The Hitlist: Compliance
This post is focused on compliance and cyber security. What we mean is if your organization is attempting to become compliant to an industry standard or regulation, these are things that will have to be considered and more than likely implemented across the board for things such as PCI-DSS, HIPAA, ISO27k, FISMA and more. Here is a hitlist for things to consider when planning to meet a compliance standard:
1. Risk Assessment
How do you know what to protect if you don’t know where your risks are? A risk assessment will evaluate your biggest gaps and your biggest liabilities. This will allow your organization to focus its efforts where the most impact can be made quickly.
2. Data Classification
You need to know what your data is and where your data is. If only a small portion of your data contains sensitive information, then all of your data doesn’t need to be under the same scrutiny. You need to identify what the sensitive data is so that you can identify where that data is. Once you know where it resides, then you can put controls and processes in place to protect it. Additionally, it is essential to have policies and procedures in place so that all this information is documented.
3. Network Monitoring/Testing
Many compliance standards require annual penetration testing and vulnerability assessments. Additionally tools should be in place to monitor the network in real time: antivirus, intrusion detection/prevention (IDS/IPS), enterprise class firewalls, Data Loss Prevention (DLP). The extent of the required real-time monitoring will vary on the budget of the organization, the requirements of the compliance standard and the type of data being protected.
4. Data Encryption
Do you have sensitive data? It needs to be encrypted now. Whenever it moves (email, ftp, file shares) that communication needs to be encrypted. Whenever it’s at rest (USB drives, file shares, desktops, mobile devices) it needs to be encrypted, no exception. Industry standard, strong encryption is the only sure way to make sure that if portable media is lost or stolen, prying eyes can’t read the data.
5. User Training
Most standards require annual security training. It is also just a good practice for any organization. How many of your users can recognize a phishing email? How many users have their guard up for a phone call asking them to give up sensitive information? Users need to good reminders on basic security tenants.
Why lock your doors if the key is hanging on the wall? Not only to strong and unique passwords need to be enforced (this includes the C-suite), but 2 factor authentication needs to be strongly considered, especially for access to sensitive data. If 2 factor authentication is available, then the complexity requirements on passwords can drop a notch (that doesn’t mean 6 characters, no special characters). An ideal corporate authentication strategy for standard users would be 8-12 characters, numbers, letters, special characters, and a password history of at least 10 in addition to 2 factor authentication. For users with direct access to sensitive data or with technical administration roles the requirements should be stricter.
7. Separation of Duties
Have you ever seen the movie where they are about to launch the nuclear missiles and it requires a code and 2 keys? They do that so that no single person can launch a nuclear missile. The same is true for network administrative. Your network admins should be using their standard user accounts for performing administrative functions. They should have separate accounts used for remote access, email access, and workstation access from the accounts they use to manage the network. There are exceptions based on the magnitude of the operations (adding users, joining a computer to the domain, etc). I have seen too many organizations where a system administrator has a standard account that is a member of the most privileged groups in the domain and also uses that account for remote access.
8. Centralized Logging
This one isn’t a requirement for all standards, but it is for some and it is essential to know what is happening in your network. Centralized logging can allow you to find information about a security incident without having to go look through 15 different sources. Additionally, there are tools that allow an organization to add analytic and correlation to those logs that provides intelligence on top of the logs. What if you could know if a user account was attempting to log into your network from multiple cities or countries? This is how you can reduce the mean time of 87 days until discovery of a breach to just a few days.
9. Physical Security
If you have everything else buttoned up, but leave the back door open, it doesn’t matter. You need to be able to know when people come and go, you need to be able to see when people come and go, and you need to know where your assets are. Electronic key cards, video surveillance, and asset management are essential to a robust network security program.
You can theorize about how good you are, you can make educated guesses, and you can read a bunch of studies, but until you have a third party measure your compliance against your policies and your standards you won’t know. Most standards require for ‘periodic review,’ but put it this way, how will you ever know if you are compliant without having someone look?
Cross posted from http://www.securit360.com/blog where I was a regular author.