Developing a Cybersecurity Program for an Early-Stage Business
What are the objectives of a cybersecurity program?
The objectives are to maintain the confidentiality, integrity, and availability of systems and data – this is known as the CIA triad and it’s at the core of all cybersecurity programs. Maintain confidentiality by preventing or minimizing unauthorized access to data. Protect integrity by preventing unauthorized alterations of data. Protect availability by ensuring authorized subjects are granted timely and uninterrupted access to data.
Who should own cybersecurity outcomes?
The board of directors are ultimately responsible for the outcomes of the cybersecurity program – they should be asking about cybersecurity at every board meeting. If they don’t, it won’t get the attention it deserves. The CEO and CFO need to be held accountable to thinking about cybersecurity. Governance is a board responsibility.
How should a small business get started improving their cybersecurity posture?
Begin with a risk assessment – identify your assets, their worth, and the potential risks that could affect them. If you don’t have a cybersecurity leader on your team, you can use a qualified vCISO (virtual Chief Information Security Officer) or MSSP (Managed Security Services Provider) to perform a risk assessment and provide an actionable roadmap for cybersecurity improvement.
Work with an MSSP – partnering with an MSSP can provide a full-service security solution for small businesses that may not have dedicated security staff. They can perform risk assessments, develop improvement plans, perform continuous monitoring, respond to incidents, and provide various other security services. They might cover:
- Endpoint protection – endpoint protection software, such as anti-malware software for devices like Windows machines, helps secure your company’s devices and networks.
- Incident response – in the event of a security incident, an MSSP can provide step-by-step guidance through the investigation process, connecting you with necessary resources such as lawyers and partners for breach notifications.
- Cloud security – if your company utilizes a software as a service (SaaS) product, an MSSP can help secure and monitor your product in the cloud, ensuring the safety of your data and services.
Consider a dedicated cybersecurity leader – as you grow, you’ll want to consider adding a Chief Information Security Officer (CISO) or other senior cybersecurity leader to your team who will manage and monitor your cybersecurity program. A dedicated leader will be able to right-size the program as you grow, manage costs, maintain compliance, and present updates to management and the board of directors. And if your customers are large enterprises, they’re cybersecurity teams often expect to have a counterpart within your organization to interact with.
Are there frameworks on which a small business can model their cybersecurity program?
Select the security framework that aligns with your organization’s needs and goals – these frameworks provide a solid foundation for your security program and help ensure that your internal controls and policies are effective and up-to-date. Ask your vCISO or MSSP what they recommend based on your risk assessment.
ISO 27001 – this is a globally recognized standard for information security management systems. It provides a systematic approach to managing sensitive company information and ensuring its security.
NIST-800 – the National Institute of Standards and Technology (NIST) Special Publication 800 series is a set of guidelines and recommendations for federal agencies to follow in order to protect their information and information systems.
COBIT – Control Objectives for Information and Related Technologies (COBIT) is a framework that covers not only security but also IT governance in general, including the supply and demand of IT resources.
CIS Critical Security Controls – these controls are a prescriptive, prioritized, and simplified set of best practices that you can use to strengthen your cybersecurity posture.
SOC-2 – Service Organization Control (SOC) 2 is a set of criteria for managing customer data based on five trust service principles: security, availability, processing integrity, confidentiality, and privacy. It is not a compliance system, but rather an official audit of a company’s security controls and policies.
NIST is one of the best frameworks for categorizing cybersecurity topics – the NIST Cybersecurity Framework includes five broad categories: Identify, Protect, Detect, Respond, Recover. To understand the scope of activities a cybersecurity program might include, see an excerpt below from the NIST framework documentation.
NIST Framework activities – Identity
| Sub-Category | Activities to consider | ||||
| Asset Management – the data, personnel, devices, systems, and facilities that enable the organization to achieve business purposes are identified and managed consistent with their relative importance to organizational objectives and the organization’s risk strategy. | – Inventory physical devices and systems within the organization – Inventory software platforms and applications – Map communication and data flows – Catalogue external information systems – Prioritize resources (e.g. hardware, devices, data, time, personnel and software) based on classification, criticality, and business value – Establish cybersecurity roles and responsibilities for your workforce and third-party stakeholders (suppliers, customers and partners) | ||||
| Business Environment – the organization’s mission, objectives, stakeholders, and activities are understood and prioritized; this information is used to inform cybersecurity roles, responsibilities and risk management decisions. | – Identify and communicate organization’s role in the supply chain – Identity and communicate organization’s place in critical infrastructure and industry sector – Establish and communicate priorities for organizational mission, objectives, and activities – Establish dependencies and critical functions for delivery of critical services – Establish resilience requirements to support delivery of critical services for all operating states (under duress/attack, during recovery, normal operations | ||||
| Governance – the policies, procedures, and processes to manage and monitor the organization’s regulatory, legal, risk, environmental, and operational requirements are understood and inform the management of cybersecurity risk. | – Establish and communicate cybersecurity police – Coordinate and align on cybersecurity roles and responsibilities with internal roles and external partners – Understand and manage legal and regulatory requirements – Address cybersecurity risks with governance and risk management processes | ||||
| Risk Assessment – the organization understands the cybersecurity risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals. | – Identify and document asset vulnerabilities – Receive cyber threat intelligence from information sharing forums and sources – Identify and document internal and external threats – Identify potential business impacts and likelihoods – Determine risk using threats vulnerabilities, likelihoods and impacts – Identify and prioritize risk responses | ||||
| Risk Management Strategy – the organization’s priorities, constraints, risk tolerances, and assumptions are established and used to support operational risk decisions. | – Risk management processes are established, managed, and agreed to by organizational stakeholders – Organizational risk tolerance is determined and clearly expressed – The organization’s determination of risk tolerance is informed by its role in critical infrastructure and sector specific risk analysis | ||||
| Supply Chain Risk Management – The organization’s priorities, constraints, risk tolerances, and assumptions are established and used to support risk decisions associated with managing supply chain risk. The organization has established and implemented the processes to identify, assess and manage supply chain risks. | – Suppliers and third party partners of information systems, components, and services are identified, prioritized, and assessed using a cyber supply chain risk assessment process – Contracts with suppliers and third-party partners are used to implement appropriate measures designed to meet the objectives of an organization’s cybersecurity program and Cyber – Supply Chain Risk Management Plan. – Suppliers and third-party partners are routinely assessed using audits, test results, or other forms of evaluations to confirm they are meeting their contractual obligations. – Response and recovery planning and testing are conducted with suppliers and third-party providers | ||||
NIST Framework activities – Protect
| Sub-Category | Activities to consider | ||||
| Identity Management, Authentication, and Access Control – access to physical and logical assets and associated facilities is limited to authorized users, processes, and devices, and is managed consistent with the assessed risk of unauthorized access to authorized activities and transactions. | – Identities and credentials are issued, managed, verified, revoked, and audited for authorized devices, users and processes – Physical access to assets is managed and protected – Remote access is managed – Access permissions and authorizations are managed, incorporating the principles of least privilege and separation of duties – Network integrity is protected (e.g., network segregation, network segmentation) – Identities are proofed and bound to credentials and asserted in interactions – Users, devices, and other assets are authenticated (e.g., single-factor, multi-factor) commensurate with the risk of the transaction (e.g., individuals’ security and privacy risks and other organizational risks) | ||||
| Awareness and Training – The organization’s personnel and partners are provided cybersecurity awareness education and are trained to perform their cybersecurity-related duties and responsibilities consistent with related policies, procedures, and agreements. | – All users are informed and trained – Privileged users understand their roles and responsibilities – Third-party stakeholders (e.g., suppliers, customers, partners) understand their roles and responsibilities – Senior executives understand their roles and responsibilities – Physical and cybersecurity personnel understand their roles and responsibilities | ||||
| Data Security – Information and records (data) are managed consistent with the organization’s risk strategy to protect the confidentiality, integrity, and availability of information. | – Data-at-rest is protected – Data-in-transit is protected – Assets are formally managed throughout removal, transfers, and disposition – Adequate capacity to ensure availability is maintained – Protections against data leaks are implemented – Integrity checking mechanisms are used to verify software, firmware, and information integrity – The development and testing environment(s) are separate from the production environment – Integrity checking mechanisms are used to verify hardware integrity | ||||
| Information Protection Processes and Procedures – Security policies (that address purpose, scope, roles, responsibilities, management commitment, and coordination among organizational entities), processes, and procedures are maintained and used to manage protection of information systems and assets. | – A baseline configuration of information technology/industrial control systems is created and maintained incorporating security principles (e.g. concept of least functionality) – A System Development Life Cycle to manage systems is implemented – Configuration change control processes are in place – Backups of information are conducted, maintained, and tested – Policy and regulations regarding the physical operating environment for organizational assets are met – Data is destroyed according to policy – Protection processes are improved – Effectiveness of protection technologies is shared – Response plans (Incident Response and Business Continuity) and recovery plans (Incident Recovery and Disaster Recovery) are in place and managed – Response and recovery plans are tested – Cybersecurity is included in human resources practices (e.g., deprovisioning, personnel screening) – A vulnerability management plan is developed and implemented | ||||
| Maintenance – Maintenance and repairs of industrial control and information system components are performed consistent with policies and procedures. | – Maintenance and repair of organizational assets are performed and logged, with approved and controlled tools – Remote maintenance of organizational assets is approved, logged, and performed in a manner that prevents unauthorized access | ||||
| Protective Technology – Technical security solutions are managed to ensure the security and resilience of systems and assets, consistent with related policies, procedures, and agreements. | – Audit/log records are determined, documented, implemented, and reviewed in accordance with policy – Removable media is protected and its use restricted according to policy – The principle of least functionality is incorporated by configuring systems to provide only essential capabilities – Communications and control networks are protected – Mechanisms (e.g., failsafe, load balancing, hot swap) are implemented to achieve resilience requirements in normal and adverse situations | ||||
NIST Framework activities – Detect
| Sub-Category | Activities to consider | ||||
| Anomalies and Events – anomalous activity is detected and the potential impact of events is understood. | – A baseline of network operations and expected data flows for users and systems is established and managed – Detected events are analyzed to understand attack targets and methods – Event data are collected and correlated from multiple sources and sensors – Impact of events is determined – Incident alert thresholds are established | ||||
| Security Continuous Monitoring – the information system and assets are monitored to identify cybersecurity events and verify the effectiveness of protective measures | – The network is monitored to detect potential cybersecurity events – The physical environment is monitored to detect potential cybersecurity events – Personnel activity is monitored to detect potential cybersecurity events – Malicious code is detected – Unauthorized mobile code is detected – External service provider activity is monitored to detect potential cybersecurity events – Monitoring for unauthorized personnel, connections, devices, and software is performed – Vulnerability scans are performed | ||||
| Detection Processes – detection processes and procedures are maintained and tested to ensure awareness of anomalous events. | – Roles and responsibilities for detection are well defined to ensure accountability – Detection activities comply with all applicable requirements – Detection processes are tested – Event detection information is communicated – Detection processes are continuously improved | ||||
NIST Framework activities – Respond
| Sub-Category | Activities to consider | ||||
| Response Planning – response processes and procedures are executed and maintained, to ensure response to detected cybersecurity incidents. | – Response plan is executed during or after an incident | ||||
| Communication – response activities are coordinated with internal and external stakeholders (e.g. external support from law enforcement agencies). | – Personnel know their roles and order of operations when a response is needed – Incidents are reported consistent with established criteria – Information is shared consistent with response plans – Coordination with stakeholders occurs consistent with response plans – Voluntary information sharing occurs with external stakeholders to achieve broader cybersecurity situational awareness | ||||
| Analysis – analysis is conducted to ensure effective response and support recovery activities. | – Notifications from detection systems are investigated – The impact of the incident is understood – Forensics are performed – Incidents are categorized consistent with response plans – Processes are established to receive, analyze and respond to vulnerabilities disclosed to the organization from internal and external sources (e.g. internal testing, security bulletins, or security researchers) | ||||
| Mitigation – activities are performed to prevent expansion of an event, mitigate its effects, and resolve the incident. | – Incidents are contained – Incidents are mitigated – Newly identified vulnerabilities are mitigated or documented as accepted risks | ||||
| Improvements – organizational response activities are improved by incorporating lessons learned from current and previous detection/response activities. | – Response plans incorporate lessons learned – Response strategies are updated | ||||
NIST Framework activities – Recover
| Sub-Category | Activities to consider | ||||
| Recovery Planning – recovery processes and procedures are executed and maintained to ensure restoration of systems or assets affected by cybersecurity incidents. | – Recovery plan is executed during or after a cybersecurity incident | ||||
| Improvements – recovery planning and processes are improved by incorporating lessons learned into future activities. | – Recovery plans incorporate lessons learned – Recovery strategies are updated | ||||
| Communications – restoration activities are coordinated with internal and external parties (e.g. coordinating centers, Internet Service Providers, owners of attacking systems, victims, other CSIRTs, and vendors). | – Public relations are managed – Reputation is repaired after an incident – Recovery activities are communicated to internal and external stakeholders as well as executive and management teams | ||||
See the NIST framework file for a comprehensive list of cybersecurity areas you should be thinking about.
What are some actions a small business can take today to reduce their cyber risk?
Enable MFA on all services for all employees – enabling multi-factor authentication (MFA) is one of the easiest ways for a small business to reduce cyber risk. MFA means that authentication to a system requires at least two factors: something you know (password), something you have (mobile phone or MFA device), or something you are (fingerprint or face match). Every employee should be required to use MFA for authentication to company cloud and on-premises systems such as email, collaboration tools, file storage, financial systems, websites, etc.
Provide security awareness training to employees – Employees in a small business are often the weakest link in the cybersecurity chain. However, without training, how can employees be expected to recognize threats? There are many providers of security awareness training to choose from and some, such as KnowBe4, even offer phishing simulations which automatically assign additional training to “clickers.” Conduct training at least annually.
Implement cybersecurity policies – make it clear to employees, partners, and customers that you take cybersecurity seriously by developing cybersecurity policies that are enforced. Employees must understand that they play an important role in keeping company data safe. Policies should be distributed to all new hires, stored alongside other company policies, and be discussed at least annually.
Implement endpoint detection & response software on all devices – your MSSP will likely have a list of EDR tools they support so it is a good idea to partner with them on this topic. EDR installed on all servers, laptops, desktops, and mobile devices will allow the MSSP to continuously monitor and respond to potential threats. These systems usually include anti-virus and encryption tools for additional protection. Encryption should be enforced on all laptops and mobile devices to prevent data access due to loss or theft.
Start a lifecycle management program – maintain an inventory of all software and hardware assets used by the company, ensure they are kept updated with the latest patches and hotfixes, and retire end-of-support (EOS) assets that are no longer receiving regular updates from the developer or manufacturer.
Provide employees with a password manager – password managers allow employees to use very complex passwords which are not easy to remember without having to write them down in unsecure places like sticky notes. Consider subscribing to services like 1Password and LastPass for your employees.
Consider subscribing to a VPN service for employees – while most connections between your device and individual websites are encrypted by default, an attacker on the same untrusted network as you, like at a hotel or a coffee shop, could still intercept your secure connection request to a website and perform what is called a man-in-the-middle attack. Virtual Private Network services encrypt and route all your internet traffic through their servers to prevent this.
What are the most important things to get right?
Select an MSSP and accompanying toolset that work well together and meet your needs – work with an MSSP who can meet the unique security requirements of your organization, and select a toolset that your MSSP can help you handle.
Refer to a framework as you mature your cybersecurity capabilities – use a framework (e.g. NIST) to understand where your organization’s cybersecurity capabilities stand, and how you can move them to the next stage.
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