Intelligent CISO Issue 04 | Page 85

The ability to quickly detect, respond and, most importantly, investigate breaches will mean a lot when it comes to meeting those obligations. It already takes 101 days – according to Mandiant – before the average organisation even discovers a breach but, when that breach is spotted, how quickly will they be able to investigate and report on it? Most enterprises simply can’t monitor, detect, investigate or respond in the way that they need to effectively disclose within that 72-hour window. It seems that most organisations freely admit that. A recent survey by the Ponemon Institute and the law firm McDermott Will & Emery showed that 83% of companies list reporting as the most difficult aspect of GDPR. What is perhaps more encouraging is that 68% realise that failing to comply with this aspect of the regulation poses the biggest risk to them. www.intelligentciso.com | Issue 04 Reporting is currently hamstrung by a number of problems, which will make a swift and detailed submission to GDPR regulators that much harder. They centre around four key areas of this process. First, scoping and root cause analysis, followed by containment and mitigation. Scoping and root cause analysis are related but not the same. Scoping will help you understand the size of the impact crater – how much damage was done in the breach. The SOC can be best prepared with an accurate catalogue of assets in your environment and which data they process. With regard to GDPR, that means personal data. You’ll need to effectively scope in order to begin root cause analysis, which requires the analyst to thoroughly explore and trace the activities and touch points of the attacker en- route to the exfiltration. This means finding accurate and current data on transactions and time series and then forensically reconstructing the steps of how an attacker broke into and made their way through your network. It also often means sifting through the human errors or simple misconfigurations that so often lead to breaches. Compliant organisations will have to document their breaches in detail even if they don’t need to directly report them. 85