United States: Inside The Federal Government's Latest Guidance On IoT Security

Last Updated: February 8 2017
Article by Hanley Chew

Companies need to be mindful of November guidance from DHS and NIST.

On Oct. 21, 2016, a massive distributed denial of service (DDoS) attack occurred against the domain name system (DNS) provider Dyn, causing widespread disruption of internet activity against the United States. A DNS is the part of the internet infrastructure that is responsible for translating domain names into numeric IP addresses, which ensures that information requests are routed to the proper server. The DDoS attack was accomplished when the attackers hacked a large number of unsecured internet-connected digital devices, such as CCTV video cameras and digital video recorders (i.e., the "Internet of Things" (IoT)), and directed the devices to transmit huge amounts of traffic to Dyn's servers. The hack of the IoT devices was made possible because the owners of these devices continued to use default user names and passwords and the utilization of the Mirai bot, which scans the internet for IoT devices that use those usernames and passwords.

The DDoS raised public awareness and concern about the lack of adequate security in IoT devices. Approximately three weeks later, two federal agencies—the Department of Homeland Security (DHS) and the National Institute of Standards and Technology (NIST), an agency in the Department of Commerce—released their guidance concerning security for IoT devices.

The DHS Guidance
On Nov. 15, 2016, DHS released its guidance on "Strategic Principles for Securing the Internet of Things," which set forth six nonbinding principles for addressing the security of IoT devices. The guidance was targeted toward stakeholders who "develop, manufacture, implement, or use network-connected devices."

Incorporate Security at the Design Phase: The guidance recommends that developers should build in security at the earliest phases of design and development. Some suggested practices include adopting unique, hard to crack default usernames and passwords; building the device using the most recent operating system; using hardware that already incorporates security features; and designing the device with system and operational disruptions in mind.

Promote Security Updates and Vulnerability Management: Even when security is included at the design stage, vulnerabilities in devices may still be discovered after they are employed. The guidance suggests that these vulnerabilities can be mitigated through patching, security updates and vulnerability management. Some suggested practices include securing devices over network connections or through automated means; coordinating software updates among third-party vendors; developing automated mechanisms for addressing vulnerabilities; developing a policy concerning the coordinated disclosure of vulnerabilities; and developing an end-of-life strategy for IoT devices.

Build on Recognized Security Practices: The guidance recommends applying many of the tested practices in traditional IT and network security to IoT devices. In particular, the guidance refers to the NIST Cybersecurity Risk Management Framework as a starting point for assessing risk and best practices. Referring to relevant sector-specific guidance, where it exists; employing a holistic approach to security; and participating in information sharing platforms are suggested practices.

Prioritize Security Measures According to Potential Impact: The guidance recommends focusing on the potential consequences of disruption, breach or malicious activity across the consumer spectrum to determine where security efforts should be directed. It suggests knowing a device's intended use and environment, performing a "red-team" exercise where developers attempt to bypass the device's security measures at different levels (i.e., application, network, data or physical); and identifying and authenticating the devices connected to the network.

Promote Transparency Across the IoT: The guidance recommends that developers and manufacturers need to know any vulnerabilities associated with the software and hardware components provided by their vendors outside their organization. Increased awareness could help manufacturers and industrial consumers know where and how to apply security measures or build in redundancies. Some suggested practices include inclusion of vendors and suppliers in the risk assessment process; creating a publicly-disclosed mechanism for using vulnerability reports, such as a Bug bounty program; and developing and employing a list of known hardware and software components in the device package.

Connect Carefully and Deliberately: The guidance notes that IoT consumers should consider whether continuous connectivity is necessary, given the use of the IoT device and risks associated with its disruption. It suggests that consumers be advised of the intended purpose of any network connection, and controls should be built into IoT devices to enable manufacturers, service providers and consumers to disable network connections or specific ports when it is desired to enable selective connectivity.

NIST's Guidance
On the same day as DHS released its principles for securing IoT devices, NIST released its own guidance in NIST Special Publication 800-160, Systems Security Engineering Considerations for a Multidisciplinary Approach in the Engineering of Trustworthy Secure Systems (NIST SP 800-160). NIST stated in NIST SP 800-160 that its objective to "address security issues" and "to use established engineering processes to ensure that needs, concerns, and requirements, are addressed with appropriate fidelity and vigor, early and in a sustainable manner."

NIST SP 800-160 recognizes that identifying all potential risks and/or preventing all breaches, disruptions or attacks are not realistic goals and, therefore, focuses on incorporating system security engineering (SSE) at all stages of the device's lifecycle (i.e., design, development, deployment, and maintenance) so as to make IoT devices less inherently vulnerable and more resilient and to limit the damage from the inevitable breaches, disruptions, and attacks. It starts with and builds upon a well-established international standards published by the International Organization for Standardization (ISO), the International Electrotechnical Commission (ICO) and the Institute of Electric and Electronic Engineering (IEEE). NIST SP 800-160 defines 30 different processes from initial business and mission analysis through the design and architecture stages, and outlines specific SSE activities and tasks for each process.

NIST SP 800-160 also outlines design principles for security spanning three areas: security architecture and design (i.e., organization, structure, interconnections and interfaces); security capability and intrinsic behaviors (i.e., what the protections are and how they are provided); and life cycle security (i.e., security process definition, conduct, and management). It further provides an overview of engineering and security fundamentals, covering subjects such as protection needs; security requirements and policy; distinguishing requirements, policy, and mechanisms; system security architecture, views and viewpoints; security relevance; security function protection criticality; trustworthiness and assurance; and cost, performance, and effectiveness.

Although the guidance released by DHS and NIST is nonbinding, companies should be mindful of it. Because this guidance has been approved and released by the federal government, there will likely be regulators and/or plaintiffs who refer to the guidance when attempting to impose liability on IoT developers and manufacturers following a breach or disruption. Failure to follow the guidance may be argued to be evidence of inadequate security and negligence. In addition, insurers may also refer to the guidance during the underwriting process for obtaining cyber insurance to ensure that IoT developers and manufacturers have an appropriate level of security. In effect, the guidance released by DHS and NIST may become a de facto standard of care. At a minimum, this guidance should be part of the conversation for the security of IoT devices.

Originally published in Legaltech News​ on January 19, 2017.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Events from this Firm
17 Oct 2017, Conference, California, United States

Women are a more powerful presence in business than ever, as entrepreneurs and corporate leaders. Join us for a half-day packed with real-worl​d know-how, firsthand experiences and an in-depth look at the entrepreneurial climate today – all designed to help entrepreneurial women take their businesses (and their careers) to the next level.​​

17 Oct 2017, Seminar, California, United States

Ivy Associates presents the annual All Hands Meeting in coordination with the Silicon Valley Association of General Counsel, an association of chief legal officers from more than one hundred leading technology and life science companies.​

17 Oct 2017, Seminar, California, United States

TEDx Wilmington is holding the first TEDx Salon dedicated to ideas worth spreading in transportation on Tuesday, October 17, 2017 in Wilmington, Delaware.

In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.