security – Page 6 – Bredemarket

On the RIBridges Benefits System Hack

I originally worked with state benefits systems during my years at Printrak, and have performed analysis of such systems at Bredemarket. These systems store sensitive personal data of many Americans, including myself. And they are therefore a target for hackers.

The hack at RIBridges

A huge benefits system was hacked in Rhode Island, according to the State.

“On December 5, the State was informed by its vendor, Deloitte, that the RIBridges data system was the target of a potential cyberattack….”

That was just the beginning.

“On December 10, the State received confirmation from Deloitte that there had been a breach of the RIBridges system based on a screenshot of file folders sent by the hacker to Deloitte. On December 11, Deloitte confirmed that there is a high probability that the implicated folders contain personally identifiable information from RIBridges. On December 13, Deloitte confirmed there was malicious code present in the system, and the State directed Deloitte to shut RIBridges down to remediate the threat.”

RIBridges is…um…a bridge from Rhode Island residents to various Federally sponsored but State administered benefits programs, including:

Medicaid,
Supplemental Nutrition Assistance Program (SNAP),
Temporary Assistance for Needy Families (TANF),
Child Care Assistance Program (CCAP),
Health coverage purchased through HealthSource RI
Rhode Island Works (RIW),
Long-Term Services and Supports (LTSS), and
General Public Assistance (GPA) Program

State benefits systems such as RIBridges are complex and often hosted on old infrastructure that requires modernization. (“Modernization” is a great buzzword to use to toss around when describing aging state computer systems, as I know from my years working with driver’s license and biometric identification systems.) The older and more complex the system, the easier to hack.

The history of RIBridges

This complexity is certainly true of Deloitte’s hacked RIBridges system.

As StateScoop noted in 2021:

“Gov. Daniel McKee…said the state will pay the firm $99 million over the next three years to manage and build out the RIBridges computer system….The firm has been developing the software, which handles the state’s Medicaid, SNAP and other welfare programs, since 2016, though delays and errors during (previous Governor) Raimondo’s administration caused the state to overspend by at least $150 million as of 2019, the last time the state renewed Deloitte’s contract.”

Why is Deloitte’s performance less than ideal? Anthony Kimerv of Biometric Update explains the issues facing RIBridges.

“Federal agencies, including the federal Centers for Medicare and Medicaid Services, had warned Rhode Island before the system’s launch that it was not ready for deployment….RIBridges proceeded despite clear operational risks, leading to immediate and widespread problems. The launch resulted in significant disruptions to benefits distribution, with thousands of residents experiencing delays in receiving critical assistance. Backlogs soared, with more than 20,000 cases piling up due to system malfunctions.”

After much time and effort the backlogs decreased, but the treasure trove of personally identifiable information (PII) remained a target.

“As a central repository for sensitive personal data, including financial information and health records, RIBridges became a potential target for cyberattacks. Security audits revealed vulnerabilities in the system’s defenses….Cybercriminals exploited weaknesses in RIBridges to access sensitive data. The attackers bypassed existing security measures, inserted malicious code, and obtained unauthorized access. The breach exposed flaws in the system’s technical defenses and highlighted issues with its oversight and vendor management.”

The consequences for RIBridges applicants

So now the system is down, applicants are using paper forms, and a cyber criminal is requesting a payout.

(Image by Google Gemini)

Delivery Packages and Geolocation in Residential Neighborhoods

Today’s musings concern delivery packages and geolocation, and may be pertinent if you receive a residential delivery this month. You know, maybe a present or something.

Let’s say you receive a package at your house, the delivery driver takes a picture of your package on your porch as proof of delivery…and the package is subsequently stolen by a porch pirate before you get it.

“Hey, you’re out of luck,” the company may say. “The package was delivered.”

How long will it be until security professionals advise you to NEVER EVER EVER HAVE RETAILERS DELIVER PACKAGES TO YOUR HOME? Use a locker or a staffed business address, but treat residential delivery as EVIL…just like public wi-fi.

Or perhaps expensive packages could be equipped with geotagging…like your luggage. I know that delivery companies hate geolocation as much as airlines do…but it’s a thought.

(Thanks to the anonymous victim of a porch pirate who inspired this. AI-generated image by Google Gemini.)

Insecurity, For Reel

Insecurity

I didn’t write this. Google Gemini wrote this. (And created the image.)

“In essence, identity is the foundation upon which security is built. A strong, well-managed identity infrastructure is essential for protecting digital assets and preventing unauthorized access. By understanding the overlaps between identity and security, organizations can implement robust security measures that safeguard both their digital assets and the privacy of their users.”

So now take a moment and think about security WITHOUT identity.

And shudder.

Secure is a Verb

How can you anticipate the unexpected?

Such as a plane that isn’t in the sky, but lodged in a skyscraper?
Or a pressure cooker that isn’t inside in a kitchen, but outside in a backpack?
Or an illness that suddenly appears when no such illness previously existed?
Or something that mimics a bodily illness, such as a computer virus or denial of service attack?

To anticipate the unexpected, you need to plan beforehand, assess during, and quickly correct afterwards.

What is on tomorrow’s calendar? And why are you pushing it out to next year?

Treat “secure” as a verb, not an adjective. A critically important verb.

The Single Solution Microsoft E5 License vs. Best-in-class Individual Solutions

The phrase of the day is “Microsoft E5 License.”

Identity Jedi used is in the 82nd edition of his newsletter.

The biggest threat to every single vendor in the identity space right now are the following words: Microsoft E5 License.

If you read that and shuddered, I’m sorry.

The argument for a single solution

From https://www.microsoft.com/en-us/microsoft-365/enterprise/e5.

Sounds scary. But isn’t Microsoft here to help? Threatscape makes the case.

The cohesive suite of security and productivity solutions provided by an E5 licence can significantly streamline your technological landscape, doing away with a number of on-premises and SaaS tools.

While many organisations opt for the lower-cost E3 licence, they may find this soon requires a supplementary selection of single-solution tools from alternate vendors to patch gaps in its capabilities.

Too many solutions means confusion, an often-disjointed workflow, potential overlap and overspend, and crucially, increased security risk.

By consolidating your collaboration, productivity, automation, and security solutions into a single trusted vendor platform, IT management becomes simplified, redundant solutions can be axed, and ROI can be better measured.

The Microsoft E5 Security Components

So you get everything from a single source with no finger pointing. What could go wrong?

Plenty, according to those who still think of Microsoft as an evil empire.

By Lucasfilm – Star Wars Episode VI: Return of the Jedi, Fair use, https://en.wikipedia.org/w/index.php?curid=38430548.

Let’s return to the Identity Jedi.

Microsoft is making a compelling case to businesses to consolidate into the Microsoft umbrella of products. The ease of use, and financial motives just make too much sense. Now do those customers get a great IAM experience with that? Meh…kinda. Entra SSO is solid product, Active Directory/EntraID is solid, MIM…well….we don’t talk about MIM.

Microsoft Identity Manager

Well, I will talk about MIM, or Microsoft Identity Manager.

Actually, we’re talking about Microsoft Identity Manager 2016.

Microsoft Identity Manager (MIM) 2016 builds on the identity and access management capabilities of Forefront Identity Manager (FIM) 2010 and predecessor technologies. MIM provides integration with heterogeneous platforms across the datacenter, including on-premises HR systems, directories, and databases.

MIM augments Microsoft Entra cloud-hosted services by enabling the organization to have the right users in Active Directory for on-premises apps. Microsoft Entra Connect can then make available in Microsoft Entra ID for Microsoft 365 and cloud-hosted apps

Is it any good? Sources say that, from a quantitative perspective, Gartner Peer Insights ranks several products higher than MIM’s 4.3 rating, including:

Okta Advanced Server Access (4.4)
Ivanti Security Controls (4.5)
One Identity Active Roles (4.7)
Imprivata’s SecureLink Customer Connect (4.8)
Bravura Safe (5.0, 1 rating)

The argument against a single solution

But what of the argument that it’s better to get everything from one vendor? Other companies will tout their best-in-class products. While you’ll end up with a possibly disjointed solution, the work will get done more accurately.

In the end, it’s up to you. Do you want a single solution that is “good enough” and is already pre-made, or do you want to take the best solution from the best-in-class vendors and roll your own?

Authenticator Assurance Levels (AALs) and Digital Identity

(Part of the biometric product marketing expert series)

Back in December 2020, I dove into identity assurance levels (IALs) and digital identity, subsequently specifying the difference between identity assurance levels 2 and 3. These IALs are defined in section 4 of NIST Special Publication 800-63A, Digital Identity Guidelines, Enrollment and Identity Proofing Requirements.

It’s past time for me to move ahead to authenticator assurance levels (AALs).

Where are authenticator assurance levels defined?

Authenticator assurance levels are defined in section 4 of NIST Special Publication 800-63B, Digital Identity Guidelines, Authentication and Lifecycle Management. As with IALs, the AALs progress to higher levels of assurance.

AAL1 (some confidence). AAL1, in the words of NIST, “provides some assurance.” Single-factor authentication is OK, but multi-factor authentication can be used also. All sorts of authentication methods, including knowledge-based authentication, satisfy the requirements of AAL1. In short, AAL1 isn’t exactly a “nothingburger” as I characterized IAL1, but AAL1 doesn’t provide a ton of assurance.
AAL2 (high confidence). AAL2 increases the assurance by requiring “two distinct authentication factors,” not just one. There are specific requirements regarding the authentication factors you can use. And the security must conform to the “moderate” security level, such as the moderate security level in FedRAMP. So AAL2 is satisfactory for a lot of organizations…but not all of them.
AAL3 (very high confidence). AAL3 is the highest authenticator assurance level. It “is based on proof of possession of a key through a cryptographic protocol.” Of course, two distinct authentication factors are required, including “a hardware-based authenticator and an authenticator that provides verifier impersonation resistance — the same device MAY fulfill both these requirements.”

This is of course a very high overview, and there are a lot of…um…minutiae that go into each of these definitions. If you’re interested in that further detail, please read section 4 of NIST Special Publication 800-63B for yourself.

Which authenticator assurance level should you use?

NIST has provided a handy dandy AAL decision flowchart in section 6.2 of NIST Special Publication 800-63-3, similar to the IAL decision flowchart in section 6.1 that I reproduced earlier. If you go through the flowchart, you can decide whether you need AAL1, AAL2, or the very high AAL3.

The AAL CYOA from https://pages.nist.gov/800-63-3/sp800-63-3.html#63Sec6-Figure2.

One of the key questions is the question flagged as 2, “Are you making personal data accessible?” The answer to this question in the flowchart moves you between AAL2 (if personal data is made accessible) and AAL1 (if it isn’t).

So what?

Do the different authenticator assurance levels provide any true benefits, or are they just items in a government agency’s technical check-off list?

Perhaps the better question to ask is this: what happens if the WRONG person obtains access to the data?

Could the fraudster cause financial loss to a government agency?
Threaten personal safety?
Commit civil or criminal violations?
Or, most frightening to agency heads who could be fired at any time, could the fraudster damage an agency’s reputation?

If some or all of these are true, then a high authenticator assurance level is VERY beneficial.

A Few Thoughts on FedRAMP

The 438 U.S. federal agencies (as of today) probably have over 439 different security requirements. When you add state and local agencies to the list, security compliance becomes a mind-numbing exercise.

For example, the U.S. Federal Bureau of Investigation has its Criminal Justice Information Systems Security Policy (version 5.9 is here). This not only applies to the FBI, but to any government agency or private organization that interfaces to the relevant FBI systems.
Similarly, the U.S. Department of Health and Human Services has its Health Insurance Portability and Accountability Act (HIPAA) Security Rule. Again, this also applies to private organizations.

But I don’t care about those. (Actually I do, but for the next few minutes I don’t.) Instead, let’s talk FedRAMP.

Why do we have FedRAMP?

The two standards that I mentioned above apply to particular government agencies. Sometimes, however, the federal government attempts to create a standard that applies to ALL federal agencies (and other relevant bodies). You can say that Login.gov is an example of this, although a certain company (I won’t name the company, but it likes to ID me) repeatedly emphasizes that Login.gov is not IAL2 compliant.

But forget about that. Let’s concentrate on FedRAMP.

From https://www.informationweek.com/machine-learning-ai/how-fedramp-can-accelerate-cloud-adoption.

Why do we have FedRAMP?

The Federal Risk and Authorization Management Program (FedRAMP^®) was established in 2011 to provide a cost-effective, risk-based approach for the adoption and use of cloud services by the federal government. FedRAMP empowers agencies to use modern cloud technologies, with an emphasis on security and protection of federal information. In December 2022, the FedRAMP Authorization Act was signed as part of the FY23 National Defense Authorization Act (NDAA). The Act codifies the FedRAMP program as the authoritative standardized approach to security assessment and authorization for cloud computing products and services that process unclassified federal information.
From https://www.fedramp.gov/program-basics/.

Note the critical word “unclassified.” So FedRAMP doesn’t cover EVERYTHING. But it does cover enough to allow federal agencies to move away from huge on-premise server rooms and enjoy the same SaaS advantages that private entities enjoy.

From https://marketplace.fedramp.gov/products.

Today, government agencies can now consult a FedRAMP Marketplace that lists FedRAMP offerings the agencies can use for their cloud implementations.

A FedRAMP authorized product example

When I helped MorphoTrak propose its first cloud-based automated biometric identification solutions, our first customers were state and local agencies. To propose those first solutions, MorphoTrak partnered with Microsoft and used its Azure Government cloud. While those first implementations were not federal and did not require FedRAMP authorization, MorphoTrak’s successor IDEMIA clearly has an interest in providing federal non-classified cloud solutions.

When IDEMIA proposes federal solutions that require cloud storage, it can choose to use Microsoft Azure Government, which is now FedRAMP authorized.

From https://marketplace.fedramp.gov/products/F1603087869.

It turns out that a number of other FedRAMP-authorized products are partially dependent upon Microsoft Azure Government’s FedRAMP authorization, so continued maintenance of this authorization is essential to Microsoft, a number of other vendors, and all the agencies that require secure cloud solutions.

They can only hope that the GSA Inspector General doesn’t find fault with THEM.

Is FedRAMP compliance worth it?

But assuming that doesn’t happen, is it worthwhile for vendors to pursue FedRAMP compliance?

If you are a company with a cloud service, there are likely quite a few questions you are asking yourself about your pursuits in the Federal market. When will the upward trajectory of cloud adoption begin? What agency will be the next to migrate to the cloud? What technologies will be migrated? As you move forward with your business development strategy you will also question whether FedRAMP compliance is something you should pursue?

The answer to the last question is simple: Yes. If you want the Federal Government to purchase your cloud service offering you will, sooner or later, have to successfully navigate the FedRAMP process.
From https://www.mindpointgroup.com/blog/fedramp-compliance-is-it-worth-it.

And a lot of companies are doing just that. But with less than 400 FedRAMP authorized services, there’s obviously room for growth.

Ofcom and the Digital Trust & Safety Partnership

The Digital Trust & Safety Partnership (DTSP) consists of “leading technology companies,” including Apple, Google, Meta (parent of Facebook, Instagram, and WhatsApp), Microsoft (and its LinkedIn subsidiary), TikTok, and others.

The DTSP obviously has its views on Ofcom’s enforcement of the UK Online Safety Act.

Which, as Biometric Update notes, boils down to “the industry can regulate itself.”

Here’s how the DTSP stated this in its submission to Ofcom:

DTSP appreciates and shares Ofcom’s view that there is no one-size-fits-all approach to trust and safety and to protecting people online. We agree that size is not the only factor that should be considered, and our assessment methodology, the Safe Framework, uses a tailoring framework that combines objective measures of organizational size and scale for the product or service in scope of assessment, as well as risk factors.
From https://dtspartnership.org/press-releases/dtsp-submission-to-the-uk-ofcom-consultation-on-illegal-harms-online/.

We’ll get to the “Safe Framework” later. DTSP continues:

Overly prescriptive codes may have unintended effects: Although there is significant overlap between the content of the DTSP Best Practices Framework and the proposed Illegal Content Codes of Practice, the level of prescription in the codes, their status as a safe harbor, and the burden of documenting alternative approaches will discourage services from using other measures that might be more effective. Our framework allows companies to use whatever combination of practices most effectively fulfills their overarching commitments to product development, governance, enforcement, improvement, and transparency. This helps ensure that our practices can evolve in the face of new risks and new technologies.
From https://dtspartnership.org/press-releases/dtsp-submission-to-the-uk-ofcom-consultation-on-illegal-harms-online/.

But remember that the UK’s neighbors in the EU recently prescribed that USB-3 cables are the way to go. This not only forced DTSP member Apple to abandon the Lightning cable worldwide, but it affects Google and others because there will be no efforts to come up with better cables. Who wants to fight the bureaucratic battle with Brussels? Or alternatively we will have the advanced “world” versions of cables and the deprecated “EU” standards-compliant cables.

So forget Ofcom’s so-called overbearing approach and just adopt the Safe Framework. Big tech will take care of everything, including all those age assurance issues.

From https://dtspartnership.org/wp-content/uploads/2023/09/DTSP_Age-Assurance-Best-Practices.pdf.

DTSP’s September 2023 paper on age assurance documents a “not overly prescriptive” approach, with a lot of “it depends” discussion.

Incorporating each characteristic comes with trade-offs, and there is no one-size-fits-all solution. Highly accurate age assurance methods may depend on collection of new personal data such as facial imagery or government-issued ID. Some methods that may be economical may have the consequence of creating inequities among the user base. And each service and even feature may present a different risk profile for younger users; for example, features that are designed to facilitate users meeting in real life pose a very different set of risks than services that provide access to different types of content….

Instead of a single approach, we acknowledge that appropriate age assurance will vary among services, based on an assessment of the risks and benefits of a given context. A single service may also use different
approaches for different aspects or features of the service, taking a multi-layered approach.
From https://dtspartnership.org/wp-content/uploads/2023/09/DTSP_Age-Assurance-Best-Practices.pdf.

So will Ofcom heed the DTSP’s advice and say “Never mind. You figure it out”?

Um, maybe not.

Time for the FIRST Iteration of Your Firm’s UK Online Safety Act Story

By Adrian Pingstone – Transferred from en.wikipedia, Public Domain, https://commons.wikimedia.org/w/index.php?curid=112727

A couple of weeks ago, I asked this question:

Is your firm affected by the UK Online Safety Act, and the future implementation of the Act by Ofcom?
From https://bredemarket.com/2023/10/30/uk-online-safety-act-story/

Why did I mention the “future implementation” of the UK Online Safety Act? Because the passage of the UK Online Safety Act is just the FIRST step in a long process. Ofcom still has to figure out how to implement the Act.

Ofcom started to work on this on November 9, but it’s going to take many months to finalize—I mean finalise things. This is the UK Online Safety Act, after all.

This is the first of four major consultations that Ofcom, as regulator of the new Online Safety Act, will publish as part of our work to establish the new regulations over the next 18 months.

It focuses on our proposals for how internet services that enable the sharing of user-generated content (‘user-to-user services’) and search services should approach their new duties relating to illegal content.
From https://www.ofcom.org.uk/consultations-and-statements/category-1/protecting-people-from-illegal-content-online

On November 9 Ofcom published a slew of summary and detailed documents. Here’s a brief excerpt from the overview.

Mae’r ddogfen hon yn rhoi crynodeb lefel uchel o bob pennod o’n hymgynghoriad ar niwed anghyfreithlon i helpu rhanddeiliaid i ddarllen a defnyddio ein dogfen ymgynghori. Mae manylion llawn ein cynigion a’r sail resymegol sylfaenol, yn ogystal â chwestiynau ymgynghori manwl, wedi’u nodi yn y ddogfen lawn. Dyma’r cyntaf o nifer o ymgyngoriadau y byddwn yn eu cyhoeddi o dan y Ddeddf Diogelwch Ar-lein. Mae ein strategaeth a’n map rheoleiddio llawn ar gael ar ein gwefan.
From https://www.ofcom.org.uk/__data/assets/pdf_file/0021/271416/CYM-illegal-harms-consultation-chapter-summaries.pdf

Oops, I seem to have quoted from the Welsh version. Maybe you’ll have better luck reading the English version.

This document sets out a high-level summary of each chapter of our illegal harms consultation to help stakeholders navigate and engage with our consultation document. The full detail of our proposals and the underlying rationale, as well as detailed consultation questions, are set out in the full document. This is the first of several consultations we will be publishing under the Online Safety Act. Our full regulatory roadmap and strategy is available on our website.
From https://www.ofcom.org.uk/__data/assets/pdf_file/0030/270948/illegal-harms-consultation-chapter-summaries.pdf

If you want to peruse everything, go to https://www.ofcom.org.uk/consultations-and-statements/category-1/protecting-people-from-illegal-content-online.

From https://www.ofcom.org.uk/consultations-and-statements/category-1/protecting-people-from-illegal-content-online

And if you need help telling your firm’s UK Online Safety Act story, Bredemarket can help. (Unless the final content needs to be in Welsh.) Click below!