Awareness Program on Compliance in the Era of Technology ICAI, Mumbai October 19, 2008 u 1 Public Document <version 1.0> Agenda 1. 2. 3. Compliance Today Business Risks Evolving Security and Compliance landscape Technology and IT value for business Incidents and Security related industry information Snapshot of Global Compliance requirements over time Extracting Compliance ROI Suggested Safeguards (unified framework) Common regulatory reqmts (standards, etc) 4. 5. 6. 7. 8. 9. 2 10. The technology solution 11. Compliance spotlight – PCIDSS 12. Leverage the technology solution 13. VA/PT 14. Continuous VA and Monitoring 15. List of Tools 16. Why VA/PT 17. Web App Security, Secure Coding Public Document <version 1.0> Compliance Today • Organizations have numerous Compliance requirements which keep growing by the day / hour / minute ! – Regulatory – Standards / Best Practice Frameworks – Industrial, Contractual, etc. • Technology is constantly evolving providing new tools and methods to tackle the increasing information and compliance overload 3 Public Document Much of the increase in cost is due to duplication of regulation and ambiguous or inconsistent rules -Securities Industry Association, 2006 <version 1.0> Compliance Today Compliance with Compliance requirements takes up too much resources Compliance initiatives are considered “Projects” (e.g. SOX / PCI project) but these are continuous processes (benefits are not realized) Technology solutions will leverage Compliance efforts to enable Governance and Risk Management leading to Business gains (productivity, cost-savings) • • • Compliance must be part of your organization DNA Regulatory Compliance is not just a legal requirement but a critical business function. 4 Public Document <version 1.0> Business Risks Operational risk Physical damage/theft Services not available Market risk Lost customers Global partners Legal risk SLAs Lawsuits What is at Risk Information on your network Databases Intellectual Property Financial Information Personally Identifiable Information Reputation & Market Value Regulatory Compliance Financial Risk 5 Claims and losses Quantification of information assets/impact Public Document <version 1.0> 6 Public Document <version 1.0> Technology and Information Made People Smarter Google Luhn’s algorithm (to validate any credit card) VB based basic key loggers Web based IP tools, DNS network tools, traceroute etc Network tools Nmap Nessus etc…. All available online Password cracking tools 7 Public Document <version 1.0> 8 Public Document <version 1.0> Incidents (2000-2007) According to Attrition Data Loss Archive and Database and FlowingData, following are the 10 largest data breaches since 2000 (http://flowingdata.com/2008/03/14/10-largest-data-breaches-since-2000-millions-affected/) 9 Is there a trend? Yes, numbers are growing! Public Document <version 1.0> Are we safe in 2008? UK Government Depts. reported loss of 29 million records in last one year (August 2008) Countrywide Financial Corp. – possible all 2 million records were sold (August 2008) If sensitive data only includes SSNs and financial account data and not date of birth and email ids then should we decide Facebook’s 80 million records as a data breach? (July 2008) Bank of New York Mellon, PA – as many as 4.5 million customer records are thought to be compromised (March 2008) Compass Bank – 1 million (March 2008) Hannaford Bros. supermarket chain – 4.2 million (March 2008) 10 Trend – Numbers are still growing! Public Document <version 1.0> Some Facts Who are behind these breaches: External sources including past employees Insiders Business partners Multiple parties How these breaches are caused Business process errors or no policy/procedural controls Hacking and intrusions including malicious code System/Application vulnerabilities including for those patches already exist Physical threats Victims don’t know that breach has occurred or more often aware of the criticality of the data/information Mostly breaches are opportunistic in nature 11 Mostly……… More than 90% breaches are avoidable Public Document <version 1.0> Some Insights – drivers for security spend By 2008, more than 75% of large and midsize companies will purchase new compliance management, monitoring, and automation solutions. By 2009, compliance will grow to 14.2% of IT budget from 12% in 2006. Source: Gartner 2007 12 Public Document <version 1.0> 13 Public Document <version 1.0> Common Regulatory Reqmts / Standards / Frameworks / Guidelines Clause 49 (SEBI Guideline, Government of India) CTCL ISO:27001 – 2005 133 Control objectives PCI-DSS 12 requirements CobiT NERC-CIP BS:25999 ITIL Data Protection Act IT Act and applicable Criminal / Civil legislation 14 HIPAA/GLBA Sarbanes Oxley Basel II PCAOB SAS 70 Privacy Laws (e.g.PIPEDA) … many more….. Public Document <version 1.0> Extracting Compliance ROI Organizations must plan beyond Compliance Better Security means reduced / managed risk Managed (reduced) risk means better business Operational efficiencies result from compliance efforts Approach Compliance as a as a business process, not as requirement / overhead Use learning to shorten future compliance cycles Identify opportunities to build unified compliance ecosystem Lead the organization to Industry certifications resulting in higher brand value Eliminate the risk of penalties for non-compliance Address multiple compliance requirements in a unified approach 15 Public Document <version 1.0> Suggested Safeguards 16 Public Document <version 1.0> Suggested Safeguards 17 Public Document <version 1.0> 18 Public Document <version 1.0> Technology Solution Systems must be developed providing a risk based approach that is aligned with Business, Regulatory and Contractual requirements Leverage technology and co-ordinate Security spend with Compliance with the overall objective achieve Governance (automation) Technology practices to enable proactive security Risk management 19 Vulnerability Assessment / Penetration Testing (VA/PT) Web Application Security (AppSec) Code Review Continuous Vulnerability Management Managed Security Services Public Document <version 1.0> Compliance Spotlight : PCI – Data Security Standard 20 Public Document <version 1.0> Compliance Spotlight : PCI-DSS Requirement 5 and 6 (Maintain Vulnerability Management Program) Stay Current on versions (Anti Virus, Patches, Systems, Configuration) Monitor Custom Web applications SDLC (do we practice secure coding) Invest in automated tools Secure Audit Logs Requirement 10 and 11 (Regularly Monitor & Test Networks) Monitor Systems for Intrusions and Anomalies Implement Reporting and Analysis Tools Centralize and Secure Data ISO:27001 – A.12.6 Technical Vulnerability Management 21 ISO:27001 – A.15 Compliance -Compliance with Legal Requirements -Compliance with Security Policies, and standards and technical compliance Public Document <version 1.0> Leverage the Technology Solution Technology Practices for Compliance providing proactive Risk Management Continuous Vulnerability Monitoring and Assessment Vulnerability Assessment (VA) 22 Penetration Testing (PT) Secure Application Development (Coding) Practices Web Application Security Assessment Public Document <version 1.0> Leverage the Technology Solution Vulnerability Assessment (VA) Penetration Testing (PT) 23 Results allow the organization to compare findings against known vulnerabilities and prioritize remediation by implementing controls. Provides a health report on the organization security posture. All Standards, Regulations, Frameworks recommend (or require) Network Assessments as an essential practice. Helps determine whether the controls are in fact preventing the vulnerability from actually endangering the network. A well-executed penetration test can identify the most critical holes in an organization’s defensive net; including the holes exploited by social engineering. pen tests are best used as a way to get an extra set of eyes on a network after major system upgrades. Public Document <version 1.0> Leverage the Technology Solution Continuous Vulnerability Monitoring and Assessment Provides a 24 x 7 x 365 watch on network traffic and is available as a Managed Security Service. Traffic is monitored and events (incidents) are correlated against updated industry Common Vulnerability & Exposure (CVE) database. Reports are available online to client via a web interface which will provide information about the threat(s) and remediation plans. 24 Public Document <version 1.0> VA/PT Undertaken by qualified professionals Methodology includes use of automated tools augmented with manual skills Meet regulatory requirements (PCI-DSS, HIPAA, GLBA, PIPEDA, etc.) Organizations can realize their true security level Measure IT security effectiveness Identify and remediate potential breach points reducing security risk and liability Benchmark / baseline security posture Certifications Certified Vulnerability Assessor (CVA) (Secure Matrix - DNV) CEH (EC Council) CISSP (ISC2) certifications in Forensics, Fraud (Secure Matrix) Commonly used Tools for VA/PT (commercial / open source) Nessus, GFI Languard (c), Nmap; Metasploit, Canvas (c), etc. 25 Public Document <version 1.0> List of Tools (indicative) Vulnerability Assessment Nessus Nessus is one of the most popular and widely used vulnerability assessment scanner with nearly 14,000 plugins. GFI Languard GFI Languard is a commercial vulnerability assessment scanner with neat reporting capabilities. Netcat Netcat is a network debugging and exploration tool Hping This tool is particularly useful when trying to traceroute/ping/probe hosts behind a firewall that blocks attempts using the standard utilities. This is to map out firewall rulesets. Nikto A comprehensive webserver scanner Sam Spade Windows network query tool Web Inspect Web Application Scanner Firewalk An Advanced traceroute tool Penetration Testing Metasploit Framework This is a framework to deploy vulnerability exploits and payloads. Securematrix has created a database of nearly 100 exploits in this framework Canvas A Commercial Penetration Testing tool Core Impact A Commercial Penetration Testing tool SAINT A commercial Penetration Testing tool CenZic A Commercial Web application testing tool John the ripper powerful, flexible, and fast multi-platform password hash cracker THC Hydra A Fast network authentication cracker which support many different services Dsniff A suite of powerful network auditing and penetration-testing tools Solarwinds Network discovery/monitoring/attack tools 26 Public Document <version 1.0> Why VA/PT 27 To catch a thief…..You have to think like one. You hack into your network to do a Vulnerability Assessment (VA), identifying “vulnerabilities” in the same manner as they may be visible to an intruder like open ports. Following up a VA is the Penetration Test – you are taking advantage of the ‘vulnerabilities’ by “penetrating” the network. When you test all IP addresses that are visible to the outside world you can get answers to sticky questions like: Can an intruder hop on to the conference room network ? Is it possible for the intruder to connect to the database server ? What can you do (that which no one wants an intruder to do!) ?? Public Document <version 1.0> Presented by Dinesh Bareja CISA, CISM, ITIL, IPR, ERM, BS: 7799 (Imp & LA) - Senior Vice President Email: dinesh@securematrix.in Information Security professional, having more than 11 years of experience in technology in commercial, operational, functional and Project Management roles on multiple large and small projects in global and domestic markets. Experienced in establishing ISMS (Information Security Management System), planning and implementation of large scale CobiT® implementation, ISO: 27001, Risk Management, BCP/DR, BIA, Asset Management, Incident Mgt, Governance and Compliance among others. He is also member of ISACA, OCEG, iTSMF and co-founder of Canadian Honeynet Project and Open Security Alliance among others. 28 Public Document <version 1.0> Contact Information Registered Office Mumbai: 12 Oricon House, 14, K. Dubash Marg Fort, Mumbai 400 001 Tel: +91 22 3253 7579; Fax:+91 22 2288 6152; Email: info@securematrix.in Technology Centre Pune: Trident Towers 2nd Floor, Pashan Road Bavdhan, Pune - 411021 Email: info@securematrix.in Technology Centre Chennai: Plot No. 1, Door No. 5, Venkateshwara Street, Dhanalakshmi Colony, Vadapalani, Chennai – 600026 Email: info@securematrix.in Dubai: P O Box 5207 Dubai Email: dubai@securematrix.in London: 16-20 Ealing Road Wembley Middlesex Hao 4TL Email: london@securematrix.in Bahrain * Atlanta 29 Public Document <version 1.0> Thank You ICAI, Mumbai 30 Public Document <version 1.0>