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Originally posted on Corporate Compliance Insights on September 27, 2019
There’s a natural desire among humans to simplify and encapsulate an event with a clear antagonist upon whom we (the royal “we”) heap the blame. This notion is illustrated by two recent cyber events in particular, and this oversimplification leads to a false sense of security and completely misses the issues that led to these types of events in the first place.
For example, the cause of the Desjardins breach in June was described as a staffer who had shared personal information of 2.7 million people. “Shared?” Talk about a euphemism! And the more recent Capital One breach was, according to the company, tied to “an outside individual who gained unauthorized access and obtained certain types of personal information about Capital One credit card customers and applicants.” Again, it’s a simplification. The person was arrested. Case closed.
But the case isn’t closed. It’s barely open.
Author Sidney Dekker captures two views of human error (or in this case, intentional actions) in his book, The Field Guide to Human Error. Human error is often targeted as the cause of incidents, but by chalking incidents up solely to human error, we stop investigating other factors around the human at the center of it, such as their environment, their employer’s policies, employee training, security controls, social requirements, political and workplace pressures, budget and resourcing decisions, etc. These factors are called systemic factors.
What’s more, we tend to bring three biases to these examinations, particularly how we respond to errors and mistakes.
So, back to the financial firms I mentioned in the beginning.
Desjardins blames a rogue employee, which by inference exonerates the company’s actions and systems. But should those be exonerated? What controls were put in place? How did the rogue employee conduct their nefarious business without detection? That’s where the focus needs to be. It’s the same for Capital One. Criminal was arrested; case closed.
But beyond our convenient avoidance of looking at the bigger picture, we seek justice. The criminal was arrested and (we assume) will be convicted and sentenced. And the insider employee was terminated. The problem is, of course, the real issues haven’t been addressed. Terminating the employee or a vendor that led (or contributed) to the breach only provides a short-term reward, and it creates longer-term headaches.
Terminating the culprit will likely shift their priority to self-defense. Similarly, terminating a business contract that bound the vendor to the client will likely shift the vendor’s focus to avoiding legal liability, which makes them less open and cooperative when it comes to the investigation. In fact, a study of 650 security and IT professionals indicated that 44 percent of their companies experienced a material breach at the hands of their vendors, and about 49 percent terminated the contract. It’s the “ready, shoot, aim” approach. Organizations should worry less about getting back at the culprit and more about protecting their business and ensuring a future repeat of the breach doesn’t occur.
So how do we overcome our innate biases and get to the root causes? In other words, how do we learn from our mistakes instead of continually repeating them?
We can learn from the airline industry. The National Transportation Safety Board (NTSB) investigates incidents and makes recommendations that the Federal Aviation Authority (FAA) then mandates throughout the industry, creating an ever-improving cycle of air travel safety. Perhaps due to the life-and-death nature of airline safety, we as a society demand this safety net. When will we do the same when it comes to the ubiquitous and destructive financial and personal consequences of a data breach? This isn’t about blame. This is about continuous improvement and protecting consumers’ rights and privacy.
Will we ever get to the point where we conduct public inquiries into major security events? There are a lot of barriers to cross. First, no company wants its shortcomings spilled out on the floor of public investigation, and their lawyers will fight to ensure such liability-creating issues aren’t exposed to the light of day. It will take government to legislate and mandate such investigations beyond what the Federal Trade Commission does today. For example, check out the Equifax findings. These findings provide specific measures that the FTC mandates the company to adopt. What it doesn’t do is look at trends and correlate issues to develop simple-to-understand guidelines for companies to follow and for consumers to use as a guide to their rights.
Change will take a long time. And given the fact that these breaches already affect hundreds of millions of consumers, but change has yet to occur, it’s hard to imagine the magnitude of the event that will overcome our lethargy and tendency to continue accepting these breaches and their financial consequences. Examining our own biases is a start, though. It’s time to stop blaming one person and look deeper at the systemic causes.
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