Corporate custodians of confidential medical data should be closely monitoring events connected to a nightmarish computer security breach in the St. Louis region.

Express Scripts is one of the nation’s largest pharmacy benefits managers. The company, with headquarters in St. Louis County, handles approximately 500 million prescriptions per year for 50 million workers at 1,600 American companies. Early in October, it received an extortion letter, the details of which it released on Nov. 6.

The letter included personal information on about 75 Express Scripts clients — Social Security numbers, dates of birth and, in some cases, information about prescription medications. Whoever sent the letter demanded money from the company — the amount has not been disclosed — and threatened to use the Internet to reveal personal and medical information about millions of people if the demands were not met.

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Beyond the scale of the problem for Express Scripts — and the potential impact on the company is enormous — the issue extends well beyond the mounting concerns about identity theft, a phenomenon with which most people have become at least somewhat familiar.

The greater problem is the unique nature of personal medical records, the importance of moving to computerization of such records to improve health safety and reduce costs and the irreversibility of the damage people can suffer if confidential medical information becomes public. The stakes are so high that a federal law establishes strict standards for maintaining the privacy of medical information and stiff fines for failing to do so.

Medical records of all kinds — paper and, especially, electronic — must be protected with the most sophisticated kinds of security systems available, including backup protections and automatic alerts of security violations. Yet Express Scripts learned of this breach in the “worst way,” as InformationWeek.com security correspondent George Hulme put it in an online report: “via an extortion letter.”

The Express Scripts breach raises many questions for all elements of the health industry: hospitals, clinics and doctors’ practices, benefits management firms, insurance companies, pharmacies, employers and government agencies:
Are they using the most advanced information security technology possible? Do they minimize the amount of data they collect and keep it only as long as necessary? Do they have strict protocols governing access to personal and medical data — and systems to enforce those protocols? If criminals were to hack into their systems, how would the companies know? How soon? And are the systems capable of instantly cutting off illegal access as soon as a breach is discovered?

Confronted with a grave breach of electronic security, Express Scripts has responded by contacting law enforcement, establishing an informational website, offering a substantial reward and hiring a private consulting firm to help clients who have privacy concerns and investigate situations that “appear to be tied to identity theft” and provide “identity restoration services.” There is no question that the company is taking the situation extremely seriously.
Given the ongoing criminal situation, information about how Express Scripts’ data systems were compromised — and whether it could have been avoided — has yet to be disclosed. But the American people have the right to expect that their sensitive personal and medical information is zealously protected and kept secure — not only by Express Scripts but also by every person or company entrusted with it.

"Customers and customer relationships...have tangible measurable value to businesses, and their value is much easier to communicate to those who fund projects. So in an enterprise risk management scenartio, their vlaue informs the risk management process...[For example, consider] a farmer deciding which crop to grow. A farmer interested in short term profits may grow the same high yield crop every year, but over time this would burn the fields out. The long term focused farmer would rotate the crops and invest in things that build the value of the farm and soil over time. Investing in security on behalf of your customers is like this. The investment made in securing your customer's data build current and future value for them. Measuring the value of the customer and relationships helps to target where to allocate security resources."

He makes the argument that the Digital Theft Deterrence and Copyright Damages Improvement Act of 1999 is very much unconstitutional, in that its hefty fines for copyright infringement (misleadingly called "theft" in the title of the bill) show that the bill is effectively a criminal statute, yet for a civil crime. That's because it really focuses on punitive damages, rather than making private parties whole again. Even worse, it puts the act of enforcing the criminal statute in the hands of a private body (the RIAA) who uses it for profit motive in being able to get hefty fines.

Imagine a statute which, in the name of deterrence, provides for a $750 fine for each mile-per-hour that a driver exceeds the speed limit, with the fine escalating to $150,000 per mile over the limit if the driver knew he or she was speeding. Imagine that the fines are not publicized, and most drivers do not know they exist. Imagine that enforcement of the fines is put in the hands of a private, self-interested police force, that has no political accountability, that can pursue any defendant it chooses at its own whim, that can accept or reject payoffs in exchange for not prosecuting the tickets, and that pockets for itself all payoffs and fines. Imagine that a significant percentage of these fines were never contested, regardless of whether they had merit, because the individuals being fined have limited financial resources and little idea of whether they can prevail in front of an objective judicial body.

Another news story.

After Interop Las Vegas you may have seen our analysis of the data that we collected and delivered in our NOC view.  I thought I’d recreate the same data for NY and do a short comparison.

1) Like in Vegas, uptime for the network 100%.  This is no small feat considering that we introduced a new wrinkle in NY, taking down the primary NOC while the education portion of the show was still going on.  This was a forced failover to the backup systems, and it went flawlessly.  I’d like to give a little credit to EM7 on the 100% uptime as it caught a failover to battery power that allowed AC to be restored before a series of critical equipment would have gone down.

2) Again like Vegas, the average monitored device in the show network didn’t even hit 10% CPU utilization.  Still lots of computing overhead availabe in the show network.

3) The NY show network wasn’t nearly as busy as in Las Vegas, sustaining an average of only 27Mbps of usage (versus 56 Mbps) in Vegas.

4) Power consumption for the network and NOC in NY clocked in at 445kwh per day, about 25% less than the Las Vegas show.  This wasn’t because the equipment was any more power efficient, but instead because the show was smaller and therefore there was less network gear.

5) Finally, a stat we didn’t track too carefully in Las Vegas, but that I find interesting.  During show hours the wireless network average 1,100 users attached.  That’s a lot of people and a lot of wireless devices.

The good news is there was nothing too unexpected in the data, overall the smaller show led to a smaller number of tickets and smaller consumption of resources across the board.  We hope to have the opportunity to work with the InteropNet team again next year and take a look at this data year-over-year for each show.

The analysts paired up today:
Antonio Piraino (Tier1 Research)
William Fellows (The 451 Group)

My usual disclaimers on live-blogging: doesn’t include everything covered (just what was most interesting to me) and had to paraphrase some answers because I simply cannot type that fast.

Quick definition of Cloud Computing
WF: The cloud is a continuum of grid, virtualization and utility done right. It is about provisioning services instead of servers; flexible computing instead of fixed assets. Done right, the cloud abstracts users from the complexity of grid. Cloud computing is IT as a service. Cloud computing is the Third Way – not entirely in-house or outsourced, but an optimized hybridized version of both. In light of the Goldman Sachs report out resetting IT spending forecast from up 6% to down 1%, don’t underestimate the ability for enterprises to move from capex to opex by buying cloud computing instead of building it themselves.

The 451 Group conducted a survey on cloud computing in March, and then revisited it a month ago. Some interesting results:

• 84% have no plans to develop an internal cloud. 5% had no answer to this question. And for the 10% who did answer – the uses for a private/internal cloud were the same as those for a public cloud.
• Top 6 vendors they look to help them develop an internal cloud: Microsoft, IBM, Cisco, HP, Oracle, VMware

Is it all “upside” when it comes to cloud computing?

WF: Watch out for the Trojan horse, the red flag. What about the software needed to manage all this stuff? Any management software needs to take a holistic approach to solve the problem.

AP: Increased management requirements and capability – this is actually a great story for managed hosters who can hold your hand while getting you up into the cloud. Hosters alleviate the pain points, and this is why we’re going to see continued growth and focus in the managed hosting sector.

WF: I would argue that they’re too expensive. Look at Amazon – 10 cents a hit adds up.

AP: It’s almost impossible to do an apples-to-apples comparison between cloud providers. One reason is that they charge differently. I’d say that when you’re talking about the big cloud providers, you are right – that they are expensive over the long-term, but for use in the short-term, they can be optimal.

WF: The cloud is setting big expectations. Can IT deliver? It’s nice to talk about “shared resources for the greater good” but in any organization, you will still run into issues of power and control! Plus it’s still early days for resolution of regulatory issues and compliance around the cloud.

Final Thoughts

AP: Think of the opportunities of using cloud computing resources in the areas of testing and pre-production – short-term use/environment (quick up/quick down), inexpensive, opex not capex. We’re already seeing the cloud fostering much innovation.

WF: “It’s okay to fall in love with the term.” It is real but keep the expectations lower and realistic.

AP: I agree with you. The reality is that the cloud is driving a very fundamental underlying platform change. This is not just a term or something that will fall out of fashion. There’s a real need to build trust in the cloud and leveraging shared resources in this way – so use the cloud computing term cautiously; don’t abuse it and make the cloud seem like IT’s new toy.

I’ve often read people who say that we (security, risk management) need to “think like the attacker”.  And when you read this sort of article, that usually alludes to trying to anticipate the tactics an attacker might use to mess with your C, I, or A.  Smart stuff, that, and very useful when architecting security solutions.  But as I was training some folks Monday, I was thinking in the back of my head about Threat Capability (TCap) in FAIR.  As you might know, we like to estimate the capability of a threat to apply some level of “force” against our assets.  This ability to apply force is a byproduct of the attacker’s skills and resources.  And thinking of how an attacker applies skills and resources, I came across another way we might “think” like an attacker.

Traditionally, I’ve thought of “skills” as being a byproduct of the toolset an attacker has.  This mindset probably stems from my time with Penetration Testing teams, where in the process of scoping the  PenTest I would ask our clients to select the level of effort that they wanted us to throw at them.  If a client chose “high” we’d throw every ‘spoit we had at them.  If they chose “low” we’d limit ourselves to a more commonly available toolset.

But while the resources part of TCap is time & materials (money) - the skills are really more than just the toolset.  Skills would include the ability of the attacker to be creative and innovative.    As an example of that innovation from those PenTesting days - when we got a “high” effort request, we would always try to couple that with some “social engineering”-type of attack, or some unique means of delivering an existing exploit.  Our creativity was not necessarily a byproduct of a unique exploit or tool we had, but the process by which we might deliver pre-existing or commonly available exploits.  I remember when we first got ahold of a handful of 32mb thumb drives (hey, 32mb was huge back then) and “dropped” a few in the lobby of a client’s retail space.  The keystroke loggers and phone-home script weren’t new, but using the thumb drive as delivery vehicle certainly was.

So I’ve started to really think about this concept of innovation, and how if “thinking like an attacker” means to be innovative, we ought to do the same.  I’ve been thinking of two main categories of innovation this morning.

INNOVATION

The first I’ll call Technology Innovation.  And by Technology Innovation, I mean some new, unique, “ahead of the curve” technology that an attacker can use against us.  The obvious example of which is a zero-day.  It’s that “high” tool set our PenTesters would use against the clients.  For security departments, this might be the latest security product designed to enhance our ability to P, D, and/or R.

Alternately, we can be creative in the way we deliver (manage) existing technology.  I think of this as Process Innovation.  It’s doing more with what we already have, just like the PenTest team would be creative in the delivery of an existing exploit.

Unfortunately for us - attackers have traditionally had quite a leg up on us in terms of Process Innovation.  It is much easier fro them to be creative, as they are free of political constraints and bureaucracy.  In contrast, when the security industry tries Process Innovation, the results are checklists and “standards”.  It’s committees and consensus.  An extreme example of which might be something like SABSA - a great work if you want to understand some very smart people’s comprehensive understanding of organizational security  - but the “adoption”of which will do very little to help you be innovative in P/D/R.

It’s worth noting that ultimately, this is one reason I don’t like regulatory compliance efforts - they simply serve to prove how mundane your security department is,  wasting valuable resources that could be spent on creating ways to be more effective.

PROCESS INNOVATION AS A SUBSTITUTE FOR TECHNOLOGY INNOVATION

As we come to the close of 2009, some surveys suggest that security spending isn’t horribly impacted yet by the economy (the latest from E&Y points to only 5% of their respondents getting budget cuts).  But if this is a protracted downturn, and because InfoSec is an operational expense, I would expect cash to become more and more difficult to keep.  And regardless if technology spends do slow, I believe it makes sense to think about Process Innovation because I see Process Innovation as a means to increase effectiveness without significant capital expenditures (effectiveness increases because our ability to manage risk has a direct correlation to the amount of risk we have).

The bad news is, of course, that great innovation is hard.  It is R & D.  Failure is usually a pre-requisite to success.

The good news is, our current state is so bad that many of us don’t need to come up with a whizbang new way of reducing software defects in the SDLC as innovation.  Simply inserting a risk analyst into the PMO’s processes might count as a big enough victory. Be cautioned, though,  that if we’re substituting the risk reductions provided by technology acquisition - Process Innovation might actually be even more “expensive” as it requires us to expend political capital.   But there are (forgive the term) innovative ways to spend this political capital.

For example, by taking a second now and figuring out the 3 things that the rest of the organization can do to make your life easier, when that “I need to reduce your budget” talk comes, you can be prepared to negotiate.  Get a political capital “loan” or “investment” from the C-Suite reducing your budget.  Something to the effect of: “I expected this, and am happy to give up my budget.  But if our tolerance for risk hasn’t changed, what I’d like to do is get you to personally back my office on three projects I’ve identified that can reduce our risk without requiring significant capital expenditure.”

After meetings and calls, I was finally able to slip into a conference session – just in time to catch uber-smart analysts Rachel Chalmers (The 451 Group) and Dan Golding (Tier1 Research) engage in a lively and not-so-mock debate on “Hosting Meets the Cloud”.

Now this doesn’t cover the entire debate – and part II is coming tomorrow. But what it does cover is the most interesting questions (to me) and paraphrase the points made by the analysts. I thought they both had very interesting points and more similarities than differences in the end; the real difference is how they thought about the issues and through what lens – for Rachel it was the enterprise and for Dan it was managed hosting providers. (image from inmagine)

Question: What is a cloud and why?

Dan: Shared infrastructure leveraged/run by third parties for the benefit of enterprises, developers, etc. This is not a new idea – just recently “rebranded.” Given all the discussion and disagreement over this now, what will the cloud end up looking like?

Rachel: The cloud is “IT infrastructure as a service” down to the level of a server operating system. Take the example of Amazon web services – in this case it’s not just the infrastructure but also the internal processes built around service delivery, e.g., provisioning, that are being exposed as a commodity to external customers.

Dan’s Question for Rachel: In your opinion, how much is the cloud a fad versus CIOs really trying to solve a problem?

Rachel: For the practical, roll-up-your-sleeves types of CIOs – those coming up from the engineering ranks – that I talk to, the cloud is real, as opposed to SOA and middleware.

What about “internal” cloud computing – built and maintained by an enterprise versus a third-party provider?

Dan: Cloud computing is done by providers for customers. Certainly there are enterprises that have made internal computing investments, e.g., for publishing, large-scale phone systems, etc - but they were stupid ideas made by companies that have too much money. A better question here is does it make any sense for an enterprise to create their own cloud? While an enterprise can play at it, they can’t do it cost-effectively, not in a way that a third party provider can do it.

Rachel: Many CIOs have “managed-hoster” envy – for things like chargeback and billing that hosters understand a do better. Of course there has been a rise in automation and virtualization tools in the enterprise which may not be as efficient and built for scalability as a hoster can achieve, but what is important is that they are customized/specialized for that business.

Dan: Can you give a specific example of optimization to make it worthwhile for enterprises to do it themselves?

Rachel: One example is sovereignty. The privacy laws around financial and healthcare information are not the same everywhere. Clouds and their geographically-dispersed data centers don’t necessarily have “national” borders. This is definitely a concern for the CIO that has to comply with regulations in their industry around privacy protection, for instance. Another example is security. Dow Chemical does a lot of work via joint ventures and has a need to provide but lock down desktops given to contractors as corporate workspaces. For their level of security, they need to “own” their computing resources.

Dan: But why can’t someone like SunGard provide that as they do for many other large companies?

Rachel: It comes down to a question of trust.

Do people trust their hosting providers?

Dan: Yes. Whether it’s for a content delivery network or collocation, hosting the customers of hosting providers are some of the largest companies in the world in industries like energy and financial services. Give me a case when there was a major security issue with a hosting company. In fact, managed hosting providers usually provide better security than enterprises are capable of.

And a question provided by an attendee from EMC: A few years ago, this would have been a grid discussion. How is the cloud different?

Rachel: Grid computing ended up being applicable only for niches – which I predicted. The real opportunity for everyone else with the cloud only comes up when you combine the kinds of automation tools (originally developed for grid computing) with x86 virtualization.

Dan: I agree. Grid was a niche play. There were very few orgs that needed it and that the economics worked for. There were very few enterprises for whom it made sense to build their own for. The cloud is shared/leveraged versus grid computing. It economically makes sense in a way grid never did.

Things are so bad in China that its gross domestic product growth rate may fall from double digits to the dowdy level of 8%. Eight percent, by the way, is a level at which the United States is unlikely to ever grow again. It can't. Our economy is simply fully developed. Thus the sobriquet "developed economy." I know, not exactly catchy.

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All of the headlines show China sitting at a crossroads. But the reason I have faith in China is that it has historical proxies. Since 1970, with the exception of a few OPEC members, only four economies have made the transition from emerging to developed markets (meaning their per-capita incomes exceed $15,000 per year): Taiwan, Singapore, Hong Kong, and South Korea.

These four economies have two things in common. First, they have few natural resources; and second, they are dominated by Chinese values and the traditional Chinese work ethic. Mainland China is different only because it got a later start.

“When I wrote the book, I thought I was writing about the future. When it was going to press, I thought it was about current affairs. Now I wish it was about history.”

This part below reminds me a lot of 1995 security architectures used to defend 2008 integrated applications

The present crisis had been triggered because the international financial system had undertaken activities that had “far outpaced the ability of the infrastructure to sustain them”, said El-Erian.

And it was not just the markets that could not cope with their own changes, but governments as well. Significant weaknesses had been exposed “from the firms, to the regulatory agencies, to governments, to multilateral oversight”.

“Turbocharge that with financial innovations, which history tells us we tend to overproduce and overconsume, and it’s inevitable that you will get a series of market accidents,” he said.