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NIST Addressing PII Protection

The National Institute of Standards and Technology (NIST) has drafted a document that specifically addresses Personally identifiable information (PII).  The document will become Appendix J of SP 800-53.  This means FISMA is likely to change to include these new privacy controls.

What does this mean to you?  In the short term, nothing.  The standard will be in a public comment period until September 2, 2011, and is not scheduled to be included in SP 800-53 until December 2011 when Revision 4 gets released.  After that, it still needs to be updated in FISMA and other regulations derived from SP 800-53.

However, the controls outlined in the draft are significant, and will eventually add extra layers of complexity to an organization’s plan to become compliant.  I’m still fully digesting the draft, but something that initially stands out is that NIST is treating PII data similar to how PCI-DSS treats card-holder data, and to how NERC-CIP treats Critical Cyber Assets.  For example, control SE-1 in the NIST draft states:

The organization:
a. Establishes, maintains, and regularly updates a PII inventory that contains a listing of all programs and information systems identified as collecting, using, maintaining, or sharing PII;
and
b. Provides each update of the PII inventory to the CIO or other information security officials to support the establishment of appropriate information security requirements for all new or modified information systems containing PII.

This sounds very similar to the approaches in PCI-DSS for defining and securing the Cardholder Data Environment (CDE), or the NERC-CIP Critical Cyber Asset identification.
The draft also adds on all the standard process and procedure requirements, auditing requirements, monitoring, roles and responsibilities, etc, that are seen across the board in other compliance regulations.

While there will still be quite some time before organizations are mandated to adhere to this draft standard, getting a head-start now will save headaches in the future, and protecting PII is simply the right thing to do, regardless of whether it’s mandated by compliance.

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2 Comments | ComplianceDigital ForensicsSecurity

 
 

With great freedom comes great responsibility….

If it didn’t come across as mind-bendingly smug, I might describe the Sega hack as ‘old news before it even broke’.  But it is.  Old news.  Another global digital meganame falls prey to malicious, possibly mafia- or triad-backed ill-doers.

Recently I sat and watched a trusted colleague deliver a presentation to a roomful of security personnel and liken their industry to an air wreck.  I believe his exact words were ‘if this were a plane, I’d be running up and down the aisles screaming that we’re all going to die!’.  Needless to say this was not well received on the day, but I can’t help but think that he had a point.

Now, I work for an SIEM vendor – the best on the planet, in my opinion, but I’m not going to ambulance-chase this one.  There are crucial issues raised now.  This raises questions about whose responsibility personal privacy actually IS.  As I’ve said before, Amazon, Barclays Retail, Dell, Dabs – any of these guys could get hacked tomorrow and lose YOUR data.  What then?  It can take weeks to recover from a personal identity breach – resetting email accounts, changing card numbers, suppliers and addressing the huge numbers of interconnected services and locations where your identity converges.  This is not to mention the consequences if you actually lose money.

What more can individuals do?  Most of us are getting it right:  Don’t throw old business cards in the bin.  Go for strong passwords, changed at least monthly.  Don’t show identity badges in public places (watch out for my next blog on this!).  Speak to everyone about the need for security.  Educate the less technically literate about malware.  Don’t respond to emails or phone calls about online matters unless you initiated the conversation.  Keep one eye on the security blogs.  Learn the language.

Can companies say the same thing?  What about the people who I entrust my identity to?  Invest in security – with all that entails.  Infrastructure.  Dedicated FTEs.  Education.  Compliance.  Regular reviews.  Fire drills.  Specific executives whose job IS security.  Clearly the people who take online privacy seriously are being let down by the companies who don’t, and the more companies that are breached, the more excusable it seems.

My own view on Sega and the bi-monthly additions to the ranks of large companies who didn’t make the grade, is that it’s time to think of security as a multi-partite affair.  Your strategy should start with compliance, then loop through infrastructure best practise, via rigorous HR policies and finish by directly addressing social engineering.  The modern breach is a blended affair.  Only a blended security strategy will work.  One that centres around human factors.

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0 Comments | ComplianceDigital ForensicsSecuritySIEM

 
 

Why SIEM? A Retrospective

Ten years ago, I was put into the position of having to figure how to manage a serious gap in enterprise security for a vitally sensitive environment.  The problem was introduced to me like this:  “The team can read 3,000 pages of logs per day but they receive 55,000 pages.”  Adding more heads to the problem wasn’t the right solution- they were losing context, were inaccurate, under-trained, and bored.  The success stories from this team were few and the needle-in-a-haystack factor was high.  This process needed to be automated.

There was another serious problem besides log volume.  I explained the systemic issues to my supervisors like this; “The security controls in our organization are like musical instruments in an orchestra.  We have firewalls, anti-virus, intrusion detection devices, file integrity monitoring, content filters, anti-spam, host security, and application security.  But right now each does security ‘solo’.”

Each control was managed by a different group.  Reporting was all hand constructed and carried to the security team.  The firewall manager would deliver the firewall report daily, intrusion detection was handled by the incident handling team once a week, anti-virus reports were delivered monthly by the IT staff, and so on.

The whole of the system was as reliable as clockwork: each piece did its part exactly as planned and yet each was still ineffective.  The whole process was too high-level to determine if a problem existed, too low-level to see the problem as it happened, incomplete because not all data was reviewed, and lacked the context to determine if a threat was real even if it was suspected.

The bottom line?  All controls play a different piece in the same symphony.  They need to work together to turn noise into music.

The promise of SIEM was that computers can solve large, complex and tedious problems faster and more accurately than people; as such they are the ideal tool to police themselves and their users.  We wanted the entire system of security controls in the enterprise working cooperatively, in harmony, and armed with the intelligence needed to protect the organization.

The emerging SIEM (SIM, SEM, or ‘master console’) technology was often focused on specific tools such as Intrusion Detection or Host Security that ‘extended’ into logging. Many critical systems had no logging whatsoever and companies withheld such features in an attempt to keep their proprietary systems closed.  It would take most of the 2000′s to get the message to vendors that 3rd party auditing was a requirement.  Now SIEMs can be practical and more creative means of using them can be applied.

Once the orchestra is together, the Conductor can lead. It’s of utmost importance that the managers, investigators, analysts, engineers and operators hear the same song.  What SIEM needed and has achieved today the ability to connect logs to organizational regulations, policy, plan, procedures, organizational divisions, and even by individual project requirements.  Alerts can be tailored to correlate between identified events, known threats, and critical assets.  Reports can be automated and customized to fit any manner of output requirements rather than being limited hand-made spreadsheets.  And valuable metrics can be mined from the official record of events that the SIEM establishes.

Thanks to SIEM technology, logs can be reviewed properly, human resource requirements to review them are less, and can handle volumes that now may exceed tens-of-millions of pages of data per day rather than just 55,000.  Coverage now extends to the entire networked enterprise and information can be presented in a timely manner and in ways that are useful to all stakeholders.  There is no doubt to me, SIEMs are a key innovation for information technology and will be critical for what is shaping up to be a brutal future for security problems.

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0 Comments | General

 
 

“Keeping it in context”

Earlier this week, HP announced its plans to acquire ArcSight for $1.5 billion. This news signaled HP’s recognition that central log and event management is an essential technology platform for HP to pursue their vision on multiple fronts. Bill Veghte, HP’s executive vice president for software and solutions, said on a call with Wall Street analysts that the announcement confirms “HP’s intent to be a leader in enterprise security”.

Some SIEM vendors have used this news as a chance to spread FUD (fear, uncertainty and doubt) to organizations that might be considering an ArcSight purchase by suggesting that product development schedules at ArcSight/HP will be delayed, service response times will be hit, etc. Do they really think most IT purchasers just fell off the turnip truck? Certainly things will change for ArcSight. But mergers and acquisitions happen all the time and most IT purchasers are more than capable of assessing how vendors match up against their decision criteria, including those vendors that are in the process of being, or have recently been, acquired. These IT purchasers don’t benefit from vendor fear-mongering. Rather than contributing more FUD, I think a closer evaluation of Mr. Veghte’s comments serves a more useful purpose.

Mr. Veghte stated that the visibility ArcSight’s products bring into an organization is a cornerstone for HP to becoming a leader in enterprise security and that “if you can’t see it, you can’t secure it.”
While his statement certainly sounds good, if you’re only seeing “it” without seeing “it” in context, you’ll remain blind to potentially serious threats and significant points of exposure. By “context” I’m referring to all the other information relevant to that activity (the forensic details that help to tell the full story and/or paint the complete picture).

Let’s take an activity that on the surface is deemed benign at the time of occurrence, such as a successful authentication to a VPN server. Successful VPN connections happen all day long and represent normal business activity. As such, this activity never gets classified as an “event”. It’s simply seen as one of a million benign logs. But what if the user was connecting via VPN from Poltava, Ukraine at 2am local time? Wait a minute. You don’t have any operations in Ukraine and the apparent “trusted” user copied data from your payment application server to their laptop. Furthermore, that particular user logged off from his office in San Diego just six hours earlier. It becomes clear that just seeing your VPN server and perhaps even watching for unauthorized access isn’t enough.

Capturing valuable contextual data such as direction, bytes in/out, geolocation information, impacted hosts and applications, universal time, etc., and storing it in a single, highly accessible and searchable data structure is critical to truly securing your enterprise. LogRhythm provides over 40 metadata fields to capture such context with powerful tools to tap that information for unprecedented insight and awareness.

We’ll be steering clear of turnip trucks and continuing to build truly best-in-class Log Management and SIEM 2.0 solutions (and keeping things in context).

 

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1 Comment | General