MarTech Today: Companies are afraid of everyone’s website but their own

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Article appeared in MarTech Today, Nov. 16, 2017

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The Media Trust CEO: Most of what happens on your web site is not controlled by you

And this third-party code, says Chris Olson, results in dozens of cookies for each user, security vulnerabilities and performance hits.

 

The Honest Truth about The Honest Ads Act

Building transparency with a little upfront disclosure

Authored by Chris Olson, CEO & Co-Founder, The Media Trust

Red, white, and blue vote buttons background

The fake news furor and potential Russian involvement in the U.S. 2016 general election is reaching a fever point with multiple congressional hearings, and, digital advertising is in the crosshairs. Like many challenging discussions about digital advertising, transparency is at the heart of the issue.

Digital compliance for political ads

The proposed Honest Ads Act, a bipartisan effort to govern digital advertising according to the same rules followed by traditional broadcast media regarding political advertising, and is the one tangible fallout from the investigations.

The act calls for all politically-oriented digital ads to be declared at purchase, clearly labeled in the creative, and available for consumer access via a searchable interface. Among other things, the buyer must disclose their contact information, candidate and/or campaign, ad flight duration, number of impressions/views, and targeting criteria. The platform must collect this information and retain it for at least four years. It applies to digital platforms with at least 50 million unique visitors a month for the preceding 12-month period that have political ad buyers who spend at least $500 within a calendar year.

In a nutshell, it requires publishers know their ad buyers, ensure ads comply with (regulatory) policies and provide consumer access to these ads and any associated targeting criteria. Sounds familiar?

Transparency starts with the buyer

As The Media Trust announced a few short months ago, our Digital Vendor Risk Management (DVRM) platform provides real-time visibility and insight into non-compliant activity and threats operating in an enterprise website and mobile app environments. More than a risk management framework, DVRM operationalizes client-specific digital asset policies, continuously evaluates digital partner compliance, and actively facilitates the resolution of violating behavior.

The crux of this solution is the ability to identify and manage an enterprise’s digital ecosystem participants, from ad tech up to the source buyer, and authorize their presence. In addition to privacy regulation and escalating security concerns, the Honest Ads Act is just another reason why enterprises need to know their partners.

DVRM – A simple solution to a complex problem

Applying a political lens to DVRM it’s evident that the platform is already satisfying most of the requirements to enable transparency and accountability. Advertising supply chain partners register via an online portal; ads are uploaded and continuously scanned according to targeting criteria; client-specific policy violations are flagged; and, ads are stored for historical reference.

Self-regulation forces a new digital approach

Major platforms have announced their approaches to address congressional concerns and hopefully stave off the vote, let alone passage, of the Honest Ads Act. However, this self-regulation will need to extend to others meeting the requirement threshold, like ecommerce and media publishers.

Regardless of Honest Ads going to vote, changes are in the air. As an industry that has largely grown via self-regulation, the signals are obvious. It is incumbent upon the industry to embrace these changes, especially with the DVRM platform as an easy way to codify and operationalize your policies.

GDPR: The Pandora’s Box is Open for Enterprise Websites

Authored by Chris Olson, CEO & Co-Founder, The Media Trust

This article originally appeared in Website Magazine in September 2017

GDPR Pandora's Box
Compliance officers need to rein in the regulatory risks associated with their digital properties. The European Union’s General Data Protection Regulation (GDPR) is a conversation starter for most companies looking to control compliance, reputational and revenue risks. However, while focus has been on identifying data elements–customer, partner and employee–held by the organization, most have overlooked the data collection activities occurring via the company’s websites and mobile apps. Just as with Pandora’s box, there’s a slew of GDPR-driven evil emitting from your digital properties. 

Digital vendors and the GDPR

The internet is a highly-dynamic environment and most websites require a host of third-party providers to render content on a consumer’s browser. In fact, enterprises tend to find two to three times more external code on their websites than expected. The purpose of this code is to provide or enable services–data management platforms, image or video hosting, marketing analytics, content delivery, customer identification, payment processing, etc.–required to deliver the website experience. However, most enterprises are not aware of the full depth of their reliance on these vendors and therefore do not fully examine the code executing in their own digital environment. This results in “Digital Shadow IT”, which is rampant on most enterprise digital properties since a majority of third-party contributed code executing on the consumer browser operates outside IT infrastructure.

True, third-party digital vendors power today’s robust and feature-rich websites and apps; the downside, however, is that their code execution goes largely unchecked, enabling unauthorized and unmonitored data tracking. This applies to not only known third-party vendors, but also other vendors with whom they are associated—frequently an external provider needs to call a fourth, fifth and sixth party to help execute its requested service. This essentially means that not only do organizations need to get their own house in order, they need to ensure their digital vendors do so as well.

Reliance on web application security tools (appsec) to holistically monitor website and app code is misguided since current web appsec tools are inadequate in capturing third-party code execution. Additionally, security and compliance professionals aren’t fully aware of the amount of consumer data collection activity that takes place–such as cookie drops, pixel fires, device ID fingerprint collection, and more. When GDPR goes live in May 2018, Ignorantia juris non excusat (ignorance of the law excuses not) will not be a valid defense when confronted with a data privacy violation. It comes as little surprise that around 86% of organizations worldwide are concerned about GDPR noncompliance.

What goes online stays online

One of GDPR’s key requirements centers around personal online behavior data—specifically information collected from an individual’s digital activity, i.e., websites visited, links clicked, forms submitted, etc.–and imposes restrictions on its safe transfer outside the European Union to other businesses or legal entities. Organizations will need a clear understanding of whose data is being collected, what data is being collected, what it is used for, and, if the data subject resides within the EU, where this information is being transferred and confidence that it is adequately protected!

Thanks to the density of code executing behind today’s websites and mobile apps this data inventory task is easier said than done.

Data documentation is much harder than companies anticipate, particularly for media and ecommerce websites offering digital display advertising space. Ultimately companies will need to ensure each of their advertising partners do not engage in activity which could put their organization or customer data in violation of GDPR.

Let’s not forget that recent website security breaches also demonstrate that third-parties are often the weakest link in the security chain. While an organization may employ rigorous security controls around physical vendors and contracted partners, they fail to extend the same rigor to their digital counterparts. Gartner predicts that by 2020, 33% of attacks experienced by enterprises will be as a result of shadow IT resources. Based on this evidence it is no wonder the GDPR focuses so heavily on third-party relationships. Clearly, when it comes to unchecked third-party code on websites and mobile apps, it isn’t just compliance risks but significant security risks that enterprises need to consider. How do firms control something they enable but don’t see and can ill-afford to ignore?

Limiting the risks

The odds are stacked against enterprise website operators, but creating a holistic digital vendor risk management program is a step in the right direction. The first step is documenting a few basic facts about your specific digital environment by asking website teams the following:

1. How many third-party vendors execute on websites and mobile apps?
2. What are the names of these vendors?
3. What exactly are they doing, i.e., intended purpose and also any additional, out-of-scope activity?
4. Do we have contracts to authorize the scope of the work?
5. How does third-party vendor activity affect overall website and mobile app performance?
6. What are the risks to data privacy?
7. What is my business’s exposure to regulatory risk via vendor behavior?
8. Is my organization maintaining encryption throughout the code execution chain?
9. As these vendors change over time, what is the process to identify new vendors and their activity on websites and apps?
10. Have Data Compliance policies been communicated to digital vendors?

Once these questions are successfully (or satisfactorily) answered, they should be revisited on a regular basis. Continuous monitoring of the digital environment helps create a compliance mechanism that alerts you to violations.

Organizations must then, of course, strive to document how their third-party partners handle this same data—another GDPR requirement. This information is critical to ensuring customer data is not being put at risk at any time regardless of data holder. In effect, both your organization and your third parties need to develop, communicate and enforce the policies, processes and technologies necessary to support all digital-related aspects of GDPR, from consumer online behavior data collection, use, storage and transfer.

When the regulation comes into force, enterprises that look at this as a key opportunity to protect user/ consumer data, and their own brand, could establish a competitive advantage. The end result should also translate to fewer breaches, less opportunities for cybercriminals, and a much safer cyberspace. The internet’s Pandora’s box may have been opened, but it doesn’t have to spread evil into the world.

GDPR Compliance Risks on Websites

Authored by Matt O’Neill, General Manager, Europe, The Media Trust. 

The way the cookie crumbles

Website-compliance-risks

Today’s websites and apps (your corporate website included) are powered by sophisticated technology. After all, in order support consumer expectations—content consumption, search, social networking, shopping carts, travel booking, banking, news, gaming and so much more—websites incorporate robust solutions on the backend.

These solutions aren’t news to most InfoSec professionals, but it is where security problems start. Think about it. Almost 80% of a typical website’s functionality is outsourced to vendors providing specialized services such as data management platforms, marketing analytics, customer identification, image or video hosting, payment processing, content delivery and more. This third-party code operates outside the purview of your IT and security infrastructure, which means that you control less than 25% of the code executing on your website. As the website operator, you have no insight into when this code is compromised to act as a conduit for malware propagation and unauthorized audience data collection. Considering the current regulatory environment around data compliance, the above statistics should make you nervous.

Cookie crumbs

To put it bluntly: You can’t control what you don’t see, and the third-party code enabled functionalities on your digital properties are compromised more often than you think. Also, you have more third-party code than you realize.

As the security provider of choice for the world’s largest digital properties, The Media Trust scans websites for security and policy violations and actively manages more than 500 incidents at any one time. Some of the simplest websites average 10 third-party vendors, but most have dozens. The vendors continuously change and so do their actions.

The Media Trust’s website security and scanning team often detects persistent or unauthorized cookies with a lifespan of 30 years or more; one brand name ecommerce website recently dropped a 7,000+ year cookie. This is a huge issue with the EU’s General Data Protection Regulation (GDPR) which goes into effect in less than a year. Compliance to GDPR requires detailed, real-time, knowledge of executing digital partners and their activity, including the type of data collected and how long the partner remains on the user’s device, i.e., browser, phone, tablet, etc.

If you are wondering how GDPR affects your business, then you’ve got a lot of catching up to do. GDPR supports the data protection rights of every EU resident, therefore every business with EU interests—in the form of customers, legal entities, business infrastructure, etc.—needs to comply. And, the global nature of the internet means any business with EU website traffic or app users needs to comply as well.

Clearly, enterprises should make some changes to digital operations in order to reduce exposure to GDPR violations. At a minimum, you need to do the following for all your digital properties—websites (desktop and mobile) and mobile apps included:

1. Communicate privacy policy

  • Write a clear privacy policy that explains use of third-party code and outlines any data collection activity
  • Place banner on homepage
  • Deliver Internal training

2. Provide easy-to-use opt in/ opt out mechanism

  • Explain need for tracking and how cookies are used to drive digital operations
  • Share links to individual privacy policies of all in-scope vendors on your site
  • Allow individuals to explicitly agree and/or refuse tracking

3. Understand how website/app-generated data is acquired, used & stored

  • Identify data: Registration, Cookies, IP addresses, device IDs
  • Assess the legal basis to collect data and determine if consent is necessary, e.g., Personally Identifiable Information (PII) vs. transaction functionality, etc.
  • Evaluate need for a specific policy regarding data collection of minor activity (16 years old in GDPR; under 13 years old in U.K. and U.S.)

4. Support data portability

5. Incorporate website intrusion in data breach reporting

While the GDPR mandate for websites has been clearly laid out, meeting it is easier said than done! With the fines for noncompliance enumerated in the regulation (between 4% of global revenues or €20 Million), InfoSec is under pressure from internal risk and compliance professionals to ensure all data elements are documented, assessed and controlled.   

Ignorance is real. So is anarchy.

With such a tall order, it is disturbing that so many InfoSec professionals overlook the perils of third-party vendor code going unchecked. Companies desperately need to incorporate digital vendors into their vendor risk management program. Most website/app operators are in the dark about how many direct and indirect vendors contribute to code on their site and who these vendors are, let alone know how many domains and cookies these vendors use to track website visitors.

Digital vendor risk management will highlight the security and compliance gaps inherent in the digital environment. For example, there really isn’t a clear chain of command when it comes to authorizing the presence of third-party vendors executing on a website. It is a fairly decentralized process, with departments like marketing, sales, IT, risk and legal all making decisions regarding the vendors they would like to use for various website functionalities. This makes creating accountability challenging, with most issues relegated to the IT and security departments to solve.

Putting the “Digital” in Vendor Risk Management

Yes, the odds are stacked against website operators, but creating a holistic digital vendor risk management program isn’t impossible. To create a risk management and GDPR compliance program for your digital properties, you should be able to answer the following:

Within 2 weeks:

  1. How many third-party vendors execute in websites and mobile apps
  2. What are the names of these vendors?
  3. What exactly are they doing, i.e., intended purpose and also additional, out-of-scope activity?

Within 1 month:

4. Do we have contracts to authorize the scope of the work?
5. How does third-party vendor activity affect overall website/app performance?
6. What are the risks to data privacy?
7. What is my exposure to regulatory risk via vendor behavior?

Within 3 months:

8. Am I maintaining encryption throughout the call chain?
9. As these vendors change over time, what is the process to identify new vendors and their activity on websites and apps?
10. If the corporate website isn’t fully secure, what happens when employees visit the site? Is the enterprise network at risk?

Once you’ve been able to answer the above questions, within a year’s time, you should be able to create comprehensive digital vendor governance process that looks like this:

GDPR Complian Blog Post Image

Ecommerce: Payment card stealing malware

Authored by Chris Olson, CEO and Co-Founder, The Media Trust.

Malware compromise demonstrates how payment security standards are in dire need of an update for the digital environment.credit cards falling as dominoes

A bad actor has upped the stakes in his campaign to collect consumer payment card information by expanding his reach to mid-tier ecommerce providers across the US, UK and India, covering a range of industries including apparel, home goods, beauty and sporting event registrations.

Echoing a similar scenario observed over Memorial Day weekend in 2016, the bad actor injected a transparent overlay on top of the credit/debit card information block on a payment page so that a victim’s financial information is surreptitiously collected and sent to another party, not the e-retailer.

Considering these ecommerce firms earn anywhere from a $10,000 to $400,000 a day, the ecommerce firms risk significant revenue loss and negative consumer confidence. In addition, they also demonstrate inadequate security processes, even though these processes may comply with Payment Card Industry (PCI) standards.

[Please note, The Media Trust has a policy of not revealing the names of websites experiencing an active compromise. Affected ecommerce site operators were, however, notified of this breach.]

The big picture

The infection gradually spread to a number of small and mid-tier ecommerce sites in the US, UK and India, over the last few days. Upon analysis, The Media Trust discovered that each ecommerce provider uses the same open source content management system (CMS) to serve as the consumer-facing front end. The CMS platform’s master page script is infected with one of the several malicious domains. The malicious domain is present in the website’s footer section which means that it permeates every page of the site and not just the checkout page.

In addition, researchers detected multiple domain pairs, which were registered by the same bad actor within the past few months and labeled as suspicious by The Media Trust within two weeks of creation. The domains are now overtly malicious. To avoid detection, the malicious domains execute over varying time intervals and, in at least one instance, move from website to website across the three regions.

Scenario breakdown

In the course of supporting our clients, The Media Trust first detected the malicious actor via client-side scans of advertising-related content, i.e., creative, tags and landing page. The ecommerce site serves as the landing page for an advertising campaign.

The actor used multiple techniques to carry out his attack. In the following scenario, the landing page contains <assetsbrain[dot]com>, extraneous code unnecessary for the proper execution of a payment.

Image 1Malicious domain in the website’s footer

When the victim chooses to make a purchase via the checkout page, <assetsbrain[dot]com> performs two distinct actions: executes JavaScript to inject a transparent overlay on top of the payment card information block and drops a user-identifying cookie.

Ecommerce Post Image 2.pngExecution of transparent overlay

After input of card details, the malicious domain sends the information to <bralntree.com/checkPayments[dot]php>, an obvious spoof of a common payments platform.

Because the ecommerce operator doesn’t receive the card details, the shopper receives an error message and/or request to re-submit their payment information. The unauthorized cookie identifies the user and therefore does not execute the malicious script when the user re-enters the payment card information.

Online transactions remain a risky endeavor

In the realm of compromises, this infection highlights the inadequacy of current PCI security standards. Issued by the Payment Card Industry Council in 2005, the PCI Data Security Standard (PCI DSS) aims to protect cardholder data used during online financial transactions. Backed by the world’s largest credit card issues, PCI DSS requires online merchants to conform to a set of standards such as regular website and server vulnerability checks.

The affected ecommerce sites do not have certifications or seals demonstrating PCI compliance. Their privacy policies declare regular scanning and website security policy review; however, these processes are insufficient, since traditional web application security (appsec) solutions are not able to effectively detect malicious behavior executing via third-party code.

Proving the fallibility of traditional web application scanning utilities, all domains (ecommerce providers, initial malicious domain and spoofed payments platform) are considered clean by VirusTotal as of early morning May 16.

Protect your business by securing your revenue stream

Any size ecommerce provider can protect their revenue and reputation by adopting the following website risk management strategies:

  • Secure your CMS platform: Review security processes with the CMS platform and keep all code and plugins up to date.
  • Surpass PCI DSS standards. Demand more rigorous scanning of the entire website to identify compromise of both owned and third-party code not visible to the website operator.
  • Audit operations. Document all vendors and their actions when executing on your website. This helps you quickly identify anomalous behavior and establishes a remediation path.