In June 1953, American cartoonist Walt Kelly wrote about human frailty in the introduction to The Pogo Papers, a compilation of his cartoon strip, Pogo:
There is no need to sally forth, for it remains true that those things which make us human are, curiously enough, always close at hand. Resolve then, that on this very ground, with small flags waving and tinny blasts on tiny trumpets, we shall meet the enemy, and not only may he be ours, he may be us.
Kelly’s words ring especially true today with respect to the murky underworld of cybercrime and insider threats. According to a 2012 financial services sector study by the Software Engineering Institute (SEI), the impact of insider attacks is considerable. Each attack, which, on average, remains undetected for 32 months, costs the victim between $382,750 and $479,000. More frightening still is the fact that over a third of insider attacks target the personally identifiable information (PII) of either employees or customers.
Those facts alone are cause for concern. But it gets worse. The statistics cited above apply only to malicious insiders. Mounting evidence indicates the magnitude of risks realized due to unwitting insider threat actors. Unwitting insider threats are trusted persons who fail to exercise good cyber hygiene. This can range from failing to follow good patch management practices to opening email attachments and clicking on links found in communications from untrusted sources.
The impact of the unwitting insider threat is large. According to a report published by the Ponemon Institute in December 2013, the costs to remediate damage caused by an advanced persistent threat (APT) attack run as high as $18 million ($9.4 million in reputational damage, $3.1 million in lost user productivity, $3 million in lost revenue and business disruption, and $2.5 million in technical support costs). Approximately 50% of known APT attacks are initiated through phishing or spear phishing attacks. Put another way, half of successful APT attacks succeed because of users with poor cyber hygiene habits, or unwitting insider threat actors.
It’s worth noting that these are just the costs that can be quantified economically. The impact to national security of cyber attacks occasioned through the actions of either malicious or unwitting insiders is impossible to fully quantify. Perhaps the words of Executive Order 13526, which describes certain information as being so sensitive that its unauthorized disclosure can reasonably be expected to “cause exceptionally grave damage to the national security,” best illustrates the point.
Despite the prevalence and potential consequences of cyber attacks originating from insider threats, there have been few, if any, regulatory attempts to mitigate the problem within the national security space. Thankfully, that state of affairs is about to change with the upcoming issuance of Conforming Change 2 of the National Industrial Security Program Operating Manual (NISPOM) by the US Department of Defense through the Defense Security Service (DSS). The NISPOM establishes standards, procedures, and requirements for all government contractors who have access to or manage classified information.
Specifically, Conforming Change 2 will require all cleared US government contractors to establish an insider threat program that gathers, integrates, and reports relevant information on insider threat activity in accordance with Executive Order 13587. Additionally, contractors will be required to designate a senior official to manage the insider threat program to ensure that it has the necessary levels of executive authority within the organization.
Conforming Change 2 requires contractors to maintain, and be prepared to provide, records pertinent to insider threat information, including:
- Counterintelligence and security records
- Network data
- Personnel records
Importantly, Conforming Change 2 also requires that contractor personnel be properly trained with respect to insider threats within 30 days of hiring or before being granted access to classified information. The training must cover:
- Counterintelligence and security fundamentals including applicable legal issues
- Procedures for conducting insider threat response actions
- Laws and regulations on gathering, integrating, retaining, safeguarding, and using records and data and on the consequences of misuse of such information
- Legal, civil liberties, and privacy policies
- Detecting and reporting insider threats
Perhaps the most effective component of the change is that contractors will now be required to monitor activity on classified networks to detect insider threat indicators. While implementation details are not specified, monitoring mechanisms must adhere to guidance issued by the Cognizant Security Agency (CSA) and federal systems requirements as specified by FISMA, NIST, CNSS, and others.
Is Conforming Change 2 a silver bullet with respect to the insider threats? No. But it does provide sorely needed regulatory teeth to address a problem that has long plagued both industry and government. And DSS taking steps toward that end is indisputably a good thing.