Enforce an Acceptable Use Policy

A subject unlawfully accesses copyrighted material, such as pirated media or illegitimate streaming sites.

A subject accesses web content that is deemed inappropriate by the organization.

A subject installs unapproved software on a corporate device, contravening internal policies on acceptable use of company equipment.

A subject may exfiltrate data via a physical medium, such as a removable drive.

A subject uses an external device, such as a mobile phone or camera, to record audio, photos, or video to capture media.

A subject exfiltrates files through a network. A network can be an Internet Protocol (IP) network or other technology enabling the communication of data between two or more digital devices.

A subject intentionally provides system or data access to a third party that is not authorized to access it.

A subject can access the web with an organization device.

A subject is unaware that they are prohibited from accessing and exfiltrating or destroying sensitive data or otherwise contravening internal policies.

A subject accesses and exfiltrates or destroys sensitive data or otherwise contravenes internal policies with the aim to successfully defeat controls in order to demonstrate ability and/or skill.

A subject uses organizational resources, such as internet access, email, or work devices, for personal activities both during and outside work hours, exceeding reasonable personal use. This leads to reduced productivity, increased security risks, and the potential mixing of personal and organizational data, ultimately affecting the organization’s efficiency and overall security.

A subject interacts with a public Artificial Intelligence (AI) chatbot (such as ChatGPT and xAI Grok), leading to the intentional or unintentional sharing of sensitive information.

The subject uninstalls software, which may also remove relevant artifacts from the system's disk, such as regsitry keys or files necessary for the software to run, preventing them from being used by investigators to track activity.

A subject, driven by excessive pride in their nation, country, or region, undertakes actions that harm an organization. These actions are self-initiated and conducted unilaterally, without instruction or influence from legitimate authorities within their nation, country, region, or any other third party. The subject often perceives their actions as acts of loyalty or as benefiting their homeland.

While the subject may believe they are acting in their nation’s best interest, their actions frequently lack strategic foresight and can result in significant damage to the organization.

An individual or individuals knowingly assist a subject to gain access to devices, systems, or services that hold sensitive information, or otherwise contravene internal policies.

Sensitivity label leakage refers to the exposure or misuse of classification metadata—such as Microsoft Purview Information Protection (MIP) sensitivity labels—through which information about the nature, importance, or confidentiality of a file is unintentionally or deliberately disclosed. While the underlying content of the document may remain encrypted or otherwise protected, the presence and visibility of sensitivity labels alone can reveal valuable contextual information to an insider.

This form of leakage typically occurs when files labeled with sensitivity metadata are transferred to insecure locations, shared with unauthorized parties, or surfaced in logs, file properties, or collaboration tool interfaces. Labels may also be leaked through misconfigured APIs, email headers, or third-party integrations that inadvertently expose metadata fields. The leakage of sensitivity labels can help a malicious insider identify and prioritize high-value targets or navigate internal systems with greater precision, without needing immediate access to the protected content.

Examples of Use:

• An insider accesses file properties on a shared drive to identify documents labeled Highly Confidential with the intention of exfiltrating them later.
• Sensitivity labels are exposed in outbound email headers or logs, revealing the internal classification of attached files.
• Files copied to an unmanaged device retain their label metadata, inadvertently disclosing sensitivity levels if examined later.

A subject holds access to both physical and digital assets that can enable insider activity. This includes systems such as databases, cloud platforms, and internal applications, as well as physical environments like secure office spaces, data centers, or research facilities. When a subject has access to sensitive data or systems—especially with broad or elevated privileges—they present an increased risk of unauthorized activity.

Subjects in roles with administrative rights, technical responsibilities, or senior authority often have the ability to bypass controls, retrieve restricted information, or operate in areas with limited oversight. Even standard user access, if misused, can facilitate data exfiltration, manipulation, or operational disruption. Weak access controls—such as excessive permissions, lack of segmentation, shared credentials, or infrequent reviews—further compound this risk by enabling subjects to exploit access paths that should otherwise be limited or monitored.

Furthermore, subjects with privileged or strategic access may be more likely to be targeted for recruitment by external parties to exploit their position. This can include coercion, bribery, or social engineering designed to turn a trusted insider into an active participant in malicious activities.

A subject uses a website or peer-to-peer (P2P) network (such as BitTorrent) to unlawfully download copyrighted material.

A subject accesses a website that allows for the unauthorized streaming of copyrighted material.

A subject uses a website or peer-to-peer (P2P) network (such as BitTorrent) to unlawfully distribute copyrighted material.

A subject accesses lawful pornographic material from an organization device, contravening internal policies on acceptable use of organization equipment.

A subject accesses or participates in online gambling from a corporate device, contravening internal policies on acceptable use of company equipment.

A subject misuses social media platforms to engage in activities that violate organizational policies, compromise security, disclose confidential information, or damage the organization’s reputation. This includes sharing sensitive data, making unauthorized statements, engaging in harassment or bullying, or undertaking any actions that could risk the organization’s digital security or public image.

A subject accesses or participates in web-based online gaming from a corporate device, contravening internal policies on acceptable use of company equipment.

A subject accesses other inappropriate web content from a corporate device, contravening internal policies on acceptable use of company equipment.

A subject installs a hypervisor that allows them to create and access virtual environments on a device.

A subject can install an unapproved browser with features that frustrate or prevent preventions or detections, such as built-in VPN, Tor access, or automatic browser artifact destruction.

A subject installs a VPN application that allows them to tunnel their traffic.

A subject can install unapproved browser extensions that provide additional features and functionality to the browser.

A subject can install an unapproved cloud storage application that has the ability to sync files across the Internet.

A subject installs an unapproved note taking application with the ability to sync notes across the Internet.

A subject installs an unapproved messenger application with the ability to transmit data and/or files across the Internet.

A subject installs a Secure Shell (SSH) client, which can be used to access SSH servers across a network.

A subject installs a File Transfer Protocol (FTP) client which can be used to access FTP servers across the a network.

A subject installs a Remote Desktop Protocol (RDP) client which can be used to access RDP servers across a network.

A subject installs screen sharing software which can be used to capture images or other information from a target system.

A subject may use an existing, legitimate external Web service to exfiltrate data

A subject uses a cloud storage service, such as Dropbox, OneDrive, or Google Drive to exfiltrate data. They will then access that service again on another device to retrieve the data. Examples include (URLs have been sanitized):

• hxxps://www.dropbox[.]com
• hxxps://drive.google[.]com
• hxxps://onedrive.live[.]com
• hxxps://mega[.]nz
• hxxps://www.icloud[.]com/iclouddrive
• hxxps://www.pcloud[.]com

A subject uses a code repository service, such as GitHub, to exfiltrate data. They will then access that service again on another device to retrieve the data. Examples include (URLs have been sanitized):

• hxxps://github[.]com
• hxxps://gitlab[.]com
• hxxps://bitbucket[.]org
• hxxps://sourceforge[.]net
• hxxps://aws.amazon[.]com/codecommit

A subject uses a text storage service, such as Pastebin, to exfiltrate data. They will then access that service again on another device to retrieve the data. Examples include (URLs have been sanitized):

• hxxps://pastebin[.]com
• hxxps://hastebin[.]com
• hxxps://privatebin[.]net
• hxxps://controlc[.]com
• hxxps://rentry[.]co
• hxxps://dpaste[.]org

A subject exfiltrates data using a USB-connected mass storage device, such as a USB flash drive or USB external hard-drive.

A subject exfiltrates data by retrieving the physical drive used by a system.

A subject exfiltrates data by connecting an additional drive to a system using the Serial Advanced Technology Attachment (SATA) interface on a motherboard, and copying files to the new storage device.

A subject exfiltrates data using a floppy disk drive.

A subject uses a device, such as a mobile phone or camera, to take photos containing sensitive information.

A subject uses an external device, such as a mobile phone or camera, to take video recordings containing sensitive information.

A subject uses an external device, such as a mobile phone or camera, to take record audio containing sensitive information, such as conversations.

A subject exfiltrates files using BlueTooth as the transportation medium.

A subject exfiltrates files using AirDrop as the transportation medium.

A subject exfiltrates information using a messaging application that is already installed on the system. They will access the conversation at a later date to retrieve information on a different system.

A subject exfiltrates information using a web-based messaging application that is accessed through a web browser. They will access the conversation at a later date to retrieve information on a different system.

A subject can access personal webmail services in a browser.

A subject can access personal cloud storage in a browser.

A subject can access websites containing inappropriate content.

A subject can access external note-taking websites (Such as Evernote).

A subject can access external messenger web-applications with the ability to transmit data and/or files.

A subject exfiltrates data using an organization-owned device (such as a laptop) by copying the data from the device to a personal Network Attached Storage (NAS) device, which is attached to a network outside of the control of the organization, such as a home network. Later, using a personal device, the subject accesses the NAS to retrieve the exfiltrated data.

A USB to USB data transfer cable is a device designed to connect two computers directly together for the purpose of transferring files between them. These cables are equipped with a small electronic circuit to facilitate data transfer without the need for an intermediate storage device. Typically a USB to USB data transfer cable will require specific software to be installed to facilitate the data transfer. In the context of an insider threat, a USB to USB data transfer cable can be a tool for exfiltrating sensitive data from an organization's environment.

A subject uploads confidential organization data to a note-taking web service, such as Evernote. The subject can then access the confidential data outside of the organization from another device. Examples include (URLs have been sanitized):

• hxxps://www.evernote[.]com
• hxxps://keep.google[.]com
• hxxps://www.notion[.]so
• hxxps://www.onenote[.]com
• hxxps://notebook.zoho[.]com

A subject can access external text storage websites, such as Pastebin.

A subject exfiltrates data outside of the organization's control using the built-in file transfer capabilities of software such as Teamviewer.

A subject intentionally submits sensitive information when interacting with a public Artificial Intelligence (AI) chatbot (such as ChatGPT and xAI Grok). They will access the conversation at a later date to retrieve information on a different system.

A subject recklessly interacts with a public Artificial Intelligence (AI) chatbot (such as ChatGPT and xAI Grok), leading to the inadvertent sharing of sensitive information. The submission of sensitive information to public AI platforms risks exposure due to potential inadequate data handling or security practices. Although some platforms are designed not to retain specific personal data, the reckless disclosure could expose the information to unauthorized access and potential misuse, violating data privacy regulations and leading to a loss of competitive advantage through the exposure of proprietary information.

A subject connects their personal device, under a Bring Your Own Device (BYOD) policy, to organization resources, such as on-premises systems or cloud-based platforms. By leveraging this access, the subject exfiltrates sensitive or confidential data. This unauthorized data transfer can occur through various means, including copying files to the personal device, sending data via email, or using cloud storage services.

A subject creates an email collection file such as a Personal Storage Table (PST) file or an MBOX file to copy an entire mailbox or subset of a mailbox containing sensitive information.

PII (Personally Identifiable Information) leakage refers to the unauthorized disclosure, exposure, or mishandling of information that can be used to identify an individual, such as names, addresses, phone numbers, national identification numbers, financial data, or biometric records. In the context of insider threat, PII leakage may occur through negligence, misconfiguration, policy violations, or malicious intent.

Insiders may leak PII by sending unencrypted spreadsheets via email, exporting user records from customer databases, misusing access to HR systems, or storing sensitive personal data in unsecured locations (e.g., shared drives or cloud storage without proper access controls). In some cases, PII may be leaked unintentionally through logs, collaboration platforms, or default settings that fail to mask sensitive fields.

The consequences of PII leakage can be severe—impacting individuals through identity theft or financial fraud, and exposing organizations to legal penalties, reputational harm, and regulatory sanctions under frameworks such as GDPR, CCPA, or HIPAA.

Examples of Infringement:

• An employee downloads and shares a list of customer contact details without authorization.
• PII is inadvertently exposed in error logs or email footers shared externally.
• HR data containing employee National Insurance or Social Security numbers is copied to a personal cloud storage account.

PHI Leakage refers to the unauthorized, accidental, or malicious exposure, disclosure, or loss of Protected Health Information (PHI) by a healthcare provider, health plan, healthcare clearinghouse (collectively, "covered entities"), or their business associates. Under the Health Insurance Portability and Accountability Act (HIPAA) in the United States, PHI is defined as any information that pertains to an individual’s physical or mental health, healthcare services, or payment for those services that can be used to identify the individual. This includes medical records, treatment history, diagnosis, test results, and payment details.

HIPAA imposes strict regulations on how PHI must be handled, stored, and transmitted to ensure that individuals' health information remains confidential and secure. The Privacy Rule within HIPAA outlines standards for the protection of PHI, while the Security Rule mandates safeguards for electronic PHI (ePHI), including access controls, encryption, and audit controls. Any unauthorized access, improper sharing, or accidental exposure of PHI constitutes a breach under HIPAA, which can result in significant civil and criminal penalties, depending on the severity and nature of the violation.

In addition to HIPAA, other countries have established similar protections for PHI. For example, the General Data Protection Regulation (GDPR) in the European Union protects personal health data as part of its broader data protection laws. Similarly, Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) governs the collection, use, and disclosure of personal health information by private-sector organizations. Australia also has regulations under the Privacy Act 1988 and the Health Records Act 2001, which enforce stringent rules for the handling of health-related personal data.

This infringement occurs when an insider—whether maliciously or through negligence—exposes PHI in violation of privacy laws, organizational policies, or security protocols. Such breaches can involve unauthorized access to health records, improper sharing of medical information, or accidental exposure of sensitive health data. These breaches may result in severe legal, financial, and reputational consequences for the healthcare organization, including penalties, lawsuits, and loss of trust.

Examples of Infringement:

• A healthcare worker intentionally accesses a patient's medical records without authorization for personal reasons, such as to obtain information on a celebrity or acquaintance.
• An employee negligently sends patient health data to the wrong recipient via email, exposing sensitive health information.
• An insider bypasses security controls to access and exfiltrate medical records for malicious use, such as identity theft or selling PHI on the dark web.

Sanction violations involve the direct or indirect engagement in transactions with individuals, entities, or jurisdictions that are subject to government-imposed sanctions. These restrictions are typically enforced by regulatory bodies such as the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United Nations, the European Union, and equivalent authorities in other jurisdictions.

Unlike export violations, which focus on the control of goods and technical data, sanction violations concern the status of the receiving party. A breach occurs when a subject facilitates, authorizes, or executes transactions that provide economic or material support to a sanctioned target—this includes sending payments, delivering services, providing access to infrastructure, or sharing non-controlled information with a restricted party.

Insiders may contribute to sanction violations by bypassing compliance checks, falsifying documentation, failing to screen third-party recipients, or deliberately concealing the sanctioned status of a partner or entity. Such conduct can occur knowingly or as a result of negligence, but in either case, it exposes the organization to serious legal and financial consequences.

Regulatory enforcement for sanctions breaches may result in significant penalties, asset freezes, criminal prosecution, and reputational damage. Organizations are required to maintain robust compliance programs to monitor and prevent insider-driven violations of international sanctions regimes.

Anti-trust or anti-competition violations occur when a subject engages in practices that unfairly restrict or distort market competition, violating laws designed to protect free market competition. These violations can involve a range of prohibited actions, such as price-fixing, market division, bid-rigging, or the abuse of dominant market position. Such behavior typically aims to reduce competition, manipulate pricing, or create unfair advantages for certain businesses or individuals.

Anti-competition violations may involve insiders leveraging their position to engage in anti-competitive practices, often for personal or corporate gain. These violations can result in significant legal and financial penalties, including fines and sanctions, as well as severe reputational damage to the organization involved.

Examples of Anti-Trust or Anti-Competition Violations:

• A subject shares sensitive pricing or bidding information between competing companies, enabling coordinated pricing or market manipulation.
• An insider with knowledge of a merger or acquisition shares details with competitors, leading to coordinated actions that suppress competition.
• An employee uses confidential market data to form agreements with competitors on market control, stifling competition and violating anti-trust laws.

Regulatory Framework:

Anti-trust or anti-competition laws are enforced globally by various regulatory bodies. In the United States, the Federal Trade Commission (FTC) and the Department of Justice (DOJ) regulate anti-competitive behavior under the Sherman Act, the Clayton Act, and the Federal Trade Commission Act. In the European Union, the European Commission enforces anti-trust laws under the Treaty on the Functioning of the European Union (TFEU) and the Competition Act.

Subjects with access to production and pre-production environments—whether as users, developers, or administrators—hold the potential to exploit or compromise highly sensitive organizational assets. Production environments, which host live applications and databases, are critical to business operations and often contain real-time data, including proprietary business information and personally identifiable information (PII). A subject with access to these systems can manipulate operational processes, exfiltrate sensitive data, introduce malicious code, or degrade system performance.

Pre-production environments, used for testing, staging, and development, often replicate production systems, though they may contain anonymized or less protected data. Despite this, pre-production environments can still house sensitive configurations, APIs, and testing data that can be exploited. A subject with access to these environments may uncover system vulnerabilities, access sensitive credentials, or introduce code that could be escalated into the production environment.

In both environments, privileged access provides a direct pathway to the underlying infrastructure, system configurations, logs, and application code. For example, administrative access allows manipulation of security policies, user permissions, and system-level access controls. Similarly, access to development environments can provide insights into source code, configuration management, and test data—all of which could be leveraged to further insider activity.

Subjects with privileged access to critical environments are positioned not only to exploit system vulnerabilities or bypass security controls but also to become targets for recruitment by external actors seeking unauthorized access to sensitive information. These individuals may be approached or coerced to intentionally compromise the environment, escalate privileges, or exfiltrate data on behalf of malicious third parties.

Given the sensitivity of these environments, subjects with privileged access represent a significant insider threat to the integrity of the organization's systems and data. Their position allows them to manipulate or exfiltrate sensitive information, either independently or in collaboration with external actors. The risk is further amplified as these individuals may be vulnerable to recruitment or coercion, making them potential participants in malicious activities that compromise organizational security. As insiders, their knowledge and access make them a critical point of concern for both data protection and operational security.

Subjects with physical access to critical hardware—such as data center infrastructure, on-premises servers, network appliances, storage arrays, or specialized equipment like CCTV and alarm systems—represent a significant insider threat due to their ability to bypass logical controls and interact directly with systems. This level of access can facilitate a wide range of security compromises, many of which are difficult to detect through conventional digital monitoring.

Physical access may also include proximity to sensitive areas such as network closets, on-premises server racks, backup repositories, or control systems in operational technology (OT) environments. In high-security settings, even brief unsupervised access can be exploited to compromise system integrity or enable ongoing unauthorized access.

With this type of access, a subject can:

• Extract or clone drives and media for offline analysis or exfiltration of sensitive data, including proprietary documents, logs, authentication secrets, and configuration files.
• Introduce malicious hardware or firmware, such as USB-based keyloggers, hardware implants, or modified components that persist beyond reboots and may evade traditional endpoint protections.
• Bypass access controls by booting from external media, altering BIOS or UEFI settings, or resetting system passwords using direct hardware manipulation.
• Install or modify software directly on the system, enabling surveillance tools, remote access backdoors, or malicious code that blends in with legitimate system processes.
• Capture network traffic by tapping physical interfaces or inserting intermediary devices such as portable switches, protocol analyzers, or rogue wireless access points.
• Disable security mechanisms, such as disconnecting monitoring systems, tampering with surveillance equipment, or disabling redundant power and failover systems to induce outages.

In operational environments, subjects with access to physical control systems (e.g., ICS/SCADA components, industrial HMIs, or IoT gateways) may alter processes, cause service disruptions, or create safety hazards. Similarly, access to CCTV or badge systems may allow them to erase footage, monitor employee movements, or manipulate access control logs.

Subjects with this form of access represent an elevated risk, especially when combined with technical knowledge or administrative privileges. The risk is compounded in environments with limited physical security controls, inadequate logging of physical entry, or weak segmentation between physical and digital assets.

Subjects with authorized access to sensitive physical spaces—such as secure offices, executive areas, data centers, SCIFs (Sensitive Compartmented Information Facilities), R&D labs, or restricted zones in critical infrastructure—pose an increased insider threat due to their physical proximity to sensitive assets, systems, and information.

Such spaces often contain high-value materials or information, including printed sensitive documents, whiteboard plans, authentication devices (e.g., smartcards or tokens), and unattended workstations. A subject with physical presence in these locations may observe confidential conversations, access sensitive output, or physically interact with devices outside of typical security monitoring.

This type of access can be leveraged to:

• Obtain unattended or discarded sensitive information, such as printouts, notes, or credentials left on desks.
• Observe operational activity or decision-making, gaining insight into projects, personnel, or internal dynamics.
• Access unlocked devices or improperly secured terminals, allowing direct system interaction or credential harvesting.
• Bypass digital controls via physical means, such as tailgating into secure spaces or using misappropriated access cards.
• Covertly install or remove equipment, such as data exfiltration tools, recording devices, or physical implants.
• Eavesdrop on confidential conversations, either directly or through concealed recording equipment, enabling the collection of sensitive verbal disclosures, strategic discussions, or authentication procedures.

Subjects in roles that involve frequent presence in sensitive locations—such as cleaning staff, security personnel, on-site engineers, or facility contractors—may operate outside the scope of standard digital access control and may not be fully visible to security teams focused on network activity.

Importantly, individuals with this kind of access are also potential targets for recruitment or coercion by external threat actors seeking insider assistance. The ability to physically access secure environments and passively gather high-value information makes them attractive assets in coordinated attempts to obtain or compromise protected information.

The risk is magnified in organizations lacking comprehensive physical access policies, surveillance, or cross-referencing of physical and digital access activity. When unmonitored, physical access can provide a silent pathway to support insider operations without leaving traditional digital footprints.

A subject with a people management role holds significant influence over their direct reports, which can be leveraged to conduct insider activities. As a leader, the subject is in a unique position to shape team dynamics, direct tasks, and control the flow of information within their team. This authority presents several risks, as the subject may:

• Influence team members to inadvertently or deliberately carry out tasks that contribute to the subject’s insider objectives. For instance, a manager might ask a subordinate to access or move sensitive data under the guise of a legitimate business need or direct them to work on projects that will inadvertently support a malicious agenda.
• Exert pressure on employees to bypass security protocols, disregard organizational policies, or perform actions that could compromise the organization’s integrity. For example, a manager might encourage their team to take shortcuts in security or compliance checks to meet deadlines or targets.
• Control access to sensitive information, either by virtue of the manager’s role or through the information shared within their team. A people manager may have direct visibility into highly sensitive internal communications, strategic plans, and confidential projects, which can be leveraged for malicious purposes.
• Isolate team members or limit their exposure to security training, potentially creating vulnerabilities within the team that could be exploited. By controlling the flow of information or limiting access to security awareness resources, a manager can enable an environment conducive to insider threats.
• Recruit or hire individuals within their team or external candidates who are susceptible to manipulation or willing to participate in insider activities. A subject in a management role could use their hiring influence to bring in new team members who align with or are manipulated into assisting in the subject's illicit plans, increasing the risk of coordinated insider actions.

In addition to these immediate risks, subjects in people management roles may also have the ability to recruit individuals from their team for insider activities, subtly influencing them to support illicit actions or help cover up their activities. By fostering a sense of loyalty or manipulating interpersonal relationships, the subject may encourage compliance with unethical actions, making it more difficult for others to detect or challenge the behavior.

Given the central role that managers play in shaping team culture and operational practices, the risks posed by a subject in a management position are compounded by their ability to both directly influence the behavior of others and manipulate processes for personal or malicious gain.