Building Resilient Web Applications on AWS: A Comprehensive Approach to Security


I have been asked by friends and customers what is the best way to implement a web based application with minimum costs and good security. Of course, the best way is to define exactly what you want to achieve and let professionals do it, while keeping an eye on the Secure Software Development Lifecycle.

But, this article is not about SSDLC, it is about how to start web application development having also security as a top priority. Securing a classical web application involves a multi-layered approach, addressing the presentation, business logic, and database layers.

Most important thing to keep in mind when engaging into such an enterprise is: don’t try to do everything by yourself – use existing tools and services, which come with a more than decent security built-in.

This article explores how to architect a secure web application on AWS, but it can be applied very well to other cloud based services provider,  and conduct a thorough risk assessment at each level.

A good security approach is to practice defense in depth, meaning that you should check and validate the security of the components used as well. This means that we need to perform at least a high-level risk assessment of these components as well.



Securing the Presentation Layer

At the forefront of user interaction, the presentation layer demands robust security measures. Amazon CloudFront serves as a reliable content delivery network, ensuring low latency and protection against DDoS attacks.

AWS Identity and Access Management (IAM) steps in to control access to resources at this layer, while AWS Web Application Firewall (WAF) safeguards against common web exploits and secures APIs.

The Presentation layer hosts the UI of the application, typically a website written in HTML5 or a combination of HTML, php, JS, or some high level programming languages that can produce HTML as output.

Such web UIs must be uploaded on a AWS S3 bucket read accessible to everyone and then configure the CloudFront to distribute it.

Risk Assessment at the Presentation Layer

  • Regularly review and adjust IAM policies to mitigate the risk of unauthorized access.
  • Conduct penetration testing on the web application to identify and address vulnerabilities.
  • Monitor CloudFront logs for unusual patterns indicative of a security threat.
  • Make sure nobody has unrestricted access to your S3 bucket hosting the web content

Security practices

  • If you collect data, make sure it is encrypted using AWS Secrets Manager;
  • Do not encrypt using your own keys, hardcoded in your application.
  • Do not invent yourself some “encryption” mechanism, which in the end is just an obfuscation.

Securing the Business Logic Layer

The business logic layer is the heart of a web application, where critical processes take place. Containerizing application logic using AWS Elastic Container Service (ECS) or AWS Fargate ensures enhanced isolation.

AWS Lambda, offering serverless computing, executes sensitive business logic securely. AWS Secrets Manager manages and rotates sensitive API keys and tokens.

Risk Assessment at the Business Logic Layer

– Regularly audit and review AWS Lambda functions to maintain the security of business logic.
– Conduct static and dynamic code analysis to identify vulnerabilities in the application logic.
– Implement AWS CloudWatch for real-time monitoring and alerting on anomalous Lambda function behavior.

Securing the Database Level

The database, housing crucial data, requires robust security measures. Amazon RDS provides secure and scalable relational databases with automatic backups and encryption.

Fine-grained access control through IAM roles and policies is essential for secure database access. AWS Key Management Service (KMS) handles encryption of data at rest within the database.


Risk Assessment at the Database Level

– Regularly audit and review database access controls and IAM roles to prevent unauthorized access.
– Implement automated vulnerability scanning tools for the database to identify potential weaknesses.
– Set up AWS CloudTrail to log and monitor all database-related API activity.


Continuous Monitoring and Response

Ensuring the ongoing security of a web application involves continuous monitoring and a robust incident response plan. AWS Security Hub acts as a centralized monitoring tool, while AWS Config rules automate the assessment and remediation of non-compliance.

An incident response plan with specific procedures for each layer of the web application architecture ensures a swift and effective response to security incidents.


In the next post: risk assessment for the Amazon services used in this article:

  • AWS Elastic Container Service (ECS)
  • AWS Fargate
  • AWS Key Management Service (KMS)
  • AWS Lambda
  • AWS CloudTrail
  • AWS Secrets Manager
  • AWS CloudFront
  • AWS S3


By adopting a comprehensive security strategy across the presentation layer, business logic, and database levels, small organizations can build resilient and cost aware web applications on the AWS platform.

This approach, coupled with regular risk assessments, establishes a solid foundation for web application security, safeguarding against common cybersecurity threats.

The post Building Resilient Web Applications on AWS: A Comprehensive Approach to Security first appeared on Sorin Mustaca on Cybersecurity.

Evolving beyond your core expertise: it’s time to add security

This post is for creators of digital services like optimization tools,  VPN solutions, Backup and Disaster Recovery tools, Parental control tools, Identity protection tools, Privacy tools, Email clients, Browsers and many others.

Your products are doing a good job in the dynamic landscape of digital services, and it is amazing of how much commitment and work is invested in providing top-notch tools. However, in this era of escalating cyber threats, there’s a pivotal evolution taking place —a shift that you have seen it coming already : it is time to integrate robust security measures into your existing offerings.

Are you curious why? Read on …


Threat landscape evolved way beyond your core expertise

The digital world is witnessing an unprecedented surge in cyber threats. Malware, ransomware, data breaches—the risks are multifaceted and affect your users’ security and privacy. Your customers, while benefiting from your solutions, now seek a more comprehensive shield against these threats, ideally coming from the same producer or from a single product.


Customer expectations are higher

Your customers are discerning individuals who are continuously looking at the market. They expect a comprehensive approach to their digital safety. Strengthening your service portfolio with robust cybersecurity measures aligns with their evolving needs and fortifies their trust in your brand.


Competitive Edge Through Diversification

By diversifying into the security space, you’re not merely meeting customer demands; you’re cementing your competitive position in the market. Companies that offer a holistic suite of security solutions distinguish themselves as leaders in a crowded market.


Value of Integrated Solutions

Integrated security solutions that seamlessly blend with your services create an all-encompassing safety net for users. Presenting a unified platform that prioritizes both speed and security establishes a compelling value proposition, attracting customers seeking efficiency without compromising on safety.


In conclusion, embracing the integration of cybersecurity measures into your existing services isn’t just an option; it’s a strategic decision that must be taken.

This evolution ensures not only meeting customer expectations but also securing a more competitive edge in an industry that demands continuous innovation and adaptability.


The post Evolving beyond your core expertise: it’s time to add security first appeared on Sorin Mustaca on Cybersecurity.

Balancing functionality and privacy concerns in AI-based Endpoint Security solutions

The integration of Artificial Intelligence (AI) in endpoint security has revolutionized the way organizations protect their devices and data.

Ok, let’s take a break here: have you read the article about Artificial Intelligence vs. Machine Learning ?


By leveraging AI and machine learning models that analyze user behavior on devices, organizations can detect anomalies and potential security threats more effectively.

However, this advanced approach to endpoint security raises significant privacy concerns, as it necessitates the collection of user activity data, sometimes in real time.

One thing needs to be clear: if you want to do anomaly detection, you need to train your ML model with what “normal” is first – this is called “baseline”. And this means that data needs to be collected from the user.

Now the question remains, how can we reduce the privacy concerns?

This short article explores the privacy challenges I think are associated with using AI models that require user data(behavior), discusses potential solutions, and suggests ways to deploy AI on devices while minimizing privacy concerns.

What are the privacy concerns when data is collected for training an ML model?

Data Collection and Usage

Collecting user data for AI-driven endpoint security involves monitoring and logging user activities on devices.

This process includes:

  • capturing information about the applications used (URLs accessed, CPU usage, memory usage),
  • websites visited and items clicked
  • files accessed
  • applications installed
  • applications started
  • time of login, logout, inactivity
  • webcam usage
  • microphone usage
  • biometrics

This data is essential for creating baselines of normal behavior and identifying deviations that might indicate security threats.

This extensive data collection raises concerns about user privacy, as it creates a comprehensive profile of a user’s digital activities.

AI-based endpoint security solutions can infer or predict sensitive information from non-sensitive forms of data, such as user preferences, interests, or behaviors.

This can enable the systems to provide personalized or customized services or recommendations, but it can also violate the privacy or autonomy of the users or the owners of the devices or networks.

For example, someone’s keyboard typing patterns can be analyzed to deduce their emotional state, which includes emotions such as nervousness, confidence, sadness or anxiety


Data Security

Safeguarding the collected user data is critical, as it contains sensitive information about an individual’s online behavior.

The risk of data breaches or unauthorized access to this information poses a significant privacy threat.

Where is this data stored, how long, how is it stored, who has access to it, how is it going to be used/processed and by who, are just a few questions that need to be asked.

GDPR has made clear which are the responsibilities of the controller and processor(s) of the data.


Transparency and Consent

A good user experience of a security product means that users will be as unaware as possible that their activity data is being collected for security purposes.

Ensuring transparency and obtaining explicit user consent for data collection is critical. Without clear communication, users may feel their privacy is being violated.


Data Retention

Storing user data indefinitely can compound privacy concerns. Organizations should establish clear data retention policies, specifying how long the data will be retained and under what circumstances it will be deleted.


User Profiling and Discrimination

The detailed user activity data collected for AI analysis can lead to user profiling, which may be used for purposes beyond cybersecurity, such as targeted advertising.

AI-based endpoint security solutions can make automated decisions or recommendations based on the data they analyze, such as blocking access, flagging anomalies, or prioritizing alerts.

Discriminatory decisions and practices can arise from the insights drawn from user behavior data. However, these decisions or recommendations can be discriminatory, unfair, inaccurate, or biased, if the data or the algorithms are flawed, incomplete, or skewed.

For example, people can be misclassified, misidentified, or judged negatively, and such errors or biases may disproportionately affect certain demographics.


Solutions to address privacy concerns

The solutions to address these concerns are actually not new, they are covered pretty good by the GDPR and other privacy laws world-wide.

They are :

Data Minimization

Organizations should adopt a data minimization approach, collecting only the data necessary for security purposes.  This is definitely not as easy as it sounds.

In Security, you usually collect as much as possible, because the more you know about your target, the better it is for the ML model (better detection, less false positives).

However, the Compliance dept. should be involved from the early stages of developing the product in order to control what is being collected.



Anonymizing user data can be a privacy-enhancing technique. By removing personally identifiable information from collected data, the risk of individual users being identified is reduced.

This works good when data is collected from many computers, but when the solution works on a single computer, it usually needs time to “learn” the user’s behavior.

There is nothing anonymous there and this is usually OK, as long as this data is not sent to the backend for further processing and analysis.



Encrypting the data collected for AI analysis ensures that even if a breach occurs, the information remains unreadable and inaccessible to unauthorized parties.

When “cleaned up” data needs to be sent, it is mandatory to send it encrypted and keep it at rest encrypted all the time.


Informed consent

Transparently informing users about data collection and obtaining their explicit consent is a fundamental step in addressing privacy concerns.

Users should have the option to opt in or out of data collection at any time. It is mandatory for the ML models to be able to cope without any datasets, because they could disappear at any time.


Data deletion

After the data is no longer needed for security analysis, organizations can ideally erase the data, and if this is not possible, then it should remove any direct or indirect associations with individual users.

Balancing Security and Privacy

Balancing AI-based endpoint security and privacy is essential. Organizations can adopt the following strategies to minimize privacy concerns:

  • Implement Strong Privacy Policies

Establish comprehensive privacy policies that clearly define data collection, usage, retention, and disposal procedures. These policies should adhere to legal and regulatory requirements for the region where the users reside (GDPR, CPA, etc.).

This can by itself be a challenging task, because no company is willing to block access to potential customers.


  • Regular risk assessment and impact analysis

Conduct periodic risk assessment and impact analysis to ensure that data collection and analysis practices align with privacy policies and legal requirements and correct any deviations promptly.

The audits should be first performed internally, in order to have time to fix any deviations. If an external audit body finds any irregularity, the company can be fined with large sums of money.


  • Third-Party Vetting

When using third-party AI solutions, organizations should thoroughly vet the security and privacy practices of these providers.


  • Ongoing Monitoring

Continuously monitor the effectiveness of privacy protection measures and adjust them as needed to address emerging privacy concerns.



AI-based endpoint security is a powerful tool for protecting devices and data from cyber threats. However, it should not come at the cost of user privacy or well-being.

Organizations must strike a delicate balance by implementing privacy-enhancing measures, obtaining informed consent, and adhering to transparent data collection and usage practices.



PS: The image of the post was generated using DALL-E.


The post Balancing functionality and privacy concerns in AI-based Endpoint Security solutions first appeared on Sorin Mustaca on Cybersecurity.

Thoughts on AI and Cybersecurity

Being an CSSLP gives me access to various emails from (ISC)2. One of these announced me that there is a recording of a webinar about AI and Cybersecurity held by Steve Piper from CyberEdge.

Very nice presentation of 1h, and I found out that there is a sequel to that on November 1st.

So, following Steve’s article, I did some research, read a lot and used ChatGPT to summarize some of my findings.

This article explores the multifaceted ways AI is transforming cybersecurity, from threat detection to incident response and beyond. It also looks into What it means actually to use AI in some of these fields. What is the impact on privacy and confidentiality?

Important to keep in mind that any AI must first learn (trained) in order to be able to understand the system and then potentially predict what is happening.


  1. Threat Detection

One of the primary applications of AI in cybersecurity is threat detection. Traditional rule-based systems are no longer sufficient to identify and combat sophisticated attacks.

AI-driven technologies, such as machine learning and deep learning, can analyze massive datasets to detect anomalies and potential threats.

Here’s how:

a. Anomaly Detection: AI algorithms can establish a baseline of normal behavior in a network or system. Any deviation from this baseline can trigger an alert, indicating a potential security breach.

b. Behavioral Analysis: AI can analyze user and entity behavior to detect patterns that may indicate malicious activity. This is particularly useful for identifying insider threats.

c. Malware Detection: AI can scan files and code for patterns consistent with known malware or recognize behavioral patterns of malicious software.

We’ll talk more in the future on this topic.


  1. Predictive Analysis

AI-driven predictive analysis enhances cybersecurity by identifying potential threats before they become full-blown attacks.

By crunching vast amounts of historical data, AI systems can predict emerging threats, trends, and vulnerabilities. This early warning system allows organizations to preemptively shore up their defenses.

It would have to gather huge amounts of data, crunch them (preprocess, normalize, structure), creating an ML model and then based on the chosen technology train the system.

Here we can think of supervised (pre-categorized data, requiring feature to be defined) and unsupervised learning (non categorized data, basically being restricted to Anomaly detection).

There is a huge warning here, because :

a) such huge amounts of data has to come from somewhere and

b) predictions can be influenced by specially crafted training data, for unsupervised training models.


  1. Automation and Orchestration

AI can automate routine cybersecurity tasks and workflows, reducing the workload on human analysts and minimizing response times. AI-driven systems can:

a. Automatically quarantine infected devices or isolate compromised areas of a network to prevent lateral movement by attackers.

b. Investigate and analyze security incidents, rapidly categorizing and prioritizing alerts.

c. Initiate predefined incident response procedures, such as patching vulnerable systems or resetting compromised user accounts.



Automation involves the use of technology, such as scripts, workflows, or AI-driven systems, to perform routine and repetitive tasks without human intervention. In the context of cybersecurity, automation can significantly improve efficiency and response times by handling various operational and security-related processes automatically. Here’s how it works:

a. Incident Response: When a security incident is detected, automation can trigger predefined actions to contain, investigate, and mitigate the threat. For example, if a system detects a malware infection, an automated response might involve isolating the affected device from the network, blocking the malicious IP address, and initiating a forensic investigation.

b. Vulnerability Patching: Automation can be used to deploy security patches and updates to systems and software as soon as they are released. This reduces the window of vulnerability and helps prevent attacks that target known vulnerabilities.

c. Log Analysis and Alerts: Automation can continuously monitor logs and events from various systems. It can detect and respond to predefined security events, generating alerts or triggering specific actions when unusual or malicious activity is detected.



Orchestration is a broader concept that focuses on integrating and coordinating various security tools, processes, and workflows into a unified and streamlined system. It enables organizations to create end-to-end security workflows by connecting different security solutions and ensuring they work together cohesively. Here’s how it works:

a. Workflow Integration: Orchestration systems allow the creation of predefined security workflows that link multiple tools, such as firewalls, intrusion detection systems, antivirus software, and incident response platforms. For example, when a malware alert is triggered, orchestration can coordinate the response by isolating the affected system, collecting forensic data, and alerting the incident response team.

b. Information Sharing: Orchestration enables the sharing of critical information among security tools. This ensures that all relevant security solutions have access to the latest threat intelligence, allowing for more effective threat detection and mitigation.


  1. Phishing Detection

Phishing attacks remain a prevalent threat. AI can help identify phishing attempts by:

a. Analyzing email content and sender behavior to identify suspicious emails.

b. Scanning URLs for malicious domains or suspicious patterns.

c. Inspecting attachments for known malware signatures.

d. Recognizing social engineering techniques and language used in phishing emails.


  1. Network Security

AI-driven intrusion detection systems (IDS) and intrusion prevention systems (IPS) monitor network traffic for anomalies and threats.

They can identify and block malicious traffic in real-time, protecting the network from various attacks, including DDoS attacks and data exfiltration.


  1. Threat Intelligence

AI can be used to aggregate and analyze threat intelligence from various sources, including open-source feeds, dark web monitoring, and industry-specific data.

This aggregated intelligence can help security teams stay informed about emerging threats and vulnerabilities.


  1. Endpoint Security

AI-driven endpoint security solutions provide real-time protection for individual devices.

They can identify and mitigate threats at the device level, even when the device is not connected to the corporate network. This is especially crucial for remote workers and mobile devices.

This raises another red flag for me: complete monitoring of user’s actions on the device. What happens to the data gathered, is the model trained locally on in the cloud? And many other such concerns.

I will write a dedicated post about AI and Privacy very soon.

The post Thoughts on AI and Cybersecurity first appeared on Sorin Mustaca on Cybersecurity.

Authentication vs. Authorization

These two fundamental concepts play a pivotal role in ensuring the integrity and security of digital systems.

While these terms are often used interchangeably, they represent distinct and equally essential aspects in the world of identity and access management (IAM), which safeguards sensitive information and resources .

Executive summary

Authentication confirms that users are who they say they are. Authorization gives those users permission to access a resource.

The relationship between authentication and authorization is symbiotic. Authentication precedes authorization, as it’s imperative to confirm an entity’s identity before permitting or denying access.



Authentication: Proving Identity

Authentication is the process of verifying the identity of a user, system, or entity attempting to access a particular resource, system, or network.

It aims to answer the fundamental question: “Who are you?” and “Are you who you say you are?”.

In other words, the purpose of authentication is to ensure that the entity requesting access is indeed who they claim to be.

A successful authentication process provides a digital identity, often represented by a username or user ID, that can be used for subsequent authorization.

For answering these questions, authentication typically relies on one or more factors, categorized as:

  1. Something you know: This factor involves information only the user should know, such as a password, PIN, or passphrase.
  2. Something you have: This includes possession of a physical object like a smart card, token, or mobile device.
  3. Something you are: Also known as biometrics, this factor uses unique physical or behavioral attributes like fingerprints, retinal scans, or voice recognition.


Authorization: Granting Permissions

Authorization takes place after a successful authentication.

Authorization is the process of determining what a user, system, or entity can do after they’ve been authenticated.

It answers the question: “What are you allowed to do?”.

To implement this, authorization is typically implemented through access control policies, which dictate which actions a user is allowed to perform, what data they can access, and the extent of their privileges.

Access control decisions can be based on various factors, including user roles, permissions, and the context in which a request is made.


Have a look for more demystifying terms:

Demystifying cybersecurity terms: Policy, Standard, Procedure, Controls, Framework, Zero Trust



The post Authentication vs. Authorization first appeared on Sorin Mustaca on Cybersecurity.

Demystifying cybersecurity terms: Policy, Standard, Procedure, Controls, Framework, Zero Trust

I am often asked what is the difference between Policy, Standard, Procedure in cybersecurity.

Well, here it is:

1. Cybersecurity Standard

A cybersecurity standard is a set of guidelines, criteria, or best practices that organizations follow to ensure that their security controls and procedures align with industry standards or regulatory requirements. Standards provide a benchmark for measuring security maturity and often serve as a reference for audits and assessments. Common cybersecurity standards include ISO 27001, NIST Cybersecurity Framework, and CIS Controls.

2. Cybersecurity Framework

A cybersecurity framework is a structured approach to managing and improving an organization’s cybersecurity posture. It’s a comprehensive set of best practices, guidelines, and tools designed to help organizations assess, develop, and enhance their cybersecurity programs. Frameworks provide a strategic perspective and often include a collection of policies, procedures, controls, and standards. Prominent frameworks include NIST Cybersecurity Framework, CIS Critical Security Controls, and ISO 27001.

As can be seen, a standard often doesn’t come alone, it comes with a framework, which allows the implementer to start quickly and create a basis for the cybersecurity implementation.

3. Cybersecurity Policy

A cybersecurity policy is a foundational document that sets the overarching principles and guidelines for an organization’s security posture. It is a high-level, strategic document that outlines the organization’s commitment to security, the roles and responsibilities of individuals and departments in safeguarding assets, and the consequences of non-compliance. Cybersecurity policies are essential for aligning security efforts with business goals and regulatory requirements.

4. Cybersecurity Procedure

While policies provide a high-level framework, procedures are the detailed step-by-step instructions that help employees or security personnel implement the policies effectively. Procedures are specific and actionable, often detailing how to respond to security incidents, configure software securely, or conduct security audits. They ensure consistency and best practices are followed in day-to-day operations.

5. Cybersecurity Control

Controls are measures, safeguards, or countermeasures that organizations put in place to protect their information systems and data. Controls can be technical, administrative, or physical in nature. They are designed to mitigate risks by preventing, detecting, or responding to security threats. Examples include firewalls, access controls, encryption, and antivirus software.

In summary, these four terms play distinct but interrelated roles in the world of cybersecurity. Policies set the overarching goals and principles, procedures provide the detailed instructions for implementation, controls are the measures and safeguards in place to protect against threats, and standards offer a reference point to ensure compliance with established best practices.

Effective cybersecurity requires a holistic approach that encompasses all these elements. By establishing clear policies, well-documented procedures, robust controls, and adherence to industry standards, organizations can better defend themselves against the ever-evolving threat landscape and protect their sensitive data and digital assets.

6. Zero Trust

Zero Trust in Cybersecurity: from myth to the guide


7. Authentication and Authorization


The post Demystifying cybersecurity terms: Policy, Standard, Procedure, Controls, Framework, Zero Trust first appeared on Sorin Mustaca on Cybersecurity.

NIS2: 3.Establish a cybersecurity framework

We wrote here that the 3rd  step in implementing the requirements of the directive is to establish a cybersecurity framework.

If you haven’t read what a cybersecurity framework means, then you should read article: .


Establishing a cybersecurity framework is critically important for organizations of all sizes and types because it is the basis on which you build your cybersecurity. The cybersecurity framework is the basis of the ISMS, which represents the plan of your cybersecurity strategy.


Why it is essential to have a cybersecurity framework

In case you still wonder if you need a cybersecurity framework, here are several key reasons why it is essential:

  1. Protection against Cyber Threats
    Cyber threats are constantly evolving and becoming more sophisticated. A cybersecurity framework provides a structured approach to identifying and mitigating these threats, reducing the risk of data breaches, cyberattacks, and other security incidents.
  2. Risk Management
    Cybersecurity frameworks help organizations assess their cybersecurity risks and prioritize their efforts to address the most critical vulnerabilities. This risk-based approach ensures that resources are allocated where they are needed most.
  3. Compliance and Legal Requirements
    Many industries and regions have specific cybersecurity regulations and legal requirements that organizations must adhere to. A cybersecurity framework provides a roadmap for meeting these compliance obligations, reducing the risk of fines and legal repercussions.
  4. Business Continuity
    Cybersecurity incidents can disrupt business operations, leading to downtime, financial losses, and damage to reputation. A well-structured cybersecurity framework helps organizations prepare for and respond to incidents, minimizing their impact and ensuring business continuity.
  5. Protection of Sensitive Data
    Organizations store vast amounts of sensitive and confidential data, including customer information, financial records, and intellectual property. A cybersecurity framework helps safeguard this data from unauthorized access or theft.
  6. Preservation of Reputation
    A security breach can seriously damage an organization’s reputation and erode customer trust. Implementing a cybersecurity framework demonstrates a commitment to security, which can enhance the organization’s reputation and instill confidence among customers, partners, and stakeholders.
  7. Cost Savings
    Proactively addressing cybersecurity through a framework can ultimately save an organization money. Preventing security incidents is more cost-effective than dealing with the aftermath of a breach, which can involve significant financial and legal expenses.
  8. Consistency and Standardization
    Cybersecurity frameworks promote consistency and standardization of security practices across an organization. This is especially important in larger enterprises with multiple locations, business units, or teams, ensuring that security measures are applied uniformly.
  9. Continuous Improvement
    Cyber threats and technology evolve rapidly. A cybersecurity framework emphasizes the importance of ongoing monitoring, assessment, and improvement, helping organizations stay ahead of emerging threats and vulnerabilities.
  10. Competitive Advantage
    Having a robust cybersecurity framework can be a competitive advantage. It can differentiate an organization in the eyes of customers, partners, and investors who prioritize security when choosing business partners.

Steps to Choose or Create a Cybersecurity Framework

Choosing a cybersecurity framework is a tedious process and potentially long. If you want to succeed, then you need to plan for it. In order to create a project plan, follow these milestones:

  1. Assess Organizational Needs and Objectives
    Begin by understanding your organization’s specific cybersecurity needs, objectives, and goals. Consider the industry you operate in, the types of data you handle, and your organization’s size and complexity.
  2. Identify Relevant Regulations and Standards
    Determine which cybersecurity regulations, standards, and compliance requirements are applicable to your organization. These may include GDPR, HIPAA, ISO 27001, NIST, CIS Controls, TISAX, ISO 21434 and industry-specific regulations.
  3. Conduct a Risk Assessment
    Perform a comprehensive risk assessment to identify potential cybersecurity threats, vulnerabilities, and the potential impact of security incidents. This assessment will help you prioritize security measures.
  4. Define Your Scope
    Clearly define the scope of your cybersecurity efforts. Consider which systems, data, and assets are in scope for protection and compliance efforts. Document this scope in detail.
  5. Research Existing Frameworks
    Investigate existing cybersecurity frameworks and standards that align with your organization’s needs and objectives. Consider well-established frameworks like NIST Cybersecurity Framework, ISO 27001, CIS Controls, and others.
    Have a look here to view a comparison. Consider country-specific frameworks like the recommendations or requirements from your country’s information security agency.
  6. Evaluate Framework Alignment
    Evaluate how closely each candidate framework aligns with your organization’s requirements, risk assessment findings, and compliance obligations. Consider factors like ease of implementation and ongoing maintenance.
  7. Customization vs. Adoption
    Decide whether to adopt an existing framework as-is or customize it to fit your organization’s specific needs. Customization may be necessary to address unique risks or industry-specific requirements.
  8. Engage Stakeholders
    Involve key stakeholders, including senior leadership, IT teams, compliance experts, and legal advisors, in the decision-making process. Ensure their input and buy-in throughout the framework selection or development process.
  9. Develop Framework Documentation
    If you choose to customize or create a framework, develop comprehensive documentation that outlines the framework’s policies, procedures, controls, and guidelines. This documentation serves as a roadmap for the implementation of the ISMS.
  10. Implement and Test
    Begin implementing the selected or customized framework within your organization. Test its effectiveness in addressing cybersecurity risks and compliance requirements.
  11. Training and Awareness
    Train employees and raise awareness about the cybersecurity framework, its policies, and best practices. Ensure that everyone in the organization understands their role in maintaining security.
  12. Continuous Monitoring and Improvement
    Establish ongoing monitoring and assessment processes to ensure the framework’s effectiveness. Regularly review and update the framework to adapt to evolving threats and technology.


Key Considerations When Choosing or Creating a Cybersecurity Framework

There are some things to keep in mind when implementing the project plan for choosing the cybersecurity framework. The project can easily go out of scope because of the security landscape continuously changing.

Please review regularly these considerations and make sure you go through the list before taking any big decisions.

  1. Alignment with Objectives: Ensure that the chosen framework aligns with your organization’s cybersecurity objectives, risk profile, and compliance requirements.
  2. Applicability: Consider the framework’s applicability to your industry and specific business needs.
  3. Resource Requirements: Assess the resources (financial, human, and technological) required for framework implementation and maintenance.
  4. Scalability: Determine whether the framework can scale with your organization’s growth and evolving cybersecurity needs.
  5. Integration: Ensure that the framework can integrate with existing security technologies and processes within your organization.
  6. Cost vs. Benefit: Evaluate the cost-effectiveness of implementing and maintaining the framework relative to the expected security benefits and risk reduction.
  7. Accessibility of Expertise: Consider the availability of expertise and training resources related to the chosen framework.
  8. Audit and Certification: If compliance or certification is a goal, verify that the framework is recognized and accepted by relevant certification bodies or authorities.
  9. Legal and Privacy Considerations: Ensure that the framework supports compliance with relevant data protection and privacy laws.
  10. Flexibility: Assess the framework’s flexibility to adapt to changing threat landscapes and emerging technologies.



Having a robust cybersecurity framework can be a competitive advantage. It can differentiate an organization in the eyes of customers, partners, and investors who prioritize security when choosing business partners.

Remember that selecting or creating a cybersecurity framework is not a one-size-fits-all process. It should be a thoughtful and strategic decision that aligns with your organization’s unique needs and circumstances.

Establishing a cybersecurity framework is essential to protect an organization’s digital assets, manage risks effectively, comply with legal requirements, and maintain the trust of stakeholders.


The post NIS2: 3.Establish a cybersecurity framework first appeared on Sorin Mustaca on Cybersecurity.

How to implement an Information Security Management System (ISMS)

We wrote here that the 3rd  step in implementing the requirements of the directive is to establish a cybersecurity framework.

If you haven’t read what a cybersecurity framework means, then you should read article: .

An ISMS is typically based on the ISO 27001 standard, which provides a framework for establishing, implementing, maintaining, and continually improving information security within an organization.

Establishing a cybersecurity framework is usually achieved together with, or while implementing an Information Security Management System (ISMS) based on a standard like ISO 27001. So, before going to the NIS2 Step 3, I must explain why is it important to have a “good” ISMS.

This article will guide you through the steps to create a solid foundation for the ISMS which uses a cybersecurity framework.


Here are the steps you must follow to implement your ISMS:

  1. Get Top Management Support
    • Before you start, synchronize with the top management in order to define company’s goals in this regard. Usually it should be clear, since the company strives to receive a certification like ISO 27001, ISO 16949, TISAX, CSMS, etc..
    • Then secure the commitment and support of senior management by helping them understand the necessary resources and efforts.
    • In all standards that require an ISMS it is imperative to have the commitment of the management because their feedback and support are required in several places along the way.
  2. Scope Definition
    • Define the scope of your ISMS: determine which assets, processes, and locations will be covered by the ISMS.
    • This will help in setting boundaries for your security efforts. Some certifications require an assessment per location and scope, so this needs to be developed properly and in accordance with company’s goals.
  3. Risk Assessment
    • Create policies that help identify and assess information security risks.
    • This involves:
      • How to identifying assets: List all the information assets your organization handles, such as data, hardware, software, and personnel, intellectual property.
      • How to identify threats and vulnerabilities: Determine potential risks and vulnerabilities that could impact your assets.
      • How to assess risks: Analyze the likelihood and potential impact of these risks.
      • How to calculate risk levels: Prioritize risks based on their severity.
  4. Risk Treatment
    • Develop a policy for risk treatment plan:
      • How to implement controls: Select and implement security controls and measures to mitigate identified risks.
      • Document policies and procedures that enforce the creation of security controls.
      • Allocate responsibilities: Assign roles and responsibilities for managing and monitoring security measures.
      • Set risk acceptance criteria: Determine which risks can be accepted, mitigated, or transferred.
  5.  Establish the ISMS Framework
    • Establish the ISMS framework based on ISO 27001:
      • Define information security objectives.
      • Develop an information security policy.
      • Create a risk assessment methodology.
      • Define criteria for risk acceptance.
      • Develop and implement security controls.
  6. Implementation
    • Execute the ISMS based on the established framework:
      • Train employees: Provide information security training to all staff members.
      • Implement security controls: Put in place the technical, administrative, and physical controls identified in your risk treatment plan.
      • Monitor and review: Continuously monitor the effectiveness of your controls and review your risk assessment.
  7. Measurement and Evaluation
    • Regularly measure and evaluate the performance of your ISMS to ensure that it remains effective and aligned with your objectives.
      • Conduct internal audits.
      • Perform security testing (e.g., penetration testing, vulnerability scanning).
      • Analyze security incident data.
  8. Management Review
    • Conduct regular management reviews to assess the ISMS’s performance and effectiveness.
      • Ensure that the ISMS is aligned with the organization’s strategic goals.
      • Make improvements based on review findings.
  9. Continual Improvement
    • Use the results of audits, reviews, and incidents to continually improve the ISMS.
      • Update policies and procedures as needed.
      • Enhance security controls based on new threats and vulnerabilities.
      • Maintain employee awareness and training.
  10. Certification (Optional):
    • If your organization desires ISO 27001 or any other certification, engage an accredited certification body to perform an external audit and certification assessment.
    • Be careful because several certification require a pre-certification or pre-assessment performed either with in-house auditors (internal) or external auditors.
  11. Documentation
    • Maintain detailed documentation of all ISMS activities, including policies, procedures, risk assessments, and audit reports.
    • Maintain a log of all changes in time, because this demonstrates continual improvement and usage.
  12. Training and Awareness
    • Continuously educate and raise awareness among employees regarding information security policies and best practices.
  13. Incident Response and Recovery
    • Develop an incident response plan to address security incidents promptly and effectively.


Remember, and make sure that your management remembers as well, that implementing and maintaining an ISMS is an ongoing process. Even if certifications are renewed only after 3 years (usually) it is important that in these 3 years the ISMS is lived.

Regularly update your risk assessments and adapt your security controls to evolving threats and business needs. Continuous improvement is key to the success of your ISMS.


The post How to implement an Information Security Management System (ISMS) first appeared on Sorin Mustaca on Cybersecurity.

NIS2: 2.Designate a responsible person or team

We wrote here that the second step in implementing NIS2 requirements is to designate a responsible person or team.

Appointing an individual or a team responsible for overseeing the implementation of the NIS2 directive within your company is critical to ensure its success.

NIS2 implementation and compliance is a project, and as any project must have a dedicated team that is actively working on its implementation.

Due to the fact that the the NIS2 requirements are demanding a continuous activity, there must be a continuity of the project after its implementation. This means that there has to be a team appointed to this project that is responsible for continuously monitoring and adapting the activities required for NIS2 compliance. To effectively manage these challenges, companies should establish a new dedicated team or name an existing team to be responsible for cybersecurity and compliance.

In this article, we will explore the reasons behind the need for such a team and identify existing teams within a company that could take on these vital responsibilities.

Cyber threats are constantly evolving, becoming more sophisticated and persistent. From data breaches and ransomware attacks to regulatory changes, companies are exposed to a multitude of risks that can have significant consequences.

Here’s why a dedicated cybersecurity and compliance team is essential:

  1. Proactive Threat Mitigation: A dedicated team can stay ahead of emerging threats by continuously monitoring the threat landscape, analyzing vulnerabilities, and implementing proactive security measures. They can assess potential risks and ensure that the company is well-prepared to defend against cyberattacks.
  2. Regulatory Compliance: Compliance with industry-specific regulations (ISO 27001, TISAX, ISO 21434) and data protection laws (such as GDPR or HIPAA) is a legal requirement. A dedicated team can ensure that the company adheres to these regulations, avoiding costly fines and legal repercussions.
  3. Incident Response: In the unfortunate event of a cybersecurity breach, a well-prepared team can swiftly respond to contain the damage, investigate the incident, and minimize the impact on the business and its customers.


Good news: existing teams can take on cybersecurity and compliance roles!

Identifying the right team to assume the responsibility of cybersecurity and compliance is crucial.

Below are some existing teams within a company that could take on these roles. However, be aware that due to the complex nature of the task, most chances of success has an interdisciplinary team.


  • IT Department: IT professionals are typically responsible for managing the company’s technology infrastructure. They can play a critical role in implementing security measures, monitoring networks, and ensuring that software and hardware are up to date with security patches.

Be aware, the IT teams may not have the specialized expertise needed for compliance and may benefit from additional support. With the right people on board, they can take over this critical task.


  • Legal and Compliance Teams: Legal and compliance departments are already well-versed in navigating complex regulatory frameworks. They can take on the compliance aspect of cybersecurity, ensuring that the company aligns with industry-specific laws and regulations.

L&C teams may require additional cybersecurity expertise to address the technical aspects of protection.


  • Dedicated Cybersecurity Team: For companies with significant digital assets and a higher level of exposure to cyber threats, establishing a dedicated cybersecurity team is advisable.

This team would focus exclusively on safeguarding the company’s digital assets, monitoring threats, conducting penetration testing, and developing comprehensive cybersecurity policies and strategies.


  • Cross-Functional Cybersecurity Team: In some cases, it may be beneficial to establish a cross-functional committee that includes representatives from various departments, including IT, legal, compliance, and risk management.

This team can collaborate to address cybersecurity and compliance challenges effectively.


Important activities that must be performed for NIS2 compliance

As part of the NIS2 requirements, the team responsible make sure that these activities are performed.

However, due to the fact that so many areas are involved, it is quite clear that the entire company must be involved.


  1. Risk Assessment and Management:
    • Identifying and assessing cybersecurity risks and vulnerabilities across the organization.
    • Developing risk mitigation strategies and prioritizing security measures based on the level of risk.
  2. Compliance Monitoring:
    • Ensuring the company complies with relevant industry-specific regulations, data protection laws, and compliance standards (e.g., GDPR, HIPAA, ISO 27001).
    • Conducting regular compliance audits and assessments to identify and address non-compliance issues.
  3. Policy Development and Enforcement:
    • Developing and maintaining comprehensive cybersecurity policies, procedures, and guidelines that align with regulatory requirements and industry best practices.
    • Enforcing these policies throughout the organization and ensuring employees are aware of and adhere to them.
  4. Security Awareness Training:
    • Providing cybersecurity awareness training to employees and stakeholders to enhance their understanding of security risks and best practices.
    • Promoting a security-conscious culture within the organization.
  5. Incident Response Planning:
    • Developing and maintaining an incident response plan that outlines the steps to take in the event of a security incident or data breach.
    • Conducting tabletop exercises and simulations to test the effectiveness of the incident response plan.
  6. Security Auditing and Testing:
    • Conducting regular security audits and assessments to identify vulnerabilities and weaknesses in the company’s systems and processes.
    • Performing penetration testing and vulnerability scanning to proactively detect and address security flaws.
  7. Security Architecture and Design:
    • Collaborating with IT teams to ensure that security is integrated into the design and architecture of systems, applications, and networks.
    • Evaluating and selecting security technologies and solutions to protect the organization’s assets.
  8. Threat Intelligence and Monitoring:
    • Monitoring the threat landscape to stay informed about emerging cybersecurity threats and trends.
    • Collecting and analyzing threat intelligence to proactively identify potential risks to the organization.
  9. Security Incident Investigation:
    • Investigating security incidents and breaches to determine their scope, impact, and root causes.
    • Collecting and preserving digital evidence for potential legal and regulatory purposes.
  10. Vendor and Third-Party Risk Management:
    • Assessing the cybersecurity practices of third-party vendors and partners who have access to the company’s data or systems.
    • Implementing risk mitigation strategies for third-party relationships.
  11. Reporting and Communication:
    • Reporting cybersecurity and compliance status and incidents to senior management, the board of directors, and relevant stakeholders.
    • Maintaining open lines of communication with legal, IT, risk management, and other relevant departments.
  12. Continuous Improvement:
    • Continuously evaluating and improving the organization’s cybersecurity posture based on lessons learned from security incidents and evolving threats.
    • Staying updated on cybersecurity trends and best practices to adapt security measures accordingly.
  13. Business Continuity and Disaster Recovery Planning:
    • Developing and maintaining business continuity and disaster recovery plans to ensure the organization can recover from disruptive events, including cybersecurity incidents.
  14. Regulatory Liaison:
    • Interacting with regulatory authorities and auditors during compliance assessments and audits.
    • Ensuring timely responses to regulatory inquiries and requests for information.


Cybersecurity and compliance are ongoing commitments that require dedicated attention and expertise. By establishing a specialized team or task force responsible for these crucial aspects, companies can better protect their data, reputation, and financial stability. Whether by empowering existing teams or creating new ones, the commitment to cybersecurity and compliance is an investment in the long-term success and resilience of the organization.

The post NIS2: 2.Designate a responsible person or team first appeared on Sorin Mustaca on Cybersecurity.

How-To: NIS2 EU Directive

The NIS2 Directive is a European Union legislative text on cybersecurity that supersedes the first NIS (Network and Information Security) Directive, adopted in July 2016.

NIS vs. NIS2

While the first NIS (Network and Information Security) Directive increased the Member States’ cybersecurity capabilities, its implementation proved difficult, resulting in fragmentation at different levels across the internal market. To respond to the growing threats posed with digitalisation and the surge in cyber-attacks, the Commission has submitted a proposal to replace the NIS Directive and thereby strengthen the security requirements, address the security of supply chains, streamline reporting obligations, and introduce more stringent supervisory measures and stricter enforcement requirements, including harmonised sanctions across the EU.

NIS2 strengthens security requirements in the EU by expanding the NIS scope to more sectors and entities, taking into account

  • the security of supply chains,
  • streamlining reporting obligations,
  • introducing monitoring measures,
  • introducing more stringent enforcement requirements,
  • adding the concept of “management bodies” accountability within companies, and
  • harmonizing and tightening sanctions in all Member States.

To achieve the above mentioned goals, NIS2 requires member states to take a number of measures that forces them to work together:

  • Establish or improve information sharing between member states and a common incident response plan that coordinates with other member state plans
  • Establish a national Computer Emergency Response Team
  • Strengthen cooperation between public and private sector entities


In a nutshell, companies can stay compliant with the NIS2 Directive by

  • establishing an effective monitoring system that can detect intrusions, detect suspicious activities, and alert the authorities when necessary
  • developing comprehensive plans that detail how they will respond to an attack and what steps they will take to recover from it.


The official website of the EU for the NIS2 Directive has prepared an FAQ with many good questions and answers.

However, what the website is not saying (for good reasons) is how should companies start to prepare for implementing the directive.


How to start the compliance path

In order to successfully start implementing the requirements, the following steps should be implemented in this order. We will publish articles about pretty much each of these topics.


1.Conduct a gap analysis

Assess your company’s current cybersecurity practices, policies, and infrastructure against the requirements of the NIS2 directive.

Identify any gaps or areas that need improvement to comply with the directive.

Dedicated article:


2.Designate a responsible person or team

Appoint an individual or a team responsible for overseeing the implementation of the NIS2 directive within your company. This could be a dedicated cybersecurity team or an existing department with relevant expertise.

Dedicated article:


3.Establish a cybersecurity framework

Develop or update your company’s cybersecurity framework to align with the NIS2 directive. This framework should include policies, procedures, and technical controls to protect your network and information systems effectively.

Dedicated article:


4.Perform a risk assessment

Conduct a comprehensive risk assessment of your company’s network and information systems. Identify potential threats, vulnerabilities, and risks that may impact the availability, integrity, and confidentiality of critical systems and data. This assessment will help you prioritize security measures and allocate appropriate resources. Risk management and assessments are an ongoing process. Once one risk assessment is carried out, it is important to schedule regular updates to ensure all steps are maintained.

Dedicated article:


5.Implement security measures

Based on the risk assessment findings, implement appropriate security measures to mitigate identified risks. This may include network segmentation, access controls, intrusion detection systems, incident response procedures, encryption, employee training, and regular security updates, among others.

Dedicated article:


6.Establish incident response capabilities

Develop an incident response plan and establish procedures for detecting, responding to, and recovering from cybersecurity incidents. Ensure the assigned employees are trained on how to recognize and report security breaches promptly. Business continuity is a very complex topic, which must be planned with a lot of time in advance and it requires extra resources (both human and financial).

Dedicated article:


7.Continuously Monitor and review

Implement mechanisms to continuously monitor and assess your network and information systems for potential threats. Regularly review and update your cybersecurity measures to adapt to emerging risks and changes in the threat landscape.

Dedicated article:


8. Maintain documentation and records

Keep comprehensive documentation of your cybersecurity measures, risk assessments, incident response activities, and any other relevant information. This documentation will serve as evidence of compliance and may be required for regulatory audits or investigations. A good record might save your company legal and regulatory repercussions in case of a major incident (cyber related or not).

Dedicated article:


9.Engage with regulatory authorities

Stay informed about any reporting or notification obligations outlined in the NIS2 directive. Establish communication channels with the relevant regulatory authorities and comply with any reporting requirements or inquiries they may have. NIS2 strives to improve EU-wide communication and sharing of cyber events in order to better prepare answers and reactions. Communication has never been more important than now.

Dedicated article:


10. Define KPIs for cybersecurity and measures taken based on them

In order to measure the effectiveness of the cybersecurity, you need to define metrics that allow identifying and quantifying changes. Example of metrics are number of incidents, types of incidents,  how many trainings have been made, how many people were trained, how many pentests were made and how many issues were identified, and many more.

Dedicated article:




The post How-To: NIS2 EU Directive first appeared on Sorin Mustaca on Cybersecurity.