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2023 Information Sharing Best Practices

Data sharing practices

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0% found this document useful (0 votes)
31 views

2023 Information Sharing Best Practices

Data sharing practices

Uploaded by

thunder strike
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 17

TLP:WHITE August 2023

Information Sharing
Best Practices
Dark blue
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.

Purple

health-isac.org
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

Benefits & Value of Information Sharing . . . . . . . . . . . . . . . . . . . 3

What Information to Share . . . . . . . . . . . . . . . . . . . . . . . . . 4


Strategic Intelligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Tactical Intelligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Operational Intelligence . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Open-Source Intelligence (OSINT) . . . . . . . . . . . . . . . . . . . . . . 6
Sharing of Industry Best Practices . . . . . . . . . . . . . . . . . . . . . . 6
Incident Response Information Sharing . . . . . . . . . . . . . . . . . . . . 7
Threat Defender Content and Resources Sharing . . . . . . . . . . . . . . . 7
Media Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

How to Share . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Traffic Light Protocol . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Legal Protections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Who to Share With . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

How to Prepare for Information Sharing . . . . . . . . . . . . . . . . . . 12

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

The Final Word – TRUST . . . . . . . . . . . . . . . . . . . . . . . . . 16


Additional Reading . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

We encourage HPH information-sharing organizations to use this document as the


basis of their own Information Sharing Best Practices Guidelines. Organizations can
customize the content provided here for their own information-sharing environment.

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Light B

Purpose of this document


This document was developed in partnership between Health-ISAC and the Healthcare and Public Health
Sector Coordinating Council (HSCC). Health-ISAC is a trusted community of critical infrastructure owners
and operators within the global Healthcare and Public Health sector (HPH). The community is focused on
sharing timely, actionable, relevant information on threats, incidents, vulnerabilities, best practices, mitigation
strategies, and more. The HSCC is a coalition of private-sector critical healthcare infrastructure entities
organized under US Presidential Policy Directive 21 and the National Infrastructure Protection Plan to partner
with the government in identifying and mitigating strategic threats and vulnerabilities facing the sector’s
ability to deliver services and assets to the public. The HSCC Joint Cybersecurity Working Group (JCWG) is
a standing working group of the HSCC, composed of almost 400 industry and government organizations
working together to develop strategies to address emerging and ongoing cybersecurity challenges to the
health sector.

The guidelines provide information about the following: Dark b


• What organizations need to do to prepare for information sharing
• What information to share
• How to share the data
• How to protect any sensitive information they receive
• B
 est practices to obtain necessary internal approvals, including legal approval for information sharing
processes and identifying types of information that can be shared
This document operationalizes a 2019 publication by the HSCC — the Health Industry Cybersecurity Matrix
for Information Sharing Organizations (HIC-MISO) — which provides an inventory of information sharing
organizations and their key services for stakeholders wanting to know where and how to get started. When a
health organization is new to information sharing, it can be confusing to navigate these sharing organizations
and their services, and how to engage with them in a way that reduces risk for the organization.

Please visit https://healthsectorcouncil.org/ for more information about the HSCC and JCWG.

Purp

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Benefits & Value of Information Sharing


Cybersecurity information-sharing programs provide significant benefits to participating organizations.
There are many instances of increased security and risk mitigation because of these sharing initiatives.

1. Improved Security Posture through Shared Situational Awareness


It is unlikely that an organization targeted by an attack is experiencing a new attack vector. More likely still,
the attack vector has been attempted on others in the past, and will be used against others in the future.
Organizations that participate in an information-sharing program will often learn about novel attacks and
mitigations before they are targeted—knowing what attacks other firms are facing allows the organization
to prepare

2. Crowdsourced Cybersecurity Expertise


Many organizations targeted by cybersecurity attacks do not have the resources available to monitor every
threat, evaluate possible impacts, and develop mitigations. Cybersecurity budgets and the knowledge of
in-house staff are often limited. Participation in an information-sharing program allows organizations to
tap into the pooled expertise of partner organizations and informs staff of new threats before they hit their
own environments. Community collaboration enables organizations to leverage expertise within the sector-
specific security community to improve their defenses. These sharing communities also allow for analysts
to learn from each other. Organizations benefit from current security strategies, and individuals benefit
from gained knowledge and experiences, resulting in improved security posture on both an enterprise and
individual level.

3. Heightened Community Trust and Resilience


A chain is only as strong as its weakest link, and in today’s connected healthcare environment, one of the
best ways to increase the chain’s strength is through information sharing. Cybersecurity threats evolve
rapidly, and the ability to stay on top of continuous developments and with ever-increasing technological
environments can be proactively addressed through the timely sharing of actionable intelligence.
Implementing an adequate security posture requires an IT infrastructure with sufficient operational and
security resources with members that have an excellent grasp of security policies and regulatory compliance.
A trusted collaborative ecosystem taps into sizeable economies to provide improvements in information
security for organizations and improved patient safety against cyber-threats without bearing additional costs.

4. Improved Cyber Security Innovation


Sector-wide awareness also significantly increases the avenues an organization has to receive advanced
threat warnings. Cross-organization collaboration improves patient safety and supports the ability to
establish reliable networks that help manage potential threats. As innovations in cyber-attacks continue to
challenge the healthcare industry, security professionals will need to ensure their organizations are engaged
and evolving along with unique sector challenges, standards, and best practices to keep patient care
information safe.

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Ligh

What Information to Share


Threat intelligence is one of the most important data types to information-sharing programs. While some
may believe that threat intelligence only includes information about malware, hacking techniques, and threat
actors — threat intelligence data truly comes in a variety of forms and should encompass all risk vectors
that could impact the healthcare industry, such as third-party risks, insider threats, cybersecurity risks,
regulatory risks, and geopolitical risks. These are good examples of the types of threats that the healthcare
industry faces daily, and therefore are prime areas to focus on when it comes to understanding the types of
insights the information-sharing organization shares throughout the community. More recently, the scope of
information sharing programs has also broadened to include sharing of threat detection and defense content
such as SIEM rules, YARA rules, Response Playbooks, MITRE ATT&CK data, and analytics files to foster close
collaboration between threat defense and detection teams.

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.

Within the healthcare information-sharing community, strategic intelligence is created by intelligence


analysts and the information-sharing community at large. Boards of directors can use strategic reports to
define business priorities which are continually refined through the consumption of strategic intelligence
production; a service offered by any of the information-sharing organizations in your enterprise that may
participate. The broader stakeholder community, including cybersecurity researchers, law enforcement,
government policymakers, and industry regulators, also influence strategic intelligence creation to produce
the most effective and current threat-informed resilience strategies.
Pu
Members of the information-sharing community use strategic intelligence to proactively engage risk by
using intelligence to identify emerging threats, thus minimizing potential adverse impacts on consumer
organizations. Finally, strategic intelligence can help navigate the complex risk landscape and shed
some light into unknown unknowns which may give client organizations an advantage in long-term
business planning.

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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.

Open-Source Intelligence (OSINT)


Open-Source Intelligence (OSINT) is data collected from public sources, such as the internet, news sites,
social media, and the dark web to be used in an intelligence context. OSINT is an essential part of the overall
intelligence process as often these sources are the first to report about new threats and vulnerabilities.
OSINT drives timeliness in intelligence production.

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.

Sharing of Industry Best Practices


Industry best practices are often shared among members of an information-sharing community. These
practices continually evolve due to members requesting feedback from other organizations regarding
implementing policies, procedures, and governance. The requests may address how organizations address
a specific issue or risk and then share the information with the rest of the group. Direct feedback from
peers helps members gain insight into how the industry approaches a problem or challenge and can
inform the member’s decision-making process and strategy, and lead to the refinement of such processes.
Understanding the challenges and successes that peers have experienced is invaluable information. Some
examples in this area are:

1. Addressing Third-Party Risk


2. Intelligence Gathering Techniques
3. Presenting Cyber Risk to the Board
4. Securing the Internet of Things (IoT)
5. Securing Big Data
6. Changes in Laws and Regulations and the Impacts to your Policies
Best practices typically reference standards and frameworks designed to be used across industries. Often,
there are areas of ambiguity in these standards that organizations can help clarify by sharing key insights
with the community members. In addition to gaining clarity, understanding how other members use these
standards provides a great deal of insight into methods of effective implementation.

Sharing step-by-step procedures or templates enable members of an information-sharing organization to


become productive faster, protect their network better and become more resilient than trying to do it alone.
Sharing guidance on technical challenges is also commonplace within an information-sharing organization.
Typical topics within these forums include how to quarantine/eradicate specific malware, tool guidance
(including command-line tools), or extensive guidance on hunting for threats within your environment. These
types of knowledge sharing often occur in real-time across the membership of an information-sharing
organization.

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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.

Incident Response Information Sharing


The health industry is heavily regulated and is subject to specific breach reporting requirements. In cyber
crises, information flows must be clear, consistent, and accurate. Information-sharing organizations are
positioned to provide that clarity during these times.

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.

Threat Defender Content and Resources Sharing


Until now, information sharing programs have had their scope largely limited to the sharing of threat
indicators of compromise (IOCs) and attacker tactics, techniques, and procedures (TTPs). While sharing
IOCs and TTPs is critical to proactively mitigate attacks, modern cyber security programs are expanding
the scope of information sharing by including threat defender and defense content and resources. Such
resources include sharing SIEM rules, YARA rules, MITRE ATT&CK data, and Automated Response Playbooks,
and more.

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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Light Blue

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
Purple
• O
 rchestrate threat data flow from detection technologies and reporting tools to threat intelligence
platforms (TIP) for review and approval
• L
 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

Traffic Light Protocol


The Traffic Light Protocol (TLP) is used by information-sharing organizations, such as Health-ISAC,
to set strict information handling guidelines and procedures for the recipients. All information
submitted, processed, stored, archived, or disposed of, is classified, and handled in accordance
with the following:
• U
 nless otherwise specified, all information is treated as confidential information (TLP:AMBER)
and is not disclosed to parties outside of the information-sharing organization without the
permission of the originator
• Information classified as TLP:GREEN, TLP:AMBER, or TLP:RED must be disclosed, transported,
stored, transmitted, and disposed of, safely and securely using controls appropriate to the
classification level. These controls include but are not limited to, encryption, shredding, securely
erasing and degaussing of media
The table below describes the Health-ISAC classifications of information and intended audiences.
Organizations can create their own TLP definitions, and therefore, there are many nuances that
exist. We urge the reader to be familiar with the TLP definitions of their respective information
sharing community.

Traffic Light Protocol

Classification When Should It Be Used? How May It Be Shared?

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.

Source: Health-ISAC Traffic Light Protocol (TLP) Definition


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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.

The Freedom of Information Act (FOIA)


The Freedom of Information Act (FOIA) is a US law that allows the public to request access to records from
any US federal agency. FOIA does not apply to private sector organizations, including Health-ISAC, meaning
a FOIA cannot be issued to Health-ISAC requesting the release of sensitive member information.

Information Sharing and GDPR


The European Union General Data Protection Regulation, or“GDPR,” went into effect in2018 and provides
individuals in the European Union (EU) and the European Economic Area (EEA) rights and control over their
personal information.

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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Light Blue

Who to Share With


As cybersecurity threats continue to increase and IT environments grow even more complex, the need
for an organization to implement measures for effective and efficient information sharing increases. One
emerging challenge is addressing and managing risk from upstream organizations and third-party providers.
Recognizing shared responsibility across the HPH sector allows for combined efforts to identify and mitigate
supply chain risks that could impact many organizations.

The importance of community-wide protection increases as additional IT services are outsourced to


third-party providers. Organizations can significantly benefit from forward-looking practices, such as
operational threat information combined with shared situational awareness, made available through
information-sharing programs.

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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How to Prepare for Information Sharing


The following recommendations will guide you through the initial preparation to perform before you join an
Information Sharing program.

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).

Data Type Description Data Owner Share With Authorized Release

SA
Malicious IP Addresses discovered Jane Doe, SOC ISAC SOC
Malicious IP running exploits against external Cyber Threat

MP
Addresses devices Intelligence

LE
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

Observables around Distributed Denial John Jones, NOC ISAC NOC


DDoS Activity of Service (DDoS) activity Law Enforcement External Liaison

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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Information Sharing Best Practices

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.

5. Establish Sanitization Rules. Organizations should establish a process to ensure no proprietary or


sensitive information is disclosed when sharing information with external entities. Refer to the HIPAA
Minimum Necessary rule when deciding which sensitive information, such as PHI or PII, should be disclosed.
To completely redact PHI or PII, it is recommended to use the “safe harbor method” listed in the HIPAA
De-Identification document. Offering a limited data set may be the preferred method if certain information
is necessary for shared information to be meaningful.

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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Information Sharing Best Practices

Light Blue

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.

Example 1: Untargeted Attack From Triage to Threat Indicator


Organization A receives
thousands of malicious
untargeted e-mail messages Dark blue
per day. 70% of them are
rejected thanks to email
filters. 20% are inspected
for malicious content in
quarantine and rejected.
10% evade all automated
filters and are delivered
to an end user’s desktop.
These trigger a response
from Security Operations
and a new collection
of “fresh” indicators to
be shared. Below is an
example of the indicators
shared with the Health-
ISAC membership by
Organization A.

Example 2: Targeted Campaign

The second example provides insight into the other end of the information-sharing spectrum. An in-depth
Purple
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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Information Sharing Best Practices

Organization B develops and shares a full report to the Health-ISAC, exposing the details of the campaign
and relevant indicators:

• Summary: provides context to the event as applicable


• Analysis: Outlines harvested indicators from the campaign, noting details of the timing and similarity of
malicious content relative to the organization the attack attempted to impersonate, including details of the
infrastructure used to launch the attack.
• H
 igh-Level Tactics, Techniques and Procedures: Highlights vital elements of attacker tradecraft and
approach to this specific campaign.
• M
 itigations, Recommendations, Indicators of Compromise: Detailed steps taken to block and detect
inbound attacks or outbound communications if a recipient is impacted.

Example 3: Cyber Threat Indicators and Defensive Measures


In a June 2016 posting on Sharing Guidance, DHS provided examples of cyber threat indicators and
defensive measures. The items below are good examples of indicators and analysis that your organization
could provide to the information-sharing community:
• Malware
• Information Regarding the Intrusion Vector and Method of Establishing Persistent Presence
• Information Regarding When Unauthorized Access Occurred
• Information Regarding How the Actor Moved Laterally Within a Network and How Network Protections
Were Bypassed
• Information Regarding the Type of Servers, Directories, and Files That Were Accessed
• Information Regarding What Was Exfiltrated and the Method of Exfiltration
• Information Regarding the Damage or Loss Caused by the Incident, Including Remediation Costs

Example 4: Pro-Russian Hacktivists Launch Distributed Denial of Service Attack Against


Healthcare Organizations1
The following is a synopsis of a mass healthcare-targeting event being remediated by knowledge obtained
through information sharing.

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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Information Sharing Best Practices

The Final Word — TRUST


The success of information sharing in any community relies on the trust established between individuals.
Trust is a requirement when an individual wants to share sensitive information with others.

We encourage you to get involved in your applicable industry-specific information-sharing community to


help build and maintain networks of trust. Host and attend in-person meetings whether at a conference,
regional workshop, or informal gathering of security professionals in your city. The personal relationships
that are built with other professionals will help establish a network of trust in the wider information-sharing
community and help maximize the benefits received from membership.

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.

Feedback and suggestions on this document are encouraged and welcome.


Please e-mail [email protected]

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