The proper perspectives on defending against insider threats
Executive Order 13587, issued by the Obama administration to draw attention to the insider cyber threat problem within federal agencies, set the requirements for programs to protect classified information. In the wake of a series of damaging insider threat incidents, the U.S. government has had no choice but to focus more attention protecting sensitive data.
These policies are a step in the right direction and have generated awareness and a sense of urgency to address insider threats, but it is critical that agencies do not bring a check-box mentality to following these policies. Continuous efforts must be made in order for agencies and contractors to successfully detect, prevent and mitigate insider threats.
It is unlikely that agencies are overrun with insider actors, but following a series of high profile insider threat-related breaches, enhancing insider threat-readiness is a top priority for an agency’s cyber posture. Accountability and deliverables have been outlined in several executive orders from NISPOM (the National Industrial Security Policy Operating Manual) to the National Insider Threat Policy. These policies have been enacted to strengthen the protection and safeguarding of classified information by establishing common expectations, institutionalizing best practices and enabling flexible implementation. As a result, agencies are investing significant resources to address insider threats and ensure compliance with these new regulations.
NISPOM conforming change #2 is particularly noteworthy, and incorporates minimum standards for insider threat and cyber intrusion reporting. It required that contractors with classified programs implement insider threat programs by Nov. 30, 2016 – recognizing the potential vulnerabilities of private companies supporting agency missions. One key requirement for contractors to pay attention to is to monitor employees for insider threat activities using the following tactics:
- Monitor the classified network: This requirement does not extend to the unclassified networks, but organizations should examine the advantages of implementing similar monitoring on the major egress point available to employees.
- Protect the monitoring methods and the resulting audit data: The information technology branch of the company will need to be involved in deploying the monitoring solution, but organizations should take extreme care to protect the specific auditing and monitoring rules from those who do not have a legitimate need-to-know. And when it comes to access to the collected data, we have seen companies subject the analysts to additional vetting and sometimes require a specific non-disclosure agreement be executed.
- User agreements: The acceptable use policy should highlight the fact that employee activities on the classified networks is subject to monitoring and that the employee is consenting to that monitoring as a condition of access. The contents of the acceptable use policy should be a component of the awareness training that is also required by the change.
- Login banner: The acceptable use policy informs the employee of the user activity monitoring when they are granted access to the network, but the login banner serves as a daily reminder of the asserted right to monitor by the employer and the consent the employee has given. The login banner and the acceptable use policy should be reviewed by legal counsel; we’ve seen the Department of Defense take months to review every word, comma and semicolon in its banners. It’s important to get this right.
Since 2012, more than 20 government agencies have suffered some form of significant data compromise or breach (10 breaches were reported in 2014 alone). These breach events have dramatically changed the policy landscape as a result. The recent policy changes and technical/programmatic directives underscore the importance of effective holistic solutions to insider threats. In order to make these initiatives successful, however, both agencies and contractors must take meaningful steps toward an effective, long-term, insider threat-protected cybersecurity posture. Following the minimal compliance requirements to check the box will not be enough to ensure an organization and its data are protected.
It is important to reemphasize that there is no silver bullet for deterring, detecting and defeating insider threats, but proven technical solutions exist and must be implemented. These policies offer the roadmap to an aggressive cyber posture that will safeguard sensitive unclassified and classified data.
Without an active insider threat program, agencies cannot rest on their laurels. Consider the damage that has already occurred as a result of weak policies and inadequate, poorly-funded technical programs. The proven technology exists; it is time to recognize the imminent threat of insider actors and move beyond basic compliance. NISPOM is a great start, but evolving at the speed of insiders in the fast-moving world of cyber threats means much work remains to be done.
Dan Velez, CISSP, is the director of insider threat operations at Forcepoint,and is responsible for the delivery and support of insider threat monitoring, investigation solutions and related services.