Category: GDPR

Incentive Policy for Coordinated Vulnerability Disclosure

Assessment

For the past ten years or so, organizations have been trying to implement operational policies to avoid “Full Disclosure” reports or “Open Bug Bounty” whose methods are not that good in terms of honesty and responsibility.

Speaking of responsibility, you may be familiar with the notion of “Responsible Disclosure” and you wonder how it differs from the concept of Coordinated Vulnerability Disclosure?

The concept of responsible disclosure has too often been at the root of endless discussions:

On the one hand the vendors denounce “Disclosing a vulnerability without providing patches is not responsible”.
and the other, “Don’t fix this vulnerability as quickly as possible is not responsible”, say security researchers.

During this precious time when both sides argue, the system concerned is at the opponent’s mercy.

In order to move towards greater efficiency and to get out of sterile debates, it is therefore important to avoid speaking of “responsible disclosure”. This is why many organizations advocate the concept of “Coordinated Vulnerability Disclosure” (CVD) in order to promote and strengthen cooperation between the various actors in cybersecurity, all of whom have a common goal: Make the Internet safer.

Coordinated Vulnerability Disclosure

Coordinated Vulnerability Disclosure

Theory & Definitions

Coordinated Vulnerability Disclosure (CVD) is a process aimed at reducing risk and ultimately mitigating potential damage caused by a vulnerability affecting an information system. CVD is a process that cannot be reduced to the deployment of a patch or publication of a report, even though these events are indicators of the efficiency of cooperation.

A bounty bug platform such as Bountyfactory.io facilitates this process by encouraging the cooperation of thousands of security experts and organizations.
Cooperation: it is a key element of Cyber Governance.

Guillaume Vassault Houlière | YesWeHack CEO

Coordinated Vulnerability Disclosure is therefore the process of collecting information from Security Researchers, coordinating the sharing of this information among actors, and disclosing the existence of vulnerabilities (software or even hardware) and their mitigation measures to various stakeholders, including the public.

Coordinated Vulnerability Disclosure significantly increases the likelihood of success of any vulnerability response process. Contributions are often vulnerability reports written by security researchers.

CVD reports for a product (software or hardware) typically include patches as well as vulnerability report documentation or recordings in a vulnerability database.

NB: many operational vulnerabilities can be corrected by the operator and do not necessarily result in public disclosure.

Vulnerability disclosure is a process by which vendors and people who discover vulnerabilities can work collaboratively to find solutions that reduce the risks associated with a vulnerability.

ISO/IEC 29147 standard defining Vulnerability Disclosure

This process includes actions such as the reporting, coordination and publication of information on one vulnerability, its mitigation or, ideally, its remediation.

Let’s zoom in the concept :

Principles:

  • Reduce the risk of damage
  • Believe in good deeds, believe in good Samaritans
  • Avoid randomness
  • Boost cooperation
  • Follow the code of ethics
  • Learn from the OODA loop
  • Consider CVD as a process navigating between the “best” and the “worst”.

Goals:

  • Ensure that identified vulnerabilities are – well – addressed;
  • Reduce the risk of vulnerability;
  • Provide users with sufficient information to assess the risks associated with the vulnerabilities of their systems;

StakeHolders:

Coordinated Vulnerability Disclosure commonly begins with the detection of a vulnerability and ends with the deployment of patches or mitigation.

Therefore, several actors are involved in the CVD process:

  • Security researcher – the person or organization that identifies vulnerability.
  • Reporter – the person or organization who notifies the vendor
  • Vendor – the individual or organization that created or maintains the product that is vulnerable
  • System Administrator – an individual or organization that must implement a corrective action or take other corrective actions.
  • Coordinator – an individual or organization that facilitates the coordinated response process

Steps:

  • Discovery – Someone discovers a vulnerability in a product.
  • Report – The product vendor or a third party coordinator receives a vulnerability report.
  • Qualification – The recipient of a report validates it to ensure its accuracy before prioritizing it for further action.
  • Remediation – A remediation plan (ideally a software patch) is developed and tested.
  • Public Awareness – Vulnerability and corrective measures are disclosed to the public.
  • Deployment – Corrective measures are applied to the systems concerned.

The reporting step is important because it requires the creation of secure channels to ensure that transmitted information is not intercepted by a third party.

However, there are some obstacles within the process:

  • No vendor contact available – This may occur because a contact could not be found or because the contact is not reactive.
  • Termination of cooperation – participants in the CVD process may have other priorities that attract their attention.
  • Information leakage – Whether intentional or unintentional, information for a small group of actors can be passed on to others who are not involved in the CVD process.
  • Independent Discovery – Any vulnerability that can be found by one individual can be found by another, and not everyone will tell you about it.
  • Active Exploitation – Evidence that a vulnerability is being actively exploited by adversaries requires accelerating the CVD process to reduce users’ exposure to risk.
  • Communication is deteriorating – CVD is a process of coordinating human activities. As such, its success depends on the quality of the relationships between the participants.
  • Marketing – In some cases, vulnerabilities can be used as a marketing tool. This is not always conducive to the smooth running of the CVD process.

To sum up:

Vulnerability disclosure practices are no longer restricted to web applications. The Internet of Things and the constellation of SCADA systems, connected health devices, CCTV, Connected cars, etc. have become so dependent on software and the Internet that they increase the exposure perimeter and will inevitably be exposed to new attacks.

The Coordinated Vulnerability Disclosure is a major ally to federate the largest number of cyberspace actors and stimulate the exchange of knowledge to ensure both security and privacy protection by design.

By encouraging cooperation, CVD will enable all stakeholders not only to defend their common information assets but also to fight more effectively against the black market and the resale of Zerodays.

*

The set is now planted, so let’s switch from theory to practice.

Security.txt: the promising RFC!

In order to respond to the lack of contacts available to disclose a vulnerability on a website, security researcher EdOverflow, well inspired by the role of the famous robots. txt, suggested since the beginning of August 2017 to include in each website the file security.txt as a reference file containing the procedure to be followed to disclose more effectively to the editor of a site a bug, a vulnerability.

This approach has the merit of establishing clear guidelines for security researchers on how to report security issues and allows bug bounty programs to use them as a basis for defining the attack perimeter for future researchers.

security.txt is a draft that has been submitted to the RFC for review. This means that security.txt is still in the early stages of development. You can contribute on github!

Bug Bounty as part of your disclosure policy

As part of agile development on their own products, more and more vendors are choosing to be proactive by stimulating and cooperating with IT researchers:

  • by relying on in-house resources and expertise;
  • by contracting directly with external researchers;
  • via a platform that will connect researchers and one vendor. The latter will therefore pay for the result and will be able to choose between various options such as program management or even patch management if its internal resources are not sufficient.

NB: The creation and long-term implementation of a Bug Bounty program is considered as an indicator of the maturity of publishers’ E-governance in terms of vulnerability.

Since 2013, YesWeHack has been developing tools that greatly facilitate the implementation of an incentive policy for CVD.

YesWeHack, its community and ecosystem of services enable organizations and IT security researchers to better cooperate.

Thanks to the tools developed by YesWeHack, beneficiary organizations can more easily overcome the obstacles encountered by their CVD policy. In addition, organizations gain reputation by demonstrating their appetite and willingness for continuously improving their systems.

Bountyfactory.io as the first European platform of Bug bounty.

Differentiating criteria

  • Cooperation with European partners and providers as a matter of sovereignty.
  • Legal and technical infrastructure that meets the highest security requirements.
  • Security and confidentiality of communications based on encryption and compliance with ISO standards.
  • Securing financial transactions between organizations and security researchers.
  • Payment platform compliant with European anti-money laundering and anti-terrorist financing arrangements.
  • Support throughout the entire process: from the drafting of the program to assistance with corrective measures.
  • Operational ranking of the best researchers: Management of a security research community.
  • Reactivity that enables the best researchers to be mobilized in record time.
  • Ability to organize different types of Bounty bug programs (Private / Public / In situ / Hardware and/or Software).

Give it a try ! Register on BountyFactory.io

What should I do if a product does not offer Bug Bounty or Security.txt?

Zerodisclo.com

A simple and effective tool to avoid full disclosure of vulnerabilities in the wild.

It is important to note that some products (software or hardware) do not have their own Bug Bounty program. Thus, it is difficult for a security researcher to report a vulnerability to a vendor. Not all countries have a law allowing this kind of practice, as is the purpose of Article 47 of the Law for a Digital Republic initiated by ANSSI.

YesWeHack has created Zerodisclo.com to facilitate the escalation of vulnerabilities in a secure and even anonymous way and put in touch the different actors working for a safer Internet.

Thanks to Zerodisclo several obstacles are removed: no login, anonymization of the report via the Tor (.onion) network and mandatory and automatic encryption of the report content with the public PGP key of the CERT chosen.

The list of CERTs included in ZeroDisclo.com

Please find below the infographic of ZeroDisclo.com

European Regulation for the Protection of Personal Data and Data Security


By

Eric A. Caprioli, Attorney Admitted to Practice Before Court of Appeals, Juris Doctor, Member of French Delegation to United Nations
&
Isabelle Cantero, Associate (Caprioli & Associés), Lead for Privacy and Personal Data Practice


The European Regulation for the Protection of Personal Data (GDPR) was adopted on April 27, 2016 after 4 years of involved negotiations. Being a directly applicable regulation in each of the Member States (that is, not requiring a national law to implement), it should enable the harmonization of the statutes having to do with the protection of personal data within the European Union and bring the principles of protection into line with the realities of the digital era. It will go into effect on May 25, 2018. For many companies, these new provisions will involve costs related to the investment required to bring their current tools or procedures into compliance with the new rules.

Single Flexible Protective Statute for All EU Member States

The regulation is applicable to every entity in the private and the public sectors. It applies to the issues of Big Data, profiling, Cloud Computing, security of transborder data traffic, data portability when changing service providers… These issues are to be placed alongside the new advance protection principles (privacy by design or by default), analysis-based protection (impact assessment), documented protection (mandatory documentation serving as evidence of statutory compliance), cascading protection (processor liability and the possibility of joint liability), and stronger protection (rights of individuals and consent). And finally, the accountability principle (i. e. the obligation to prove statutory compliance of how personal information is being handled).

As far as stronger protection for the rights of individuals in concerned, consent should be the focus since it should never be implicit or general and it must be provable (documented and traceable) by the controller. Further, in addition to the conventional rights of individuals, such as access, correction/deletion and objection, the GDPR creates new rights (limitation on data processing, portability, etc.).

As for sanctions handed down by the enforcement authority  (CNIL), it should already be noted that they could be as high as EUR 3 million pursuant to the Digital Republic legislation of October 2016 but with GDPR, for violations of obligations set forth in matters of individual rights they could go all the way to 4% of global revenues, or EUR 20 million. For violations of other obligations prescribed by GDPR, the fines could be as high as 2% of global revenue, or EUR 10 million.

And to round off this brief summary of the changes, the current Ombudsperson for IT and Freedoms (optional designation) will be replaced by a Data Protection Officer whose functions will clearly be broader. This designation is mandatory under certain conditions: in a Government body or authority, whenever data processing enables regular and systematic large-scale monitoring of individuals, whenever sensitive or criminal record information is being processed on a large scale, or whenever required by Union or Member State law.

Personal Data Protection Core Security

GDPR Article 32 on the security of data processing lists the various criteria that a controller and a processor must take into account to determine the level of security required, namely, the state of the art, the costs of implementing security, the processing in question, including its purpose and context, the probability and the severity of the risks for individual rights and freedoms The logic consists in customizing security measures to the risks identified with respect to the processing of personal data.
Major change: the Regulation provides for an assessment of risks to privacy from data processing. Subsequently, it is up to the controller to perform a PIA (privacy impact assessment) for all the processing actions likely to result in a high degree of privacy risk for the individuals in question. According to GDPR, some types of processing are deemed to constitute risks and are subject to a PIA because of the nature of the data being processed (large-scale processing of sensitive or criminal record data) or the purpose of such processing (profiling, large-scale monitoring of public areas, etc.).
Given that this is about safeguards to be put in place, Article 32 lists certain measures that are to be implemented by the controller and/or the processor, such as data pseudonymization or encryption, the implementation of methods capable of ensuring system confidentiality, integrity, availability, and resilience, the implementation of techniques capable of restoring availability and access to personal data in the event of a physical or technical incident, regular verification of such measures. The Code of Conduct (GDPR Article 40) and certification (GDPR Article 42) are also solutions that are likely to be considered with respect to security.
Pursuant to GDPR Article 36, whenever a PIA identifies a high level of risk, it becomes mandatory to consult the CNIL prior to proceeding with the data processing in question. This requires, for instance, that the CNIL be advised of any measures having to do with the security of processing for the CNIL to evaluate whether they are sufficient to allow the processing to proceed.
Pursuant to GDPR, data security also requires that a notification of a personal data breach be made initially to the supervisory authority (CNIL) within 72 hours of it becoming known (Article 33) and to the data subject (Article 34) if CNIL believes the security measures to have been inadequate. This obligation extends to the processor who must notify the controller of any data breaches as soon as it becomes aware of them. These data breaches result from one or more security incidents (unauthorized access to an IT system, data extraction, reproduction, or distribution). Advance incident detection and correction help obviate the need to notify since there is no breach.
We understand that the new regulation requires that locations where data are processed within an organization (mapping) be brought to a condition that will help determine specific priorities for bringing into compliance as well as the relevant support. As for security, implementation of Bug Bounty practices appears to us to be highly recommended to detect security incidents early, thereby preventing them.

GDPR leads us to the following motto:

When security works, everything works!

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