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Hit the Snooze on Lancope’s Data Loss Alarms

Update– Lanscope posted some new information positioning this as a compliment, not substitute, to DLP. Looks like the marketing folks might have gotten a little out of control. I’ve been at this game for a while now, but sometimes I see a piece of idiocy that makes me wish I was drinking some chocolate milk so I could spew it out my nose in response the the sheer audacity of it all. Today’s winner is Lancope, who astounds us with their new “data loss prevention” solution that detects breaches using a Harry Potter-inspired technique that completely eliminates the need to understand the data. Actually, according to their extremely educational marketing paper, analyzing the content is bad, because it’s really hard! Kind of like math. Or common sense. Lancope’s far superior alternative monitors your network for any unusual activity, such as a large file transfer, and generates an alert. You don’t even need to look at packets! That’s so cool! I thought the iPad was magical, but Lancope is totally kicking Apple’s ass on the enchantment front. Rumor is your box is even delivered by a unicorn. With wings! I’m all for netflow and anomaly detection. It’s one of the more important tools for dealing with advanced attacks. But this Lancope release is ridiculous – I can’t even imagine the number of false positives. Without content analysis, or even metadata analysis, I’m not sure how this could possibly be useful. Maybe paired with real DLP, but they are marketing it as a stand-alone option, which is nuts. Especially when DLP vendors like Fidelis, McAfee, and Palisade are starting to add data traffic flow analysis (with content awareness) to their products. Maybe Lancope should partner with a DLP vendor. One of the weaknesses of many DLP products is that they do a crappy job of looking across all ports and protocols. Pretty much every product is capable of it, but most of them require a large number of boxes with sever traffic or analysis limitations, because they aren’t overly speedy as network devices (with some exceptions). Combining one with something like Lancope where you could point the DLP at target traffic could be interesting… but damn, netflow alone clearly isn’t a good option. Lancope, thanks for a great DLP WTF with a side of BS. I’m glad I read it today – that release is almost as good as the ThinkGeek April Fool’s edition! Share:

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How Much Is Your Organization Telling Google?

Palo Alto Networks just released their latest Application Usage and Risk Report (registration required), which aggregates anonymous data from their client base to analyze Internet-based application usage among their clients. For those of you who don’t know, one of their product’s features is monitoring applications tunneling over other protocols – such as P2P file sharing over port 80 (normally used for web browsing). A ton of different applications now tunnel over ports 80 and 443 to get through corporate firewalls. The report is pretty interesting, and they sent me some data on Google that didn’t make it into the final cut. Below is a chart showing the percentage of organizations using various Google services. Note that Google Buzz is excluded, because it was too new collect a meaningful volume of data. These results are from 347 different organizations. Here are a few bits that I find particularly interesting: 86% of organizations have Google Toolbar running. You know, one of those things that tracks all your browsing. Google Analytics is up at 95% – is 5% less than I expected. Yes, another tool that lets Google track the browsing habits of all your employees. 79% allow Google Calendar. Which is no biggie unless corporate info is going up there. Same for the 81% using Google Docs. Again, these can be relatively private if configured properly, and you don’t mind Google having access. 74% use Google Desktop. The part of Desktop that hits the Internet, since Palo Alto is a gateway product that can’t detect local system activity. Now look back at my post on all the little bits Google can collect on you. I’m not saying Google is evil – I just have major concerns with any single source having access to this much information. Do you really want an unaccountable outside entity to have this much data about your organization? Share:

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Friday Summary: March 26, 2010

It’s been a bit of a busy week. We finished up 2 major projects and I made a quick out of town run to do a little client work. As a result, you probably noticed we were a bit light on the posting. For some silly reason we thought things might slow down after RSA. I’m writing this up on my USAirways flight but I won’t get to post it until I get back home. Despite charging the same as the other airlines, there’s no WiFi. Heck, they even stopped showing movies and the AirMall catalogs are getting a bit stale. With USAirways I feel lucky when we have little perks, like two wings and a pilot. You know you’re doing something wrong when you provide worse service at the same price as your competitors. On the upside, they now provide free beer and wine in the lounge. Assuming you can find it. In the basement. Without stairs. With the lights out. And the “Beware of Tiger” sign. Maybe Apple should start an airline. What the hell, Hooters’ pulled it off. All the flight attendants and pilots can wear those nice color coded t-shirts and jeans. The planes will be “magical” and they’ll be upgraded every 12 months so YOU HAVE TO FLY ON ONE! The security lines won’t be any shorter, but they’ll hand out water and walk around with little models of the planes to show you how wonderful they all are. Er… maybe I should just get on with the summary. And I’m sorry I missed CanSecWest and the Pwn2Own contest. I didn’t really expect someone to reveal an IE8 on Windows 7 exploit, considering its value on the unofficial market. Pretty awesome work. Since I have to write up the rest of the Summary when I get home it will be a little lighter this week, but I promise Adrian will make up for it next week. On to the Summary: Webcasts, Podcasts, Outside Writing, and Conferences Effort Will Measure Costs Of Monitoring, Managing Network Security. Database Security Metrics for the Community at Large. Security Optimism. Favorite Securosis Posts David Mortman: FireStarter: There is No Market for Security Innovation. Mike Rothman: FireStarter: There is No Market for Security Innovation. Rich nails it. Read the comments. Great discussion. Rich: Announcing NetSec Ops Quant: Network Security Metrics Suck. Let’s Fix Them. I never thought Quant would grow like this – we’re now on our third project, with two of them running concurrently. Other Securosis Posts Hello World. Meet Pwn2Own. Some DLP Metrics. Bonus Incite 3/19/2010: Don’t be LHF. Favorite Outside Posts David Mortman: Side-Channel Leaks in Web Applications. Mike Rothman: Time and Cost to Defend the Town. Security is about trade-offs. Bejtlich strikes again by presenting the discussion we have to have with senior management.. Rich: Securing Your Facebook. Threatpost with a nice place to send your friends and family for some easy to understand advice. Project Quant Posts Project Quant: Database Security – Patch. Top News and Posts Hacker exploits IE8 on Windows 7 to Win Pwn2Own. Website Security Seals Smackdown. Google releases “Skipfish”, a free web application security scanner. Busting CyberFUD. Fired CISO says his comments never put Penn’s data at risk . Sorry, if you don’t have permission, and you want to keep your job, you don’t talk. I wish it were otherwise, but that’s how the world works. Mozilla Acknowledges Critical Zero Day Flaw in Firefox. TJX Hacker Gets 20-Year Jail Sentence. Researchers Finding New Ways to Bypass Exploit Mitigations. Blog Comment of the Week Remember, for every comment selected, Securosis makes a $25 donation to Hackers for Charity. This week’s best comment goes to Jim Ivers, in response to FireStarter: There is No Market for Security Innovation. Great post and good observations. The security market is a very interesting and complex ecosystem and even companies that have an innovation that directly addresses a generally accepted problem have a difficult road. The reactive nature of security and the evolving nature of the problems to which the market responds is one level of complexity. The sheer number of vendors in the space and the confusing noise created by those numbers is another. Innovation is further dampened by the large established vendors that move to protect market share by assuring their customer base that they have known problems covered when there is evidence to the contrary. Ultimately revenue becomes the gating factor in sustaining a growing company. But buyers have a habit of taking a path of risk avoidance by placing bets on establish suites of products rather than staking professional reputation on unproven innovative ideas. Last I checked, Gartner had over 20 analysts dedicated to IT security in one niche or another, which speaks to how complex the task of evaluating and selecting IT security products can be for any organization. The odds of even the most innovative companies being heard over the noise are small, which is a shame for all concerned, as innovation serves both the customers and the vendors. Share:

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Hello World. Meet Pwn2Own.

I’m currently out on a client engagement, but early results over Twitter say that Internet Explorer 8 on Windows 7, Firefox on Windows 7, Safari on Mac OS X, and Safari on iPhone were all exploited within seconds in the Pwn2Own contest at the CanSecWest conference. While these exploits took the developers weeks or months to complete, that’s still a clean sweep. There is a very simple lesson in these results: If your security program relies on preventing or eliminating vulnerabilities and exploits, it is not a security program. Share:

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FireStarter: There is No Market for Security Innovation

I often hear that there is no innovation left in security. That’s complete bullshit. There is plenty of innovation in security – but more often than not there’s no market for that innovation. For anything innovative to survive (at least in terms of physical goods and software) it needs to have a market. Sometimes, as with the motion controllers of the Nintendo Wii, it disrupts an existing market by creating new value. In other cases, the innovation taps into unknown needs or desires and succeeds by creating a new market. Security is a bit of a tougher nut. As I’ve discussed before, both on this blog and in the Disruptive Innovation talk I give with Chris Hoff, security is reactive by nature. We are constantly responding to changes in the underlying processes/organizations we protect, as well as to threats evolving to find new pathways through our defenses. With very few exceptions, we rarely invest in security to reduce risks we aren’t currently observing. If it isn’t a clear, present, and noisy danger, it usually finds itself on the back burner. Innovations like firewalls and antivirus really only succeeded when the environment created conditions that showed off value in these tools. Typically that value is in stopping pain, and not every injury causes pain. Even when we are proactive, there’s only a market for the reactive. The pain must pass a threshold to justify investment, and an innovator can only survive for so long without customer investment. Innovation is by definition almost always ahead of the market, and must create its own market to some degree. This is tough enough for cool things like iPads and TiVos, but nearly impossible for something less sexy like security. I love my TiVo, but I only appreciate my firewall. As an example, let’s take DLP. By bringing content analysis into the game, DLP became one of the most innovative, if not the most innovative, data security technologies we’ve seen. Yet 5+ years in, after multiple acquisitions by major vendors, we’re still only talking about a $150M market. Why? DLP didn’t keep your website up, didn’t keep the CEO browsing ESPN during March Madness, and didn’t keep email spam-free. It addresses a problem most people couldn’t see without DLP a DLP tool! Only when it started assisting with compliance (not that it was required) did the market start growing. Another example? How many of you encrypted laptops before you had to start reporting lost laptops as a data breach? On the vendor side, real innovation is a pain in the ass. It’s your pot of gold, but only after years of slogging it out (usually). Sometimes you get the timing right and experience a quick exit, but more often than not you either have to glom onto an existing market (where you’re fighting for your life against competitors that really shouldn’t be your competitors), or you find patient investors who will give you the years you need to build a new market. Everyone else dies. Some examples? PureWire wasn’t the first to market (ScanSafe was) and didn’t get the biggest buyout (ScanSafe again), but they timed it right and were in and out before they had to slog. Fidelis is forced to compete in the DLP market, although the bulk of their value is in managing a different (but related) threat. 7+ years in and they are just now starting to break out of that bubble. Core Security has spent 7 years building a market- something only possible with patient investors. Rumor is Palo Alto has some serious firewall and IPS capabilities, but rather than battling Cisco/Checkpoint, they are creating an ancillary market (application control) and then working on the cross-sell. Most of you don’t buy innovative security products. After paying off your maintenance and licens renewals, and picking up a few widgets to help with compliance, there isn’t a lot of budget left. You tend to only look for innovation when your existing tools are failing so badly that you can’t keep the business running. That’s why it looks like there’s no security innovation – it’s simply ahead of market demand, and without a market it’s hard to survive. Unless we put together a charity fund or those academics get off their asses and work on something practical, we lack the necessary incubators to keep innovation alive until you’re ready to buy it. So the question is… how can we inspire and sustain innovation when there’s no market for it? Or should we? When does innovation make sense? What innovation are we willing to spend on when there’s no market? When and how should we become early adopters? Share:

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Some DLP Metrics

One of our readers, Jon Damratoski, is putting together a DLP program and asked me for some ideas on metrics to track the effectiveness of his deployment. By ‘ask’, I mean he sent me a great list of starting metrics that I completely failed to improve on. Jon is looking for some feedback and suggestions, and agreed to let me post these. Here’s his list: Number of people/business groups contacted about incidents – tie in somehow with user awareness training. Remediation metrics to show trend results in reducing incidents – at start of DLP we had X events, after talking to people for 30 days about incidents we now have Y events. Trend analysis over 3, 6, & 9 month periods to show how the number of events has reduced as remediation efforts kick in. Reduction in the average severity of an event per user, business group, etc. Trend: number of broken business policies. Trend: number of incidents related to automated business practices (automated emails). Trend: number of incidents that generated automatic email. Trend: number of incidents that were generated from service accounts – (emails, batch files, etc.) I thought this was a great start, and I’ve seen similar metrics on the dashboards of many of the DLP products. The only one I have to add to Jon’s list is: Average number of incidents per user. Anyone have other suggestions? Share:

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Mogull’s Law

I’m about to commit the single most egotistical act of my blogging/analyst career. I’m going to make up my own law and name it after myself. Hopefully I’m almost as smart as everyone says I think I am. I’ve been talking a lot, and writing a bit, about the intersection of security and psychology in security. One example is my post on the anonymization of losses, and another is the one on noisy vs. quiet security threats. Today I read a post by RSnake on the effectiveness of user training and security products, which was inspired by a great paper from Microsoft: So Long, And No Thanks for the Externalities: The Rational Rejection of Security Advice by Users. I think we can combine these thoughts into a simple ‘law’: The rate of user compliance with a security control is directly proportional to the pain of the control vs. the pain of non-compliance. We need some supporting definitions: Rate of compliance equals the probability the user will follow a required security control, as opposed to ignoring or actively circumventing said control. The pain of the control is the time added to an established process, and/or the time to learn and implement a new process. The pain of non-compliance includes the consequences (financial, professional, or personal) and the probability of experiencing said consequences. Consequences exist on a spectrum – with financial as the most impactful, and social as the least. The pain of non-compliance must be tied to the security control so the user understands the cause/effect relationship. I could write it out as an equation, but then we’d all make up magical numbers instead of understanding the implications. Psychology tells us people only care about things which personally affect them, and fuzzy principles like “the good of the company” are low on the importance scale. Also that immediate risks hold our attention far more than long-term risks; and we rapidly de-prioritize both high-impact low-frequency events, and high-frequency low-impact events. Economics teaches us how to evaluate these factors and use external influences to guide widescale behavior. Here’s an example: Currently most security incidents are managed out of a central response budget, as opposed to business units paying the response costs. Economics tells us that we can likely increase the rate of compliance with security initiatives if business units have to pay for response costs they incur, thus forcing them to directly experience the pain of a security incident. I suspect this is one of those posts that’s going to be edited and updated a bunch based on feedback… Share:

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LHF: Quick Wins with DLP—the Conclusion

In the last two posts we covered the main preparation you need to get quick wins with your DLP deployment. First you need to put a basic enforcement process in place, then you need to integrate with your directory servers and major infrastructure. With these two bits out of the way, it’s time to roll up our sleeves, get to work, and start putting that shiny new appliance or server to use. The differences between a long-term DLP deployment and our “Quick Wins” approach are goals and scope. With a traditional deployment we focus on comprehensive monitoring and protection of very specific data types. We know what we want to protect (at a granular level) and how we want to protect it, and we can focus on comprehensive policies with low false positives and a robust workflow. Every policy violation is reviewed to determine if it’s an incident that requires a response. In the Quick Wins approach we are concerned less about incident management, and more about gaining a rapid understanding of how information is used within our organization. There are two flavors to this approach – one where we focus on a narrow data type, typically as an early step in a full enforcement process or to support a compliance need, and the other where we cast a wide net to help us understand general data usage to prioritize our efforts. Long-term deployments and Quick Wins are not mutually exclusive – each targets a different goal and both can run concurrently or sequentially, depending on your resources. Remember: even though we aren’t talking about a full enforcement process, it is absolutely essential that your incident management workflow be ready to go when you encounter violations that demand immediate action! Choose Your Flavor The first step is to decide which of two general approaches to take: Single Type: In some organizations the primary driver behind the DLP deployment is protection of a single data type, often due to compliance requirements. This approach focuses only on that data type. Information Usage: This approach casts a wide net to help characterize how the organization uses information, and identify patterns of both legitimate use and abuse. This information is often very useful for prioritizing and informing additional data security efforts. Choose Your Deployment Type Depending on your DLP tool, it will be capable of monitoring and protecting information on the network, on endpoints, or in storage repositories – or some combination of these. This gives us three pure deployment options and four possible combinations. Network Focused: Deploying DLP on the network in monitoring mode provides the broadest coverage with the least effort. Network monitoring is typically the fastest to get up and running due to lighter integration requirements. You can often plug in a server or appliance over a few hours or less, and instantly start evaluating results. Endpoint Focused: Starting with endpoints should give you a good idea of which employees are storing data locally or transferring it to portable storage. Some endpoint tools can also monitor network activity on the endpoint, but these capabilities vary widely. In terms of Quick Wins, endpoint deployments are generally focused on analyzing stored content on the endpoints. Storage Focused: Content discovery is the analysis of data at rest in storage repositories. Since it often requires considerable integration (at minimum, knowing the username and password to access a file share), these deployments, like endpoints, involve more effort. That said, it’s scan major repositories is very useful, and in some organizations it’s as important (or even more so) to understand stored data than to monitor information moving across the network. Network deployments typically provide the most immediate information with the lowest effort, but depending on what tools you have available and your organization’s priorities, it may make sense to start with endpoints or storage. Combinations are obviously possible, but we suggest you roll out multiple deployment types sequentially rather than in parallel to manage project scope. Define Your Policies The last step before hitting the “on” switch is to configure your policies to match your deployment flavor. In a single type deployment, either choose an existing category that matches the data type in your tool, or quickly build your own policy. In our experience, pre-built categories common in most DLP tools are almost always available for the data types that commonly drive a DLP project. Don’t worry about tuning the policy – right now we just want to toss it out there and get as many results as possible. Yes, this is the exact opposite of our recommendations for a traditional, focused DLP deployment. In an information usage deployment, turn on all the policies or enable promiscuous monitoring mode. Most DLP tools only record activity when there are policy violations, which is why you must enable the policies. A few tools can monitor general activity without relying on a policy trigger (either full content or metadata only). In both cases our goal is to collect as much information as possible to identify usage patterns and potential issues. Monitor Now it’s time to turn on your tool and start collecting results. Don’t be shocked – in both deployment types you will see a lot more information than in a focused deployment, including more potential false positives. Remember, you aren’t concerned with managing every single incident, but want a broad understanding of what’s going on on your network, in endpoints, or in storage. Analyze and PROFIT! Now we get to the most important part of the process – turning all that data into useful information. Once we collect enough data, it’s time to start the analysis process. Our goal is to identify broad patterns and identify any major issues. Here are some examples of what to look for: A business unit sending out sensitive data unprotected as part of a regularly scheduled job. Which data types broadly trigger the most violations. The volume of usage of certain content or files, which may help identify valuable assets that don’t cleanly match a pre-defined policy. Particular users or business units with higher numbers of

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LHF: Quick Wins in DLP, Part 2

In Part 1 of this series on Low Hanging Fruit: Quick Wins with DLP, we covered how important it is to get your process in place, and the two kinds of violations you should be immediately prepared to handle. Trust us – you will see violations once you turn your DLP tool on. Today we’ll talk about the last two pieces of prep work before you actually flip the ‘on’ switch. Prepare Your Directory Servers One of the single most consistent problems with DLP deployments has nothing to do with DLP, and everything to do with the supporting directory (AD, LDAP, or whatever) infrastructure. Since with DLP we are concerned with user actions across networks, files, and systems (and on the network with multiple protocols), it’s important to know exactly who is committing all these violations. With a file or email it’s usually a straightforward process to identify the user based on their mail or network logon ID, but once you start monitoring anything else, such as web traffic, you need to correlate the user’s network (IP) address back to their name. This is built into nearly every DLP tool, so they can track what network addresses are assigned to users when they log onto the network or a service. The more difficult problem tends to be the business process; correlating these technical IDs back to real human beings. Many organizations fail to keep their directory servers current, and as a result it can be hard to find the physical body behind a login. It gets even harder if you need to figure out their business unit, manager, and so on. For a quick win, we suggest you focus predominantly on making sure you can track most users back to their real-world identities. Ideally your directory will also include role information so you can filter DLP policies violations based on business unit. Someone in HR or Legal usually has authorization for different sensitive information than people in IT and Customer Service, and if you have to manually figure all this out when a violation occurs, it will really hurt your efficiency later. Integrate with Your Infrastructure The last bit of preparation is to integrate with the important parts of your infrastructure. How you do this will vary a bit depending on your initial focus (endpoint, network, or discovery). Remember, this all comes after you integrate with your directory servers. The easiest deployments are typically on the network side, since you can run in monitoring mode without having to do too much integration. This might not be your top priority, but adding what’s essentially an out of band network sniffer is very straightforward. Most organizations connect their DLP monitor to their network gateway using a SPAN or mirror port. If you have multiple locations, you’ll probably need multiple DLP boxes and have to integrate them using the built-in multi-system management features common to most DLP tools. Most organizations also integrate a bit more directly with email, since it is particularly effective without being especially difficult. The store-and-forward nature of email, compared to other real-time protocols, makes many types of analysis and blocking easier. Many DLP tools include an embedded mail server (MTA, or Mail Transport Agent) which you can simply add as another hop in the email chain, just like you probably deployed your spam filter. Endpoint rollouts are a little tougher because you must deploy an agent onto every monitored system. The best way to do this (after testing) is to use whatever software deployment tool you currently use to push out updates and new software. Content discovery – scanning data at rest in storage – can be a bit tougher, depending on how many servers you need to scan and who manages them. For quick wins, look for centralized storage where you can start scanning remotely through a file share, as opposed to widely distributed systems where you have to manually obtain access or install an agent. This reduces the political overhead and you only need an authorized user account for the file share to start the process. You’ll notice we haven’t talked about all the possible DLP integration points, but instead focused on the main ones to get you up and running as quickly as possible. To recap: For all deployments: Directory services (usually your Active Directory and DHCP servers). For network deployments: Network gateways and mail servers. For endpoint deployments: Software distribution tools. For discovery/storage deployments: File shares on the key storage repositories (you generally only need a username/password pair to connect). Now that we are done with all the prep work, in our next post we’ll dig in and focus on what to do when you actually turn DLP on. Share:

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Low Hanging Fruit: Quick Wins with Data Loss Prevention

Two of the most common criticisms of DLP that comes up in user discussions are a) its complexity and b) the fear of false positives. Security professionals worry that DLP is an expensive widget that will fail to deliver the expected value – turning into yet another black hole of productivity. But when used properly DLP provides rapid assessment and identification of data security issues not available with any other technology. I don’t mean to play down the real complexities you might encounter as you roll out a complete data protection program. Business use of information is itself complicated, and no tool designed to protect that data can simplify or mask the underlying business processes. However, there are steps you can take to obtain significant immediate value and security gains without blowing your productivity or wasting important resources. Over the next few posts I’ll highlight the lowest hanging fruit for DLP, refined in conversations with hundreds of DLP users. These aren’t meant to incorporate the entire DLP process, but to show you how to get real and immediate wins before you move on to more complex policies and use cases. Establish Your Process Nearly every DLP reference I’ve talked with has discovered actionable offenses committed by employees as soon as they turn the tool on. Some of these require little more than contacting a business unit to change a bad process, but quite a few result in security guards escorting people out of the building, or even legal action. One of my favorite stories is the time the DLP vendor plugged in the tool for a lunchtime demonstration on the same day a senior executive decided to send proprietary information to a competitor. Needless to say, the vendor lost their hard drives that day, but they didn’t seem too unhappy. Even if you aren’t planning on moving straight to enforcement mode, you need to put a process in place to manage the issues that will crop up once you activate your tool. The kinds of issues you need to figure out how to address in advance fall into two categories: Business Process Failures: Although you’ll likely manage most business process issues as you roll out your sustained deployment, the odds are high some will be of such high concern they will require immediate remediation. These are often compliance related. Egregious Employee Violations: Most employee-related issues can be dealt with as you gradually shift into enforcement mode, but as in the example above, you will encounter situations requiring immediate action. In terms of process, I suggest two tracks based on the nature of the incident. Business process failures usually involve escalation within security or IT, possible involvement of compliance or risk management, and engagement with the business unity itself. You are less concerned with getting someone in trouble than stopping the problem. Employee violations, due to their legal sensitivity, require a more formal process. Typically you’ll need to open an investigation and immediately escalate to management while engaging legal and human resources (since this might be a firing offense). Contingencies need to be established in case law enforcement is engaged, including plans to provide forensic evidence to law enforcement without having them walk out the door with your nice new DLP box and hard drives. Essentially you want to implement whatever process you already have in place for internal employee investigations and potential termination. In our next post we’ll focus more on rolling out the tool, followed by how to configure it for those quick wins I keep teasing you with. Share:

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  • If the content does not meet their needs, the licensee is not required to pay, and the research will be released without licensing or with alternate licensees.
  • Licensees may host and reuse the content for the length of the license (typically one year). This includes placing the content behind a registration process, posting on white paper networks, or translation into other languages. The research will always be hosted at Securosis for free without registration.

Here is the language we currently place in our research project agreements:

Content will be created independently of LICENSEE with no obligations for payment. Once content is complete, LICENSEE will have a 3 day review period to determine if the content meets corporate objectives. If the content is unsuitable, LICENSEE will not be obligated for any payment and Securosis is free to distribute the whitepaper without branding or with alternate licensees, and will not complete any associated webcasts for the declining LICENSEE. Content licensing, webcasts and payment are contingent on the content being acceptable to LICENSEE. This maintains objectivity while limiting the risk to LICENSEE. Securosis maintains all rights to the content and to include Securosis branding in addition to any licensee branding.

Even this process itself is open to criticism. If you have questions or comments, you can email us or comment on the blog.