Safe choices drive security policies

Working in many companies as an IT consultant allows me to see a broader spectrum of policies, business justifications and processes than many of the clients I work with, especially if they have been with their company for many years.  One of the more vexing notions that continue to surface in different forms is making decisions based on the logic of the herd concept.  Or put another way, let’s pretend we are lemmings!  Many years ago it was “No one got fired for buying from IBM” and after that “No one got fired for hiring Andersen Consulting” and there are more permutations of this phrase than time allows to list.

A recent iteration is “No one got fired for banning IM”.  There was an article in www.networkworld.com December 1, 2008 issue that covered this topic with a touch of humor and angst, written by Andreas Antonopoulos.  

Conducting business entails risk.  Does not matter what type business you participate in.  Instant Messaging (IM) and various chat capabilities available to companies internally and externally are nothing more than extensions of using a phone or sending e-mail (really fast!!).  Those forms of communications are not banned and are seen as integral communication methods.  IM is just a variation of those methods.  It is often easier for security groups within companies to just say “NO” than to develop creative methods to support the business. 

Most companies I have worked in allow users Administrative privileges for their Widows laptops.  Even though that is a really bad idea and allows everyone to load software they bring in from home, they do not trust them to conduct business over IM.   

Sarbanes-Oxley Act (SOX) Audit Requirements

Sarbanes-Oxley Act (SOX), passed in 2002, spells out requirements for internal controls.  Some organizations have turned to the standards published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). These do not, however, provide specific guidelines for organizations that deal with databases, a key area of concern for SOX compliance, but instead provide an excellent conceptual architecture for organizations to build a compliant IT Control framework for the enterprise.  Others are relying upon the best practices set forth by COBIT (Control Objectives for Information and related Technology) and ITIL (Information Technology Infrastructure Library). However, these frameworks are incomplete with regards to the concerns set forth under SOX relating to databases. Databases are at the center of SOX control issue. Ensuring effective controls over database activity—writes, deletes, changes, and administration—is absolutely crucial to maintaining data integrity.  Control must also extend to server and mainframe applications and unstructured data. Meeting SOX compliance centers on four areas:  audit trails, segregation of duties, change control, and patch management.  

Audit Trails

Companies need to answer who changed a record, who deleted a record, changes to a schema, with particular detailed attention to privileged users.  These audit logs are usually a normal by-product of most database and application tools.  There needs to be a process to regularly review patterns and to store the logs for at least 5 years. 

Segregation of Duties

The Information Systems Audit and Control Association (ISACA) has issued guidelines calling for IT organizations to assign clear job roles and functions, and to assign database and system permissions according to those roles and functions. Please refer to www.isaca.org and the publication titled Control Objectives for Sarbanes-Oxley 2^nd Edition for additional detail.   

Change Control

Organizations need to document changes to their technical environment and adoption of ITIL’s Change and Release Management play a crucial role in satisfying this area.

Patch Management

Applications and associated databases should be patched on a predefined schedule that takes into account the peak usage periods for these systems, while providing substantial review of the patches with adequate testing. There are some other internal controls over financial reporting (ICoFR) that relate to database auditing and include:

• Network access should be limited only to certain defined systems (via strong firewall and IP restrictions).

• Unnecessary service access should be blocked at the network access device.  This would be satisfied by “hardened” proxy servers.

• Frequent review of user accounts and passwords should regularly verify that all permissions reflect actual user roles and responsibilities.  This has given rise to a number of products associated with Identity Management (IM) and Network Access Control (NAC).

These should be performed several times a year, in alignment with HR systems and general identity management solutions.

• Financial transactions are properly recorded by authorized users
• Data has not been compromised by unauthorized or authorized means
• All changes to the financial data are monitored

Achieving these controls presents IT managers with the challenge of auditing (and maintaining an audit history) for a variety of SOX-related activity, including all:

• privileged user activity
• changes to user privileges
• failed login attempts
• logical access failures
• database schema changes
• direct data access events

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ISO 20000 Background, Audit, and Assessment (Plan-Do-Check-Act)

ISO 20000 is based upon an original pair of documents, BS15000-1/2, which were published in 2002 and 2003 respectively.  ISO 20000 is the international standard for IT Service management and is comprises two parts: ISO/IEC 20000-1 and ISO/IEC 20000-2. ISO 20000-1 is the ‘Specification for Service Management, and it is this which is certifiable against. ISO 20000-2 is the ‘ Code of practice for Service Management’, and describes best practices, and the requirements of Part 1.

ITIL is the process defined framework for IT operations.  ISO 20000-2 is the code of practice built on top of ITIL tailored processes.   ISO 20000-1 is the specification for ITSM that would facilitate the audit.  The framework had been harmonized with other international standards, to embrace the familiar PDCA (Plan-Do-Check-Act).

plan-check-do-act.pdfManaged Services illustrated in the diagram could be internal IT services or externally supplied services.  Aligning processes and procedures is accomplished in the planning and implementation phase. The methodology, known as Plan-Do-Check-Act (PDCA), can be applied to all processes, as follows:

• Plan: Establish the objectives and processes necessary to deliver results in accordance with customer requirements and the organization’s policies.
• Do: Implement the processes.
• Check: Monitor and measure processes and services against policies’ objectives and requirements and report the results;.
• Act: Take actions on the differences and continually improve process performance.

Multiple service management plans may be used in place of one large plan or program. Where this is the case, the underlying service management processes should be consistent with each other. It should also be possible to demonstrate how each process and requirement is managed by linking it to the corresponding roles, responsibilities and procedures. ISO 20000 section 4.3 (monitoring, measuring and reviewing) states that in order to identify these process areas and improve upon them, a regular audit program must be planned. Users also need to take into consideration the status and importance of the processes and areas to be audited, as well as the results of previous audits. The audit criteria, scope, frequency and methods must be defined in a procedure. The selection of auditors and conduct of audits must ensure objectivity and impartiality of the audit process. Auditors must not audit their own work. Any significant areas of noncompliance or concern should be communicated to relevant parties and corrective action taken.

Scope creep

As organizations change and grow, the scope of the services provided under the ISO 20000 standard expands. However, the organization often times fails to expand their certification activities to cover any new services. This is known as an “extension to scope.” This can be addressed by following the rules set forth in section 7.2. ISO 20000 section 7.2 (business relationship) requires the service provider and customer to attend a review to discuss any changes to the scope, service-level agreement, contract (if present) or the business needs at least annually and shall hold interim meetings at agreed intervals to discuss performance, achievements, issues and action plans. These meetings shall be documented.

Not everything is recorded or measured

According to ISO 20000 section 4.3 (monitoring, measuring and reviewing), the organization must apply suitable methods for monitoring and, where applicable, measuring service management processes. These methods must demonstrate the suitability of the processes to achieve planned results. Management must then conduct reviews at planned intervals to determine whether the service management requirements:

• Conform with the service management plan and to the requirements of this standard;
• Are effectively implemented and maintained.

Additionally, under section 4.4.2 (management improvements), all suggested service improvements shall be assessed, recorded, prioritized and authorized. The service provider must have a process in place to identify, measure, report and manage improvement activities on an ongoing basis.

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IT Framework Relationships

There are numerous processes designed to enhance the overall effectiveness of IT and often times what gets overlooked is how they might fit together.  Described below are the various frameworks and their relationship to one another and when you might adopt these frameworks over time.  Each of the frameworks has their set of implementation issues and problem areas for adoption.

• ITIL maps service delivery to process execution and technical aspects of process control.
• PMBOK primarily focuses on project management.
• CMM primarily focuses on software delivery, but can be used to assess maturity of process execution.
• ISO 20000 is a process to measure the effectiveness and points towards improvements for ITIL.
• ISO 17799 primarily deals with an overall security process, awareness, standards and measures of control
• COBIT focuses on process control as well as strategic control in an enterprise
  • Strongly focused on control and less on execution.
    • Helps optimize IT-enabled investments,
    • Ensures service delivery
    • Provides a measure against which to judge when things do go wrong.
• Six Sigma methodology is the implementation of a measurement-based strategy that focuses on process improvement and variation reduction through the application of Six Sigma improvement

 IT Framework Relationships

 

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What is ITIL?

The IT Infrastructure Library (ITIL) is a series of eight books and is referred to as the only consistent and comprehensive best practice for IT service management to deliver high-quality IT services. Although produced and published by a single governmental body, ITIL is not a standard and is generally referred to as a framework.  There is a lot of work involved in tailoring an implementation to any organization. The published books (subject to change my mid-2007) are:

• Software Asset Management
• Service Support
• Service Delivery
• Planning to Implement Service Management
• ICT Infrastructure Management
• Application Management
• Security Management
• Business Perspective, Volume II

There are two main operational components or logical groupings within ITIL, with Security Management completing the underpinning for both groups are:

• Service Support (activities that are more or less performed daily)
• Service Delivery (activities that tend to take place monthly or quarterly, but at a minimum annually)

ITIL Process Overview

 

BUSINESS DRIVERS FOR IMPLEMENTING

ITIL is usually implemented subject to one or more of the following business cases:

• Defining of service processes within the IT organization
• Defining and improving the quality of services
• Need to focus on the customer of the IT
• Implementation of a central help desk function

There are several methods in approaching an implementation of ITIL and having done several operations assessments, I can attest that the two main building blocks that have to be solid are Configuration Management and Change Management.  Both gear their activities off a Configuration Management Data Base (CMDB).  If the CMDB does not exist or if Change Management is a haphazard process, then the other processes within ITIL tend to fail on a regular basis.  Recently more and more vendors are creating products geared specifically towards CMDB (e.g., HP, CA, BMC, etc.) that address a method to collect all of the configuration specifics of your environment.  If you don’t know what you have, it will be problematic when implementing any change, but you can never been certain of the effect of the change.Two principal concepts characterize the basic thinking of ITIL:

• Service management—IT service managers:
  • Assure the consideration of requirements for operations and maintenance
  • Develop test plans
  • Identify the effects on existing infrastructure caused by new or modified systems
  • Define future requirements
• Customer orientation—IT services are to be provided at a level of quality that allows permanent reliance on them. To assure this quality, responsibility is assigned to individuals who:
  • Consult the users and help them use the services in an optimal approach
  • Collect and forward opinions and recommendations of users
  • Track complaints
  • Monitor the users’ appraisals of the services delivered
  • Support internal user groups

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