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1 CYBER BREACH MITIGATION How Do I Start & Where is my Money Best Spent? Speakers: George Adkins, Wortham Power Gen Insurance Brad Luna, N-Dimensions TPPA

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Page 1: CYBER BREACH MITIGATION - TPPA€¦ · -Target Mitigation Of 80% Of Cyber Risk At A Reasonable Cost -Deploy Cyber Insurance For Balance Sheet Protection From Other 20%. -Many Cyber

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CYBER BREACH MITIGATION How Do I Start & Where is my Money Best Spent?

Speakers: George Adkins, Wortham Power Gen Insurance Brad Luna, N-Dimensions

TPPA

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THE FUTURE IS HERE

INCIDENTS WITH PUBLIC POWER ELEMENTS 2010 (Stuxnet) • WORM affects Seimans Software Based PLC • Reprogrammed to Vary Speeds of Rotating Machinery • Hid Speed Variance from Control Room Operator

2015 (PREN) • Power Grid Shutdown Using “Black Energy” Malware • Variation of Same Malware Found on U.S. Utilities in 2014

2016 • Denial of Service attack

– Printers, IP cameras, residential gateways and baby monitors • Overload/Shutdown DNS Provider - Dyn • Mirai Botnet Used • (THINK SMART METERS)

• 2 of 3 Considered STATE SPONSORED

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THE FUTURE IS HERE

PUBLIC POWER/UTILITY INCIDENTS • 2005 (St. Louis, MO)

– Retention Dam - Hacker caused equipment malfunctions and issues with remote monitoring – Resulted in release of 1 billion gallons of water.

• 2008 (New Orleans) – CIA confirmed cyber attack led to a power outage spanning multiple

towns.

• Nov 2011 (Central Illinois) – SCADA (Water System Management) hacked by computer in Russia –

damaged water plant pumps

• 2013, a Northeast IOU – 1/3 of customers records are taken before blocked

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THE FUTURE IS HERE

PUBLIC POWER/UTILITY INCIDENTS • 2014, a Southern Utility

– W2s taken from HR, hackers file false tax returns

• 2015 (Rye Brook, NY) – Hacker gained control of Bowman Avenue Dam Through cable modem – Found before any damage done

• 2015 - Rural Electric Cooperative Hacks

– Hacker program IP based phone to to dial a (900) when customer service called � Customer charged for call

– New HVAC System sent outbound communications for to Russian IP address – Communications Provider hit with DNS attack and shutdown

� COOP lost communications with AMI. Substation SCADA, field workers

• 2016 Midwest Utility – Outsourced AMI Server Hacked, Financial and Customer Data at risk – Traced to Chinese IP address

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THE FUTURE IS HERE

PUBLIC POWER/UTILITY INCIDENTS

• March 2016 (Kemuri Water Utility – Fake Name) – Exploited Web Accessible Payment System – Changed Levels Of Chemicals In Treatment Plant – Manipulated Hundreds Of Plc’s To Change Valve Patterns And Duct Movements – IP Addresses Of Hackers Linked Hacktivist In Syria.

• April 2016 – Lansing, MI BWL – Employee Open Infected E-mail Attachment – Hackers Shutdown Accounting And Email – $2.4m Total Cost, All But $500k Covered By Insurance ($100k Ded Plus System

Upgrades) – $25,000 Bitcoin Ransom

• Late 2016 (Southeast U.S.) – Small Southeast Integrated Water/WW/Elec Utility – Ransonware Payment – Converted To Bitcoin Amount Unknown

• • Many Others Undocumented

Brad to jump in on Lansing
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NERC CIP v5 expands to LOW Impact Assets, Transient Devices • July 1 2016 Requirements

• Most Requirements Apply to HIGH and MEDIUM Impact Assets. • Basic Program Elements Apply to LOW Impact Assets.

• April 1 2017 Requirements

• LOW: Document Policies and Plans For Cybersecurity Awareness, Physical Security, Electronic Access & Incident Response.

• HIGH & MEDIUM: Implement Plans for Transient Cyber Assets and Removable Media.

• September 1 2018 Requirements • LOW: Implement Plans for Physical Security and Electronic Access.

• NERC CIP Compliance Does Not Equal Cybersecurity. There are Intersecting Points, but Represent Two Different Goals and Two Different Scopes.

THE FUTURE IS HERE

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BakerHostetler 2016 Data Security Incident

HOW ARE THE BREACH'S OCCURRING?

The Future is Here

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THE FUTURE IS HERE

REALITY CHECK • Utility Cyber Breaches Already Occurring • Mitigating 100% of Cyber Risk is Expensive &

Impossible • FERC Fines & Penalties for Non-Compliance • Most Incidents Caused by Employees

Public Power

Water & Gas Utilities

Rural Co-Ops

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Mitigating 100% Of Cyber Risk Is A Financial Hardship And Nearly Impossible

THE PLAN - Target Mitigation Of 80% Of Cyber Risk At A Reasonable Cost

- Deploy Cyber Insurance For Balance Sheet Protection From Other 20%.

HYPOTHESIS

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PUBLIC POWER CYBER RISK EVALUATION SURVEY

• http://worthampowergen.com/cyber-risk-evaluation-tool.html

– 12 Question Survey (Check Boxes)

– Evaluates Cyber-Hygiene

– Controls that Mitigate 80% of Cyber Risks

– Generates Report (Plan of Attack)

Evaluate/Plan of Attack

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80% Mitigation

CYBER SECURITY EVALUATION REPORT • No-Cost Report

– Developed and Evaluated By Cyber Risk Process Experts – Cybersecurity Maturity Score – Weak Area Discussion/Action List – NERC CIP Overview for Low Impact Asset Deadlines – Survey Responses Are Confidential/ SSL/TLS Encryption

• Uses – Management Reporting – Budget Request Support – “To-Do” List

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PLAN OF ATTACK

EVALUATION AREAS

– Access and Account Management

– Asset Baselines and Change Management

– Asset Inventory: Hardware and Software

– Boundary Defense: Electronic and Physical Security

– Incident Management and Review

– Information Management and Protection

– Boundary Defense: Electronic and Physical Security

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• N-Dimension’s N-Sentinel Monitoring – Proactive Continuous Cyber Threat Vigilance – Detection And Alerts – Timely assessment and correlation of alerts to verify threat (source, type, etc.) – Identify and prioritize remediation – In-depth Intelligence About Attacks – Utility Community Insights – Global cyber awareness – utility community insights, flash alerts, etc

**** DOE Grant Supplements 80% of Cost – 1st year ****

• N-Dimension’s N-Sentinel Vulnerability Assessment – On-demand endpoint Vulnerability Assessments (servers, firewalls, PCs, ….) – Identify, Report and prioritize remediation – Actionable insights in vulnerabilities discovered – Timely actions to improve security posture – Correlate Vulnerabilities Assessment findings with Intrusion Alerts

Monitoring

Both with Easy, fast deployment (no costly consulting work needed), hands off management so you can

focus on what you do best.

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How N-Sentinel Works

Substations Meters

Distribution Devices

Reports

Alerts Secure

Customer Web Portal

Network Operations Center

Community-based Contextual Analysis

N-Dimension Security Analysts

SCADA AMI

OMS

Threat Intelligence

Denotes possible service deployment locations

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Mitigating 100% Of Cyber Risk Is A Financial Hardship And Nearly Impossible

THE PLAN Target Mitigation Of 80% Of Cyber Risk At A Reasonable Cost

DEPLOY CYBER INSURANCE FOR BALANCE SHEET PROTECTION FROM OTHER 20%.

HYPOTHESIS

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20% - Balance Sheet Protection

CYBER LIABILITY INSURANCE – THE COVERAGE

Third Party Liability Coverages Coverage Description

Security & Privacy Liability Damages & Expenses Incurred for liability from allegations of security and privacy wrongful acts.

Regulatory Defense and Fines/Penalties

Amount obligated to pay from certain privacy regulatory actions.( i.e. HIPAA, NERC, FERC, NRC, Payment Card Assessments)

Media Liability Liability from allegations of multimedia wrongful acts (libel, slander, invasion of privacy, etc.).

First Party Coverages Coverage Description

Notification Expense/Credit Monitoring

Notification expenses incurred following a privacy event/breach. (Credit monitoring services, call center services, etc.)

Network Interruption Data Asset Restoration

Costs to restore/replace computer programs, software and electronic data (i.e. Customer consumption and preference data).

Extortion Expenses Money/Expenses paid relating to cyber extortion demands.

Fraud

Loss of funds arising out of fraudulent email wire transfer requests or other direct monetary loss (Computer Fraud/Electronic Fraud/Social Engineering Fraud).

Loss of Profits/Extra Expense

Business Interruption/Extra Expense (Loss of profits) resulting from a Cyber Breach.

Crisis Management/ Reputational Harm

Expenses including forensics, public relations etc.

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INCIDENT RESPONSE PLAN

• TOLL-FREE NUMBER (24/7) TO REPORT INCIDENT • SERVICE TRIAGES AND DETERMINES PLAN • CLAIMS MANAGEMENT – Process Management Including

Appointing Specialists & Legal Services • COMPUTER FORENSIC SERVICES – “How, When & Breach

Impact” • NOTIFICATION/CALL CENTER SERVICES – Instructions for

Reaction Response, Notification & Call Center. • FRAUD RESOLUTION SERVICES – Credit/ID Theft Monitoring &

Remediation. • PUBLIC RELATIONS AND CRISIS MANAGEMENT SERVICES

POST BREACH INSURANCE RESOURCES

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-Utility Cyber Risk Trending Towards Ransom and Physical Damage

-Most Breaches Caused by Employee Errors

-Mitigating 100% Of Cyber Risk Is A Financial Hardship And Nearly Impossible

-Target Mitigation Of 80% Of Cyber Risk At A Reasonable Cost -Deploy Cyber Insurance For Balance Sheet Protection From Other 20%.

-Many Cyber Breach Costs not covered in Traditional Insurance (General Liability)

-APPA Insurance Programs Less Expensive and Broader Coverage

-Leverage Group Purchasing Power -Use Savings to Fund Cyber effort

SUMMARY

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THE FUTURE IS HERE

• Norse Attack Map

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APPENDIX • Program Costs • Public Power Hacking Video • Itegriti & N-Dimensions Overview • N-Sentinel Costs • Evaluation Areas • How N-Sentinel Works

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PROGRAM COSTS

ANNUAL REV ($m)

(1)

POLICY LIMIT

Deductible Network Monitoring (If bundled with Insurance)(2)

$1m $2m

Premiums

0 - 5 $2,525 $3,775 $2,500

$7,500

*1st Year Cost Reduced to $1,960 for APPA members

through DOE program

5 - 15 $3,275 $4,850 $10,000

15 - 25 $4,650 $6,900 $10,000

25 - 35 $6,925 $10,300 $15,000

35 - 50 $9,200 $13,700 $15,000

50 - 75 $12,250 $19,000 $25,000

75 - 100 $16,750 $25,000 $25,000

Over 100 Refer to Underwriters Higher Limits Available Upon Request

(1) Parent( City) can be included in coverage if revenues are reported (2) Monitoring Cost is Annual Per Network, Assumes 1 Network

HCI Cyber Program (Financial Protection)

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APPA/HOMETOWN CYBER LIABILITY APPLICATION

• Organization and Contact Information

• # of Personally Identifiable Records?

– #meters + #past customers + # employees + #retirees

• Annual Utility Revenues?

• Disaster Recovery Plan in Place?

• Sensitive Data Encrypted or Masked? • Firewalls and Auto Updating Antivirus Software In force?

• Developing a Plan Per NERC CIP Standards?

• Had any Incidents in Last 3 years That Would Have Been a Claim?

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Data Breach Cost Estimates NUMBER OF RECORDS (PCI) 5,000 20,000 100,000 Forensics $14,700 $16,800 $28,000 Security Remediation $70,700 $72,700 $84,000 Breach Coach/Legal Advice $38,000 $38,000 $38,000

INVESTIGATION COST TOTAL $123,400 $127,500 $150,000 Fines & Penalties $26,000 $26,000 $25,000 Fraud Assessment $62,500 $250,000 $1,250,000 Card Re-Issuances $10,000 $40,000 $200,000

PCI TOTAL COST $98,500 $316,000 $1,475,000 Customer Notification $5,000 $20,000 $100,000 Call Center $375 $1,500 $7,500 Credit/ID Monitoring $4,500 $18,000 $72,500 Public Relations $21,000 $21,000 $21,000

CUSTOMER NOTIFICATION/CRISIS MANAGEMENT COST $30,875 $60,500 $201,000

State AG $6,650 $18,300 $58,300 HHS $0 $0 $0 Other $0 $0 $0 REGULTORY FINES/PENALTIES $6,650 $18,300 $58,300 Defense $283,000 $283,000 $283,000 E Discovery $73,600 $73,500 $140,000 Settlements/Damages $150,000 $150,000 $150,000

CLASS ACTION LAWSUIT COSTS $506,600 $506,500 $573,000

TOTAL COST $766,025 $1,028,800 $2,457,300

COST per RECORD $153 $51 $25

NOTES: FIRST BREACH FOR COMPANY, DATA STORED IN CENTRALIZED SYSTEM

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Verizon 2016 Data Breach Investigations Report

CYBER INSURANCE PAYOUTS PER TYPE OF COST

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Cyber Breaches – The Risks How Insurance Responds?

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• Exposure: 1st Party Physical Damage – Risk

� Damage to Owned Physical Assets as a result of a Cyber attack.

– Insurance Response

� Cyber Insurance - Available from limited Underwriters, Expensive. � All Risk Property Insurance – Historically, “Resultant Damage”

Covered.

HOW INSURANCE RESPONDS TO A CYBER ATTACK

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• Exposure: Business Interruption

– Risk � Business Interruption here is loosely defined as “Loss of Profits +

Continuing Expenses”. o Historically, Business Interruption has not been offered to Public Power due

to its ability to recover the financial loss in a subsequent rate case. However,

utilizing the argument that “buying Business Interruption is a more

responsible use of the Rate Payer funds”, there are some Public Power

entities that are now pursuing Business Interruption Insurance.

– Insurance Response

� Cyber Insurance - Available through Select Markets, Including the HCI/APPA Program.

� All Risk Property Insurance – Covered as a result of Physical Damage caused by a Cyber attack.

HOW INSURANCE RESPONDS TO A CYBER ATTACK

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• Exposure: Extra Expense – Risk

� Extra Expense is cost associated with minimizing the loss of profits. (i.e. renting a temporary transformer while original being repaired)

– Insurance Response � Cyber Insurance - Available through Select Markets, Including the

HCI/APPA Program. � All Risk Property Insurance - Covered as a result of Physical Damage

caused by a Cyber attack. o Extra Expense, in an All Risk Property Insurance Policy, generally does not

include costs associated with buying Replacement Power. Replacement

Power coverage has developed a separate insurance market.

HOW INSURANCE RESPONDS TO A CYBER ATTACK

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• Exposure: Customer Physical Damage/Loss of Profits from

“Failure to Supply Power” – Risk

� 3rd Party Lawsuit as a Result of a Failure to Supply Power � Most Public Power entities enjoy some 3rd party liability tort protection from

“Failure to Supply” power. This is generally outlined in the “Transmission

Tariff” document and liability is usually limited to “Gross Negligence or

Intentional Wrongdoing” and/or a monetary cap.

– Insurance Response

� Cyber Insurance - Generally Excluded, but can be purchased for expensive rates.

� General Liability – Generally Excluded if an Exposure Exists � Excess Liability Insurance – Coverage Available

HOW INSURANCE RESPONDS TO A CYBER ATTACK

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Electric Utility Cyber Liability Insurance Benchmarking

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CYBER INSURANCE PREMIUM DISTRIBUTION FOR ELECTRIC UTILITIES

BENCHMARKING

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CYBER INSURANCE POLICY LIMIT DISTRIBUTION FOR ELECTRIC UTILITIES

BENCHMARKING

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CYBER INSURANCE DEDUCTIBLE DISTRIBUTION FOR ELECTRIC UTILITIES

BENCHMARKING