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2010 Secure World Boston Nist

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Presentation on using the NIST Risk Mgmt Framework to comply with FISMA, HIPAA and State Data Privacy Requirements

Presentation on using the NIST Risk Mgmt Framework to comply with FISMA, HIPAA and State Data Privacy Requirements

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  • 1. NIST, FISMA, HIPAA and Data Privacy – Where to Begin Candy Alexander, CISSP CISM SecureWorld Expo Boston March 24, 2010 Room 104 SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 2. Topics Setting the stage for a Case Study Understanding the requirements How can NIST help Closer look at NIST Summary SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 3. Setting the Stage Organization driven by multiple requirements FIMSA HIPAA* Data Privacy (45 states and the Feds) MA 201 CMR17 Small organization with minimal resources Need to work smart Identify 1 size to fit all requirements (framework) Existing work based on HIPAA Privacy & Security rules Redirect into the NIST framework to meet *all* requirements * Additional push with new HITECH Act – Summary of changes at end of slides SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 4. Understanding the Requirements… Need to understand business requirements Compliance (just enough or to protect) Big budget or barely enough Frameworks available ISO ($$$) COBIT ($$) NIST (free) Do it yourself ($?) All of these + Notification process* Federal Contractor, we used NIST Risk Management Framework (RMF) for SP800-53 SP800-66-Rev.1 SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 5. Using the NIST Risk Management Framework (RMF)* SecureWorld Expo - Boston - March 24, 2010 - Room 104 * NIST SP800-66 Rev. 1 October 2008
  • 6. Step 1 – Categorize Information and Assets FIPS199 to identify CIA (confidentiality, Integrity and Availability) rating score Great tool for communicating risk to businesses. PHI (Protected Health Information) the “C” and “I” should be high – availability is up to process owner Identify PII (Personal Identifiable Information) and business owner (supports data privacy requirements) Identify “where” in the organization PII/PHI is (applications, folders, etc.) Supports the PHI tracking requirement for HIPAA Use NIST SP800-60 for guidance SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 7. Step 2 – Security Controls Use FIPS 200 to identify the minimum baseline Select controls to be used Identified in SP800-53 (Rev.3) that are appropriate to the environment (risk approach) Document controls/requirements into a security plan for each IT System. NIST SP800-18 Guide for Developing Security Plans for Federal Information Systems SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 8. Step 3 – Implement Security Controls Uses various automated tools and manual processes Operating system controls Application controls System Development Life Cycle Full array of publications available to provide guidance to the specific topic/requirement See http://csrc.nist.gov Special Pubs, FIPS pubs, IR (internal reports), and ITL (Info Tech Lab) Bulletins SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 9. Step 4 - Assess Controls Evaluate the controls with SP800-53A Internal Audits External Audits SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 10. Step 5 – Authorize Information System Authorization to Operate (ATO) Primarily for FISMA compliance Essentially Designation Authority reviews controls and evaluation of controls – then authorizes use with an explicit decision to accept the risk Not a BAD idea for getting executives to understand, review and accept the risk SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 11. Step 6 – Monitor Security Continuous monitoring Threats & vulnerabilities Controls put into place to mitigate risk Ensure all is effective and as intended Ensure documentation is updated Conduct impact analysis SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 12. FISMA… Certification & Accreditation What is Certification and Accreditation? Certification and Accreditation is a process that ensures that systems and major applications adhere to formal and established security requirements that are well documented and authorized. 1 Sound a little like MA 201 CMR17? Obtaining the C&A removes the uncertainty of compliance Much like a ISO, PCI and SAS70 Type II? Auditors appreciate the structure 1 e-Articles.info on ask.com SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 13. FISMA/NIST C&A C&A guidance available through SP800-37 Provides accrediting authority ( and auditors) high degree of confidence that the managerial, technical and op security controls work as intended & that the information processed, stored and transmitted with the system is protected. Controls based on FIPS 199, 200 and NIST SP800-66 (HIPAA) and SP800-53 C&A should be completed prior to production and re-accredited when significant change occurs, as directed by the agency contract/ authorizing official or at minimum every three years. SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 14. C & A Phases Consists of 4 distinct phases 1. Initiation Phase 2. Security Certification Phase 3. Security Accreditation Phase 4. Continuous Monitoring Phase Each phase has a detailed list of tasks and subtasks, documents and artifacts that are used to support the next phase SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 15. Certification Package* 1. Updated System Security Plan 2. Completed Security Risk Assessment 3. Updated Config. Mgmt Plan 4. Contingency Mgmt Plan(s) 5. Security Test & Eval. Report 6. User Manuals 7. Interconnection Security Agreements or MOUs (Business Associates Agreements for HIPAA) 8. Privacy Impact Assessments 9. Federal Register System of Record Notice 10. Plan of Action & Milestones *Exact contents are defined by Information System Owner SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 16. Accreditation Package 1. Security Assessment Report 2. Security Accreditation Decision Letter 3. System Security Plan 4. Plan of Action & Milestones SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 17. HITECH Act - Tougher HIPAA From Privacy/Security Perspective: Breach Notification (tougher requirements) Wider scope – including BAs (2/17/10) Account of disclosures (more rigorous) Enforcement (2/17/10) – increased $$$ State AG’s enforcement SecureWorld Expo - Boston - March 24, 2010 - Room 104
  • 18. Questions? Candy Alexander, CISSP CISM calexander@ltcpartners.com SecureWorld Expo - Boston - March 24, 2010 - Room 104