Let’s examine the role of the 3PAO in the FedRAMP assessment process.

The Federal Risk and Authorization Management Program (FedRAMP) was designed to support the federal government’s “cloud-first” initiative by providing a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. All cloud service providers (CSPs) that work with the U.S. government must comply with FedRAMP, and during the assessment process, all of these CSPs will work with a FedRAMP third-party assessment organization, or 3PAO, such as Lazarus Alliance.

What is a FedRAMP 3PAO?

A FedRAMP 3PAO is an independent assessor that has been certified to help cloud service providers and government agencies meet FedRAMP compliance regulations. CSPs who are pursuing certification through the FedRAMP JAB P-ATO process must partner with an accredited 3PAO for their FedRAMP security assessment. A 3PAO is optional for CSPs pursuing FedRAMP Agency authorization.

The 3PAO accreditation process is quite rigorous, requiring auditors to meet very high standards for quality and technical competence. To accredit 3PAOs, FedRAMP partners with the American Association for Laboratory Accreditation (A2LA). The A2LA assessment process evaluates the 3PAO’s technical competence and assesses their compliance with the general requirements of ISO/IEC 17020:2012 and FedRAMP specific requirements.

FedRAMP 3PAOs must be reassessed and recertified annually.

The role of the 3PAO during a FedRAMP assessment

The FedRAMP certification process begins with the preparation of the System Security Plan (SSP) document, in which the CSP describes all of the information security controls they are currently using and their implementation. Due to the potential for a severe conflict of interest, a 3PAO is not allowed to prepare an SSP for a CSP and then perform the CSP’s FedRAMP assessment; the CSP must prepare their own SSP prior to the commencement of the assessment.

During the FedRAMP assessment, a 3PAO:

• Assesses the CSP’s system’s operational security capabilities and prepare a Readiness Assessment Report (RAR), if the CSP is seeking a “FedRAMP Ready” designation prior to commencement of the formal assessment
• Develops the Security Assessment Plan (SAP), a customized account of the security assessment methodology, in conjunction with the CSP
• Performs the CSP’s security assessment
• Documents the results of the security assessment in the Security Assessment Report (SAR) and supporting documents

The SSP, SAP, and SAR make up the authorization package, which is submitted to the authorizing party (either the JAB or the agency) for review and approval.

After their initial certification is approved, CSPs enter what FedRAMP calls “continuous monitoring.” To maintain their certification, they must have their cloud systems reassessed annually, as well as whenever they make certain changes to their systems, to ensure that the systems still meet FedRAMP requirements. These reassessments must also be performed by a 3PAO.

To make it easier for our FedRAMP clients to prepare their SSP, Lazarus Alliance includes, at no additional cost, access to the IT Audit Machine (ITAM) FedRAMP SSP module from Continuum GRC. ITAM has self-help modules that walk the CSP through the process of preparing an SSP, and Lazarus Alliance also uses ITAM to perform the actual FedRAMP 3PAO assessment. By automating as much of the process as possible, we’re able to dramatically cut the time requirements and costs of FedRAMP certification and put it within reach of most CSPs.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.

New HIPAA fines will be based on an organization’s “level of culpability”

Following a record year for HIPAA settlements that saw the U.S. Department of Health and Human Services (HHS) collect $28.7 million in HIPAA fines, HHS has reduced the maximum annual HIPAA fine in three out of the four penalty tiers. However, HHS’ move doesn’t mean that healthcare organizations are now free to take a laissez-faire approach to compliance or cyber security.

More culpability = higher HIPAA fines

For years, healthcare organizations have been complaining about eye-popping HIPAA fines in the wake of breaches that were not their fault. The adjusted fines address this issue by making willfully negligent organizations pay more than those who exercise due diligence. The new HIPAA penalty tiers are effective now and are as follows:

• Tier 1 (no knowledge of violation): $100 to $50,000 per violation; capped at $25,000 per year
• Tier 2 (reasonable cause): $1,000 to $50,000 per violation; capped at $100,000 per year
• Tier 3 (willful neglect, corrected): $10,000 to $50,000 per violation: capped at $250,000 per year
• Tier 4 (willful neglect, not corrected): $50,000 per violation; capped at $1.5 million per year

While the maximum HIPAA fines have gone down significantly, these are still hefty chunks of change, especially for small and medium-sized organizations with tight budgets. It’s also important to note that the annual cap is per year for every year the violation persists.

There’s more at stake than just HIPAA penalties

HIPAA compliance does not automatically equate to cyber security, and healthcare organizations have a lot more to worry about than just being slapped with HIPAA penalties, which are assessed only in a minority of cases, anyway. Even if a healthcare organization faces no HIPAA fine or only a small one, it is still subject to:

• Other compliance mandates, such as PCI DSS.
• The theft of confidential business information or employee data.
• State data privacy laws, such as the law Washington State just enacted, halving the time organizations have to notify victims of a breach from HIPAA requirements and broadening the definition of what would be considered breached information.
• Civil lawsuits filed by angry patients, including class action suits.
• Bad PR and brand damage that could lead to lost business and difficulty recruiting talent.
• Difficulties with current or future M&A transactions; no organization wants to inherit another’s cyber security or compliance problems.
• Incident response and mitigation costs, including system restoration, replacement of hardware, and the price of identity theft solutions for breach victims.

Healthcare organizations can also be victimized by cyber attacks that do not involve data breaches or HIPAA penalties but are quite costly and destructive, such as ransomware and cryptojacking malware. Ransomware, which has plagued the healthcare industry for several years, can be used to disable medical IoT devices or lock providers out of electronic health records and other critical systems, putting patients’ health and lives at risk.

The cyber security landscape is dynamic, and new threats are emerging literally daily. HIPAA is important, but it should not be healthcare organizations’ only compliance or cyber security concern, and fines should not be the only motivating factor to defend against cyber abuse.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.

Formjacking allows hackers to steal payment card data and other information submitted through online forms

As individuals become more savvy about avoiding phishing emails, and enterprises get better at filtering them out before they ever reach employees’ inboxes, it’s become more difficult for hackers to infect enterprise systems with ransomware and cryptojacking malware. Companies are also becoming more diligent about backing up their systems, and cryptocurrency prices have fallen, meaning that the potential profits from ransomware and cryptominers have likewise diminished.

So what’s a hacker to do if they want to make a fast, illicit buck? The answer is formjacking, a cyber attack that dramatically increased in popularity in 2018 and is now hitting an estimated 4,800 websites a month.

What is formjacking?

Formjacking is sometimes described as the online version of ATM card skimming – another hacking method that is becoming less fruitful as more brick-and-mortar retailers implement EMV chip technology. In a typical formjacking scheme, hackers breach an ecommerce site and insert malicious JavaScript code into the form where shoppers enter their payment information. When the customer hits “submit,” the information is transmitted to the hackers, who can then sell the credit card data or use it themselves.

Formjacking is very difficult to detect because it’s invisible to both the customer and the retailer. The customer sees the transaction being processed normally, and the retailer still receives the order information and payment. The malicious code tends to be very short, and hackers disguise it to appear innocuous or routine. There is no indication that anything unusual has happened until days, weeks, sometimes even months later, when the retailer discovers the code or customers see unusual charges appearing on their credit card statements.

Most formjacking malware is developed by Magecart, the name given to a hacking ring composed of loosely affiliated groups that specialize in stealing credit card data. In addition to orchestrating their own attacks, Magecart groups also offer formjacking malware-as-a-service to other cybercriminals.

Small- and medium-sized retailers are the most frequent victims of formjacking, likely because their cyber defenses tend to be less robust than large ecommerce sites. However, because formjacking malware often gets onto sites by compromising third-party services, such as payment processing and chatbot applications, very large companies are not immune. British Airways and Ticketmaster number among the high-profile victims of Magecart formjacking attacks.

While formjacking is usually deployed to steal payment card data from ecommerce sites, it can be used to compromise any type of online form. This means that formjacking could also be used to steal other sensitive data, including login credentials, Social Security Numbers, or even confidential business information, such as contact information for sales prospects who have signed up for a company’s mailing list.

Protecting your website against formjacking

Implement Subresource Integrity (SRI) tags. SRI tags use cryptographic hashes to ensure that the files that web applications and web documents fetch do not contain unexpected content that could indicate they’ve been manipulated by a malicious third party, such as additional code.

Monitor your site’s outbound traffic. If you see form data being transmitted to an unusual or unknown resource, your site could be under attack from formjacking or other malware.

Secure your supply chain. Hackers frequently insert formjacking malware onto sites by compromising third-party application developers, especially payment processors but also chatbots, quizzes, and other common web applications. Talk with a cybersecurity expert, such as Lazarus Alliance, about solutions to test software updates and scan your website for unexpected code changes.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.