isolating a compromised endpoint via an EDR API are automated actions. These are usually discrete, rule-based, and repeatable, focused on speed and consistency at the task level.
**_Read more about security automation._**
**Orchestration** connects and coordinates security tools so they can share data and trigger actions across systems. Workflow logic—such as decision branches and task dependencies—is typically handled in the playbook or automation layer.
For instance, a phishing response playbook that ingests a reported email, enriches indicators, checks historical logs, quarantines messages, and creates a case is an orchestrated workflow that leverages multiple automations.
In essence, automation handles the “what,” while orchestration governs the “when,” “how,” and “in what order.” SOAR platforms combine both to streamline and scale security operations.
## How SOAR Works
A SOAR platform acts as a centralized coordination layer across the security operations stack, enabling structured, repeatable, and semi- or fully-automated responses to diverse security events.
Its architecture typically integrates four core capabilities: orchestration, automation, intelligence, and response. These components work together to reduce manual effort, increase consistency, and accelerate time to resolution.
### Orchestration: Connectors and Integration Frameworks
At the foundation of SOAR is its orchestration capability—unifying a fragmented toolset through a robust integration layer. This is accomplished via connectors and APIs and prebuilt or custom integrations that link the SOAR platform with other security and IT systems.
These may include SIEMs (e.g., Splunk, Microsoft Sentinel), EDR platforms (e.g., CrowdStrike, SentinelOne), firewalls, sandbox environments, threat intelligence platforms (e.g., VirusTotal, Recorded Future), and ITSM tools (e.g., ServiceNow, Jira).
These integrations allow SOAR to:
- Ingest alerts and telemetry from disparate systems
- Trigger response actions (e.g., block IP, isolate endpoint)
- Enrich data by querying external or internal intel sources
- Open or update tickets in workflow management tools
The breadth and reliability of these integrations directly impact the efficiency and scalability of SOAR workflows.
### Automation: Playbooks and Execution Engine
The automation engine is responsible for carrying out predefined actions at machine speed. These actions are organized into playbooks—structured, logic-driven workflows triggered by specific alert types or event conditions.
Playbooks can:
- Parse and normalize alert data
- Enrich artifacts (e.g., domains, hashes) using threat intel or DNS/whois lookups
- Query past events or correlated logs from the SIEM
- Trigger containment or remediation steps, such as disabling user accounts or isolating devices
- Create or update tickets in ITSM systems
These workflows are typically defined in a visual or YAML-based interface and support complex logic (conditional branching, loops, error handling). Some playbooks are fully automated, while others include human-in-the-loop controls—checkpoints that require analyst review or approval before proceeding with potentially disruptive actions (e.g., quarantining a host or sending user notifications).
### Intelligence: Contextual Enrichment and Correlation
Many SOAR platforms now include built-in threat intelligence modules or integrate directly with real-time threat scoring engines, enabling more accurate enrichment and prioritization.
Key enrichment and correlation activities include:
- IP/domain reputation checks
- Geolocation and whois lookups
- Asset criticality and vulnerability data mapping
- Historical alert correlation to detect broader attack patterns
By automatically aggregating this information, SOAR gives analysts a richer, more actionable view of each incident without requiring time-consuming manual lookups.
### Response: Case Management and Incident Lifecycle
SOAR wraps the detection and response process in a case management system, which organizes alerts, artifacts, actions taken, and analyst notes into a single interface. This helps ensure consistent incident handling, facilitates collaboration between Tier 1–3 analysts, and preserves full audit trails for post-incident review, compliance, or metrics reporting.
Cases can be:
- Automatically generated from alert ingestion
- Escalated or closed based on playbook logic
- Reopened if new evidence emerges
All response actions, both manual and automated, are tracked, timestamped, and correlated within the case to provide full traceability.
### Example: Phishing Alert Playbook
An everyday use case is the automated triage of phishing alerts. When a suspicious email is reported, the SOAR playbook begins by parsing the email header and extracting embedded indicators such as domains, URLs, and attachment hashes. These indicators are then checked against internal and external threat intelligence feeds.
The case is auto-closed if the IOCs are benign or previously marked as false positives. If malicious indicators are confirmed, the playbook queries historical SIEM data to identify other recipients or related activity.
It then automatically quarantines the email across all user inboxes, notifies the security team, and escalates the incident for further investigation. All actions and findings are logged in the case record for traceability throughout the process.
## SOAR vs. SIEM: Complementary, Not Redundant
While SIEM and SOAR platforms often overlap in the security operations stack, they serve distinct functions:
**Feature** **SIEM** **SOAR** |
Core Function Log aggregation & correlation Incident response & automation |
Input Logs, events, telemetry Alerts, indicators, case metadata |
Output Alerts, dashboards Tickets, response actions, reports |
Response Manual or limited Automated & orchestrated |
Analyst Role Investigate alerts Investigate + respond |
Modern SOCs typically deploy both, feeding SIEM alerts into SOAR playbooks for triage, enrichment, and containment.
## Key Use Cases for SOAR
SOAR becomes more powerful the more workflows you automate. While some organizations begin with simple enrichment tasks, high-performing teams build full-stack orchestration pipelines that address various security scenarios. Here are four of the most impactful use cases.
### 1\. Phishing Response
Phishing Response is one of the most common and practical starting points for SOAR automation. When users report suspicious emails—often through integrated mailbox plugins—SOAR can automatically ingest those reports, extract relevant data like headers and attachments, and parse indicators such as URLs, IPs, and domains. It then queries threat intelligence feeds to determine reputation or known maliciousness.
Based on this analysis, the platform can automatically quarantine the email from user inboxes, delete duplicates enterprise-wide, and create a case for analyst review if needed.
### 2\. Ransomware Containment
Ransomware Containment requires speed and coordination across multiple systems. SOAR can monitor for anomalous encryption behaviors flagged by EDR or SIEM tools, such as mass file renames or spikes in CPU usage from unauthorized processes.
When such behaviors are detected, SOAR playbooks can isolate affected endpoints from the network in real time, notify incident response teams, and even trigger automated workflows to restore from known-good backups. This containment workflow drastically reduces the blast radius of ransomware infections and shortens response windows.
### 3\. Insider Threat Detection
Insider Threat Detection benefits from SOAR’s ability to correlate data across disparate systems. By ingesting events from DLP, IAM, and UEBA platforms, SOAR can identify behavioral anomalies that suggest potential insider activity, such as large-volume downloads outside business hours or access to sensitive systems outside an employee’s typical role.
These events can trigger investigative playbooks that aggregate contextual data, generate alerts, and automatically disable user accounts or revoke access privileges in high-severity scenarios.
### 4\. Vulnerability Management
Vulnerability Management workflows can be fully orchestrated with SOAR. SOAR platforms can prioritize vulnerabilities using contextual risk data, such as known exploits, asset criticality, or business impact. The platform can then generate remediation tickets, route them to the appropriate owners with relevant configuration information, and track patch status.
Once remediation is confirmed, the SOAR playbook can verify closure through rescans and automatically close the loop in the case management system.
## Benefits of SOAR
Implementing SOAR can result in:
- **Lower MTTR** – From hours to minutes with automated response.
- **Fewer False Positives** – Enrichment and correlation improve fidelity.
- **Scalable Operations** – One analyst can manage hundreds of alerts per day.
- **Auditable Workflows** – Every action is logged and replayable.
- **Centralized Control**– This reduces the need to manually switch between consoles for common tasks, though deep investigations may still require native tool interfaces.
Critically, SOAR doesn’t just automate—it **codifies tribal knowledge** into repeatable processes. This institutional memory is essential as teams grow or turnover.
### Operational Considerations
While powerful, SOAR implementation isn’t trivial. Teams need to account for:
- **Playbook Design** – Building effective workflows that reflect actual response practices.
- **Data Quality** – Garbage in, garbage out. Enrichment depends on clean, structured inputs.
- **Integration Overhead** – Custom connectors may be required for niche or legacy tools.
- **Change Management** – Analysts must trust automation, especially when performing destructive actions.
Security engineers should also test and version-control playbooks like any production codebase, using staging environments where possible.
## When Does SOAR Make Sense?
SOAR shines in environments where:
- Alert volume outpaces manual triage capacity
- Security tooling is mature but fragmented
- Incident response is inconsistent or poorly documented
- Teams want to scale without linear headcount growth
Even smaller orgs can benefit by automating high-frequency, low-complexity tasks first (e.g., phishing triage) and layering complexity over time.
## The Future of SOAR: AI and Autonomous Response
Next-gen SOAR platforms increasingly incorporate ML and LLMs to assist decision-making, recommend actions, and summarize incidents. While some platforms enable limited autonomous response, such as endpoint isolation under predefined policies, full automation of destructive actions remains rare and highly controlled.
- **Autonomous response loops**
- **Natural language playbook creation**
- **Proactive risk reduction workflows** (e.g., patch prioritization)
Still, human oversight remains critical. The goal isn’t full automation—it’s augmented decision-making.
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The Top 12 SOAR Platforms to Supercharge Your Security Operations
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https://www.centraleyes.com/top-soar-platforms/
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security automation SOAR
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## What is a SOAR Platform?
A SOAR platform (Security Orchestration, Automation, and Response) is like the command center for your security operations. Think of it as your security team’s “easy button” for handling the repetitive and time-consuming tasks involved in monitoring, responding, and mitigating threats. Unlike other tools that focus on collecting and analyzing data (like SIEMs), SOAR platform cybersecurity is designed to take action—automatically and at scale.
SOAR platforms integrate and orchestrate multiple tools—like Endpoint Detection and Response (EDR), Threat Intelligence, Vulnerability Management, and more—bringing everything under one roof. They streamline workflows by automating complex processes, creating playbooks for common incident responses, and using threat intelligence to prioritize real threats over false alarms.
## What Does S-O-A-R Mean?
SOAR, which stands for Security Orchestration, Automation, and Response, brings together the essential elements to supercharge your security team’s capabilities. Here’s a look at how each letter of the acronym contributes to a smoother, faster, and smarter approach to security.
- S: Security
SOAR platforms are built to keep security front and center, providing a solid foundation to manage threats. With SOAR, all your tools and insights come together in one place, streamlining defenses and making it easier to detect, analyze, and act on threats—all from a single command center.
- O: Orchestration
Orchestration syncs your tools seamlessly, turning your defenses into a powerful, coordinated response system. SOAR allows threat intelligence, endpoint protection, firewalls, and reports to communicate and share data smoothly, creating a fast-moving, unified security operation that leaves no gaps.
- A: Automation
With SOAR’s automation capabilities, routine tasks become swift, automatic processes. SOAR handles everything from threat validation to initiating responses, empowering your team to focus on critical analysis and strategy while handling the operational details on its own.
- R: Response
SOAR is action-driven at its core, meaning it doesn’t just observe; it actively responds. It swiftly executes tasks like isolating suspicious endpoints or blocking risky IPs, maintaining a consistent and quick approach to neutralizing threats. With SOAR, your team always has a trusted first responder.
## SOAR vs. SIEM
Both SIEM (Security Information and Event Management) and SOAR (Security Orchestration, Automation, and Response) are essential tools for security teams but have unique roles in protecting your environment:
- **SIEM as the Eyes**: SIEM gathers, analyzes, and alerts on security data, giving teams visibility into potential threats. Think of SIEM as your “radar,” scanning for unusual activities and flagging them for review.
- **SOAR as the Brain and Hands**: SOAR steps in to handle those alerts. By automating responses, orchestrating workflows across tools, and even running incident playbooks, SOAR reduces manual work for your team. SOAR doesn’t just detect but _acts_, managing threats more quickly and consistently. This can mean blocking a malicious IP, containing a suspicious endpoint, or sending immediate alerts to stakeholders—all without waiting for human intervention.
## 12 Top SOAR Platforms
### **1\. Splunk SOAR**
Splunk SOAR (formerly known as Phantom) is widely known for its integration depth and flexibility. It’s built to handle complex workflows and connect easily with numerous data sources. Splunk SOAR is ideal for organizations with mixed tech stacks, providing a comprehensive solution for automating responses, running playbooks, and centralizing security operations. Plus, if your team is already using Splunk for SIEM, this is a natural extension.
**Best For:** Organizations needing highly customizable automation capabilities with multiple data sources.
### **2\. Cortex XSOAR by Palo Alto Networks**
A leader in endpoint and network security, Palo Alto Networks offers Cortex XSOAR, a SOAR platform with a rich library of integrations and out-of-the-box playbooks. With Cortex XSOAR, you can automate response and incident triage with built-in intelligence, making it a great choice for organizations with a variety of security tools and processes.
**Best For:** Enterprises looking for extensive, built-in playbooks and intelligence-powered automation.
### **3\. IBM Security QRadar SOAR**
IBM QRadar SOAR (formerly Resilient) offers end-to-end case management and a powerful orchestration engine. Known for its detailed incident response functionalities, it’s designed for use by teams looking to fine-tune every aspect of their workflows. IBM QRadar integrates smoothly with IBM’s other cybersecurity solutions, making it ideal for larger organizations with significant incident management needs.
**Best For:** Large enterprises focused on granular incident response and tight integration within the IBM ecosystem.
### **4\. Siemplify (Now Part of Google Cloud)**
Siemplify has gained attention for its intuitive interface and is especially appealing for managed security service providers (MSSPs). Now part of Google Cloud, Siemplify helps teams cut down on alert fatigue with tools for playbook automation and threat intelligence management. It’s especially valuable for organizations wanting to scale operations without adding headcount.
**Best For:** MSSPs and SOCs looking for a scalable solution for automated workflows and threat intelligence.
### **5\. ServiceNow Security Operations**
ServiceNow’s Security Operations integrates seamlessly with its IT service management platform, which is a huge benefit for organizations already using ServiceNow. The platform offers automation and orchestration capabilities specifically designed for improving security operations, incident response, and vulnerability management workflows.
**Best For:** Organizations deeply invested in the ServiceNow ecosystem looking to unify IT and security operations.
### **6\. Swimlane**
Swimlane stands out for its low-code automation, allowing analysts with limited programming knowledge to create and manage complex playbooks. With its flexibility and ease of customization, Swimlane is suitable for teams that want high levels of control over automation but need to avoid extensive coding.
**Best For:** Teams with limited coding resources seeking a highly customizable, low-code SOAR solution.
### **7\. DFLabs (IncMan SOAR)**
DFLabs IncMan SOAR is well-regarded for its advanced automation and incident response features, including the ability to build custom workflows without heavy coding. It emphasizes flexibility in response automation and is particularly useful in high-security environments that need a fully adaptable SOAR solution.
**Best For:** High-security industries needing granular control over incident response workflows.
### **8\. Rapid7 InsightConnect**
InsightConnect by Rapid7 is highly accessible, designed to simplify workflow automation for security teams of all sizes. It integrates well with other Rapid7 solutions, making it an efficient choice for companies already using Rapid7’s vulnerability and incident management tools. InsightConnect is also known for providing excellent pre-built playbooks and an intuitive interface.
**Best For:** Small to mid-sized teams or those already using Rapid7, looking for ease of setup and deployment.
### **9\. SIRP (Security Incident Response Platform)**
SIRP is an analytics-driven SOAR that emphasizes risk-based management of security incidents. It combines automation with insights into risk levels, allowing teams to prioritize incident response based on impact. This approach is valuable for organizations aiming to align incident response with overall risk management strategies.
**Best For:** Organizations focused on risk-based incident response with analytics-driven prioritization.
### **10\. ThreatConnect**
ThreatConnect’s unique offering is its combination of threat intelligence with orchestration and automation. Built with intelligence analysis in mind, it’s highly effective for organizations with mature threat intelligence functions, allowing for well-informed, context-rich automation.
**Best For:** Teams with a mature threat intelligence program needing integration between intelligence and automated response.
### **11\. LogRhythm SOAR**
LogRhythm SOAR is a powerful platform built to integrate seamlessly with LogRhythm’s NextGen SIEM solution. It’s particularly valuable for automating and streamlining security operations and compliance efforts, with easy-to-implement workflows that reduce manual tasks.
**Best For:** Organizations using LogRhythm’s SIEM, looking to simplify compliance and incident response.
### **12\. FortiSOAR by Fortinet**
FortiSOAR is Fortinet’s answer to complex security operations challenges. Known for its scalability and ease of integration with other Fortinet products, FortiSOAR provides centralized automation and case management. Its modular approach makes it a good choice for organizations looking to build tailored solutions that grow with their needs.
**Best For:** Teams heavily invested in Fortinet products needing a scalable and customizable SOAR solution.
## Exploring Free and Open Source SOAR Platforms
For organizations seeking powerful automation capabilities without a large investment, free SOAR platforms are excellent options. These solutions offer flexible and customizable security orchestration tools that fit various budgets and resource levels. Open-source SOAR platforms, in particular, give organizations the freedom to tailor workflows and integrations to their unique security operations.
Some popular open-source SOAR platforms include TheHive and Shuffle, designed for teams experimenting with and implementing robust automation without heavy licensing costs. While free SOAR platforms might require more in-house setup and maintenance, they allow for high degrees of customization, making them well-suited to security teams with development expertise.
Choosing between a commercial and open-source SOAR platform depends on your organization’s needs, budget, and technical capabilities. A free SOAR platform could be an ideal starting point, giving your team powerful tools to automate repetitive tasks and streamline incident response without initial financial commitment.
## When Do You Know You Need a SOAR Platform Vendor?
Here are a few indicators that it might be time for your team to bring in a SOAR solution:
- **Alert Fatigue**: If your team is bogged down by too many low-priority alerts, SOAR can filter and automate responses to free up analyst time.
- **Repetitive Tasks**: Automating simple but time-consuming tasks can significantly increase your team’s efficiency.
- **Scalability Challenges**: If your organization is expanding rapidly and hiring more analysts isn’t feasible, SOAR can help you handle the increased workload without adding headcount.
- **Multi-Tool Ecosystem**: For organizations managing a range of security tools, SOAR provides a unified platform, reducing the manual overhead of switching between solutions.
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What is EDR? Endpoint Detection & Response Defined - CrowdStrike
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https://www.crowdstrike.com/en-us/cybersecurity-101/endpoint-security/endpoint-detection-and-response-edr/
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endpoint detection response EDR
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## What is EDR?
**Endpoint Detection and Response (EDR)**, also referred to as endpoint detection and threat response (EDTR), is an endpoint security solution that continuously monitors end-user devices to detect and respond to cyber threats like ransomware and malware.
Coined by Gartner's Anton Chuvakin, EDR is defined as a solution that "records and stores endpoint-system-level behaviors, uses various data analytics techniques to detect suspicious system behavior, provides contextual information, blocks malicious activity, and provides remediation suggestions to restore affected systems."
## How does EDR work?
**EDR** security solutions record the activities and events taking place on endpoints and all workloads, providing security teams with the visibility they need to uncover incidents that would otherwise remain invisible. An EDR solution needs to provide continuous and comprehensive visibility into what is happening on endpoints in real time.
An EDR tool should offer advanced threat detection, investigation and response capabilities — including incident data search and investigation alert triage, suspicious activity validation, threat hunting, and malicious activity detection and containment.
## Key EDR functions
### Automatically uncovers stealthy attackers
EDR technology pairs comprehensive visibility across all endpoints with IOAs and applies behavioral analytics that analyze billions of events in real time to automatically detect traces of suspicious behavior.
Understanding individual events as part of a broader sequence allows CrowdStrike's EDR tool to apply security logic derived from CrowdStrike Intelligence. If a sequence of events matches a known IOA, the EDR tool will identify the activity as malicious and automatically send a detection alert. Users can also write their own custom searches, going back up to 90 days, with Falcon Insight’s cloud architecture returning query results in five seconds or less.
### Integrates with threat intelligence
Integration with CrowdStrike Adversary Intelligence provides faster detection of the activities and tactics, techniques and procedures (TTPs) identified as malicious. This delivers contextualized information that includes attribution where relevant, providing details on the adversary and any other information known about the attack.
### Managed threat hunting for proactive defense
Using EDR, the threat hunters work proactively to hunt, investigate and advise on threat activity in your environment. When they find a threat, they work alongside your team to triage, investigate and remediate the incident, before it has the chance to become a full-blown breach.
### Provides real-time and historical visibility
EDR **acts like a DVR on the endpoint, recording relevant activity to catch incidents that evaded prevention**. Customers are given comprehensive visibility into everything that is happening on their endpoints from a security perspective as CrowdStrike tracks hundreds of different security-related events, such as process creation, drivers loading, registry modifications, disk access, memory access or network connections.
This gives security teams the useful information they need, including:
- local and external addresses to which the host is connected
- all the user accounts that have logged in, both directly and remotely
- a summary of changes to ASP keys, executables and administrative tool usage
- process executions
- both summary and detailed process-level network activity, including DNS requests, connections, and open ports
- archive file creation, including RAR and ZIPS
- removable media usage
This complete oversight of security-related endpoint activity allows security teams to “shoulder surf” an adversary’s activities in real time, observing which commands they are running and what techniques they are using, even as they try to breach or move around an environment.
### Accelerates investigations
CrowdStrike endpoint detection and response is able to accelerate the speed of investigation and ultimately, remediation, because the information gathered from your endpoints is stored in the CrowdStrike cloud via the Falcon platform, with architecture based on a situational model.
The model keeps track of all the relationships and contacts between each endpoint event using a massive, powerful graph database, which provides details and context rapidly and at scale, for both historical and real-time data. This enables security teams to quickly investigate incidents.
**This speed and level of visibility, combined with integrated, contextualized intelligence provides the information needed to thoroughly understand the data**. This enables security teams to effectively track even the most sophisticated attacks and promptly uncover incidents, as well as triage, validate and prioritize them, leading to faster and more precise remediation.
### Enables fast and decisive remediation
CrowdStrike EDR can isolate the endpoint, which is called “network containment.“ It allows organizations to take swift and instantaneous action by isolating potentially compromised hosts from all network activity.
When an endpoint is under containment, it can still send and receive information from the CrowdStrike cloud, but it will remain contained even if the connection to the cloud is severed and will persist with this state of containment during reboots.
CrowdStrike EDR includes Real Time Response, which provides the enhanced visibility that enables security teams to immediately understand the threats they are dealing with and remediate them directly, while creating zero impact on performance.
## What should you Look for in an EDR solution?
Understanding the key aspects of EDR security and why they are important will help you better discern what to look for in a solution. It’s important to **find EDR security solution that can provide the highest level of protection while requiring the least amount of effort and investment** — adding value to your security team without draining resources. Here are the six key aspects of EDR you should look for:
### 1\. Endpoint visibility:
Real-time visibility across all your endpoints allows you to view adversary activities, even as they attempt to breach your environment, and stop them immediately.
### 2\. Threat database:
Effective EDR requires massive amounts of telemetry collected from endpoints and enriched with context so it can be mined for signs of attack with a variety of analytic techniques.
### 3\. Behavioral protection:
Relying solely on signature-based methods or indicators of compromise (IOCs) lead to the “silent failure” that allows data breaches to occur. Effective endpoint detection and response requires behavioral approaches that search for indicators of attack (IOAs), so you are alerted of suspicious activities before a compromise can occur.
### 4\. Insight and intelligence:
An endpoint detection and response solution that integrates threat intelligence can provide context, including details on the attributed adversary that is attacking you or other information about the attack.
### 5\. Fast response:
EDR that enables a fast and accurate response to incidents can stop an attack before it becomes a breach and allow your organization to get back to business quickly.
### 6\. Cloud-based solution:
Having a cloud-based endpoint detection and response solution is the only way to ensure zero impact on endpoints, while making sure capabilities such as search, analysis and investigation can be done accurately and in real time.
## Why is EDR important?
All organizations should know by now that with enough motivation, time and resources, adversaries will eventually devise a way to get through your defenses, no matter how advanced. The following are some compelling reasons EDR should be a part of your endpoint security strategy.
### Reason \#1: Prevention alone can’t ensure 100 percent protection
When prevention fails, your organization can be left in the dark by its current endpoint security solution. Attackers take advantage of this situation to linger and navigate inside your network.
### Reason \#2: Adversaries can be inside your network for weeks and return at will
Because of silent failure, attackers are free to move around in your environment, often creating back doors that allow them to return at will. In most cases, the organization learns about the breach from a third party, such as law enforcement or its own customers or suppliers.
### Reason \#3: Organizations lack the visibility needed to effectively monitor endpoints
When a breach is finally discovered, the victim organization can spend months trying to remediate the incident because it lacks the visibility required to see and understand exactly what happened, how it happened and how to fix it — only to see the attacker return within a matter of days.
### Reason \#4: Access to actionable intelligence is needed to respond to an incident
Organizations may not only lack the visibility required to understand what is happening on its endpoints, it may not be able to record what is relevant to security, store it and then recall the information quickly enough when needed.
### Reason \#5: Having the data is only part of the solution
Even when data is available, security teams need the resources required to analyze and take full advantage of it. This is why many security teams find that soon after they’ve deployed an event collection product, such as a SIEM, they are often facing a complex data problem. Challenges around knowing what to look for, speed, and scalability begin cropping up and other problems surface before their primary objectives can even be addressed.
### Reason \#6: Remediation can be protracted and costly
Without the capabilities listed above, organizations can spend weeks trying to discern what actions to take — often the only recourse is to reimage machines, which can disrupt business processes, degrade productivity and ultimately cause serious financial loss.
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An Overview of Endpoint Detection and Response (EDR)
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https://www.digitalguardian.com/blog/overview-endpoint-detection-and-response-edr
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endpoint detection response EDR
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The proliferation of endpoints due to the increasing growth of a remote workforce, mobile devices, and the Internet of Things (IoT) has exposed organizations to a much broader attack surface.
As a result, technologies like endpoint detection and response (EDR) systems are designed to evaluate the threats the network perimeter poses to data security respond to them in real-time.
## What Is Endpoint Detection and Response (EDR)?
**EDR is a cybersecurity technology that monitors and collects data from endpoints to detect, analyze, investigate, and respond to cybersecurity threats. Endpoints in an organization can include computers, laptops, mobile devices, and servers.**
EDR is designed to help organizations detect suspicious activities, eliminate possible threats, and offer quicker response times to limit attack damage. This approach focuses on keeping threats out and dealing with those that make their way into the network.
## Why Is EDR Important?
EDR (Endpoint Detection and Response) is crucial for several reasons:
- **Advanced Threat Detection:** EDR can detect sophisticated and advanced threats that traditional antivirus systems might miss. It looks beyond just malware and can identify suspicious behavior or patterns that could indicate a security breach.
- **Real-time Response:** EDR solutions can provide real-time monitoring, threat detection, and response, significantly decreasing the detection and response time compared to traditional methods. This real-time response can minimize the damage caused by security incidents.
- **Increased Visibility:** EDR provides comprehensive visibility across your network. It continuously monitors and collects data from all endpoints, enabling the identification of threats at any point in the network. This increased visibility is essential in today’s complex IT environments.
- **Incident Investigation and Forensics:** In addition to detecting and responding to threats, EDR tools also provide in-depth data analysis, supporting incident investigation and forensics. This can help understand how a breach occurred and prevent future incidents.
- **Compliance:** Many industries have regulations requiring companies to take specific measures to protect data. Implementing an EDR solution can help meet these data compliance requirements.
- **Endpoint Management:** With the rise of remote work, employees are accessing company resources from different types of devices and various locations. EDR allows the security team to manage and secure these multiple endpoints effectively.
- **Proactive Security:** Instead of waiting for a breach to occur, EDR allows for proactive hunting of threats and suspicious activities. This approach bolsters the organization's security posture and resilience against cyber threats.
## How Does EDR work?
Endpoint Detection and Response (EDR) works by closely monitoring endpoint and network events and recording all the information in a central database. This information is then analyzed to identify patterns or behaviors indicating a cyber threat or attack.
Here's a closer look at how EDR operates:
- **Data Collection:** EDR works by installing agents on all endpoints. These agents continuously collect and record data about every activity on that endpoint. This includes information about running processes, network connections, registry changes, file access, and other system activities.
- **Threat Detection:** The collected data is then analyzed, typically using sophisticated artificial intelligence and machine learning algorithms. These algorithms look for patterns and behaviors that indicate a potential threat, such as malware operation, intrusion techniques, or unusual data access patterns.
- **Alert Generation:** The EDR solution generates an alert if suspicious activity is detected. This alert provides detailed information about the suspected threat, including what kind of threat it is, what systems are affected, and the potential impact.
- **Threat Response:** EDR solutions also include automated response capabilities. Depending on the severity of the threat, the solution can take several actions: It can isolate the affected endpoint from the network to prevent the spreading of malware, quarantine malicious files, or even roll back systems to their pre-infected state if needed.
- **Investigation and Forensics:** The collected data and metadata can also be used for a deeper investigation and forensics. It can help security teams understand how the attack happened, what vulnerability was exploited, and what steps need to be taken to prevent future attacks.
- **Remediation:** Finally, EDR tools support remediation by either executing appropriate countermeasures automatically or guiding the security teams to do them manually to plug the identified security gaps.
## What Are the Functions of EDR?
Endpoint Detection and Response (EDR) performs the following major functions:
- **Real-Time Visibility:** EDR monitors endpoints in real time to detect suspicious or anomalous activities. This includes capturing data such as running processes, registry changes, network connections, and user activities.
- **Threat Detection:** EDR uses machine learning and behavioral analysis to identify potential threats. It can detect known threats using databases or signature-based detection and unknown threats using advanced analytics and heuristics.
- **Response and Remediation:** Upon detecting a threat, EDR solutions trigger a response, which could include isolating the infected endpoint, terminating malicious processes, or even rolling back changes made by the malware.
- **Threat Hunting:** EDR allows security teams to proactively search for advanced threats that may not have been automatically detected. This involves an in-depth investigation of endpoints to uncover hidden threats.
- **Data Collection & Forensics:** EDR solutions collect and store comprehensive forensic data that can be used to investigate and analyze security incidents. This data can be used to understand the source of the attack, the methods used, and the extent of the damage.
- **Incident Reporting & Alerts:** When a threat is detected, the EDR solution alerts the security team. It also provides detailed reporting on all endpoint activities and detected threats.
- **Integration with Other Systems:** EDR solutions can integrate with other security technologies like Security Information and Event Management (SIEM), firewalls, and threat intelligence feeds, providing a more holistic approach to cybersecurity.
- **Compliance Assurance:** EDR can help enforce security policies and ensure compliance with regulations by monitoring endpoint activities and logging and reporting any non-compliance.
## The Best Practices for Implementing EDR
Implementing an Endpoint Detection and Response (EDR) solution needs to follow best practices to effectively protect the endpoints from different cybersecurity threats. Here are some of the best practices for implementing EDR:
- **Understand Your Environment:** Before implementing EDR, to identify the types of threats that your specific organization may face, it is necessary to comprehend your IT environment fully. Knowing the type of endpoints and their sensitivity can help design better solutions.
- **Choose the Right Solution:** Conduct thorough research and choose the EDR solution that fits your requirements. Make sure it adequately covers your environment, it is scalable, affordable, and suited to your organization’s specific needs.
- **Integration with Existing Systems:** The chosen EDR solution should integrate well with the existing cybersecurity infrastructure. It should complement other security measures already in place, like firewalls, encryption, and antivirus, among others.
- **Regular System Updates:** EDR systems must be kept updated to tackle the latest threat trends. Regular updates allow the system to identify newer forms of threats.
- **Conduct Regular Training:** Train all IT staff and end users on how to use EDR and the importance of endpoint security. The training should also educate them on the latest cybersecurity threats and measures to counteract them.
- **Automated & Manual Threat Hunting:** Leverage both automated rule-based hunting and manual hunting queries to be more intentional and proactive in threat hunting.
- **Define Response Procedures:** Clear processes and protocols for incident response should be laid out. This includes both automated responses that the EDR solution may carry out and manual responses by the security team.
- **Periodic Review:** Constantly review new threats, user behavior, and the effectiveness of the EDR solution. Changes made should be analyzed for improvements and adjusted as necessary.
- **Privacy Settings:** While setting up EDR, consider information and privacy regulations related to personal and sensitive data. This is especially important in regulated industries like healthcare, financial services, etc.
- **Incident Response Plan:** In case a security breach occurs, it’s essential to have an incident response plan in place. This plan should detail the steps to limit damage, reduce recovery time and costs, and mitigate the breach's exploitation.
## What Is the Future of EDR?
The future of Endpoint Detection and Response (EDR) is likely to be influenced by the ongoing advancements in technology and the ever-evolving landscape of cybersecurity threats. Here are a few predictions about the future of EDR:
- **Integration with Extended Detection and Response (XDR):** Many cybersecurity vendors have already started developing XDR solutions, which aim to provide a more holistic approach to threat detection and response by combining multiple detection capabilities, such as EDR, Network Detection and Response (NDR), and Cloud Security Posture Management (CSPM).
- **Use of Artificial Intelligence (AI) and Machine Learning (ML):** As AI and ML technologies become more sophisticated, they will likely play a more prominent role in EDR solutions. These technologies can analyze vast amounts of data for patterns far quicker and more accurately than humans, leading to faster and more effective threat detection and response.
- **Automation:** As the cybersecurity landscape becomes more complex, the need for automation in response processes is likely to increase. This will enable security teams to respond more quickly and efficiently to threats, reducing the potential impact on the organization.
- **Cloud-Based EDR:** As more businesses move their operations to the cloud, EDR solutions will likely follow suit. Cloud-based EDR can offer advantages including better scalability, easier updates and maintenance, and the ability to protect remote workers more effectively.
- **Proactive Threat Hunting:** Instead of just reacting to threats, future EDR solutions are predicted to focus more on proactive threat hunting. This involves actively looking for signs of threats and potentially harmful anomalies within the system.
- **Insider Threat Detection:** Future EDR solutions will likely improve their capabilities to detect insider threats, both malicious actions by disgruntled or negligent employees and cases where an external attacker has gained access to insider credentials.
- **Improved IoT Device Security:** With the rise of the Internet of Things (IoT), EDR solutions will likely adapt to better detect and respond to threats targeting IoT devices, which can often serve as entry points for cyberattacks.
- **Data Privacy Regulations Compliance:** As data privacy regulations become more stringent, EDR will have to adapt to provide security while simultaneously ensuring compliance with them.
- **Security Skills Shortage:** Given the shortage of cybersecurity skills in many organizations, EDR solutions in the future will likely offer more user-friendly interfaces and automated response capabilities, allowing even those with minimal cybersecurity expertise to use the tool effectively.
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What are Endpoint Detection and Response Tools? - Palo Alto ...
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https://www.paloaltonetworks.com/cyberpedia/what-are-endpoint-detection-and-response-tools
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endpoint detection response EDR
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EDR (Endpoint Detection and Response) tools are security solutions designed to monitor, detect, and respond to cyber threats on endpoints, such as laptops, desktops, servers, and mobile devices. These tools provide advanced capabilities to identify suspicious activities, investigate potential security incidents, and mitigate threats in real-time.
## Endpoint Detection and Response Overview
Security operations (SecOps) teams work diligently to protect their increasingly digital organizations. Various categories of security tools are designed to help businesses prevent as many adversaries as possible from entering systems and to detect and respond to those who manage to bypass their initial defenses. For SecOps teams, keeping up with advanced threats is not only more critical than ever but also more complex, as new technologies introduce new threat vectors.
EDR is designed to identify potential cybersecurity threats, such as malware, ransomware, and intrusion attempts. When a threat is detected and a security incident is believed to have occurred or is about to occur, EDR tools send out alerts, triggering an incident response.
An EDR solution typically integrates with other cybersecurity tools, such as System Information Event Management (SIEM) or Intrusion Detection Systems (IDS), to initiate the necessary actions to stop the event's spread and address any impact. Following containment of the event and neutralization of the threat, an investigation usually takes place to assess what happened, where the threat occurred, why it happened, what actions were taken to contain it, and how it can be identified and prevented in the future.
## Control Points of EDR Tools
The future of cybersecurity is centered around four main control points: endpoints, identities, applications, and data.
Endpoints are crucial because they are the source of most activity and the most common target in an attack. Detecting malicious activity at the endpoints, where data is unencrypted, is essential.
Digital transformation requires increased connectivity between applications and business processes. The goal is to integrate trust into this "machine" of connected services to enhance business agility and provide a seamless experience for customers and partners. As applications become more independent from specific servers and networks, traditional network-centric security measures are becoming less effective. Security measures need to be applied at the application level, with Layer 7 taking precedence over Layer 3.
Data is essential for digital transformation and is also a prime target for cyberattacks. Protecting data access is an ongoing challenge, and implementing security measures that travel with the data can significantly enhance the integrity of digital transformation activities.
## EDR Critical Capabilities
EDR equips security professionals with modern forensic tools for endpoints, providing telemetry to uncover hard-to-find malware. Additionally, the "response" capability enables security professionals to take action, such as quarantining a file or disconnecting an endpoint from the network.
Expectations for EDR focus on two primary attributes: visibility and efficacy, along with people efficiency. Of course, visibility and efficacy are self-explanatory. EDR needs to be able to detect and block malicious activity that EPP is not expected to detect and block. Almost by definition, EDR must leverage data outside of the endpoint.
### Visibility and Efficacy
Context matters. For example, PowerShell scripts are useful for managing endpoints, and running such a script is not necessarily malicious. Seeing a lone script run on an endpoint does not necessarily indicate malicious activity.
However, if a PowerShell script was launched from a Word document that was previously attached to an email from an external sender, the context changes. Similarly, if an executable sends a beacon to a location from a known questionable IP range before encrypting a file, the context is important.
Understanding what happened before a file landed on an endpoint and what happened after is crucial. For example, knowing that an executable was unpacked on a networked printer or internet-connected fax machine before finding its way onto a laptop via an unknown lateral movement can provide context that may indicate a file's potential maliciousness.
Today, having a broad perspective is crucial. "Seeing" can be measured in degrees; more visibility is better, and understanding context has never been more important.
### People Efficiency
People are our most valuable assets, and security experts are hard to come by. This scarcity has real implications, as security teams cannot respond to every alert. Instead, they focus on addressing the maximum number of alerts within their allotted time. There are informal or formal rules that guide the investigation and remediation processes.
For instance, a company's security policy might dictate that the security team prioritize the highest severity alerts, giving the best effort to Level 4 alerts. The attack plan is typically prioritized, meaning that some alerts receive immediate response while others may not be addressed at all.
As a result, the efficiency and ease of use of EDR (Endpoint Detection and Response) tools directly impact their value. Analytics that correlate multiple alerts help filter out noise and enable automation of Level 1 analyst work. Guided search and automated intelligence tools allow Level 1 analysts to free up time by not having to triage alerts, thereby reducing the workload for Level 2 analysts. Therefore, people and time become the new return on investment (ROI) metrics for EDR tools.
## Visibility and Efficiency EDR Feature Evaluation Checklists
For EDR to add value in the modern era, EDR tools must do the following:
- Find threats that cannot be detected by using telemetry on the endpoint alone
- Provide forensics information that will illuminate how adversaries got past the other layers of security before they were stopped by EPP
Both use cases have a similar implication: The data that fuels EDR needs to come from more than just the endpoint. Telemetry needs to come from the network, cloud, and other security measures.
Following is a table of attributes that should be considered in evaluating the visibility and efficiency of an EDR Tool. Each feature should be scored with a numerical weight (for example, troubling (1) to excellent (4).
### Visibility and Efficacy EDR Features Evaluation
For People Efficiency Features, the same rating system applies—troubling (1) to excellent (4). Once again, the emphasis is on maximizing people's ROI.
### EDR People Efficiency Features Evaluation
### Optional Features that Enhance EDR Success
The following features aid the success of EDR solutions:
- Cloud-based sandbox for deep inspection and second opinion analysis
- Lightweight agent to minimize impact
- Single agent for both EPP and EDR
- Hardening such as application control or other features that reduce the attack surface
- Ability to collect data from and quickly share intelligence with network and cloud protection technologies
- Support for Windows, MacOS, and Linux operating systems
## Endpoints Supported by EDR Tools
Defining an endpoint to assess the role of EDR tools is more challenging today than ever. Not only are more endpoints installed, but the variety of those endpoints is far more complex and challenging to spot and manage. All endpoints are connected in some way to a network, to the internet, or to each other.
Traditional endpoint configurations include computers such as desktops, notebooks, and servers. In recent years, however, endpoints have been broadened in their applications and definitions, including smartphones and tablets. More recently, endpoints have been broadened to include the Internet of Things (IoT), sensors, and intelligent everyday electronics like office equipment or appliances.
Endpoints also include a wide range of specialty devices that are computer-driven or computer-controlled and connected to a network. These include digital signage, kiosks, wearable computers, and vehicle-mounted computers.
## Benefits of EDR Tools
EDR tools provide endpoint systems and an organization's entire IT infrastructure with end-to-end detection, protection, response, and remediation. They cover a wide range of use cases (see the "EDR use cases" section below) and are typically implemented fairly easily and quickly by experienced security teams and knowledgeable IT professionals.
Specific benefits of EDR tools include:
- Continuous monitoring
- Integration with threat intelligence services
- Threat hunting
- Behavioral analysis
- Contextual analysis
- Report generation for management and compliance requirements
- Event triage and validation
- Automated alerts and incident response
## Deployment of EDR Tools
EDR tools can be implemented in several ways. They are often deployed as software products on endpoint hardware and monitored continuously. They can also be implemented as managed services, outsourced to a managed software service provider (MSSP) that offers managed detection and response (MDR) over the cloud.
EDR tools may also be deployed hybrid, using both on-premises-installed tools and outsourced/cloud-based tools for different parts of the solution. In those cases, the full range of EDR tools are linked in a platform configuration, using both hardware and software to build a common foundation for all EDR tools.
## EDR Tools vs. EDR Services
The terminology used to describe the technologies that enable Endpoint Detection and Response (EDR) can be confusing because they often overlap. Systems, solutions, tools, services, and products are all used to describe how EDR is acquired, implemented, and utilized, but they are not interchangeable.
#### To clarify, let's distinguish between EDR tools and EDR services.
EDR tools are software products or applications that are installed on individual endpoint systems. They can also be deployed on an organization's physical or virtual network to support, manage, and control endpoint cybersecurity. These tools provide continuous monitoring, collect endpoint data, perform data analytics, trigger incident response, and share forensic details after an event.
On the other hand, EDR services offer similar capabilities but are provided as a managed service by an external provider. This is typically done by an experienced third-party service provider, often referred to as a managed security service provider (MSSP). These MSSPs often include EDR services as part of a broader range of security services, known as Managed Detection and Response (MDR). These service providers offer a wide range of capabilities similar to EDR tools but as an outsourced service.
## EDR Use Cases
One of the most important and attractive qualities of EDR is its ability to be applied across a wide—and growing—number of use cases. As the number, complexity, and diversity of endpoints continue to expand, so does the potential for use cases for EDR.
EDR is used in a wide range of use cases because it requires a number of the same capabilities, including advanced threat detection, continuous monitoring, incident response, end-to-end visibility, alert triage and validation, and reporting.
Specific use cases include:
- Malware Detection and Prevention: Identify and block various types of malware, whether they are known or unknown (zero-day threats).
- Behavioral Analysis: Monitor the behavior of applications and processes on endpoints, as well as spot deviations from standard behavior patterns.
- Cloud Security: Extend endpoint security coverage to cloud-based endpoints and resources, ensuring consistent security coverage in hybrid and multi-cloud environments.
- Zero-Day Threat Detection: Identify new vulnerabilities and threats for which no patches or signatures are available.
- Incident Response: Provide real-time visibility into endpoint activities, helping security teams to identify and respond to events rapidly.
- Threat Hunting: Proactively searching for known and unknown threats within the organization's endpoints and networks.
- IoT Device Security: Protect Internet of Things (IoT) devices, helping organizations secure a broader range of endpoints--many of which come from the factory with limited, "light" cybersecurity defenses.
- Insider Threat Detection: EDR tools review user behavior and access patterns to spot insider threats, which may be either malicious or unintentional.
- File Integrity Management: Unanticipated or unauthorized file changes may indicate potential attacks leading to file tampering.
- Forensic Investigation: Security analysts use endpoint data to trace the source of attack, understand its root cause and gather information that could indicate how to stop and block it.
- Endpoint Patch Management: Many attacks succeed simply because users fail to keep their endpoints properly up-to-date on the latest security tools.
- Compliance/Auditing: Audit trails, security event logs, and reports demonstrating compliance with various regulations are essential parts of EDR capabilities.
## EDR Tools FAQs
### What is the role of cloud computing in using EDR tools?
Many leading EDR tools providers, including Palo Alto Networks, offer a cloud-based set of EDR tools to take advantage of the many benefits of a cloud architecture. Cloud computing's infinite scalability, rapid deployment, and cost efficiency are desirable qualities to organizations looking to deploy a cloud-based EDR toolkit. Cloud-based EDR tools offer such specific benefits as centralized management, automated updates and patch management, large-scale data aggregation and data analytics, shared threat intelligence, dynamic storage and processing bandwidth, and reliable disaster recovery and redundancy.
### What is proactive EDR?
Proactive EDR anticipates potential endpoint problems rather than simply reacting when they do happen. The critical requirements of a proactive EDR toolkit include advanced threat protection, superior detection capabilities, simplified investigation and response, simplified deployment and management, and industry validation and independent testing.
### What are the differences between EDR and Extended Detection and Response (XDR)?
XDR is similar to EDR in that it secures endpoints against cyberthreats by using continuous monitoring and analytics to spot, identify, block, and, if necessary, remediate the attack's impact. The difference, however, is that XDR tools and services extend their coverage beyond endpoints also to include all aspects of an organization's digital infrastructure, including hardware, software, cloud gateways, and web services.
### What are the differences between EDR and antivirus?
The most significant difference between these two forms of endpoint protection is that antivirus defends endpoints primarily against known threats with a threat signature. At the same time, EDR also defends against new and emerging endpoint threats. This happens because EDR tools are usually integrated with threat intelligence services that identify emerging threats. EDR tools also provide a more comprehensive array of endpoint protection capabilities, including analytics, incident response, reporting, and integration with other security tools. Antivirus software often comes pre-installed on personal computers but often needs to be included from the factory for other types of endpoint devices.
Related Content
- What is EDR vs. Antivirus
Discover the key differences between EDR and Antivirus. Learn how each protects your system and which solution is best for your cybersecurity needs.
- Cortex Endpoint Detection and Response
A strong endpoint security strategy starts with best-in-class endpoint prevention, but the most sophisticated attacks need robust detection and response to stop breaches.
- Choosing the Right Endpoint Security
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Intune endpoint detection and response policy. Microsoft Learn
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https://learn.microsoft.com/en-us/intune/intune-service/protect/endpoint-security-edr-policy
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endpoint detection response EDR
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When you integrate Microsoft Defender for Endpoint with Intune, you can use endpoint security policies for endpoint detection and response (EDR) to manage the EDR settings and onboard devices to Microsoft Defender for Endpoint.
Endpoint detection and response capabilities of Microsoft Defender for Endpoint provide advanced attack detections that are near real-time and actionable. Security analysts can prioritize alerts effectively, gain visibility into the full scope of a breach, and take response actions to remediate threats.
Applies to:
- Linux
- macOS
- Windows 10
- Windows 11
- Windows Server 2012 R2 and later _(when managed by Configuration Manager through the tenant attach scenario, or through the Microsoft Defender for Endpoint Security settings management scenario)_
Section titled: About Intune policy for endpoint detection and response
## About Intune policy for endpoint detection and response
Intune's endpoint detection and response policies include platform-specific profiles to manage the onboarding installation of Microsoft Defender for Endpoint. Each profile includes an _onboarding package_ that applies to the device platform that the policy targets. Onboarding packages are how devices are configured to work with Microsoft Defender for Endpoint. After a device onboards, you can start to use threat data from that device.
You create and manage EDR policies from _Endpoint detection and response_ node that is in the _Endpoint security_ node of the Microsoft Intune admin center.
When you create EDR policy to onboard devices, you can use the preconfigured policy option, or create a policy that requires manual configuration of the settings, including identification of the onboarding package:
- **Preconfigured policy**: Supported for only Windows devices, use this option to rapidly deploy a preconfigured EDR onboarding policy to all applicable devices. You can use the preconfigured policy option for devices managed with Intune and for tenant attached devices managed through Configuration Manager. When using the preconfigured option, you can’t edit settings in the policy before its creation and initial deployment. After deployment, you can edit a few select settings. For more information, see Use a preconfigured EDR policy in this article.
- **Manually create a policy**: Supported for all platforms, use this option to create an onboarding policy you can deploy to discrete groups of devices. When using this path, you can configure any of the available settings in the policy before it deploys to assigned groups. For more information, see Use a manually created EDR policy in this article.
Based on the platform a policy targets, EDR policies for devices you manage with Intune deploy to groups of devices from Microsoft Entra ID, or to collections of on-premises devices that you synchronize from Configuration Manager through the tenant attach scenario.
In addition to EDR policy, you can use device configuration policy to onboard devices to Microsoft Defender for Endpoint. However, device configuration policies don't support tenant attached devices.
When using multiple policies or policy types like _device configuration_ policy and _endpoint detection and response_ policy to manage the same device settings (such as onboarding to Defender for Endpoint), you can create policy conflicts for devices. To learn more about conflicts, see Manage conflicts in the _Manage security policies_ article.
Section titled: Prerequisites for EDR policies
## Prerequisites for EDR policies
**General**:
- **Tenant for Microsoft Defender for Endpoint** – Your Microsoft Defender for Endpoint tenant must be integrated with your Microsoft Intune tenant (Intune subscription) before you can create EDR policies. For more information, see:
- Use Microsoft Defender for Endpoint for guidance on integrating Microsoft Defender for Endpoint with Microsoft Intune.
- Connect Microsoft Defender for Endpoint to Intune to set up the service-to-service connection between Intune and Microsoft Defender for Endpoint.
**Support for Configuration Manager clients**:
- **Set up tenant attach for Configuration Manager devices** \- To support deploying EDR policy to devices managed by Configuration Manager, configure _tenant attach_. This task includes configuring Configuration Manager device collections to support endpoint security policies from Intune.
To set up tenant attach, including the synchronization of Configuration Manager collections to the Microsoft Intune admin center and enabling them to work with policies for endpoint security, see Configure tenant attach to support endpoint protection policies.
For more information about using EDR policies with tenant attached devices, see Set up Configuration Manager to support EDR policy in this article.
Section titled: Role-based access controls (RBAC)
## Role-based access controls (RBAC)
For guidance on assigning the right level of permissions and rights to manage Intune endpoint detection and response policy, see Assign-role-based-access-controls-for-endpoint-security-policy.
Section titled: About the endpoint detection and response node
## About the endpoint detection and response node
In the Microsoft Intune admin center, the _Endpoint detection and response_ node is divided into two tabs:
**Summary tab**:
The Summary tab provides a high-level view of all your EDR policies, both manually configured policies and the policies you create using the Deploy preconfigured policy option.
The Summary tab includes the following areas:
- **Defender for Endpoint Connector status** – This view displays the current connector status for your tenant. The label, Defender for Endpoint Connector Status, is also a link that opens the Defender portal. This view is the same as found on the Endpoint security Overview page.
- **Windows devices onboarded to Defender for Endpoint** – This view shows a tenant-wide status for endpoint detection and response (EDR) onboarding, with counts for both devices that have or haven’t onboarded to Microsoft Defender for Endpoint.
- **Endpoint detection and response (EDR) policies** – Here you can create new manually configured EDR policies, and view the list of all EDR policies for your tenant. The policy list includes both manually configured policies and the policies you create using the Deploy preconfigured policy option.
Selecting a policy from the list opens a deeper view of that policy where you can review its configuration and choose to edit its details and configuration. If the policy was preconfigured, the settings you can edit are limited.
**EDR Onboarding Status tab**:
This tab displays a high-level summary of devices that have or haven’t onboarded to Microsoft Defender for Endpoint, and supports drilling into individual devices. This summary includes devices managed by Intune and devices that are managed through the tenant attach scenario and Configuration Manager.
This tab also includes the option to create and deploy a preconfigured onboarding policy for Windows devices.
The EDR onboarding status tab includes:
- **Deploy preconfigured policy** – This option appears near the top of the page, above the onboarding summary chart, and is used to create a preconfigured policy for onboarding Windows devices to Microsoft Defender for Endpoint.
- **The EDR onboarding status summary chart** – This chart displays the counts of devices that have or haven’t onboarded to Microsoft Defender for Endpoint.
- **Device list** – Below the summary chart is a list of devices with details, including:
- Device name
- How the device is managed
- The devices EDR onboarding status
- Last check-in time and date
- The last known state of the devices Defender sensor
Section titled: EDR profiles
## EDR profiles
Section titled: Devices managed by Microsoft Intune
### Devices managed by Microsoft Intune
Section titled: Linux
#### Linux
To manage EDR for Linux devices, select the **Linux** platform. The following profiles are available:
- **Endpoint detection and response** \- Intune deploys the policy to devices in your assigned groups. This profile supports use with:
- Devices enrolled with Intune.
- Devices managed through Security Management for Microsoft Defender for Endpoint.
EDR templates for Linux include two settings for the _Device tags_ category from Defender for Endpoint:
- **Value of tag** \- Only one value per tag can be set. The Type of a tag is unique and shouldn’t be repeated in the same profile.
- **Type of tag** – The GROUP tag, tags the device with the specified value. The tag is reflected in the admin center on the device page and can be used for filtering and grouping devices.
To learn more about Defender for Endpoint settings that are available for Linux, see Set preferences for Microsoft Defender for Endpoint on Linux in the Defender documentation.
- **Microsoft Defender Global Exclusions (AV+EDR)** \- Use this profile to manage both endpoint detection and response exclusion and Antivirus exclusions on Linux devices that are managed through the Microsoft Defender for Endpoint security settings management scenario. Exclusions you can deploy through this profile are added to exclusions that devices might receive from other sources, including EDR and Antivirus exclusions managed by Intune or Microsoft Defender Antivirus policies. Settings from multiple sources are subject to policy merge, and create a super set of exclusions for applicable devices and users.
This profile supports use with:
- Devices managed through Security Management for Microsoft Defender for Endpoint.
The EDR global exclusion template for Linux includes a simple template where you can **Add** and then edit one or more instances of exclusion configurations. This is the same configuration process as when configuring Intune policy for Microsoft Defender Antivirus Exclusions for Linux devices. The EDR global exclusion profile for Linux doesn't replace Microsoft Defender Antivirus Exclusions profiles you might already use for Linux.
To configure exclusions, each entry you add supports the following options:
- **Path** \- Define a path to exclude from endpoint detection and response. This can be a file or directory. Wild cards aren't supported.
- **Process name** \- Define a process name to exclude from endpoint detection and response. This can be a file name or full path. Wild cards aren't supported.
For more information about Linux exclusions, see Configure and validate exclusions for Microsoft Defender for Endpoint on Linux in the Microsoft Defender documentation.
Section titled: macOS
#### macOS
To manage EDR for macOS devices, select the **macOS** platform. The following profile is available:
- **Endpoint detection and response** \- Intune deploys the policy to devices in your assigned groups. This profile supports use with:
- Devices enrolled with Intune.
- Devices managed through Security Management for Microsoft Defender for Endpoint.
EDR templates for macOS include two settings for the _Device tags_ category from Defender for Endpoint:
- **Type of tag** – The GROUP tag, tags the device with the specified value. The tag is reflected in the admin center on the device page and can be used for filtering and grouping devices.
- **Value of tag** \- Only one value per tag can be set. The Type of a tag is unique and shouldn’t be repeated in the same profile.
To learn more about Defender for Endpoint settings that are available for macOS, see Set preferences for Microsoft Defender for Endpoint on macOS in the Defender documentation.
Section titled: Windows
#### Windows
To manage EDR for Windows devices, select the **Windows** platform. The following profile is available:
- **Endpoint detection and response** \- Intune deploys the policy to devices in your assigned groups. This profile supports use with:
- Devices enrolled with Intune.
- Devices managed through Security Management for Microsoft Defender for Endpoint.
Beginning on April 5, 2022, the _Windows 10 and later_ platform was replaced by the _Windows_ platform.
The _Windows_ platform supports devices communicating through Microsoft Intune or Microsoft Defender for Endpoint. These profiles also add support for the Windows Server platform which isn't supported through Microsoft Intune natively.
Profiles for this new platform use the settings format as found in the Settings Catalog. Each new profile template for this new platform includes the same settings as the older profile template it replaces. With this change you can no longer create new versions of the old profiles. Your existing instances of the old profile remain available to use and edit.
**Options for** _**Microsoft Defender for Endpoint client configuration package type**_:
- _Applies to Windows devices only_
After you configure the service-to-service connection between Intune and Microsoft Defender for Endpoint, the **Auto from connector** option becomes available for the setting **Microsoft Defender for Endpoint client configuration package type**. This option isn't available until you configure the connection.
When you select **Auto from connector**, Intune automatically gets the onboarding package (blob) from your Defender for Endpoint deployment. This choice replaces the need to manually configure an **Onboard** package for this profile. There isn't an option to automatically configure an offboard package.
Section titled: Devices managed by Configuration Manager
### Devices managed by Configuration Manager
Section titled: Endpoint detection and response
#### Endpoint detection and response
To manage Endpoint detection and response policy settings for Configuration Manager devices when you use tenant attach.
**Platform**: _Windows (ConfigMgr)_
**Profile**: _Endpoint detection and response (ConfigMgr)_
**Required version of Configuration Manager**:
- Configuration Manager current branch version 2002 or later, with in-console update Configuration Manager 2002 Hotfix (KB4563473)
- Configuration Manager technical preview 2003 or later
**Supported Configuration Manager device platforms**:
- Windows 8.1 (x86, x64), starting in Configuration Manager version 2010
- Windows 10 and later (x86, x64, ARM64)
- Windows 11 and later (x86, x64, ARM64)
- Windows Server 2012 R2 (x64), starting in Configuration Manager version 2010
- Windows Server 2016 and later(x64)
Important
On October 22, 2022, Microsoft Intune ended support for devices running Windows 8.1. Technical assistance and automatic updates on these devices aren't available.
If you currently use Windows 8.1, then move to Windows 10/11 devices. Microsoft Intune has built-in security and device features that manage Windows 10/11 client devices.
Section titled: Set up Configuration Manager to support EDR policy
## Set up Configuration Manager to support EDR policy
Before you can deploy EDR policies to Configuration Manager devices, complete the configurations detailed in the following sections.
These configurations are made within the Configuration Manager console and to your Configuration Manager deployment. If you're not familiar with Configuration Manager, plan to work with a Configuration Manager admin to complete these tasks.
The following sections cover the required tasks:
1. Install the update for Configuration Manager
2. Enable tenant attach
To learn more about using Microsoft Defender for Endpoint with Configuration Manager, see the following articles in the Configuration Manager content:
- Onboard Configuration Manager clients to Microsoft Defender for Endpoint via the Microsoft Intune admin center
- Microsoft Intune tenant attach: Device sync and device actions
Section titled: Task 1: Install the update for Configuration Manager
### Task 1: Install the update for Configuration Manager
Configuration Manager version 2002 requires an update to support use with Endpoint detection and response policies you deploy from the Microsoft Intune admin center.
**Update details**:
- **Configuration Manager 2002 Hotfix (KB4563473)**
This update is available as an _in-console update_ for Configuration Manager 2002.
To install this update, follow the guidance from Install in-console updates in the Configuration Manager documentation.
After installing the update, return here to continue configuring your environment to support EDR policy from the Microsoft Intune admin center.
Section titled: Task 2: Configure tenant attach and synchronize collections
### Task 2: Configure tenant attach and synchronize collections
With Tenant attach, you specify collections of devices from your Configuration Manager deployment to synchronize with the Microsoft Intune admin center. After collections synchronize, use the admin center to view information about those devices and to deploy EDR policy from Intune to them.
For more information about the Tenant attach scenario, see Enable tenant attach in the Configuration Manager content.
Section titled: Enable tenant attach when co-management isn't enabled
#### Enable tenant attach when co-management isn't enabled
You use the **Co-management Configuration Wizard** in the Configuration Manager console to enable tenant attach, but you don't need to enable co-management.
If you're planning to enable co-management, be familiar with co-management, its prerequisites, and how to manage workloads before you continue. See What is co-management in the Configuration Manager documentation.
To enable tenant attach when co-management isn’t enabled, you’ll need to sign-in to the _AzurePublicCloud_ for your environment. Before proceeding, review Permissions and roles in the Configuration Manager documentation to ensure you have an account available that can complete the procedure.
1. In the Configuration Manager admin console, go to **Administration** \> **Overview** \> **Cloud Services** \> **Co-management**.
2. In the ribbon, select **Configure co-management** to open the wizard.
3. On the **Tenant onboarding** page, select **AzurePublicCloud** for your environment. Azure Government cloud isn't supported.
1. Select **Sign In** and specify an account that has sufficient permissions to to your _AzurePublicCloud_ environment.
The following are supported for devices you manage with Intune:
- Platform: **Windows** \- Intune deploys the policy to devices in your Microsoft Entra groups.
- Profile: **Endpoint detection and response**
Section titled: Use a preconfigured EDR policy
## Use a preconfigured EDR policy
Intune supports use of a preconfigured EDR policy for Windows devices managed by Intune, and by Configuration Manager through the tenant attach scenario.
On the _EDR Onboarding Status_ page of Intune’s Endpoint detection and response policy, select the **Deploy preconfigured policy** option to have Intune create and deploy a preconfigured policy to install Microsoft Defender for Endpoint on applicable devices.
This option is found near the top of the page, above the Windows Devices onboarded to Defender for Endpoint report:
Before you can select this option, you must successfully configure the **Defender for Endpoint Connector**, which establishes a service-to-service connection between Intune and Microsoft Defender for Endpoint. The policy uses the connector to get a Microsoft Defender for Endpoint onboarding blob for use to onboard devices. For information about configuring this connector, see Connect Microsoft Defender for Endpoint to Intune in the _Configure Defender for Endpoint_ article.
If you use the tenant attach scenario to support devices managed by Configuration Manager, set up Configuration Manager to support EDR policy from the Microsoft Intune admin center. See Configure tenant attach to support endpoint protection policies.
Section titled: Create the preconfigured EDR policy
### Create the preconfigured EDR policy
When using the **Deploy preconfigured policy** option, you can’t change the default policy configurations for installing Microsoft Defender for Endpoint, scope tags, or assignments. However, after the policy is created, you can edit some of its details, including configuration of assignment filters.
To create the policy:
1. In the Microsoft Intune admin center, go to **Endpoint security** \> **Endpoint detection and response** \> open the **EDR Onboarding Status** tab > select **Deploy preconfigured policy**.
2. On the **Create a profile** page, specify one of the following combinations, and then select **Create**:
- For devices managed by Intune:
- Platform = **Windows**
- Profile = **Endpoint detection and response**
- For devices managed through the tenant attach scenario:
- Platform = **Windows (ConfigMgr)**
- Profile = **Endpoint detection and response (ConfigMgr)**
Important
Deployment to tenant attached devices requires the **All Desktop and Server Client** collection to be enabled and synchronized in your tenant.
3. On the **Basics** page, Provide a Name for this policy. Optionally, you can also add a Description.
4. On the **Review and Create** page, you can expand the available categories to review the policy configuration, but you can’t make changes. Intune only uses applicable settings based on the Platform and Profile combination you selected. For example, for devices managed by Intune, the policy targets the _All Devices_ group. The _All Desktop and Server clients_ group is targeted for tenant attached devices.
Select **Save** to create, and deploy the preconfigured policy.
Section titled: Edit a preconfigured EDR policy
### Edit a preconfigured EDR policy
After you create a preconfigured policy, you can find it on the **Summary** tab for Endpoint detection and response policy. By selecting a policy, you can then choose to edit some, but not all policy options. For example, for Intune devices, you can edit the following options:
- Basic: You can edit the following options:
- Name
- Description
- Configuration setting: The following two settings can be changed from their default of Not configured:
- Sample Sharing
- \[Deprecated\] Telemetry Reporting Frequency
- Assignments: You can't change the group assignment, but you can add Assignment filters.
Section titled: Use a manually created EDR policy
## Use a manually created EDR policy
On the EDR Summary page of Intune’s Endpoint detection and response policy, you can select **Create Policy** to begin the process of manually configuring an EDR policy to onboard devices to Microsoft Defender for Endpoint.
This option is found near the top of the page, above the Windows Devices onboarded to Defender for Endpoint report:
Section titled: Create a manually configured EDR policy
### Create a manually configured EDR policy
1. Sign in to the Microsoft Intune admin center.
2. Select **Endpoint security** \> **Endpoint detection and response** \> **Create Policy**.
3. Select the platform and profile for your policy. The following information identifies your options:
- Intune - Intune deploys the policy to devices in your assigned groups. When you create the policy, select:
- Platform: **Linux**, **macOS**, or **Windows**
- Profile: **Endpoint detection and response**
- Configuration Manager - Configuration Manager deploys the policy to devices in your Configuration Manager collections. When you create the policy, select:
- Platform: **Windows (ConfigMgr)**
- Profile: **Endpoint detection and response (ConfigMgr)**
4. Select **Create**.
5. On the **Basics** page, enter a name and description for the profile, then choose **Next**.
6. On the **Configuration settings** page, Choose **Auto from Connector** for **Microsoft Defender for Endpoint Client configuration package type**. Configure the **Sample Sharing** and **Telemetry Reporting Frequency** settings you want to manage with this profile.
To onboard or offboard tenants using the onboarding file from the Microsoft Defender for Endpoint portal, select either _Onboard_ or _Offboard_ and supply the contents of the onboarding file to the input directly below the selection.
When you're done configuring settings, select **Next**.
7. If you use Scope tags, on the **Scope tags** page, choose **Select scope tags** to open the _Select tags_ pane to assign scope tags to the profile.
Select **Next** to continue.
8. On the **Assignments** page, select the groups or collections that receive this policy. The choice depends on the platform and profile you selected:
- For Intune, select groups from Microsoft Entra.
- For Configuration Manager, select the collections from Configuration Manager that have synced to the Microsoft Intune admin center and enabled for Microsoft Defender for Endpoint policy.
You can choose not to assign groups or collections at this time, and later edit the policy to add an assignment.
When ready to continue, select **Next**.
9. On the **Review + create** page, when you're done, choose **Create**.
The new profile is displayed in the list when you select the policy type for the profile you created.
Section titled: Update the onboarding state for a device
## Update the onboarding state for a device
Organizations might need to update the onboarding information on a device via Microsoft Intune.
This update can be necessary due to a change in the onboarding payload for Microsoft Defender for Endpoint, or when directed by Microsoft support.
Updating the onboarding information directs the device to start utilizing the new onboarding payload at the next _Restart_.
This information won't necessarily move a device between tenants without fully offboarding the device from the original tenant. For options migrating devices between Microsoft Defender for Endpoint organizations, engage Microsoft Support.
Section titled: Process to update the payload
### Process to update the payload
1. Download the new Mobile Device Management **New** onboarding payload from the Microsoft Defender for Endpoint console.
2. Create a **New Group** to validate the new policies effectiveness.
3. Exclude the **New Group** from your existing EDR policy.
4. Create a **New** Endpoint Detection and Response policy, outlined in Create EDR policies.
5. While creating the policy, select **Onboard** from the client package configuration type, and specify the **contents** of the onboarding file from the Microsoft Defender for Endpoint console.
6. **Assign the policy** to the new group created for validation.
7. **Add** existing devices to the validation group and ensure the changes work as expected.
8. **Expand** the deployment gradually, eventually decommissioning the original policy.
If previously using the _Auto from connector_ option to retrieve the onboarding information, engage Microsoft support to confirm the use of the new onboarding information.
For organizations updating onboarding information at the direction of Microsoft support, Microsoft will direct you when the connector has been updated to use the new onboarding payload.
Section titled: EDR policy reports and monitoring
## EDR policy reports and monitoring
You can view details about the EDR policies you use in the endpoint deployment and response node of the Microsoft Intune admin center.
For policy details, in the admin center, go to **Endpoint security** \> **Endpoint deployment and response** \> **Summary** tab, and select the policy for which you want to view compliance details:
- For policies that target the **Linux**, **macOS**, or **Windows** platforms (Intune), Intune displays an overview of compliance to the policy. You can also select the chart to view a list of devices that received the policy, and drill-in to individual devices for more details.
- For Windows devices, the chart for **Windows devices onboarded to Defender for Endpoint** displays the count of devices that have successfully onboarded to Microsoft Defender for Endpoint and that have yet to onboard.
To ensure you have full representation of your devices in this chart, deploy the onboarding profile to all your devices. Devices that onboard to Microsoft Defender for Endpoint by external means, like Group Policy or PowerShell, are counted as **Devices without the Defender for Endpoint sensor**.
- For policies that target the **Windows (ConfigMgr)** platform (Configuration Manager), Intune displays an overview of compliance to the policy that doesn't support drill-in to view additional details. The view is limited because the admin center receives limited status details from Configuration Manager, which manages the deployment of the policy to Configuration Manager devices.
To view details for individual devices, go to **Endpoint security** \> **Endpoint deployment and response** \> **EDR Onboarding Status** tab, and select a device from the list to view additional device-specific details.
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How intrusion detection systems help identify cyber threats in real-time
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https://www.dataguard.com/blog/how-intrusion-detection-systems-help-identify-cyber-threats/
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network intrusion detection
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Yes (reduced from 48913 to 29771 chars)
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Risk management Cyber security Cybersecurity measures
# How intrusion detection systems help identify cyber threats in real-time
DataGuard Insights
Is your network security keeping up with today’s threats? Cybercriminals are constantly finding new ways to infiltrate systems, making intrusion detection and prevention more crucial than ever. Intrusion Detection Systems (IDS) and Intrusion Prevention Systems (IPS) play a key role in protecting your network by spotting suspicious activities and blocking potential attacks before they cause damage.
**This guide breaks down how IDS work, the different types, their benefits and limitations, and practical steps for implementation. You'll learn how to strengthen your defenses, meet security standards, and stay one step ahead of evolving cyber threats.**
In this blog, we'll cover:
- What are intrusion detection systems (IDS)?
- How do intrusion detection systems work?
- What are the types of intrusion detection systems?
- What are the benefits of using intrusion detection systems?
- How do intrusion detection systems help identify cyber threats in real-time?
- What are the limitations of intrusion detection systems?
- How can businesses implement and maintain an effective intrusion detection system?
- Frequently asked questions
Key takeaways
- Intrusion Detection Systems (IDS) are tools that monitor network and user behavior to identify potential cyber threats in real-time.
- IDS use various techniques such as analyzing network traffic and integrating with other security tools to help identify and respond to cyber threats quickly.
- Businesses can benefit from implementing an IDS by having a customizable alert system, early detection of threats, and improved incident response time.
## What are intrusion detection systems (IDS)?
How do you catch threats before they strike? Intrusion Detection Systems (IDS) and Intrusion Prevention Systems (IPS) are your first line of defense, constantly scanning network traffic and system activity to spot signs of trouble. By detecting unauthorized access, malware, and other suspicious behaviors, IDS help you stop attacks before they cause harm.
These systems go beyond just monitoring—they actively strengthen your organisation’s security posture by uncovering vulnerabilities, ensuring compliance with regulations, and reinforcing security policies across your entire network. Whether it's analyzing data packets or reviewing system logs, IDS are essential for staying one step ahead of cyber threats.
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## How do intrusion detection systems work?
Intrusion Detection Systems (IDS) operate by employing real-time monitoring techniques to analyse network traffic and identify anomalies based on predefined signatures of known attacks, such as malware and exploitation vulnerabilities. This process generates security alerts for any suspicious activity that may suggest a potential cyber threat, enabling prompt incident response.
## What are the types of intrusion detection systems?
Intrusion Detection Systems (IDS) can be classified into three primary types. Let's have a closer look:
### 1\. Network-based IDS
Network-based Intrusion Detection Systems (NIDS) are designed for you to analyse network traffic in real-time, identifying malicious activity by monitoring data packets, such as DNS queries and specific ports, and detecting suspicious patterns that may indicate an intrusion.
These systems employ a variety of protocols to scrutinise the flow of information across your network. That way, they enable them to capture and evaluate different types of traffic, such as TCP, UDP, and ICMP. Through continuous monitoring, they can generate instant alerts upon recognising anomalies that deviate from established norms, which is essential for your rapid response to potential threats.
Additionally, the incorporation of machine learning algorithms enhances their capabilities, allowing them to adapt and refine detection techniques based on historical data and emerging patterns, ultimately improving accuracy and reducing false positives.
### 2\. Host-based IDS
Host-based Intrusion Detection Systems (HIDS) monitor individual hosts for unauthorised access. They analyse system logs to detect any suspicious activity that may indicate a security incident.
These systems play a critical role in maintaining a secure environment by tracking changes to files, monitoring user behaviour, and evaluating system configurations. By scrutinising file integrity, they identify unauthorised alterations, which is essential for safeguarding sensitive data. Additionally, they observe user activity to highlight unusual behaviour patterns that could signal potential insider threats or compromised accounts.
Unlike network-based IDS, which monitor traffic across an entire network, HIDS provide more granular insights. However, they can require considerable resources and may be limited in scope to the host environment. This can lead to challenges in managing a vast number of endpoints, necessitating careful consideration of both the advantages and disadvantages these systems present for your organisation.
### 3\. Hybrid IDS
A hybrid IDS combines the strengths of both network-based IDS (NIDS) and host-based IDS (HIDS). This IDS offers a comprehensive approach to monitoring network traffic alongside individual host systems for enhanced security coverage.
This versatile system not only improves detection capabilities by cross-referencing data from multiple sources but also enables a dynamic analysis of suspicious activities. By using advanced machine learning algorithms, a hybrid IDS can adapt intelligently to emerging threats and evolving attack patterns.
The correlation of insights gathered from both network and host levels significantly reduces false positives, allowing security teams to concentrate their efforts on genuine threats rather than being overwhelmed by irrelevant alerts, thereby optimising security policies and compliance requirements.
The outcome is a more efficient and effective security posture, give the power to organisations to respond swiftly to potential breaches.
## What are the benefits of using intrusion detection systems?
The adoption of Intrusion Detection Systems (IDS) offers numerous advantages for organisations.
### 1\. Real-time monitoring
Intrusion Detection Systems (IDS) offer continuous surveillance, scanning network traffic for signs of trouble like unauthorised access or malware. This allows you to catch and contain threats before they turn into serious breaches.
Real-time insights help security teams spot unusual patterns and behaviours instantly, enabling quick action to neutralise risks. This constant vigilance boosts your situational awareness, making your defences more resilient against evolving cyber threats. With IDS in place, you gain peace of mind knowing your sensitive data is protected around the clock.
### 2\. Early detection of cyber threats
Early detection of cyber threats is one of the most significant advantages of utilising an Intrusion Detection System. This capability allows your organisation to identify and neutralise malicious activity before it escalates into a full-blown security incident.
By using advanced algorithms, these systems efficiently analyse vast amounts of network traffic, pinpointing unusual patterns that signify emerging threats. Machine learning plays a pivotal role in this process, continuously refining detection mechanisms to adapt to new attack methodologies.
### 3\. Customisable alerts and notifications
Customisable alerts and notifications provided by Intrusion Detection Systems (IDS) enable you to tailor your security responses effectively. This ensures that critical security alerts reach the appropriate personnel promptly, facilitating efficient incident management.
This tailored approach is essential as it allows your security team to concentrate on specific threats relevant to your unique environment, thereby enhancing the overall efficiency of your security operations. By configuring alerts based on particular compliance requirements or emerging threat patterns, you can mitigate risks more effectively.
### 4\. Improved incident response time
Implementing an Intrusion Detection System (IDS) significantly enhances your incident response time, enabling your organisation to quickly identify and address security incidents, thereby reducing the potential impact of cyber threats.
By seamlessly integrating with your incident response teams, the IDS automates various protocols, allowing for a swift reaction to alerts. This integration is vital, as it facilitates real-time communication, ensuring that your security personnel are immediately informed of any threats.
Certain alerts can even trigger automated responses triggered by detecting suspicious activity that mitigate risks before human intervention is necessary. The importance of timely intervention and addressing security incidents cannot be overstated; responding promptly reduces the likelihood of extensive damage, protecting critical data and preventing unauthorized access and maintaining your organisation’s integrity.
## How do intrusion detection systems help identify cyber threats in real-time?
How do IDS catch threats as they happen?
Intrusion Detection Systems (IDS) actively scan network traffic to spot unusual activity, using techniques like anomaly detection to flag suspicious behaviour instantly. By integrating with other security tools, such as firewalls and Snort, IDS strengthen your threat detection and response capabilities.
### 1\. Detection of known and unknown threats
Intrusion Detection Systems (IDS) excel at catching both known and unknown threats. Using signature-based methods, they quickly identify familiar attack patterns, while anomaly detection techniques help uncover new or evolving threats that don’t match established profiles.
Signature-based detection is fast and effective for known threats, but it can struggle with unfamiliar attacks or advanced techniques that evade known signatures. That’s where machine learning comes in. By analyzing large volumes of network data and system logs, IDS can learn to recognize subtle anomalies, continuously improving detection accuracy.
With this dual approach, IDS help organizations stay ahead of emerging threats, strengthen defenses, and reduce the risk of breaches from previously unknown exploits.
### 2\. Analysis of network traffic and user behaviour
Spotting unusual activity with network and user behaviour analysis
Intrusion Detection Systems (IDS) continuously analyse network traffic and user behaviour to uncover signs of potential threats. By tracking key metrics like data packet volumes, login attempts, and access patterns, IDS create a baseline of what "normal" looks like across your network.
When activity deviates from this baseline—such as a sudden spike in data transfers or unusual login times—IDS trigger alerts, prompting a closer look. This proactive approach helps identify possible breaches early, allowing your security team to act quickly and minimise risks.
By understanding typical network behaviour, your organisation can strengthen defenses and react swiftly to potential intrusions.
### 3\. Integration with other security tools
Integrating Intrusion Detection Systems (IDS) with other security tools, like firewalls and SIEM systems, boosts your overall security. This coordinated approach enables faster, more effective responses to potential threats while aligning with your security policies.
By combining the strengths of network-based IDS (NIDS) and host-based IDS (HIDS), your organization can better detect and respond to suspicious activities across different platforms. This integration helps correlate events, making it easier to spot patterns and address risks quickly.
With these tools working together, your security team can analyse threats in real-time, improving incident response and fortifying your defences against diverse cyber threats.
### 4\. Use of machine learning and artificial intelligence
Machine learning and artificial intelligence (AI) are game-changers for Intrusion Detection Systems (IDS), boosting their ability to spot and respond to cyber threats. These technologies automate the process of detecting anomalies, making threat assessments more accurate and cutting down on false alarms.
With AI, IDS can sift through massive amounts of data in real-time, quickly distinguishing between normal traffic and potential threats. Advanced algorithms allow the systems to learn from past incidents, continuously fine-tuning their ability to spot unusual behaviour.
This adaptability not only sharpens threat detection but also reduces false positives that can overwhelm security teams. As cyber threats grow more sophisticated, AI and machine learning ensure your defences keep pace, helping your organisation stay resilient and one step ahead of attackers.
## What are the limitations of intrusion detection systems?
Despite their numerous advantages, Intrusion Detection Systems (IDS) do have limitations.
These include a tendency for false positives, restricted visibility caused by encrypted traffic into encrypted traffic, and the resource-intensive nature affecting network infrastructure of their operation, which can affect overall network performance.
### 1\. False positives
False positives happen when an Intrusion Detection System (IDS) mistakenly flags legitimate network activity as a threat. These inaccurate alerts can overwhelm security teams, pulling their focus away from real risks.
When your Security Operations Centre (SOC) is flooded with unnecessary alerts, valuable time is wasted chasing non-issues. This not only slows down the response to actual threats but also weakens the overall effectiveness of the IDS. Critical incidents could slip through the cracks, putting your network at greater risk.
Excessive false positives can also lead to alert fatigue, where SOC analysts become desensitised to alarms. This reduces their ability to react swiftly and accurately when a genuine threat arises, making prompt action even more challenging
### 2\. Limited visibility
Limited visibility is a major obstacle for Intrusion Detection Systems (IDS), particularly when it comes to monitoring encrypted traffic. While encryption protects sensitive data, it can also hide malicious activity from detection, creating blind spots in your security.
These blind spots make it harder for security teams to detect and respond to potential threats in real time. The very encryption that safeguards data can also obscure suspicious traffic patterns, increasing the risk of missed breaches.
To tackle this issue, consider strategies like:
- Using decryption proxies where permitted to inspect traffic.
- Leveraging advanced machine learning to detect anomalies.
- Implementing robust logging solutions to capture metadata and improve visibility.
By adopting these measures, your organisation can close detection gaps, strengthen network security, and maintain regulatory compliance.
### 3\. Resource intensive
Intrusion Detection Systems (IDS) can be resource-intensive, requiring substantial computing power and bandwidth to analyse large amounts of data. This can strain network performance and put pressure on organisations with limited IT resources.
IDS typically need robust hardware, including high-performance servers with powerful processors and ample memory, to handle real-time monitoring and data analysis. If the system struggles to keep up, it can result in delayed or missed alerts, weakening your security posture.
To mitigate these challenges, strategic resource optimisation to enhance network performance is essential. Employing techniques like load balancing and efficient data filtering, efficient data filtering, and leveraging cloud computing for scalable network infrastructure can significantly improve operational capabilities while reducing the resource burden on existing systems.
## How can businesses implement and maintain an effective intrusion detection system?
Protecting your network starts with the right approach. To implement and maintain an effective Intrusion Detection System (IDS), businesses need a clear strategy that covers everything from selecting the right tools to ongoing monitoring and updates.
Here’s how to get it right and keep your defences strong.
### 1\. Define security goals and requirements
The first step in implementing an effective Intrusion Detection System (IDS) is defining your security goals and requirements. This helps you choose the right technologies and strategies that align with your organisation's needs.
Start by assessing your current security environment to identify vulnerabilities, potential threats, and regulatory requirements. Pinpoint key assets and the risks they face, such as cyber threats or unauthorised access, to determine what specific capabilities your IDS needs.
Aligning these requirements with your overall cybersecurity strategy ensures that the IDS enhances threat detection while fitting seamlessly into your broader security framework. Consider advanced features like machine learning and anomaly detection for more sophisticated threat detection.
### 2\. Choose the right IDS solution
Choosing the right Intrusion Detection System (IDS) is key to building a robust security framework. The selection process should consider your network setup, compliance requirements, existing security measures, and the unique threats your organisation faces.
Decide whether a Network IDS (NIDS), which monitors traffic, a Host IDS (HIDS), which focuses on endpoints, or a hybrid solution best suits your needs. Each type offers different strengths, so aligning them with your security goals is crucial.
Ensure the IDS integrates smoothly with your current tools, such as firewalls and SIEM systems, for a unified defence strategy. When evaluating solutions, look at factors like false positive rates, detection accuracy, real-time monitoring capabilities, and how easy it is to manage alerts. This approach will help you choose an IDS that not only detects threats but also supports your broader cybersecurity and compliance objectives.
### 3\. Regularly update and test the system
To stay ahead of cyber threats, your Intrusion Detection System (IDS) needs regular care. Frequent updates and testing ensure it can spot the latest dangers and keep your network secure.
Skipping this maintenance can leave gaps for attackers to exploit, potentially leading to costly data breaches. Keeping the IDS up-to-date with the latest security patches helps close these gaps and strengthens your defences.
Routine testing is just as crucial. It validates that your IDS is correctly configured and performing well, even as threats evolve. Incorporating threat intelligence into the process provides valuable insights into new attack patterns, allowing the system to adapt quickly.
By regularly updating and testing your IDS, you can boost its ability to detect threats and maintain a strong security posture in a constantly changing landscape.
### 4\. Train employees on cybersecurity awareness
Training employees in cybersecurity awareness is a vital part of a strong Intrusion Detection System (IDS) strategy. When employees know what to look for, they can help identify threats and act quickly on security alerts, boosting your incident response.
Phishing scams are getting more sophisticated, often disguised as legitimate emails or messages. Training equips employees to spot these risks and follow security policies, ensuring sensitive data is protected and compliance standards are met.
Encourage a culture where reporting suspicious activity is second nature. When employees feel confident raising concerns without hesitation, your organisation's overall security becomes stronger, creating a proactive workplace where everyone helps maintain a safer digital environment.
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Open Source IDS Tools: Comparing Suricata, Snort, Bro (Zeek), Linux
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https://levelblue.com/blogs/security-essentials/open-source-intrusion-detection-tools-a-quick-overview
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network intrusion detection
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### **IDS Detection Techniques**
There are two primary threat detection techniques: signature-based detection and anomaly-based detection. These detection techniques are important when you’re deciding whether to go with a signature or anomaly detection engine, but vendors have become aware of the benefits of each, and some are building both into their products. Learning their strengths and weaknesses enables you to understand how they can complement one another.
### **Signature-based IDS Tools**
With a signature-based IDS, aka knowledge-based IDS, there are rules or patterns of known malicious traffic being searched for. Once a match to a signature is found, an alert is sent to your administrator. These alerts can discover issues such as known malware, network scanning activity, and attacks against servers.
## Unified Security Management
One platform combining the essential security capabilities, including IDS, asset discovery, and SIEM log management.
Learn more
### **Anomaly-based IDS Tools**
With an anomaly-based IDS, aka behavior-based IDS, the activity that generated the traffic is far more important than the payload being delivered. An anomaly-based IDS tool relies on baselines rather than signatures. It will search for unusual activity that deviates from statistical averages of previous activities or previously seen activity. For example, if a user always logs into the network from California and accesses engineering files, if the same user logs in from Beijing and looks at HR files this is a red flag.
Both signature-based and anomaly-based detection techniques are typically deployed in the same manner, though one could make the case you could (and people have) create an anomaly-based IDS on externally-collected netflow data or similar traffic information.
### **Advantages and Disadvantages**
Fewer false positives occur with signature-based detection but only known signatures are flagged, leaving a security hole for the new and yet-to-be-identified threats. More false positives occur with anomaly-based detection but if configured properly it catches previously unknown threats.
## Network-Based IDS (NIDS)
Network-based intrusion detection systems (NIDS) operate by inspecting all traffic on a network segment in order to detect malicious activity. With NIDS, a copy of traffic crossing the network is delivered to the NIDS device by mirroring the traffic crossing switches and/or routers.
A NIDS device monitors and alerts on traffic patterns or signatures. When malicious events are flagged by the NIDS device, vital information is logged. This data needs to be monitored in order to know an event happened. By combining this information with events collected from other systems and devices, you can see a complete picture of your network’s security posture. Note that none of the tools here correlate logs by themselves. This is generally the function of a Security Information and Event Manager (SIEM).
### **Snort**
Ah, the venerable piggy that loves packets. Many people will remember 1998 as the year Windows 98 came out, but it was also the year that Martin Roesch first released Snort. Although Snort wasn't a true IDS at the time, that was its destiny. Since then it has become the de-facto standard for IDS, thanks to community contributions.
It's important to note that Snort has no real GUI or easy-to-use administrative console, although lots of other open source tools have been created to help out, such as BASE and Sguil. These tools provide a web front end to query and analyze alerts coming from Snort IDS.
Snort Summary
- Long product life with no signs of going away
- Great community support
- Plenty of administrative front-ends
- Thoroughly proven and tested
- Great community support
- According to Snort’s website, features include:
- Modular design:
- Multi-threading for packet processing
- Shared configuration and attribute table
- Use a simple, scriptable configuration
- Plugin framework, make key components pluggable (and 200+ plugins)
- Auto-detect services for portless configuration
- Auto-generate reference documentation
- Scalable memory profile
- Rule parser and syntax (support sticky buffers in rules)
- Documentation:
- Ruleset Updates
- Snort FAQ
- A Snort Cheatsheet
- A plugin for Snort is available for AlienVault USM Anywhere.
### **Suricata**
What's the only reason for not running Snort? If you're using Suricata instead. Although Suricata's architecture is different than Snort, it behaves the same way as Snort and can use the same signatures. What's great about Suricata is what else it's capable of over Snort. It does so much more, it probably deserves a dedicated post of its own.
There are third-party open source tools available for a web front end to query and analyze alerts coming from Suricata IDS.
Suricata Summary
- Multi-Threaded - Snort runs with a single thread meaning it can only use one CPU(core) at a time. Suricata can run many threads so it can take advantage of all the cpu/cores you have available. There has been much contention on whether this is advantageous, Snort says No and a few benchmarks say Yes.
- Built in Hardware Acceleration - Did you know you can use graphic cards to inspect network traffic?
- File Extraction - Someone downloading malware? You can capture it right from Suricata and study it.
- LuaJIT - It's a lot of letters yes, but it's also a scripting engine that can be used with information from the packets inspected by Suricata. This makes complex matching even easier and you can even gain efficiency by combining multiple rules into one script.
- Logging more than packets - Suricata can grab and log things like TLS/SSL certs, HTTP requests, DNS requests
- Great community support
- According to Suricata’s website, features include:
- High performance - multi-threaded, scalable code base
- Multipurpose Engine - NIDS, NIPS, NSM, offline analysis, etc.
- Cross-platform support - Linux, Windows, macOS, OpenBSD, etc.
- Modern TCP/IP support including a scalable flow engine, full IPv4/IPv6, TCP streams, and IP packet defragmentation
- Protocol parsers - packet decoding, application layer decoding
- HTTP engine - HTTP parser, request logger, keyword match, etc.
- Autodetect services for portless configuration
- Lua scripting (LuaJIT)
- Application-layer logging and analysis, including TLS/SSL certs, HTTP requests, DNS requests, and more
- Built-in hardware acceleration (GPU for network sniffing)
- File extraction
- Documentation:
- Suricata User Guide
- User and Developer Docs
- Suricata FAQ
### **Bro (renamed Zeek)**
Bro, which was renamed Zeek in late 2018 and is sometimes referred to as Bro-IDS or now Zeek-IDS, is a bit different than Snort and Suricata. In a way, Bro is both a signature and anomaly-based IDS. Its analysis engine will convert traffic captured into a series of events. An event could be a user login to FTP, a connection to a website or practically anything. The power of the system is what comes after the event engine and that's the Policy Script Interpreter. This policy engine has its own language (Bro-Script) and it can do some very powerful and versatile tasks.
If you're an analyst and you've wondered "How can I automate some of my work?" then this is the tool you've been looking for. Want to download files seen on the wire, submit them for malware analysis, notify you if a problem is found then blacklist the source and shutdown the user's computer who downloaded it? Want to track the usage patterns of a user after they've contacted an IP from a reputation database?
If you're not an analyst then this tool will have a challenging learning curve. Since it was developed as a research tool, it didn't initially focus on things like GUIs, usability, and ease of installation. While it does numerous cool things out of the box many of those things aren't immediately actionable and may be difficult to interpret.
There’s no native GUI but there are third-party open source tools available for a web front end to query and analyze alerts coming from Bro-IDS. Consider ELK stack.
Bro Summary
- Complicated to set up
- Can detect patterns of activity other IDS systems can not
- Very extensible architecture
- Good community support
- According to Bro’s website, features include:
- Comprehensive traffic logging and analysis
- Powerful and flexible event-driven scripting language (Bro scripts)
- Deploys on UNIX-style systems, including Linux, FreeBSD, and MacOS
- DNS/FTP/HTTP/IRC/SMTP/SSH/SSL/other protocol support
- Fully passive traffic analysis with network tap or monitoring port
- Real-time and offline analysis
- Cluster-support for large-scale deployments
- Comprehensive IPv6 support
- IDS-style pattern matching
- File extraction
- Extensible architecture
- Analysts can use Bro for automation (file extraction, malware analysis, blacklisting, track usage patterns, research work, etc.)
- Documentation:
- ~~Bro Manual~~
- ~~Bro Docs~~
- ~~Bro FAQ~~
## Host-based IDS (HIDS)
Host-based intrusion detection systems (HIDS) work by monitoring activity occurring internally on an endpoint host. HIDS applications (e.g. antivirus software, spyware-detection software, firewalls) are typically installed on all internet-connected computers within a network, or on a subset of important systems, such as servers. This includes those in public cloud environments.
HIDS search for unusual or nefarious activities by examining logs created by the operating system, looking for changes made to key system files, tracking installed software, and sometimes examining the network connections a host makes.
The first HIDS systems were basic, usually just creating MD5 hashes of files on a recurring basis and looking for discrepancies, utilizing a process dubbed file integrity monitoring (FIM). Since then, HIDS have grown far more complex and perform a variety of useful security functions and will continue to grow. This includes modern Endpoint Response (EDR) capabilities.
If your organization has a compliance mandate, such as for PCI DSS, HIPAA, or ISO 27001, then you may require HIDS to demonstrate file integrity monitoring (FIM) as well as active threat monitoring.
### **OSSEC**
In the realm of full-featured open source HIDS tools, there is OSSEC and not much else. The great news is OSSEC is very good at what it does and is rather extensible.
OSSEC runs on almost any major operating system and includes client/server based management and logging architecture, which is very important in a HIDS system. Since local HIDS can be compromised at the same time the OS is, it is very important security and forensic information leave the host and be stored elsewhere asap to avoid any kind of tampering or obfuscation that would prevent detection.
OSSEC's client/server architecture incorporates this strategy by delivering alerts and logs to a centralized server where analysis and notification can occur even if the host system is taken offline or compromised. Another advantage of client/server architecture is the ability to centrally manage agents from a single server. Since deployments can range from one to thousands of installations, the ability to make global changes from a central server is critical for an administrator's sanity.
When discussing OSSEC (and other HIDS) there is often anxiety over installing an agent or software on critical servers. It should be noted that the installation of OSSEC is extremely light (the installer is under 1MB) and the majority of analysis actually occurs on the server which means very little CPU is consumed by OSSEC on the host. OSSEC also has the ability to send OS logs to the server for analysis and storage, which is particularly helpful on Windows machines that have no native and cross-platform logging mechanisms.
#### OSSEC Summary:
- Agents for almost every OS
- Compiled Agent for Windows
- Lots of functionality than just FIM
- Rigid but simple installation process
- Good community support
- According to OSSEC’s website, features include:
- File integrity monitoring (FIM)
- Log monitoring collects, analyzes, and correlates system logs
- Rootkit detection, which searches for system modifications similar to rootkits
- Active response can invoke automated response action when alerts are triggered
- Client/Server architecture
- Multi-platform support (Linux, Solaris, Windows, MacOS, etc.)
- Supports compliance requirements for FIM
- Real-time and configurable alerts
- Integration with current infrastructure
- Centralized server for mass policy management
- Agent and agentless monitoring
- A plugin for OSSEC is available for AlienVault USM Anywhere. To learn more, read here.
- Documentation:
- OSSEC Docs
- OSSEC FAQ
- OSSEC Github
### **Samhain Labs**
Samhain is probably the only HIDS open-source that gives OSSEC a run for its money. But it’s very much the case of “same but different” when comparing the two. Samhain has the same client/server architecture but doesn’t require it as OSSEC does. The agent itself has a variety of output methods, one being a central log repository but includes others like Syslog, Email, and RDBMS. There is even an option to use Samhain as a standalone application on a single host.
Another important difference is where analysis occurs. Unlike OSSEC, the processing occurs on the client itself, which has operational implications. From a practical point of view, care must be taken it doesn’t overload a busy server and interfere with operations. From the security point of view, having the brains on the endpoint invites hackers to deactivate the tool so warnings aren’t issued.
#### Samhain Summary:
- Harder to install
- Windows clients require Cygwin
- Great FIM functionality
- More flexible client
- Okay community support
- According to Samhain’s website, features include:
- File integrity monitoring (FIM)
- Log file monitoring and analysis
- Rootkit detection
- Port monitoring
- Detection of rogue SUID executables and hidden processes
- Multi-platform support
- Centralized logging and maintenance
- Client/Server architecture (mostly)
- Variety of output methods (e.g. syslog, email RDBMS)
- Can be used as a standalone application on a single host
- Documentation:
- Samhain Docs
- Samhain User Manual
- Samhain FAQ
## File Integrity Monitoring (FIM Only)
Many file integrity monitoring(FIM) tools get categorized with HIDS since FIM involves threat detection, so let’s talk about them. FIM is tool that validates operating system and specified application file integrity by comparing current versions with known valid versions, alerting your administrator whenever they are modified. This is important because changes on critical servers often signal a breach has occurred. If you are still wondering “what is file integrity monitoring and why do I need it?”, we have an entire blog post explaining why.
Some FIM are actively developed while others haven't been updated in years. Open Source Tripwire and AFICK are two open-source FIM products options. For standalone Unix-based systems, consider checking out rootkit-finding file integrity checkers, such as chkrootkit, rkhunter, or Unhide. The unique rootkit-finding mechanism makes these solutions worth considering. Proprietary solutions are also available for Windows.
AlienVault Unified Security Management (USM) Platform provides built-in FIM capabilities to drive threat detection technologies and accelerate your cybersecurity compliance efforts. To learn more about how AlienVault USM uses FIM to protect your assets, read here.
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