Maintaining Rational Policies in the Face of Failure

Posted by Frank Milia

May 29, 2019 2:48:09 PM

When we fail in life, especially at our security, we tend to overreact and make quick and sweeping changes.  If you leave your door open and your home is burglarized, moving out of your neighborhood or installing a state of the art security system may be an irrational response compared to locking your doors from now on. When implementing changes, it is important to address the specific cause of the failure and not let fear of reoccurrence cloud the way you make improvements.         

When organizations uncover regulatory data protection non-compliance or suffer the consequences of an outright data breach, many times they struggle to implement corrective actions that address the root cause of the issue or otherwise implement new policies that can adversely affect the business and fail to focus on addressing the deficiency head on.   Security, IT, and compliance stakeholders need to stay focused on resolving the cause of an issue and not be distracted by fear or be rushed into implementing hastily designed corrective actions.  

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To illustrate this point I will provide a common scenario I have witnessed from clients that I provide data disposition and regulatory compliance consulting as well as IT asset disposition and data destruction services to.       

Scenario:

A large financial institution has internal policies and procedures to perform erasure of hard drives prior to performing lease returns and disposal of retired assets.  The firm is notified that a shipment back to a vendor contained drives that were not wiped. The drives were encrypted so at the time of this event there were no regulations in the USA that would consider this event a breach requiring disclosure.  However, the company’s internal policies and procedures were not followed therefore an investigation and corrective action was required by internal stakeholders. 

The company identified the risk was from allowing erasure and reuse of the hard drives and implemented a new policy and procedure that all hard drives would now have to be physically destroyed before disposal or lease return.  Although one could argue that this approach makes sense considering the high cost and risk of a data breach, it is actually a flawed response that does not address the root cause of the non-conformity (an employee’s actions failed to adhere to company policy). 

When I analyze and investigate events like this, common root causes tend to include:

  1. Technician(s) failed to erase and document erasure as designed and provided in existing management system
  2. Management system failed to assign accountability of such events
  3. Technician(s) not properly trained or no documented training sessions found
  4. Routine audit of applicable work not practiced
  5. Process for erasure and equipment returns failed to have redundancies, spot checks, and/or verification steps to ensure compliance
  6. Inadequate managerial oversight or approval system in place for data destruction and return management
  7. Detailed processes and work flow procedures poorly documented or none in writing found

The client’s response to require on-site destruction of all media does not address any of the issues noted above.  The firm can change the method, destruction tool, and policy but without addressing the core deficiencies in the management system, procedures, training, and redundancies the threat of a non-conformity or event that leads to a data breach remains. 

Not only has the firm made a policy change that will cost millions of dollars in lost revenue from resale and increased lease return fees but they have also done little to reduce the risk stemming from the lack of accountability and the imperfect system that lead to a technician shipping a device with live data still residing on the hard drive.   This same flawed system left unchanged, other than method of destruction, will likely lead to a technician again shipping a device with a hard drive (not wiped or physically shredded).   

Security is too often judged as a consensus of feelings. Many times even the most sophisticated organizations and experienced practitioners will make irrational policies based on how a policy makes them feel.  In this case although the financial firm’s policy to destroy the drives does not address the root-cause, it does make them feel more secure now that all drives will be destroyed.  Organizations incorrectly choose abrupt and elementary policy changes rather than more complicated procedural updates that require greater oversight and investment but will more effectively address deficiencies.          

As security professionals we need to analyze the logical and empirical security deficiencies, prescribe solutions based on the root causes, assign accountability and test and evaluate our systems and programs all the while taking care to prove the value of such investment to the business’s stakeholders.  When changing policies in the face of failure, it is important to remove fear from the equation and focus on addressing the problem with a clear mindset. 

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Topics: education & tips, IT Best Practices, IT Management, Risk Management, Information Security

Add NIST 800-88 to Your DoD Data Destruction Playbook

Posted by Frank Milia

Oct 9, 2017 3:00:25 PM

It’s time your IT asset disposal program manager ditches a murky understanding of DoD data destruction(Department of Defense 5220.22-M) by adding a clearer understanding of the NIST 800-88 (National Institute of Standards and Technology 800-88 Guidelines for Media Sanitization).

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The DoD data destruction standard does not provide the adequate specifics an organization or business will require in order to run a secure program in a real world operation. The DoD does provide broad guidelines that should be adhered to by any organization maintaining or disposing of sensitive data.

The NIST 800-88 Guidelines, however, provides a detailed roadmap for creating a data destruction program built on the principles of identifying risk, life cycle stage of media, selecting and implementing appropriate methods of destruction, verifying and overseeing success, and documenting procedures and work performed.

“We perform DoD data destruction” has been a mantra of the ITAD (IT asset disposal) industry for well over a decade. But when one pushes for more specifics from a vendor or program manager one is likely to find inconsistent interpretations of the standard from a belief that it exclusively refers to three pass binary wiping, seven pass binary wiping, to a misconception that only physical shredding and pulverization of media can achieve data security.

In reality the DoD data destruction method does have recommended standards for two step erasure of drives using a clear and binary pass overwriting. It also includes basic standards for the removal of physical identifiers, chain of custody documentation, and physical destruction of optical media. The DoD standard does not recommend any specific tools, software, machinery, or provide any types of certifications to vendors or products.

The NIST 800-88 provides a clear manual that guides IT professionals to select the appropriate tool by the life cycle, risk level, and type of media. For example the document points out that a degausser should never be used for solid state media. Since SSD media is not magnetic media the degausser would not destroy the data on the chip sets. This type of granular knowledge is a must have for every IT asset manager.

Here at ITAMG we help our clients understand the NIST 800-88 model and how to develop custom programs that address unique business, industry, and regulatory compliance requirements.  

For more information on appropriate methods and documentation of data destruction practices please review our short guide to NIST 800-88.

Download 5 Data Destruction Tips

 

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Topics: IT Asset Disposal, data destruction, NIST 800-88, eWaste Disposal, Risk Management, hard drive disposal, dod data destruction

Bidding a Project to Computer Liquidators

Posted by Frank Milia

Sep 18, 2017 9:14:26 AM

If your IT department generates valuable surplus computer equipment whether through a regular refresh project, office relocation, staff reduction or merger it will be helpful to understand how to bid out an IT asset disposal project to computer liquidators.


We suggest contracting a prime source for ongoing IT asset disposal services, but from time to time it may be required to get a fixed bid on excess IT assets. In this post we will be providing a few tips on how to solicit offers in a way that will fairly evaluate capable vendors.

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1. Qualify a list of bidders before distributing a Request for Proposal. Do not waste time taking offers from vendors that do not meet your company’s security, environmental compliance, or risk assessment requirements. When researching vendors and compiling a list of potential bidders weed out any vendors that do not meet your internal requirements. We suggest only bidding projects to vendors with third party certifications such as ISO 14001, Responsible Recycling (R2), and e-Stewards certification.

2. Create a spec sheet for the equipment that you will be bidding out, including an accurate estimate of the quantity of machines by locations. As an example for a desktop, note the make, model, processor model, RAM configurations, hard drive type and size, and form factor. Sometimes providing a service tag or part number will be enough, but to avoid potential issues from discrepancies it is best to have all bidders on the same page at day one of bidding. For a vendor to include all shipping and packaging costs in an offer they will need to know how many units and where the units are located.

3. Create a fixed timeline to receive accurate pricing. Provide bidders with a deadline for bids and what day the equipment will be released and ready for pickup. Most vendors will have an expiration date for competitive offers. A long timeline for a sale puts the vendor and your organization at risk of a bid expiring and the depreciation of the market effecting value returns for all parties. Reduce your company’s exposure by providing accurate timelines and rebidding if the timelines are not met.

4. Make sure all service level requirements are specified at the time of bid. Clearly outline any packaging services, de-racking, wiring, on-site data destruction, or any other services that will come at a cost to your company or vendor at the time of the bid. In order to fairly evaluate vendors one needs to avoid selecting a vendor and then finding out that there are additional costs and reductions to the value back because the requirements of the equipment sale were not clearly specified at the bidding.

Following these guidelines will help you seamlessly sell surplus IT equipment.

Looking for a tool to get the most value back on your company's IT disposals?

Download the ITAMG Inventory Template Today:

Tips & Inventory Template

 

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Topics: IT Asset Disposal, IT Asset Disposition, eWaste Disposal, Risk Management, IT Liquidation

Three Quick IT Liquidation Tips

Posted by Frank Milia

Aug 1, 2017 10:25:22 AM

Evaluating an IT liquidation provider to purchase your corporate IT equipment can be a difficult task to accomplish. There are a good deal of variables that can lead an IT manager down a path where he or she will be unable to accurately evaluate competitive quotes, incur unnecessarily high service costs, or set incorrect expectations of value returns that will not be achieved at the end of a project.

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Here are some quick tips to make you aware of potential pitfalls and help you eliminate these variables.


1. Know what you’re selling. Having a good understanding and detailed inventory of the models, specs, functional conditions, and cosmetic conditions of your equipment is the most empowering tool you will have available in the process. The more details and assurances you’re able to provide to a vendor the more comfortable and competitive the solution the ITAD provider will be able to offer. Its understandable most IT departments will not have the resources to test equipment and note cosmetic issues on every machine, but if you’re aware of equipment defects and issues provide this information to your IT liquidation vendor and get an understanding of what the cost reductions will be ahead of executing the project.


2. Understand your service level requirements. Make sure to provide all IT liquidators bidding on your project with detailed information on what data destruction service level, packaging requirements, building access requirements, shipping requirements, or any other data and asset management requirements you may have. This can be particularly important when the service level will affect the value of the equipment. For example, if you choose to require a vendor to shred the hard drives from a laptop liquidation there be additional costs for the destruction services and the machines’ overall value will be decreased from removing the hard drives.


3. Set a rigid time frame for the project. The secondary markets fluctuate rather quickly and most IT disposal vendors will not be willing to hold aggressive return rates in effect for longer than 10 business days. Keep in mind that if you’re planning a project 30-90 days out to set these expectations upfront so the vendors are able to give realistic pricing that can be met. We suggest in these situations to get the IT asset recovery estimate from vendors early in the planning stage and qualify capable providers. You can then re-price the project and make final decisions closer to the release of the equipment.

Having a good understanding of your disposal inventory, conditions of the equipment, service levels required, and time frame of project will allow you to control the process and meet the expectations set with your IT asset disposal vendor.

Looking for a tool to get the most value back on your company's IT disposals?

Download the ITAMG Inventory Template Today:

Tips & Inventory Template

 

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Topics: IT Asset Disposal, IT Asset Disposition, eWaste Disposal, Risk Management, IT Liquidation

Hard Drive Disposal Options

Posted by Frank Milia

Jun 2, 2017 12:38:46 PM

Proper handling of end of life computer equipment and electronic media is critical to avoiding costly data breaches and debilitating exposures to your business and client data.  Your options for hard drive disposal should not be limited by archaic security policies, vendor capabilities, or lack of in-house expertise or access to industry leading tools.    

The below is a quick guide to the common tools and methods utilized by sophisticated IT asset disposal providers and IT departments alike. 

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Binary wiping and secure erasure:

Many times referred to as Department of Defense (DoD) three pass erasure, secure erasure writes multiple passes of binary code over a drive’s data to eliminate the path to the data.  The term DoD erasure is an asset disposal industry and IT shorthand and it should be noted that no software or erasure method is specifically endorsed by the DoD.  The method is a commonly accepted software tool for destroying data on magnetic and solid state media.

Having a contracted erasure service or in-house capability to securely erase machines is ideal to reuse machines in your environment, sell machines to a computer liquidator at optimum value, and ship or relocate machines that are not encrypted. 

Enterprise erasure tools should include reporting and verification utilities that allow organizations to save detailed certificates of destruction to the NIST 800-88 standards as well as identify drives that do not wipe to one hundred percent satisfaction.  When drives fail to wipe securely the user can quarantine and use another physical destruction method. 

DoD erasure is a method approved in the NIST 800-88 Guidelines for Media Sanitization in certain situations, but is not recommended for media that has higher risks associated to an exposure or contains top secret data. 

Hard Drive Shredding and Media Pulverization

Hard drive pulverizing or media shredding are terms commonly used for the industrial shredding of electronic media.  Although the equipment can be expensive for many business to own and maintain, many organizations utilize the method with the help of various asset disposal or document shredding service providers.  This method is ideal for quickly and cost effectively destroying large quantities of hard drives, optical media, flash drives, and other electronic storage. 

Hard drive shredding can be performed off-site at a vendor’s facility or on-site utilizing specialty shredding equipment typically deployed by the tier one IT asset disposal providers like IT Asset Management Group. 

Hard Drive Punching

Smaller machinery like hard drive punchers are ideal for eliminating the risk of shipping live and accessible data by first punching the drives before shipping or relocating the drives for the final shredding and recycling process.  Punchers are utilized where the large footprint of a shredder would not be possible or cost effective.  This method is ideal for small quantities of drives and is typically not cost or time effective for the destruction of large quantities of media.

Much like hard drive shredders there are hundreds of different kinds of hard drive punchers and some are not as effective for solid state drives or other types of media.  It is important to research and understand what a specific machine or service provider is able to do on a case by case basis. 

Degaussing Hard Drives

Degaussing hard drives is another solution ideal for smaller projects where an industrial hard drive shredder may not be available in the geographical area or economically appropriate for the project.  Degaussers use powerful magnets to destroy data on hard drives and other media but does not work for solid state hard drives or flash media.

Degausser machines are no longer the prevalent tool that they once were due to the superior output of shredders and more effective verification methods of enterprise erasure software utilities.  Nonetheless, the tool remains active due to security policies that have been written and not updated or where other tools prove to be near impossible to deploy.

For more information on appropriate methods and documentation of data destruction practices please review our short guide to NIST 800-88.

Download 5 Data Destruction Tips

 

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Topics: IT Asset Disposal, data destruction, eWaste Disposal, Risk Management, hard drive disposal

   

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