Preventions
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- -PV022
- ID: PV022
- Created: 12th June 2024
- Updated: 21st July 2024
- Contributor: The ITM Team
Internal Whistleblowing
Provide a process for all staff members to report concerning and/or suspicious behaviour to the organization's security team for review. An internal whistleblowing process should take into consideration the privacy of the reporter and the subject(s) of the report, with specific regard to safeguarding against reprisals against reporters.
Sections
ID | Name | Description |
---|---|---|
MT007 | Resentment | A subject is motivated by resentment towards the organisation to access and exfiltrate or destroy data or otherwise contravene internal policies. |
MT004 | Political or Philosophical Beliefs | A subject is motivated by their political or philosophical beliefs to access and destroy or exfiltrate sensitive data or otherwise contravene internal policies. |
MT012 | Coercion | A subject is persuaded against their will to access and exfiltrate or destroy sensitive data, or conduct some other act that harms or undermines the target organization. |
MT010 | Self Sabotage | A subject accesses and exfiltrates or destroys sensitive data or otherwise contravenes internal policies with the aim to be caught and penalised. |
MT005 | Personal Gain | A subject seeks personal gain from another by accessing and exfiltrating or destroying sensitive data or otherwise contravening internal policies. |
MT011 | Hubris | 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. |
MT001 | Joiner | A subject joins the organisation with the pre-formed intent to gain access to sensitive data or otherwise contravene internal policies. |
MT002 | Mover | A subject moves within the organisation to a different team with the intent to gain access to sensitive data or to circumvent controls or to otherwise contravene internal policies. |
IF021 | Harassment and Discrimination | A subject engages in unauthorized conduct that amounts to harassment or discriminatory behavior within the workplace, targeting individuals or groups based on protected characteristics, such as race, gender, religion, or other personal attributes. Incidents of harassment and discrimination may expose the organization to legal risks, potential reputational damage, and regulatory penalties. Additionally, individuals affected by such behavior may be at higher risk of retaliating or disengaging from their work, potentially leading to further insider risks. |
MT020 | Ideology | A subject is motivated by ideology to access, destroy, or exfiltrate data, or otherwise violate internal policies in pursuit of their ideological goals.
Ideology is a structured system of ideas, values, and beliefs that shapes an individual’s understanding of the world and informs their actions. It often encompasses political, economic, and social perspectives, providing a comprehensive and sometimes rigid framework for interpreting events and guiding decision-making.
Individuals driven by ideology often perceive their actions as morally justified within the context of their belief system. Unlike those motivated by personal grievances or personal gain, ideological insiders act in service of a cause they deem greater than themselves. |
IF023 | Regulatory Non-Compliance | Regulatory non-compliance refers to insider actions that lead to breaches of laws, regulations, or industry standards governing organizational conduct. These violations may arise from deliberate misconduct, willful disregard, or negligent failure to follow established legal or compliance frameworks. In many cases, insiders exploit their access or authority to bypass controls, misrepresent information, or act in ways that conflict with regulatory obligations.
Incidents of regulatory non-compliance may involve unauthorized exports, sanctions breaches, anti-competitive behavior, or unreported conflicts of interest. Such infringements not only expose the organization to fines, legal action, and operational restrictions but also erode trust with customers, regulators, and partners. |
MT021 | Conflicts of Interest | A subject may be motivated by personal, financial, or professional interests that directly conflict with their duties and obligations to the organization. This inherent conflict of interest can lead the subject to engage in actions that compromise the organization’s values, objectives, or legal standing.
For instance, a subject who serves as a senior procurement officer at a company may have a financial stake in a vendor company that is bidding for a contract. Despite knowing that the vendor's offer is subpar or overpriced, the subject might influence the decision-making process to favor that vendor, as it directly benefits their personal financial interests. This conflict of interest could lead to awarding the contract in a way that harms the organization, such as incurring higher costs, receiving lower-quality goods or services, or violating anti-corruption regulations.
The presence of a conflict of interest can create a situation where the subject makes decisions that intentionally or unintentionally harm the organization, such as promoting anti-competitive actions, distorting market outcomes, or violating regulatory frameworks. While the subject’s actions may be hidden behind professional duties, the conflict itself acts as the driving force behind unethical or illegal behavior. These infringements can have far-reaching consequences, including legal ramifications, financial penalties, and damage to the organization’s reputation. |
ME024 | Access | 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. |
ME025 | Placement | A subject’s placement within an organization shapes their potential to conduct insider activity. Placement refers to the subject’s formal role, business function, or proximity to sensitive operations, intellectual property, or critical decision-making processes. Subjects embedded in trusted positions—such as those in legal, finance, HR, R&D, or IT—often possess inherent insight into internal workflows, organizational vulnerabilities, or confidential information.
Strategic placement can grant the subject routine access to privileged systems, classified data, or internal controls that, if exploited, may go undetected for extended periods. Roles that involve oversight responsibilities or authority over process approvals can also allow for policy manipulation, the suppression of alerts, or the facilitation of fraudulent actions.
Subjects in these positions may not only have a higher capacity to carry out insider actions but may also be more appealing targets for adversarial recruitment or collusion, given their potential to access and influence high-value organizational assets. The combination of trust, authority, and access tied to their placement makes them uniquely positioned to execute or support malicious activity. |
MT005.001 | Speculative Corporate Espionage | A subject covertly collects confidential or classified information, or gains access, with the intent to sell it to a third party private organization. |
MT005.002 | Corporate Espionage | A third party private organization deploys an individual to a target organization to covertly steal confidential or classified information or gain strategic access for its own benefit. |
MT012.003 | Psychological Manipulation | A third party uses deception, exploitation, or other unethical methods to psychologically manipulate a subject over time, with the intent to influence their perceptions, actions, and decisions. This manipulation can lead the subject to, knowingly or unknowingly, act against the organization’s interests. |
MT012.007 | Sexual Extortion | A subject is extorted by a third party threatening to expose sexual or indecent images connected to them, a tactic commonly referred to as sextortion. These images may be real, obtained by a third party, AI-generated ‘deep fake’ images resembling the subject, or entirely fabricated claims. The extortion is typically financially motivated, which can drive the subject to harm the organization for personal gain. Alternatively, the third party may coerce the subject into compromising the organization by revealing sensitive information or granting unauthorized access. |
MT005.003 | Financial Desperation | A subject facing financial difficulties attempts to resolve their situation by exploiting their access to or knowledge of the organization. This may involve selling access or information to a third party or conspiring with others to cause harm to the organization for financial gain. |
MT012.005 | Romantic Seduction | A malicious third party employs romantic interest or seduction as a manipulation tactic. Through emotional and psychological engagement, the third party persuades the subject to reveal confidential information, grant access to restricted resources, or carry out actions detrimental to the organization. |
MT012.001 | Social Engineering (Inbound) | A third party deceptively manipulates and/or persuades a subject to divulge information, or gain access to devices or systems, or to otherwise cause harm or undermine a target organization. |
IF023.001 | Export Violations | Export violations occur when a subject engages in the unauthorized transfer of controlled goods, software, technology, or technical data to foreign persons or destinations, in breach of applicable export control laws and regulations. These laws are designed to protect national security, economic interests, and international agreements by restricting the dissemination of sensitive materials and know-how.
Such violations often involve the failure to obtain the necessary export licenses, misclassification of export-controlled items, or the improper handling of technical data subject to regulatory oversight. The relevant legal frameworks may include the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and similar export control regimes in other jurisdictions.
Insiders may contribute to export violations by sending restricted files abroad, sharing controlled technical specifications with foreign nationals (even within the same organization), or circumventing export controls through the use of unauthorized communication channels or cloud services. These actions are considered violations regardless of the recipient’s sanction status and may occur entirely within legal jurisdictions if export-controlled information is shared with unauthorized individuals.
Export violations are distinct from sanction violations in that they pertain specifically to the nature of the goods, data, or services exported, and the mechanism of transfer, rather than the status of the recipient. Failure to comply with export control laws can result in civil and criminal penalties, loss of export privileges, and reputational damage to the organization. |
IF023.002 | Sanction Violations | 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. |
IF023.003 | Anti-Trust or Anti-Competition | 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:
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. |
ME024.001 | Access to Customer Data | A subject with access to customer data holds the ability to view, retrieve, or manipulate personally identifiable information (PII), account details, transactional records, or support communications. This level of access is common in roles such as customer service, technical support, sales, marketing, and IT administration. Access to customer data can become a means of insider activity when misused for purposes such as identity theft, fraud, data exfiltration, competitive intelligence, or unauthorized profiling. The sensitivity and volume of customer information available may significantly elevate the risk profile of the subject, especially when this access is unmonitored, overly broad, or lacks audit controls.
In some cases, subjects with customer data access may also be targeted by external threat actors for coercion or recruitment, given their ability to obtain regulated or high-value personal information. Organizations must consider how customer data is segmented, logged, and monitored to reduce exposure and detect misuse. |
ME024.002 | Access to Privileged Groups and Non-User Accounts | A subject with access to privileged groups (e.g., Domain Admins, Enterprise Admins, or Security Groups) or non-user accounts (such as service accounts, application identities, or shared mailboxes) gains elevated control over systems, applications, and sensitive organizational data. Access to these groups or accounts often provides the subject with knowledge of security configurations, user roles, and potentially unmonitored or sensitive activities that occur within the system.
Shared mailboxes, in particular, are valuable targets. These mailboxes are often used for group communication across departments or functions, containing sensitive or confidential information, such as internal discussions on financials, strategic plans, or employee data. A subject with access to shared mailboxes can gather intelligence from ongoing conversations, identify targets for further exploitation, or exfiltrate sensitive data without raising immediate suspicion. These mailboxes may also bypass some security filters, as their contents are typically considered routine and may not be closely monitored.
Access to privileged accounts and shared mailboxes also allows subjects to escalate privileges, alter system configurations, access secure data repositories, or manipulate security settings, making it easier to both conduct malicious activities and cover their tracks. Moreover, service and application accounts often have broader access rights across systems or environments than typical user accounts and are frequently excluded from standard monitoring protocols, offering potential pathways for undetected exfiltration or malicious action.
This elevated access gives subjects insight into critical system operations and internal communications, such as unencrypted data flows or internal vulnerabilities. This knowledge not only heightens their potential for malicious conduct but can also make them a target for external threat actors seeking to exploit this elevated access. |
ME024.003 | Access to Critical Environments (Production and Pre-Production) | 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. |
ME024.005 | Access to Physical Spaces | 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:
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. |
ME025.001 | Proximity to Strategic Business Functions | A subject’s placement within critical business units or specialized teams can grant them access to highly sensitive operational data, strategic initiatives, and proprietary information. Roles within departments such as executive leadership, corporate strategy, legal, finance, R&D, supply chain management, and security operations position the subject to interact with confidential communications, forward-looking business plans, and strategic decision-making processes.
Subjects in close proximity to organizational leadership—including C-suite executives, senior directors, or key decision-makers—are uniquely positioned to access sensitive insights, manipulate decision-making, or gather intelligence on high-stakes initiatives. These individuals may be exposed to:
Having direct or indirect access to leaders facilitates eavesdropping on confidential conversations and provides early awareness of business initiatives. This proximity allows the subject to assess organizational vulnerabilities or identify high-value targets for insider exploitation. Furthermore, the subject may be positioned to:
Subjects in such positions hold considerable power to shape business outcomes—both through direct influence over strategic initiatives and by gaining early insights into organizational direction, which can be exploited for personal gain, external manipulation, or other malicious intents.
Additionally, such individuals may become targets for recruitment by external entities seeking to exploit their access to confidential business data or influence over strategic decisions. Their proximity to leadership and critical business functions makes them an ideal conduit for conducting insider threats on behalf of external adversaries. |
ME025.002 | Leadership and Influence Over Direct Reports | 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:
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. |