Category Archives: Compliance

An Eerie Silence on Cybersecurity

Apparently it takes an alleged Chinese threat to get the New York Times to notice Internet security problems. The Times has escalated from a recent article to an editorial.

NYTimes Editorial 26 February 2013, An Eerie Silence on Cybersecurity, notes a few exceptions, and then remarks:

American companies have been disturbingly silent about cyberattacks on their computer systems — apparently in fear that this disclosure will unnerve customers and shareholders and invite lawsuits and unwanted scrutiny from the government.

In some cases, such silence might violate the legal obligations of publicly traded companies to share material information about their businesses. Most companies would tell investors if an important factory burned to the ground or thieves made off with hundreds of millions of dollars in cash.

Maybe it’s better to have a prescribed burn of released breach information than to have a factory fire of unprescribed released information.

Why don’t companies do this?

Continue reading

Companies fear reputation for bad security

As more companies come out of the closet about their Internet security being compromised, still more start to admit it. But many (perhaps most) don’t even know. Fortunately, there is a way the public can get a clue even about those companies.

Nicole Perlroth wrote for the NYTimes 20 February 2013 that corporations try to hide successful cracking of their Internet security:

Most treat online attacks as a dirty secret best kept from customers, shareholders and competitors, lest the disclosure sink their stock price and tarnish them as hapless.

However, as some companies come out of the closet about this (Twitter, Facebook, Apple, etc.) and such

revelations become more common, the threat of looking foolish fades and more companies are seizing the opportunity to take the leap in a crowd.

“There is a ‘hide in the noise’ effect right now,” said Alan Paller, director of research at the SANS Institute, a nonprofit security research and education organization. “This is a particularly good time to get out the fact that you got hacked, because if you are one of many, it discounts the starkness of the announcement.”

Now here’s the interesting part:

Continue reading

ISPs, spam, and botnets? a case in Finland

In Finland, some ISPs proactively detect spamming botnets and do something about it.

A small company that does computer maintenance, “HS-Works Oy” located in Helsinki, HS-Works Oy Finland, received a computer from a customer that needed to be fixed since it was acting slow. HS-Works personnel hooked up the malfunctioning computer to the company’s switch to gain Internet access and so they could control it over their LAN.

Sonera After the computer was through the LAN to the Internet for a while, the local ISP (Sonera) realized someone from HS-Works was connecting to a known botnet and acting in possibly malicious way. So what did the ISP do?

The solution was rigid: they closed the Internet connection from HS-works and informed the company via an SMS message that there had been illicit or malicious connections originating from their IP address and the connection would remain closed until the problem was solved. All web traffic was directed to the ISP’s “Access blocked” page, which offers a link to a free 30-day trial of Sonera Internet Security package (F-Secure software branded under Sonera name).

Network access would be returned after the infected host was fixed or removed from the network. The company raised their firewalls to a more strict level and got the Internet access back on the same day.

How about Finland’s ranking in spam listings in general and the rest of the big Finnish ISP policies on spam? Stay tuned, more information about these on the next post!

-Sami Sainio

Quis custodiet ipsos medici?

Internet security is in a position similar to that of safety in the medical industry. Many doctors have an opinion like this one, quoted by Kent Bottles:
“Only 33% of my patients with diabetes have glycated hemoglobin levels that are at goal. Only 44% have cholesterol levels at goal. A measly 26% have blood pressure at goal. All my grades are well below my institution’s targets.” And she says, “I don’t even bother checking the results anymore. I just quietly push the reports under my pile of unread journals, phone messages, insurance forms, and prior authorizations.”

Meanwhile, according to the CDC, 99,000 people die in the U.S. per year because of health-care associated infections. That is equivalent of an airliner crash every day. It’s three times the rate of deaths by automobile accidents.

The basic medical error problems observed by Dennis Quaid when his twin babies almost died due to repeated massive medically-administered overdoses and due to software problems such as ably analysed by Nancy Leveson for the infamous 1980s Therac-25 cancer-radiation device are not in any way unique to computing in medicine. The solutions to those problems are analogous to some of the solutions IT security needs: measurements plus six or seven layers of aggregation, analysis, and distribution.

As Gardiner Harris reported in the New York Times, August 20, 2010, another problem is that intravenous and feeding tubes are not distinguished by shape or color: Continue reading

What we can learn from the Therac-25

What does Nancy Leveson’s classic analysis of the Therac-25 recommend? (“An Investigation of the Therac-25 Accidents,” by Nancy Leveson, University of Washington and Clark S. Turner, University of California, Irvine, IEEE Computer, Vol. 26, No. 7, July 1993, pp. 18-41.)
“Inadequate Investigation or Followup on Accident Reports. Every company building safety-critical systems should have audit trails and analysis procedures that are applied whenever any hint of a problem is found that might lead to an accident.” p. 47

“Government Oversight and Standards. Once the FDA got involved in the Therac-25, their response was impressive, especially considering how little experience they had with similar problems in computer-controlled medical devices. Since the Therac-25 events, the FDA has moved to improve the reporting system and to augment their procedures and guidelines to include software. The input and pressure from the user group was also important in getting the machine fixed and provides an important lesson to users in other industries.” pp. 48-49

The lesson being that you have to have built-in audit, reporting, transparency, and user visibility for reputation.

Which is exactly what Dennis Quaid is asking for.

Remember, most of those 99,000 deaths a year from medical errors aren’t due to control of complicated therapy equipment: Continue reading

What about the Therac-25?

Someone suggested that Dennis Quaid should be reminded of the Therac-25 “if he thinks computers will reduce risk without a huge investment in quality, quality assurance and operational analysis.” For readers who may not be familiar with it, the Therac-25 was a Canadian radiation-therapy device of the 1980s that was intended to treat cancer. It had at least six major accidents and caused three fatalities, because of poor software design and development.

Why should anyone assume Dennis Quaid doesn’t know that quality assurance and operational analysis are needed for anything designed or controled by software? The man is a jet pilot, and thus must be aware of such efforts by aircraft manufacturers, airlines, and the FAA. As Quaid points out, we don’t have a major airline crash every day, and we do have the equivalent in deaths from medical errors. Many of which could be fixed by Computerized Physician Order Entry (CPOE).

Or ask the Mayo Clinic: Continue reading

Medical Metrics Considered Overrated

One of the presenters at Metricon 5.0 was comparing IT security to other fields in various aspects of metrics and monitoring. I mentioned I thought she was giving far too much green for good to the field of medicine. This provoked repeated back and forth later.

My point was that 150 years after the invention of epidemiology and 100 years after the discovery of bacterial transmission of disease, in medicine application of known preventive measures is so low that Atul Gawande of Harvard has gotten large (on the order of 30%) reductions in deaths from complications of surgery in many hospitals simply by getting them to use checklists for things like washing hands before surgery.

I have an elderly relative in a nursing home who can’t take pills whole due to some damage to nerves in her neck. Again and again visitors sent by the family discover nursing home staff trying to give her pills whole without grinding them up. Why? They don’t read instructions about her, and previous shifts don’t remind later shifts. This kind of communication problem is epidemic not only in nursing homes but in hospitals. I found my father in a diabetic coma because nurses hadn’t paid any attention to him being a diabetic and needing to eat frequently. Fortunately, a bit of honey brought him out of it. Even nurses readily acknowledge this problem, but it persists. I can rattle off many other examples.

To which someone responded, yes, but medicine has epidemiology, and Edward Tufte demonstrated in one of his books that that goes well beyond checklists in to actual analysis, as in a physician’s discovery of a well in London being he source of cholera. I responded, yes, John Snow, in 1854: that was the first thing I said when I stood up to address this. But who now applies what he learned? One-shot longitudinal studies are not the same as ongoing monitoring with comparable metrics to show how well one group is doing compared to both the known science and to other groups.

Many people still didn’t get it, and kept referring to checklists as rudimentary.

So I tried again. If John Snow were alive today, he wouldn’t be prescribing statins for life to people with high blood pressure. He would be compiling data on who has high blood pressure and what they have been doing and eating before they got it. He would follow this evidence back to discover that one of the main contributors to high blood pressure, heart disease, and diabetes in the U.S. is high fructose corn syrup (HFCS). Then he would mount a political campaign to ban high fructose corn syrup, which would be the modern equivalent of his removal of the handle from the pump of the well that stopped the cholera.

To which someone replied, but there are political forces who would oppose that. And I said, yes, of course. Permit me to elaborate.

There were political forces in John Snow’s time, too, and he dealt with them:

Dr Snow took a sample of water from the pump, and, on examining it under a microscope, found that it contained “white, flocculent particles.” By 7 September, he was convinced that these were the source of infection, and he took his findings to the Board of Guardians of St James’s Parish, in whose parish the pump fell.

Though they were reluctant to believe him, they agreed to remove the pump handle as an experiment. When they did so, the spread of cholera dramatically stopped. [actually the outbreak had already lessened for several days]

Snow also investigated several outliers, all of which turned out to involve people actually travelling to the Soho well to get water.
Still no one believed Snow. A report by the Board of Health a few months later dismissed his “suggestions” that “the real cause of whatever was peculiar in the case lay in the general use of one particular well, situate [sic] at Broad Street in the middle of the district, and having (it was imagined) its waters contaminated by the rice-water evacuations of cholera patients. After careful inquiry,” the report concluded, “we see no reason to adopt this belief.”

So what had caused the cholera outbreak? The Reverend Henry Whitehead, vicar of St Luke’s church, Berwick Street, believed that it had been caused by divine intervention, and he undertook his own report on the epidemic in order to prove his point. However, his findings merely confirmed what Snow had claimed, a fact that he was honest enough to own up to. Furthermore, Whitehead helped Snow to isolate a single probable cause of the whole infection: just before the Soho epidemic had occurred, a child living at number 40 Broad Street had been taken ill with cholera symptoms, and its nappies had been steeped in water which was subsequently tipped into a leaking cesspool situated only three feet from the Broad Street well.

Whitehead’s findings were published in The Builder a year later, along with a report on living conditions in Soho, undertaken by the magazine itself. They found that no improvements at all had been made during the intervening year. “Even in Broad-street it would appear that little has since been done… In St Anne’s-Place, and St Anne’s-Court, the open cesspools are still to be seen; in the court, so far as we could learn, no change has been made; so that here, in spite of the late numerous deaths, we have all the materials for a fresh epidemic… In some [houses] the water-butts were in deep cellars, close to the undrained cesspool… The overcrowding appears to increase…” The Builder went on to recommend “the immediate abandonment and clearing away of all cesspools — not the disguise of them, but their complete removal.”

Nothing much was done about it. Soho was to remain a dangerous place for some time to come.

John Snow didn’t shy away from politics. He was successful in getting the local politicians to agree to his first experiment, which was successful in helping end that outbreak of cholera. He even drew his biggest opponent into doing research, which ended up confirming Snow’s epidemiological diagnosis and extending it further to find the original probable source of infection of the well. But even that didn’t suffice for motivating enough political will to fix the problem.

From which I draw two conclusions:

  1. Even John Snow is over-rated. Sure, he found the problem, but he didn’t get it fixed longterm.

  2. Why not? Because that would require ongoing monitoring of likely sources of infection (which sort of happened) compared to actual incidents of disease (which does not appear to have happened), together with eliminating the known likely sources.
Eliminating likely known sources is what Dr. Gawande’s checklist is about, 150 years later, which was my original point. And the ongoing monitoring and comparisons appear not to be happening, even yet.

As someone at Metricon said, who will watch the watchers? I responded, yes, that’s it!

One-shot longitudinal studies can create great information. That’s what John Snow did. That’s what much of scientific experiment is about. But even when you repeat the experiment to confirm it, that’s not the same as ongoing monitoring. And it’s not the same as checklists to ensure application of what was learned in the experiment.

What is really needed is longitudinal experiments combined checklists, plus ongoing monitoring, plus new analysis derived from the monitoring data. That’s at least four levels. All of them are needed. Modern medicine often only manages the first. And in the case of high fructose corn syrup (HFCS), until recently even the first was lacking, and most of the experiments that have happened until very recently have not come from the country with the biggest HFCS health problem, namely the U.S. A third of the entire U.S. population is obese, and another third is overweight, with concomittant epidemics of heart disease, diabetes, and high blood pressure. And the medical profession prescribes statins for life instead of getting to the root of the problem and fixing it.

Yes, I think the field of medicine gets rated too much green for good.

And if IT security wants to improve its own act, it also needs all four levels, not just the first or the second.


Checks on Checks, or Shipping and Shipping Software

Paul Graham points out that big company checks on purchasing usually have costs, such as purchasing checks increase the costs of purchased items because the vendors have to factor in their costs of passing the checks.
Such things happen constantly to the biggest organizations of all, governments. But checks instituted by governments can cause much worse problems than merely overpaying. Checks instituted by governments can cripple a country’s whole economy. Up till about 1400, China was richer and more technologically advanced than Europe. One reason Europe pulled ahead was that the Chinese government restricted long trading voyages. So it was left to the Europeans to explore and eventually to dominate the rest of the world, including China.

The Other Half of “Artists Ship”, by Paul Graham, November 2008

I would say western governments (especially the U.S.) subsidizing petroleum production and not renewable energy is one of the biggest source of current world economic, political, and military problems. Of course, lack of checks can also have adverse effects as we’ve just seen with the fancy derivatives the shadow banking system sold in a pyramid scheme throughout the world. It’s like there should be a balance on checks. Which I suppose is Graham’s point: without taking into account the costs of checks (and I would argue also the risks of not having checks), how can you strike such a balance?

He doesn’t neglect to apply his hypothesis to SOX: Continue reading

Loopholes Closed by FTC in CAN-SPAM Act Rules

The U.S. FTC has updated its regulations regarding the CAN-SPAM Act (PDF) to require:
(1) an e-mail recipient cannot be required to pay a fee, provide information other than his or her e-mail address and opt-out preferences, or take any steps other than sending a reply e-mail message or visiting a single Internet Web page to opt out of receiving future e-mail from a sender;

(2) the definition of “sender” was modified to make it easier to determine which of multiple parties advertising in a single e-mail message is responsible for complying with the Act’s opt-out requirements;

(3) a “sender” of commercial e-mail can include an accurately-registered post office box or private mailbox established under United States Postal Service regulations to satisfy the Act’s requirement that a commercial e-mail display a “valid physical postal address”; and

(4) a definition of the term “person” was added to clarify that CAN-SPAM’s obligations are not limited to natural persons.

FTC Approves New Rule Provision Under The CAN-SPAM Act, Press Release, FTC, May 12, 2008

These changes appear to tighten up what is required of marketers; they have to say who they are and they can’t weasel out by claiming a corporation is not a person.

However, it’s not clear to me why it’s opt-out that’s required; why not opt-in? I never trust a spammer to process an opt-out; I assume they’re just collecting more addresses. Plus the spammer still has ten days to process opt-out requests.


Auditing Georgia Government Security

93177422govheadshot3finalpreview.jpg Georgia’s governor wants to standardize information security reporting across the entire state government:
The Executive Order calls for a single set of information security reporting standards for all agencies to follow. Currently, state agencies use a variety of reporting standards, making it difficult to measure information security across state government or to track progress from year to year.

Governor Perdue has directed the Georgia Technology Authority (GTA) to work with the Georgia Department of Audits and Accounts and the Governor’s Office of Planning and Budget to develop a reporting format and required content for agency information security reports. Each agency will be responsible for reporting to GTA at the end of the fiscal year. GTA will compile agency reports into a single Enterprise Information Security Report, available by October 31 of each year.

Gov. Perdue Signs Executive Order Strengthening Georgia’s Information Technology Security, News Report, Government Technology, Mar 20, 2008

I think this is a good move. Now how about monthly reporting in a publicly visible web page.