Showing posts with label compliance. Show all posts
Showing posts with label compliance. Show all posts

Tuesday, January 29

Virtual Directory as Database Security

I've written plenty of posts about the various use-cases for virtual directory technology over the years. But, I came across another today that I thought was pretty interesting.

Think about enterprise security from the viewpoint of the CISO. There are numerous layers of overlapping security technologies that work together to reduce risk to a point that's comfortable. Network security, endpoint security, identity management, encryption, DLP, SIEM, etc. But even when these solutions are implemented according to plan, I still see two common gaps that need to be taken more seriously.

One is control over unstructured data (file systems, SharePoint, etc.). The other is back door access to application databases. There is a ton of sensitive information exposed through those two avenues that aren't protected by the likes of SIEM solutions or IAM suites. Even DLP solutions tend to focus on perimeter defense rather than who has access. STEALTHbits has solutions to fill the gaps for unstructured data and for Microsoft SQL Server so I spend a fair amount of time talking to CISOs and their teams about these issues.

While reading through some IAM industry materials today, I found an interesting write-up on how Oracle is using its virtual directory technology to solve the problem for Oracle database customers. Oracle's IAM suite leverages Oracle Virtual Directory (OVD) as an integration point with an Oracle database feature called Enterprise User Security (EUS). EUS enables database access management through an enterprise LDAP directory (as opposed to managing a spaghetti mapping of users to database accounts and the associated permissions.)

By placing OVD in front of EUS, you get instant LDAP-style management (and IAM integration) without a long, complicated migration process. Pretty compelling use-case. If you can't control direct database permissions, your application-side access controls seem less important. Essentially, you've locked the front door but left the back window wide open. Something to think about.

Thursday, May 10

Access Governance on Unstructured Data

Gartner research VP Earl Perkins posted a few days ago on the intersection of data and applications within IAG (Identity and Access Governance). I've certainly seen the same issues and we've been working with customers on these challenges quite a bit over the past six months. In fact, I authored a paper on the topic in April which is available in the STEALTHbits resource library titled Access Governance on Unstructured Data.

I hinted at the paper back in February and it was clear from the response I got that many are not willing to acknowledge a shift from the era of Identity Management to the era of Access Governance. But, I still see our current Access Governance efforts (as an industry) as analogous to what we did about a decade ago for Identity Management. Obviously, the industry remains dynamic and there's overlap but I think we have a pretty good handle on managing accounts while we're still working on the best ways to provide governance over access (whether to applications or data).

In my own phrasing (and ignoring structured and semi-structured data for the moment), the issue Earl addresses is, essentially that traditional IAM and IAG solutions are application-centric but a significant portion of enterprise data is unstructured (many estimates indicate that 80% of data is unstructured) rather than accessed and controlled via applications. IAG vendors are struggling with getting their arms around data as it sits out in the environment. And it's a hard problem.

I've been a part of two software vendors who addressed access rights to unstructured data. Neither company nailed it in the first attempt and there were challenges along the way. I've spoken with three large companies who tried to build in-house solutions for themselves. All failed and eventually sought commercial solutions. And I've spoken to IAG vendors who struggle with unstructured data solutions - even having tried popular brand name commercial solutions with unsatisfactory results. In my paper, I point out many of the challenges (platform coverage, geography, scalability, deployment, etc.) and how we've addressed them.

The one item that I'd differ on in Earl's post is that he mentions IAG vendors as looking to partner with SIEM and/or DLP solutions to address the issue. I don't think either is a good fit. SIEM is obviously event-driven and relies on logs. It may answer a piece of the question but it's not a direct fit. Even where it does provide value (who is doing what), it's data is limited to what shows up in logs, which isn't ideal for this scenario and doesn't generally enable context-based filtering.

And DLP may get much of the right information but the folks I've talked to describe it as overkill (too expensive and too difficult to deploy). Where DLP seems to shine is in the actual prevention (blocking action at the end-point or at the firewall). But for a quick, efficient scan of access rights and the ability to analyze high-risk conditions, I'm not sure you can bend DLP solutions to do what you need.

I'd love to discuss more with anyone interested. Let me know. I can also get you a copy of the paper. It's short and to-the-point, but is a good conversation starter.

Monday, February 13

Is the era of Identity Management behind us?

From a forthcoming paper I'm working on:
The era of identity management is behind us. It’s not that we don’t still need it, but there are plenty of mature solutions on the market to help organizations manage user accounts across systems. Over the past decade, we built the core technologies, added features and workflow, and built numerous useful solutions on top of the platforms. It has all led to this. We’re now in the age of Access Governance.
What do you think? Am I overstating it? The point is simple. We've done a pretty good job figuring out how to help organizations centrally manage user accounts. The question has now shifted to management and audit of rights across the enterprise. It goes beyond the typical Identity Management sandbox. It's not just user accounts in various repositories. It's unstructured data. It's evaluating security policies in addition to share and folder permissions to figure out true file system effective rights. Or where user accounts are being used to run Windows services. Or where they have GPOs applied to them. This is the new frontier.

More to come.

Friday, August 19

Mobile Apps for Health

Jennifer Flynn (same family) who is a health field professional has a bog called Health & Productivity Thinker where she posted yesterday on Mobile Apps for Health. She asks "what type of app would you want to use for your health?"

As a security professional, I'm very interested in the answer. As an industry, we spend a lot of time focused on information privacy and health information is among the most talked about types.

Health organizations spend a fortune on personal health information protection (perhaps primarily in an effort to comply with HIPAA). Johns Hopkins and similar organizations have reported spending $4-5 Million in their early HIPAA compliance efforts. Earlier this year, the HHS fined one provider in MD $4.3M for a privacy violation. CVS paid over $2M in 2009 and Rite Aid $1M in 2010. Walgreens is currently being investigated. Early on, Gartner estimated that the industry would spend near $4B per year on HIPAA and the HHS estimated it would cost the industry $18B in the first decade. (I couldn't find current/actual numbers)

So, protection of consumer health information is a big deal. A lot of time, money, and energy is expended in the process. But do people really care? If someone gave you an app for your phone that enabled you to carry around your complete medical history for easy distribution to doctors and health providers -- and it meant you'd never have to fill out another form in a doctor's office waiting room -- would you use it? My guess is that most people would. If it makes life easier, it will get used regardless of the privacy risk.

We all know that our phones and computers are susceptible to privacy breaches, eavesdropping, and other data leakage, but would that stop you from using an app that improved your health? Made life easier? I'd love to know, so if 2000 of you would please go answer Jennifer's question, I'd appreciate the info.

Friday, February 4

+1 for Continuous Compliance

Anton Chuvakin posted a blog entry today about Continuous Compliance. I've written on the subject in numerous places (here for example) and have even written a white paper and given a webinar on the topic.

As a software vendor, I often hear from organizations who are looking for the silver bullet. People actually say things like "your software is PCI compliant, right? ...because we need to be PCI compliant and I'm looking for software to get us there". It's not their fault. Apparently, the folks pushing down the requirements, despite their efforts, haven't done a great job at educating the people that need to be educated.

My paper and my responses explain that the idea isn't to find a piece of software or even a business process that will get you compliant for your audit next month and then you forget it until next year. The idea is to create what I've called a "culture of compliance" (a borrowed phrase) through which you remain in compliance continuously. Put controls in place, create a way to test controls, understand access rights, regularly monitor and review permissions, and you'll ultimately be able to respond to any new (related) regulation that comes at you.

Sure, I can map specific reports to specific subsections of a regulation or security framework, but that shouldn't be the goal. Take a look at our recent article on the topic: When compliance is at odds with security - sometimes focusing on the goal of point-in-time compliance can actually negatively affect your security posture. I hope Anton is right that the times may be upon us because I have to say that I often feel like people listen to what I'm saying but ultimately ignore it and really just want a set of reports labelled with the regulation du jour.

Thursday, July 29

Next Generation Compliance: Expect Answers

As an industry, we've been getting much better with understanding access rights and enabling compliance with access-related regulatory requirements. I know there are nay-sayers out there who focus on the negative - what we haven't done well. But, overall, given the speed at which we've enabled access to sensitive information, it's pretty amazing that we have any control at all.

Having said that, one of the primary problems with our current solutions for tracking changes and enabling audit response is that we just can't make sense of all the data that's being collected. One of the findings in the SANS Log Management Survey for 2010 is that the top two challenges with log management are being able to search through the data and being able to interpret the results. That's no surprise given the mountains of data generated by log management solutions. But it's also alarming because that's the exact value proposition that those solutions are supposed to provide. It's like a car that does everything well except move from one place to another.


Failure: Mountains of Data with No Actionable Information
There's a better way. In this SC Magazine article titled Answers, Not Data: The Key to Access Security, David Rowe explains that next generation audit solutions need to focus on providing answers and enabling continuous audit rather than stubbornly latching on to quantity of data as the success indicator. Give it a read and please let me know what you think.

Thursday, April 8

Governance the next Era of Identity Management

Ben Goodman, in an Intelligent Workload Management article, notes that there's a coming paradigm shift in the world of compliance. He talks specifically about the new trend of turning to identity management solutions for help with compliance. We heard more about this trend from Dave Kearns in his discussion on SailPoint expanding its Access Governance solutions into the Identity Management space and Courion doing the inverse.

I spoke to an analyst recently who was hoping to see additional convergence between identity management, access governance, and compliance solutions. I think we can probably all agree that it would be nice. In my opinion, we're at least a few years out from that. Not because of technology, but because we need customer demand to drive it. And this is all so confusing, I don't think many organizations have come the Buddha-like realization of what an ideal identity and access state would look like for them.

Mr. Goodman can correct me, but I boil his point down to one easy statement:

Start with Security and compliance will follow.

I published a paper in late 2007 in which I discussed creating a Culture of Compliance leveraging frameworks for a Multi-Regulatory Approach (it's still on the NetVision site if you're interested). Essentially, I was making the same points as Goodman. Tech professionals get really wrapped around the axle on mapping specific controls to specific regulations. But, that's a recipe for unnecessary cost, effort, and frustration.

If you must do mapping, map to a single framework and then show how that framework meets the requirements in the numerous regulations you may be facing. But an even better approach is to look at each of your critical systems and:

a) Secure them to satisfaction
b) Enable auditing to prove that security is real

We've gotten a lot better at part A. Security assessors can poke holes, identify weaknesses, and provide best-practices to get an environment to a pretty secure state. But part B means both answering the big question who has access to what? and monitoring activity to ensure that a secure state is maintained. Even in secure, locked-down environments, someone has access to sensitive information. And that needs to be watched.

If you can quickly provide answers on part B, compliance should be easier, and less costly. Even without a 30 page spreadsheet showing mappings of each control to each section of every regulation.

Friday, September 18

Security Policy Annual Acknowledgement

Over the past few years, I've encountered a number of customers who were struggling with a compliance mandate requiring employees to annually acknowledge that they have read the organization's security policy, code of conduct, or other important policy. Coreblox recently outlined how you can enforce that annual acceptance using a Web Access Management solution. If you're employees regularly need to access web resources, this is a good way to force their attention as-needed. How have you solved the problem?

Friday, September 4

Crows Using Vending Machines and the Security Implications

As reported in the NY Times, researcher Josh Klein actually taught crows to buy their own food from vending machines. If you have 10 minutes, the TED presentation is definitely worth watching. Crows are way more intelligent than you would think.

And we think we can stop them with an inanimate pile of clothes stuffed with hay!


Of course, there's a lesson to be learned for information security practicioners. Your company's employees and system adminstrators will learn and adapt. They can see the scarecrow that you've put in place to ensure security. And they figure out how work around it.

Security company RSA in their Oct. 2008 survey reported that:
53% [of employees] have felt the need to work around IT security policies in order to get their work done.
Those are well-meaning employees just trying to do their best for the company.

A recent NetworkWorld article titled Inside a data leak audit provides a real-world example. It describes an organization that was seemingly doing everything right with regard to information security. But, a thorough audit revealed 11,000 potential leaks in two weeks. All the scarecrows you could imagine were hanging on posts all across the organization. They weren't enough.

Preventative security doesn't always get the job done. Many organizations would benefit from real-time audit and monitoring solutions. In addition to after-the-fact forensic and audit trail benefits, active monitoring can be a powerful deterrent and even enable real-time remediation.

Monday, June 15

Quick Reference Guides for Windows and AD admins

Active Directory UserAccountControl – Common values related to access rights.

Windows File System Permissions – As labelled in the Windows Security dialog with descriptions for both folders and files.

Wednesday, June 10

Obama Stimulates Compliance Spend

from HIPAA.com:

A new requirement (one of the HITECH Act provisions of the American Recovery and Reinvestment Act (ARRA), signed by President Obama on February 17, 2009) will have business associates of covered entities required to comply with the Security Rule safeguard standards, beginning February 17, 2010.

from the article:
Covered entities are required to have in place audit controls to
monitor activity
on their electronic systems that contain or use electronic protected health information. In addition, they have to have a policy in place for regularly monitoring and reviewing of audit records to ensure that activity on those electronic systems is appropriate. Such activity would include, but is not limited to, logons and logoffs, file accesses, updates, edits, and any security incidents.

Monitoring and review of audit trails must be as close to real time as possible to be useful. There is no benefit in discovering a problem days or weeks after it has occurred. How a covered entity sets its policies and procedures will be based on outcomes of the covered entity’s risk analysis. If a security incident occurs, failure to exercise this audit control standard may be proof in an inquiry that a covered entity had the capability of knowing what was occurring, but failed to exercise timely corrective action.
(emphasis added)

Interesting. I need to track down the source docs to see what's real and what is interpretation.

Tuesday, February 10

Security Audit: 10 things

My daily visit to RiskStop.org led me to a presentation titled 10 Things the Security Auditor Saw. The presentation is based on data from Deloitte's 6th Annual Global Security Survey.

Number one on the list? Excessive Access Rights. Will I be accused of FUD for pointing out that this is a problem? View the presentation for yourself to see how numbers 1, 3, 4, 6, 7, & 8 are tightly related and even solved with the same swoosh of your magic wand (or samurai sword, depending on what type of geek you are).

Tuesday, February 3

Actionable Intelligence the Achilles Heal of SIEM

Today, I watched the fourth in a series of video discussions moderated by Richard Stiennon on various security topics. This one was focused on ESM (Enterprise Security Management) and SEM (Security Event Management). I combine the acronyms as 'SIEM'.

The panelists (Amrit Williams, Martin McKeay, and Mike Murray) covered a number of aspects of ESM-SEM solutions. My one line summary conclusion of the discussion is that:

SIEM's are not able to effectively correlate information and provide actionable intelligence.

A few of the supporting statements:

Murray: They lack the ability to "take data and pull information out of it"

Williams: The problem "can't be solved in a centralized way." The only way SIEMs would meet their goal is via "cooperation, communication and cognizance distributed out so the agents are essentially communicating with each other and responding to events that are being provided to each other" "I've talked to customers that are 18 months in and still can't get it properly deployed"

Murray: "there are vendors out there that you still have to manually setup every agent... the cost is staggering"

McKeay: "when I think SIEM, I think glorified log management"

Williams: "rarely are these things being used to detect and respond to incidents in real time... the market driver [...] is compliance... it is unfortunate"

McKeay: "it comes down to being able to understand your own environment... it's the definition of the problem that we don't have yet"

The consensus seemed to be that vendors do a good job of gathering and storing logs to meet compliance requirements that mandate storage of those logs. What customers really need and want from these vendors, however, is actionable intelligence.

Williams concisely defined the goal of information security:

"to limit the possibility of an incident from occurring... and when it does occur, to limit its impact (by identifying it quickly and responding)"
He continued "...what the ultimate goal of an intelligence system would be is that it's able to detect what are seemingly innocuous events and provide some actionable level of intelligence that shows that that's actually an incident occurring and you can respond to it and limit its impact on the environment - that's what they'd like to be, but they're not that"

Murray added that customers want the solution to "just tell me the five things I need to do - that's what SIEMs should do"As an industry, we're "really good at generating reams of data, but we're not very good at handling information... turning it into 'here's the 5 things'..." SIEM tools are great if "you have defined the problem that you're trying to solve and you know what the information is that you're trying to manage and you can setup a way to manage that."

It was a really interesting discussion. I've enjoyed each of the video discussions in this series so far which have also covered DLP and Firewalls/IPS.

Next, I'll tell you what NetVision is doing about the problem. We're not a SIEM vendor, but we beat the SIEMs to the finish line of actionable intelligence. Actionable Intelligence has been our internal mantra for the past year or so and it is the motivator behind our latest solution to market (as well as a few that are still on the road map).

Tuesday, January 27

What Makes a Control Effective?

Wade Baker at the Verizon Business Security Blog posted on the definition of Effectiveness in relation to Security Controls.

I like his basic definition:
"If it does what it’s supposed to, to the degree it’s supposed to"
This highlights the need for a thorough analysis of what a control is supposed to do – and how well it's supposed to work. ...which I think sometimes gets missed among all the vendor sales and marketing materials that are designed to talk about the big picture (compliance, etc.) rather than actual functionality.

Thursday, December 11

Small Orgs Hit by Economy - Maximize Your Budget

A new CIO article titled How to Maximize your IT Security Budget discusses how to make the most of your IT Security budget given current economic, regulatory, and threat conditions.

Cybercriminals are finding it easier to move downstream and target small to medium businesses... Regardless of whether you are... [smaller] ...you face the same problems as a global enterprise when a breach occurs: potential fines, bad press, class-action lawsuits and customer attrition.
I have noticed recently that the affects of PCI-DSS are extending out of retail and into Healthcare and other verticals. HIPAA is extending into law firms and other organizations that somehow support healthcare rather than actually being healthcare.

So yes, the NEED to provide security and proof-of-security (audit) seems to be GROWING as BUDGETS to address the needs are SHRINKING.

NEED - GROWING
BUDGET - SHRINKING

...not an ideal scenario. So, what do you do?

Page 2 has the tips on how to maximize the budget. Basically, you need to look at efficiency, automation, and finding the right fit (rather than blowing the budget on something that attempts to cover everything). Think Operationalizing Security.

One thing I took away from SC World Congress was the fact that smart people are still recommending an approach that includes business alignment and risk analysis rather than a shotgun approach. Be a surgeon. Figure out your risks and find the right way to address them while balancing cost, approach, efficiency, etc. Don't just keep boarding up all the windows.

Tuesday, November 25

Managed Service for AD Monitoring

The engineers at NetVision were incredible visionaries back in 1995 when they built some of the first identity management tools (for Novell-Microsoft sync) and identity audit tools. (check out their site from 1999) Their directory knowledge is unparalleled and now, that spirit of leadership is alive again.

NetVision recently brought to market the industry's first managed service offering for monitoring and reporting of identity & access information on core network directory platforms (Microsoft Active Directory and Novell eDirectory) and their related file systems.

We have effectively removed all the typical obstacles - software, hardware, configuration, setup, maintenance, etc.. The solution is delivered via an appliance allowing us to handle the heavy lifting (while the data stays close to home):
  • WE do the configuration to match your environment
  • WE install, configure and lock down the OS
  • WE install and configure the supporting software (database, report engine)
  • WE install and configure the solution, including setup of policies, reports, and customizations
  • WE handle all of the patch management and upgrades
  • WE monitor the system for performance
  • WE provide policy and report updates when needed
The only thing left for our customers to do is to enjoy the critical data that they wouldn't get anywhere else (and the extra time they now have on their hands).

Please say hello to SIMON.

Friday, October 3

Better data from Active Directory for your SIEM

If you Have or are Planning to Have:
  • A SIEM solution (ArcSight ESM, RSA enVision, Novell Sentinel, IBM TCIM)
  • An enterprise Log Management solution (LogLogic, TriGeo, SenSage)
And your employees log on to:
  • Microsoft Active Directory / Windows
  • Novell eDirectory / NetWare
And you're unhappy with the solution's ability to:
  • Get complete information from the directory or file system
  • Filter which information is collected
  • Generate highly relevant alerts based on filtered event data and custom policies
  • Collect event data directly from the source (independent of system logs)
  • Apply decisions or alerts based on WHO is performing the action
  • Report on ANY combination of objects and attributes in the directory
  • Report on who is opening or modifying files, folders, or file system permissions

THEN ...Please give us a call.

I recently wrote a paper discussing how we (NetVision) extend the ability of SIEM or log management solutions by getting better, more reliable, and more relevant information directly from what is arguably your most critical source (the network directory). The paper isn't publicly available (it's not that kind of paper). So, let us know and we'll pass it along or we can save you the trouble of reading and just explain it.

Wednesday, July 16

Something Old and Something New

Eric Norlin provides some insight into what to do (related to identity management) in an economic slowdown:

Something Old:

"1. SSO and Password Reset: The facts are on the wall. If you can reduce the number of helpdesk calls for password reset, you're going to save a TON of money. You can do that through self-service modules, E-SSO, web sso, or even federation. Just do it."

Something New:

"2. Automating Compliance: This is a big one, and you probably won't get it done before the recession ends. However, the more you achieve automated compliance controls, the more big bucks you can save on manual audits. Throw everything from RBAC to de-provisioning into this bucket and then get started looking at what really will slice greenbacks soonest."

Password Reset and SSO have long been good entry points into Identity Management and also proven creators of cost reduction and efficiency.

Automated Compliance is a somewhat more recent phenomena that also yields cost reduction and efficiency. You may be wondering though how many companies are able to get to automated compliance without giving an arm and a leg to define requirements and processes that enable automated compliance. Might the initial effort might defeat the purpose of cost reduction?

One thing Eric wrote is probably key to that discussion – "the more you achieve automated compliance controls..." which to me means, let's not get caught up in the grand notion of automated compliance. Implement a few key automated controls that eliminate significant manual effort in the compliance audit process. And that will bring you cost reduction.

Monday, July 7

What to Monitor in Active Directory

If you manage an Active Directory infrastructure, you probably know that you should be monitoring activity or data or something. But what exactly needs to be monitored? Well, as I say in my latest paper, there is no one-size-fits-all prescription for Active Directory monitoring. But, there are five items that carry particular interest. In this paper, I go into detail on each of the five – what needs to be monitored and why.

For many mid-market organizations, these five may cover 80% of security monitoring needs – especially for organizations that are strategic about their use of Active Directory. As the title says, it's strictly limited to Active Directory, so don't look for firewall logs or changes to virus protection files. There's a short excerpt here if you'd like to take a peek.

If you're a security or Identity Management consultant, feel free to contact me directly and I'll be happy to send you a copy.

...The 5 Most Critical Points for Active Directory Security Monitoring

Thursday, May 22

PCI Compliance and Network Segmentation

I spoke at a CSO Executive Seminar on PCI Compliance in January. During my talk, I put up a slide showing a PCI reference architecture and went through many of the various security components that could help lock down an infrastructure and mapped each to the related PCI requirements. I covered topics like authentication, access control, IDS/IPS, anti-virus, encryption, key management, policy management, change management, rights audit, user monitoring, and a few others.

Before I began with that slide, I gave a disclaimer that there are a few key techniques that I would not include in the reference. One was network segmentation. I hadn't heard others mention it before in reference to PCI, but as I was thinking about my talk and building the reference architecture, it occurred to me that segmentation would be a really useful way to reduce risk in an environment where credit cards are accepted. So, I mentioned it in passing as something that companies should think about in addition to what I had on the screen.

Today, I read this article, by Stephen Cobb, in which he discusses PCI compliance and pays specific attention to the topic of network segmentation. I thought it would be a nice supplement to my talk back in January. In retrospect, I might have spent a bit more time on that topic, but I really tried to cover a ton in a short time. So, if anyone from that audience is reading this... Or if you're looking to improve your security or your PCI compliance posture...