Information Assurance in a Global Context:Strategies for Security and Privacy for Cross-Border and
Multi-national Organizations
Matt Stamper, MPIA, MS, CISA, ITIL
VP of Services: redIT
President: ISACA San Diego Chapter
Co-Chair: InfraGard San Diego
Board of Advisors: Multiple
WCIT
Guadalajara, Jalisco
September 28th, 2014
Agenda Why information assurance (IA) matters
Core Definitions: ILM, Security, Privacy, and IA
Regulatory Requirements
Frameworks & Approaches
New Technologies: IoT & Cloud
Lessons from Tijuana/San Diego
Questions & Comments
PAGE 3
Why Information Assurance Matters…
We rarely question the quality of information we use to make
decisions…putting our organizations, economies, and personal lives at
risk
Information is the most valuable asset in our economy and fuels
innovation & growth (data is the raw material of the global economy)
o Commerce
o Science
o Government
Our dependencies on accurate and timely information are increasing
exponentially
Massive asymmetries in IA practices
Gap between laws & regulations and practice
Critically, trust is at risk!
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Trust and Societies: Quantifiable Impact
“If you take a broad enough definition of trust, then it would explain basically all the difference between the per capita income of the United States and Somalia,” ventures Steve Knack, a senior economist at the World Bank who has been studying the economics of trust for over a decade. That suggests that trust is worth $12.4 trillion dollars a year to the U.S., which, in case you are wondering, is 99.5% of this country’s income (2006 figures). If you make $40,000 a year, then $200 is down to hard work and $39,800 is down to trust” (http://www.forbes.com/2006/09/22/trust-economy-markets-tech_cx_th_06trust_0925harford.html)
Trust is essential to maintaining the social and economic benefits that networked technologies bring to the United States and the rest of the world” (Consumer Data Privacy in a Networked World: A Framework for Protecting Privacy and Promoting Innovation in the Global Digital Economy, February, 2012: White House)
Trust is at the heart of today’s complex global economy. But, paradoxically, trust is also in increasingly short supply in many of our societies, especially in our attitudes towards big business, parliaments and governments. This decline threatens our capacity to tackle some of today’s key challenges (http://www.oecd.org/forum/the-cost-of-mistrust.htm)
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The Impact of Lost Trust on Society
Financial Crisis
http://www.youtube.com/watch?v=uw_Tgu0txS0
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International Data Flows: The Global Currency
“The Growth of the Internet and the ability to move data rapidly and globally has been a key building block of the global economic order” (The Internet, Cross-Border Data Flows and International Trade, Joshua Meltzer, The Brookings Institute, February, 2013)
“Exports (emphasis mine) of cloud computing services were estimated to be worth approximately $1.5b in 2010 (and this is likely a conservative figure and the market for cloud computing services is anticipated to grow by up to 600 percent by 2015” (Policy Challenges of Cross-Border Computing” – Journal of International Commerce and Economics, November 2012).
Over 2 Billion Individual have access to the Internet
More devices will be connected than people – billions of devices
Nearly free transaction costs
The days of information arbitrage are over
Barriers to innovation & exploitation are equally low
Critical Shared Data Sets
Weather & Climate data
Census data
Healthcare and Disease Control data
Financial & Currency data
Trade data
A McKinsey Global Institute study estimated that the Internet contributed over 10 percent to GDP growth in the last five years to the world’s top ten economies and for every job lost as a result of the Internet, 2.6 jobs have been created.
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Open Government Initiatives: Public Sector Data
Governments across the globe recognize that information is both:
A national resource that requires protection
A public good that should be readily disseminated
Key areas of focus within the Open Government community include:
Transparency with budgets & procurement
Private/Public Sector data sharing
Innovation
“The original and essentially libertarian nature of the Internet is increasingly being challenged by
assertions by government of jurisdiction over the Internet or the development of rules that restrict
the ability of individuals and companies to access the Internet and move data across borders” (The
Internet, Cross-Border Data Flows and International Trade, Joshua Meltzer, The Brookings Institute,
February, 2013)
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Why Information Assurance is Critical Now!
Here’s just a quick sampling of what’s occurring on a daily basis. This is just the US public sector.
Organized Criminals in Russia Steal 1b Passwords (8/5/2014)
http://www.nytimes.com/2014/08/06/technology/russian-gang-said-to-amass-more-than-a-billion-stolen-internet-credentials.html?_r=0
JP Morgan Potentially Compromised (8/18/2014)
http://online.wsj.com/articles/fbi-probes-possible-computer-hacking-incident-at-j-p-morgan-1409168480
Hospital Hacked – 4.5 Million Records Compromised (8/18/2014)
http://money.cnn.com/2014/08/18/technology/security/hospital-chs-hack/
Home Depot
http://www.forbes.com/sites/quickerbettertech/2014/09/22/why-the-home-depot-breach-is-worse-than-you-think/
Target
http://online.wsj.com/news/articles/SB10001424052702304773104579266743230242538
The Car (2014 Moving Forward)
http://money.cnn.com/2014/06/01/technology/security/car-hack/
PAGE 9
The Assault on Healthcare & ePHI
According to a Ponemon Institute Study, criminal attacks on healthcare systems
have risen 100% since 2010 with an average cost of a breach is $2m (US)
Over 90% of healthcare organizations have had a breach in the last two years with
38% having had more than five incidents (down from 45% the previous year)
Risks with mandated health information exchanges (third-party considerations) /
weakest link despite security standards from HIPAA-HITECH
Bring Your Own Device (BYOD) - nearly 50% of breaches attributed to a lost or
stolen device and over 88% of organizations allow the use of BYOD
Fortunately, the number of records compromised has decreased based on earlier
detection and incident response – we’re getting better at handling security
breaches…practices makes perfect?
Working Definitions
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Security - Defined
The easiest way to think about security is to think about the outcome of what good
security provides: confidentiality, integrity, and availability of information (CIA).
Confidentiality is the end-state of ensuring that information is only viewed and
acted upon by those individuals, organizations, or systems that are authorized to
see such information. “A loss of confidentiality is the unauthorized disclosure of
information” – FIPS 199.
Integrity is the end-state of information and its processing such that the
information is believed to be complete, accurate, valid and subject to restricted
access (CAVR)…essentially un tampered with or otherwise modified by
unauthorized activity. “A loss of integrity is the unauthorized modification or
destruction of information” – FIPS 199.
Availability is simply that…that the information is available for its required use
without delay or loss. “A loss of availability is the disruption of access to or use of
information or an information system” – FIPS 199.
Collectively, IT security is the set of processes that are involved with ensuring that
data and information meet the confidentiality, integrity, and availability objectives of
business.
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Privacy - Defined
Definitions of privacy are growing more nuanced over time.
Privacy is “the right to be left alone” (Samual Warren & Louis Brandeis: The Right to
Privacy, Harvard Law Review, 1890).
Privacy is “the right of the individual to be protected against the intrusion into his
(her) personal life or affairs, or those of his (her) family, by direct physical means or by
publication of information” (UK, Calcutt Committee: 1997)
Privacy has contextual considerations:
Information Privacy
Bodily Privacy
Territorial / Physical Privacy
Communications Privacy (Foundations of Information Privacy and Data Protection, Swire, et. al., IAPP, 2012)
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Information Assurance: Three Perspectives
National Defense: Information Assurance as a concept is strongly influenced by the defense and national security communities and the concept of network centric warfare techniques:
“Measures that protect and defend information systems by ensuring their availability, integrity, authentication, confidentiality, and non-repudiation. This includes providing for restoration of information systems by incorporating protection, detection, and reaction capabilities” (Department of Defense Directive Number 8500.1: October 24, 2002)
Corporate View: Intellectual Property, Financial, Client & Partner Data, is subject to appropriate governance & controlled – CAVR.
Consumer View: Personal Health, Financial and other UII Data is controlled by the individual and disclosure is also controlled by the individual.
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Data Classification
Given the regulatory and jurisdictional issues related to information and data flows, organizations need to implement best practices to classify their data. There are a number of approaches including:
National Security
• Top Secret
• Classified
• Unclassified:FOUO
Corporate Security
Confidential
Proprietary
Privileged / Restricted Access
Personal Data
• ePHI
• Financial Information
• Phone, Internet & Utility
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Information Lifecycle & IA
Tech Target: http://searchdatamanagement.techtarget.com/feature/Information-assurance-Dependability-and-security-of-networked-information-systems
Cloud Security Alliance
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Bringing It All Together: IA, Security, and Privacy
If we agree that information is the new global currency and that innovation and growth
are predicated on the quality of the information and data we use, it’s important that
we couple IA, Security and Privacy and make information governance a top priority for
our organizations.
Let’s get to work!
Privacy Laws & StandardsBy Country / Region
• Mexico
• Canada
• US
• EU
• APEC
By Industry
HIPAA-HITECH
Financial Services
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Laws & Regulations: Mexico, Canada and US
Mexico – National Privacy Law
http://www.diputados.gob.mx/LeyesBiblio/pdf/LFPDPPP.pdf
Canada – National Privacy Law
https://www.priv.gc.ca/index_e.asp
https://www.priv.gc.ca/leg_c/leg_c_p_e.asp
US – Sectoral Approach (Federal Trade Commission)
http://www.whitehouse.gov/sites/default/files/privacy-final.pdf
States
Massachusetts - http://www.mass.gov/ocabr/docs/idtheft/201cmr1700reg.pdf
California - http://oag.ca.gov/ecrime/databreach/reporting
Nevada - http://www.leg.state.nv.us/NRS/NRS-603A.html
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Laws & Regulations: Australia, APEC & Europe (EU)
Australia
http://www.oaic.gov.au/privacy/privacy-act/the-privacy-act
http://www.oaic.gov.au/privacy/privacy-resources/privacy-fact-sheets/other/privacy-fact-sheet-17-australian-privacy-principles
APEC
http://www.apec.org/About-Us/About-APEC/Fact-Sheets/APEC-Privacy-Framework.aspx
European Union
http://europa.eu/about-eu/countries/member-countries/index_en.htm
http://ec.europa.eu/dataprotectionofficer/legal_framework_en.htm
https://safeharbor.export.gov/list.aspx (Safe Harbor Registrants)
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Privacy & Security – Inextricably Linked
Security can exist without privacy but privacy
cannot exist without security. Consequently,
privacy frameworks offer insights into good
governance and security practices though many
standards and frameworks have been challenged
by recent events – notably the Payment Card
Industry – Data Security Standard (PCI-DSS).
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International Privacy Regimes: APEC & OECD
APEC - 2004 OECD - 1980
Preventing Harm Collection Limitation Principle
Notice Data Quality Principle
Collection Limitation Purpose Specification Principle
Uses of Personal Information Use Limitation Principle
Choice Security Safeguards Principle
Integrity of Personal Information Openness Principle
Security Safeguards Individual Participation Principle
Access and Correction Accountability
Accountability
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International Privacy (Cont.): FIPS & Madrid
FIPS (1973) Madrid Resolution (2009)
No Secret Repositories Principle of Lawfulness & Fairness
Individual Control Over Use Purpose Specification Principle
Individual Consent Proportionality Principle
Correction Data Quality
Precautions Against Misuse Openness Principle
Accountability
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HIPAA-HITECT: Administrative, Physical & Technical
Security Management Process 164.308(a)(1)
Risk AnalysisRisk ManagementSystem Review
Assigned Security Responsibility 164.308(a)(2)
Accountability
Workforce Security164.308(a)(3)
Authorization and/orSupervision, Clearance & TerminationProcedures
Information Access Management164.308(a)(4)
RBAC Procedures
Security Awareness and Training164.308(a)(5)
Anti-malware, log-in procedures, password management
Security Incident Procedures164.308(a)(6)
Incident Response Procedures
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HIPAA-HITECT: Administrative, Physical & Technical
Contingency Plan164.308(a)(7)
Backup & RecoveryBC/DR Procedures & Testing Applications and Data Criticality Analysis
Evaluation164.308(a)(8)
Review of Systems
Business Associate Contracts andOther Arrangements164.308(b)(1)
Contractual Obligations with Service Providers (Business Associates)Cascading Liability
Facility Access Controls164.310(a)(1)
Access Controls, Maintenance of Records,Contingency Operations
Access Control164.312(a)(1)
Encryption, Decryption, Log-off, Emergency Access*
Audit Controls164.312(b)
Evidence of Review
Transmission Integrity Controls (A)Security 164.312(e)(1)
Security and Integrity
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Gramm-Leach-Bliley (GLB) – FTC Enforcement
Financial Services Firms have an obligation to safeguard non-public information (NPI)
such as full account numbers, social security numbers (SSNs), etc.
Obligations:
Privacy Notices
Non-Affiliated Third Parties & Opt Out
Ensure the Security & Confidentiality of Customer Records
Protect Against Anticipated Threats or Hazards
Protect Against Unauthorized Access
The FTC has established a clear expectation of security as a corporate
obligation.
Security Frameworks Security Frameworks & Standards
• SANS 20
• PCI-DSS
• ISO 27001/27002
• Cloud Security Alliance
• COBIT (ISACA)
PAGE 27
SANS Top 20 Security Controls
The SANS Top 20 is considered a good set of minimum necessary security controls. The controls cover a broad suite of good control activity:
Critical Control 1: Inventory of Authorized and Unauthorized Devices
Critical Control 2: Inventory of Authorized and Unauthorized Software
Critical Control 3: Secure Configurations for Hardware and Software on Mobile Devices, Laptops, Workstations, and Servers
Critical Control 4: Continuous Vulnerability Assessment and Remediation
Critical Control 5: Malware Defenses
Critical Control 6: Application Software Security
Critical Control 7: Wireless Device Control
Critical Control 8: Data Recovery Capability
Critical Control 9: Security Skills Assessment and Appropriate Training to Fill Gaps
Critical Control 10: Secure Configurations for Network Devices such as Firewalls, Routers, and Switches
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SANS Top 20 Security Controls
The SANS Top 20 is considered a good set of minimum necessary security controls.
The controls cover a broad suite of good control activity:
Critical Control 11: Limitation and Control of Network Ports, Protocols, and
Services
Critical Control 12: Controlled Use of Administrative Privileges
Critical Control 13: Boundary Defense
Critical Control 14: Maintenance, Monitoring, and Analysis of Audit Logs
Critical Control 15: Controlled Access Based on the Need to Know
Critical Control 16: Account Monitoring and Control
Critical Control 17: Data Loss Prevention
Critical Control 18: Incident Response and Management
Critical Control 19: Secure Network Engineering
Critical Control 20: Penetration Tests and Red Team Exercises
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PCI-DSS: 3.0 – 12 Requirements
Requirement 1: Install and maintain a firewall configuration to protect cardholder
data
Requirement 2: Do not use vendor-supplied defaults for system passwords and
other security parameters
Requirement 3: Protect stored cardholder data
Requirement 4: Encrypt transmission of cardholder data across open, public
networks
Requirement 5: Protect all systems against malware and regularly update anti-
virus software or programs
Requirement 6: Develop and maintain secure systems and applications
https://www.pcisecuritystandards.org/documents/PCI_DSS_v3.pdf
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PCI-DSS: 3.0 – 12 Requirements
Requirement 7: Restrict access to cardholder data by business need to know
Requirement 8: Identify and authenticate access to system components
Requirement 9: Restrict physical access to cardholder data
Requirement 10: Track and monitor all access to network resources and
cardholder data
Requirement 11: Regularly test security systems and processes.
Requirement 12: Maintain a policy that addresses information security for all
personnel.
Requirement A.1: Shared hosting providers must protect the cardholder data
environment
https://www.pcisecuritystandards.org/documents/PCI_DSS_v3.pdf
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ISO:27001, CSA & ISACA
There are three organizations that are driving good security standards and practices in
particular that should be part of an organization’s control design:
International Standards Organization (ISO)
http://www.iso.org/iso/home/standards/management-standards/iso27001.htm
Cloud Security Alliance (CSA)
https://cloudsecurityalliance.org/
Information Systems Audit and Control Association (ISACA)
https://www.isaca.org/Pages/default.aspx
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COBIT – Cloud Governance
ISACA’s “IT Control Objectives for Cloud Computing: Controls and Assurance in the Cloud” provides a solid framework for assessing controls in cloud environments and a reference for good governance.
“ISACA defines governance as the set of responsibilities and practices exercised by the board and executive management with the goal of providing strategic direction, ensuring that objectives are achieved and ascertaining that risks are managed appropriately.”
Leveraging cloud services requires controls and governance that touch upon the following:
Plan and Organize (PO) Acquire and Implement (AI)
Deliver & Support (DS) Monitor & Evaluate (ME)
Technology and IAInternet of Things (IoT)
Cloud Computing
PAGE 34
Internet of Things
http://www.theregister.co.uk/2014/05/07/freescale_internet_of_things/
PAGE 35
On Site
Applications
Database
O/S
Hypervisors
Servers
Storage
Networks
Backups
Infrastructure(as a Service)
Applications
Database
O/S
Hypervisors
Servers
Storage
Networks
Backups
Platform(as a Service)
Applications
Database
O/S
Hypervisors
Servers
Storage
Networks
Backups
Software(as a Service)
Applications
Database
O/S
Hypervisors
Servers
Storage
Networks
Backups
Service Demarcation & Information Assurance
Roles & Responsibilities are Crucial Regardless of the Service Model
Security, Monitoring & Governance: Critical Foundation
PAGE 36
Application
Database
OS
Hypervisors
Servers
Storage
Network
Backups
Application
SE
CU
RI
TY
MO
NI
TO
RI
NG
ITIL
/S
ER
VIC
E M
AN
GE
ME
NT
• Audit Trail• Client • SaaS
• Segregation of Duties • What is logged?• Who’s responsible for
the application is based on the service model
• How is the application impacted by other layers?
• What information is shared among layers?
• Shared administrative accounts?D a t a C e n t e r
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Cloud Layers – Application Risk
Applications probably offer the widest array of risks to
organizations. One of the key reasons…think about who uses
applications…it’s us.
Applications – Typical Risks:
Human error / social networking exposure / APT attacks
Segregation of duties / elevated privileges
Database linkages / poor data validation
Session-hacking, man-in-the-middle attacks, cross-site scripting
Poor application coding
Poor passwords (complexity/aging)
Poor logging habits
Many firewalls are not application aware (just ports 80, 443)
Other considerations?
PAGE 38
Database
Database
OS
Hypervisors
Servers
Storage
Network
Backups
Application
SE
CU
RI
TY
MO
NI
TO
RI
NG
ITIL
/S
ER
VIC
E M
AN
GE
ME
NT
• Database activity monitoring
• Time-stamping transactions / logs
• Memory-based databases…data living in memory
• HADOOP and other changing non-database approaches to analytics
D a t a C e n t e r
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Service Provider Considerations
Contracts Matter – Wrap Around Agreements Present Risks to Organizations
Right to audit clause
Data location covenants
Compliance Reviews:
SSAE 16 SOC 1
ISAE 3402
SOC 2
Roles & Responsibilities
Statements of Work
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Common Themes
• Inventory of Information
• Inventory of Critical Assets
• Supply-Chain / Vendor assessments
• Risk Assessments
• Security Assessments
• Board of Directors
• Executive Responsibility
• Investment in Training & Competencies
PAGE 41
Tijuana – San Diego (Our IA Ecosystem)
Brier & Thorn – SOC in Tijuana
http://brierandthorn.com/
BridgeSTOR – Cloud Data Encryption
http://bridgestor.com/
CyberFlow Analytics – APT Solution
http://www.cyberflowanalytics.com/
CyberTECH & CyberHive
http://cybertechnetwork.org/
http://cyberhivesandiego.org/cybertech/
InfraGard
http://www.infragardsd.org/
ISACA – SD
http://isaca-sd.org/
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Quick Wins
Information Assurance begins with:
• Know Legal Obligations
• Data Classification
• Data Inventory
• Data Retention
• Privacy Impact Assessment
• Security / Vulnerability Assessment
• Keep The Board Informed – No Surprises
• Assume a Breach!
PAGE 43
References
Privacy
https://www.privacyrights.org/data-breach/new
http://www.hhs.gov/ocr/privacy/hipaa/administrative/breachnotificationrule/breachtool.html
https://www.enisa.europa.eu/activities/identity-and-trust/risks-and-data-breaches/dbn
Security
https://www.isaca.org
http://www.sans.org/
http://www.nist.gov/cybersecurity-portal.cfm
https://cloudsecurityalliance.org/
us.redit.com
Matt Stamper, MPIA, MS, CISA, ITIL (CIPP-US: Pending)
T 858.836.02224
M 760.809.2164