2023 Information Sharing Best Practices
2023 Information Sharing Best Practices
Information Sharing
Best Practices
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TLP:WHITE This report may be shared without restriction. For Health-ISAC members—be sure
to download the full version of the report from the Health-ISAC Threat Intelligence Portal (HTIP).
Contact Membership Services for assistance.
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Information Sharing Best Practices
Abstract
Information-sharing programs produce significant benefits at minimal risk for the
organizations that participate. This document provides Healthcare and Public Health Sector
(HPH) organizations with a set of guidelines and best practices for efficient and effective
information sharing strategies. It addresses barriers to information sharing often found in
laws, regulations, corporate policies, or management support and will help organizations
overcome these obstacles.
Contents
Purpose of this document . . . . . . . . . . . . . . . . . . . . . . . . . 2
How to Share . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Traffic Light Protocol . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Legal Protections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Case Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Example 1: Untargeted Attack From Triage to Threat Indicator . . . . . . . . . 14
Example 3: Cyber Threat Indicators and Defensive Measures . . . . . . . . . . 15
Example 4: Pro-Russian Hacktivists Launch Distributed Denial of Service Attack
Against Healthcare Organizations1 . . . . . . . . . . . . . . . . . . . . . 15
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Please visit https://healthsectorcouncil.org/ for more information about the HSCC and JCWG.
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Indeed, information sharing is successful only if the correct information is shared among its members
and through information-sharing organizations built to protect critical infrastructure such as the Health Dark
Information Sharing and Analysis Center (Health-ISAC) and other specialized and government organizations
identified in the HIC-MISO. This section highlights the types of information actively shared within the
Health-ISAC community.
The following groupings of threat intelligence are routinely shared throughout the HPH industry and are
disseminated through multiple channels offered by information-sharing organizations.
Strategic Intelligence
Strategic intelligence is the collection, processing, analysis, and dissemination of intelligence required to
inform policy, help set and/or justify information security budgets, and refine business plans at the corporate
and divisional levels. It typically focuses on new and emerging trends, changes in the cyber threat landscape,
changes in laws and regulations, and the ever-evolving geopolitical and supply chain landscape.
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Here are a few examples of strategic intelligence shared within the information-sharing community:
• A
nalysis of the geopolitical landscape and its effects on the cyber landscape and the healthcare
supply chain
• Guidance on privacy regulations such as General Data Protection Regulation
• Russia’s Data Localization legislation
• Cyber Security Law of the People’s Republic of China and impacts on the protection of intellectual property
• R
isks of technologies used in specialized environments such as IoT/OT environments including medical
devices and manufacturing facilities
• Risks of emerging technologies such as Artificial Intelligence; Machine Learning
• G
uidance on new government cybersecurity strategies such as the National Cybersecurity Strategy of
March 2023
• Insight on how to build business resilience in the face of the Russia/Ukraine war
• Analysis of adversarial nation state activity and the trends therein
• Illuminated risks of early adoption of new technology such as ChatGPT and other sophisticated artificial
intelligence models
• P
redictive analysis of emerging trends in cybercrime at all levels to create long term threat-informed
defense strategies
All these examples could impact how an organization might change their risk posture, meet regulatory
compliance, avoid policy violations, and preemptively mitigate developing security threats. Discussions
about strategic intelligence issues help educate, prioritize, and cultivate proactive decision making within
the HPH sector. For more information on strategic intelligence, please see the report, How Strategic Threat
Intelligence Informs Better Security Decisions.
Tactical Intelligence
Tactical intelligence includes the details of threat actor tactics, techniques, and procedures (TTPs). Tactical
intelligence provides information focused on the techniques that threat actors leverage to gain access to
computerized systems and the mechanisms employed to carry out an attack, similar to what is highlighted in
the MITRE ATT&CK Matrix.
Some examples of this type of intelligence are exploitation methods that threat actors use to carry out
credential harvesting attacks (e.g., Credential Dumping, Brute Force), lateral movement (e.g., internal spear
phishing, tainting shared content , and remote service exploitation), and command and control mechanisms
(e.g., Domain Fronting, Fallback Channels, Domain Generation Algorithms).
Operational Intelligence
Operational intelligence is actionable information about specific weaponized attacks.
Operational intelligence is typically gathered by monitoring the internet, the dark web, and social media
platforms to give intelligence consumers early notification of potential attacks on their industry or
organizations.
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Security researchers typically publish their research on new vulnerabilities and threats. These vulnerability
and threat reports are shared amongst the community and provide members with situational awareness and
mitigation strategies.
All these intelligence types serve important, specific purposes and complement each other to provide
the health industry with both short and long-term insights and strategies to reduce risk.. Beyond threat
intelligence, organizations can offer many different types of data, such as detection and defense
recommendations, that should be shared throughout the information-sharing community.
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This is especially useful in times of an emerging cyber threat that escalates to an elevated status. Whether
discussing best practices or providing general guidance, this information is shared in various forums such as
regularly scheduled webinars, workshops, summits, and focused discussions.
It is important to note that members of an information-sharing organization benefit by turning these activities
into actionable communications that a non-technical audience can leverage through standardized templates
and sample communications. These assist members in communicating effectively to their leadership
and stakeholders. These types of communications serve multiple purposes, such as ensuring a clear and
consistent message across the health industry.
Whether a crisis affects the entire industry or a single entity, information-sharing organizations share
pertinent information across the industry while keeping the victim’s identity protected. In an industry that
is negatively impacted by misinformation, information-sharing organizations provide clarifying details of
an event, correct public misinformation, and provide clarity in a time of ambiguity. The rapid sharing of
situational awareness is made possible because information-sharing organizations offer a medium for
directly from the impacted organizations to share their experiences.
Organizations can benefit from sharing such defense and detection resources as they foster close
collaboration between the threat defenders across the larger community of information security
professionals and enables doubling down of efforts against attackers by sharing proven operational
knowledge around effectively mitigating attacks. An organization defending itself from an attack can benefit
from the knowledge shared by other organizations such as what SIEM rule should be written to proactively
detect a specific attack or what YARA rule should be deployed on an endpoint detection and response
system (EDR) or an intrusion prevention/detection system (IDS/IPS) to identify and detect a certain malware.
Media Response
Information-sharing organizations can share responses to media inquiries as a representation of the health
industry, rather than as an individual member. For example, the media may inquire about the impact of new
privacy regulations on the HPH industry. Rather than hearing from one individual company, information-
sharing organizations can poll their members and pull together a collective response that is a better
representation of the entire industry. Health-ISAC can facilitate anonymous feedback, provide a more holistic
representation of the health industry, and drive a clear and consistent message. A community response can
include sharing talking points with its members to aid in media inquiries, especially during an incident. These
talking points can provide guidance as to what is appropriate to share with the media.
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How to Share
Sharing guidelines are intended to control the publication and distribution of threat information. They also
exist to help prevent the dissemination of information that, if improperly disclosed, may have adverse
consequences for an organization, its customers, or business partners. Information-sharing rules should
consider the recipient’s trustworthiness, the sensitivity of the shared information, and the potential impact
of sharing or withholding specific types of information. Types of information sharing include:
Firm-Derived Information:
• D
o not share sensitive information about specific impacts or details that could be
used to identify the firm
• S
afeguard Personally Identifiable Information (PII), Protected Health Information
(PHI), or proprietary information
• If guidance is not clear, request permission to share data that is not your own Dark blue
Sharing Third Party and Vendor derived information:
• Share in accordance with third-party and vendor disclosure agreements
• Do not violate confidentiality agreements
Share quality information
• Include confidence levels in any analyst judgments made in your reporting
• S
hare source information as permitted (do not source specific vendors by name; instead, say “security/
intelligence vendor;” do directly source Open-Source Information)
• Share analysis and include the “so what” to explain why this information is essential to you and your peers
Sanitize and Redact Security Reports:
• Do share analysis
• Do not share the impact or consequences to the firm
• Do share open-source information
• Do not share vendor names
• Do not share author information
• Do share approved IOCs
For more sophisticated organizations or those that have the resources to invest in automation, the following
tips can be used to Automate Intelligence Approval, Processing, Sharing, and Actioning Processes
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• O
rchestrate threat data flow from detection technologies and reporting tools to threat intelligence
platforms (TIP) for review and approval
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everage TIP orchestration to automatically review and approve the information to be shared. Predefine
rules to classify which and what type of information can be shared externally
• Process information shared by other partners using automated TIPs to gather more context and relevance
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• C
orrelate received information, through TIPs, with internal threat intelligence and telemetry to enrich, add
context, and score intelligence
• A
utomatically share back processed threat intelligence with more context and confidence with information
sharing partners
• Automate actioning of threat data in response technologies using TIPs
• A
void manual processes for processing and sharing threat intelligence to scale threat intelligence
operations, derive more value from information sharing programs and reduce analyst burden
Sources may use TLP:RED when information Restricted to a defined group (e.g., only those present in a
cannot be effectively acted upon by additional meeting or recipient of a defined group.)
TLP:RED parties and could lead to impacts on a party’s Information labeled TLP RED should not be shared with anyone
privacy, reputation, or operations if misused. outside of the group
Sources may use TLP:AMBER when This information may be shared with Health-ISAC members
information requires support to be effectively and Health-ISAC member employees with a need to know.
TLP:AMBER acted upon, yet carries risks to privacy, Generally, alerts with the Health-ISAC TLP AMBER classification
reputation, or operations if shared outside of will be kept behind the Health-ISAC secure portal.
the organizations involved.
Sources may use TLP:GREEN when Information within the TLP GREEN category may be shared
information is useful for the awareness of all with Health-ISAC members and trusted partners (e.g., CERTS,
TLP:GREEN participating organizations as well as with law enforcement, government agencies and other ISACs).
peers within the broader community or sector. Information in this category is not to be shared in public
forums or over public channels.
Sources may use TLP:WHITE when TLP WHITE information may be shared freely subject to
information carries minimal or no foreseeable standard copyright rules.
TLP:WHITE
risk of misuse, in accordance with applicable
rules and procedures for public release.
Legal Protections
Cybersecurity Information Sharing Act of 2015 (CISA2015)
The Cybersecurity Information Sharing Act of 2015 (CISA2015) – was signed into law on December 18, 2015,
and provides private sector entities with liability protection when sharing information with peer firms and
public sector government organizations.
Section 104(c) of CISA2015 states that private sector organizations may, notwithstanding any other law,
share cyber threat indicators or defensive measures with peer firms, ISACs and ISAOs. CISA2015 protects
any private entity from liability arising from sharing a cyber threat indicator or defensive measure.
More details, examples and guidance is available in this document, Guidance to Assist Non-Federal Entities
to Share Cyber Threat Indicators and Defensive Measures with Federal Entities under the Cybersecurity
Information Sharing Act of 2015, published by The Department of Homeland Security and The Depart of
Justice in October 2020, and available here.
GDPR Article 6(1)(f) states that processing personal data is lawful when it “is necessary for the purpose
of the legitimate interests pursued by the controller or by a third party.” The processing of personal data
under this Article must meet a three-step test: legitimacy, necessity, and a balancing of interests. A 2018
paper, Threat Information Sharing and GDPR: A Lawful Activity that Protects Personal Data, outlines how
the processing of personal data in threat information by an ISAC and its Members meets this criteria.
Specifically,
• T
he ISAC’s and its Members’ interests – sharing information to prevent fraud and improve network security
against cyberattacks – are legitimate uses of personal data under GDPR.
• T
he processing of personal data for these interests is necessary and proportionate as a critical component
of ensuring network and system security and the prevention of fraud.
• P
roviding that appropriate privacy safeguards are adopted by the ISAC and its Members, the interests
are balanced because controls are implemented to ensure that the goal of preventing or stopping fraud
and ensuring the security of members‘ networks are not outweighed by the interests of the data subjects
whose personal data is processed. The interests of data subjects are aligned with those of the ISAC
and Members.
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Consider the following list of potential information-sharing partners, and identify which partners fit best
within your organization’s information-sharing strategy. You should establish an information-sharing Dark blue
agreement with these organizations. In the case of the Health-ISAC, for example, a Membership Services
Agreement outlines data sharing and classification requirements for the parties involved.
External Partners
• P
ublic Entities - Law enforcement, regulatory bodies, public associations, and government organizations
such as the HHS Health Sector Cybersecurity Coordination Center (HC3)
• P
rivate Entities - Industry associations, third-party service providers, information-sharing organizations
such as Health-ISAC
Internal Groups
• Cyber Threat Intelligence Teams
• Fusion Centers
• Information Security Staff
• Physical Security Staff
• Business Continuity and Disaster Recovery Professionals
• Incident Response Teams
• Education, Training & Awareness Teams
• Legal Teams
• Senior Leadership Purple
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1. Establish Your Information Sharing Goals & Objectives. It is crucial to start by establishing the overall
purpose of your information-sharing program, especially in the business context of your environment. The
strategy should outline its scope, identify which information-sharing organizations you will partner with, and
detail the roles and responsibilities of your internal teams.
2. Establish Governance Models To Ensure Compliance. Identify data owners across the organization that
could be candidates for information sharing participants, such as your internal Security Operations Center
(SOC), malware research team, digital forensics unit, incident response team, threat management team, or
cyber threat intelligence team.
Categorize your Information-Sharing Assets Develop a table that lists each data type, its description, the
corresponding internal data owner, which external organizations the data can be shared with (ISACs, ISAOs,
Law Enforcement, etc.), and who is authorized to release the data (see example below).
SA
Malicious IP Addresses discovered Jane Doe, SOC ISAC SOC
Malicious IP running exploits against external Cyber Threat
MP
Addresses devices Intelligence
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Malicious e-mails containing suspicious Jane Doe, SOC ISAC SOC
Phishing
URLs, attachments along with e-mail
E-mails External Liaison
source IP, sender, and subject line
3. Create a Governance Body. Assemble a steering committee, working group, or informal body to review
these processes and procedures to establish a consensus around the governance of sharing information
externally from the organization. The same governance body can also review and catalogue findings
from other external entities to enhance knowledge and bring awareness to internal security teams.
The governance body should meet regularly (at least once a quarter) and review both internal and
external findings.
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4. Embrace Third Party Review. Consider voluntarily gaining accreditation or look for others who have
embraced the performance of an audit. This may be proven in many different types of forums, including but
not limited to financial reports, Privacy, Security and Cybersecurity Audits, Accreditation and Certification.
When organizations handling data voluntarily go through audits/certification processes, they show trading
partners they have been vetted and can be trusted. When accepting another’s accreditation/certification
credentials, first be sure to confirm that the scope of the audit includes the data regarding the information
your organization will be sharing.
6. Bring the Legal Department into the Information Sharing Process. Internal legal counsel may not fully
appreciate the value or scope of information sharing and often see only the risks. Organizations experience
roadblocks to information-sharing activity because legal counsel within their organization has no experience
with the information-sharing process thus not recognizing the value information-sharing programs can
provide and see the overall program as adding more risk to the firm. Educating legal experts is an essential
step towards information-sharing.
7. Engage the Legal Department Early in the Process of Establishing an Information-Sharing Program.
Consider running a healthcare-themed tabletop exercise with legal staff in attendance so they can better
understand the problems that HPH IT and Information Security professionals face. Internal counsel may be
more willing to engage in finding solutions if they are included in the development of the program.
8. Consider Dedicating Resources to Legal Outreach. Engaging and educating legal staff can be a long-
term process. Engaging the legal department can provide concrete benefits to the speed and flexibility with
which the HPH sector can act during widespread security incidents such as WannaCry. A primary concern
during these types of events is the timeliness and accuracy of the information being shared. Reducing legal
roadblocks allows more HPH organizations to feel comfortable discussing and actively sharing and providing
more detailed data for the technical community to analyze and implement ways to better protect their own firm.
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Case Studies
The following case studies offer examples of information sharing in different circumstances. Every
situation is different, and these examples can be adapted to suit your organization’s unique information-
sharing requirements.
The first example only includes four pieces of data, but the data is highly valuable because an adversary’s
infrastructure may only be active for a few hours or days. Therefore, information shared during an active
attack can be useful only if the infrastructure is still operational.
The second example provides insight into the other end of the information-sharing spectrum. An in-depth
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analysis of a specific, targeted campaign adds value by illustrating attacker detailed activity and is especially
useful for analysis and strategic decision-making.
Organization B becomes aware of a potentially targeted spear phishing campaign through a trusted third
party. They observe and record activity based on this information. After a few days, no new indicators are
received and the campaign ends.
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Organization B develops and shares a full report to the Health-ISAC, exposing the details of the campaign
and relevant indicators:
On January 27, 2023, Organization A observed Killnet associate, KillMilk, releasing a Distributed Denial of
Service (DDoS) targeting list on Telegram. Telegram is an encrypted messaging platform. The targeting list
announced on January 27 was unique because it exclusively targeted healthcare. The day after, January
28, a twitter user posted the targeting list, making it public. The list was shared with a healthcare sector
information sharing organization that discovered the list contained numerous organizations from the
Health-ISAC community. DDoS attacks began taking place on the day the adversary specified, [January 30],
but were successfully mitigated through rapid sharing of IOCs pertaining to Killnet infrastructure, targeted
alerts sent from the information sharing community to organizations present on the list and sharing best
practices with the sector at large.
Organizations that were members of the information sharing organization not only possessed the advantage
of increased visibility into the cyber threat landscape, but also were able to incorporate a set of crowdsourced
industry-specific best practices.
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Additional Reading
The National Institute of Standards and Technologies (NIST) published a thorough document providing
additional guidance and factors to consider beyond what was covered in this document. For additional
reading, we recommend the NIST Guide to Cyber Threat Information Sharing, NIST Special Publication 800-
150, October 2016.
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