Ben Rothke - Effective Data Destruction Practices


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Ben Rothke - Effective Data Destruction Practices

  1. 1. Garlic, Wooden Stakes and Silver Bullets - Ensuring Effective Data Destruction Practices Ben Rothke, CISSP, CISA Senior Security Consultant BT Professional Services June 29, 2010
  2. 2. About me • Senior Security Consultant – BT Professional Services • Frequent writer and speaker • Author of Computer Security: 20 Things Every Employee Should Know (McGraw-Hill) • Veteran O’Reilly webinarist – Information Security and Social Networks – 2
  3. 3. Agenda • Business case for media sanitization • Why must end-of-life media/data be sanitized? • Types of media sanitization • DIY or outsource? • References • Q/A • Twitter hashtag #rothkewebinar 3
  4. 4. Business case for media sanitization • Every business has digital media (often terabytes) that must be sanitized • Media sanitization is often overlooked • Failure to adequately sanitize media can have catastrophic consequences to a business – financial loss – damage to a company’s reputation – regulatory violations – civil and criminal liability for Directors and Officers • especially since effective media sanitization is not rocket science • Therefore - digital media must be sanitized before disposal or redeployment 4
  5. 5. Where magic fails, formal processes are effective 5
  6. 6. Old data is big news 6
  7. 7. Information security - printers and copiers 7
  8. 8. Regulations, standards and other drivers • HIPAA • PCI DSS • GLBA • Privacy Act • Electronic Espionage Act • PIPEDA (Canada) • FACTA Disposal rule • Check 21 • FISMA • Contracts • Best Practices • and more….. 8
  9. 9. Storage data is remarkably resilient Fire - Found after fire Soaked – PowerBook destroys home – all Crushed - Bus runs underwater for two data recovered over laptop – all data days - all data recovered recovered Fall from space – Hard drive recovered from space shuttle Columbia recovered from a dry river bed. 99% of 400MB data recovered 9
  10. 10. Sanitization as part of the data lifecycle Discovery Sanitization Classification Auditing Protection Control
  11. 11. When do you need to sanitize media? • Device is sold, donated, discarded or recycled • End of lease • Device returned to a manufacturer for warranty repair • After severe malware/hacking attempt, for complete removal of offending code from infected storage device • RAID or hot spare: – Hot spare placed into service, then removed when faulty RAID drive was replaced – Hot spare should be sanitized, as well as the original failed RAID drive if the drive is still operational 11
  12. 12. Hard drives and media are everywhere…. • Over 500 million hard drives were sold in 2009 • There are still billions out there • Thumb drives are everywhere • 4GB USB drives given away at conferences for free 12
  13. 13. Sanitization as a formal process • Formal system of information sanitization – Based on risk factors specific to the organization – policy must be created and implemented – should be extensive, explicit, auditable and audited – performed in a formal, consistent, documented manner – done on a scheduled basis – in the event of a failure, plaintiff’s lawyers will have much less to use, which could likely be judged positively by a jury – has quality control built in 13
  14. 14. Policy • Policy is dependent on a number of factors including: – age and type of the storage technology – classification of the data residing on the device – environment in which the device had been used • One policy does not fit all – If device was used to store public data, but used in a SCIF that handles top secret information; the drive, since it was used in a SCIF, likely classified as the highest level of classification • Create a responsible policy – must encompass all types of storage hardware and information classifications and employ a responsible sanitization practice using both in-house and if required external services/resources 14
  15. 15. Sanitization moratorium • Include notion of a data sanitization moratorium – Often called a Litigation Hold or Legal Hold – organization must stop its data sanitization activities – sanitization activities must immediately be placed on hold until Legal department determines whether these sanitization activities jeopardize sought-after data – doesn’t just mean when there is a lawsuit • can be regulatory investigation, internal investigation for workplace misconduct, preservation because a client or vendor is in litigation • while you aren’t technically part of it, you may have data material to the matter they are involved in 15
  16. 16. Form factors • Hard drives • USB / thumb drives • Optical disks • Solid state storage • Flash • VHS video • External hard drives • Floppies • MFP • Back-up tapes • Copy machines • DVD/CD • Smart phones 16
  17. 17. Selling is not sanitization 17
  18. 18. NIST Special Publication 800-88 • Guidelines for Media Sanitization • Sanitization – general process of removing data from storage media, such that there is reasonable assurance that the data may not be easily retrieved and reconstructed • 800-88 assists with decision-making when media require disposal, reuse, or will be leaving the effective control of an organization • Develop and use local policies and procedures in conjunction with 800-88 to make effective, risk-based decisions on the ultimate sanitization and/or disposition of media and information 18
  19. 19. Types of media sanitization • Clearing – Protects confidentiality of data against keyboard attack. – Example: overwriting • Purging – Protects the confidentiality of information against a laboratory attack (use of special equipment by trained recovery technicians) – Example: Secure Erase, degaussing • Destroying – Absolute destruction – Example: Hard drive shredding, smelting, disintegration 19
  20. 20. Unacceptable media sanitization practices • File deletion • Drive formatting • Disk partitioning • Encryption / key destruction 20
  21. 21. Software-based disk sanitization Advantages Disadvantages • Single pass is adequate (as long as • Requires significant time to process all data storage regions can be entire high capacity drive addressed) • May not be able to sanitize data from • Cost-effective and easily configurable inaccessible regions (HPA, DCO, etc.) sanitization solution • Inconsistent data logging, audit trails or • Can be configured to clear specific certification labels data, files, partitions or just the free • No security protection during the space erasure process / subject to intentional • Erases all remnants of deleted data or accidental parameter changes to maintain ongoing security • May require separate license for every • Green solution hard drive • Ineffective without good QA processes • Not scalable 21
  22. 22. Single pass vs. multiple passes • DoD standard 5220.22-M (1995) – at least 3 passes required • NIST Special Publication 800-88, section 2.3 – Replaces 5220 which is retired – for ATA disk drives manufactured after 2001 (over 15 GB) clearing by overwriting the media once is adequate to protect the media from both keyboard and laboratory attack – single pass is adequate only if able to access the entire data storage region of the media surface 22
  23. 23. Secure Erase – Purge Level Sanitization • HDD manufacturers & Center for Magnetic Recording Research created Secure Erase sanitization standard – component of the ANSI ATA Specification – optional inclusion for use in SCSI as Secure Initialize – embedded in the firmware of all standards compliant ATA hard drives manufactured since 2001 (IDE, ATA, PATA, SATA) – single pass operation eradicates all data in all data sectors – highly effective and fast – validated and certified by various governing bodies – but most individuals and companies don’t even know it exists – HDD manufacturers scared of irate help-desk calls – inhibited by most PC manufacturers to protect from the potential exploitation by virus / malware 23
  24. 24. Hardware-based disk sanitization – degaussing • Removal of data by exposing data storage bits on media surface to a magnetic field of sufficient strength to achieve coercion of the bit – Ensure model is on NSA Degausser Evaluated Products List (DEPL) • Destructive process – Creates irreversible damage to hard drives • destroys the special servo control data on the drive, which is meant to be permanently embedded on the hard drive • once the servo is damaged, the drive is unusable • if you plan to reuse the drive, don’t degauss it 24
  25. 25. Choosing a degausser • Cycle time – amount of time it takes to complete the erasure • Heat generation – may generate significant heat and need to be cooled down – If you need to degauss many drives, downtime can be an issue • Wand or cavity style – hand wands models are generally cheaper, but may lack certain power features – cavity style degaussers enable you to place the entire unit into the degausser • Size – smaller portable unit or a larger more powerful unit? – Some powerful models require wheels to move as they can weigh nearly 400 pounds 25
  26. 26. Environmental considerations - location placement • Should be installed in a location that will not interfere with equipment or cause risk to operator or the public • Caution must be taken so that the strong electromagnetic fields created by the degausser don’t produce collateral damage to other susceptible equipment nearby • Must not impose potential health risk – Consideration for interference with those who have pacemakers 26
  27. 27. Physical disk destruction • Physical destruction achieved using many methods – Shredding – Disintegration – Bending, breaking or mangling the hard drive • hard drive is easily distinguishable from unprocessed hard drives - ensuring the disposal of the correct hard drive – Is absolute destruction required? • Media must be ground to a diameter smaller than a single data 512KB block, which would require a particle size of no larger than 1/250 inch 27
  28. 28. Hardware-based disk sanitization – Secure Erase • Enables the native Secure Erase command - Overcomes host limitations to effectively launch Secure Erase - Maintains internal audit log - Issues destruction certificate upon successful completion • Automatically format drives after erasure – used to rollout a new O/S to multiple workstations 28
  29. 29. Optical media sanitization • Securely and permanently eradicates digital data on DVD, CD-ROM and other optical media – grinds the information layer off media • Ensure device meets the requirements of NSA/CSS 04- 02 for Optical Media Destruction 29
  30. 30. In-house data sanitization Advantages Disadvantages • Media never leaves your location, no risk • Destruction systems can be expensive of loss in transit • Low volume makes a longer time for ROI • Full control • Staff with other duties may miss devices • Data is destroyed by your own trusted • Must manage internal personnel and staff technology changes – Recommended that all destruction • Lack of space and/or resources for proper activities be carried out under the segregation between destroyed and non- office of the CISO, and by a trained destroyed units and trusted technology support • Still must have a qualified vendor to deal with technician residual waste and/or drives that fail sanitization/wiping process • Disposal of residual material • Technicians will miss drives • Requires good QC process to be effective 30
  31. 31. In-house sanitization • Quality control – If your organization is going to do any of its own data sanitization, it must have quality control mechanisms • Separation of duties - one tech removes hard drives while another is assigned to verify the drives have been removed, document the verification, and replace the cover – Wiping - assign a separate tech to take a random sample of at least 10% (depending on quantity) and attempt to recover data with a COTS data recovery tool 31
  32. 32. Outsourced data sanitization Advantages Disadvantages • No initial capital investment required • No direct control of vendor employees • can handle varying destruction needs • media may be transported outside of your (disintegration, degaussing, etc.) location • can handle varying volume needs • possible security concerns with off- • experts utilizing best practices premise transportation and handling • may have higher security standards than • may get locked into a bad contract your location • may require minimums greater than your • no need to manage personnel and needs technology changes • data is handled/destroyed by non- • regulatory compliant residual disposal employees • if litigated, professional secure destruction • if hardware is not disposed of properly, services destruction documentation is you could be included in a pollution more credible than internally generated liability case processes • Given these disadvantages, special emphasis should be placed on vendor selection criteria that specifically address these issues 32
  33. 33. Questions for a prospective outsourced firm • What type of insurance coverage do they have? – professional liability (sometimes called Errors & Omissions) – pollution / environmental liability – demand to see certificate of insurance demonstrating coverage for both • What processes do they follow from receipt of asset through disposition? • What are their security procedures? • How do they sanitize data? • Are they NAID certified for digital data destruction? • How do they verify data is eradicated? • Do they do full background checks? • What are financial capabilities? • If private, where do they get their funding? How stable is source? • Can they provide customer references? • Do they have the necessary state and local permits? • Do they export e-waste overseas? • Can they handle all or most of the locations for which you will require services? • Do they have processes around chain of custody? • Will they agree to the SLA’s that you have created? • Do they barcode items? • The key is to ask a lot of questions in advance! 33
  34. 34. Outsourcing - Caveat Emptor • A certificate of destruction, and a contract assuring responsibility of the process mean very little in the real world • If a device is lost or data is exposed, it will be the owner of the data who will be getting the penalty and making the mandatory disclosure • The service provider will be little more than a footnote in the disclosure 34
  35. 35. Taking data sanitization seriously • Segregation – separate all storage devices and media from others to be disposed of materials. – specifically remove all hard drives from to-be-disposed-of PCs, laptops and servers • Inventory – establish the chain of possession of the data storage device. – best practice - establish the connection of a particular storage device to the unit it was removed from and use internal asset management records to track the device back to the actual user • Isolation – using secure collection containers, isolate the inventoried data storage devices in such a manner as to prevent unauthorized removal from the sanitization process – but avoid warehousing – Media must be processed frequently as to avoid warehousing of drives containing confidential data. 35
  36. 36. NAID • National Association for Information Destruction • International trade association for companies providing information destruction services • Mission is to promote the information destruction industry and the standards and ethics of its member companies • NAID certified companies are audited annually by an independent 3rd-party and subject to unannounced audits • 36
  37. 37. References • Guidelines for Media Sanitization (NIST SP 800-88) • UCF Media Disposal Implementation Guide • NAID Information Destruction Policy Compliance Toolkit • ARMA Contracted Destruction for Records and Information Media • Gartner - Best Practices for Data Destruction 37
  38. 38. Vendors / solution providers • DestructData • Ensconce Data – Technology – • Security Engineered Machinery • Garner Products – – • Ontrack Eraser • Darik’s Boot And Nuke – – • CPR Tools • Reclamere – – • Back Thru the Future – 38
  39. 39. For more information • National Association of Corporate Directors – Record Retention and Document Destruction Policy – • Remembrance of Data Passed: A Study of Disk Sanitization Practices – • Best Practices for the Destruction of Digital Data – • Hard Drive Disposal: The Overlooked Confidentiality Exposure – • Storage & Destruction Business Magazine – 39
  40. 40. References • Center for Magnetic Recording Research – • Australian Department of Defence – Information and Communications Technology Security Manual – • Can Intelligence Agencies Read Overwritten Data? – 40
  41. 41. Conclusion / Action Items • Management awareness – management must be aware of the risks – must ensure formal sanitization processes are developed • Develop strategies on media sanitization • Review security procedures for adequacy, completeness, scope and failure analysis • Develop an information lifecycle audit program – Follow a life cycle approach to IT risk management that includes making an explicit decision about data destruction • Implement sanitization process • Ensure quality control is built into the process 41
  42. 42. Thanks for attending – Q/A Ben Rothke, CISSP, CISA Senior Security Consultant BT Professional Services 42