How to emrace risk-based Security management in a compliance-driven culture


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This lecture was presented at the IEEE ITPC at the Trenton Computer Festival on March 16.

Security and Regulatory Compliance aren’t the same thing – but they’re often confused. When you’re working in a government, healthcare, or financial environment there’s a tendency to think that if you’re FISMA-compliant or HIPAA-compliant or any other X-compliant that you must have good security.

However, sophisticated risk management and real security don’t have much to do with compliance and you can actually great security and be non-compliant with regulatory requirements as well be fully compliant but not secure. This talk, led by Security guru Shahid Shah, will talk about how make sure risk-based security management is properly incorporate into compliance-driven cultures.

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How to emrace risk-based Security management in a compliance-driven culture

  1. 1. Do’s and Don’ts of Risk-based Security Management in a Compliance-driven Culture Security and Regulatory Compliance aren’t the same thing – but they’re often confused Shahid N. Shah, CEO
  2. 2. NETSPECTIVE Who is Shahid? • 20+ years of architecture, design, software engineering, and information assurance (security) in embedded, desktop, and enterprise environments such as – FISMA-regulated government systems – HIPAA-regulated health IT systems – FDA-regulated medical devices and systems • Have held positions at CTO, Chief Architect, or Senior Engineer in a variety of regulated environments 2
  3. 3. Compliance vs. Security
  4. 4. NETSPECTIVE Compliance vs. Security is like… Compliance Security 4
  5. 5. NETSPECTIVE Human Resources Law: Compliance Order: Security 5
  6. 6. NETSPECTIVE Knowledge Compliance knowledge bases FISMA HIPAA FDA Security knowledge areas PCI DSS Firewalls Encryption ONC Access Control Pen Testing SOX Continuous Monitoring Packet Analysis 6
  7. 7. NETSPECTIVE States Compliance: Usually Binary Security: Continuous Risk Management 7
  8. 8. NETSPECTIVE Reality You can be compliant and not secure, secure but not compliant, or both Compliant Both Secure 8
  9. 9. NETSPECTIVE An example of compliant insecurity It’s easy to check off compliance boxes and still be insecure Compliance Requirement • Encrypt all data at FIPS 140 level Insecure but compliant • Full disk encryption – Encryption keys stored on same disk • SSL encryption – No TLS negotiation or man in the middle monitoring Secure and compliant • Full disk encryption – Disk-independent key management • TLS encryption – Force SSL  TLS and monitor for MIM threats 9
  10. 10. NETSPECTIVE Why does compliant insecurity occur? Compliance is focused on… • • • • Regulations Meetings & discussions Documentation Artifact completion checklists Instead of… • Risk management – Probability of attacks – Impact of successful attacks • Threat models – Attack surfaces – Attack vectors 10
  11. 11. Recommendations
  12. 12. NETSPECTIVE Forget compliance Get your security operations in proper order before concentrating on compliance. Start sounding like a broken record, ask “is this about security or compliance?” often. 12
  13. 13. NETSPECTIVE Consider costs while planning security 100% security is impossible so compliance driven environments must be slowed by cost drivers Source: Olovsson 1992, “A structured approach to computer security” 13
  14. 14. NETSPECTIVE Don’t rely on perimeter defense Firewalls and encryption aren’t enough 14
  15. 15. NETSPECTIVE Classify data and assets NIST 800-60 can help you or you can use your own system (e.g. Microsoft) Objective Purpose Low Impact Moderate Impact High Impact Confidentiality Protecting personal privacy and proprietary Information Limited adverse effect from disclosure Serious adverse effect from disclosure Catastrophic effect from disclosure Integrity Guarding against improper information modification or destruction and nonrepudiation Limited adverse effect from unauthorized modification Serious adverse effect from unauthorized modification Catastrophic effect from unauthorized modification Availability Ensuring timely and reliable access to and use of information. Limited adverse effect from service disruption Serious adverse effect from service disruption Catastrophic effect from service disruption 15
  16. 16. NETSPECTIVE Clearly express business impacts Only evidence-driven business-focused impacts should be considered real threats 16
  17. 17. NETSPECTIVE Create risk and threat models He will win who, prepared himself, waits to take the enemy unprepared – Sun Tzu Define threats Create minimal documentation that you will keep up to date • Capability, for example: – – Access to the system (how much privilege escalation must occur prior to actualization?) Able to reverse engineer binaries Able to sniff the network – – – Experienced hacker Script kiddie Insiders – – – – Simple manual execution Distributed bot army Well-funded organization Access to private information – • Skill Level, for example: • Resources and Tools, for example: Motivation + Skills and Capabilities tells you what you’re up against and begins to set tone for defenses Source: OWASP .org, Microsoft 17
  18. 18. NETSPECTIVE Visualize attacks / vulnerabilities 18
  19. 19. NETSPECTIVE Create an Attack Library • • • • • • • • • • Password Brute Force Buffer Overflow Canonicalization Cross-Site Scripting Cryptanalysis Attack Denial of Service Forceful Browsing Format-String Attacks HTTP Replay Attacks Integer Overflows • • • • • • • • • • LDAP Injection Man-in-the-Middle Network Eavesdropping One-Click/Session Riding/CSRF Repudiation Attack Response Splitting Server-Side Code Injection Session Hijacking SQL Injection XML Injection Source: Microsoft 19
  20. 20. NETSPECTIVE Collect attack causes and mitigations Define the relationship between • The exploit • The cause • The fix SQL Injection Use of Dynamic SQL Use parameterized SQL Ineffective or missing input validation Validate input Use stored procedure with no dynamic SQL Source: Microsoft 20
  21. 21. NETSPECTIVE How you know you’re “secure” • Value of assets to be protected is understood • Known threats, their occurrence, and how they will impact the business are cataloged • Kinds of attacks and vulnerabilities have been identified along with estimated costs • Countermeasures associated with attacks and vulnerabilities, along with the cost of mitigation, are understood • Real risk-based decisions drive decisions not security theater 21
  22. 22. NETSPECTIVE Review security body of knowledge Everyone • • • FIPS Publication 199 (Security Categorization) FIPS Publication 200 (Minimum Security Requirements) NIST Special Publication 800-60 (Security Category Mapping) Security ops and developers • • • NIST Special Publication 800-53 (Recommended Security Controls) Microsoft Patterns & Practices, Security Engineering OWASP Executives and security ops Auditors • NIST Special Publication 800-18 (Security Planning) • NIST Special Publication 800-30 (Risk Management) • • • NIST Special Publication 800-53 (Recommended Security Controls) NIST Special Publication 800-53A Rev 1 (Security Control Assessment) NIST Special Publication 800-37 (Certification & Accreditation) 22
  23. 23. NETSPECTIVE Key Takeaway • If you have good security operations in place then meeting compliance requirements is easier and more straightforward. • Even if you have a great compliance track record, it doesn’t mean that you have real security. 23
  24. 24. Visit E-mail Follow @ShahidNShah Call 202-713-5409 Thank You