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What the GAO Report missed about the Equifax data breach

The Government Accountability Office did its part to deliver some closure regarding the Equifax data breach by way of a newly published report on the now-infamous security incident.

The GAO report offers a comprehensive look at the numerous missteps made by Equifax, which allowed attackers to maintain a presence in the company’s network for 76 days and extract massive amounts of personal data without being detected. Those errors included having an outdated recipient list of system administrators for vulnerability alerts and an expired digital certificate, which led to a misconfiguration in Equifax’s network inspection system.

But for all its merits, the GAO’s report on the Equifax data breach omits or minimizes important parts of the story. Here are five things that were left out of the report.

  1. Website “issues”: The GAO noted the breach checker website that Equifax set up for consumers suffered from “several technical issues, including excessive downtime and inaccurate data.” But that’s hardly an adequate description of what ailed the website. For starters, the domain resembled a classic phishing URL — It was also built on a stock version of WordPress (was the company trying to get hacked again?). And it was vulnerable to cross-site scripting attacks. And the site’s TLS certificate didn’t perform revocation checks. These are significantly bigger problems than website downtime.
  2. PIN problems: If the assortment of flaws with the breach checker website wasn’t enough, astute observers also discovered that the PINs generated for consumers who froze their credit files weren’t random, non-consecutive numbers – they were the date and time a consumer made the freeze request. As a result, the chances of threat actors guessing your code are significantly higher than they would be if the PIN digits were randomly selected.
  3. Encryption: This is the biggest omission in the Equifax breach report. While the report does mention encryption several times, it’s never in regard to the personally identifiable information that was exposed by the breach, and how encryption could have protected that data even after the attackers gained access to Equifax’s environment. Instead, the majority of the encryption talk is around how the threat actors abused existing encrypted communication channels to avoid detection when they issued commands and exfiltrated data. Encryption is obviously a sensitive topic within the federal government, but it’s as if the GAO is more concerned with how encryption helped the attackers rather than with how it could have stopped them.
  4. Insider trading: The GAO report doesn’t include any references to the former Equifax executive who was charged with insider trading by the Department of Justice. Jun Ying, the former CIO of Equifax’s U.S. Information Systems business unit, allegedly used non-public information about the breach to exercise his vested options and sell all of shares. While the case has no direct bearing on Equifax’s infosec posture, past or present, it’s a painful reminder that insider trading can be a by-product of enterprise breaches. Omitting any mention of Ying and the insider trading case from an accountability report seems like a missed opportunity for the federal government to address what could potentially be a reoccurring problem as breaches increase in frequency.
  5. Lack of incident response plan: Incident response is sparsely mentioned in the report, and when the GAO does mention it, it’s in the footnotes. For all the faults and errors laid out in the Equifax breach report, the GAO fails to identify a fundamental problem: the company apparently didn’t have a functional incident response plan in place. This is led to Equifax not only making several errors with its breach checker website but also later missteps, such as not knowing whether the company had encrypted consumer data post-breach. A solid, proper incident response plan would have saved Equifax a lot of trouble in the aftermath of the attack.
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