Last weekend, along with countless employees and ex-employees of Microsoft, Amazon, Expedia, and Premera itself, I received a breach notification signed by Premera’s President & CEO, Jeffrey Roe.
Here’s a few things I think can already be learned from this letter and the available public information:
Whenever I see the phrase “sophisticated cyberattack”, not only am I turned off by the meaningless prefix “cyber”, which seems to serve only to “baffle them with bullshit”, but I’m also convinced that the author is trying to convince me that, hey, this attack was just too amazing and science-fictiony to do anything to stop.
All that does is push me in the other direction – to assume that the attack was relatively simple, and should have been prevented and/or noticed.
Granted, my experience is in Information Security, and so I’m always fairly convinced that it’ll be the simple attacks, not the complex and difficult ones, that will be the most successful against any site I’m trying to protect. It’s a little pessimistic, but it’s been proven right time and again.
So, never say that an attack is “sophisticated” unless you really mean that the attack was way beyond what could have been reasonably imagined. You don’t have to say the attackers used simple methods to get in because your team are idiots, because that’s unlikely to be entirely true, either. Just don’t make it sound like it’s not your fault. And don’t make that your opening gambit, either – this was the very first sentence in Premera’s notification.
“some of your personal information may have been accessed”
Again, this phrasing simply makes me think “these guys have no idea what was accessed”, which really doesn’t inspire confidence.
Instead, you should say “the attackers had access to all our information, including your personal and medical data”. Then acknowledge that you don’t have tracking on what information was exported, so you have to act as if it all was.
The worst apologies on record all contain some variation of “I’m sorry you’re upset”, or “I’m sorry you took offence”.
Premera’s version of this is “We … regret the concern it may cause”. So, not even “sorry”. And to the extent that it’s an apology at all, it is that we, current and past customers, were “concerned”.
Premera Blue Cross (“Premera”) …
… Information Technology (IT) systems
As if the lack of apology didn’t already tip us off that this document was prepared by a lawyer, the parenthetical creation of abbreviations to be used later on makes it completely clear.
If the letter had sounded more human, it would have been easier to receive as something other than a legal arse-covering exercise.
The letter acknowledges that the issue was discovered on January 29, 2015, and the letter is dated March 17, 2015. That’s nearly two months. And nearly a year since the attackers got in. That’s assuming that you’ve truly figured out the extent of the “sophisticated cyberattack”.
Actually, that’s pretty fast for security breach disclosure, but it still gives the impression to customers that you aren’t letting them know in enough time to protect themselves.
The reason given for this delay is that Premera wanted to ensure that their systems were safe before letting other attackers know about the issue – but it’s generally a fallacy to assume that attackers don’t know about your vulnerabilities. Premera, and the health insurance industry, do a great job of sharing security information with other health insurance providers – but the attackers do an even better job of sharing information about vulnerable systems and tools.
Which leads us to…
If your company doesn’t have a prepared breach disclosure letter, approved by public relations, the security team and your lawyers, it’s going to take you at least a week, probably two, to put one together. And you’ll have missed something, because you’re preparing it in a rush, in a panic, and in a haze while you’re angry and scared about having been attacked.
Your prepared letter won’t be complete, and won’t be entirely applicable to whatever breach finally comes along and bites you, but it’ll put you that much closer to being ready to handle and communicate that breach. You’ll still need to review it and argue between Security, Legal and PR teams.
Have a plan for this review process, and know the triggers that will start it. Maybe even test the process once in a while.
If you believe that breaches could require a credit notification or ID tracking protection, negotiate this ahead of time, so that this will not slow you down in your announcement. Or write your notification letter with the intent of providing this information at a later time.
Finally, because your notification letter will miss something, make sure it includes the ability to update your customers – link to an FAQ online that can be updated, and provide a call-in number for people to ask questions of an informed team of responders.
There’s always more information coming out about this vulnerability, and I plan to blog a little more about it later.
Let me know in particular if there’s something you’d like me to cover on this topic.