General Security Issues

Is Protective Monitoring Necessary for an SME?

I’ve talked about protective monitoring in the past but there is still some misperceptions about it, particularly amongst SMEs.  Probably first and foremost is that it is way too expensive, which leads to thinking that it’s not for them and is much more of a nice to have than a necessity.  I thought I’d take a bit of a deeper dive into this.

So, what is it? 

Protective monitoring in cyber defence is a systematic approach to continuously observing and analysing an organisation’s digital environment to detect, prevent, and respond to security threats. It involves gathering and analysing data about network traffic, system activity, and user behaviours to identify potential vulnerabilities or malicious activities. Here’s a breakdown of its key components and purposes:

For a small or medium-sized enterprise (SME), implementing cyber protective monitoring is crucial for a variety of reasons. This proactive approach can be the difference between quickly identifying and mitigating threats or facing significant damage from a cyber-attack. Here are key reasons why SMEs should consider cyber protective monitoring:

1. Protection Against Data Breaches

SMEs often hold sensitive data like customer information, financial records, and intellectual property.  Companies like law firms, financial advisors and estate agents, will hold years worth of personal identifiable information as defined by the Data Protection Act, or UK GDPR if you prefer.  Protective monitoring helps identify unusual activity within their network, such as unauthorised access or data exfiltration attempts, allowing for swift action to prevent breaches.

This is especially important as SMEs can be perceived as easier targets by cybercriminals compared to larger enterprises with more robust defences.

2. Regulatory Compliance

Many industries have strict regulations around data privacy and cybersecurity, such as GDPR and PCI-DSS. Protective monitoring helps SMEs stay compliant by providing visibility into how data is accessed, used, and secured.

It allows them to maintain audit trails of activity, which are often required to prove compliance during an audit or investigation.

3. Early Threat Detection

Cyber threats are constantly evolving, and attackers are often inside a network for days or weeks before launching an attack (such as ransomware). Protective monitoring enables the detection of anomalous behaviour that could indicate a security threat before it becomes critical.

This helps minimise damage by enabling a faster response to potential threats like malware infections, unauthorized access, or network vulnerabilities.

4. Cost-Effectiveness in the Long Run

While some SMEs may view cyber protective monitoring as an additional cost, it is often more cost-effective than dealing with the fallout of a cyber-attack. The financial impact of a breach includes legal fees, loss of business, damage to reputation, and potential fines from regulatory bodies.

By investing in monitoring, SMEs can save significantly on these potential costs, making it a smart investment, especially now that there are systems specifically designed and costed for SMEs.

5. Building Trust with Clients and Partners

Customers and business partners expect their data to be handled securely. An SME with strong cybersecurity practices, including protective monitoring, can build trust and demonstrate its commitment to data security.

This can serve as a competitive advantage, especially when dealing with larger enterprises or industries that prioritise security.

6. Rapid Incident Response

When a security incident occurs, the speed of the response is critical. Cyber protective monitoring provides real-time alerts when suspicious activities are detected, enabling SMEs to quickly isolate affected systems and take necessary actions.

A rapid response can help contain potential damage, maintain business continuity, and limit operational disruptions.

7. Mitigating Insider Threats

Not all cybersecurity risks come from outside the organisation. Insider threats, whether malicious or accidental, can cause significant damage. Protective monitoring can help detect unusual behaviour from employees or contractors, such as unauthorised access to sensitive data or suspicious data transfers.

This allows SMEs to address these issues before they lead to data leaks or other security incidents.

8. Scalability and Adaptability

As SMEs grow, their digital footprint and potential vulnerabilities expand as well. Cyber protective monitoring solutions can scale alongside the business, ensuring that security measures remain effective even as new systems, networks, and applications are added.

This adaptability makes it easier for SMEs to adjust their cybersecurity strategy as their needs change, without a complete overhaul of their security infrastructure.

9. Insights for Better Decision-Making

Beyond just identifying threats, protective monitoring can provide valuable insights into network usage and performance. SMEs can leverage this data to make better strategic decisions regarding their IT infrastructure, such as identifying redundant systems or optimising network resources.

It can also highlight areas that require further security investments, helping prioritise spending on cybersecurity.

10. Improving Overall Cybersecurity Posture

Cyber protective monitoring is a key part of a broader cybersecurity strategy. By continuously monitoring and analysing network activities, SMEs can better understand their vulnerabilities and areas for improvement.

This helps create a culture of security within the organisation, where cybersecurity is not just an afterthought but an ongoing priority.

Overall, cyber protective monitoring provides visibility, control, and peace of mind for SMEs, helping them navigate the complex and ever-changing landscape of cyber threats. By taking a proactive stance, they can protect their assets, maintain customer trust, and ensure long-term resilience against cyber-attacks.

Protective monitoring is not just for corporate organisations, but is for everyone, especially now that there are systems and services designed especially for SMEs and priced accordingly.  Don’t leave it until it’s too late. Playing catch up and fixing problems after the event, is always much more expensive that taking a pro-active stance.

To learn more about the protective monitoring managed solutions we provide please click here https://www.hah2.co.uk/

Cyber Resilience – what it means and just as importantly, what it doesn’t mean

Cyber resilience can mean different things to different people, depending upon their priorities, their perception of cyber security and the business they are in.  This means that there are a lot of misconceptions about what it means, and I’m sure I’ll get some disagreeing with what I write here.  And that’s OK, because it really can depend on your situation as I’ve said above.  Essentially though it refers to an organisation’s ability to prepare for, respond to, and recover from cyber incidents, ensuring that critical operations continue despite attacks, failures, or unexpected events. Unlike cybersecurity, which focuses mainly on preventing attacks, cyber resilience combines prevention with the capability to withstand and adapt to adverse conditions, even if breaches or disruptions occur.

It encompasses five main aspects:

  • Identify: Understanding what an attack or scam might look like.
  • Protection: Implementing strong security measures to prevent cyberattacks and minimise vulnerabilities.
  • Detection: Quickly identifying and recognising cyber threats or breaches when they occur.
  • Response: Reacting effectively to contain and mitigate the impact of a cyber incident.
  • Recovery: Restoring systems and data to normal functioning after an incident, while learning from the event to improve future preparedness.

A cyber-resilient organisation is not only prepared to handle potential attacks but is also structured to adapt, recover, and continue functioning in the face of disruptions. This approach ensures minimal downtime, data loss, and damage to reputation.

Now let’s look at some misconceptions around cyber resilience.

  • Complete Immunity from Cyber Attacks: Cyber resilience does not mean that an organisation will be entirely immune to cyber threats. Rather, it focuses on minimising the impact and ensuring continuity in the face of such events. No system can be entirely hack proof.
  • Just Having Strong Cybersecurity: While cybersecurity is a crucial part of cyber resilience, the latter encompasses more than just security measures like firewalls or anti-virus software. It also involves having an effective strategy encompassing sound policies and processes, incident response plans, business continuity plans, and recovery strategies. A purely preventive approach, without considering recovery, does not constitute true cyber resilience.
  • A One-Time Effort: Cyber resilience is not a one-time project or a static state. It requires continuous assessment, updating of policies, and adaptation to new threats. It’s an iterative process of improvement and adjustment to maintain resilience against evolving threats.
  • Quick and Easy Recovery: While resilience involves the ability to recover, it does not guarantee that recovery will be quick or without challenges. It means that recovery is possible, but it might still take time and effort to restore normal operations depending on the severity of the incident.
  • An IT Department’s Responsibility Alone: Cyber resilience is not just about technical solutions managed by the IT department. It involves a holistic approach, including organisational culture, employee training, risk management strategies, and coordination across different business functions. It’s an organisational-wide commitment.  In a nutshell, it’s a business issue, not an IT issue.

Understanding what cyber resilience is not helps organisations better align their strategies towards truly being prepared for and able to recover from cyber incidents.

Don’t get bogged down in this though, don’t think it’s way too difficult and not really something that an SME for instance, can afford to do.  It’s a matter of scale and there are some things that a corporate business will need to do, that an SME doesn’t need to do, or perhaps can scale down. 

Help is at hand and if you want to talk this over then do please give me a call.

Can Remote Working be Dangerous?

Well frankly, yes it can be dangerous.  There is a myriad of issues which have sprung out of remote working since COVID, with many SMEs, now operating a hybrid working scenario, although in my experience, certainly amongst my customer base, there are very few going 100% remote.

Businesses of all sizes have been forced to transform their operations to support remote work and by and large have done well, but not without many challenges—including video conferencing burn out, (along with wishing they’d taken out shares in Zoom!!), and a yearning to work together in person again, someday.  We all realise that group working, face to face, is often necessary not just for efficiency, but because we are social animals.  Experience has taught many businesses many things, but strangely, to my mind at least, many have simply not grasped the potentially dire consequences in terms of cyber security and data protection.

A distributed work environment i.e., personnel spread around various locations, office, home working, even the local coffee shop, creates critical challenges and new security threats as a result.  The speed with which this has happened has meant that many simply did not take this into account and if they did, thought, well, this is temporary, and it won’t matter in the long run.  Well perhaps, but as many are now finding, there have been advantages to home working, not least a lowering of costs in terms of how much office space is needed to carry out the business function.  Many are now looking at Hybrid working i.e., from home with a day or two in the office during the week.  There are pros and cons to this outside of the scope of this article, and businesses will have to make their own judgements, but one thing is clear and that is that businesses need to understand the risks now inherent in distributed work and need to get better at cyber security and data protection, in those environments.

Employees when remote working, are at much greater risk than those in offices. Since home connections are less secure, cybercriminals have an easier entry into the company network.  Furthermore, the explosion of various online tools, solutions, and services for collaboration and productivity tend to have the bare minimum of security default setting, and updates from third-party vendors can change security preferences and be easily overlooked.

Phishing becomes an even greater threat to home workers simply because, in an office environment, they have access to colleagues and managers, who they can approach for advice and guidance.  This is much harder to replicate with remote workers, especially those who may not be particularly tech savvy and who may not wish to become ‘burdensome’ to their co-workers.

Ransomware also enjoys an advantage in the remote working model.  If their connection to the company is blocked, it is more difficult for workers to get assistance from the right experts and authorities.  And since trust levels are lower when working from home, some workers will be concerned that they have “done something wrong” and so may be more reluctant to seek help. While this risk can be addressed by increased training, as well as messaging that vigilance and involving corporate IT will be rewarded, it can still be an uphill battle.

One of the biggest dangers I still see day to day is the dangers inherent in working from the local coffee shop.  This is a subject that I tend to jump on every so often, because it’s one that people just don’t seem to get.  Whenever I drop into a coffee shop for my caffeine infusion, there are usually at least a couple of people with their laptops open, working away on business issues.  I could see open spreadsheets (and easy to read if you were sitting behind them), and all have their email open.  They are often on a video call, and I can often hear all their side of the conversation, annoying enough for other café users but they are oblivious of the data being released into the wild.

If you are among those free Wi-Fi lovers, there’s bad news for you… your online privacy and security is at risk, if you rely on the weak to non-existent Wi-Fi security protocolsat coffee shops.  This means that you could be exposed to various threats such as identity theft which has over 15 million cases each year, data theft/breaches, introducing malware to your business network and that of your customers/suppliers.  This list is not exhaustive.

Free or public Wi-Fi’s are hotspots for hackers and data snoopers who want to steal your private data or financial information. It is easy for hackers to do that nowadays. You will be surprised to know the different ways hackers can compromise your device or your private information and why you shouldn’t rely on Wi-Fi security at coffee shops as they come with a lot of risk.

  • Unencrypted Data Exposure: If the Wi-Fi network is not encrypted, your sensitive information (e.g., passwords, emails, and financial data) can be intercepted by hackers using packet-sniffing tools.
  • Man-in-the-Middle Attacks: Hackers can position themselves between you and the network, intercepting and potentially altering the communication between your device and the server, leading to data theft or manipulation.
  • Fake Hotspots (Evil Twin Attacks): Cybercriminals may create a rogue Wi-Fi network that mimics the coffee shop’s legitimate network. If you connect to it, they can access all the data transmitted over the connection.
  • Malware Injection: Open networks can allow hackers to inject malware or viruses onto your device, which can lead to long-term breaches of your data or systems.
  • Session Hijacking: Attackers can intercept your session cookies, giving them access to your accounts, even if you’re using secure websites.
  • To mitigate these risks, use a VPN, avoid sensitive transactions, and ensure your firewall and antivirus software are active.  Although a VPN may not save your data if it’s stored on your laptop.

We are huge supporters of Cyber Awareness training for managers and staff, arguing that this is no longer a ‘nice to have’ and is now very much a necessity.  In fact, it is arguably the biggest quick win, giving the greatest potential return on investment that there is.  Of course, this means that companies must understand what their threats, vulnerabilities and risks are, to assess exactly what training is going to be the most effective.

But that alone won’t save you from a dedicated hacker.  We need to look at some more technical solutions to help you beat attacks.  Here at H2 we have researched and developed services using Software as a Service (SaaS), which, being cloud based, work wherever you are, office, home or coffee shop, and encrypts your most sensitive data whether on your machine, or in transit. 

If you feel a no obligation chat about this would be helpful, give us a call.

How are Mid-Market Businesses Faring Regarding Cyber Security

Mid-sized businesses are under as much pressure to keep the organisation secure as are the larger corporates but without the deep pockets that those larger corporates have.  Because of this they are also fast becoming the easy target that we often view small businesses as being, but with a larger payload for the cyber-criminal.  In fact, in 2023, 59% of medium sized businesses suffered a cyber-attack or data breach in the UK. 

The biggest issue facing mid-market organisations is balancing limited resources with the growing complexity and volume of cyber threats. The lack of resources is compounded by an overall dearth of cyber-security skills in general, and a real lack of skills in mid-sized companies and the IT companies they often outsource to.  Key aspects of this challenge include:

1. Resource Constraints: Mid-market organisations typically lack the budget and personnel to implement robust, enterprise-level cyber-security solutions. They may not have dedicated security teams, forcing IT departments to manage cyber-security alongside other duties. This dilutes skills and leaves them vulnerable to sophisticated attacks.

2. Rising Threat Sophistication: Cyber-criminals are increasingly using advanced tools and techniques, such as ransomware, phishing, and supply chain attacks, now enhanced with AI, which often outpace the security capabilities of mid-sized businesses. These organisations are prime targets because they are often seen as less protected than larger enterprises but more valuable than small businesses.

3. Compliance and Regulatory Challenges: As regulations like GDPR, FCA, and industry specific mandates grow, mid-market companies struggle to meet compliance requirements without the same level of support and infrastructure that larger organisations can afford.

4. Lack of Cyber security Awareness: Employees at mid-market organisations may not have adequate training on cyber-security best practices, making them vulnerable to human error, such as falling for phishing scams or weak password practices.

5. Third-Party Risks: Mid-market companies often rely on third-party vendors for various services, but they may lack the resources to thoroughly vet these vendors’ security postures, leading to vulnerabilities in their supply chain.

Addressing these issues requires mid-market organisations to prioritise cyber-security despite resource constraints, invest in scalable security solutions, and foster a strong security culture throughout the organisation.

There is a very real difficulty in breaking out of this cycle.  The mind set of most board members is to focus on the core business and keep costs to an absolute minimum.  Costs are important in a mid-sized business, especially one where margins may be tight.  IT budgets will focus on items, both hardware and software, that are required to keep the revenue flowing and its cyber-security solutions, including data protection solutions, are often seen as nebulous because there is no obvious return on investment.  CIOs/CISOs/IT Directors are often left trying to prove a negative, ie we haven’t had any security issues because we have protections in place, as opposed to we haven’t had any security issues therefore we don’t need to budget for protections.  It’s a years old argument that never seems to have a resolution. 

However, breaking out of this cycle, this thought process, is very important.  Cyber threats, what we refer to as the threat landscape, are evolving at a frightening pace, often enhanced using AI.  This will further compound any argument about budget simply because there is this need to keep pace with the cyber-criminal, and those of us in this industry know that we have always been playing catch up.

So how do we do it?  Not an easy answer but one way that some mid-sized organisations are now looking at is managed security solutions.  The provision of SOC (Security Operations Centre) solutions, in a shared way, as we do with cloud services for example, makes managed security more affordable.  Many of the large enterprise organisations also make use of managed security solutions for the reasons of cost.  On site solutions are not just expensive in terms of hardware and software, but also staffing costs, training etc, can be exorbitant.  So, sharing those costs becomes very attractive.

Of course, there is no one size fits all solution and most managed service providers will have a set of services it provides, and do not tailor their services simply because it would make them too complex and expensive to provide, somewhat obviating the whole reason for doing it in the first place.

To make sure that you have the level of protection that you need, then you must do some up front work, maybe getting some consultancy that will save you money in the long run, by getting the protections and levels of service in place that you actually need.

There are several solutions around and organisations that provide them, and I do recommend that you shop around.  Some are better than others and the CrowdStrike issue hasn’t done the reputation of managed services much good.  Here at H2 we offer solutions for both monitoring your technical estate, your user actions, email, cloud services etc, as well as your data protection issues providing monitoring of any compliances that you may need, including UK GDPR, PCI DSS as an example.

If in doubt give us call, we’d be delighted to chat it over, offer a demo and a FREE trial lasting up to 30 days for the data protection solutions and 14 days for the more technical solution.

Is Cyber Security about Tech or the Business?

It’s simply a fact that many owners, managers, directors etc, believe that cyber security is a technology issue and is best left to those guys in IT who understand that stuff.  Here at H2 we spend a lot of time and effort trying to educate C level people, that it really is a business issue, although it has significant input from the techies.  It’s a business issue because breaches can have a significant financial and reputational impact.  It’s also an IT issue because it involves implementing technical measures to protect systems and data.  Effective cyber security requires a collaboration between business leaders and IT professionals to address both the strategic and technical aspects of security.

The crux of the issue though, is that it must be led by the business, and at board level.  It requires a strategy to be followed, which is laid down at board level and which is focused on the goals and aspirations of the business, especially when your IT is outsourced.  You can outsource your IT, but you can’t outsource your responsibility.

A valid argument is that the proliferation of security tools creates an illusion of safety.  Organisations, large and small, often believe that by deploying a firewall, antivirus software and maybe some other tools, such as intrusion detection systems, they are adequately protected.  This ignores the fact that such tools are controls put in place to mitigate risks identified and qualified in terms of importance, in a risk assessment and unless the benefits they bring are properly identified, and the solutions placed and configured correctly, they may well not be doing what you think they are doing.  This thinking can also introduce significant third-party risks into your domain.  The most recent example of this is the CrowdStrike issue which caused so much chaos throughout the globe.

To be fair to most companies in the smaller and mid-market arenas, their focus is on obtaining IT solutions as cost effectively as possible, and with the minimum of support costs.  Cost control is vital to most.  This means that they are extremely reluctant to spend money on what they see as not being part of their core business.  Of course, if they get a cyber-attack or scam, or worse a data breach attracting the attention of the ICO, then their costs trying to fix the issue can easily outstrip any costs in prevention.  Unless they have a well thought out risk managed strategy, they are wide open to slick sales pitches which push products.  The rub is that in order to have that well thought out strategy, it means spending on what they see as expensive services that can seem somewhat nebulous, not something they can see and feel, and there is that vague feeling that they are being led to do something that really isn’t all that important.

The approach most take is to trust their IT provider to give them the protections they need.  Most of these IT providers are what is known as re-sellers, ie they sell other people’s products and will push those products because that’s their business model.  What they won’t do is take a risk managed approach which is essential in ensuring that any limited spend on security, limited because of cost constraints, is targeted where it’s needed and will be most effective.  In other words, the technological approach taken by most IT support company’s will do half a job at best.

In essence then, if you don’t understand the risks you face, how can ensure that your cyber security strategy and protections are fit for purpose?  Risk management is all about helping us to create plans for our future in a deliberate and responsible way. This requires us to explore what could go wrong in an organisation, on a day-to-day basis.

A quote from Bruce Schneier, Fellow at the Berkman Center for Internet & Society at Harvard Law School, goes like this:

If you think technology can solve your security problems, then you don’t understand the problems and you don’t understand the technology’. 

How do we approach this then?  First and foremost, you need to identify the risks that you face. How can you identify that risk and then mitigate it?  Taking risks is a part of business.  You assess risk every day when doing business.  Do you want to do this deal?  What happens if it goes not as expected?  Do I want to take this person on?  Whether you formally undertake a risk assessment or whether you assess that risk informally, you are working out what is appropriate to a level that is consistent with the risk that your organisation is prepared to take.  Failure to do that will almost certainly be damaging to your business, perhaps fatally so. 

The difference between assessing day to day business risk and assessing risk to cyber assets, is one of understanding.  What is a cyber asset?  In this context insert the word ‘information’ instead of cyber.  It is the information contained within the IT system that is the important asset, not the piece of hardware it is sitting on.  You understand your business risk, after all it is your business, but do you understand information risk?  Do you have a clear idea of what information assets you have and where they are?  Before you answer that think it through.  Do you really know where all the data is?  OK, you know that you have a server or servers probably in a cloud somewhere (cloud storage and access is a whole other subject) and that somewhere in those servers there is a bunch of data which runs your business.  How much of that data has been saved onto staff workstations when they needed it to carry out some work?  How much has been copied off somewhere else for what was probably a very good reason at one point?  How well is your firewall functioning?  Can malware work its way onto the network because the firewall does not have Universal Threat Management installed and can therefore be probing the servers and workstations.  And we haven’t even thought about changes in working patterns.  How many of your staff now work remotely some or all of the time.  I could go on.

How can we be sure where all this information is and how important each bit is to the business?  How can we assess this risk to the business, if information is lost or otherwise compromised?  What about ransomware, phishing scams etc?  The good news is that some of this can now be automated and managed for you at an affordable price and you can even arrange a 14 day totally free trial to assess its effectiveness.

AI and Risk Management – What’s Changed?

The answer to the question posed is, quite simply, nothing, in terms of risk management.  The process of analysis of the threats posed to any particular organisation or infrastructure, the assessment of how vulnerable that organisation is to those threats, and the application of controls to bring down the risk to an acceptable level, remains pretty much the same.

Of course, the threat is changing, quite considerably, with billions being invested globally in the field of AI, which is affording huge advances in technology which brings with it great benefits but also new risks which are potentially more dangerous than those associated with current IT systems.

There is guidance coming out from several sources internationally on these risks and how to address them, but the EU has gone one step further and is producing the first comprehensive continental legislation on AI, the EU AI Act.  Unlike most countries guidance, it is not voluntary but will become law and has real teeth.  It wouldn’t be a shock to find other countries following suite.

The EU AI Act focuses on impacts to the rights, freedoms and safety of the public within the EU but is nevertheless a landmark legislative proposal by the European Union aimed at regulating artificial intelligence across its member states. Proposed in April 2021, the Act seeks to establish a comprehensive legal framework for AI that ensures the technology is developed and used in a way that respects fundamental rights, safety, and democratic values.

Here are the key points of the EU AI Act:

1. Risk-Based Approach

The Act adopts a risk-based classification system that categorises AI systems into four risk levels:

  • Unacceptable Risk: AI systems deemed harmful (e.g., social scoring by governments) are banned outright.
  • High Risk: AI systems with significant potential to impact safety, rights, or wellbeing (e.g., biometric identification, critical infrastructure) must meet strict requirements regarding transparency, accuracy, oversight, and documentation.
  • Limited Risk: Systems with moderate risk must comply with transparency obligations (e.g., AI chatbots must inform users they are interacting with AI).
  • Minimal Risk: Systems with negligible or no risk (e.g., spam filters, AI in video games) are largely unregulated.

2. High-Risk AI Regulation

For high-risk AI systems, the EU AI Act imposes stringent regulatory requirements. These include:

  • Thorough risk assessments before deployment.
  • Ongoing monitoring during use.
  • Ensuring traceability and transparency in the system’s decision making processes.
  • Compliance with technical documentation and human oversight standards.

3. Prohibited Practices

Certain AI uses are banned outright because they are considered to violate fundamental rights. Examples include:

  • Real-time remote biometric identification in public spaces for law enforcement purposes (with some exceptions).
  • AI systems that exploit vulnerabilities of specific groups, such as children or the elderly.

4. Governance and Enforcement

A new European Artificial Intelligence Board (EAIB) will be created to oversee the implementation of the AI Act. This body will work alongside national regulators to enforce compliance across the EU.

5. Penalties

Non-compliance with the AI Act can result in hefty fines, with penalties of up to €30 million or 6% of global annual turnover, whichever is higher, for serious violations.

6. Promoting Innovation

While the AI Act imposes strict controls on high-risk systems, it also includes provisions to encourage innovation in the AI sector. It proposes the creation of regulatory sandboxes, controlled environments where companies and public institutions can test AI systems under the supervision of regulators before full deployment.

7. Scope

The AI Act has a broad scope, applying not just to companies and institutions based in the EU, but also to non-EU organisations that place AI systems on the European market or whose AI systems affect individuals within the EU.

The EU AI Act is significant because it represents the first major attempt globally to create a legal framework that balances the benefits and risks of AI. It aims to position the EU as a global leader in AI regulation, prioritizing ethical AI development while promoting safety, transparency, and accountability.

As I said earlier, there are other sets of guidance being issued but they are not enforceable and can be adopted in whole or in part or ignored.  The US Dept pf Commerce National Institute for Standards and Technology (NIST) and the UK National Cyber Security Centre (NCSC) have issued such guidance.  The NIST guidance for example covers Harm to People, Harm to an Organisation and Harm to an Ecosystem.  But it remains just guidance.  On the upside it is all based on sound risk management and for those of us who have been steeped in that culture, almost for as long as information security has been taken into the IT sphere, that is music to our ears.

If you want to know more or to chat over the issues, drop me a message.  I’d be only too pleased.  If you are interested in knowing a bit more about risk management then this article might be of interest to you https://hah2.co.uk/still-on-the-subject-of-cyber-resilience/.

New Cyber Threats and Innovations

Cybersecurity is an ever-evolving field, with new threats and innovations emerging regularly. Not all these threats will apply to everyone, the trick is, and has always been, identifying the threats that apply to you, working out how vulnerable you are too those threats, and applying controls to bring those down to an acceptable level.  That acceptable level will change, not just from company to company, but also asset to asset.  Don’t waste valuable time and energy trying to achieve a zero-threat level.  It doesn’t exist.  You need to understand clearly what your appetite for risk is, ie what is an acceptable level of risk for you, and then go for it. 

But what emerging threats are there that you just might have to combat in your daily business life.  These trends highlight the ongoing innovation in both cyber threats and defences, driven by the growing reliance on digital infrastructure and the rapid evolution of technology.

Here are some suggestions and trends in cybersecurity as of late 2024:

1. AI-Powered Cyber Attacks and Defences

Threats:  Cybercriminals are increasingly using AI to launch more sophisticated attacks, such as AI-driven phishing campaigns, automated hacking attempts, and machine learning-based malware that adapts to security measures.  We’re seeing AI powered social engineering, phone calls mimicking voices of managers, and similar.  Like with just about all AI usage, what it does it make things much easier by reducing human effort.  So, attacks can be set up using AI and become almost fire and forget, just letting it get on with it in the background.

Defense: Organisations are countering this with AI-based threat detection systems, anomaly detection, and predictive analytics to identify potential breaches before they occur.  What about your defences?  Are they keeping up with these types of threat.  What about mobile workforces, are your staff covered once they leave the office; do you have a hybrid or even fully remote workforce?  If so, are your defences up to the job? Check out https://hah2.co.uk/

2. Ransomware Evolution

Ransomware continues to be a major threat, but it’s evolving with more advanced encryption techniques, and multi-stage attacks where attackers exfiltrate data before encrypting it. They then threaten to publish the stolen data unless a ransom is paid.  I recently heard of a company that had been infiltrated through its website which was transactional, ie it sold stuff via the website and the website was connected to their database of products and sales order processing system.  The web developer didn’t have sufficiently robust security in place.  A good example of an SME being exploited via their supply chain.

Double extortion and Ransomware-as-a-Service (RaaS) have become more common, where hackers sell ransomware kits to other criminals.

3. Zero Trust Architecture

Zero Trust has moved from a buzzword to a mainstream security model. Organisations are adopting a “never trust, always verify” approach, assuming that every user and device, both inside and outside the network, could be compromised.

Implementing least privilege access, micro-segmentation, and continuous authentication are key features of this approach.  And no, this doesn’t have to be cost prohibitive.

4. Supply Chain Attacks

Attacks targeting third-party vendors and software providers have increased. By compromising trusted suppliers, attackers can infiltrate many organisations through a single breach.

Notable Examples: The SolarWinds and Kaseya attacks were significant instances that highlighted the dangers of such supply chain vulnerabilities.  The attack on the NHS via a contracted service provider, is also a good example but it doesn’t just affect the big organisations.  See above for an example of how an SME was attacked via a third-party web designer.

5. Post-Quantum Cryptography

With quantum computing on the horizon, there’s increasing focus on developing encryption algorithms that can resist quantum attacks. Post-quantum cryptography is becoming a hot topic as organisations prepare for the future of computing.

Even without quantum computing, many organisations do not use encryption, even for their critical data.  If you are subject to a data breach, but that data is encrypted, you could save yourself a lot of money and reputational damage.

6. Cloud Security and Misconfiguration

As cloud adoption accelerates, the security of cloud environments remains a top concern. Misconfigured cloud settings continue to expose sensitive data, while cloud-native security solutions (e.g., CSPM, CWPP) are becoming more prevalent.

Securing multi-cloud environments and addressing shared responsibility models are critical challenges.

7. Cybersecurity for IoT and OT

The Internet of Things (IoT) and Operational Technology (OT) are becoming frequent attack targets. Securing connected devices, industrial systems, and critical infrastructure from cyber threats is a growing concern, especially as they are often lacking in adequate security protocols.

This is becoming more critical as home working becomes more and more popular.  Employees connecting to your company cloud and systems using home broadband and WIFI, are also de fact connecting to any IOT devices that they are using in the home, potentially opening up back doors into your system.

8. Data Privacy Regulations and Compliance

Data privacy is a key focus as more countries introduce stricter regulations like the Data Protection Act 2018, now becoming known as UK GDPR (General Data Protection Regulation). There are other compliances such as FSA regulations and other industry bodies, that many need adherence to.  Data breaches can produce fines from regulatory bodies, law suites from those affected, and quite severe reputational damage.

9. Cybersecurity Automation and SOAR

Automation is becoming critical in cybersecurity due to the sheer volume of threats. Security Orchestration, Automation, and Response (SOAR) tools help streamline incident detection and response, freeing up analysts to focus on complex tasks.

Do you have anything in place to automate your defences?  Do you monitor your systems for threats?

10. Identity and Access Management (IAM)

Identity theft and credential stuffing attacks are rising, making IAM solutions more important than ever. Multi-factor authentication (MFA), password less authentication, and biometrics are seeing widespread adoption to prevent unauthorised access.

Farewell to Bob – A data protection swan song

Today is somewhat of a sad day for me as tomorrow I will attend Bob Hays funeral.  Bob and I started this business when we both returned from Dubai where we worked for HPE in their cyber security business, across the Middle East.  We came a long way since starting up in 2017 even though COVID happened in the middle, changing the way that business was conducted by many companies and therefore how we had to adapt and change in order to compete and provide the services needed by the new normal.  I think we did a pretty good job all told.

In honour of Bob, I thought I’d focus my blog this week on data protection, his pet subject.  He always went to great lengths to point out that we weren’t lawyers but were providing the how to, rather than the legal requirements of data protection legislation.  He always said that lawyers were great at telling us what we need to do to meet our legal obligations but were lousy at telling us how to do it.

Data Protection, a somewhat dry subject that many companies, particularly SMEs, think they can get away from by simply paying a bit of lip service.  The Data Protection Act 2018, or as it has become known, UK GDPR, is far from a toothless beast and can cause businesses to find themselves in all sorts of problems if they’re not careful.

Businesses that you might not think about, like Estate Agents, hold large amounts of personally identifiable information or PII, that is information that can identify a living individual.  Not so long ago a London estate agent was fined £80,000 by the Information Commissioner’s Office (ICO), after leaving the personal data of more than 18,000 customers exposed for almost two years.

The incident occurred when the estate agent passed the details from its own servers onto a partner company. An “Anonymous Authentication” function was not switched off, which meant there were no access restrictions to the data.

It’s surprising just how much PII estate agents hold.  Just think about what they ask for when you’re buying a house.  In this case the exposed details included bank statements, salary details, copies of passports, dates of birth and addresses of both tenants and landlords.

But in some cases that might not be the end of it.  Individuals can sue companies that release data into the wild.  In fact, there are now law firms advertising no win no fee when representing these cases.  Remember that data breaches almost always involve multiple people, sometimes hundreds if not thousands of records.

One thing that many misunderstand is the link between cyber security and data protection.  The Act requires personal data to be secured by ‘default and design’.  This means that cyber security requirements must be designed into your data protection processes which could considerably increase the number of policies and processes you require to stay safe and within the law.

Data Protection is a bit of a bureaucratic nightmare I have to admit.  Here at H2 we have a raft of templates we use, originally drafted up by Bob, that have been successfully introduced into a variety of organisations, often integrated with their company handbooks.  These include:

Data Protection – Overarching PolicyData Protection Training
Data Protection – ConsentConsent Withdrawal
Subject Access RequestData Protection Complaints
Retention of RecordsData Breach Notification (note there is an electronic version of this on the ICO website)
Data Protection Impact Assessment Procedure  Security & Control of data protection documentation  
Policy Management Review ProcedureInternal Data Protection Breach Register
Retention & Disposal of Records RegisterData Protection Officer (DPO) Responsibilities  
Required records to be maintained 

Of course these aren’t necessarily the only things needed, there are a whole list of cyber security policies required to complement these.  Nearly all are available online, but the problem is knowing what you need and what you don’t and not just downloading, topping and tailing, and hoping for the best.  That happens all too often.

Our approach to this has been refined over the years as not just the legislation evolves, both here and in Europe, but as working practices evolve alongside it.  We have spent many hours researching solutions and crafting them into services that meet the requirements, which in turn have evolved into a system which works, is both affordable and appropriate for all types of business, and is accreditable to standards such as cyber essentials, if that is required.  Flexibility is another key attribute that the new working practices demand.  Long gone is the old bastion security system whereby everyone works within a secure boundary, protected by firewalls and other similar technologies.  These days we need a system of protection that works regardless of where you are working, office, home, on the move, and can switch seamlessly between them.

When we are first approached by a prospective client and we begin our offer of a free trial to examine their requirements, one of the first things we find is that they don’t know what data they are holding, or where it all is.  Oh, they have a general idea; it’s on the cloud server(s), it’s not on laptops or desktops, it’s just the stuff we need to process our clients’ requirements and yes, we’ve only got one copy.  And then we install our software that first carries out a discovery exercise and we find that their laptops/desktops are holding lots of copies of the data that is on the cloud server(s).  How does that happen?  Over time, especially with many now employing the hybrid system of working, ie between the office and remote (home) locations, employees log on to the cloud, find they have a bit of shaky internet link and download the data they need, work on it and then upload it again, forgetting to delete it from their machine.  Or they need to share it and attach it to an email and send it out, forgetting, or perhaps not realising, that the data is now stored, attached to an email, on their email server.

Then comes the issue with audit trails.  If the ICO ever wanted to carry out an investigation, then having an audit trail of who created/copied/deleted/forwarded what to who, is essential.  And let’s not forget the member of the public who is fully entitled to submit a Data Subject Access Request or DSAR, which demands that you reveal what data you are holding on that person.  The law insists on it, and you can’t refuse it.  I know of a financial firm that took nearly 3 weeks to satisfy a DSAR, taking an employee off billing, for that time.

Our solution meets the requirements needed today and not only that, has a built-in encryption system, all within the same monthly cost.  It’ll cost you nothing to trial it and we’d be very surprised if once you’ve seen it and seen the ridiculously low monthly charge for the managed service, you don’t want to keep it.

So a final farewell to Bob, with thanks for all his work in the data protection arena, and for the friendship forged in 3 different company’s before we took the bull by the horns and went out on our own.

Disaster Recovery and Business Continuity         

I’ve made quite a bit recently about cyber resilience and the focus being placed on computer outages caused by third party suppliers, highlighted by not just the CloudStrike issue but also the ransomware attack on the UK NHS, made possible by infiltrating a key supplier.  All of this of course highlights the importance of supply chain security, but my focus today will be all about disaster recovery and business continuity.

Disaster recovery and business continuity are very much connected but are different.  The former is basically a plan for when things go sideways—like when a natural disaster hits, a cyberattack happens, or even if there’s a major tech failure. It’s all about making sure that businesses can bounce back and keep things running as smoothly as possible. Imagine your favourite coffee shop gets flooded. Disaster recovery is like their game plan for getting back on their feet: they might have backup equipment stored somewhere, a way to communicate with customers, and a strategy for cleaning up and reopening. In the tech world, it often involves regular backups of data, having alternate servers ready to go, and making sure everyone knows what to do in case of an emergency. The goal? To minimize downtime and get everything back to normal without too much hassle. It’s like having an insurance policy but for your operations—very important for keeping the lights on when the unexpected hits!

However, we need to understand that when it comes to the type of outages caused by supply chain cyber failures as we saw with CloudStrike, there isn’t much a customer can do to recover from that, without fixes from the suppliers.  So, in this instance disaster recovery planning becomes a little difficult to say the least.

Business continuity on the other hand, is all about making sure that a company can keep running smoothly when it is deprived of their IT systems, in whole or in part.  So, it’s about keeping business running whilst the disaster recovery plan kicks in and gets stuff back online.  The idea is to have a plan in place that helps the business bounce back quickly. This includes figuring out which critical functions need to keep going, having some way of operating manually if necessary.  Can you place an order, process an order, raise an invoice, pay a bill etc. It’s like having an emergency kit for your business—batteries included! Companies should create a business continuity plan (BCP) that outlines the steps they’ll take during a crisis. This way, they don’t just react on the fly; they can hit the ground running. It’s all about minimising downtime and keeping customers happy. In short, it’s like being prepared for a rainy day—just with more spreadsheets and meetings!

The first thing to decide is what the priorities are regarding business processes.  What is essential, what is a nice to have and what you can live without in the short to medium term.  Don’t leave it to managers and staff to guess, have it documented.  This priority order is determined based on what is known as a business impact analysis (BIA).  This determines the impact of an outage on the business and its customers.  Don’t ever forget that your reputation is on the line, and you need to keep your customers serviced and happy.  Each business process should have recovery time attached to it, ie how long you can do without it before it becomes truly disastrous.

It all sounds terribly complicated and therefore expensive, but in fact, it isn’t.  All the information you need to work this out is already in your hands.  You know your business best and you know what’s important and what isn’t quite so important.  You just have probably never written it down. And that’s the crux of the matter.

Disaster recovery planning addresses the processes, technical requirements and infrastructure an organisation needs to implement to recover data and operations as required by the business in the event of a disaster. The planning process will involve identification of critical business processes, business impact analysis and thus determination of the overall requirements for a cost-effective plan.

Following the disaster recovery plan, business recovery planning is the process that organisations must use to assess appropriate timeframes for business resumption, also allowable data losses and risk tolerances for business disruptions.  As stated earlier, it also needs a plan to carry on manually whilst the disaster recovery plan is implemented.  Budgetary requirements for infrastructure and processes, to meet the disaster recovery plan, will also be determined by the business recovery planning process.

There are also 2 other key parts to this.  Firstly, companies must ensure that their plans are tested, that everyone in the company is aware of them, where they can find them, and what their responsibilities are in this regard.  Testing is critical to ensure that processes, systems and business restoration can meet the requirements laid down for them.  Where the plans rely on third party service providers and/or indicate the need to support key customers, these should be involved in the testing process. This will give re-assurance that support will be received and/or given as expected.

And then we have key stakeholders.  Who in your organisation is responsible for what, regarding disaster recovery and business continuity planning?  Do they know their respective responsibilities, have they accepted this?  Have you placed this in their job descriptions?  Can they be held to this responsibility?  Are they part of the planning and testing process?  All seems a bit obvious when you say it, but you’ll probably not be surprised to know that it’s often totally overlooked.

Key StakeholdersRoles and Responsibilities
CEO/Board of DirectorsAware of business continuity processes, inputs as required Approval of business continuity processes and integration with other technical functions – Note 1 Ownership of business continuity processes together with relevant business units – Note 1
Infrastructure (IT operations)Input into business continuity processes.  Consideration of any infrastructure changes which may impact security architecture. Provide inputs and coordination for systems’ resiliency testing and remediation.  Provide costs/budgets for systems requirements
Business unitsCreation of BIA and corresponding recovery requirements.  Budgetary approval.

Note 1 – these two functions would be carried out by a CIO and/or and CISO in a larger organisation, but as most, even top end, SMBs are unlikely to have anyone in that role, then it must be owned by other board members. I hope this is helpful, but it can only be a guide and there is no one size fits all solution. 

Still on the subject of Cyber Resilience………

Last week I talked about whether our ability to demonstrate resilience in the cyber field, is impacted by an over reliance on the companies who supply our IT products and services, and whether over time, that reliance has grown to the point where we are ignoring our own responsibilities in this area.  I have used the phrase that you can outsource your IT, but you can’t outsource your responsibility.  At the end of the day, there is only you and your employees who have the best interests of you company at heart.  You wouldn’t tolerate a single point of failure in your business, you would try and ensure that there is resilience built into your business processes.  Why then do we not apply that to IT?

It’s a fact, which often goes unrecognised or ignored, that cyber security is not a technical issue but a business issue, and as such much of it is reliant on policy and process.  It is also a fact that your employees are both your first line of defence and potentially, your weakest link.  Technology comes in in third place.  The cyber mantra is People, Process, Technology.  If your people don’t have at least a basic understanding of the issues involved, and you do not have the right policies and processes, rolled out to, and understood by all who need them, then all the technology in the world is likely to be a waste of money.

People

Let’s take a closer look, starting with People.  Many businesses out there don’t have inhouse IT support but outsource that to an IT provider.  That’s fine, you can ensure that your contract with them spells out their responsibilities regarding your security, your data.  It then becomes their responsibility to ensure they protect to the standard stated in the contract, and that their people understand their responsibility.  However, you still have your own staff who interact with suppliers, customers and possibly members of the public, on your behalf.  I’ve discussed in my blogs before that most businesses are more likely to suffer from scams, than they are from technical hacks.  Even ransomware can be considered a scam, as can most phishing attacks.  The cyber-criminal is relying on someone on your staff to click a malicious link, or access something they shouldn’t, in order to facilitate the scam.  Staff often make the mistake of opening malware because they didn’t know they shouldn’t, not because they are themselves malicious or lack common sense.  If they fail, it’s often because they haven’t had any training.  Likewise, staff can make mistakes, such as copying and releasing data to unauthorised persons, because they didn’t know they shouldn’t.  So, whose failures are those, staff or managers?

Cyber Awareness Training (https://hah2.co.uk/cyber-awareness-training-smes/)

It is critical to the success of the cyber-security resilience that the organisation develops a mature culture of understanding and awareness about cyber risks. Above all this is an issue that must be driven from the top of the organisation – unless cyber-security has the full support of the Board it will be impossible to generate the level of commitment necessary to develop the culture of awareness.

Awareness and understanding of cyber risks are so important because these are the essential elements of the “human firewall” that is all that stands between the organisation’s critical IT systems and the clever social engineering tactics of sophisticated cyber-criminals. Such tactics are even more ubiquitous in our “always on” culture that is driven by the social media and applications accessed through smartphones and other mobile devices.  Employees need to be aware of the cyber risks inherent in the devices that are part of their everyday lives; and of the damage to their occupation and livelihoods that can be done as a result of ignorance, carelessness or inattention in their use (and abuse) of such devices.

For the security function in an organisation, the development of a mature culture of awareness and understanding is also critical. In order to achieve the shift in thinking needed to develop the culture of awareness, four things are required:

  • Board and CEO Level involvement and support
  • Training that is relevant to the job function.  Giving technical awareness training to a shop floor worker will have no impact.  If lessons from the training can be taken home and used there as well, big dividends will accrue from the reinforcement provide.
  • Training must be fun.  A little humour lightens the load and will brighten the day of employees and mean that they are more likely to remember what was taught.
  • Training must be continual.  It is more effective to do a little training each month than to have a single long session. 

Policy and Process

Moving onto to processes now.  First and foremost, all companies should have a cyber security policy.  It doesn’t need to be more than a page and should lay down what other polices are needed and who is responsible for producing them and keeping them in date.  Any of you who have achieved an ISO certification, in whatever subject you needed to, will have had a similar process to go through and if you ever wanted to achieve ISO27001, then you would need to fully understand and comply with this.

The development and documentation of an agreed set of clear and coherent policies and supporting standards, processes and baselines are essential to the success of a cyber-security program. These must be signed off at board level and preferably set within the context of the organisations cyber-security strategy. However, the nature of the policies and supporting elements themselves will, to some extent, also be governed by the risk management controls that are needed in order to manage risk to a level that is consistent with the organisation’s assessed risk, overall risk appetite and budgetary and cost constraints.  I talked about risk management last week and that can be found at https://hah2.co.uk/are-we-failing-in-our-cyber-resilience/.

The are 3 elements to this that are essential:

  • Policy.
  • Standards and processes.
  • Minimum baselines.

This may seem onerous and a step too far for many businesses but they are essential to ensure that you are self-reliant and resilient.  The whole process need not be that difficult or expensive and it is a lot cheaper than many of the technical solutions managers jump to, without first ensuring that such technologies are actually what is required.  We can offer advice and guidance in this area (https://hah2.co.uk/why-use-an-independent-board-advisor/).

Policy is the highest element in the hierarchy – representing “why” the governance controls must be used. Below this, the standards and processes represent “what” needs to be implemented, in order to deliver compliance with the policy. Thirdly, minimum baselines constitute the element that shows “how” the standards and processes should be delivered. Each of the elements is discussed in more detail below.

Technology

Finally, we come to technology.  In last weeks blog (https://hah2.co.uk/are-we-failing-in-our-cyber-resilience/ ) I went into more detail about risk management and how we go about putting the right controls in the right place, to reduce our liability to the lowest level we can, without impacting operational resilience.  But let’s just reiterate that many of these controls will be procedural and not necessarily technical, or they might be a mix of the two.  The message is don’t get hung up on technology, approach it from a risk management point of view, treat IT and cyber security in the same way you would treat any other business process.  Don’t get swamped with technical jargon, it’s not that difficult.

Next Week

Another vital piece in our resilience matrix is disaster recovery and business continuity.  Not the same thing and I have already touched on this in recent articles (https://hah2.co.uk/you-can-outsource-your-it-but-you-cant-outsource-your-responsibility/), relevant to the current issues around CloudStrike.  Disaster recovery is how you plan to recover from a disaster whilst business continuity is all about how you keep the business running whilst you recover your IT assets and data.  It’s quite an involved subject and demands an article on its own.

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