Cyber Security Planning Guide

The below entities collaborated in the creation of this guide. This does not constitute or imply an endorsement by the FCC of any commercial product, service or enterprise of these entities. This guide is not a substitute for consulting trained cyber security professionals.



Table of Contents

Thank you for using the FCC’s Small Biz Cyber Planner, a tool for small businesses to create customized cyber security planning guides. Businesses large and small need to do more to protect against growing cyber threats. As larger companies take steps to secure their systems, less secure small businesses are easier targets for cyber criminals.

This planning guide is designed to meet the specific needs of your company, using the FCC’s customizable Small Biz Cyber Planner tool. The tool is designed for businesses that lack the resources to hire dedicated staff to protect their business, information and customers from cyber threats. Even a business with one computer or one credit card terminal can benefit from this important tool. We generally recommend that businesses using more sophisticated networks with dozens of computers consult a cyber security expert in addition to using the cyber planner. The FCC provides no warranties with respect to the guidance provided by this tool and is not responsible for any harm that might occur as a result of or in spite of its use.

The guidance was developed by the FCC with input from public and private sector partners, including the Department of Homeland Security, the National Cyber Security Alliance and The Chamber of Commerce.

Section Page #s Privacy and Data Security PDS-1 - PDS-5

Scams and Fraud SF-1 - SF-3

Network Security NS-1 - NS-3

Website Security WS-1 - WS-5

Email E-1 - E-2

Mobile Devices MD-1 - MD-3

Employees EMP-1 - EMP-3

Facility Security FS-1 - FS-2

Operational Security OS-1 - OS-3

Payment Cards PC-1 - PC-2

Incident Response and Reporting IRR-1 - IRR-2

Policy Development, Management PDM-1 - PDM-3

Cyber Security Glossary CSG-1 - CSG-10

Cyber Security Links CSL-1 - CSL-3

TC-1



Privacy and Data Security

Data security is crucial for all small businesses. Customer and client information, payment information, personal files, bank account details - all of this information is often impossible replace if lost and dangerous in the hands of criminals. Data lost due to disasters such as a flood or fire is devastating, but losing it to hackers or a malware infection can have far greater consequences. How you handle and protect your data is central to the security of your business and the privacy expectations of customers, employees and partners.

Cyber Plan Action Items:

1. Conduct an inventory to help you answer the following questions:

• What kind of data do you have in your business?

A typical business will have all kinds of data, some of it more valuable and sensitive than others, but all data has value to someone. Your business data may include customer data such as account records, transaction accountability and financial information, contact and address information, purchasing history, buying habits and preferences, as well as employee information such as payroll files, direct payroll account bank information, Social Security numbers, home addresses and phone numbers, work and personal email addresses. It can also include proprietary and sensitive business information such as financial records, marketing plans, product designs, and state, local and federal tax information.

• How is that data handled and protected?

Security experts are fond of saying that data is most at risk when it’s on the move. If all your business-related data resided on a single computer or server that is not connected to the Internet, and never left that computer, it would probably be very easy to protect.

But most businesses need data to be moved and used throughout the company. To be meaningful data must be accessed and used by employees, analyzed and researched for marketing purposes, used to contact customers, and even shared with key partners. Every time data moves, it can be exposed to different dangers.

As a small business owner, you should have a straightforward plan and policy – a set of guidelines, if you like – about how each type of data should be handled, validated and protected based on where it is traveling and who will be using it.

• Who has access to that data and under what circumstances?

Not every employee needs access to all of your information. Your marketing staff shouldn’t need or be allowed to view employee payroll data and your administrative staff may not need access to all your customer information.

When you do an inventory of your data and you know exactly what data you have and where it’s kept, it is important to then assign access rights to that data. Doing so simply means creating a list of the specific employees, partners or contractors who have access to specific data, under what circumstances, and how those access privileges will be managed and tracked.

Your business could have a variety of data, of varying value, including:

• Customer sales records

• Customer credit card transactions

• Customer mailing and email lists

• Customer support information

PDS-1



FCC SMALL BIZ CYBER PLANNING GUIDE

• Customer warranty information

• Patient health or medical records

• Employee payroll records

• Employee email lists

• Employee health and medical records

• Business and personal financial records

• Marketing plans

• Business leads and enquiries

• Product design and development plans

• Legal, tax and financial correspondence

2. Once you've identified your data, keep a record of its location and move it to more appropriate locations as needed.

3. Develop a privacy policy

Privacy is important for your business and your customers. Continued trust in your business practices, products and secure handling of your clients’ unique information impacts your profitability. Your privacy policy is a pledge to your customers that you will use and protect their information in ways that they expect and that adhere to your legal obligations.

Your policy starts with a simple and clear statement describing the information you collect about your customers (physical addresses, email addresses, browsing history, etc), and what you do with it. Customers, your employees and even the business owners increasingly expect you to make their privacy a priority. There are also a growing number of regulations protecting customer and employee privacy and often costly penalties for privacy breaches. You will be held accountable for what you claim and offer in your policy.

That’s why it’s important to create your privacy policy with care and post it clearly on your website. It’s also important to share your privacy policies, rules and expectations with all employees and partners who may come into contact with that information. Your employees need to be familiar with your legally required privacy policy and what it means for their daily work routines.

Your privacy policy will should address the following types of data:

• Personally Identifiable Information: Often referred to as PII, this information includes such things as first and last names, home or business addresses, email addresses, credit card and bank account numbers, taxpayer identification numbers, patient numbers and Social Security numbers. It can also include gender, age and date of birth, city of birth or residence, driver’s license number, home and cell phone numbers.

• Personal Health Information: Whether you’re a healthcare provider with lots of sensitive patient information or you simply manage health or medical information for a small number of employees, it’s vital that you protect that information. A number of studies have found most consumers are very concerned about the privacy and protection of their medical records. They do not want their health information falling into the hands of hackers or identity thieves who might abuse it for financial gain. But they also may not want employees or co-workers prying into their personal health details. And they often don’t want future employers or insurers finding out about any medical conditions or history.

• Customer information: This includes payment information such as credit or debit card numbers and verification codes, billing and shipping addresses, email addresses, phone numbers, purchasing history, buying preferences and shopping behavior.

PDS-2



FCC SMALL BIZ CYBER PLANNING GUIDE

The Better Business Bureau has a copy of a privacy policy that you are free to download and use. It is available here: http://www.bbbonline.org/reliability/privacy/.

4. Protect data collected on the Internet

Your website can be a great place to collect information – from transactions and payments to purchasing and browsing history, and even newsletter signups, online enquiries and customer requests.

This data must be protected, whether you host your own website and therefore manage your own servers or your website and databases are hosted by a third party such as a web hosting company.

If you collect data through a website hosted by a third party, be sure that third party protects that data fully. Apart from applying all the other precautions that have been described, such as classifying data and controlling access, you need to make sure any data collected through your website and stored by the third party is sufficiently secure. That means protection from hackers and outsiders as well as employees of that hosting company.

5. Create layers of security

Protecting data, like any other security challenge, is about creating layers of protection. The idea of layering security is simple: You cannot and should not rely on just one security mechanism – such as a password – to protect something sensitive. If that security mechanism fails, you have nothing left to protect you.

When it comes to data security, there are a number of key procedural and technical layers you should consider:

Inventory your data

We mentioned before the need to conduct a data inventory so you have a complete picture of all the data your business possesses or controls. It’s essential to get a complete inventory, so you don’t overlook some sensitive data that could be exposed.

Identify and protect your sensitive and valuable data

Data classification is one of the most important steps in data security. Not all data is created equal, and few businesses have the time or resources to provide maximum protection to all their data. That’s why it’s important to classify your data based on how sensitive or valuable it is – so that you know what your most sensitive data is, where it is and how well it’s protected.

Common data classifications include:

HIGHLY CONFIDENTIAL: This classification applies to the most sensitive business information that is intended strictly for use within your company. Its unauthorized disclosure could seriously and adversely impact your company, business partners, vendors and/or customers in the short and long term. It could include credit-card transaction data, customer names and addresses, card magnetic stripe contents, passwords and PINs, employee payroll files, Social Security numbers, patient information (if you’re a healthcare business) and similar data.

SENSITIVE: This classification applies to sensitive business information that is intended for use within your company, and information that you would consider to be private should be included in this classification. Examples include employee performance evaluations, internal audit reports, various financial reports, product designs, partnership agreements, marketing plans and email marketing lists.

INTERNAL USE ONLY: This classification applies to sensitive information that is generally accessible by a wide audience and is intended for use only within your company. While its unauthorized disclosure to

PDS-3



FCC SMALL BIZ CYBER PLANNING GUIDE

outsiders should be against policy and may be harmful, the unlawful disclosure of the information is not expected to impact your company, employees, business partners, vendors and the like.

Control access to your data

No matter what kind of data you have, you must control access to it. The more sensitive the data, the more restrictive the access. As a general rule, access to data should be on a need-to-know basis. Only individuals who have a specific need to access certain data should be allowed to do so.

Once you’ve classified your data, begin the process of assigning access privileges and rights – that means creating a list of who can access what data, under what circumstances, what they are and are not allowed to do with it and how they are required to protect it. As part of this process, a business should consider developing a straightforward plan and policy – a set of guidelines – about how each type of data should be handled and protected based on who needs access to it and the level of classification.

Secure your data

In addition to administrative safeguards that determine who has access to what data, technical safeguards are essential. The two primary safeguards for data are passwords and encryption.

Passwords implemented to protect your most sensitive data should be the strongest they can reasonably be. That means passwords that are random, complex and long (at least 10 characters), that are changed regularly and that are closely guarded by those who know them. Employee training on the basics of secure passwords and their importance is a must.

Passwords alone may not be sufficient to protect sensitive data. Businesses may want to consider two-factor authentication, which often combines a password with another verification method, such as a dynamic personal identification number, or PIN.

Some popular methods of two-factor identification include:

▪ Something the requestor individually knows as a secret, such as a password or a PIN.

▪ Something the requestor uniquely possesses, such as a passport, physical token or ID card.

▪ Something the requestor can uniquely provide as biometric data, such as a fingerprint or face geometry.

Another essential data protection technology is encryption. Encryption has been used to protect sensitive data and communications for decades, and today’s encryption is very affordable, easy-to-use and highly effective in protecting data from prying eyes.

Encryption encodes or scrambles information to such an advanced degree that it is unreadable and unusable by anyone who does not have the proper key to unlock the data. The key is like a password, so it’s very important that the key is properly protected at all times.

Encryption is affordable for even the smallest business, and some encryption software is free. You can use encryption to encrypt or protect an entire hard drive, a specific folder on a drive or just a single document. You can also use encryption to protect data on a USB or thumb drive and on any other removable media.

Because not all levels of encryption are created equal, businesses should consider using a data encryption method that is FIPS-certified (Federal Information Processing Standard), which means it has been certified for compliance with federal government security protocols.

Back up your data

Just as critical as protecting your data is backing it up. In the event that your data is stolen by thieves or hackers, or even erased accidentally by an employee, you will at least have a copy to fall back on.

PDS-4



FCC SMALL BIZ CYBER PLANNING GUIDE

Put a policy in place that specifies what data is backed up and how; how often it’s backed up; who is responsible for creating backups; where and how the backups are stored; and who has access to those backups.

Small businesses have lots of affordable backup options, whether it’s backing up to an external drive in your office, or backing up automatically and online so that all your data is stored at a remote and secure data center.

Remember, physical media such as a disc or drive used to store a data backup is vulnerable no matter where it is, so make sure you guard any backups stored in your office or off site and also make sure that your backup data storage systems are encrypted.

6. Plan for data loss or theft

Every business has to plan for the unexpected, and that includes the loss or theft of data from your business. Not only can the loss or theft of data hurt your business, brand and customer confidence, it can also expose you to the often-costly state and federal regulations that cover data protection and privacy. Data loss can also expose businesses to significant litigation risk.

That’s why it’s critical to understand exactly what data or security breach regulations affect your business and how prepared you are to respond to them. That should be the foundation of a data breach response plan that will make it easier to launch a rapid and coordinated response to any loss or theft of data.

At the very least, all employees and contractors should understand that they must immediately report any loss or theft of information to the appropriate company officer. And because data privacy and breach laws can be very broad and strict, no loss should be ignored. So even if you have sensitive data that just can’t be accounted for, such as an employee who doesn’t remember where he left a backup tape, it may still constitute a data breach and you should act accordingly.

And just in case you don’t think a data breach could happen at your small business, think about this. In 2010, the U.S. Secret Service and Verizon Communications Inc.'s forensic analysis unit responded to a combined 761 data breaches. Of those, 482, or 63 percent, were at companies with 100 employees or fewer. And in 2011 Visa estimated that about 95 percent of the credit-card data breaches it discovers are on its smallest business customers.

The Online Trust Alliance has a comprehensive guide to understand and preparing for data breaches, available at https://otalliance.org/resources/2011DataBreachGuide.pdf.

The Federal Trade Commission has materials to help small businesses secure data in their care and protect their customers’ privacy, including an interactive video tutorial, at http://business.ftc.gov/privacy-and-security.

PDS-5



Scams and Fraud

New telecommunication technologies may offer countless opportunities for small businesses, but they also offer cyber criminals many new ways to victimize your business, scam your customers and hurt your reputation. Businesses of all sizes should be aware of the most common scams perpetrated online.

To protect your business against online scams, be cautious when visiting web links or opening attachments from unknown senders, make sure to keep all software updated, and monitor credit cards for unauthorized activity.

Cyber Plan Action Items:

1. Train employees to recognize social engineering

Social engineering, also known as "pretexting," is used by many criminals, both online and off, to trick unsuspecting people into giving away their personal information and/or installing malicious software onto their computers, devices or networks. Social engineering is successful because the bad guys are doing their best to make their work look and sound legitimate, sometimes even helpful, which makes it easier to deceive users.

Most offline social engineering occurs over the telephone, but it frequently occurs online, as well. Information gathered from social networks or posted on websites can be enough to create a convincing ruse to trick your employees. For example, LinkedIn profiles, Facebook posts and Twitter messages can allow a criminal to assemble detailed dossiers on employees. Teaching people the risks involved in sharing personal or business details on the Internet can help you partner with your staff to prevent both personal and organizational losses.

Many criminals use social engineering tactics to get individuals to voluntarily install malicious computer software such as fake antivirus, thinking they are doing something that will help make them more secure. Fake antivirus is designed to steal information by mimicking legitimate security software. Users who are tricked into loading malicious programs on their computers may be providing remote control capabilities to an attacker, unwittingly installing software that can steal financial information or simply try to sell them fake security software. The malware can also make system modifications which make it difficult to terminate the program. The presence of pop-ups displaying unusual security warnings and asking for credit card or personal information is the most obvious method of identifying a fake antivirus infection.

2. Protect against online fraud

Online fraud takes on many guises that can impact everyone, including small businesses and their employees. It is helpful to maintain consistent and predictable online messaging when communicating with your customers to prevent others from impersonating your company.

Be sure to never request personal information or account details through email, social networking or other online messages. Let your customers know you will never request this kind of information through such channels and instruct them to contact you directly should they have any concerns.

3. Protect against phishing

Phishing is the technique used by online criminals to trick people into thinking they are dealing with a trusted website or other entity. Small businesses face this threat from two directions -- phishers may be impersonating them to take advantage of unsuspecting customers, and phishers may be trying to steal their employees’ online credentials. Attackers often take advantage of current events and certain types of the year, such as:

• Natural disasters (Hurricane Katrina, Indonesian tsunami)

SF-1



FCC SMALL BIZ CYBER PLANNING GUIDE

• Epidemics and health scares (H1N1)

• Economic concerns

• Major political elections

• Holidays

Businesses should ensure that their online communications never ask their customers to submit sensitive information via email, personal visits, or phone. Make a clear statement in your communications reinforcing that you will never ask for personal information via email so that if someone targets your customers, they may realize the request is a scam.

Employee awareness is your best defense against your users being tricked into handing over their usernames and passwords to cyber criminals. Explain to everyone that they should never respond to incoming messages requesting private information. If a stranger claims to be from a legitimate organization, verify his or her identity with his or her stated company before sharing any personal or classified information. Also, to avoid being led to a fake site, employees should know to never click on a link sent by email from an untrustworthy source. Employees needing to access a website link sent from a questionable source should open an Internet browser window and manually type in the site’s web address to make sure the emailed link is not maliciously redirecting to a dangerous site.

This advice is especially critical for protecting online banking accounts belonging to your organization. Criminals are targeting small business banking accounts more than any other sector. If you believe you have revealed sensitive information about your organization, make sure to:

• Report it to appropriate people within your organization

• Contact your financial institution and close any accounts that may have been compromised (if you believe

financial data is at risk)

• Change any passwords you may have revealed, and if you used the same password for multiple resources,

make sure to change it for each account

4. Don’t fall for fake antivirus offers

Fake antivirus, "scareware" and other rogue online security scams have been behind some of the most successful online frauds in recent times. Make sure your organization has a policy in place explaining what the procedure is if an employee's computer becomes infected by a virus.

Train your employees to recognize a legitimate warning message (using a test file from eicar.org, for example) and to properly notify your IT team if something bad or questionable has happened. If possible, configure your computers to not allow regular users to have administrative access. This will minimize the risk of them installing malicious software and condition users that adding unauthorized software to work computers is against policy.

5. Protect against malware

Businesses can experience a compromise through the introduction of malicious software, or malware. Malware can make its way onto machines from the Internet, downloads, attachments, email, social media, and other platforms. One specific malware to be aware of is key logging, which is malware that tracks a user’s keyboard strokes.

Many businesses are falling victim to key-logging malware being installed on computer systems in their environment. Once installed, the malware can record keystrokes made on a computer, allowing bad guys to see passwords, credit card numbers and other confidential data. Keeping security software up to date and patching your computers regularly will make it more difficult for this type of malware to infiltrate your network.

SF-2



FCC SMALL BIZ CYBER PLANNING GUIDE

6. Develop a layered approach to guard against malicious software

Despite progress in creating more awareness of security threats on the Internet, malware authors are not giving up. The malware research firm SophosLabs reports seeing more than 100,000 unique malicious software samples every single day.

Effective protection against viruses, Trojans and other malicious software requires a layered approach to your defenses. Antivirus software is a must, but should not be a company’s only line of defense. Instead, deploy a combination of many techniques to keep your environment safe.

Also, be careful with the use of thumb drives and other removable media. These media could have malicious software pre-installed that can infect your computer, so make sure you trust the source of the removable media devices before you use them.

Combining the use of web filtering, antivirus signature protection, proactive malware protection, firewalls, strong security policies and employee training significantly lowers the risk of infection. Keeping protection software up to date along with your operating system and applications increases the safety of your systems.

7. Be aware of spyware and adware

Spyware and adware, when installed will send pop-up ads, redirect to certain websites, and monitor websites that you visit. Extreme versions can track what keys are typed. Spyware can cause your computer to become slow and also leaves you susceptible to privacy theft. If you are subject to endless pop-up windows or are regularly redirected to websites other than what you type in your browser, your computer is likely infected with spyware.

To remove spyware run an immediate full scan of your computer with anti-virus software and if necessary run a legitimate product specifically designed to remove spyware. To avoid being infected with spyware, limit cookies on your browser preferences, never click on links within pop-up windows, and be wary of free downloadable software from unreputable sources.

8. Verify the identity of telephone information seekers

Most offline social engineering occurs over the telephone. Information gathered through social networks and information posted on websites can be enough to create a convincing ruse to trick your employees. Ensure that you train employees to never disclose customer information, usernames, passwords or other sensitive details to incoming callers. When someone requests information, always contact the person back using a known phone number or email account to verify the identity and validity of the individual and their request.

Helpful links

• Use the Department of Homeland Security’s Stop.Think.Connect.TM Campaign’s resources created especially for businesses to train their employees: www.dhs.gov/stopthinkconnect

• Find the most updated patches for your computer and software applications: http://www.softwarepatch.com/

• Free computer security scan tools for your PC or network: http://www.staysafeonline.org/tools-resources/free-security-check-ups

• Stay on top of the latest scams, frauds and security threats as they happen: http://nakedsecurity.sophos.com/

• Additional tops to prevent against phishing: http://www.fraud.org/tips/internet/phishing.htm

• Learn how to resist phishing techniques with this interactive game: http://cups.cs.cmu.edu/antiphishing_phil/

SF-3