Legal Strategies When Executing a Distributed Workforce Strategy

July 15, 2020

In a short period there has been a monumental push for remote working arrangements by almost every existing organization. As a result of the Coronavirus outbreak, our calendar has been filled with appointments to discuss the practical considerations and steps that every leadership team is facing, from executive to technology, including application and business stakeholders. This incident has brought on evaluations of an organization’s readiness through the lens of business continuity, incident response, and more expansive administrative, technical, and physical safeguards.

While not exhaustive, below is a list of some areas to consider in executing a distributed workforce strategy:

Principle of Least Privilege - Has the organization operationalized a principle of least privilege? Does this extend to your remote access management? Opening the floodgates to all end users at once is neither practical nor safe. Discuss a tiered approach and where preventative controls are not possible or practical, implement detective controls. This would look like automated log management, reviews, and analytics to identify anomalous behavior on networks or systems that are classified as mission critical or that handle the most critical data. Take a risk based approach to identity access management and consider a more restrictive policy, you can remind your user base this is a temporary measure. From a security perspective, your objective is to narrow the threat surface; remember the security triad -Confidentiality, Integrity and Availability.  

Remote Desktop Protocol -  Now is the time to check your remote access configurations. We are sure to see a significant uptick in cyber incidents exploiting enabled ports that are commonly used for remote access, this is the point that is frequently the way of entry for ransomware attacks. Audit your network and if you haven’t already, identify servers and devices with ports 22 (SSH), 23 (Telnet), and 3389 (RDP) enabled. Once identified, and where permitted based on your unique circumstances, immediately close port 23 on all systems as well as any unnecessary SSH and RDP ports. It was only a year ago we witnessed Bluekeep, the security vulnerability that allowed for remote code execution through RDP.  

Data in Transit and At-Rest - Revisit your organization’s encryption standards as they apply to data in transit and at rest. With an expanded workforce now remote and handling sensitive and non-public data, an encrypted data at rest conversation should be at the top of your discussion list. The NY SHIELD Act, which became effective March 21st, expands upon the definition of private information to include personal information in combination with various listed data elements (refer to NY Senate Bill S5575B) that “were not encrypted” or “was encrypted with an encryption key that was accessed or acquired.” For financial institutions the FFIEC, which prescribes uniform principles and standards, states that institutions should employ encryption to mitigate the risk of disclosure or alteration of sensitive information in storage and transit.

Password Strength and Two-Factor Authentication - Replace any default or weak login credentials with passphrases. Roughly two years ago the National Institute of Standards and Technology (NIST) published a guidance on this and organizations have been slow to adopt passphrases in place of their typical 8 character passwords. Now is a good time to implement passphrases and communicate this as a necessary response to the recent distributed workforce requirement. Similarly, you should also consider revisiting screensaver and session lockout times, remember, this is about narrowing the threat surface. If you can shorten these times by 5 minutes, the compounding effect across say, 1,000 employees, could be 5,000 minutes of time or 83 hours. That’s 83 hours less time a bad actor has to compromise your devices. In addition, consider looking at failed login attempt configurations, you can adjust this setting to lock an account on less attempts than usual. This can be a temporary measure until your workforce return to the office setting.

Communication – The question which has come up the most has been regarding communication while working remote. Workforce will need to be informed as they transition to remote. Organizations will need to remind their workforce of what is expected of them as it pertains to policies such as acceptable use, BYOD, information security, business continuity, disaster recovery, and incident response. Similarly, the workforce should also be reminded of safe security practices in the home (for example, when was the last time they updated their router firmware?) While company-wide communications will be necessary, tailored communications to various departments may be equally important. For example, the Incident Response Team leader should communicate regularly with all stakeholders. They will need to review the Incidence Response Plan to evaluate whether the procedures have limitations based on physical proximity of all parties with responsibilities. Likewise, physical security may have unique requirements since the offices will largely be empty.  

The push to remote work has forced organizations to revisit their control environments, operational workflows, and technical capabilities. This is an exercise that requires input and coordination across the organization and highlights the importance of a policy governance structure.  

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