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to employees. Second, it’s possible to protect the rest of the network<br />

from compromised desktops and laptops by segmenting the<br />

network and implementing strong authentication between user<br />

networks and anything of importance.<br />

According to Mortakis, this is the principle of least privilege. No<br />

users should be assigned administrative access unless absolutely<br />

needed. “If someone isn’t in human resources, they shouldn’t have<br />

access to HR files,” he explains. “In addition, there should be controls<br />

in place to alert you when an employee tries to access files<br />

they shouldn’t.”<br />

Another issue that comes with employees is that they want to use<br />

their own devices to access data. “There isn’t a complete solution to this<br />

issue,” Mortakis says. But there are some steps that can reduce the risk.<br />

“With data logging, you know when something has been downloaded,<br />

and remote-access controls can stop them from being able to download<br />

specific types of files.”<br />

Another area of concern is vendors, contractors, and other partners<br />

who use or have access to your company’s data. “Vendors entrusted<br />

with critical data need to have secure storage facilities with access controls,<br />

corporate security policies and testing, and certification, such as a<br />

Service Organization Controls (SOC) audit,” Moody says. “You need to<br />

ask probing questions and have written agreements on standards that<br />

are to be maintained.”<br />

IT Solutions<br />

Of course, there are steps best left to the professionals, beginning<br />

with automatically applying critical security patches (pieces of software<br />

designed to remedy vulnerabilities that have been identified in<br />

software) or updates to all systems and applications by investing in<br />

a patch-management solution. Patch management is a strategy used<br />

to determine what patches should be applied to which applications<br />

and when. Many vulnerabilities are remediated by simply applying the<br />

latest patches to existing systems.<br />

In addition, you must regularly back up data and verify the integrity<br />

of those backups. “Backups are critical in ransomware incidents; if you<br />

are infected, backups may be the best — or only — way to recover your<br />

critical data,” Mortakis explains. “The backups must also be secure and<br />

not connected to the computers and networks they are backing up.”<br />

Examples might include securing backups in the cloud, or physically<br />

storing them offline.<br />

With more data being stored in cloud environments and employees<br />

accessing that data from their own devices, consider implementing<br />

two-factor authentication, Moody says. With two-factor authentication,<br />

employees and other users are required to have not only a password and<br />

user name, but also something that only they have, such as a physical<br />

token. For example, if you have tried to log in to your bank account from<br />

a new computer, your bank may have texted you a code to enter before<br />

granting you access to your account information.<br />

To reduce risk, don’t keep sensitive information if you don’t need it,<br />

advises Mortakis. “Put in place a well-defined retention policy that limits<br />

the amount of time that sensitive data is stored.”<br />

An important step to ensure that data is secure is to test your system.<br />

Penetration testing, ethical hacking, and vulnerability assessments are<br />

useful tools for identifying hidden network and host vulnerabilities. “At<br />

ILG, we have our own team, and we also have a third party on demand,”<br />

Mortakis says. “I recommend performing all types — web and network<br />

layers, internal and external networks — of penetration testing at least<br />

annually. We perform twice-a-year penetration testing, quarterly internal<br />

network-vulnerability assessments, and monthly external networkvulnerability<br />

assessments. And that doesn’t count any additional testing<br />

we undergo for compliance purposes, such as PCI scans.”<br />

Where Credit Goes Through<br />

Because so many data breaches have targeted payment-card information,<br />

that’s an area of particular concern. “Developers should only work<br />

with a payment-card processor that has achieved the Payment Card<br />

Industry Security Standards Council’s highest level of certification: PCI<br />

Certification Level 1,” Moody says. “This certification provides them with<br />

reassurance that the processor can accept, process, store, and transmit<br />

credit-card information on their behalf in a secure environment.”<br />

In addition, if a company accepts credit cards at — for example —<br />

resorts, sales centers, and retail environments, it should have upgraded<br />

to EMV chip readers for credit cards by now. “As of October 2014, if<br />

a merchant doesn’t have EMV in place, they’re automatically deemed<br />

responsible for any breaches that occur,” Moody says. “If you’re still<br />

swiping, it’s way past time to adopt this technology, which has far superior<br />

security.”<br />

Judy Kenninger, RRP, heads Kenninger Communications and has been covering<br />

the shared ownership and vacation real estate industries for nearly two decades.<br />

Resources<br />

At AIFEducates.com, you can watch ARDA International<br />

Foundation’s Learning Center webinar on Consumer Financial<br />

Protection Bureau requirements, Risk Management Strategies:<br />

The Need for a Robust Compliance Management Program.<br />

Open Web Application Security Project is a worldwide<br />

not-for-profit charitable organization focused on improving the<br />

security of software. Similar to Wikipedia, it’s a community that<br />

shares information regarding best practices in software security<br />

and application tools.<br />

owasp.org<br />

The Payment Card Industry (PCI) Security Standards<br />

Council is a global forum for the ongoing development,<br />

enhancement, storage, dissemination, and implementation<br />

of security standards for account-data protection.<br />

pcisecuritystandards.org<br />

Verizon’s 2016 Data Breach Investigations Report<br />

examines more than 100,000 incidents, including 2,260<br />

confirmed data breaches across 82 countries. With data<br />

provided by 67 contributors, including security-service providers,<br />

law enforcement, and government agencies, the report offers<br />

insight into cybersecurity threats.<br />

verizonenterprise.com/verizon-insights-lab/dbir/2016<br />

The Visa Global Registry of Service Providers lists providers<br />

that adhere to strict security standards and are in compliance<br />

with PCI regulations. Visa recommends, “Clients and merchants<br />

should reference the site regularly as part of their due-diligence<br />

process and should only use service providers that are listed<br />

on the registry for outsourcing their payment-related services.”<br />

visa.com/splisting<br />

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