Learn why CCPA is important and how Cyber AI can assist, plus discover insights on data privacy and protection.
The California Consumer Privacy Act (CCPA) is the most comprehensive and significant data protection regulation enacted in the United States. Giving the strongest privacy rights to consumers, it entered its enforcement stage on July 1. While only directly applicable to Californian residents, the state’s position as the world’s fifth largest global economy has meant that corporations across the world have had to rethink their approach to data processing and privacy.
Customer protection and data privacy rights
At its core, the CCPA provides individuals foundational rights regarding their personal data including: the right to opt out of having their personal data sold, the right to erase personal data both from first party sites and companies it’s been sold to, and the right to know what personal information companies have gathered. For California residents who exercise these rights, the CCPA specifies a non-discrimination clause, meaning that everyone is privy to the same services and price, regardless of whether they allow organizations to sell their data or not.
Intended to enhance consumer protection and data privacy rights, the CCPA takes an even broader view than GDPR of what constitutes ‘private data’ and lays out a variety of requirements for the management and security of consumers’ personal information. So, what exactly is meant by ‘personal information’ according to the CCPA?
Obvious examples include a person’s name, postal address, and passport number. But political convictions, health and fitness profiles, sexual orientation, personality characteristics, employment history, and inferences also count – provided they are not already publicly available in the form of an interview or self-published article, for example. This snapshot of some of the sensitive information that has to be monitored reveals the immense task ahead of organizations, which now have to keep track of exactly what information is logged, deduced, and sold on each and every consumer. And with the average internet user spending 6.5 hours per day online, the vast volumes of data that organizations have to monitor is adding up.
The clock is ticking: in the event that someone does request access to a copy of their personal data or asks for its erasure, organizations must acknowledge their receipt of the customer’s communication within 10 days and respond with a meaningful answer within 45 calendar days.
Providing data transparency
The CCPA’s goal is to equip consumers with increased knowledge of what happens with their data. Instead of restricting the collection of sensitive information, it aims to provide data transparency and accountability, allowing consumers to see their digital footprint and forbid the selling of their personal information. This is a major differentiator from other data privacy laws such as GDPR, in which European citizens actively have to consent to having their data collected in the first place. With the CCPA, data is always collected by first party sites – it is how that information is used, individuals’ right to view that data, and the erasure of that data which is the law’s central concern.
The consequences
If organizations fail to comply with the CCPA’s requirements, steep penalties will ensue, with additional fines able to be issued in the event of a data breach. While this act does not impose cyber security regulations, the California Attorney General can stipulate digital hygiene guidelines, with organizations liable for inadequate security procedures and practices which are disproportionate to the data under their care.
Each consumer can claim up to $750 per data breach – or the actual damages, whichever is greater. Meanwhile, the state can charge up to $7500 per person, per violation, if an organization’s conduct is deemed intentional. This quickly becomes expensive. Most significantly though, the regulation introduces the right for consumers to bring data privacy issues to court, where they can seek financial redress. This is conditional upon unauthorized access to their personal information resulting from businesses’ failure to implement reasonable security practices and procedures appropriate for the particular type of information.
The three central tenets of this law present minefields for organizations. Keeping track of large volumes of data at an individual level is necessary in order to fulfil these requirements. In the face of companies’ growing digital infrastructures, including recent surges in cloud, SaaS, and email usage, the potentially dispersed storage of sensitive information, and the increasing risk of cyber-attack, CCPA compliance has become an even more daunting task.
How can AI help?
Darktrace’s Cyber AI helps support CCPA compliance by providing 100% visibility into the movement of data throughout an organization’s digital infrastructure, including noting who accesses it. By using self-learning AI to learn the ‘pattern of life’ of every user across cloud, SaaS, email, and traditional networks, Darktrace’s Cyber AI can automatically alert security teams of threats in real time and take autonomous action when an access policy is breached. And while the California Attorney General gives businesses a 30-day period to assess and remediate alleged violations of the CCPA, Cyber AI provides real-time understanding of cyber incidents, including data exfiltration, which enables businesses to not only meet this CCPA requirement, but to limit the impact of emerging threats.
For organizations to comply with this regulation, they need to be constantly aware of all activity involving sensitive consumer data. The Model Editor within the Threat Visualizer, Darktrace’s user interface, provides security teams with the ability to track specific parameters for this targeted, continuous monitoring. Darktrace offers customizable compliance models for customers to specifically watch over and safeguard user data as stipulated by the CCPA. A tag can be added to devices, stating that they contain personal data protected under the CCPA. This means that when an external or internal data transfer is instigated on the given device, it will immediately be flagged to organizations’ security teams. The same happens in the event of any unusual activity.
Figure 1: CCPA tag in the Threat Visualizer
The reality is that organizations’ digital environments – and the consumer data stored within them – are too extensive to manage, keep track of, and protect without Cyber AI. And with California set to vote on the implementation of even stricter privacy regulations in the coming months, organizations will need complete digital visibility and the ability to easily identify and fight back against emerging threats in order to keep pace with changing requirements. Cyber AI is no longer a nice-to-have, but a necessity.
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Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Bytesize Security: Insider Threats in Google Workspace
What is an insider threat?
An insider threat is a cyber risk originating from within an organization. These threats can involve actions such as an employee inadvertently clicking on a malicious link (e.g., a phishing email) or an employee with malicious intent conducting data exfiltration for corporate sabotage.
Insiders often exploit their knowledge and access to legitimate corporate tools, presenting a continuous risk to organizations. Defenders must protect their digital estate against threats from both within and outside the organization.
For example, in the summer of 2024, Darktrace / IDENTITY successfully detected a user in a customer environment attempting to steal sensitive data from a trusted Google Workspace service. Despite the use of a legitimate and compliant corporate tool, Darktrace identified anomalies in the user’s behavior that indicated malicious intent.
Attack overview: Insider threat
In June 2024, Darktrace detected unusual activity involving the Software-as-a-Service (SaaS) account of a former employee from a customer organization. This individual, who had recently left the company, was observed downloading a significant amount of data in the form of a “.INDD” file (an Adobe InDesign document typically used to create page layouts [1]) from Google Drive.
While the use of Google Drive and other Google Workspace platforms was not unexpected for this employee, Darktrace identified that the user had logged in from an unfamiliar and suspicious IPv6 address before initiating the download. This anomaly triggered a model alert in Darktrace / IDENTITY, flagging the activity as potentially malicious.
Figure 1: A Model Alert in Darktrace / IDENTITY showing the unusual “.INDD” file being downloaded from Google Workspace.
Following this detection, the customer reached out to Darktrace’s Security Operations Center (SOC) team via the Security Operations Support service for assistance in triaging and investigating the incident further. Darktrace’s SOC team conducted an in-depth investigation, enabling the customer to identify the exact moment of the file download, as well as the contents of the stolen documents. The customer later confirmed that the downloaded files contained sensitive corporate data, including customer details and payment information, likely intended for reuse or sharing with a new employer.
In this particular instance, Darktrace’s Autonomous Response capability was not active, allowing the malicious insider to successfully exfiltrate the files. If Autonomous Response had been enabled, Darktrace would have immediately acted upon detecting the login from an unusual (in this case 100% rare) location by logging out and disabling the SaaS user. This would have provided the customer with the necessary time to review the activity and verify whether the user was authorized to access their SaaS environments.
Conclusion
Insider threats pose a significant challenge for traditional security tools as they involve internal users who are expected to access SaaS platforms. These insiders have preexisting knowledge of the environment, sensitive data, and how to make their activities appear normal, as seen in this case with the use of Google Workspace. This familiarity allows them to avoid having to use more easily detectable intrusion methods like phishing campaigns.
Darktrace’s anomaly detection capabilities, which focus on identifying unusual activity rather than relying on specific rules and signatures, enable it to effectively detect deviations from a user’s expected behavior. For instance, an unusual login from a new location, as in this example, can be flagged even if the subsequent malicious activity appears innocuous due to the use of a trusted application like Google Drive.
Credit to Vivek Rajan (Cyber Analyst) and Ryan Traill (Analyst Content Lead)
Appendices
Darktrace Model Detections
SaaS / Resource::Unusual Download Of Externally Shared Google Workspace File
RansomHub Ransomware: Darktrace’s Investigation of the Newest Tool in ShadowSyndicate's Arsenal
What is ShadowSyndicate?
ShadowSyndicate, also known as Infra Storm, is a threat actor reportedly active since July 2022, working with various ransomware groups and affiliates of ransomware programs, such as Quantum, Nokoyawa, and ALPHV. This threat actor employs tools like Cobalt Strike, Sliver, IcedID, and Matanbuchus malware in its attacks. ShadowSyndicate utilizes the same SSH fingerprint (1ca4cbac895fc3bd12417b77fc6ed31d) on many of their servers—85 as of September 2023. At least 52 of these servers have been linked to the Cobalt Strike command and control (C2) framework [1].
What is RansomHub?
First observed following the FBI's takedown of ALPHV/BlackCat in December 2023, RansomHub quickly gained notoriety as a Ransomware-as-a-Service (RaaS) operator. RansomHub capitalized on the law enforcement’s disruption of the LockBit group’s operations in February 2024 to market themselves to potential affiliates who had previously relied on LockBit’s encryptors. RansomHub's success can be largely attributed to their aggressive recruitment on underground forums, leading to the absorption of ex-ALPHV and ex-LockBit affiliates. They were one of the most active ransomware operators in 2024, with approximately 500 victims reported since February, according to their Dedicated Leak Site (DLS) [2].
ShadowSyndicate and RansomHub
External researchers have reported that ShadowSyndicate had as many as seven different ransomware families in their arsenal between July 2022, and September 2023. Now, ShadowSyndicate appears to have added RansomHub’s their formidable stockpile, becoming an affiliate of the RaaS provider [1].
Darktrace’s analysis of ShadowSyndicate across its customer base indicates that the group has been leveraging RansomHub ransomware in multiple attacks in September and October 2024. ShadowSyndicate likely shifted to using RansomHub due to the lucrative rates offered by this RaaS provider, with affiliates receiving up to 90% of the ransom—significantly higher than the general market rate of 70-80% [3].
In many instances where encryption was observed, ransom notes with the naming pattern “README_[a-zA-Z0-9]{6}.txt” were written to affected devices. The content of these ransom notes threatened to release stolen confidential data via RansomHub’s DLS unless a ransom was paid. During these attacks, data exfiltration activity to external endpoints using the SSH protocol was observed. The external endpoints to which the data was transferred were found to coincide with servers previously associated with ShadowSyndicate activity.
Darktrace’s coverage of ShadowSyndicate and RansomHub
Darktrace’s Threat Research team identified high-confidence indicators of compromise (IoCs) linked to the ShadowSyndicate group deploying RansomHub. The investigation revealed four separate incidents impacting Darktrace customers across various sectors, including education, manufacturing, and social services. In the investigated cases, multiple stages of the kill chain were observed, starting with initial internal reconnaissance and leading to eventual file encryption and data exfiltration.
Attack Overview
Internal Reconnaissance
The first observed stage of ShadowSyndicate attacks involved devices making multiple internal connection attempts to other internal devices over key ports, suggesting network scanning and enumeration activity. In this initial phase of the attack, the threat actor gathers critical details and information by scanning the network for open ports that might be potentially exploitable. In cases observed by Darktrace affected devices were typically seen attempting to connect to other internal locations over TCP ports including 22, 445 and 3389.
C2 Communication and Data Exfiltration
In most of the RansomHub cases investigated by Darktrace, unusual connections to endpoints associated with Splashtop, a remote desktop access software, were observed briefly before outbound SSH connections were identified.
Following this, Darktrace detected outbound SSH connections to the external IP address 46.161.27[.]151 using WinSCP, an open-source SSH client for Windows used for secure file transfer. The Cybersecurity and Infrastructure Security Agency (CISA) identified this IP address as malicious and associated it with ShadowSyndicate’s C2 infrastructure [4]. During connections to this IP, multiple gigabytes of data were exfiltrated from customer networks via SSH.
Data exfiltration attempts were consistent across investigated cases; however, the method of egress varied from one attack to another, as one would expect with a RaaS strain being employed by different affiliates. In addition to transfers to ShadowSyndicate’s infrastructure, threat actors were also observed transferring data to the cloud storage and file transfer service, MEGA, via HTTP connections using the ‘rclone’ user agent – a command-line program used to manage files on cloud storage. In another case, data exfiltration activity occurred over port 443, utilizing SSL connections.
Lateral Movement
In investigated incidents, lateral movement activity began shortly after C2 communications were established. In one case, Darktrace identified the unusual use of a new administrative credential which was quickly followed up with multiple suspicious executable file writes to other internal devices on the network.
The filenames for this executable followed the regex naming convention “[a-zA-Z]{6}.exe”, with two observed examples being “bWqQUx.exe” and “sdtMfs.exe”.
Figure 1: Cyber AI Analyst Investigation Process for the SMB Writes of Suspicious Files to Multiple Devices' incident.
Additionally, script files such as “Defeat-Defender2.bat”, “Share.bat”, and “def.bat” were also seen written over SMB, suggesting that threat actors were trying to evade network defenses and detection by antivirus software like Microsoft Defender.
File Encryption
Among the three cases where file encryption activity was observed, file names were changed by adding an extension following the regex format “.[a-zA-Z0-9]{6}”. Ransom notes with a similar naming convention, “README_[a-zA-Z0-9]{6}.txt”, were written to each share. While the content of the ransom notes differed slightly in each case, most contained similar text. Clear indicators in the body of the ransom notes pointed to the use of RansomHub ransomware in these attacks. As is increasingly the case, threat actors employed double extortion tactics, threatening to leak confidential data if the ransom was not paid. Like most ransomware, RansomHub included TOR site links for communication between its "customer service team" and the target.
Figure 2: The graph shows the behavior of a device with encryption activity, using the “SMB Sustained Mimetype Conversion” and “Unusual Activity Events” metrics over three weeks.
Since Darktrace’s Autonomous Response capability was not enabled during the compromise, the ransomware attack succeeded in its objective. However, Darktrace’s Cyber AI Analyst provided comprehensive coverage of the kill chain, enabling the customer to quickly identify affected devices and initiate remediation.
Figure 3: Cyber AI Analyst panel showing the critical incidents of the affected device from one of the cases investigated.
In lieu of Autonomous Response being active on the networks, Darktrace was able to suggest a variety of manual response actions intended to contain the compromise and prevent further malicious activity. Had Autonomous Response been enabled at the time of the attack, these actions would have been quickly applied without any human interaction, potentially halting the ransomware attack earlier in the kill chain.
Figure 4: A list of suggested Autonomous Response actions on the affected devices."
Conclusion
The Darktrace Threat Research team has noted a surge in attacks by the ShadowSyndicate group using RansomHub’s RaaS of late. RaaS has become increasingly popular across the threat landscape due to its ease of access to malware and script execution. As more individual threat actors adopt RaaS, security teams are struggling to defend against the increasing number of opportunistic attacks.
For customers subscribed to Darktrace’s Security Operations Center (SOC) services, the Analyst team promptly investigated detections of the aforementioned unusual and anomalous activities in the initial infection phases. Multiple alerts were raised via Darktrace’s Managed Threat Detection to warn customers of active ransomware incidents. By emphasizing anomaly-based detection and response, Darktrace can effectively identify devices affected by ransomware and take action against emerging activity, minimizing disruption and impact on customer networks.
Credit to Kwa Qing Hong (Senior Cyber Analyst and Deputy Analyst Team Lead, Singapore) and Signe Zahark (Principal Cyber Analyst, Japan)