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The impact of regulatory compliance on DBA(latest)


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The impact of regulatory compliance on DBA(latest)

  1. 1. The Impact of Regulatory Complianceon Database AdministrationCraig S. MullinsCorporate TechnologistNEON Enterprise Software, Inc.
  2. 2. Authors This presentation was prepared by: Craig S. Mullins Corporate Technologist NEON Enterprise Software, Inc. 14100 Southwest Freeway, Suite 400 Sugar Land, TX 77478 Tel: 281.491.6366 Fax: 281.207.4973 E-mail: This document is protected under the copyright laws of the United States and other countries as an unpublished work. This document contains information that is proprietary and confidential to NEON Enterprise Software, which shall not be disclosed outside or duplicated, used, or disclosed in whole or in part for any purpose other than to evaluate NEON Enterprise Software products. Any use or disclosure in whole or in part of this information without the express written permission of NEON Enterprise Software is prohibited. © 2006 NEON Enterprise Software (Unpublished). All rights reserved.2
  3. 3. Agenda An Overview of Government Regulations and Issues Impacts on Data and Database Management  Data Quality  Long-term Data Retention  Database Security  Database and Data Access Auditing  Data Masking  Controls on DBA Procedures — Backup & Recovery — Change Management  Metadata Management3
  4. 4. Compliance Continues to Exert Pressure Increasing compliance pressure. Compliance requirements, such as Sarbanes-Oxley, HIPAA, CA SB 1386, and the Gramm-Leach-Bliley Act (GLBA), are driving interest for all enterprises to take strong security measures to protect private data. These include initiatives around data-at-rest encryption, granular auditing, intrusion detection and prevention, and end-to- end security measures. Source: Trends 2006: Database Management Systems, Forrester Research4
  5. 5. Regulatory Compliance GLB HIPAA PCI-DSS Basel II Sarbanes-Oxley CA SB1386 Federal Information Security Management Act “Red Flag” Rules (FRCA)5
  6. 6. Legislation & Compliance The Gramm-Leach-Bliley Act (GLB), is a federal law enacted in the United States to control the ways that financial institutions deal with the private information of individuals. The Act regulates the collection and disclosure of private financial information; stipulates safeguards requiring security programs; and prohibits the practice of pretexting. HIPAA (Health Insurance Portability and Accountability Act) creates national standards to protect individuals medical records & personal health information. The Privacy Rule provides that, in general, a covered entity may not use or disclose an individual’s healthcare information without permission except for treatment, payment, or healthcare operations. PCI DSS (Payment Card Industry Data Security Standard) includes requirements for security management, policies, procedures, network architecture, software design and other critical protective measures. This comprehensive standard is intended to help organizations proactively protect customer account data.6
  7. 7. Legislation & Compliance Basel II is an international banking regulation the goal of which is to produce uniformity in the way banks and banking regulators approach risk management across national borders. The Sarbanes-Oxley Act (SOX) establishes standards for all U.S. public company boards, management, and public accounting firms. TheSection Public Company Accounting Oversight Board (PCAOB) was created by 404 SOX to oversee auditors of public companies. The primary goals of SOX were to strengthen and restore public confidence in corporate accountability and to improve executive responsibility. The California Security Breach Notification Law (CA SB 1386) requires companies to notify California customers if PII maintained in computerized data files have been compromised by unauthorized access. 7
  8. 8. FISMA: Federal Information Security Mgmt Act Title III of the E-Government Act, FISMA basically states that federal agencies, contractors, and any entity that supports them, must maintain security commensurate with potential risk. The Fair and Accurate Credit Transactions Act of 2003 (FACTA), requires all federally regulated financial institutions to be in full compliance by Nov. 1, 2008. This is also known as the "Red Flag" rules.  Requires that financial institutions and creditors develop and deploy an Identity Theft Prevention Program for combating ID theft on new and existing accounts.8
  9. 9. Other Regulations & Issues? And, there are more regulations to consider, for example:  the USA Patriot Act  Can SPAM Act of 2003  Telecommunications Act of 1996  The Data Quality Act And, there are more regulations to contend with; based upon your industry, location, etc. As well as, new regulations that will continue to be written by government and imposed over time… Regulations have brought to light some of the personal financial information that has been compromised (stolen)  More on this later…9
  10. 10. Regulatory Compliance is International Country Examples of Regulations Australia Commonwealth Government’s Information Exchange Steering Committee, Evidence Act 1995, more than 80 acts governing retention requirements Brazil Electronic Government Programme, EU GMP Directive 1/356/EEC-9 Canada Bill 198, Competition Act, France Model Requirements for the Management of Electronic Records, EU Directive 95/46/EC Germany Federal Data Protection Act, Model Requirements for the Management of Electronic Records, EU Directive 95/46/EC Japan Personal Data Protection Bill, J-SOX Switzerland Swiss Code of Obligations articles 957 and 962 United Data Protection Act, Civil Evidence Act 1995, Police and Criminal Evidence Act Kingdom 1984, Employment Practices Data Protection Code, Combined Code on Corporate Governance 200310
  11. 11. Regulations Tracked by Gartner11
  12. 12. Regulations Impacting Security Governance vs. Privacy Governance Privacy • • EU DPD Basel II • • AU/NZ NPP Sarbanes Oxley • • SB 1386/AB 1950 OFAC • • GLBA Turnbull Report • HIPAA • PCI • FCRA -- “Red Flag” Protect and control the process Protect the data12
  13. 13.
  14. 14. Regulatory Compliance and… Impact: upper-level management is keenly aware of the need to comply, if not all of the details that involves. Prosecution: being successfully prosecuted (see next slide) can result in huge fines and even imprisonment. Cost: cost of complete compliance can be significant, but so can the cost of non-compliance. No longer easier just to ignore problems. Durability: although there have been discussions about scaling back some laws (e.g. SOX), increasing regulations and therefore increasing time, effort, and capital will be spent on compliance.  That is, the issue will not just disappear if you ignore it long enough! But, at the end of the day, ensuring exact compliance can be a gray area.14
  15. 15. The Reality of Prosecution Enron – In May 25, 2006 Ken Lay (former CEO) was found guilty of 10 counts against him. Because each count carried a maximum 5- to 10-year sentence, Lay could have faced 20 to 30 years in prison. However, he died while vacationing in about three and a half months before his scheduled sentencing. Jeff Skilling (another former CEO) was found guilty of 19 out of 28 counts against him, including one count of conspiracy, one count of insider trading. Skilling was sentenced to 24 years and 4 months in federal prison. WorldCom – In June 2005, 800,000 investors were awarded $6 billion in settlements; the payouts will be funded by the defendants in the case, including investment banks, auditROI? firms, and the former directors of WolrdCom. The judge in the case noted that the settlements were “of historic proportions.” Additionally, Bernard Ebbers, former CEO of WorldCom, was convicted of fraud and sentenced to 25 years in prison. Tyco – In September 2005, Dennis Kozlowski (former Tyco CEO) and Mark Swartz (former Tyco CFO) were sentenced to 8 to 25 years in prison for stealing hundreds of millions of dollars from Tyco. Additionally, Kozlowski had to pay $70 million in restitution; Swartz $35 million. Adelphia – In June 2005, John Rigas (founder and former CEO) was sentenced to 15 years in prison; his son, Tony, was also convicted of bank fraud, securities fraud, & conspiracy - he received a 20 year sentence. HealthSouth – In March 2005, Richard Scrushy, founder and former CEO, was acquitted of charges relating to 1 $2.7 billion earnings over-statement. Scrushy blamed his subordinates for the fraud… 15
  16. 16. But Business Benefits Do Exist Source: Unisphere Research, OAUG Automating Compliance 2006 Survey16
  17. 17. Why Should DBAs Care About Compliance? Compliance starts with the CEO…  But the CEO relies on the CIO to ensure that IT processes are compliant  And the CIO relies on the IT managers  One of whom (DBA Manager) controls the database systems — Who relies on DBAs to ensure that data is protected and controlled.17
  18. 18. So What Do Data Mgmt Folks Need to Do? Implement standard controls and methods for improving:  Data Quality  Long-term Data Retention  Database Security  Database and Data Access Auditing  Data Masking  Backup & Recovery18  DBA Procedures
  19. 19. Issue #1: Data Quality A recent SAS/Risk Waters Group survey indicated that 93% of respondents had experienced losses of $10 million in one year…  And 21% of respondents said that at some point, their company suffered a loss between $10,000 and $1,000,000 in a single day. The prime reasons given for such losses were incomplete, inaccurate or obsolete data, and inadequate processes. Source: Gartner (April 2006)19
  20. 20. Examples of Data Quality Regulations The Data Quality Act  Careful, it sounds better than it actually is.  Written by an industry lobbyist and slipped into a giant appropriations bill in 2000 without congressional discussion or debate  Basically consists of two sentences directing the OMB to ensure that all information disseminated by the federal government is reliable. Sarbanes-Oxley  Financial reports must be ACCURATE  Without good data quality this is impossible.20
  21. 21. Data Quality: Is it Really a Major Concern? How good is your data quality? Estimates show that, on average, data quality is suspect:  Payroll record changes have a 1% error rate;  Billing records have a 2-7% error rate, and;  The error rate for credit records: as high as 30%. Source: T.C. Redman, Data Quality: Management and Technology, (New York, Bantam Books). Similar studies in Computer World and the Wall Street Journal back up the notion of overall poor data quality.  W.M. Bulkeley, "Databases Are Plagued by Reign of Error," The Wall Street Journal, 26 May 1992, B2.  B. Knight, "The Data Pollution Problem," ComputerWorld, 28 September 1992, 81-84.21
  22. 22. The High Cost of Poor Quality Data “Poor data quality costs the typical company at least ten percent (10%) of revenue; twenty percent (20%) is probably a better estimate.” Source: Thomas C. Redman, “Data: An Unfolding Quality Disaster”, DMReview Magazine, August 2004Valid &Accurate? 22
  23. 23. Database Constraints By building constraints into the database, overall data quality may be improved:  Referential Integrity — Primary Key — Foreign Key(s)  UNIQUE constraints  CHECK constraints  Triggers  Domains23
  24. 24. Data Profiling With data profiling, you can:  Discover the quality, characteristics and potential problems of information before beginning data-driven projects  Drastically reduce the time and resources required to find problematic data  Allow business analysts and data stewards to have more control on the maintenance and management of enterprise data  Catalog and analyze metadata and discover metadata relationships24
  25. 25. Issue #2: Long-Term Data Retention The average installed storage capacity at Fortune 1000 corporations has grown from 198TB to 680TB in less than two years. This is a growth rate of more than 340% as capacity continues to double every 10 months. Source: TIP (TheInfoPro). 2006 www.theinfopro.net25
  26. 26. More Data, Stored for Longer Durations Data Retention Issues: Volume of data (125% CAGR) Length of retention n requirement io ct Amount of Data e r ot Varied types of data P e a nc Security issues i pl C om 0 Time Required 30+ Yrs26
  27. 27. Data Retention Drives Data(base) Archiving Data Retention Requirements refer to the length of time you need to keep data Determined by laws – regulatory compliance   More than 150 state and federal laws  Dramatically increasing retention periods for corporate data Determined by business needs   Reduce operational costs  Large volumes of data interfere with operations: performance, backup/recovery, etc.  Isolate content from changes27  Protect archived data from
  28. 28. Regulatory Compliance & Data Retention Requirements28
  29. 29. Can You Read This?29
  30. 30. E-Discovery Electronic evidence is the predominant form of discovery today. (Gartner,Research Note G00136366) Electronic evidence could encompass anything that is stored anywhere. (Gartner,Research Note G00133224) When data is being collected (for e-discovery) it is imperative that it is not changed in any way. Metadata must be preserved… (Gartner,Research Note G00133224) Gartner Strategic Planning Assumption: Through 2007, more than half of IT organizations and in-house legal departments will lack the people and the appropriate skills to handle electronic discovery requirements (0.8 probability). (Gartner,Research Note G00131014)30
  31. 31. E-Discovery and the FRCP Federal Rules of Civil Procedure, Rule 34b  Took effect December 2006  A party who produces documents for inspection shall produce them . . . as they are kept in the usual course of business..."  The amended rules state that requested information must be turned over within 120 days after a complaint has been served. So data stored in database systems must be able to be produced in electronic form.31
  32. 32. What “Solutions” Are Out There?  Keep Data in Operational Database — Problems with authenticity of large amounts of data over long retention times — Operational performance degradation  Store Data in UNLOAD files (or backups) — Problems with schema change and reading archived data — Using backups poses even more serious problems  Move Data to a Parallel Reference Database — Combines problems of the previous two  Move Data to a Database Archive32
  33. 33. Components of a Database Archiving Solution Database Archiving: The process of removing selected data records from operational databasesPurge that are not expected to be referenced again and Databases storing them in an archive data store where they can be retrieved if needed. Data Data Extract Recall Metadata Archive data store and retrieve capture, design, maintenance Archive data Archive query and access metadata data policies metadata history Archive administration 33
  34. 34. Issue #3: Data and Database Security 75% of enterprises do not have a DBMS security plan. Source: Forrester Research, “Your DBMS Strategy 2005” A single intrusion that compromises private data can cause immense damage to the reputation of an enterprise — and in some cases financial damage as well. Source: Forrester Research, “Comprehensive Database Security…” Database configurations are not secure by default, and they often require specialized knowledge and extra effort to ensure that configuration options are set in the most secure manner possible. Source: Forrester Research, “Comprehensive Database Security…”34
  35. 35. Obstacles to Database Security Source: Forrester Research, “Comprehensive Database Security…”35
  36. 36. Database Security By the Numbers s 67% of 1,100 security pros said securing databases was an important or very important challenge for 2008 — #1 in a list of 13 data protection initiatives s 45% of security pros will spend more time on data protection in 2008 vs. 2007. — #3 on a list of 19 security activities s 41% will spend more time on database security specifically Source: TechTarget36
  37. 37. What is a Data Breach?37
  38. 38. Data Breaches: A Threat to Your Data Privacy Rights Clearinghouse Since 2005:  In excess of 230 million total records containing sensitive personal information were exposed due to data security breaches… — ChoicePoint: (Feb 15, 2005) – data on 165,000 customers breached — Since then, there have been 230,454,030 total records breached that contained sensitive personal information* * As of June 30, 200838 * As of Feb 27, 2007, reported by
  39. 39. How Prevalent is this Problem? 68% of companies are losing sensitive data or having it stolen out from under them six times a year An additional 20% are losing sensitive data 22 times or more per year. Sources: eWeek, March 3, 2007 IT Policy Compliance Group 39
  40. 40. The Cost of a Data Breach According to Forrester Research, the average cost per record is between $90 and $305 According to the Ponemon Institute, the average cost per lost customer record is $182  Average cost per incident: $5 million Or use the Data Loss Calculator, free on the web at
  41. 41. Most Prevalent Causes of Data Loss41
  42. 42. Database Security Issues in a Nutshell Authentication  Who is it? Authorization  Who can do it? Encryption  Who can see it? Audit  Who did it?42
  43. 43. Security From a DB2 Perspective43
  44. 44. 44
  45. 45. Database Security Who has access to high-level “roles”: Install SYSADM, SYSADM, SYSCTRL, DBADM, etc. Auditors will have issues with this, but it is difficult, if not impossible, to remove. Do any applications require DBA-level authority? Why? Security monitoring  Data Access Auditing (more on this in a moment)  Additional tools45
  46. 46. SYSADM and Install SYSADM Install SYSADM bypasses the DB2 Catalog when checking for privileges.  So, there are no limits on what a user with Install SYSADM authority can do.  And it can only be removed by changing DSNZPARMs  Basically, needed for catalog and system “stuff” SYSADM is almost as powerful, but:  It can be revoked  Biggest problem for auditors: SYSADM has access to all data in all tables.46
  47. 47. Suggestions • Limit the number of SYSADMs  And audit everything those users do. • Consider associating Install SYSADM with a group (RACF)  Authids that absolutely need Install SYSADM can be connected to the group using secondary authids. • Similar issues with SYSOPR and Install SYSOPR47
  48. 48. Data Encryption Considerations Californias SB 1386 protects personally identifiable information; obviously it doesnt matter if encrypted data becomes public since its near impossible to decrypt. Source: “Encryption May Help Regulatory Compliance” Edmund X. DeJesus, Types of encryption  At Rest  In Transit Issues  Performance — Encrypting and decrypting data consumes CPU  Applications may need to be changed — See next slide for DB2 V8 encryption functions48
  49. 49. DB2 V8: Encryption / Decryption Encryption: to encrypt the data for a column ENCRYPT_TDES(string, password, hint)  ENCRYPT_TDES [can use ENCRYPT() as a synonym for compatibility]Exit  Triple DES cipher block chaining (CPC) encryption algorithmRoutine? — Not the same algorithm used by DB2 on other platforms  128-bit secret key derived from password using MD5 hash INSERT INTO EMP (SSN) VALUES(ENCRYPT(289-46-8832,TARZAN,? AND JANE)); Decryption: to decrypt the encrypted data for a column DECRYPT_BIT(), DECRYPT_CHAR(), DECRYPT_DB()  Can only decrypt expressions encrypted using ENCRYPT_TDES — Can have a different password for each row if needed  Without the password, there is no way to decrypt SELECT DECRYPT_BIT(SSN,TARZAN) AS SSN FROM EMP; 49
  50. 50. DB2 9 for z/OS: Encryption in Transit  DB2 9 supports SSL by implementing z/OS Communications Server IP Application Transparent Transport Layer Security (AT-TLS)  AT-TLS performs transport layer security on behalf of DB2 for z/OS by invoking the z/OS system SSL in the TCP layer of the TCP/IP stack  When acting as a requester, DB2 for z/OS can request a connection using the secure port of another DB2 subsystem  When acting as a server, and from within a trusted context SSL encryption can be required for the connection50
  51. 51. Auditing In a world replete with regulations and threats, organizations have to go well beyond securing their data. Essentially, they have to perpetually monitor their data in order to know who or what did exactly what, when and how –- to all their data. Source: Audit the Data – or Else: Un-audited Data Access Puts Business at High Risk. Baroudi-Bloor, 2004. HIPAA, for example, requires patients to be informed any time someone has even looked at their data.51
  52. 52. Regulations Impacting Database Auditing ISO Audit CobiT PCI CMS 17799 NIST HIPAA GLBA NERC 800-53 (SOX) DSS ARS (Basel Requirements II) (FISMA) 1. Access to Sensitive  Data (Successful/Failed      (OMB) SELECTs) 2. Schema Changes (DDL)        (Create/Drop/Alter Tables, etc.) 3. Data Changes (DML)    (Insert, Update, Delete) 4. Security Exceptions         (Failed logins, SQL errors, etc.) 5. Accounts, Roles &         Permissions (Entitlements)52
  53. 53. Database and Data Access Auditing An audit is an evaluation of an organization, system, process, project or product.  Database Control Auditing — Who can do what (who has the authority)  GRANT, REVOKE, RACF/ACF2/Top Secret  Data Access Auditing — Who did do what — INSERT, UPDATE, DELETE — SELECT — Database Object Auditing  DCL: GRANT, REVOKE53  DDL: CREATE, DROP
  54. 54. Key Stakeholder Requirements SECURITY OPERATIONS  Real-time policies  Separation of duties  Minimal impact  Secure audit trail  Best practices reports  Change management  Data mining &  Automated controls  Performance forensics 100% Visibility & Unified View54
  55. 55. How to Audit Database Access? 1. Audit trails in tables 2. Native DBMS traces 3. Log-based 4. Network sniffing 5. Capture requests at the server55
  56. 56. Audit Trails in Tables Sometimes the first “knee jerk” reaction is to add “audit columns” to tables, such as: LAST_MODIFIED_DATE Auditors don’t like this; it is a problem because:  Audit trails should be kept outside of the database (because if you delete the row you lose the audit data)  How can you guarantee that the last modified data is completely accurate? — Couldn’t someone have set it by accident (or nefariously)?56
  57. 57. Native DBMS Audit The native DBMS audit capability may not be optimal:  Separation of duties – logging typically is turned on and off by DBAs, who need to be audited  Overhead – many require traces to be started, which can consume precious resources (as much as 10% overhead?)  Comprehensive capture – may not capture everything that needs to be captured for compliance57
  58. 58. DB2 Audit Trace The DB2 Audit Trace can record:  Changes in authorization IDs  Changes to the structure of data (such as dropping a table)  Changes to data values (such as updating or inserting data)  Access attempts by unauthorized IDs  Results of GRANT statements and REVOKE statements  Mapping of Kerberos security tickets to IDs  Other activities that are of interest to auditors Audit Trace Classes are listed on page 287, Admin Guide CREATE TABLE . . . AUDIT ALL . . .58 -START TRACE (AUDIT) CLASS (4,6) DEST (GTF) LOCATION (*)
  59. 59. Limitations of the audit trace The audit trace doesn’t record everything: s Auditing takes place only when the audit trace is on. s The trace does not record old data after it is changed (the log records old data). s If an agent or transaction accesses a table more than once in a single unit of recovery, the audit trace records only the first access. s The audit trace does not record accesses if you do not start the audit trace for the appropriate class of events. s The audit trace does not audit some utilities. The trace audits the first access of a table with the LOAD utility, but it does not audit access by the COPY, RECOVER, and REPAIR utilities. The audit trace does not audit access by stand- alone utilities, such as DSN1CHKR and DSN1PRNT. s The trace audits only the tables that you specifically choose to audit. s You cannot audit access to auxiliary tables. s You cannot audit the catalog tables because you cannot create59 or alter catalog tables.
  60. 60. What About Using the Log? Database transaction log(s) capture ALL* changes made to data. DBMS Database SQL Changes Transaction Log(s)60 * Well, maybe not all changes, all the time.
  61. 61. Issues With Database Log Auditing & Analysis  Log format is proprietary  Volume can be an issue  Easy access to online and archive logs? — But how long do you keep your archive logs?  Dual usage of data could cause problems? — Recovery and protection — Audit  Tracks database modifications, but what about reads? — Transaction logs do not record information about SELECT.  And what about non-logged operations? — LOAD LOG NO, REORG LOG NO — Non-logged table spaces (new feature in DB2 9 for z/OS)  Cannot invoke real-time actions using log-based auditing61
  62. 62. Network Capture (aka Network Sniffers) Database auditing via network sniffing captures SQL requests as they go across the network.  But not all requests go across the wire — Mainframe applications — DBA access directly on the server  Be careful, many third-party database auditing solutions use this approach62
  63. 63. A Better Approach  Audit database calls at the server — Capture all SQL requests at the server — All SQL access is audited, not just network calls — Retain all pertinent audited information  No reliance on the DBMS — No need to keep the active/archive log files — No need to start a DBMS trace — No need to modify the database schema — Must be selective, comprehensive, and non-invasive — Requires purchasing additional ISV software63
  64. 64. Server-Based Database Auditing Requirements Surveillance Mechanism  Selective – must be rules-based to enable the capture of audit details only on the specific data that requires auditing.  Comprehensive – must be able to capture the complete scenario of auditable information.  Non-invasive – must be able to audit access to data without incurring expensive performance degradation.64
  65. 65. Auditing Has to be at the Server Level If you are not capturing all pertinent access requests at the server level, nefarious users can sneak in and not be caught.65
  66. 66. On the Need to Monitor Privileged Users66
  67. 67. Data Masking67
  68. 68. The Problem Data is required to test application designs.  Data (or reports) may also need to be sent to other individuals, or organizations, on an on-going basis for various purposes. Some of the data is sensitive and should not be accessible by programmers:  PII such as SSN, salary, credit card details, etc. Referential integrity must be maintained in test, even as data values are changed.68
  69. 69. The Solution Data masking is the process of protecting sensitive information in non-production databases from inappropriate visibility. Valid production data is replaced with useable, referentially-intact but incorrect and invalid data. After masking, the test data is usable just like production; but the information content is secure.  Masking in the database or to the reports… May need to create and populate test data from scratch, as well as sanitize existing information.69
  70. 70. Data Masking in action Masking must change names, credit card and telephone numbers (invalid), e-mail addresses (invalid), postal addresses (including street names, zip codes, and postal codes), false company names, and so on. 191-64-9180 275-99-0194Craig S. Mullins John Q. Public Pittsburgh, PA 15230Sugar Land, TX 77478 70
  71. 71. What PII Might Need to be Masked?71
  72. 72. How Data Masking Protects Data If the data has been sanitized by masking it, it won’t matter if thieves gain access to it.72
  73. 73. Management & Admin Procedures Are changes made to your database environment using standard methods and in a controlled manner? Are your databases properly backed up and recoverable within the timeframe mandated by your business (and any regulations)?73
  74. 74. CobiT and Backup & Recovery COBIT and Recoverability DS1 Define and Manage Service Levels Recovery Time Objectives = recovery SLAs DS4 Ensure Continuous Service Prove recoverability and therefore, data availability DS11 Manage Data Ensures back ups are available for recovery74
  75. 75. CobiT and Change Management Control Objectives  Changes to data structures are authorized, made in accordance with design specifications and are implemented in a timely manner.  Changes to data structures are assessed for their impact on financial reporting processes. “Unauthorized change is one of the best (and worst) ways to get your auditor’s attention.” Source: Scheffy, Brasche, & Greene, IT Compliance for Dummies, (2005, Wiley, ISBN 0-471-75280-0)75
  76. 76. Compliance Requirement for Database Change Management Changes to the database are widely communicated, and their impacts are known beforehand. Installation and maintenance procedure documentation for the DBMS is current. Data structures are defined and built as the designer intended them to be. Data structure changes are thoroughly tested. Users are apprised, and trained if necessary, when database changes imply a change in application behavior. The table and column business definitions are current and widely known. The right people are involved throughout the application development and operational cycles. Any in-house tools are maintained and configured in a disciplined way. Application impacts are known prior to the migration of database changes to production. Performance is maintained at predefined and acceptable levels. The database change request and evaluation system is rational. Turn-around time on database changes is predictable. Any change to the database can be reversed. Database structure documentation is maintained. Database system software documentation is maintained. Migration through development, test, and especially, production environments is rational. Security controls for data access is appropriate and maintained. Database reorganizations are planned to minimize business disruption.76 Source: SOX Requirements for DBAs in Plain English by James McQuade
  77. 77. Database Change Management Databases protected with controls to prevent unauthorized changes  Proper security for DBAs - including access to tools Ensure controls maintained as changes occur in applications, software, databases, personnel  Maintain user ids, roles, access  Ability for replacement personnel to perform work  Test processes  Change control logs to prove what you said was done, has been done  Backout procedures  Reduce system disruptions  Accurate and timely reporting of information Routine, non-routine, emergency process defined and documented  Complex and trivial changes follow the same procedures?77
  78. 78. And it all Requires… As data volume expands and more regulations hit the books, metadata will increase in importance  Metadata: data about the data  Metadata characterizes data. It is used to provide documentation such that data can be understood and more readily consumed by your organization. Metadata answers the who, what, when, where, why, and how questions for users of the data. Data without metadata is meaningless  Consider: 27, 010110, JAN78
  79. 79. Data Categorization Data categorization is critical  Metadata is required to place the data into proper categories for determining which regulations apply — Financial data  SOX — Health care data  HIPAA — Etc.  Some data will apply to multiple regulations  Who does this now at your company? Anyone?79
  80. 80. Convergence of DBA and DM  Database Administration  Data Management — Backup/Recovery — Database Security — Disaster Recovery — Data Privacy Protection — Reorganization — Data Quality Improvement — Performance Monitoring — Data Quality Monitoring — Application Call Level Tuning — Database Archiving — Data Structure Tuning — Data Extraction — Capacity Planning — Metadata Management Managing the database environment Managing the content and uses of data80
  81. 81. So, What is the Impact of Regulatory Compliance? Data Management vs. Database Administration  Data Governance Business acumen vs. bits-and-bytes  Can’t abandon technical skills, but must add more soft skills to your bag of tricks Communication and Inter-organizational Cooperation  IT, Lines of Business, Legal81
  82. 82. Forecast: DBA challengesPerformance and tuningPatch/upgrade B&R Security2002 2003 2004 2005 2006 2007 2008 2009 201082
  83. 83. Challenges: Compliance & Database Management Source: Unisphere Research, OAUG Automating Compliance 2006 Survey83
  84. 84. Web References Industry Organizations and References         - (Basel II)  
  85. 85. Some Recommended Books  Implementing Database Security and Auditing by Ron Ben Natan (2005, Elsevier Digital Press, ISBN: 1-55558-334-2)  Manager’s Guide to Compliance by Anthony Tarantino (2006, John Wiley & Sons, ISBN: 0-471-79257-8)  IT Compliance for Dummies by Clark Scheffy, Randy Brasche, & David Greene (2005, Wiley Publishing, Inc., ISBN: 0-471-75280-0)  Cryptography in the Database: The Last Line of Defense by Kevin Kenan (2006, Addison-Wesley, ISBN: 0321-32073-5)  Electronic Evidence and Discovery: What Every Lawyer Should Know by Michele C.S. Lange and Kristin M. Nimsger (2004, ABA Publishing, ISBN: 1-59031-334-8)85
  86. 86. Craig S. Mullins NEON Enterprise Software www.DB2portal.com86