It’s a New Year and a Good Time for a Cybersecurity Checkup

2021 was a game-changing year in cybersecurity, with high profile vulnerabilities and data breaches, and government and private sector responses to them. Examples include Accellion, SolarWinds, Microsoft Exchange, Kaseya, Colonial Pipeline, and JBS Meat, the May 12, 2021, Executive Order on “Improving the Nation’s Cybersecurity,” and ending with Log4j that has been described as the most serious vulnerability in decades. As we move into 2022, it is a good time for businesses and organizations of all sizes to review their cybersecurity postures in light of these events and the resulting lessons learned. For those that have established cybersecurity programs, it is a good time to review and update them. For those that do not, it is a good time to start the process and follow through to implement a comprehensive cybersecurity program.

Cybersecurity is a process to protect the confidentiality, integrity, and availability of information. Comprehensive security should address people, policies and procedures, and technology. While technology is a critical component of effective security, the other aspects also are critical and should also be addressed.

Cybersecurity is best viewed as a part of the information governance process, which manages documents and data from creation to final disposition. Managing and minimizing data is an essential part of information governance, including security, privacy, and records and information management.

Security starts with an inventory of information assets and data to determine what needs to be protected and then a risk assessment to identify anticipated threats to the assets and data. The next steps are the development, implementation, and maintenance of a comprehensive cybersecurity program to employ reasonable physical, administrative, and technical safeguards to protect against identified risks. A cybersecurity program should cover the core security functions: identify, protect, detect, respond, and recover. Programs covering these elements are frequently required by laws, regulations, and contracts for covered industries, protected information, or both.

Comprehensive cybersecurity programs are often based on standards and frameworks like the National Institute for Standards and Technology (NIST) Framework for Improving Critical Infrastructure Cybersecurity, Version 1.1, (April 2018), more comprehensive standards, including NIST Special Publication 800-53, Revision 5, Security and Privacy Controls for Federal Information Systems and Organizations (September 2020) and standards referenced in it, and the International Organization for Standardization’s (ISO), ISO/IEC 27000 family of standards, (consensus international standards for comprehensive Information Security Management Systems (ISMS)).

These standards can be a challenge for small and mid-size businesses. For them, the Cybersecurity and Infrastructure Security Agency (CISA) maintains a website with Resources for Small and Midsize Businesses and NIST maintains a Small Business Cybersecurity Corner website.

A consideration for the new year should be staying off the cybersecurity “naughty list” by addressing what CISA has identified as Bad Practices for critical infrastructure. They include (1) use of unsupported (or end-of-life) software, (2) use of known/fixed/default passwords and credentials, and (3) use of single-factor authentication for remote or administrative access. They are focused on critical infrastructure and national critical functions and should be considered for others.

Businesses and organizations with cybersecurity programs should periodically review, evaluate, and update their programs. The review and evaluation should address areas like new or changed hardware, software and business processes, changes in personnel or job functions, supply chain changes, lessons from any security incidents, and updated threat information. Those without programs should assign responsibility and adopt a plan and schedule for developing and implementing one.

Training is a critical part of a cybersecurity program. The goal should be to promote constant security awareness, by every user, every day, every time technology is utilized.

If you have questions about the content of this alert, please contact David Ries (dries@clarkhill.com; 412.394.7787), Melissa K. Ventrone (mventrone@clarkhill.com; 312.485.0540), or another member of Clark Hill’s Cybersecurity, Data Protection, and Privacy Group.