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Cyber Security Consulting, IT Audit & Assessment
Services
Protecting Information in the Enterprise




Grant Thornton, LLP
A QSA Company


Danny Miller, CISA, CGEIT, CRISC, ITIL
April 2012
                                           -1-   © Grant Thornton LLP. All rights reserved.
Grant Thornton overview
At-a-glance

Founded in 1924, Grant Thornton LLP is the U.S. member firm of Grant
Thornton International. Through member firms in more than 80 countries
including 50 offices in United States, the partners of Grant Thornton provide
personalized attention and the highest quality of service to companies around the
globe.
                                                     Grant Thornton            Grant Thornton
                                  Statistics
                                                     International Ltd            LLP

                                  Revenues           $ 4 billion               $ 1.2 billion

                                  Personnel          29,890                    5,505

                                  Partners           2,539                     540

                                  Offices            498                       52

                                  Statistics as of   Sept. 30, 2008            July 31, 209



                                             -2-                   © Grant Thornton LLP. All rights reserved.
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  Grant Thornton's Cyber Security Solution Practice

Grant Thornton's Cyber Security practice is focused on protecting the enterprise's information no
matter where it is. In this age of distributed, mobile and cloud-based systems and data, it is vitally
important to understand how information is created, processed, transmitted and stored.


We address our client's complex security requirements through a variety of consulting support,
including strategy, information protection, data leakage, assessing security vulnerabilities, advising
on establishing or improving the operations of a security organization, remediating compliance
failures or gaps – including gaps related to PCI and HIPAA/HITECH compliance and developing
approaches and programs to effectively assess and manage risk by implementing appropriate
security countermeasures through the entire life cycle of information in the enterprise.


                                                            -3-                  © Grant Thornton LLP. All rights reserved.
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 Our IT Audit Services
 Our approach to technology risk is compatible with all major frameworks, including COSO,
  the latest Risk IT framework from ISACA and fills the gaps that other frameworks do not
  provide. We also cover application risk with a lens from the Global Technology Audit Guides
  (GTAG) from the IIA.
 The team that will be managing and executing this engagement have more than 90 years of
  combined technology experience in industry, Big-4 consultancy and as practitioners. Their
  credentials include one or more of CPA, CIA, CISA, CISM, CISSP, GAWN, GCWN, CCNP,
  CCNA, or MCSE, ITIL, CGEIT
 Grant Thornton has a long history of consulting in the Oil, Gas and Chemicals Industry.
  Relevant clients include:
          Sunoco                                                   Lyondell Chemical
          Quaker Chemical                                          Amerigas
          Philadelphia Gas Works                                   Airgas
          Donegal Insurance                                        Valspar Corporation

                                                           -4-                  © Grant Thornton LLP. All rights reserved.
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                                                                               ©2010 ISACA. All rights reserved.
                                                          -5-                       © Grant Thornton LLP. All rights reserved.
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Guiding Principles of IT Risk Management

 Ensure a connection to enterprise objectives and enterprise risk
 Align the management of IT-related business risk with overall enterprise risk
  management
 Balance the costs and benefits of managing risk
 Establish the right tone from the top while defining and enforcing personal
  accountability for operating within acceptable and well-defined tolerance levels
 Risk is a continuously changing landscape and risk management acknowledges that it
  is a continuous process




                                                          -6-                  © Grant Thornton LLP. All rights reserved.
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Grant Thornton Cyber Security services
  - Information protection at all levels
  - Data Leakage detection and prevention
  - Security Strategy and Design
  - Threat Analysis
  - Vulnerability Assessments
  - Penetration Testing
  - Anti-phishing consulting
  - Risk-event consulting
  - Data Privacy & Protection
  - PCI Data Security Standards QSA Consulting
  - HIPAA
                                                          -7-                  © Grant Thornton LLP. All rights reserved.
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Grant Thornton's Cyber Security Services
• Experienced and dedicated cyber security personnel
        – Deep technical background – real expertise in cybersecurity
        – Experience across industries
        – Practical and cost effective strategies to mitigate risk
• Address the security risk within the context of business risk
        – Understand the relationship of IT risk management within overall
          enterprise risk management
        – Communicate technical risks using layman terms and business impact
• Proven cyber security methodologies, tools, and techniques



                                                          -8-                  © Grant Thornton LLP. All rights reserved.
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Cybersecurity Life Cycle and Service Components
           Life Cycle                                                                                                         ITIL* Framework
                                         Solution Set                            Activities/Scope
          Component                                                                                                             Component
    Policy                        Strategy and Assessment            Develop and test policy, best practices               Plan/Maintain
                                                                     Risk, Data privacy and classification,
                                                                     Breaches, Programs, Monitoring, PCI,
                                  Strategy and Design,               HIPAA, Vulnerability and Penetration
    Assess                        Threats                            testing, Cloud, Agreements with third
                                                                                                                           Evaluate
                                                                     parties, Service Level Agreements (SLA),
                                                                     Operational Level Agreements (OLA)
                                                                     Threat Profiling, PCI, HIPAA, IDS/IPS,
                                                                     VPN, Firewalls, SIM/SEM, Application
                                  Plan, Design and
    Implement                     Implement
                                                                     (including Cloud-based), SDLC, Data                   Implement
                                                                     classification, Data privacy (state, federal,
                                                                     international)
                                                                     Threats, Incidents, Master Data
                                  Risk, Policy, Standards,           Management (MDM),IT Audits, Self
    Manage                        Procedures, Programs               Assessment, Penetration and
                                                                                                                           Control/Maintain
                                                                     Vulnerability, Communication, Response
                                                                     Threat reduction, Countermeasures, Data
                                  Investigate, Respond,
    Respond                       Remediate
                                                                     leakage and breaches, PCI breaches,                   Control/Maintain
                                                                     HIPAA information exposure
      * - The IT Infrastructure Library (ITIL) is a global framework for service management and is the most widely accepted approach to managing
      information technology. Services are assets from which the customer gains value, hence cybersecurity is one of those services.


                                                                                 -9-                              © Grant Thornton LLP. All rights reserved.
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Cyber Security Strategy & Design

                                                          Based upon the IT Infrastructure Library (ITIL)
                                                          framework of best practices in IT, the ITIL
                                                          Information Security Management's (ISM) strategy
                                                          goal is the alignment of IT security with business security
                                                          to ensure that information security is effectively managed
                                                          in all service and Service Management activities.

                                                          This strategy includes managing risk and security over
                                                          information assets while balancing the needs of the
                                                          business for:
                                                               • Availability of information and assets
                                                               • Confidentiality of information
                                                               • Integrity of information




                                                               - 10 -                  © Grant Thornton LLP. All rights reserved.
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The problem with "Big Data"




                                      Attribution: Cloud Security Alliance (CSA)

                                                             - 11 -                  © Grant Thornton LLP. All rights reserved.
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Vulnerability assessment vs. Penetration test

• The terms "vulnerability assessment" and "penetration test" are
  sometimes used interchangeably, so it's important to define and
  distinguish them.
• Vulnerability assessment
        – a service that provides a comprehensive prioritized identification of
          vulnerabilities, but does not attempt to exploit them.

• Penetration test
        – a goal oriented service that attempts to gain unauthorized access to a
          specified target by exploiting one or more vulnerabilities.


                                                          - 12 -                  © Grant Thornton LLP. All rights reserved.
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Other assessment services
 Wireless Assessment
    − a service that assesses the security mechanisms (e.g.,
       authentication, encryption) of a wireless network, and
       attempts to identify rogue access points.
 Web Application Security Assessment
    − a service that assesses the security of a web application,
       including session management, authentication, authorization,
       and input validation.
 Voice Over IP (VoIP) Security Assessment
    − a service that assesses the security of a deployed VoIP
       infrastructure, including the infrastructure support, the VoIP
       components, and the VoIP protocols.
 Data Leakage Prevention Assessment
    − a service that measures an organization's risk of information
       leakage.
                                                          - 13 -                  © Grant Thornton LLP. All rights reserved.
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Privacy
 Information Trends

 • Every day, companies collect, use, profile, disclose, and analyze customer
   information
 • Employees who have access to sensitive information inside an
   organization also represent a key risk – we see this as the fastest rising
   threat
 • Unfortunately, some of this information is:
         •       Misused
         •       Stolen
         •       Sold , traded or given to organizations (e.g., WikiLeaks)
 • This has led to a trust gap among customers, employees and corporate
   leadership

                                                             - 14 -                  © Grant Thornton LLP. All rights reserved.
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Privacy
       Personally Identifiable Information (PII)
       Personal information is any information that is, or reasonably could be,
       attributable to a specific individual. The information can be either factual or
       subjective, and recorded in any form or even unrecorded. Some examples
       include:

                 Social Security number
                 Driver's license number or state-issued identification card number
                  financial account number, credit card number, or debit card number
                 Name, address, email address
                 Credit records
                 Buying history
                 Employee records

       Much of this information is sensitive and greater cause for concern.
                                                             - 15 -                  © Grant Thornton LLP. All rights reserved.
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Privacy
 Information stakeholder concerns
 • Customers
         – Concerned with how and why their information is collected, used,
           disclosed, and retained
         – Want businesses to earn trust
 • Businesses
         – Trying to strike a balance between collection and use of information
         – Concerned with reducing privacy risk of poor privacy practices
         – Want to leverage good privacy practices and retain trust of customers
 • Government
         – Taking increased action on growing concerns about privacy to:
         – Protect rights of citizens
         – Better manage its own data stores


                                                          - 16 -                  © Grant Thornton LLP. All rights reserved.
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HIPAA
 GT Healthcare IT Security Offerings:
 • IT Security Risk Assessment
 • IT Security Program Implementation Assistance
 • IT Security/HIPAA Review and Recommendations
 • HIPAA Compliance Attestation Report




                                                          - 17 -                  © Grant Thornton LLP. All rights reserved.
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HIPAA
IT Security Risk Assessment




                                                          - 18 -                  © Grant Thornton LLP. All rights reserved.
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 HIPAA
IT Security Program Implementation Assistance
• Based on HIPAA/ISO/CobiT/NIST
• IT Security Risk Assessment
• Policies
• Procedures
• Business Impact Analysis
• Incident Management Program
• Security Awareness Program
• IT Contingency Plans/Updated DRP
• Vulnerability Assessment/Pen Tests
• Controls Testing




                                                           - 19 -                  © Grant Thornton LLP. All rights reserved.
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HIPAA
IT Security/HIPAA Review and Recommendations
• Evaluate and test:
    – Administrative safeguards,
    – Physical safeguards
    – Technical safeguards
    – Organizational safeguards
    – Policies, Procedures and
      Documentation Requirements




                                                          - 20 -                  © Grant Thornton LLP. All rights reserved.
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HIPAA
HIPAA Compliance Attestation Report and Readiness Review
Similar to SAS70, except opinion on HIPAA Compliance
                                                                     • Evaluate and reaffirm the appropriateness of the
                                                                       design of processes and controls with management
      Criterion           Observation             Reporting
      Definition          and testing                                • Evaluate and reaffirm management’s interpretation of
                                                                       compliance to ensure that the defined criterion are
                                                                       measurable, objective and will be understood by any
                     Management Checkpoints                            readers of the report


•    Test the operating effectiveness of identified controls for the testing period
•    Determine whether controls were operating effectively throughout the testing period
•    Confirm the validity of identified findings with the process owner and inform management of validated findings
•    Evaluate the significance of any instances of non-compliance with the specified criterion




                                                                 - 21 -                   © Grant Thornton LLP. All rights reserved.
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Privacy Assessment Approach

                 1                            2                               3                            4
          Information                   Identify Scope                    Gap Analysis        Remediation Planning &
           Collection                     Reduction                                                 Roadmap
                                        Opportunities
        Identify entry points          Reduce / modify data           Conducted Gap                 Recommendation
        Develop process                collection                     Analysis with                 remediation projects
        flows                          Reduce data storage            Enhanced Privacy              Develop prioritized
        Map flows onto IT              Modify business                Framework                     approach
        infrastructure                 processes
        Leverage DLP to
        validate



      Gained an understanding of       Reduced Scope and Risk      Created Gap analysis         Remediation plan
      the environment                                              document with gap
                                                                   prioritization




                                                                 - 22 -                   © Grant Thornton LLP. All rights reserved.
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Payment Card Industry Data Security Standard (PCI DSS)
       The Payment Card Industry Data                                Major payment card security
        Security Standard (PCI-DSS) is a set                             breaches since 2005
        of comprehensive requirements for the
        protection of payment card                                                • Card Systems

        information.                                                 2005         • 40 Million Cards, Processing Ability
                                                                                    Revoked by Visa and MasterCard



       The PCI-DSS is managed by the PCI                                         • TJX

        Security Standards Council (PCI-SSC)                         2007         • At least 45.7 Million Customers Affected,
                                                                                    Over $250 Million in costs

        and sponsored by the major card
        brands.                                                                   • Hannaford Foods
                                                                     2008         • 4.2 Million Cards, Validated Compliant at time
                                                                                    of breach, Liability and Results Pending

       The PCI-DSS is applicable to any
        organization that stores, processes or                                    • Heartland Payment Systems

        transmits cardholder data (CHD).                             2009         • Potentially more than 100 Million cards
                                                                                    compromised and untold amounts of resulting
                                                                                    damages




                                                          - 23 -                  © Grant Thornton LLP. All rights reserved.
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Payment Card Industry Data Security Standard (PCI DSS)
PCI DSS high level requirements
The PCI DSS prescribes requirements that any business of any size must adhere to in order to
accept payment cards.




                                                          - 24 -                  © Grant Thornton LLP. All rights reserved.
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What information must be protected?
                                                                                                 Storage              Protection      Encryption
                                                               Data Element
                                                                                                Permitted              Required        Required

                                                       Primary Account Number (PAN)                Yes                   Yes               Yes

                                                             Cardholder Name                       Yes                   Yes               No
                       Cardholder Data
                                                                Service Code                       Yes                   Yes               No

                                                               Expiration Date                     Yes                   Yes               No

                                                          Full Magnetic Stripe Data                No                    N/A              N/A

                 Sensitive Authentication Data             CAV2/CVC2/CVV2/CID                      No                    N/A              N/A

                                                               PIN/PIN Block                       No                    N/A              N/A




                                                                               - 25 -                       © Grant Thornton LLP. All rights reserved.
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Payment Card Industry Data Security Standard (PCI DSS)
 Some common PCI DSS myths:
 •     PCI doesn’t apply to us because:
         – We don’t take enough credit cards, or
         – It only applies to retailers and ecommerce
 •     PCI makes us store cardholder data
 •     We are compliant because we:
         – Encrypt our cardholder data, or
         – Use vendor/product ABC, or
         – Outsource our credit card processing
 •     PCI compliance is an IT project
 •     PCI will make us secure
 •     We completed our SAQ so we’re compliant

                                                          - 26 -                  © Grant Thornton LLP. All rights reserved.
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Payment Card Industry Data Security Standard (PCI DSS)

  Grant Thornton PCI DSS Capabilities
  Current capabilities:
  •     An experienced Qualified Security Assessor Company (QSAC) with a significant
        number of QSA's in our practice across two countries
  •     Client base that we can reference from in the QSA space
  •     Extensive PCI DSS consulting experience
  •     Performing PCI DSS penetration testing and risk assessments
  •     Performing PCI DSS readiness assessments for all merchant levels




                                                          - 27 -                  © Grant Thornton LLP. All rights reserved.
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Contact information


 Danny Miller
 Grant Thornton LLP
 Principal & Practice Leader
 Tel: 215.376.6010 | email: Danny.Miller@us.gt.com




 Or e-mail cybersecurity@us.gt.com




                                                          - 28 -                  © Grant Thornton LLP. All rights reserved.

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Cybersecurity It Audit Services Gt April2012

  • 1. Cyber Security Consulting, IT Audit & Assessment Services Protecting Information in the Enterprise Grant Thornton, LLP A QSA Company Danny Miller, CISA, CGEIT, CRISC, ITIL April 2012 -1- © Grant Thornton LLP. All rights reserved.
  • 2. Grant Thornton overview At-a-glance Founded in 1924, Grant Thornton LLP is the U.S. member firm of Grant Thornton International. Through member firms in more than 80 countries including 50 offices in United States, the partners of Grant Thornton provide personalized attention and the highest quality of service to companies around the globe. Grant Thornton Grant Thornton Statistics International Ltd LLP Revenues $ 4 billion $ 1.2 billion Personnel 29,890 5,505 Partners 2,539 540 Offices 498 52 Statistics as of Sept. 30, 2008 July 31, 209 -2- © Grant Thornton LLP. All rights reserved.
  • 3. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Grant Thornton's Cyber Security Solution Practice Grant Thornton's Cyber Security practice is focused on protecting the enterprise's information no matter where it is. In this age of distributed, mobile and cloud-based systems and data, it is vitally important to understand how information is created, processed, transmitted and stored. We address our client's complex security requirements through a variety of consulting support, including strategy, information protection, data leakage, assessing security vulnerabilities, advising on establishing or improving the operations of a security organization, remediating compliance failures or gaps – including gaps related to PCI and HIPAA/HITECH compliance and developing approaches and programs to effectively assess and manage risk by implementing appropriate security countermeasures through the entire life cycle of information in the enterprise. -3- © Grant Thornton LLP. All rights reserved.
  • 4. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Our IT Audit Services  Our approach to technology risk is compatible with all major frameworks, including COSO, the latest Risk IT framework from ISACA and fills the gaps that other frameworks do not provide. We also cover application risk with a lens from the Global Technology Audit Guides (GTAG) from the IIA.  The team that will be managing and executing this engagement have more than 90 years of combined technology experience in industry, Big-4 consultancy and as practitioners. Their credentials include one or more of CPA, CIA, CISA, CISM, CISSP, GAWN, GCWN, CCNP, CCNA, or MCSE, ITIL, CGEIT  Grant Thornton has a long history of consulting in the Oil, Gas and Chemicals Industry. Relevant clients include:  Sunoco  Lyondell Chemical  Quaker Chemical  Amerigas  Philadelphia Gas Works  Airgas  Donegal Insurance  Valspar Corporation -4- © Grant Thornton LLP. All rights reserved.
  • 5. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services ©2010 ISACA. All rights reserved. -5- © Grant Thornton LLP. All rights reserved.
  • 6. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Guiding Principles of IT Risk Management  Ensure a connection to enterprise objectives and enterprise risk  Align the management of IT-related business risk with overall enterprise risk management  Balance the costs and benefits of managing risk  Establish the right tone from the top while defining and enforcing personal accountability for operating within acceptable and well-defined tolerance levels  Risk is a continuously changing landscape and risk management acknowledges that it is a continuous process -6- © Grant Thornton LLP. All rights reserved.
  • 7. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Grant Thornton Cyber Security services - Information protection at all levels - Data Leakage detection and prevention - Security Strategy and Design - Threat Analysis - Vulnerability Assessments - Penetration Testing - Anti-phishing consulting - Risk-event consulting - Data Privacy & Protection - PCI Data Security Standards QSA Consulting - HIPAA -7- © Grant Thornton LLP. All rights reserved.
  • 8. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Grant Thornton's Cyber Security Services • Experienced and dedicated cyber security personnel – Deep technical background – real expertise in cybersecurity – Experience across industries – Practical and cost effective strategies to mitigate risk • Address the security risk within the context of business risk – Understand the relationship of IT risk management within overall enterprise risk management – Communicate technical risks using layman terms and business impact • Proven cyber security methodologies, tools, and techniques -8- © Grant Thornton LLP. All rights reserved.
  • 9. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Cybersecurity Life Cycle and Service Components Life Cycle ITIL* Framework Solution Set Activities/Scope Component Component Policy Strategy and Assessment Develop and test policy, best practices Plan/Maintain Risk, Data privacy and classification, Breaches, Programs, Monitoring, PCI, Strategy and Design, HIPAA, Vulnerability and Penetration Assess Threats testing, Cloud, Agreements with third Evaluate parties, Service Level Agreements (SLA), Operational Level Agreements (OLA) Threat Profiling, PCI, HIPAA, IDS/IPS, VPN, Firewalls, SIM/SEM, Application Plan, Design and Implement Implement (including Cloud-based), SDLC, Data Implement classification, Data privacy (state, federal, international) Threats, Incidents, Master Data Risk, Policy, Standards, Management (MDM),IT Audits, Self Manage Procedures, Programs Assessment, Penetration and Control/Maintain Vulnerability, Communication, Response Threat reduction, Countermeasures, Data Investigate, Respond, Respond Remediate leakage and breaches, PCI breaches, Control/Maintain HIPAA information exposure * - The IT Infrastructure Library (ITIL) is a global framework for service management and is the most widely accepted approach to managing information technology. Services are assets from which the customer gains value, hence cybersecurity is one of those services. -9- © Grant Thornton LLP. All rights reserved.
  • 10. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Cyber Security Strategy & Design Based upon the IT Infrastructure Library (ITIL) framework of best practices in IT, the ITIL Information Security Management's (ISM) strategy goal is the alignment of IT security with business security to ensure that information security is effectively managed in all service and Service Management activities. This strategy includes managing risk and security over information assets while balancing the needs of the business for: • Availability of information and assets • Confidentiality of information • Integrity of information - 10 - © Grant Thornton LLP. All rights reserved.
  • 11. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services The problem with "Big Data" Attribution: Cloud Security Alliance (CSA) - 11 - © Grant Thornton LLP. All rights reserved.
  • 12. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Vulnerability assessment vs. Penetration test • The terms "vulnerability assessment" and "penetration test" are sometimes used interchangeably, so it's important to define and distinguish them. • Vulnerability assessment – a service that provides a comprehensive prioritized identification of vulnerabilities, but does not attempt to exploit them. • Penetration test – a goal oriented service that attempts to gain unauthorized access to a specified target by exploiting one or more vulnerabilities. - 12 - © Grant Thornton LLP. All rights reserved.
  • 13. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Other assessment services Wireless Assessment − a service that assesses the security mechanisms (e.g., authentication, encryption) of a wireless network, and attempts to identify rogue access points. Web Application Security Assessment − a service that assesses the security of a web application, including session management, authentication, authorization, and input validation. Voice Over IP (VoIP) Security Assessment − a service that assesses the security of a deployed VoIP infrastructure, including the infrastructure support, the VoIP components, and the VoIP protocols. Data Leakage Prevention Assessment − a service that measures an organization's risk of information leakage. - 13 - © Grant Thornton LLP. All rights reserved.
  • 14. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Privacy Information Trends • Every day, companies collect, use, profile, disclose, and analyze customer information • Employees who have access to sensitive information inside an organization also represent a key risk – we see this as the fastest rising threat • Unfortunately, some of this information is: • Misused • Stolen • Sold , traded or given to organizations (e.g., WikiLeaks) • This has led to a trust gap among customers, employees and corporate leadership - 14 - © Grant Thornton LLP. All rights reserved.
  • 15. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Privacy Personally Identifiable Information (PII) Personal information is any information that is, or reasonably could be, attributable to a specific individual. The information can be either factual or subjective, and recorded in any form or even unrecorded. Some examples include: Social Security number Driver's license number or state-issued identification card number  financial account number, credit card number, or debit card number Name, address, email address Credit records Buying history Employee records Much of this information is sensitive and greater cause for concern. - 15 - © Grant Thornton LLP. All rights reserved.
  • 16. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Privacy Information stakeholder concerns • Customers – Concerned with how and why their information is collected, used, disclosed, and retained – Want businesses to earn trust • Businesses – Trying to strike a balance between collection and use of information – Concerned with reducing privacy risk of poor privacy practices – Want to leverage good privacy practices and retain trust of customers • Government – Taking increased action on growing concerns about privacy to: – Protect rights of citizens – Better manage its own data stores - 16 - © Grant Thornton LLP. All rights reserved.
  • 17. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services HIPAA GT Healthcare IT Security Offerings: • IT Security Risk Assessment • IT Security Program Implementation Assistance • IT Security/HIPAA Review and Recommendations • HIPAA Compliance Attestation Report - 17 - © Grant Thornton LLP. All rights reserved.
  • 18. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services HIPAA IT Security Risk Assessment - 18 - © Grant Thornton LLP. All rights reserved.
  • 19. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services HIPAA IT Security Program Implementation Assistance • Based on HIPAA/ISO/CobiT/NIST • IT Security Risk Assessment • Policies • Procedures • Business Impact Analysis • Incident Management Program • Security Awareness Program • IT Contingency Plans/Updated DRP • Vulnerability Assessment/Pen Tests • Controls Testing - 19 - © Grant Thornton LLP. All rights reserved.
  • 20. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services HIPAA IT Security/HIPAA Review and Recommendations • Evaluate and test: – Administrative safeguards, – Physical safeguards – Technical safeguards – Organizational safeguards – Policies, Procedures and Documentation Requirements - 20 - © Grant Thornton LLP. All rights reserved.
  • 21. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services HIPAA HIPAA Compliance Attestation Report and Readiness Review Similar to SAS70, except opinion on HIPAA Compliance • Evaluate and reaffirm the appropriateness of the design of processes and controls with management Criterion Observation Reporting Definition and testing • Evaluate and reaffirm management’s interpretation of compliance to ensure that the defined criterion are measurable, objective and will be understood by any Management Checkpoints readers of the report • Test the operating effectiveness of identified controls for the testing period • Determine whether controls were operating effectively throughout the testing period • Confirm the validity of identified findings with the process owner and inform management of validated findings • Evaluate the significance of any instances of non-compliance with the specified criterion - 21 - © Grant Thornton LLP. All rights reserved.
  • 22. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Privacy Assessment Approach 1 2 3 4 Information Identify Scope Gap Analysis Remediation Planning & Collection Reduction Roadmap Opportunities Identify entry points Reduce / modify data Conducted Gap Recommendation Develop process collection Analysis with remediation projects flows Reduce data storage Enhanced Privacy Develop prioritized Map flows onto IT Modify business Framework approach infrastructure processes Leverage DLP to validate Gained an understanding of Reduced Scope and Risk Created Gap analysis Remediation plan the environment document with gap prioritization - 22 - © Grant Thornton LLP. All rights reserved.
  • 23. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Payment Card Industry Data Security Standard (PCI DSS)  The Payment Card Industry Data Major payment card security Security Standard (PCI-DSS) is a set breaches since 2005 of comprehensive requirements for the protection of payment card • Card Systems information. 2005 • 40 Million Cards, Processing Ability Revoked by Visa and MasterCard  The PCI-DSS is managed by the PCI • TJX Security Standards Council (PCI-SSC) 2007 • At least 45.7 Million Customers Affected, Over $250 Million in costs and sponsored by the major card brands. • Hannaford Foods 2008 • 4.2 Million Cards, Validated Compliant at time of breach, Liability and Results Pending  The PCI-DSS is applicable to any organization that stores, processes or • Heartland Payment Systems transmits cardholder data (CHD). 2009 • Potentially more than 100 Million cards compromised and untold amounts of resulting damages - 23 - © Grant Thornton LLP. All rights reserved.
  • 24. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Payment Card Industry Data Security Standard (PCI DSS) PCI DSS high level requirements The PCI DSS prescribes requirements that any business of any size must adhere to in order to accept payment cards. - 24 - © Grant Thornton LLP. All rights reserved.
  • 25. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services What information must be protected? Storage Protection Encryption Data Element Permitted Required Required Primary Account Number (PAN) Yes Yes Yes Cardholder Name Yes Yes No Cardholder Data Service Code Yes Yes No Expiration Date Yes Yes No Full Magnetic Stripe Data No N/A N/A Sensitive Authentication Data CAV2/CVC2/CVV2/CID No N/A N/A PIN/PIN Block No N/A N/A - 25 - © Grant Thornton LLP. All rights reserved.
  • 26. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Payment Card Industry Data Security Standard (PCI DSS) Some common PCI DSS myths: • PCI doesn’t apply to us because: – We don’t take enough credit cards, or – It only applies to retailers and ecommerce • PCI makes us store cardholder data • We are compliant because we: – Encrypt our cardholder data, or – Use vendor/product ABC, or – Outsource our credit card processing • PCI compliance is an IT project • PCI will make us secure • We completed our SAQ so we’re compliant - 26 - © Grant Thornton LLP. All rights reserved.
  • 27. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Payment Card Industry Data Security Standard (PCI DSS) Grant Thornton PCI DSS Capabilities Current capabilities: • An experienced Qualified Security Assessor Company (QSAC) with a significant number of QSA's in our practice across two countries • Client base that we can reference from in the QSA space • Extensive PCI DSS consulting experience • Performing PCI DSS penetration testing and risk assessments • Performing PCI DSS readiness assessments for all merchant levels - 27 - © Grant Thornton LLP. All rights reserved.
  • 28. Cyber Security Strategy & Vulnerability & Other assessment Privacy PCI Contact & IT Audit Design Services Penetration Services services Contact information Danny Miller Grant Thornton LLP Principal & Practice Leader Tel: 215.376.6010 | email: Danny.Miller@us.gt.com Or e-mail cybersecurity@us.gt.com - 28 - © Grant Thornton LLP. All rights reserved.