Suggestions
Jamil Farshchi
Equifax CISO & CTO | UKG Board Member | FBI Advisor
Jamil Farshchi is the EVP and Chief Information Security Officer of Equifax, known for his expertise in cybersecurity.
With a background ranging from mega breaches to nuclear weapons, Farshchi has built a career at the forefront of cybersecurity.
Farshchi serves as a Strategic Engagement Advisor for the FBI and was recognized as a LinkedIn Top Voice in Technology & Innovation.
His educational qualifications include a Doctorate in Business Administration from Harvard Business School, a Master of Science in Education with an Emphasis on Decision Science from The Wharton School, and a Bachelor of Business Administration in Management Information Systems from the University of Oklahoma.
Farshchi has held prominent positions in various organizations, including EVP, Chief Information Security Officer & Chief Technology Officer at Equifax, and roles on the board of directors at companies like UKG and National Technology Security Coalition.
He has also served in key security positions at reputable organizations such as The Home Depot, Time Warner Inc., Visa, Los Alamos National Laboratory, and NASA.
Highlights
🎄🕎We just got an early holiday gift! The SEC’s breach disclosure delay process is now released… and it’s surprisingly SIMPLE. 🏖️
Here’s what we know:
🚨 The SEC’s cyber rules take effect on December 18. At that point, public companies must disclose cyber incidents within 4 days of determining materiality.
But sometimes, telling the world about a breach-in-progress may harm public safety or national security. So a rule was created to allow the Dept. of Justice (DOJ) to delay incident disclosures.
The delay process was just released, and it’s surprisingly straightforward:
1️⃣ Answer 8 basic questions about your cyber incident 2️⃣ Provide it to the FBI (or CISA, USSS or your sector risk management agency) 3️⃣ The FBI and DOJ will provide a grant/deny response
Based on discussions with the FBI, SEC and DOJ, here are a few things CISOs, CEOs, GCs and board members should consider:
⭐️ Pro Tip #1: Establish a relationship with the FBI before you have an incident. Don’t waste your precious 4 day reporting window on things you could have done in wayyy in advance.
⭐️ Pro Tip #2: Don’t assume you won’t qualify for a delay. Officials have cited all-too-common things like zero day attacks and incidents where patches aren’t available as fair game for delay requests.
⭐️ Pro Tip #3: Contacting the FBI or DOJ about an incident does not in and of itself trigger materiality. Don’t delay reaching out for fear that it’ll start the 4 day disclosure clock.
“This government process is quick and easy” has been said by literally no one ever. So kudos to the FBI and DOJ for making this one legitimately user friendly. 👏
I hope none of us ever have to use this process. But with all of us prepping for the SEC cyber rules go live while also dealing with peak cyber attack season, this simple process is a gift we really needed right now. 🙌🏼
Rush Atkinson | Bryan Vorndran #cybersecurity #technology
💀 The job of a CISO is among the most difficult and risky in corporate America... and it keeps getting harder.
You’re defending the castle from attacks every single day.
Vulnerabilities you can see. Assets you can’t. Attacks pounding you outside. The peanut gallery second-guessing you inside. And that’s just another Tuesday...
This is the unvarnished reality of cybersecurity.
So, for anyone who thinks the objective of the CISO is wholesale risk elimination: that’s a fantasy land. There’s no “winning” as a CISO and no finish line in modern cybersecurity. There’s no such thing as zero risk. That’s just not how cybersecurity works.
No, the real (and realistic) objective of every CISO is vigorous risk mitigation...and transparency. The CISO community fights this battle on two fronts...
The first is very well known: Cyber criminals and nation-states wage war on public and private infrastructure every day. Those who invest and prepare and collaborate know how to mitigate that damage.
The second doesn’t get much of the spotlight: Detractors. They’ll try to disprove your data. They’ll claim operational disruption. They’ll say everything’s fine or that the sky is falling. They’ll question the risk and the ROI.
At the same time, many expect the CISO to predict the likelihood of a breach that hasn’t even been launched yet. And when things go wrong, we question why any risk existed at all, why the CISO didn’t scream louder about those risks, and why they didn’t respond quicker to the threat. And then comes the Monday-morning-quarterbacking...
It’s a brutal job description.
For CISOs trying to navigate this (ever-changing) state of play, here’s a few recommendations:
- Define clear processes for risk classification and acceptance
- Make sure business owners are accountable for their risks
- Establish a formal incident escalation process (and automate it if possible)
- Include detailed cyber risk data in your exec reporting (pro tip: the appendix is your friend)
- Engage with (or join) your company’s disclosure committee
Oh, and today’s Tuesday. Happy Halloween... 🎃
