Category: Privacy


Writing Policies, Standards, and Procedures for Your Next IT Assessment

Writing policies can be hard, writing good policies can be even harder. Though writing policies, standards, and procedures are often last on people’s minds, they are however a necessity. When building a cybersecurity program, not only are technical controls important but policies, standards, and procedures (PSP) are required documents for any information technology assessment. Whether it is for ISO 27000, NIST, SOX, or any other type of certification or framework, auditors will want review your documentation.

Auditors want to ensure that your PSP’s back up your IT program. They will evaluate how the technology is configured and implemented. The auditor will review your PSP’s to ensure that IT governance has been established for the organization. The following describes what policies, standards, and procedures are and how to craft a document.


Policies are overarching documents which provide an overview of the control objective. They are high level documents which establish IT governance and intent of applying administrative and technical controls. Policies are high level, allowing anyone to view the document without giving away specific technologies or how they are implemented.

“Policy” is often confused for any written document, which include standards and procedures. Policies do not go into detail of how a particular technology is configured or the process of how to do it. The document is used to show intent that these are put in place.


Standards are medium to low-level documents which depict how a device is configured or acceptable technologies to use. A standard must detail the levels of adequate encryption or what SPF, DKIM, or DMARC settings must be configured for email. Standards are used to backup what was previously stated in the policy.

A standards document what is going to be done without going into detail of how to do it. That is the responsibility of a procedure document. A standard would go into details of acceptable encryption. A procedure would then detail how to configure it for a piece of software. Standards state that guest accounts should be disabled, the procedure would depict how to disable it.


Would your co-workers know how to perform your job if you were to win the lottery? Procedures must be written so that anyone can follow and understand. It should be simple enough that a new hire, or a junior admin could perform a function without much trouble. Procedures focus on how a job function is performed without getting into details of what is acceptable. They can be in the form of swim lanes or procedural, however the document must state who is responsible for what job function.

Policies, Standards, and Procedures Documentation Layout Framework

All too often I encounter an organization that has combined their PSP’s into a 30 – 100 page document. This makes searching what you are looking for extremely difficult, especially when you need to locate a document for a control. This is where breaking up documents is helpful. When you follow the methodology that procedures are written to back up standards, and standards are written to back up policies then you are on the right track. The Open Policy Framework provides a way to accomplish this.

When looking at the framework layout, the policy is on the left hand side with its subsequent standards and procedures falling beneath it. An example would be, document 100.00 is the Information Security Policy with each standard and procedure below. Acceptable Use is 100.01, Encryption 100.03, and so on. Procedures would follow the same numbering scheme with 100.03.01 being a procedure of how to configure an Apache server for instance. This numbering scheme allows one to easily locate the information needed.

Writing policies, standards, and procedures may be the non-sexy side of information technology or security but it is a necessity. When scoring a maturity level for an organization, not only will an organization need to have appropriate technical safeguards in place but also documentation to back it up.

Continuous Battle Over Encryption And Your Privacy

Privacy vs. Services

The NCTA, CTIA, and US Telecom recently sent an open letter to congress with concerns over Google’s implementation of the DNS over HTTPS (DoH) protocol. The DoH protocol allows for encryption of DNS look ups providing additional privacy on the internet. In the letter the companies state that internet service providers provide functionality including, “(a) the provision of parental controls and IoT management for end users; (b) connecting end users to the nearest content delivery networks, thus ensuring the delivery of content in the fastest, cheapest, and most reliable manner; (c) assisting rights holders’ and law enforcement’s efforts in enforcing judicial orders in combatting online privacy, as well as law enforcement’s efforts in enforcing judicial orders in combatting the exploitation of minors.” (pg. 3).

Monopolizing on DNS

Another concern that was stated in the letter is that Google will be able to monopolize on the queries made to their DNS servers. As businesses or households use a particular DNS hosting provider, that provider has the ability to collect the IP address and DNS search results. This would allow that provider to mine the data it has collected and sell it to marketing firms. The companies also state that since all Google made devices would utilize Google’s DNS service, it would cause a single point of failure (That is why Google has two DNS servers; and

Another Attack Against Encryption

U.S. Attorney General William Barr has once again made a plea with tech giant Facebook to create a backdoor into its end-to-end encrypted messaging platforms (i.e. Facebook Messanger, WhatsApp). Barr is not alone, the United Kingdom and Australia have also come out against using such end-to-end encryption. They state that without a backdoor, law enforcement cannot perform their duties in capturing and prosecuting criminals in court. Yet, law makers do not understand that encryption algorithms are completely free and open source. Anyone can do a simple search online and discover the math behind popular, and albeit strongest, encryption we have today. If such backdoors were put in place, privacy advocates will certainly use other tools, like Signal, to protect their secrecy online.

Protecting Privacy online

There are many things that one can do to protect their privacy online. The Electronic Frontier Foundation has published a number of articles on how can maintain privacy. Their Surveillance Self-Defense is a well documented series of articles that you can use to protect your privacy and security while online. From enabling multifactor authentication, creating strong passwords, using password managers, to “Choosing the VPN That’s Right for You.”


Privacy and security professionals have been pushing for encryption of internet traffic for many years now. Not only has there been a significant push from the privacy community, search engine giants like Google almost force websites to use encryption to increase search engine optimization (SEO) to drive higher results. Though the costs of purchasing Transport Layer Encryption (TLS) can be quite expensive, open source projects such as Let’s Encrypt allow anyone to create a publicly acceptable TLS certificate for free. These certificates are accepted by major browsers, without throwing warnings, and protects the privacy of the user accessing the site. This only resolves half of the problem.
In a recent article released by the Electronic Frontier Foundation (EFF), DNS is one of the biggest internet privacy issues facing home and corporate users. In its current implementation, DNS relays queries in clear text. This allows Internet Service Providers (ISP’s), or anyone inline of your internet traffic, to look at DNS queries and begin to build a profile on you.

Why is this a problem?

Prior to accessing a website, regardless whether or not it uses encryption, your computer performs a DNS lookup to find the IP address of the website you are trying to access. For instance, a simple DNS request to look up where resides goes out over plain text for anyone to see. Then once the computer knows the IP address it is supposed to be access, the web browser makes a request to the website over a TLS connection.

A person sniffing the traffic may not at that point know the contents of the website you are looking at, the individual however does know that you accessed As you might imagine, this is a significant privacy issue where an ISP or the like can then build a profile on you and sell it to third party marketers which can then target ads.

Solving it on the individual level

There are plenty of tools out there that individuals can use to protect their internet traffic. From applications which can be loaded on a computer or smart device to the use of VPN’s and Tor, these can all protect a specific person. What if you wanted to protect a household or an organization? Use of individual applications would be cumbersome to have everyone use individual applications.

BIND with DNS-over-HTTPS

One such was to do this is to set up a Bind DNS server. This will allow everyone in the organization to perform DNS queries and have those queries safeguarded from data mining. However this still allows someone to sniff DNS queries as they are sent in clear text. To overcome this problem we need to install ‘cloudflared’ on the server. The cloudflared service will then perform DNS-over-HTTPS queries, encrypting your internet traffic from the Bind server to Cloudflare’s DNS resolvers. This prevents anyone from sniffing your DNS traffic, allowing for additional anonymity on the internet.

Getting your system ready

First you will need to install and configure Bind on your server. Once that is complete, download and install the [cloudflared][cloudflared] application on the server. After installation you will need to make one minor change to the forwarders section in your `named.conf.options` file. First, remove the comments in front of forwarders, these will be in the form of double forward slashes – //

Next, add the port number to the loopback IP address. The configuration will then look like:

`forwarders { port 54; };`

After that, load up Wireshark and take a look at the traffic. You should no longer see the DNS protocol being used as everything will be running over TLS.

Am I fully protected now?

No. Though you are one step closer, you still need to ensure that you are performing your due diligence when accessing websites on the internet. Be careful when accessing websites that do not use encryption, especially when typing in your username and password. Use multifactor authentication in addition to a password manager and always double check the website you are accessing.

The California Consumer Privacy Act And The .US Domain

As I start this off I would be remiss to state that yes, I have a .us domain, however so do many Americans. You see, the .us top level domain (TLD) is only available to those who reside within the United States. There are other requirements too such as keeping your WHOIS records up to date. Ensuring that WHOIS records show that those who register a .us domain reside within the US. The major downfall to that is the fact that you cannot purchase privacy protections for your domain. So all of you who have purchased .com, .net, .org and so on have those privacy protections available. But not for .us domains. In fact, .at, .be, .ca, .cn, .cx, .de, .eu, .pl, .pro, and .tw TLD’s do not have those protections either – but that is different story for a different day. What makes the .us TLD so important?

The California Consumer Privacy Act of 2018, soon to go into affect on January 1, 2020 provides protections of personal information. You see, in order to maintain a .us domain one must accurately state their personal, or business, information in the WHOIS directory. Under the CCPA, personal information is defined as real name, signature, address, telephone number, insurance policy number, education, employment, employment history, bank account information, credit card number, debit card number, alias, postal address, unique personal identifier, online identifier such as an IP address, email address, account name, social security number, drivers license number, password number, or other similarities. Whew!

If you have never seen a WHOIS lookup on a domain before, it tends to look like:

Registry Domain ID: D20196051-US
Registrar WHOIS Server:
Registrar URL:
Updated Date: 2018-05-31T13:04:07Z
Creation Date: 2009-05-31T22:47:12Z
Registrar Registration Expiration Date: 2019-05-30T23:59:59Z
Registrar:, LLCRegistrar IANA ID: 146
Registrar Abuse Contact Email:
Registrar Abuse Contact Phone: +1.4806242505
Domain Status: clientTransferProhibited
Domain Status: clientUpdateProhibited
Domain Status: clientRenewProhibited
Domain Status: clientDeleteProhibited
Registry Registrant ID: CR17632448
Registrant Name: Jason Brown
Registrant Organization:
Registrant Street:
Registrant City:
Registrant State/Province:
Registrant Postal Code:
Registrant Country:
Registrant Phone:
Registrant Phone Ext:
Registrant Fax:
Registrant Fax Ext:
Registrant Email:
Registry Admin ID: CR17632450
Admin Name: Jason Brown
Admin Organization:
Admin Street:
Admin City:
Admin State/Province:
Admin Postal Code:
Admin Country:
Admin Phone:
Admin Phone Ext:
Admin Fax:
Admin Fax Ext:
Admin Email:
Registry Tech ID: CR17632449
Tech Name:
Tech Organization:
Tech Street:
Tech City:
Tech State/Province:
Tech Postal Code:
Tech Country: US
Tech Phone:
Tech Phone Ext:
Tech Fax:
Tech Fax Ext:
Tech Email:
DNSSEC: signedDelegation
URL of the ICANN WHOIS Data Problem Reporting System:

I obviously deleted a bunch of stuff but a simple Google search would show you the real results.

Do not get me wrong, California’s Consumer Privacy Act has provided guidelines that the rest of the country should follow. However, law makers continuously make decisions and place deadlines on mandates without fully understanding the impact. How long will it take for law makers to understand the nuances of how the internet works? I myself think its bullshit that one cannot purchase privacy protection for a particular TLD, but I see its reasons.

The amount of data mining, and the cost of providing that information to marketers is astronomical. CSO Online ran an article in 2018 which stated that records on an individual would cost around $141. Take someone 2 minutes to enumerate the entire .us TLD, compile that information and provide it to a marketing company; the amount of data retrieved is priceless.

As you can see, the CCPA has brought to light privacy implications that no one has thought of before. The collection of personal information, the sale of personal information to other companies, and even the disclosure of sale of information. However no one is looking at the information that we have to give up freely in order to do business. It is my hope that we shed a little California sunshine on this situation.

Facebook Exposes Millions of Passwords in Clear Text

Facebook has been under the spot light for quite some time now for its poor security and privacy practices. With this latest privacy blunder, its obvious that the company has not learned from its past. Last week it was uncovered that the company is storing passwords in clear text. This not only affects Facebook users, but InstaGram users too. It was not revealed as to why these passwords were stored in clear text, however what is known is that it affects millions of the company’s users.

In a Facebook blog post by Pedro Canahuati, VP Engineering, Security and Privacy mentioned that the company uncovered the error in January during a routine security review. Canahuati also stated that these clear text passwords were only viewed by those who worked for the company.

At least LinkedIn has your back… Oh nevermind.

Let’s not forget the many security breaches which affected passwords in the past. LinkedIn in 2012 had millions of passwords stolen from the company by hackers. In the breach, the passwords had been hashed, but with a low grade hashing algorithm. At least in LinkedIn’s case we can say the passwords were somewhat protected. In Facebook’s instance, they did not even bother to encrypt the passwords. If the passwords were ever stolen we would see another Yahoo! breach in the making.

Protecting Yourself Online

Canahuati did not mention in his post how to remedy the issue other than to say that the passwords are hashed and salted when an account is created. I would still suggest that everyone change their passwords anyway along with activating multifactor authentication for their account. This way even if someone were to have the password, they would not have the secret token generated by a smart app or hardware token like YubiKey. This also includes those who have InstaGram accounts as well since they were also affected.

One cannot trust the privacy and security that a service provider offers. We must take it upon ourselves to better protect our online identities from mishaps of the services we use. By using password managers to ensure we do not reuse the same password between services to ensuring multifactor authentication is used on every service that offers it is the only way to protect ourselves.

2019 State of Password and Security Behaviors

This year Yubico teamed up with the Ponemon Institute to deliver the 2019 State of Password and Authentication Security Behaviors report. The report was sampled from around 15,000 participants from around the globe which touched on topics which included privacy and security. The report depicts the grim reality of which we still live in today with regards to passwords and their use. For instance, 69% of respondents share passwords with their co-workers. That number equates to 10,350 of the 15,000 people who responded to the survey. Other statistics show:

  • 51% reuse passwords across business and personal accounts
  • 67% do not use multifactor authentication (or 2 factor authentication)
  • 57% have experienced a phishing attack and never changed their password

Though the report depicts what security professionals have stated for years of what not to do, respondents were asked what their 3 top concerns for data security and privacy:

  • Social Security Numbers or Citizen ID’s
  • Payment Account Details
  • Health Information

Their top reasons for the concerns were:

  • Government Surveillance
  • Connected Devices
  • Growing Use of Mobile Devices

The report also when on to state that the annual loss due to employee misuse of password and poor authentication averages around $5.2M. Again, we need to start doing a better job at evangelizing security best practices to our family, friends, and co-workers on what to do to better protect themselves. You can read the full report at the following link Yubico Authentication Report.

CloudFlare’s DNS Over HTTPS Service

How does DNS work?

Protecting your privacy online is a hot topic for many. Though many websites have transitioned from HTTP to HTTPS, allowing web traffic to be secured, this does not protect your overall privacy. The internet still relies on older protocols to ensure you are accessing the right website or other online resources.

DNS, or the Domain Name Service, is one of those protocols we rely heavily on everyday. Every internet connected device has at least one IP address. DNS allows you to type in and it resolves the IP address associated to it. One of the biggest issues with DNS is that it is one of those legacy protocols we rely on everyday. It has no built in security and runs completely in clear text. This allows your Internet Service Provider, or anyone capable of capturing internet traffic, to see what websites you access. This means that even if you are accessing a HTTPS website, others can still see your internet history.

Why is this bad?

As we continue on in the digital age, our internet history is being used against us. Website cookies, internet searches, and DNS queries are being sold to marketing companies. Everything you do is being bought and sold to a number of companies and marketing firms. These companies then take this information and use targeted ads in order to get you as the consumer to purchase online goods and services. There have been steps made to discourage and even eliminate this type of intrusion into our privacy however they have not been totally adopted due to complexity.

Protecting your online privacy

Using HTTPS over HTTP is a great first step in protecting the security and privacy of your internet traffic. The next step is to look at protecting the privacy and security of your DNS queries too. Many online DNS services provide this level anonymity and security. CloudFlare’s DNS over HTTPS is one such service that provides this level of protection. Their privacy policy states that under no circumstances will they ever sell your internet searches to outside third party companies. Quad9 by IBM states the same information in their privacy policy too. However just setting your DNS settings to either of these services is not enough. Your router or computer will still send clear text DNS queries without additional configuration.

CloudFlare offers a number of different ways to protect your online searches. If you are looking to just configure the service on your local machine, instructions and downloads can be found at their Downloads page. Quad9 offers the same level of integration.

If you are looking to provide DNS over HTTPS for your entire household or business your in luck as well. There are simple ways to get this configured so that everyone can take advantage. Different types of routers, including pfSense, can be configured to run DNS over HTTPS. To do so, you can utilize Untangle and configure it to run DNS over port 853. The configuration will be placed into the custom option area and will look like this:

name: "."
forward-ssl-upstream: yes
forward-addr: 2606:4700:4700::1111@853
forward-addr: 2606:4700:4700::1001@853

Once that is in place, and you have saved your configuration, you will now have an additional sense of privacy and security while online.

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