European Citizens’ Initiative Application for Certification of an Online Collection System in Ireland 1. The title of the proposed Citizens’ Initiative (max. 100 characters) ________________________________________________________________________ ________________________________________________________________________ 2. The subject matter of the proposed Citizens’ Initiative (max. 200 characters) ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 3. Outline the steps being taken in relation to the registration of the proposed initiative by the European Commission ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 4. Details of the location, including company name and address, where the Online Collection System infrastructure and the data collected is stored and contact details of people who control access to the site (all data relating to the Online Collection System must be stored in the Republic of Ireland - please see the note below entitled ‘Storage of Online Collection Systems Data’) ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 5. The full names, postal addresses, nationalities and dates of birth of the seven members of the citizens’ committee, indicating specifically the representatives designated as primary and substitute contacts for the certification process, as well as their email addresses and telephone numbers ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 6. Software has been made available to organisers by the EU for the online collection of statements of support. Is the Initiative that is the subject of this application using this software? (tick as appropriate) YES NO 7. Does the documentation being submitted with this application form fully satisfy the risk assessment requirements detailed below? (tick as appropriate) YES NO 8. Declaration: I, who have been designated under article 3.2 of Regulation (EU) No 211/2011 of the European Parliament and of the Council of 16 February 2011 to act on behalf of the citizens’ committee, (i) am satisfied that the Online Collection System which is the subject of this application complies with Article 6(4) of the above mentioned Regulation, (ii) confirm that all data collected through the Online Collection System certified by the Irish Competent Authority will be stored within and will not leave the Republic of Ireland at any time during the collection phase of this Citizens’ Initiative, and apply, accordingly, for certification of the system under Article 6(3) of Regulation (EU) No 211/2011 of the European Parliament and of the Council of 16 February 2011. Name: ______________________________ (PRINT) Signed:_______________________________ Dated: _______________________________ PLEASE READ NOTES BELOW NOTES “Regulation 211/2011” means Regulation (EU) No 211/2011 of the European Parliament and of the Council of 16 February 2011 on the Citizens’ Initiative and is available at http://eur-lex.europa.eu/JOHtml.do?uri=OJ:L:2011:065:SOM:EN:HTML “Regulation 1179/2011” means Commission Implementing Regulation (EU) No 1179/2011 of 17 November 2011 laying down technical specifications for online collection systems pursuant to Regulation (EU) No 211/2011 of the European Parliament and of the Council on the Citizens’ Initiative and is available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:301:0003:0009:EN:PDF S.I. No. 79 of 2012 – European Union (Citizens’ Initiative) Regulations 2012, which puts in place the arrangements that apply in Ireland to give effect to the European Union Citizens’ Initiative, provides as follows in relation to the certification of online collection systems: 4. Certification of Online Systems (1) Online Collection Systems submitted to the Competent Authority for certification shall include the technical and security features necessary to enable the Competent Authority to assess the compliance of the organisers’ online collection systems with Article 6(4) of Regulation 211/2011. (2) Online Collection Systems complying with Regulation 1179/2011 shall be regarded by the Competent Authority as meeting the requirements of Article 6(4) of Regulation 211/2011. Accordingly, Online Collection Systems should have adequate technical and security features in place to ensure that data is securely collected and stored. It is the responsibility of the Department of the Environment, Community and Local Government to verify the conformity of online collection systems certified in the Republic of Ireland with the requirements of Regulation 211/2011. The Online Collection System must be capable of ensuring that: only real persons (not computers) may submit a statement of support form data provided online are securely collected and stored the statements of support can be produced in the format that can be verified by the competent national authorities – this format is set out in the Schedule to S.I. No. 79 of 2012 The commission has developed open-source software that already complies with Points 1, 2(3) to 2(14) and 3(1) to 3(3) of the Annex to Regulation (EU) No 1179/2011. It is available at http://ec.europa.eu/citizens-initiative/public/software . Organisers need to ensure that the other elements of the Online Collection System - the hardware, hosting environment, business processes and staff – also comply with the remaining technical specifications. Organisers are not obliged to use this software – they may, if they wish, elect to develop their own Online Collection System. Risk Assessment Requirements: The application should include a comprehensive risk analysis, compliance assessment and vulnerability assessment of the whole system, covering hardware, environment, operating system, service configuration and backup system. The risk analysis must identify the scope of the system, highlighting business impact in case of various breaches in information assurance, enumerating the threats and vulnerabilities of the information system. It must produce a risk analysis document that also lists countermeasures to avoid such threats and remedies that will be taken if a threat occurs, and draw up a prioritised list of improvements. The risk analysis should fulfil the requirements of standard ISO/IEC 27001, short of adoption. Security controls based on the risk analysis should be chosen from standard ISO/IEC 27002 or the Information Security Forum’s ‘Standard of Good Practice’. More information on the issues these measures should address are detailed in section 2.2 of Regulation 1179/2011. These are listed below in Annex I. It is recommended that a penetration test be carried out to evaluate how vulnerabilities are exploitable and to identify possible attack paths. The penetration test should also propose solutions on how to remedy these vulnerabilities in order to make the system secure. The organisers must ensure that all possible solutions are put in place to ensure that the entire IT system is secure. In order to achieve this, it is recommended that the checks outlined in Annex II are followed prior to deploying the online collection system platform. Storage of Online Collection System Data: All data collected through the system must be stored within the Republic of Ireland. It is an offence under Regulation 6(f) of S.I. No. 79 of 2012 to store data in any other Member State where statements of support are collected on an online collection system certified by the Department of the Environment, Community and Local Government. Relevant Documentation: Organisers should refer to the following documents to assist in ensuring their online collection system is compliant with security standards, security best practices and Regulation 211/2011. Regulation 1179/2011 Common Weakness Enumeration (CWE) and in particular "potential mitigations" that are proposed to "contrast" a specific threat-vulnerability FIPS PUB 140-2 - Security requirements for cryptographic modules ISO/IEC 17799:2005 - Information technology — Security techniques — Code of practice for information security management ISO/IEC 27001:2005 - Information technology — Security techniques — Information security management systems — Requirements OWASP Application Security Verification Standard – Web Application Standard (for short OWASP ASVS) Note to Organisers: Certification of an Online Collection System by the Department of the Environment, Community and Local Government means that it provides the technical and security features necessary for certification in accordance with Article 6(3) of Regulation 211/2011. As such, it is not a guarantee of the security of the system or compliance with data protection legislation throughout the process of collection of statements of support. Organisers are reminded of the full range of their responsibilities in relation to online collection systems, statements of support and data protection, as set out in the relevant EU and Irish legislation. Regulation 211/2011, Regulation 1179/2011 and S.I. No. 79 of 2012 refer. Annex I Technical specifications from annex of Regulation 1179/2011 of the European Parliament and of the Council on the Citizens’ Initiative 1. TECHNICAL SPECIFICATIONS AIMING AT IMPLEMENTING ARTICLE 6(4)(a) OF REGULATION (EU) No 211/2011 In order to prevent automated submission of a statement of support using the system, the signatory goes through an adequate verification process in line with current practice before submission of a statement of support. One possible verification process is the use of strong ‘captcha’. 2. TECHNICAL SPECIFICATIONS AIMING AT IMPLEMENTING ARTICLE 6(4)(b) OF REGULATION (EU) No 211/2011 Information assurance standards 2.1. Organisers provide documentation showing that they fulfil the requirements of standard ISO/IEC 27001, short of adoption. For that purpose, they have: (a) performed a full risk assessment, which identifies the scope of the system, highlights business impact in case of various breaches in information assurance, enumerates the threats and vulnerabilities of the information system, produces a risk analysis document that also list countermeasures to avoid such threats and remedies that will be taken if a threat occurs, and finally draws up a prioritised list of improvements; (b) designed and implemented measures for treating risks with regard to the protection of personal data and the protection of family and private life and measures that will be taken in the case risk occurs; (c) identified the residual risks in writing; (d) provided the organisational means to receive feedback on new threats and security improvements. 2.2. Organisers choose security controls based on the risk analysis in 2.1(a) from the following standards: (1) ISO/IEC 27002; or (2) the Information Security Forum’s ‘Standard of Good Practice’ to address the following issues: (a) risk assessments (ISO/IEC 27005 or another specific and suitable risk assessment methodology are recommended); (b) physical and environmental security; (c) human resources security; (d) communications and operations management; (e) standard access control measures, in addition to those set forth in this Regulation; (f) information systems acquisition, development and maintenance; (g) information security incident management; (h) measures to remedy and mitigate breaches in information systems which would result in the destruction or accidental loss, alteration, unauthorised disclosure or access of personal data processed; (i) compliance; (j) computer network security (ISO/IEC 27033 or the SoGP are recommended).EN 18.11.2011 Official Journal of the European Union L 301/5 Application of these standards can be limited to the parts of the organisation that are relevant for the online collection system. For instance, human resources security can be limited to any staff that has physical or networking access to the online collection system, and physical/environmental security can be limited to the building(s) hosting the system. Functional requirements 2.3. The online collection system consists of a web-based application instance set up for the purpose of collecting statements of support for a single Citizens’ Initiative. 2.4. If administering the system requires different roles, then different levels of access control are established according to the principle of least privilege. 2.5. The publicly accessed features are clearly separated from the features destined for administration purposes. No access control hinders reading of the information available in the public area of the system, including information on the initiative and the electronic statement of support form. Signing up for an initiative is possible only via this public area. 2.6. The system detects and prevents submission of duplicate statements of support. Application level security 2.7. The system is suitably protected against known vulnerabilities and exploits. For this purpose it satisfies, inter alia, the following requirements: 2.7.1. The system guards against injection flaws such as structured query language (SQL) queries, lightweight directory access protocol (LDAP) queries, XML path language (XPath) queries, operating system (OS) commands or program arguments. For this purpose, it requires at least that: (a) all user input is validated; (b) validation is performed at least by the server-side logic; (c) all use of interpreters clearly separates untrusted data from the command or query. For SQL calls, this means using bind variables in all prepared statements and stored procedures, and avoiding dynamic queries. 2.7.2. The system guards against cross-site scripting (XSS). For this purpose, it requires at least that: (a) all user supplied input sent back to the browser is verified to be safe (via input validation); (b) all user input is properly escaped before it is included in the output page; (c) proper output encoding ensures that such input is always treated as text in the browser. No active content is used. 2.7.3. The system has strong authentication and session management, which requires at least that: (a) credentials are always protected when stored using hashing or encryption. The risk that someone authenticates using ‘pass-the-hash’ is mitigated; (b) credentials cannot be guessed or overwritten through weak account management functions (e.g. account creation, change password, recover password, weak session identifiers (IDs)); (c) session IDs and session data are not exposed in the uniform resource locator (URL); (d) session IDs are not vulnerable to session fixation attacks; (e) session IDs timeout, which ensures that users log out; (f) session IDs are not rotated after successful login; (g) passwords, session IDs, and other credentials are sent only over transport layer security (TLS);EN L 301/6 Official Journal of the European Union 18.11.2011 (h) the administration part of the system is protected. If it is protected by singlefactor authentication, then the password is composed of a minimum of 10 characters, including at least one letter, one number and one special character. Alternatively two-factor authentication may be used. Where only single-factor authentication is used, it includes a two-step verification mechanism for accessing the administration part of the system via the Internet, in which the single factor is augmented by another means of authentication, such as a onetime pass-phrase/code via SMS or an asymmetrically encrypted random challenge string to be decrypted using the organisers’/administrators’ private key unknown to the system. 2.7.4. The system does not have insecure direct object references. For this purpose, it requires at least that: (a) for direct references to restricted resources, the application verifies that the user is authorised to access the exact resource requested; (b) if the reference is an indirect reference, the mapping to the direct reference is limited to values authorised for the current user. 2.7.5. The system guards against cross-site request forgery flaw. 2.7.6. Proper security configuration is in place, which requires, at least, that: (a) all software components are up to date, including the OS, web/application server, database management system (DBMS), applications, and all code libraries; (b) OS and web/application server unnecessary services are disabled, removed, or not installed; (c) default account passwords are changed or disabled; (d) error handling is set up to prevent stack traces and other overly informative error messages from leaking; (e) security settings in the development frameworks and libraries are configured in accordance with best practices, such as the guidelines of OWASP. 2.7.7. The system provides for encryption of data as follows: (a) personal data in electronic format is encrypted when stored or transferred to the competent authorities of the Member States in accordance with Article 8(1) of Regulation (EU) No 211/2011, the keys being managed and backed up separately; (b) strong standard algorithms and strong keys are used in line with international standards. Key management is in place; (c) passwords are hashed with a strong standard algorithm and an appropriate ‘salt’ is used; (d) all keys and passwords are protected from unauthorised access. 2.7.8. The system restricts URL access based on the user access levels and permissions. For this purpose, it requires at least that: (a) if external security mechanisms are used to provide authentication and authorisation checks for page access, they need to be properly configured for every page; (b) if code level protection is used, code level protection needs to be in place for every required page. 2.7.9. The system uses sufficient transport layer protection. For this purpose, all of the following measures or measures of at least equal strength are in place: (a) the system requires the most current version of the hypertext transfer protocol secure (HTTPS) to access any sensitive resource using certificates that are valid, not expired, not revoked, and match all domains used by the site; (b) the system sets the ‘secure’ flag on all sensitive cookies; (c) the server configures the TLS provider to only support encryption algorithms in line with best practices. The users are informed that they must enable TLS support in their browser. 2.7.10. The system guards against invalidated redirects and forwards.EN 18.11.2011 Official Journal of the European Union L 301/7 Database security and data integrity 2.8. Where online collection systems used for different Citizens’ Initiatives share hardware and operating system resources, they do not share any data, including access/encryption credentials. In addition, this is reflected in the risk assessment and in the implemented countermeasures. 2.9. The risk that someone authenticates on the database using ‘pass-the-hash’ is mitigated. 2.10. The data provided by the signatories is only accessible to the database administrator/organiser. 2.11. Administrative credentials, personal data collected from signatories and its backup are secured via strong encryption algorithms in line with point 2.7.7(b). However, the Member State where the statement of support will be counted, the date of submission of the statement of support and the language in which the signatory filled in the statement of support form may be stored unencrypted in the system. 2.12. Signatories only have access to the data submitted during the session in which they complete the statement of support form. Once the statement of support form is submitted the above session is closed and the submitted data is not accessible anymore. 2.13. Signatories’ personal data are only available in the system, including the backup, in encrypted format. For the purpose of data consultation or certification by the national authorities in accordance with Article 8 of Regulation (EU) No 211/2011, organisers may export the encrypted data in accordance with point 2.7.7(a). 2.14. The persistence of the data entered in the statement of support form is atomic. That is, once the user has entered all required details in the statement of support form, and validates his/her decision to support the initiative, the system either successfully commits all of the form data to the database, or, in case of error, fails by saving no data at all. The system informs the user of the success or failure of his/her request. 2.15. The DBMS used is up to date and continuously patched for newly discovered exploits. 2.16. All system activity logs are in place. The system makes sure that audit logs recording exceptions and other security-relevant events listed below may be produced and kept until the data is destroyed in accordance with Article 12(3) or (5) of Regulation (EU) No 211/2011. Logs are adequately protected, for instance by storage on encrypted media. Organisers/administrators regularly check the logs for suspicious activity. Log contents include at least: (a) dates and times for log-on and log-off by organisers/administrators; (b) performed backups; (c) all database administrator changes and updates. Infrastructure security — physical location, network infrastructure and server environment 2.17. Physical security Whatever the type of hosting used, the machine hosting the application is properly protected, which provides: (a) hosting area access control and audit log; (b) physical protection of backup data against theft or incidental misplacement; (c) that the server hosting the application is installed in a secured rack. 2.18. Network security 2.18.1. The system is hosted on an Internet facing server installed on a demilitarised zone (DMZ) and protected by a firewall. 2.18.2. When relevant updates and patches of the firewall product become public, then such updates or patches are installed expediently. 2.18.3. All inbound and outbound traffic to the server (destined to the online collection system) is inspected by the firewall rules and logged. The firewall rules deny all traffic that is not needed for the secure use and administration of the system. 2.18.4. The online collection system must be hosted on an adequately protected production network segment that is separated from segments used to host non-production systems such as development or testing environments. EN L 301/8 Official Journal of the European Union 18.11.2011 2.18.5. Local area network (LAN) security measures are in place such as: (a) layer 2 (L2) access list/port switch security; (b) unused switch ports are disabled; (c) the DMZ is on a dedicated virtual local area network (VLAN)/LAN; (d) no L2 trunking enabled on unnecessary ports. 2.19. OS and web/application server security 2.19.1. A proper security configuration is in place including the elements listed in point 2.7.6. 2.19.2. Applications run with the lowest set of privileges that they require to run. 2.19.3. Administrator access to the management interface of the online collection system has a short session time-out (maximum 15 minutes). 2.19.4. When relevant updates and patches of the OS, the application runtimes, applications running on the servers, or anti-malware become public, then such updates or patches are installed expediently. 2.19.5. The risk that someone authenticates on the system using ‘pass-the-hash’ is mitigated. 2.20. Organiser client security For the sake of end-to-end security, the organisers take necessary measures to secure their client application/ device that they use to manage and access the online collection system, such as: 2.20.1. Users run non-maintenance tasks (such as office automation) with the lowest set of privileges that they require to run. 2.20.2. When relevant updates and patches of the OS, any installed applications, or anti-malware become public, then such updates or patches are installed expediently. 3. TECHNICAL SPECIFICATIONS AIMING AT IMPLEMENTING ARTICLE 6(4)(c) OF REGULATION (EU) No 211/2011 3.1. The system provides the possibility to extract for each individual Member State a report listing the initiative and the personal data of the signatories subject to verification by the Competent Authority of that Member State. 3.2. Exporting of signatories’ statements of support is possible in the format of Annex III to Regulation (EU) No 211/2011. The system may in addition provide for the possibility of exporting the statements of support in an interoperable format such as the extensible markup language (XML). 3.3. The exported statements of support are marked as being of limited distribution to the Member State concerned, and labelled as personal data. 3.4. The electronic transmission of exported data to the Member States is secured against eavesdropping using suitable end-to-end encryption. Annex II – Sugested guidelines and checks to follow prior to deploying the OCS platform Verify that all requirements defined in the technical specification have been implemented. In particular: Passwords, session IDs, and other credentials are sent only over Transport Layer Security (TLS). TS – point 2.7.3.g The system does not have insecure direct object references. TS – point 2.7.4 For direct references to restricted resources, the application verifies that the user is authorized to access the exact resource requested. TS – point 2.7.4.a If the reference is an indirect reference, the mapping to the direct reference is limited to values authorized for the current user. TS – point 2.7.4.b Proper security configuration is in place, which requires, at least, that: TS – point 2.7.6 a) All software components are up-to-date, including the OS, web/application server, Data Base Management System (DBMS), applications, and all code libraries. b) OS and web/application server unnecessary services are disabled, removed, or not installed. c) Default account passwords are changed or disabled. d) Error handling is set up to prevent stack traces and other overly informative error messages from leaking. e) Security settings in the development frameworks and libraries are configured in accordance with best practices, such as the guidelines of OWASP. The system requires the most current version of the Hypertext Transfer Protocol Secure (HTTPS) to access any sensitive resource using certificates that are valid, not expired, not revoked, and match all domains used by the site. TS – point 2.7.9.a The system sets the 'secure' flag on all sensitive cookies. TS – point 2.7.9.b The server configures the TLS provider to only support encryption algorithms in line with best practices. The users are informed that they must enable TLS support in their browser. TS – point 2.7.9.c The DBMS used is up-to-date and continuously patched for newly discovered exploits TS – point 2.15 A database activity log is in place. The system makes sure that audit logs recording exceptions and other security-relevant events listed below may be produced and kept until the data is destroyed in accordance with Article 12(3) or (5) of Regulation (EU) No 211/2011. Logs are adequately protected, for instance by storage on encrypted media. Organisers/administrators regularly check the logs for suspicious activity. Log contents include at least TS – point 2.16 a) Dates and times for log-on and log-off by organisers/administrators; b) Performed backups; c) All database administrator changes and updates. Physical security TS – point 2.17 Whatever the type of hosting used, the machine hosting the application is properly protected, which provides: a) Hosting area access control and audit log; c) Physical protection of backup data due to theft or incidental misplacement; d) That the server hosting the application is installed in a secured rack. The system is hosted on an internet facing server installed on a demilitarized zone (DMZ) and protected by a Firewall. TS – point 2.18.1 When relevant updates and patches of the Firewall product become public, then such updates or patches are installed expediently. TS – point 2.18.2 All inbound and outbound traffic to the server (destined to the online collection system) is inspected by the Firewall rules and logged. TS – point 2.18.3 The online collection system must be hosted on an adequately protected production network segment that is separated from segments used to host non-production systems such as development or testing environments. TS – point 2.18.4 Local Area Network (LAN) security measures are in place such TS – point 2.18.5 as: a) Layer 2 (L2) Access list / Port switch security; b) Unused switch ports are disabled; c) The DMZ is on a dedicated Virtual Local Area Network (VLAN)/LAN; d) No L2 trunking enabled on unnecessary ports. Administrator access to the management interface of the online collection system has a short session time-out (maximum 15 minutes). TS – point 2.19.3 When relevant updates and patches of the OS, the application runtimes, applications running on the servers, or anti-malware become public, then such updates or patches are installed expediently. TS – point 2.19.4 Organiser client security TS – point 2.20 For the sake of end-to-end security, the organisers take necessary measures to secure their client application/device that they use to manage and access the online collection system. Users run non-maintenance tasks (such as office automation) with the lowest set of privileges that they require to run TS – point 2.20.1 When relevant updates and patches of the OS, any installed applications, or anti-malware become public, then such updates or patches are installed expediently. TS – point 2.20.2 Verify that at least the security objective proposed by the Standard ISO27001 are implemented. Responsibility for asset All assets should be accounted for and have a nominated owner. ISO/IEC 27001:2005 Objective 7.1 Owners should be identified for all assets and the responsibility for the maintenance of appropriate controls should be assigned. The implementation of specific controls may be delegated by the owner as appropriate but the owner remains responsible for the proper protection of the assets. Secure Areas Critical or sensitive information processing facilities should be housed in secure areas, protected by defined security ISO/IEC 27001:2005 Objective 9.1 perimeters, with appropriate security barriers and entry controls. They should be physically protected from unauthorized access, damage, and interference. The protection provided should be commensurate with the identified risks. Equipment security Equipment should be protected from physical and environmental threats. ISO/IEC 27001:2005 Objective 9.2 Protection of equipment (including that used off-site, and the removal of property) is necessary to reduce the risk of unauthorized access to information and to protect against loss or damage. This should also consider equipment siting and disposal. Special controls may be required to protect against physical threats, and to safeguard supporting facilities, such as the electrical supply and cabling infrastructure. Third party service delivery management The organization should check the implementation of agreements, monitor compliance with the agreements and manage changes to ensure that the services delivered meet all requirements agreed with the third party. System planning and acceptance Advance planning and preparation are required to ensure the availability of adequate capacity and resources to deliver the required system performance. ISO/IEC 27001:2005 Objective 10.2 ISO/IEC 27001:2005 Objective 10.3 Projections of future capacity requirements should be made, to reduce the risk of system overload. The operational requirements of new systems should be established, documented, and tested prior to their acceptance and use. Protection against malicious and mobile code Precautions are required to prevent and detect the introduction of malicious code and unauthorized mobile code. Software and information processing facilities are vulnerable to the introduction of malicious code, such as computer viruses, network worms, Trojan horses, and logic bombs. Users should be made aware of the dangers of malicious code. Managers ISO/IEC 27001:2005 Objective 10.4 should, where appropriate, introduce controls to prevent, detect, and remove malicious code and control mobile code. Backup Routine procedures should be established to implement the agreed back-up policy and strategy for taking back-up copies of data and rehearsing their timely restoration. Network security management The secure management of networks, which may span organizational boundaries, requires careful consideration to dataflow, legal implications, monitoring, and protection. ISO/IEC 27001:2005 Objective 10.5 ISO/IEC 27001:2005 Objective 10.6 Additional controls may also be required to protect sensitive information passing over public networks. Media handling Media should be controlled and physically protected. ISO/IEC 27001:2005 Objective 10.7 Appropriate operating procedures should be established to protect documents, computer media (e.g. tapes, disks), input/output data and system documentation from unauthorized disclosure, modification, removal, and destruction. Exchange of information Exchanges of information and software between organizations should be based on a formal exchange policy, carried out in line with exchange agreements, and should be compliant with any relevant legislation (see clause 15). ISO/IEC 27001:2005 Objective 10.8 Procedures and standards should be established to protect information and physical media containing information in transit. Monitoring Systems should be monitored and information security events should be recorded. Operator logs and fault logging should be used to ensure information system problems are identified. An organization should comply with all relevant legal requirements applicable to its monitoring and logging activities. System monitoring should be used to check the effectiveness of controls adopted and to verify conformity to an access policy ISO/IEC 27001:2005 Objective 10.10 model. User access management Formal procedures should be in place to control the allocation of access rights to information systems and services. The procedures should cover all stages in the life-cycle of user access, from the initial registration of new users to the final deregistration of users who no longer require access to information systems and services. Special attention should be given, where appropriate, to the need to control the allocation of privileged access rights, which allow users to override system controls. Network access control Access to both internal and external networked services should be controlled. User access to networks and network services should not compromise the security of the network services by ensuring: ISO/IEC 27001:2005 Objective 11.2 ISO/IEC 27001:2005 Objective 11.4 a) appropriate interfaces are in place between the organization’s network and networks owned by other organizations, and public networks; b) appropriate authentication mechanisms are applied for users and equipment; c) control of user access to information services in enforced. Operating system access control Security facilities should be used to restrict access to operating systems to authorized users. The facilities should be capable of the following: a) authenticating authorized users, in accordance with a defined access control policy; b) recording successful and failed system authentication attempts; c) recording the use of special system privileges; d) issuing alarms when system security policies are breached; e) providing appropriate means for authentication; f) where appropriate, restricting the connection time of users. ISO/IEC 27001:2005 Objective 11.5 Application and information access control Security facilities should be used to restrict access to and within application systems. Logical access to application software and information should be restricted to authorized users. ISO/IEC 27001:2005 Objective 11.6 Application systems should: a) control user access to information and application system functions, in accordance with a defined access control policy; b) provide protection from unauthorized access by any utility, operating system software, and malicious software that is capable of overriding or bypassing system or application controls; c) not compromise other systems with which information resources are shared. Security requirements of information system Information systems include operating systems, infrastructure, business applications, off-the-shelf products, services, and userdeveloped applications. The design and implementation of the information system supporting the business process can be crucial for security. Security requirements should be identified and agreed prior to the development and/or implementation of information systems. ISO/IEC 27001:2005 Objective 12.1 All security requirements should be identified at the requirements phase of a project and justified, agreed, and documented as part of the overall business case for an information system. Cryptographic control A policy should be developed on the use of cryptographic controls. Key management should be in place to support the use of cryptographic techniques. Security of system file Access to system files and program source code should be controlled, and IT projects and support activities conducted in a secure manner. Care should be taken to avoid exposure of sensitive data in test environments. Technical vulnerability management ISO/IEC 27001:2005 Objective 12.3 ISO/IEC 27001:2005 Objective 12.4 ISO/IEC 27001:2005 Technical vulnerability management should be implemented in an effective, systematic, and repeatable way with measurements taken to confirm its effectiveness. These considerations should include operating systems, and any other applications in use. Objective 12.6 Reporting information security events and weaknesses ISO/IEC 27001:2005 Objective 13.1 Formal event reporting and escalation procedures should be in place. All employees, contractors and third party users should be made aware of the procedures for reporting the different types of event and weakness that might have an impact on the security of organizational assets. They should be required to report any information security events and weaknesses as quickly as possible to the designated point of contact. Management of information security incidents and improvements ISO/IEC 27001:2005 Objective 13.2 Responsibilities and procedures should be in place to handle information security events and weaknesses effectively once they have been reported. A process of continual improvement should be applied to the response to, monitoring, evaluating, and overall management of information security incidents. Where evidence is required, it should be collected to ensure compliance with legal requirements. Information security aspects of business continuity management A business continuity management process should be implemented to minimize the impact on the organization and recover from loss of information assets (which may be the result of, for example, natural disasters, accidents, equipment failures, and deliberate actions) to an acceptable level through a combination of preventive and recovery controls. This process should identify the critical business processes and integrate the information security management requirements of business continuity with other continuity requirements relating to such aspects as operations, staffing, materials, transport and facilities. The consequences of disasters, security failures, loss of service, and service availability should be subject to a business impact analysis. Business continuity plans should be developed and implemented to ensure timely resumption of essential ISO/IEC 27001:2005 Objective 14.1 operations. Information security should be an integral part of the overall business continuity process, and other management processes within the organization. Business continuity management should include controls to identify and reduce risks, in addition to the general risks assessment process, limit the consequences of damaging incidents, and ensure that information required for business processes is readily available. Compliance with legal requirements The design, operation, use, and management of information systems may be subject to statutory, regulatory, and contractual security requirements. ISO/IEC 27001:2005 Objective 15.1 Advice on specific legal requirements should be sought from the organization’s legal advisers, or suitably qualified legal practitioners. Legislative requirements vary from country to country and may vary for information created in one country that is transmitted to another country (i.e. trans-border data flow). Compliance with security policies and standards, and technical compliance The security of information systems should be regularly reviewed. Such reviews should be performed against the appropriate security policies and the technical platforms and information systems should be audited for compliance with applicable security implementation standards and documented security controls. ISO/IEC 27001:2005 Objective 15.2