Risk Assessment -- Business Impact Activity

By Drs. Dave Eargle and Anthony Vance

First, read the information in the Informative References section.

Following that section are several breach incident cases. For each of the cases, do the following from the perspective of the business affected by the incident:

  1. Identify and prioritize the key assets involved in the security incident
  2. Explain which security objective(s) failed for those assets (confidentiality, integrity, and availability)
  3. Determine the business impact to each of the assets identified in terms of “high,” “medium,” or “low” per FIPS-199: “Standards for Security Categorization of Federal Information and Information Systems.

Informative References

The below table from FIPS-199 desecribes how to categorize the business impact of a failure to meet a given information system security objective.

Table 1. Potential Impact Definitions for Security Objectives
Potential Impact
Security Objectives Low Moderate High
Confidentiality

Preserving authorized restrictions on information access and disclosure, including means for protecting personal privacy and proprietary information.

[44 U.S.C., SEC. 3542]

The unauthorized disclosure of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals.

The unauthorized disclosure of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.

The unauthorized disclosure of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.

Integrity

Guarding against improper information modification or destruction, and includes ensuring information nonrepudiation and authenticity.

[44 U.S.C., SEC. 3542]

The unauthorized modification or destruction of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The unauthorized modification or destruction of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The unauthorized modification or destruction of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.
Availability

Ensuring timely and reliable access to and use of information.

[44 U.S.C., SEC. 3542]

The disruption of access to or use of information or an information system could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals. The disruption of access to or use of information or an information system could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals. The disruption of access to or use of information or an information system could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.

Per FIPS-199, pp. 2–3:

“The potential impact is LOW if—

− The loss of confidentiality, integrity, or availability could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals.1

AMPLIFICATION: A limited adverse effect means that, for example, the loss of confidentiality, integrity, or availability might: (i) cause a degradation in mission capability to an extent and duration that the organization is able to perform its primary functions, but the effectiveness of the functions is noticeably reduced; (ii) result in minor damage to organizational assets; (iii) result in minor financial loss; or (iv) result in minor harm to individuals.

The potential impact is MODERATE if—

− The loss of confidentiality, integrity, or availability could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.

AMPLIFICATION: A serious adverse effect means that, for example, the loss of confidentiality, integrity, or availability might: (i) cause a significant degradation in mission capability to an extent and duration that the organization is able to perform its primary functions, but the effectiveness of the functions is significantly reduced; (ii) result in significant damage to organizational assets; (iii) result in significant financial loss; or (iv) result in significant harm to individuals that does not involve loss of life or serious life threatening injuries.

The potential impact is HIGH if—

− The loss of confidentiality, integrity, or availability could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.

AMPLIFICATION: A severe or catastrophic adverse effect means that, for example, the loss of confidentiality, integrity, or availability might: (i) cause a severe degradation in or loss of mission capability to an extent and duration that the organization is not able to perform one or more of its primary functions; (ii) result in major damage to organizational assets; (iii) result in major financial loss; or (iv) result in severe or catastrophic harm to individuals involving loss of life or serious life threatening injuries.

Case 1: Marriott Breach (Starwood hotels)

News articles:

Answer the following questions:

  1. What are Marriott’s key assets, in order of priority?
  2. Which security objective(s) failed (e.g., confidentiality, integrity, and/or availability)?
  3. What was the business impact to those assets (e.g., high, moderate, or low)?

Case 2: Muskingum Valley Health Centers

  • Muskingum Valley Health Centers (MVHC) is a medium-sized healthcare provider that serves over 137,000 patients a year at locations in five counties in Ohio (mvhccares.org).
  • The organization suffered a ransomware incident in August 2020 that the company subsequently reported as a data breach.
  • “Ransomware is malware that locks your keyboard or computer to prevent you from accessing your data until you pay a ransom, usually demanded in Bitcoin. The digital extortion racket is not new—it’s been around since about 2005, but attackers have greatly improved on the scheme with the development of ransom cryptware, which encrypts your files using a private key that only the attacker possesses, instead of simply locking your keyboard or computer” (Wired.com: What is Ransomware?)
  • Read the following news article excerpt about the incident:

    Ohio hospital’s EHR hit by ransomware attack, exposes 7,000+ patients’ info Jackie Drees - Thursday, August 6th, 2020

    Zanesville, Ohio-based Muskingum Valley Health Centers has notified more than 7,000 patients that their personal information may have been exposed in a ransomware attack on its EHR system.

    In the July 31 data breach notice, the hospital said that in June it discovered a ransomware attack on the EHR system of Cambridge-based OB GYN Specialists of Southeastern Ohio, which MVHC acquired in 2018

    A cybersecurity firm determined that three OB GYN Specialists’ systems, including its EHR server that contained patient records from 2012-17, were hit by ransomware on May 31. Patient names, dates of birth, Social Security numbers, diagnoses, conditions, lab results and insurance claim details were exposed.

    MVHC reported the incident on July 31 to HHS’ OCR data breach portal as affecting 7,447 individuals.

    The hospital has updated its security policies, procedures and password requirements in response to the incident and is also offering 24 months of credit monitoring and identification theft protection services to individuals affected.

    https://www.beckershospitalreview.com/cybersecurity/ohio-hospital-s-ehr-hit-by-ransomware-attack-exposes-7-000-patients-info.html

  • Breach notification letter:

    What Happened

    On June 2, 2020, an employee discovered what appeared to be a ransomware attack on the EMR system of OB GYN Specialists. We immediately took the server containing the EMR system off-line. We launched an internal investigation and hired an external cybersecurity firm to conduct an in-depth investigation. In their July 24, 2020 final report, the cybersecurity firm stated that on May 31, 2020, a ransomware attack encrypted three systems of OB GYN Specialists, including the server containing patient records for the period of 2012-2017. Although their investigation found no evidence that the data was exfiltrated (copied or transferred), we are still required to notify you of this incident.

    What Information Was Involved

    The OB GYN Specialists’ patient records included:

    • Demographic information, including patient names, dates of birth, and addresses. We assume that Social Security numbers were also included.
    • Clinical information, including diagnoses/conditions, lab results, medications, and other treatment information.
    • Financial information, including insurance claim information. This breach did NOT include patient bank account or credit card account information.

    What We Are Doing

    We take the security of your information seriously and are implementing measures to reduce the likelihood of future cyber-attacks. We have revised our security policies and procedures, strengthened our password requirements and are updating our security risk analysis.

    In addition, we are offering identity theft protection services through ID Experts®, the data breach and recovery services expert, to provide you with MyIDCare™. MyIDCare services include: 24 months of credit and CyberScan monitoring, a $1,000,000 insurance reimbursement policy, and fully managed id theft recovery services. With this protection, MyIDCare will help you resolve issues if your identity is compromised.”

    https://www.mass.gov/doc/assigned-data-beach-number-17359-muskingum-valley-health-centers/download

Answer the following questions:

  1. What are MVHC’s key assets, in order of priority?
  2. Which security objective(s) failed (e.g., confidentiality, integrity, and/or availability)?
  3. What was the business impact to those assets (e.g., high, moderate, or low)?

Footnotes

  1. “Adverse effects on individuals may include, but are not limited to, loss of the privacy to which individuals are entitled under law. effect on organizational operations, organizational assets, or individuals,” FIPS 199, p. 2, footnote in the original.