Managing IT and data risk is a challenging job. When we outsource our IT, applications and data processing to third-parties more and more every day, managing that risk becomes almost impossible. No longer are our data and systems contained within an infrastructure that we have full control over. We now give vendors our data, and allow them to conduct operations on our behalf. 

The problem is, we don’t control their infrastructure, and we can never fully look under the hood to understand and vet their ability to protect our data and operations. We have to fully understand how important this issue is, and ensure we have the right governance, processes and teams to identify and mitigate any risks found in our vendors. No longer are our data and systems contained within an infrastructure that we have full control over

Today, everything is connected. Our own networks have Internet of Things (IoT) devices.  We have VPN connections coming in, and we aren’t always sure who is on the other end of that connection. It is a full-time job just to get a handle on our own risk. How much harder, and how much larger should our teams and budgets be, to truly know and trust that our vendors can secure those devices and external connections? 

For every device and application we have internally, it is very difficult to even keep an accurate inventory. Do all of our vendors have some special sauce that allows them to overcome the traditional challenges of securing internal and vendor-connected networks? They are doing the same thing we are – doing our best with the limited human and financial resources allocated by our organisation.

Risk stratification and control objectives 

The benefits of outsourcing operations or using a vendor web application are clear. So how can we properly vet those vendors from an IT risk perspective? 

The very first thing we need to put in place is Risk Stratification. Risk Stratification presents a few targeted questions in the purchasing process. These questions include – what type of data will be shared? How much of this data? Will the data be hosted by a vendor? Will this hosting be in the US or offshored? Has the vendor ever had a data breach? These questions allow you to quickly discern if a risk assessment is needed and if so, what depth and breadth.  Risk stratification allows you to make decisions that not only improve your team’s efficiency, but also ensure that you are not being a roadblock to the business

Risk stratification allows you to make decisions that not only improve your team’s efficiency, but also ensure that you are not being a roadblock to the business. With risk stratification, you can justify the extra time needed to properly assess a vendor’s security. 

And in the assessment of a vendor’s security, we have to consider what control objectives we will use. Control objectives are access controls, policies, encryption, etc. In healthcare, we often use the HITRUST set of control objectives. In assessing against those control objectives, we usually use a spreadsheet. 

Today, there are many vendors who will sell us more automated ways to get that risk assessment completed, without passing spreadsheets back and forth. These solutions are great if you can get the additional budget approved. 

Multi-factor authentication 

Even if we are using old-fashioned spreadsheets, we can ensure that the questions asked of the vendor include a data flow and network/security architecture document.  We want to see the SOC2 report if they are hosting their solution in Amazon, etc. If they are hosting it within their own datacentre, we absolutely want to see a SOC2 Type II report. If they haven’t done that due diligence, should that be a risk for you? 

Today, we really need to be requiring our vendors to have multi-factor authentication on both their Internet-facing access, as well as their privileged internal access to our sensitive data. I rate those vendors who do not have this control in place as a high risk. We’ve recently seen breaches that were able to happen because the company did not require administrators or DBAs to use a 2-factor authentication into sensitive customer data sources. 

data risk hospital security HITRUST
In the assessment of a vendor’s security, one has to consider what control objectives to use

This situation brings up the issue of risk acceptance. Who in your organisation can accept a high risk? Are you simply doing qualitative risk assessment – high, medium and low risks? Or are you doing true quantitative risk analysis? The latter involves actually quantifying those risks in terms of likelihood and impact of a risk manifesting, and the dollar amount that could impact your organisation.  

So is it a million dollars of risk? Who can accept that level of risk? Just the CEO? These are questions we need to entertain in our risk management programs, and socialised within your organisation. 

This issue is so important – once we institute risk acceptance, our organisation suddenly starts caring about the vendors and applications we’re looking to engage.  If they are asked to accept a risk without some sort of mitigation, they suddenly care and think about that when they are vetting future outsourced solutions. Quantitative risk analysis involves quantifying risks in terms of likelihood and impact of a risk manifesting

Risk management process 

In this discussion, it is important to understand how we think of, and present, the gaps we identify in our risk management processes. A gap is not a risk. If I leave my front door unlocked, is that a control gap or a risk? It is a gap – an unlocked door. What is the risk? 

The risk is the loss of property due to a burglary or the loss of life due to a violent criminal who got in because the door was unlocked. When we present risks, we can’t say the vendor doesn’t encrypt data. The risk of the lack of encryption is fines, loss of reputation, etc. due to the breach of data. A gap is not a risk. 

Once we’ve conducted our risk analysis, we must then ensure that our contracts protect our organisation? If we’re in healthcare, we must determine if the vendor is, in fact, a true HIPAA Business Associate, and if so we get a Business Associate Agreement (BAA) in place. I also require my organisation to attach an IT Security Amendment to these contracts. The IT Security Amendment spells out those control objectives, and requires each vendor to sign off on those critical controls. We are responsible for protecting our organisation’s IT and data infrastructure – today that often means assessing a 3rd-party’s security controls

One final note on risk assessments – we need to tier our vendors. We tier them in different ways – in healthcare a Tier 1 vendor is a vendor who will have our patient information on the Internet. Tiering allows us to subject our vendors to re-assessment. A tier 1 vendor should be re-assessed annually, and may require an actual onsite assessment vs. a desk audit. A tier 2 vendor is re-assessed every 2 years, etc.

We are responsible for protecting our organisation’s IT and data infrastructure – today that often means assessing a 3rd-party’s security controls. We must be able to fully assess our vendors while not getting in the way of the business, which needs to ensure proper operations, financial productivity and customer satisfaction. If we truly understand our challenge of vendor risk management, we can tailor our operations to assess at the level needed, identify and report on risks, and follow-up on any risks that needed mitigated.

Share with LinkedIn Share with Twitter Share with Facebook Share with Facebook
Download PDF version

Author profile

Randall Frietzsche Distinguished Fellow, Information Systems Security Association (ISSA)

Randall Frietzsche is the Enterprise CISO for Denver Health.  Randall has been a leader in IT Security for ten years, with 15 years in IT Security and over 20 years in Information Technology.  He is a Distinguished Fellow with the Information Systems Security Association (ISSA.)  Randall holds a Master’s Degree in Information Security, the CISSP and 25 other Security, IT and other technical certifications.  He teaches cybersecurity both for Harvard University and Ivy Tech State College.  He is a former law enforcement officer, and a recent graduate of the FBI Citizen’s Academy.  Randall is a frequent speaker, writer, teacher and mentor.

In case you missed it

Which technologies will disrupt the security industry in the second half of 2020?
Which technologies will disrupt the security industry in the second half of 2020?

The first half of 2020 has been full of surprises, to say the least, and many of them directly impacted the physical security market. The COVID-19 pandemic created endless new challenges, and the physical security market has done our part to meet those challenges by adapting technology solutions such as thermal cameras and access control systems. In the second half of 2020, we can all hope for a return to normalcy, even if it is a “new normal.” In any case, technology will continue to play a big role. We asked this week’s Expert Panel Roundtable: Which technologies have the greatest potential to disrupt the security industry in the second half of 2020?

What do you need to know about thermal imaging cameras?
What do you need to know about thermal imaging cameras?

As businesses, schools, hospitals and sporting venues look to safely reopen in a COVID-19 world, thermal imaging systems will play a critical role in helping to detect and distinguish skin temperature variations in people. Thermal surveillance, a mainstay of traditional physical security and outdoor perimeter detection, is now being deployed to quickly scan employees, contractors and visitors as part of a first line of defense to detect COVID-19 symptoms. In the coming weeks and months, the security industry will look to implement thermal camera solutions for customers, yet many questions remain as to the differences between different system types and how to properly install thermal imaging cameras. In this Q&A, Jason Ouellette, Head of Technology Business Development for Johnson Controls, answers several of these questions. Q: What are some of the different thermal imaging solutions available in the market to detect an elevated temperature in a person? For the general market, there are three types of these thermographic screenings. There is the handheld device, which is typically lower cost, very portable, and very easy to use. Typically, this is a point and shoot type of device, but it requires you to be three feet or less from the person that you're screening, which, in today's world, means the user needs to wear protective personal equipment. For the general market, there are three types of these thermographic screenings The second type of solution would best be described as a thermal camera and kiosk. The advantage of this system over a handheld device is this can be self-service. An individual would go up to and engage with the kiosk on their own. But many of these kiosk type solutions have some integration capability, so they can provide some type of output, for either turnstiles, or physical access control, but not video management systems (VMS). Some of the downside of this type of system is that it’s less accurate than a thermographic solution because it does not have a blackbody temperature calibration device and the readings are influenced by the surrounding ambient temperature, called thermal drift. So instead of being able to achieve a ±0.3ºC accuracy rating, this system probably provides closer to ±0.5ºC at best. Some of these devices may be classed as a clinical thermometer with a higher degree of one time accuracy, but do not offer the speed and endurance of the thermographic solution for adjunctive use. And then there are thermal imaging camera systems with a blackbody temperature calibration device. These types of systems include a dual sensor camera, that has a visual sensor and a thermal sensor built right into the camera, along with a separate blackbody device. This provides the highest degree of ongoing accuracy, because of the blackbody and its ability to provide continuous calibration. These systems can provide much more flexibility and can offer integrations with multiple VMS platforms and access control devices. Q: When installing a thermal imaging camera system what is the most important element to consider? Camera placement is critical to ensure the system works as expected, however the placement of the blackbody device which verifies the correct calibration is in place is equally as important. If the customer wants to follow FDA medical device recommendations for camera placement, both the height of the camera and the blackbody as well as the distance between these devices should comply with the product installation instructions. This takes into account the device focal range and calibration parameters in addressing the distance from the person undergoing the scan. Also, integrators should minimise camera detection angles to ensure optimal accuracy and install cameras parallel with the face as much as possible, and again in compliance with installation instructions. Integrators should minimise camera detection angles to ensure optimal accuracy The blackbody should be placed outside of the area where people could block the device and located more towards the edges of the field-of-view of the camera. You need to keep in mind the minimum resolution for effective thermographic readings which is 320 by 240 pixels as defined by the standards. To achieve this, you would need to follow medical electrical equipment performance standards driven by IEC 80601-2-59:2017 for human temperature scanning and FDA guidelines. Within that measurement, the face needs to fill 240 x 180 pixels of the thermal sensor resolution, which is close to or just over 50 percent of the sensor’s viewing area typically, meaning a single person scanned at a time in compliance with the standards for accuracy.  Along with height and distance placement considerations, the actual placement in terms of the location of the system is key. For example, an expansive glass entryway may impact accuracy due to sunlight exposure. Installations should be focused on ensuring that they are away from airflow, heating and cooling sources, located approximately 16 feet from entry ways and in as consistent of an ambient temperature as possible between 50°F and 95°F. Q: Once a thermal imaging camera system is installed, how do you monitor the device? There are several choices for system monitoring, depending on whether the solution is used as standalone or integrated with other technologies, such as intrusion detection, access control or video systems. For standalone systems, the ability to receive system alerts is typically configured through the camera’s webpage interface, and the cameras include abilities such as the live web page, LED display for alerting, audio alerts and physical relay outputs. When done right, these features will all follow cybersecurity best practices which is important for any network solution today, including changing default passwords and establishing authentication methods. The ability to receive system alerts is typically configured through the camera’s webpage interface These types of thermal cameras can also integrate with turnstile systems, VMS platforms and access control systems. This is typically done through the integration of a relay output, activated by a triggered temperature anomaly event on a thermal imaging camera which can then be used for activities such as locking a turnstile, or through access control and video systems to send an email or provide an automated contagion report for contact tracing. These capabilities and integrations extend the monitoring capability above that of the standalone solution. The camera can be configured to monitor a specific range of low and high alerts. Users can determine the actions that should be taken when that alert exceeds the preset low or high threshold. These actions include things like a bright and easy-to-see LED can provide visual notification through pulsing and flashing lights as an example. Q: What about system maintenance? Does a thermal imaging camera require regular service in order to operate accurately? First it’s important to make sure the system is calibrated. This can be done after the unit stabilises for at least 30 minutes to establish the initial reference temperature source known as the blackbody. Calibrations conducted before this warm up and stability time period can throw off accuracy. Also, as part of your system maintenance schedule you will want to perform a calibration check of the blackbody device every 12 months, along with following recommendations of the FDA and IEC. If you install the solution and don’t perform maintenance and the blackbody calibration certificate expires, over time there’s a risk that the device will experience drift and a less accurate reading will result. There’s a risk that the device will experience drift and a less accurate reading will result Q: What final pieces of advice do you have for either an integrator who plans to install a thermal imaging camera system or an end user who plans to invest in this solution? Before you buy a thermal imaging camera check to see if the manufacturer ships the camera with a calibration certificate. Also, become familiar with FDA’s guidance released in April 2020, Enforcement Policy for Telethermographic Systems During the Coronavirus Disease 2019 (COVID-19) Public Health Emergency. This document places thermal/fever products for adjunctive use under the category of a Class I medical devices and subject to its regulatory control. Driven by these regulations and categorisation, users need to understand specifically what is required to meet the required level of accuracy for successful detection. While thermal imaging camera systems are more complex than traditional surveillance cameras, they can prove to be a valuable resource when set up, configured and maintained properly.

Recognising the importance of security officers to promote safety
Recognising the importance of security officers to promote safety

The general public doesn’t give much thought to the important role of security officers in creating and promoting safer environments. The low-profile work of security officers is vital to protecting people, places and property. During the pandemic, newer aspects to that role have emerged. Security personnel have been called on to perform diverse tasks such as managing queues at the supermarket, safeguarding testing centres and hospitals, ensuring food deliveries, and supporting police patrols. The British Security Industry Association (BSIA) and two other organisations in the United Kingdom are joining forces to raise awareness of the work of security officers and to recognise the vital importance of the duties they perform. BSIA, a trade association, includes members who are responsible for 70% of privately provided UK security products and services, including security guarding, consultancy services, and distribution and installation of electronic and physical security equipment. BSIA, the Security Institute and the Security Commonwealth Joining BSIA in the awareness campaign are the Security Institute, a professional security membership body; and the Security Commonwealth, which is comprised of 40 organisations from across the security landscape with common objectives to build professionalism, raise standards and share best practices. “The recognition of security officers as key workers is the start of a re-appraisal of what service they provide to the community in keeping the public safe and secure,” says Mike Reddington, BSIA Chief Executive. “As we exit lockdown and have to navigate public spaces again, [security officers] will have a crucial role in supporting public confidence. We are working closely with the Police and all other public bodies to find the best way to achieve this.” Security officers acknowledged as key workers The campaign will showcase security professionals as a respected, valued, professional service provider and a key worker that is acknowledged and embedded in daily lives. The British Security Industry Association (BSIA) and two other organisations in the United Kingdom are joining forces to raise awareness of the work of security officers “Great effort has been invested in the professional standards and capabilities of frontline [security] officers, and they have proven their worth during the coronavirus crisis in the UK,” says Rick Mounfield, Chief Executive, the Security Institute. “They, along with the wider security sector, deserve to be recognized, respected and appreciated for the safety and security they provide across the United Kingdom.” “[We are working to] build professionalism, raise standards and share best practices, and I hope this campaign can make more people recognise the changes we have all made and continue to make,” says Guy Matthias, Chairman of the Security Commonwealth (SyCom). The industry will be reaching out to companies, professionals, and organisations in the sector to participate in the campaign. The hope is that, over the coming weeks as lockdown is eased, the industry can play its part to ensure that the country emerges with confidence to start to recover and build for the future. Private security more important than ever The campaign will showcase security professionals as a respected, valued, professional service provider Across the pond in the United States, law enforcement professionals are facing a crisis of confidence during a time of civil unrest as protestors call to “defund the police” and to otherwise undermine and/or recast law enforcement’s role in preserving the peace and ensuring public safety. If an upshot is that public policing is starved of resources, the role of private security to supplement their mission is likely to increase. In short, the role of private security is more important than ever on both sides of the Atlantic. Public recognition of that role is welcome, obviously. In any case, the importance of their role protecting people, places and property has never been greater.