What is ‘Continuous Monitoring’ for Insider Threat Detection?

A core component of any Insider Risk Management program is what is referred to as Continuous Monitoring by the U.S. Government, which involves the collection, correlation and analysis of data to identify patterns of behaviour, activity or indications that a trusted insider may pose a threat (i.e. an ‘insider threat’) or be progressing down the Critical Path.

To perform Continuous Monitoring, organisations are purchasing solutions such as DTEX, Exabeam, Secureonix, and Splunk or alternatively using existing analytics platforms to introduce some level of capability. Microsoft Purview Insider Risk Management, launched in 2019, is another option in the vendor landscape. Irrespective of what system you use, they all have one thing in common: they generate ‘alerts’.

What is an ‘alert’ anyway?

Advanced analytics systems (such as those used in insider threat detection, workforce intelligence, fraud detection or cybersecurity) generate what are colloquially referred to as ‘alerts‘. Alerts are simply instances of activity (e.g. transactions, behaviours, relationships, events) which meet the criteria configured in the advanced analytics system models.

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Alerts that are generated are typically managed, or dispositioned, as a ‘case’ using some sort of case management system. Dispositioning an alert involves reviewing the information associated with that alert and potentially conducting further data collection or analysis specific to the alert’s “event type”, before determing what to do with it based on organisational policies. This sequential process is illustrated below:

Some insider threat detection solutions offer detection analytics and case management as part of an integrated solution, some have no inbuilt case management functionality but easily integrate with a third party solution via API, and yet others accomodate both options. Case Management is a large topic in its own right which I will write about more in the future.

The three levels of insider risk ‘alert’ management

The literature on Insider Risk Management typically refers to three types of alert. Whilst the terminology and specifics is inconsistent between authors, audiences and vendors, the basic principles remain the same. My interpretation is explored more below:

Level 1 alert disposition comprises the steps take to review a system generated alert based on pre-defined or deployed detection models or rules. In some situations, Level 1 alerts may only comprise a single indicator, which is likely to give rise to more ‘false positives’ and may be easily triggered out of context. Level 1 alerts are typically anonymised or masked in many Insider Threat Detection systems on the market to prevent analysts identifying individuals and reducing opportunities for analytical bias. In terms of actions, a Level 1 analyst might:

• Reject an alert as a false positive,
• Place some sort of temporary increased monitoring on the individual if there are signs of suspicious behaviour but do not meet the organisation’s criteria for escalation, or,
• Escalate the Level 1 alert to a Level 2 case where there characteristics of a case meet the businesses pre-defined criteria for escalation.

Level 1 alerts are usually the greatest in terms of volume, and are typically dispositioned by junior team members or in cases where risks are within tolerance, automated decision engines.

Level 2 preliminary assessment is where the basics of what we consider a ‘real’ investigation begin, and may involve looking for patterns of behaviour, anomalies, or performing background investigations to gather context required to disposition what are often multiple alerts on the same individual, or which involve a single typology comprising multiple inter-related indicators or behavioural patterns.

Level 2 cases are often worked by more experienced team members. They typically commence with an anonymised case but if the case is not closed as a ‘false positive’, at some point the evidence may justify de-anonymising based on the organisation’s policies and procedures. The outcomes of a Level 2 case typically include:

• Close a case as unsubstantiated / unable to substantiate / no case to answer;
• Place the trusted insider or type of behaviour / activity on a watchlist so it can be more closely monitored in the future (often involving manual review without reliance on automated detection models);
• Refer the matter to a line manager or other internal professional (e.g. HR, Compliance, Risk, IT) where action is required but criterial for Level 3 escalation is not met such as:
  • Trusted insiders who are at the early stages of progressing along the critical path and may benefit from counselling or individual support, and / or,
  • Staff who require more training, coaching or guidance to ensure proper compliance (i.e. ignorant or complacent insiders), or,
  • Identification of internal control gaps requiring remediation by the employer (i.e. cases where an employee is not a fault)
• Escalate the case to Level 3 where an allegation of misconduct, fraud or other criminal behaviour is formed.

Level 3 comprises a formal internal investigation, performed by professionaly trained and appropriately accredited investigators (see ICAC, 2022). Sometimes it is appropriate for these investigations to be performed by external service providers – if unsure, guidance should be sought with General Counsel prior to commencing an investigation. These investigations involve not just evidence collection and data analysis from systems, but may also involve interviewing witnesses and suspects, taking statements, writing formal investigative reports and, in extreme cases, preparing briefs of evidence for criminal prosecution.

Level 3 investigations are not undertaken lightly

Just because a case is meets the organisation’s criteria and is escalated for Level 3 investigation does not necessarily mean that an investigation must or will commence (see ICAC, 2022). Businesses need strong governance and clear policies when it comes to internal investigations, starting with the management decision on whether a formal investigation is justified.

Typically this decision will be made by a special committee with delegated authority from the CEO or Board and comprising representation from senior management, legal, HR, risk, compliance, security and integrity, and sometimes internal audit. This decision is based off a number of factors which will be explored more in a future article, but the important thing is to have clear guidlines and evaluate each case in a consistent manner to avoid allegations of bias.

Importantly, even for Level 3 cases employers have a range of alternatives to a formal investigation, including changes to supervision or management arrangements, employee development, or other organisational action. Where a formal internal investigation is performed, employees must be afforded procedural fairness (also known as ‘natural justice’).

In my opinion, Level 2 alert dispositions are the most critical for any employer. They can identify and divert trusted insiders at early stages of progressing along the critical path, and whilst harm may have been done against the organised, this may be relatively minimal and / or recoverable for the organisation and trusted insider concerned. In contrast, it may not be possible or practical for malicious trusted insiders to recover from some types of Level 3 cases which are substantiated. It makes sense to disproportionately allocate organisational resources – including specialists from HR, Legal, IT, security, counsellors, and professional psychologists to resolve Level 2 issues, in comparison to Levels 1 and 3.

Level 2: source of greatest risk and greatest opportunity for diversion?

In contrast to Level 1 and Level 3 cases, Level 2 presents not only the greatest opportunity (as outlined above) but the greatest risk to the organisation. I have seen overzealous individiuals do substantial damage at this stage, far more so than Level 1 where opportunities to cause harm are limited due to viewing an anonymised alert in isolation, and Level 3 which are staffed by professional and experienced investigators, oversighted by appropriate governance and legal mechanisms and who have a deep understanding of how to perform their role.

Level 2 practitioners often have a combination of advanced skills, knowledge of the alert subject’s identity, however they typically lack of understanding of the law and protocols when conducting an internal investigation. This can lead to the commencement of what is effectively a Level 3 investigation without internal approval or oversight, potentially damaging employee engagement and trust in management, removal or termination of the insider risk management program, litigation or regulatory action, and even adverse mental health and welfare outcomes for the subject concerned.

It is imperative that Level 1 and 2 team members, particularly Level 2, recieve adequate training and guidance on what is and is not appropriate in their role. Any Insider Risk Management Program, including continuous monitoring, should be fair, transparent and developed in consultation with Legal, employees and where applicable unions. Poor practices or discipline in continuous monitoring can terminally damage organisational trust in such progams.

Further Reading

• Center for the Development of Security Excellence (2015). Continuous Monitoring Student Guide, CS200.16, https://www.cdse.edu/Training/eLearning/CS200-resources/
• Curwell, P. (2022). Applying the critical-path approach to insider risk management
• Curwell, P. (2022). How can Insider Threats manifest in the Supply Chain?
• Curwell, P. (2022). Typologies demystified – what are they and why are they important?
• Gelles, M. G. (2016). Insider Threat: Prevention, Detection, Mitigation and Deterrence, Butterworth-Heinemann, Oxford.
• ICAC (2022). Factfinder: a guide to conducting internal investigations, 21 April 2022, NSW Government, https://www.icac.nsw.gov.au/prevention/corruption-prevention-publications/latest-corruption-prevention-publications/factfinder
• Spooner, D., Silowash, G., Costa, D., Albrethsen, M. (2018). Navigating the Insider Threat Tool Landscape: Low cost technical solutions to jump-start and Insider Threat Program, June 2018, Software Engineering Institute, Carnegie Mellon University, https://resources.sei.cmu.edu

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