The Safeguards Rule and its Impact on Financial Institutions
The Standards for Safeguarding Customer Information (Safeguards Rule) requires covered financial companies to develop, implement, and maintain an information security program with administrative, technical, and physical safeguards designed to protect customer information. Additional requirements, related to Section 314.4, are slated to go into effect June 9, 2023. Not all industries, or even all institutions within individual industries, are subject to regulatory compliance. That doesn’t mean, however, that cybersecurity should not be a business priority. More importantly, business leaders must not confuse regulatory compliance with security. While non-compliance by financial institutions can result in fines, the stakes for a proper security program are much higher. Unprepared organizations will become easy targets for cyberattacks. As mentioned in October’s Brainbytes, earlier this year the debt-collection company Professional Finance Company, Inc. reported a data breach which impacted 657 healthcare providers across the U.S., and 1.9 million patient records. Numerous high-profile data breaches and ransomware attacks have cost millions of dollars to American businesses and affected the data of millions of customers. What is PII? In just the past 20 years, national and international data breaches have affected hundreds of millions of individuals. In fact, according to UpGuard, together, 10 of the most impactful data breaches in the United State’s financial service history compromised Personally Identifiable Information (PII) of more than 485 million people and almost 800,000 businesses. The breached data varied by attack, but together included almost a dozen different types. Armed with this information, a wide range of cybercrime is possible, including identity theft, ransomware attacks and malware injection. This makes it crucial to put an appropriate cybersecurity program in place for your business. Again, when developing a program, it’s important to not confuse regulatory compliance with security. In addition to regulatory frameworks, organizations must implement additional cybersecurity systems that specifically address the vulnerabilities facilitating data breaches. The Proper Way to Build a Cybersecurity Program Ensure all of these steps are taken. And then checked, and rechecked. Think of this as the rinse and repeat steps in program development and implementation. The goals of your plan: Company decision makers, especially those with in-house IT department, will likely look to do this internally. And it’s certainly possible. However, compliance is essential, so companies who don’t have dedicated IT personnel or whose IT department lack the experience, training, or manpower to oversee this program need an alternative solution. Staff could do vulnerability scans and a qualified individual (I.e. lower tier cybersecurity personnel) could serve as the CISO. Again, it’s difficult for internal security teams to be vigilant for insider threats because they’re already exceeding their bandwidth with risk management tasks. Is it worth the risk for staff to take on program oversight as well? Learn from the Mistakes of Others Not sure what to include in your plan? Besides implementing a data protection solution specific to financial services, one of the best methods of mitigating data breaches is learning from the mistakes of others. In addition to security, software, and hardware updates, other important lessons to note are: In general, good practices for better security should always include, but are not limited to, the following: Does your company have the right cybersecurity plan in place? Contact us for more information on how our customizable services may help protect your business. Posted by Katie Cassens
Incident Response Plans: A Tool in Your Arsenal Against Cyberattacks
Currently Being Edited – Check Back for Updates! Malware. Ransomware. Phishing. DDoS. Insider Threat. Zero-Day Exploit. The number of cybersecurity attack incidents continues to increase exponentially. During the third quarter of 2022, internet users worldwide saw approximately 15 million data breaches, up 167% compared to the previous quarter. Small to medium-sized businesses were the likely targets, as these companies are three times more likely to be attacked by cyber-criminals than large businesses and corporations. These attacks have the potential for costly disruptions to operations and the loss of critical information and data. A former executive at a U.S.-based manufacturing company hit by a ransomware attack equated it to being “punched in the stomach and losing all the air in your diaphragm, and about four weeks later, learning how to breath again.” The repercussions of an attack on a business can be strong, long-lasting and expensive. A quick and clean resolution is often unrealistic. Authorities discourage businesses from paying a ransom as it can encourage further hacks and enrich cybercriminals. But some companies opt to pay off their attackers to stay in business. In recent cases: Which Response is the Correct Response? The answer lies in the company’s Incident Response Plan. According to DataSure24’s Chief Technology Officer Mark Musone, there is a huge gap in the knowledge of what to do when an intrusion occurs. That’s why it’s important for companies to work with cybersecurity professionals like DataSure24 when developing and implementing an Incident Response Plan. These companies can help ensure you have “all your ducks in a row”. According to the National Institute of Standards and Technology, an Incident Response Plan: 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. An Incident Response Plan should address ALL possible scenarios in response to a successful cyberattack. For example: While it’s impossible to remove all security issues, an effective Incident Response Plan can mitigate the largest cybersecurity threats. Despite another record year of breaches—15 million data breaches between July–September 2022 alone—including Solar Winds, Colonial Pipeline and others, however, half of U.S. businesses still have not put a cybersecurity risk plan in place. Cybersecurity should always be a business priority. Unprepared organizations will become easy targets for cyberattacks. Now is the time to learn the potential cybersecurity risks for your business, and build a complete cybersecurity plan. Does your company have the right cybersecurity plan in place? Contact us for more information on how our customizable services may help protect your business. Posted by Katie Cassens
(The More Things Change), the More They Stay the Same
Over the past two years, companies shifted their business models from survival mode back toward pre-pandemic operations. With the world in constant flux, however, it’s difficult to know exactly what will happen in 2023. Over the past two years, companies shifted their business models from survival mode back toward pre-pandemic operations. With the world in constant flux, however, it’s difficult to know exactly what will happen in 2023. We believe, however, that cybersecurity will become a priority in business operations. After high-profile data breaches at Google, Twitter, Uber, LinkedIn, and Rockstar Games, among others, it seems like no company is immune to cybersecurity attacks. Cyberthieves are getting more sophisticated and cyberthreats are becoming more aggressive every day. Desperate for cash and resources, cyberthieves will continue to target small businesses who often don’t have sufficient cybersecurity systems in place. Don’t be fooled in false confidence, however. High profile businesses, with insufficient or lapses in their cybersecurity systems are also vulnerable. Going into 2023, businesses must take steps to develop security programming or evaluate their existing programming and make necessary changes. So, as you conduct year end analyses, make sure you factor in the state of your business’s cybersecurity programming. If it isn’t already, cyber protection should become a “must-have,” not a “nice-to-have,” component of your business plan. As technology evolves, so does cybersecurity’s ability to protect a business from cybersecurity attacks and threats. Company Leadership is Key In order to build a cybersecurity program, there must be a shift by business leaders, and in some cases, members of the Board of Directors, toward ownership or buy-in of the program. Decision makers must view cybersecurity as central to business operations and evolve and build current and future business models to reflect this. This is vital for a successful program. If members of leadership don’t support cybersecurity practices, there is little to no chance that employees will. Business leaders cannot protect their organization if they don’t know where the security lapses/gaps are and what is needed. It’s normal to compare your business operations with a competitor of similar size, location and assets. When it comes to cybersecurity, however, it’s important to develop and implement a plan based on the company’s individual security needs. Every organization is different, and will have different strengths, weaknesses, gaps, and areas in its cybersecurity programming requiring help. Think of cybersecurity as building a house. You must have a secure foundation in place before you build on top of it. Security should utilize multiple layers of prevention measures to safeguard assets. This includes defining policies and procedures, continuously testing them, educating staff, and measuring effectiveness for improved security operations. Building the correct foundation may mean going back to the basics. Questions to ask yourself: Note: Do NOT confuse regulatory compliance with security. In addition to regulatory frameworks, organizations must implement additional cybersecurity systems that specifically address the vulnerabilities facilitating data breaches. Along with a solid foundation, good policies and procedures help ensure that security programming is not only up-to-date, using the latest technologies where needed, but effective in safeguarding data and minimizing cyberthreats. Make sure those policies and procedures include, among other practices: These regular practices, when built on top of a solid foundation, will make for a strong security program. It all comes back to cybersecurity. The more things change, the more they stay the same. Does your company have the right cybersecurity plan in place? Contact us for more information on how our customizable services may help protect your business. Posted by Katie Cassens
FTC Safeguards Rule
The deadline for complying with the FTC’s Safeguards Rule is June 9. That’s only 4 months away! Get all of your compliance ducks in a row ahead of the deadline: perform a risk assessment now, so you can prioritize the remediation and other requirements well before June 9. DataSure24 provides a variety of FTC compliance services, including: Call us at 716.600.3724 or email info@datasure24.com with any questions and/or to schedule a date and time to talk more about how DataSure24 can help your business comply with the FTC Safeguards Rule. For more on the FTC’s Safeguards Rule, go to DataSure24’s Compliance Page.
NCUA Letter to CUs
Stricter Regulations Impact Cybersecurity Audits
Last week, the Biden Administration released the National Cybersecurity Strategy to better accelerate efforts by the Federal Bureau of Investigation and the Department of Defense (DoD) to disrupt the activities of hackers and ransomware groups around the world. According to the New York Times, for years, the government has pressed companies to voluntarily report intrusions in their systems and regularly patch their programs to fix newly discovered vulnerabilities. But the new National Cybersecurity Strategy concludes that such good-faith efforts are helpful but insufficient in a world of constant attempts by sophisticated hackers. The National Cybersecurity Strategy, along with increased accountability from regulatory bodies, including the DoD, National Credit Union Association (NCUA), and the Federal Trade Commission (FTC), would force companies to implement minimum cybersecurity measures for critical infrastructure. The NCUA, for example, is already conducting stricter audits to ensure regulatory standards by covered entities are met. Effective February 1, 2023, NCUA Examiners will be auditing credit unions using its new Information Security Examination (ISE) procedures, to identify and address information and cybersecurity risks. Requirements are based on credit union size, risk, and level of assets. Those found out of compliance may be penalized and fined. What is a Cybersecurity Audit? There are thousands of questions you could ask your internal team or your vendors about security. Identifying the most important ones will help you use your resources more efficiently and determine when it’s necessary to perform a cybersecurity audit or a cybersecurity assessment. What is the difference between a Cybersecurity Audit and a Cybersecurity Assessment?A cybersecurity audit and a cybersecurity assessment are formal processes, but there are some key distinctions between the two: What are the benefits of a cybersecurity audit?A cybersecurity audit is used to find the presence of cybersecurity controls – such as firewalls and intrusion detection services, as well as physical security controls – and validate that they are working correctly and that compliance requirements are met. Because an audit is conducted by an independent company, it provides customers and business partners with a level of assurance about an organization’s security posture How are Cybersecurity audits like vehicle inspections?Overall maintenance of a business’s cybersecurity program equates to maintenance of a motor vehicle. In this sense, regular cybersecurity assessments can be equated to regular service check-ups. Regular cybersecurity audits can be equated to regular vehicle inspections. Just as a vehicle inspection may help prevent the check engine light from coming on when your car breaks down, a cybersecurity audit will help ensure you have the protections in place if, and when, your systems have a breakdown. And if the NYS DMV, for example, implemented new and/or stricter regulations for state inspections, drivers would ensure compliance with these new and/or stricter regulations, in order to pass inspection, correct? As mentioned in March’s BrainBytes, before you navigate the open road (internet) with your company, have your vehicle (cybersecurity program) inspected. Think of it as being a safe driver and not causing undue harm to those around you (customers, vendors). Identify problems before they occur, and stay safe and secure out there.
Brainbytes
March 2023The words annual check-up or vehicle inspection likely don’t elicit happy feelings. However, most of us recognize it’s just something we have to do. The same can be said for businesses facing regular regulatory audits. Click for the PDF version of March Brainbytes: Cybersecurity Audits and Vehicle Inspections
Your Guide to CMMC Compliance: Key Dates and How to Prepare
The Cybersecurity Maturity Model Certification (CMMC) is transforming the way contractors engage with the Department of Defense (DoD). It’s no longer just about fulfilling contract requirements; CMMC compliance is a critical step toward safeguarding sensitive information and maintaining national security. For businesses, staying ahead of key deadlines and preparing effectively isn’t optional—it’s a must for securing future contracts Let’s break down the critical dates and explore actionable steps to help your organization achieve certification with ease. CMMC 2.0 Certification Timeline: Here’s a breakdown of the timeline and what it means for defense contractors: 1. Phase 1 – Initial Implementation Phase 1 begins in April 2025, when the CMMC Rule becomes effective. During this phase, applicable solicitations will require Level 1 or Level 2 self-assessments to confirm compliance with basic cybersecurity standards. 2. Phase 2 – 12 Months After Phase 1 Start Phase 2 will begin one year after the start of Phase 1, around early to mid-2026. The applicable solicitations will require Level 2 certification conducted by an accredited CMMC Third-Party Assessor Organization (C3PAO). This step introduces a higher level of cybersecurity oversight, ensuring that contractors handling Controlled Unclassified Information (CUI) meet the required standards. 3. Phase 3 – 24 Months After Phase 1 Start Phase 3 will commence one year after Phase 2, around early to mid-2027 and it will focus on solicitations that require Level 3 certification. This level is designed to protect the most sensitive Controlled Unclassified Information (CUI) and involves the most rigorous assessment process. Organizations seeking to participate in these solicitations will need to demonstrate robust cybersecurity practices to safeguard CUI, ensuring compliance with the highest standards. This phase represents a critical step in enhancing security measures, as it builds on the foundation established in earlier phases, addressing the increasing complexity and sensitivity of the data involved. 4. Phase 4 – Full Implementation Full Implementation is set to begin early to mid-2028 which is 36 months after the commencement of Phase 1. During this phase, the full implementation of CMMC requirements will be realized. All solicitations and contracts issued moving forward will include the relevant CMMC level requirements as a condition for contract awards. This marks the transition from preparatory and transitional stages to a comprehensive, organization-wide enforcement of CMMC standards, ensuring that all future contracts are awarded only to entities that meet the necessary cybersecurity maturity levels. How to Prepare for CMMC Certification Preparation for CMMC compliance might seem like a daunting task, but with a clear plan and the right resources, it’s manageable. Here’s how you can take control of the process: 1. Understand Your Required Certification Level Level 1 (Basic Cyber Hygiene): Designed for contractors handling Federal Contract Information (FCI), this level focuses on simple, fundamental practices to safeguard less sensitive data. It includes basic controls to protect networks, devices, and systems from common threats, establishing a baseline level of security. Level 2 (Advanced Cybersecurity): For contractors handling Controlled Unclassified Information (CUI), this level emphasizes more advanced practices to secure critical and sensitive information. It includes enhanced monitoring, access control, and protection against more sophisticated threats. Level 3 (Enhanced Security Practices): Intended for contractors handling classified information or systems, this level requires a robust, multilayered security approach. It involves advanced encryption, regular audits, and strict access controls, ensuring the highest level of protection against targeted cyber threats. 2. Conduct a Gap Analysis Begin by evaluating your current cybersecurity measures against CMMC requirements. This analysis will help pinpoint areas where your organization needs improvement. Identifying these gaps early is key to streamlining your path to compliance. 3. Develop a Plan of Action and Milestones (POA&M) A POA&M is your roadmap to compliance. It outlines the steps your organization needs to take, establishes realistic timelines, and assigns responsibilities. A well-crafted plan ensures you stay on track and avoid last-minute panic. 4.Train Your Team CMMC compliance is a team effort. Your employees must understand their role in protecting sensitive information. Regular training sessions will keep your team informed about compliance practices and cybersecurity protocols. 5.Partner with Experts Compliance doesn’t have to be overwhelming. Partnering with experienced professionals like DataSure24 can make all the difference. From conducting a gap analysis to providing ongoing support, experts can simplify the process and ensure your success. Why CMMC Compliance Matters CMMC compliance isn’t just about meeting DoD requirements; it’s a vital step toward strengthening your organization’s cybersecurity posture. By achieving certification, you: Start Preparing Today Deadlines are fast approaching, but there’s still time to act. Take the first step toward compliance and ensure your business remains competitive in the DoD marketplace. 👉 Schedule a Free Consultation with DataSure24 We’re here to guide you through the entire process, from gap analysis to certification, so you can focus on growing your business without worrying about compliance. Don’t wait for the deadlines to creep up—secure your future today.
Understanding CMMC Scoping: Key to Successful Cybersecurity Compliance
Introduction Achieving Cybersecurity Maturity Model Certification (CMMC) is a critical step for organizations handling sensitive data in the Department of Defense (DoD) supply chain and in maintaining defense contracts. A key aspect of CMMC compliance and certification is understanding the scoping process, which determines the assets and environments that will be subject to assessment. What is CMMC Scoping? CMMC scoping is the process of identifying which systems, processes, and data in your organization are subject to CMMC compliance. Specifically, it focuses on systems handling Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). By properly scoping your environment, you can target the most critical areas and allocate resources where they’re needed most. Why is CMMC Scoping Important? a) Resource EfficiencyScoping ensures that resources are focused on the right areas. By identifying the systems that handle sensitive information, you can avoid wasting time on non-essential components.b) Risk MitigationScoping helps reduce the risk of a data breach by focusing on securing systems that manage sensitive data. It ensures that your cybersecurity efforts are concentrated on the most critical areas.c) Compliance AssuranceScoping ensures that the right systems are assessed for CMMC certification, improving your chances of passing the audit and achieving compliance. Steps for Effective CMMC Scoping Common Scoping Mistakes to Avoid Wrapping Up: The Power of Effective CMMC Scoping CMMC scoping is the foundation of a successful cybersecurity compliance strategy. By carefully identifying critical systems, mapping your environment, and reviewing third-party relationships, you can ensure that the correct scope is applied to your program and the controls you implement. At DataSure24, we guide businesses through every step of the CMMC compliance process, helping you scope your systems efficiently and achieve certification with confidence. Reach out to Datasure24 today and let us help you unlock new opportunities through CMMC compliance.
Understanding HIPAA Compliance in the Healthcare Sector: What You Need to Know
In today’s digital healthcare landscape, safeguarding patient data is a critical responsibility. With the increasing use of electronic records, telemedicine, and interconnected systems, protecting sensitive patient information is more important than ever. This is where HIPAA (Health Insurance Portability and Accountability Act) compliance comes into play. HIPAA ensures that healthcare organizations adhere to strict standards to protect patient data. Here’s a breakdown of what HIPAA compliance involves and why it’s essential. What is HIPAA Compliance? HIPAA is a U.S. federal law designed to protect the privacy and security of health information. It sets standards for healthcare organizations—hospitals, insurance companies, and other entities handling Protected Health Information (PHI)—to ensure that patient data is kept secure and confidential. Key Components of HIPAA Compliance 1. HIPAA Privacy Rule The Privacy Rule sets national standards for the protection of health information. It regulates how PHI can be used or disclosed by healthcare organizations and gives patients the right to access their own health records. 2. HIPAA Security Rule If a breach of unsecured PHI occurs, this rule requires healthcare organizations to notify affected individuals, the Department of Health and Human Services (HHS), and sometimes the media. Prompt notifications are crucial to minimize risks to patient privacy. 4. HIPAA Enforcement Rule This rule outlines procedures for investigating HIPAA violations and the penalties that may result from them. Violations can lead to hefty fines or criminal charges for severe breaches due to negligence or lack of safeguards. 5. HIPAA Omnibus Rule The Omnibus Rule strengthens HIPAA protections by holding business associates (third-party vendors handling PHI) accountable for compliance. Healthcare organizations must have contracts with these associates that enforce HIPAA standards. 6. HIPAA Patient Rights HIPAA grants patients specific rights over their health information, including the right to access and correct their medical records, request disclosures, and request restrictions on how their information is used. Why is HIPAA Compliance Important? Beyond legal obligations, HIPAA compliance is crucial for building patient trust and maintaining organizational integrity. Here’s why it matters: Avoiding Penalties: Non-compliance can result in severe penalties, ranging from fines to criminal charges for negligence. Building Patient Trust: Patients are more likely to seek care and share important information when they know their data is protected. Improving Efficiency: Compliance helps organizations streamline practices for handling PHI and ePHI, improving operational efficiency. How to Achieve and Maintain HIPAA Security Rule Compliance Achieving HIPAA security rule compliance is an ongoing effort. Here’s how healthcare organizations can stay on track: Employee Security Awareness Training: Conduct regular training to ensure staff understands HIPAA regulations and their role in protecting patient data. Risk Assessments: Regularly assess potential vulnerabilities in data handling practices and take action to address any gaps. Encryption and Security: Encrypt ePHI and implement additional security measures like firewalls and secure networks. Document Policies: Maintain clear documentation of compliance policies and procedures for internal consistency and external audits. Breach Response Plan: Develop a plan for responding to potential data breaches to ensure quick action if necessary. DataSure24: Your Partner in HIPAA Compliance At DataSure24, we specialize in helping healthcare organizations meet the HIPAA security rule compliance requirements. Our services include: Developing Security Policies: We help create comprehensive security policies aligned with HIPAA security rule standards. Risk Assessments: We identify vulnerabilities and ensure sensitive data remains secure. Encryption and Security: We implement the latest encryption techniques to protect ePHI. Breach Preparedness and Testing: We assist in developing breach notification plans and response strategies, and testing them through table-top exercises. Employee Security Awareness Training: We offer training programs to ensure your team understands HIPAA regulations and best practices for safeguarding data. Bottom Line HIPAA compliance is not just about avoiding penalties; it’s an essential part of maintaining patient trust, securing sensitive information, and ensuring operational efficiency in healthcare organizations. By understanding the core components of HIPAA and implementing best practices, healthcare organizations can protect their patients and their reputation. Take Action Today Is your organization ready for HIPAA compliance? Review your current practices, conduct risk assessments, and train your team. Partner with DataSure24 to ensure your healthcare organization is fully prepared to meet HIPAA’s requirements.