CI - Developing and Implementing a Comprehensive Privacy and

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Mitigate Risk
March 23, 2004, 2pm
Carolyn Burke, MA, CISSP, CISM
CEO, Integrity Incorporated
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Things we should go over
 Background Information
 Identifying Risks
 Relationship between Privacy
& Security
 What Causes Security &
Privacy Risks
 Using a Risk Management
Approach
 Risk and Vulnerability
Assessment
 Security & Privacy
Management
Capabilities Maturity
Model
 Case Study!
 Protecting Privacy & Security
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But first, how mature
do you think you are?
• From 1 to 5, rate yourself:
• on policy, process & procedures
• on privacy & security
• on technology
1
2
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5
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Identifying Risks
What is at Risk?
Assets of the organization include
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Secrets
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Time, effort
People
What else is at Risk?
– Public trust in the organization
• PR risk
• May impede ability of the organization to operate effectively
– Operational capabilities of the organization
• Can be disrupted by unauthorized system modifications
• Can be disrupted by Denial of Service and Distributed Denial of
Service attacks
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And still more
– Your clients
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Privacy of clients’ personal information
Legally protected (legislation)
Contractually protected (policy, contract)
What information must be protected?
– Accuracy of clients’ personal information
• Legal requirements
• Operational necessity
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Identifying Risks
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The Relationship between
Privacy & Security
confidentiality
C
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integrity
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security
A
availability
What Causes
Security & Privacy Risks
•Technical vulnerabilities
•Fraud
•Operational issues
•The bad guys
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Technical vulnerabilities
• Technical faults
• Software bugs, incorrect documentation
• Misconfiguration
– software, servers, firewalls / security systems, routers
– various other network elements
• Hardware failure
– lack of redundancy
– poor maintenance schedule
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More technical vulnerabilities
• Poor technical architecture
• Lack of
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appropriate perimeter defenses
intrusion detection systems
adequate access controls
adequate authentication systems
adequate authorization controls
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Fraud
• Intentional misrepresentation
•
•
•
•
By clients
By staff
By company executives
External parties misrepresenting the company
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Operational issues
– Insufficient checks & balances
• peer review
• periodic internal review
• external audit
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Do you have:
 a security awareness program
 a readable security policy
 an incident response plan
Human error
Faulty procedures
Undocumented or missing procedures
Lack of standardization
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More operational issues
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Lack of a clear policy framework
Poor real-time handling of security incidents
Lack of privacy awareness among all staff
Lack of security awareness among all staff
Extreme shortage of security skills among IT staff
Do you have:
 a business continuity plan
 a disaster recovery plan
 a backup and recovery system
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Bad guys
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Amateur hackers
Well-intentioned researchers
Malicious professionals
Financially motivated professionals (your loss,
their gain)
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What Causes Security &
Privacy Risks
What high-level approach does your
organization use today to address security
& privacy issues?
• How effective is it?
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The Risk Management
Approach to Security &
Privacy Strategy
You can’t eliminate 100% of risks…
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The Risk Management
Approach to Security &
Privacy Strategy
… but you can develop a risk
management framework which...
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A Risk Management Framework
– takes a strategic approach
– provides a disciplined cost-benefit framework
– establishes clear high-level policies to guide
tactical decision-making
– provides detailed processes & procedures
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A Risk Management Framework
– specifies appropriate levels of protection
(technical & procedural) based on sound
analysis of vulnerabilities & resulting risks
– sets technical standards
– justifies security & privacy expenditures on
both an economic & a legislative basis
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The Risk Management
Approach: Key Components
 Driven by risk analysis
– Types of risks X Probabilities of risk X Costs of losses
– Types of risk mitigation - impact on probabilities and losses
 High-level security & privacy mandate - policies!
 Accountability in all risk-related activities
 Success factors
– Continuous Improvement
– Dynamic response to new threats
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Continuous Security Framework
Okay, this is for the CSO.
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Continuous Security Framework
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Continuous Security Framework
Metrics & Continuous
Improvement
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Continuous Security Framework
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The Risk Management Approach
to Security & Privacy Strategy
Map out the high-level steps your
organization needs to take to use a riskmanagement approach to privacy and
security.
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Risk and Vulnerability
Assessment
Risk vs. Vulnerability
Risk is economic & legal
Vulnerability is technical & procedural
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Quantifying risk
Economic Risk ($) =
Types of risks  Probabilities of risk (%)  Costs of losses ($)
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Assessing vulnerability
– Technical
• Attack & Penetration Testing
• Network Security Review
– Procedural
• Privacy Impact Assessment
• Policy Audit
• Processes & Procedures Audit
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Risk and Vulnerability
Assessment
Estimate the outcomes which would result if your
organization were to undergo:
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A thorough Attack & Penetration test?
A thorough Network Security Review?
A thorough Privacy Policies Audit?
A thorough Operational Security
(Processes & Procedures) Audit?
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Protecting Privacy & Security
Technology solutions
Procedural solutions
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Technology solutions
– Firewalls  privacy, integrity, authentication
– Encryption  privacy
• Includes SSL (for web traffic), IPSec VPNs (for
remote network access), PGP and SMIME (for
email), etc.
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Technology solutions
– Passwords  authentication
• Risks: reusable passwords, plaintext protocols
– Tokens  authentication
– Certificates  authentication
– Intrusion Detection Systems / IDS 
integrity, privacy
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Technology solutions
– Digital signatures  integrity, authentication,
non-repudiation
– PKI  privacy, authentication, integrity, nonrepudiation
– PMI  authorization, privacy, authentication,
integrity
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Procedural solutions
– “Need to know” (principle of least privilege)
 privacy
– Change controls  privacy, authentication,
integrity, non-repudiation
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Procedural solutions
– Audit processes  increased assurance re. all
factors
– Technical standardization  privacy,
authentication, integrity, non-repudiation
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Protecting Privacy & Security
• What are the primary methods
(procedural / technological)
used by your organization to:
– Protect privacy
– Perform authentication
– Ensure non-repudiation for
online transactions
– Maintain data and systems
integrity
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Security & Privacy Management
Capabilities Maturity Model (TM)
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Security & Privacy Management
Capabilities Maturity Model (TM)
– Measuring success using a baseline
• Proprietary, standardized
• Based on CERT’s Systems Security Engineering
Capability Maturity Model
– Provides maturity metrics on high-level
organizational security and privacy
capabilities
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SPM-CMM(TM) Level 1
– Organization handles Security &
Privacy issues informally
– Organization does not have documented
Security & Privacy policies
1
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SPM-CMM(TM) Level 2
– Organization has documented Security & Privacy policies
– Organization has assigned resources to plan Security &
Privacy initiatives
– Effective training programs re. Security & Privacy
– Organization has effective processes to verify compliance
with Security & Privacy policies
2
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SPM-CMM(TM) Level 3
– Organization has concrete Security & Privacy standards
& requirements (policies, procedures, technical
standards)
– Organization has effective processes to verify
consistency of all activities with Security & Privacy
standards & requirements
3
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SPM-CMM(TM) Level 4
– Organization has measurable, quantitative
Security & Privacy goals
– Organization tracks objective performance
relative to Security & Privacy goals
– Strong individual accountability
4
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SPM-CMM(TM) Level 5
– Organization has an effective Continuous
Improvement program for Security & Privacy
– Organization has defined improvement goals,
causal analysis of Security & Privacy
performance issues, and systematic incremental
feedback
5
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Security & Privacy Management
Capabilities Maturity Model (TM)
5
1
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Security & Privacy Management
Capabilities Maturity Model (TM)
• Important considerations:
– What is the impact of moving to the next maturity
level?
– What changes to technologies, processes, and policy
would you need to make?
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Long-Distance Health Care /
Privacy
•Public sector health care network enabling doctor-to-doctor communication
between urban specialists and remote patients/hospitals/GPs
•Cost effective communication required - a private network using internet
technologies
•Maintain privacy - information shared between organizations, across borders
•Security technology, policy reviews
•Privacy policies of all organizations amalgamated
•Most stringent policy had to apply to all to ensure that all policies were met
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SPM-CMM(TM) Level 1
Level 2
Results
• Policy review for all organizations
• Co-ordination of all co-operating institutions’ privacy
policies so that they were amalgamated and covered; had
to use the most stringent policy
• Training to properly handle exchange of information varying legislative jurisdictions
Services
• Needs Assessment, Privacy Impact Assessment, Gap
Analysis, Policy Writing, Training
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Where do you rank your
organization on the SPM-CMM(TM)?
For security? For privacy?
Overall?
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Thank you!!!!
Carolyn Burke, MA, CISSP, CISM
CEO, Integrity Incorporated
www.integrityincorporated.com/subscribe.aspx
Copyright
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2004
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Mitigate Risk
March 23, 2004, 2pm
www.integrityincorporated.com/subscribe.aspx
Carolyn Burke, MA, CISSP, CISM
CEO, Integrity Incorporated
Copyright
Copyright
2004
2004
Integrity
Integrity
Incorporated
Incorporated
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