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Compliments of                                        al Edition
                                     Trend Micro Speci




   Co n q u e ri n g
   Com   pl ia nce

Learn to:
• Reduce the cost and complexity
  of security compliance

• Solve the toughest regulatory
  compliance challenges

• Maximize the real security value
  of your investments




Kevin Faulkner
Lawrence Miller
Trend Micro Incorporated, a global leader in Internet
content security and threat management, aims to create
a world safe for the exchange of digital information for
businesses and consumers. A pioneer in server-based
antivirus with over 20 years experience, Trend delivers
top-ranked security that fits customer needs, stops new
threats faster, and protects data in physical, virtualized,
and cloud environments.
Trend Micro Enterprise Security is a tightly integrated
offering of content security products, services, and
solutions powered by the Smart Protection Network.
Together they keep customers both compliant and
secure by addressing a broad range of compliance
controls, solving tough compliance challenges,
and delivering maximum protection with minimal
complexity.




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 dissemination, distribution, or unauthorized use is strictly prohibited.
Conquering
                  Compliance
                                  FOR


               DUMmIES
                                                           ‰




    TREND MICRO SPECIAL EDITION




                  by Kevin Faulkner
                 and Lawrence Miller




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Conquering Compliance For Dummies®, Trend Micro Special Edition
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   dissemination, distribution, or unauthorized use is strictly prohibited.
Introduction
         I   n the not-too-distant past, information security and compli-
             ance for most organizations was the exclusive dominion
         of a small security staff with little or no support (or budget),
         engaged in a tug-of-war with users that constantly sought
         creative new ways to circumvent seemingly needless security
         measures that hindered productivity.

         But now that PCI, HIPAA, SOX, and a plethora of European
         and other privacy regulations have become a part of our
         modern lexicon, information security and regulatory compli-
         ance have become the focus of many corporate boards and
         senior managers — and the subject of this book!



About This Book
         This book explains the challenges of regulatory compliance
         and how to address these challenges using a holistic, cost-
         effective approach that not only helps you achieve compli-
         ance across all applicable regulations but also to get real
         security for your organization and your valuable data.

         We show you how to achieve and maintain compliance by:

           ✓ Focusing on core cross-regulation controls
           ✓ Conquering the toughest compliance challenges
           ✓ Maximizing your protection and minimizing your costs

         Simply stated, that’s compliance without compromise!

         The contents of this custom book were provided by and pub-
         lished specifically for Trend Micro.




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dissemination, distribution, or unauthorized use is strictly prohibited.
2     Conquering Compliance For Dummies


    Foolish Assumptions
             We assume that you’re reading this book because you’re
             responsible for ensuring that your organization complies with
             a myriad of government and industry regulations — and you
             need some help. You may be a corporate officer, executive, or
             other senior manager, or you may be an IT security manager,
             network engineer, or system administrator.

             We assume that you have at least a basic understanding of
             the key security and privacy regulations that are relevant to
             your industry, the technology challenges of compliance, and a
             desire to make your compliance programs simpler and more
             cost-effective.



    How This Book Is Organized
             This book consists of six short chapters, summarized below.


             Chapter 1: Understanding the
             Compliance Mandate
             We start by exploring the regulatory landscape and clarifying
             the differences between security and compliance.


             Chapter 2: Targeting Core
             Compliance Controls
             In this chapter, we present a comprehensive, secure-once
             approach to achieving cross-regulatory compliance by identi-
             fying common technical controls and themes.


             Chapter 3: Addressing
             Compliance Challenges
             In this chapter, we discuss how to deal with specific compli-
             ance challenges, including evolving technology trends such as
             virtualization, teleworking, and cloud computing.


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    dissemination, distribution, or unauthorized use is strictly prohibited.
Introduction       3
         Chapter 4: Charging
         Through PCI DSS
         Chapter 4 focuses on the Payment Card Industry Data Security
         Standard (PCI DSS), showing you how to cost effectively safe-
         guard your business infrastructure and cardholder data —
         achieving both security and compliance.


         Chapter 5: Examining HIPAA
         and Healthcare Compliance
         Next, we take a closer look at U.S. HIPAA and other regulatory
         and privacy challenges facing the healthcare industry.


         Chapter 6: Ten Reasons to Use
         Trend Micro Enterprise Security
         Finally, in true For Dummies form, we conclude with a list of
         great reasons to use Trend Micro Enterprise Security solu-
         tions to help you achieve compliance without compromise!



Icons Used in This Book
         Throughout this book, we occasionally use icons to call
         attention to important information that is particularly worth
         noting. Here’s what to look for and what to expect:

         This icon points out information that may well be worth com-
         mitting to memory.


         This icon explains material of a technical nature and may be
         of more interest to a tech-savvy reader.


         This icon points out potential pitfalls and easily confused or
         difficult-to-understand terms and concepts.




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dissemination, distribution, or unauthorized use is strictly prohibited.
4     Conquering Compliance For Dummies

             This icon points out helpful suggestions and useful nuggets of
             information that may just save you some time and headaches.



    Where to Go from Here
             Each chapter in this book is written to stand on its own. You
             don’t necessarily need to start at the beginning to follow a sto-
             ryline! Chapters 2 and 3 give you the insights you need to effec-
             tively tackle most any regulation worldwide, while chapters
             4 and 5 target the specific requirements of PCI and HIPAA. So
             jump right in wherever it makes the most sense for you.

             At a minimum, we recommend reading Chapters 2 and 3 to
             gain insights into solving cross-regulation compliance chal-
             lenges. Finally, Chapter 6 will show you how Trend Micro
             Enterprise Security solutions can help you rapidly implement
             the cost effective, no-compromise strategies of this book.

             Or, you could just turn the page and start at the beginning!




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    dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 1

         Understanding the
        Compliance Mandate
In This Chapter
▶ Navigating the regulatory landscape
▶ Achieving both compliance and security




         W       ith more than 400 regulations and over 10,000
                 overlapping controls in 38 countries, compliance
         has become a challenging and complex mandate for organiza-
         tions everywhere.

         Furthermore, the rapid pace and constantly evolving nature of
         technology and strategic business and IT initiatives makes attain-
         ing and maintaining regulatory compliance still more difficult.

         And finally, regulations typically lack detail, are subject to
         interpretation, and provide only minimum baseline security
         requirements. Thus, organizations can get compliance right,
         but still not be truly secure.

         In this chapter, we explore the vast expanse (and expense)
         of the regulatory compliance landscape and its associated
         challenges.



The Compliance Maze
         Driven by the need to protect the private data (such as per-
         sonally identifiable information, financial data, and health
         records) of individual citizens from cybercriminals and iden-
         tity thieves, governments throughout the world and at every


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6     Conquering Compliance For Dummies

             level have caught the regulatory bug. Information security
             best practices are rapidly being codified with legal mandates
             that seek to ensure that corporate governance, internal con-
             trols, business processes, and operations of organizations in
             various industries are safe, sound, and secure.

             These regulations often require specific controls, corporate
             compliance programs, audits, and public disclosures, and levy
             stiff penalties for noncompliance. Some of the more significant
             information and data security regulations include:

               ✓ PCI DSS: Payment Card Industry Data Security Standard.
                 A worldwide industry mandate that establishes informa-
                 tion security requirements for organizations that process
                 payment card transactions (such as credit and debit
                 cards). See Chapter 4 for more on PCI DSS.
               ✓ EU Data Protection Directive: The EU directive and vari-
                 ous country-specific acts protect individual information
                 of a private or sensitive nature.
               ✓ FISMA: Federal Information Security Management Act.
                 Applicable to U.S. Government agencies and contractors.
               ✓ GLBA: Gramm-Leach-Bliley Act. Standards required
                 of financial institutions relating to administrative, techni-
                 cal, and physical safeguards for customer records and
                 information.
               ✓ HIPAA: Healthcare Insurance Portability and
                 Accountability Act. Security and Privacy Rules apply to
                 “covered entities” and their business associates in the
                 healthcare industry. See Chapter 5 for more on HIPAA.
               ✓ HITECH: Health Information Technology for Economic
                 and Clinical Health Act. Provides funding for electronic
                 health records (EHR) and safe harbor from disclosure
                 requirements for breached data that is encrypted, among
                 other things. See Chapter 5 for more on HITECH.
               ✓ SOX: Sarbanes-Oxley. Publicly traded companies must
                 implement a framework of computer controls. Several
                 mandates can’t be accomplished without prudent use of
                 technology and information security.
               ✓ J-SOX: Formally, the Financial Instruments and Exchange
                 Law, J-SOX is the Japanese implementation of internal
                 controls similar to U.S. SOX.



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Chapter 1: Understanding the Compliance Mandate              7
           ✓ EuroSox: Comprised of two EU statutes, formally known
             as the Statutory Audit and the Company Reporting
             Directives. Requires EU member states to implement
             internal controls similar to U.S. SOX by 2010.
           ✓ MITS: Management of Information Technology Security
             (Canada). Monitoring, lifecycle management, technical
             and operational safeguards for risk mitigation, applicable
             to Canadian government agencies.


Compliance and Security
Aren’t One and the Same
         Being compliant doesn’t necessarily mean being safe and
         secure. Even the most stringent regulations define only a mini-
         mum baseline for good security. So it is certainly possible, if
         not even probable, that an organization can be fully compli-
         ant with all applicable legal requirements and standards for
         its industry, yet still be vulnerable to security breaches and
         incidents.

         Regulations and standards mandate information security best
         practices and governance, reassure the public at large, and
         set forth penalties (including fines, disclosures) for noncom-
         pliance. In other words, when a noncompliant organization
         suffers a major security breach, security regulations ensure
         that there will be repercussions

         Regulatory compliance also, at least in theory, serves a more
         benign purpose. Disclosure laws, in addition to “shaming” an
         organization into compliance, are intended to give a timely
         warning to individuals whose private information may have
         been compromised. That way, the individuals may take proac-
         tive steps to avoid being victimized by identity theft.

         Finally, regulations help to clarify the standards of due care
         and due diligence. Due care and due diligence are related, but
         distinctly different:

           ✓ Due care: In the practice of information security, due
             care relates to the steps that individuals or organizations
             take to perform their duties and implement security best
             practices and regulations.



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8     Conquering Compliance For Dummies

               ✓ Due diligence: In the context of information security, due
                 diligence commonly refers to risk identification and risk
                 management practices.

             An organization or individual that fails to exercise due care
             and due diligence in the performance of their duties can be
             found criminally negligible and personally liable.

             So what is the state of enterprise security today? Trend
             Micro’s onsite security threat assessments of hundreds of
             enterprises throughout the world have shown that 100 per-
             cent are infiltrated by active malware — over 50 percent with
             data stealing malware and 77 percent with bots (see Figure
             1-1). Organizations need to be aware that basic compliance
             controls aren’t sufficient to protect against a serious security
             data breach.


                   Threats found in enterprises
                  100% Active malware
                          77% Bots
                                 56% Data stealers
                                         42% Worms


             Figure 1-1: Threats found in enterprises.


             And without a comprehensive security strategy and a strong
             understanding of regulatory issues affecting them, many organi-
             zations risk spending needlessly, while chasing redundant — or
             worse, conflicting — administrative, technical, or operational
             controls, in the quest for compliance.




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    dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 2

           Targeting Core
         Compliance Controls
In This Chapter
▶ Getting an overview of the controls common to most regulations
▶ Covering all the controls in more depth




         B      y focusing on the core compliance controls common to
                most regulations you will help reduce cost and dupli-
         cation of effort. If you properly secure once, you can meet a
         majority of individual compliance regulations without further
         effort. And when implemented appropriately, these controls
         put you well down the road toward a strong security posture.

         Developing and implementing clear policies and processes,
         and selecting the right technology solutions that support a
         broad range of common security mandates will help organiza-
         tions succeed in their quest to achieve cost-effective security
         and compliance.



Addressing Core Controls
         For the most part, information security and privacy regula-
         tions are based on well-established information security best
         practices. Because many of these best practices are common
         across regulations, focusing your efforts on these core con-
         trols, and adopting a technology infrastructure that meets the
         intent of the various compliance mandates, will allow you to
         build a strong security foundation while simultaneously satis-
         fying many of the compliance requirements applicable to your



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10     Conquering Compliance For Dummies

              organization. These core compliance controls are identified
              and described in the following sections.

              The core compliance controls are directly specified or implied
              by a broad range of regulatory and IT standards across the
              globe. The core security compliance controls and a few exam-
              ples of applicable regulations are listed in Figure 2-1.

                  Core Security               Privacy Laws         Financial Fraud            Government
               Compliance Controls                                    Protection              IT Security
                                          • EU Data Protection
              • IT Risk Assessment          Directive
                                          • Australia Priv. Act   • SOX                   • US FISMA; NIST
              • Vulnerablilty & Patch Mgt • Canado PAPEDA         • J-SOX                 • Canada MITS

              • IT Policy Adherence
                                               Credit Card            Healthcare              Finanacial
              • Incident Response               Security             Data Privacy            Data Privacy
              • Sensitive Data Protection • PCI DSS               • US HIPAA              • US GLBA
                                                                  • US HITECH Act
              • Firewall, IDS/IPS

              • Anti-virus/Anti-malware      IT Frameworks                   Other Regulation & Standards
                                                                              US NERC, FERC; UK,German,
              • Anti-spam/Anti-phishing
                                          • COBIT; COSO                       Swiss Data Protection; Sys Trust;
              • Logging & Reporting       • ITIL; ISO                         USAe 3402

              Figure 2-1: Core security compliance controls and examples of regulations.


              See Appendixes A and B to learn how the core controls
              specifically apply to HIPAA and PCI.



     IT Risk Assessment
              Maintaining an ongoing security risk assessment program
              helps an organization identify relevant assets that must be
              protected, and what threats and vulnerabilities they must
              be protected against.

              A risk assessment is a critical early (and ongoing) step in the
              IT risk management process. A risk assessment identifies
              three specific elements of risk:

                 ✓ Assets. This includes an inventory and valuation of all
                   organizational information assets including systems,
                   devices, applications, data, and processes.
                 ✓ Threats. This includes an analysis to determine actual
                   threats, possible consequences, likelihood of occurrence,
                   and probable frequency.

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Chapter 2: Targeting Core Compliance Controls           11
           ✓ Vulnerabilities. This includes a vulnerability assessment
             to determine weaknesses and to establish a baseline for
             determining appropriate and necessary safeguards.

         Don’t confuse vulnerability assessments with vulnerability
         management (discussed later in this chapter). They are
         distinctly different concepts.



Vulnerability and Patch
Management
         Effective vulnerability management requires periodic and
         frequent (automated) scans of all systems, applications, and
         network devices to identify, prioritize, mitigate, and patch
         security vulnerabilities that may be exploited.

         A vulnerability in information security is defined as the
         absence or weakness of a safeguard in an information asset
         that makes a threat potentially more harmful or costly, more
         likely to occur, or likely to occur more frequently.

         Vulnerabilities can exist for a number of reasons, including

           ✓ Programming/development bugs or flaws
           ✓ Improper system or device configurations
           ✓ Human errors

         Additionally, new vulnerabilities are discovered, literally
         every day, because

           ✓ Flaws and weaknesses are discovered in both new and
             legacy information assets
           ✓ New flaws and weaknesses are created by changes
             to existing information assets, such as configuration
             changes, software updates, and patches

         Patch management must be performed regularly to ensure
         applications, databases, and systems are updated with the
         latest security patches provided by the product vendors.




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12     Conquering Compliance For Dummies

              Virtual patching or shielding refers to using rules defined
              in IDS/IPS agents to stop known vulnerabilities from being
              exploited. Virtual patching is an excellent security practice
              that provides protection until patches can be deployed. It
              may also be accepted as a compensating control for systems
              that are difficult or impossible to patch in a timely manner.

              Effective patch management requires awareness of new vul-
              nerabilities and security patches, risk analysis, optional vir-
              tual patching, and the testing, deployment, and verification of
              final patches.



     IT Policy Adherence
              Assuring endpoint and server compliance with OS configura-
              tion and application access control policies increases security
              and allows organizations to clearly document compliance
              with security regulations and company policies.

              A formal, written security policy — along with supporting
              standards, guidelines, and procedures — forms the basis for
              the organization’s information security program.



     Incident Response
              A well-written incident response plan helps ensure that prop-
              erly trained personnel can quickly and effectively respond to
              a security incident in order to minimize the potential damage
              and return the business to normal operation.

              An incident response plan should include detailed procedures
              and technologies that will be used to rapidly address all
              foreseeable incidents.



     Sensitive Data Protection
              Organizations must locate, identify, classify, and protect regu-
              lated data, whether it is being stored (at rest), processed (in
              use), or transmitted (in motion).




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Chapter 2: Targeting Core Compliance Controls           13
         Data loss prevention (DLP) is critical to stopping accidental
         and malicious data leaks. A robust DLP solution helps you:

           ✓ Discover, monitor, block, and encrypt sensitive data.
           ✓ Control removable media and I/O devices such as USB
             drives, CD/DVD, Bluetooth, and external drives.

         Encryption has almost universally become the accepted
         standard for protecting the confidentiality of sensitive data.
         Encryption solutions can be hardware- or software-based, and
         can encrypt sensitive files on an entire disk (full-disk encryp-
         tion) or on an individual file or folder level (file-based encryp-
         tion). Under many laws and regulations, an organization that
         suffers a data loss incident may be able to avoid any public
         disclosure requirements or penalties if the data was properly
         encrypted.



Firewalls and Intrusion Detection/
Prevention (IDS/IPS)
         Firewall and IDS/IPS protection is generally required for
         systems that process or house regulated data.

         These systems have traditionally been deployed at the
         corporate perimeter. However with increasingly mobile
         employees and the advent of virtualization, host-based (or
         endpoint) firewalls and intrusion detection/prevention
         systems are becoming increasingly necessary.



Anti-Virus and Anti-Malware
         Since the early days of computing, anti-virus software has
         been, and remains, a basic and vital component of security.

         Anti-malware protects systems and data from viruses, as well
         as Trojans, worms, spyware, and other threats. Anti-malware
         can be signature-based and/or behavior-based. However, many
         non-standard, critical, and legacy devices may not be compat-
         ible with traditional anti-malware software that is typically
         installed directly on a system or device. Instead, network-
         based anti-malware solutions may be necessary.

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14     Conquering Compliance For Dummies


     Anti-Spam and Anti-Phishing
              Protection from e-mail and blended e-mail/Web threats is vital
              to the security of employee devices and blocking the entry of
              malware to corporate infrastructure.

              Spam and phishing have evolved from the preferred method
              for directly spreading malware to become the preferred way
              to lure users to malicious Web sites where data-stealing mal-
              ware can be unwittingly downloaded. State-of-the-art e-mail
              protection solutions now include Web site reputation capa-
              bilities to help protect users from these dangerous embedded
              e-mail links.



     Logging and Reporting
              Organizations must ensure that secure log files are created
              and maintained on all systems and devices in order to identify
              and respond to security incidents and enforce policy compli-
              ance. Detailed reporting capabilities are needed to demon-
              strate compliance to management, auditors, and customers.

              Log files are only valuable when someone is monitoring them
              for unusual or suspicious activity. Additionally, active moni-
              toring may also be required to ensure compliance. Automated
              log collection and analysis tools are required to make these
              tasks efficient and effective.




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Chapter 3

     Addressing Compliance
          Challenges
In This Chapter
▶ Tackling the toughest operating environments
▶ Securing virtual and cloud infrastructures
▶ Automating   visibility and risk management




         Y     our organization’s unique operating environment, busi-
               ness and IT initiatives, and everyday constraints create
         tough challenges for your security and compliance posture
         that include:

           ✓ Risk visibility and control
           ✓ Server and desktop virtualization
           ✓ Public cloud computing
           ✓ Web sites and portals
           ✓ Non-standard and legacy systems
           ✓ Distributed locations
           ✓ Worker mobility
           ✓ Mitigating information risk




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16     Conquering Compliance For Dummies


     Evolving Technology
              Technology evolves quickly, but regulations don’t. Current
              trends include server and desktop virtualization and public
              cloud computing, which enable your organization to rapidly
              adapt to new business requirements with minimal IT infra-
              structure and investment. What are the risks? How can you
              remain compliant?


              Server and desktop virtualization
              Virtualization is one of the hottest trends in enterprise IT
              today. Server virtualization provides significant direct cost
              savings in terms of server hardware and operating expenses,
              and allows companies to embrace the efficiencies of a private
              cloud IT model. Desktop virtualization is also a rapidly grow-
              ing trend due to its ability to significantly reduce PC costs,
              management complexity, and enterprise risk.

              According to IDC, virtualization is now the default approach
              at most enterprise IT organizations, and Gartner projects that
              the number of virtual machines will grow ten times by 2012.

              But the complexity and fluidity of virtualized environments
              pose special security and compliance challenges, rendering
              perimeter-based firewalls, intrusion detection and prevention
              systems (IDS/IPS), as well as traditional anti-malware protec-
              tion insufficient to prevent attacks on virtual machines.

              According to Information Week, 88 percent of North American
              enterprises don’t have a virtualization security strategy in
              place — leaving them both at risk and noncompliant.

              Some specific security and compliance challenges associated
              with virtual server and desktop environments include:

                ✓ Inter-VM traffic. Traditional network IPS systems are
                  blind to potentially malicious inter-VM traffic.
                ✓ VM mobility. Virtual machine migration provides flexibil-
                  ity and resilience, but creates configuration and update
                  difficulties for traditional perimeter security.
                ✓ Dormant VMs. Dormant VMs can’t run scanning agents,
                  download signatures, or install patches, yet they’re still

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Chapter 3: Addressing Compliance Challenges              17
              vulnerable to tampering and open to immediate attack
              upon reactivation.
           ✓ Resource contention and full system scans. Standard anti-
             malware solutions aren’t VM-aware and thus simultaneous
             scanning can cause severe performance degradation.

         The best answer is system self-defense. Look for host-based
         virtualization-aware solutions that can secure both physical
         and virtual servers and endpoints with the same levels of pro-
         tection, integrity monitoring, compliance controls, and perfor-
         mance. A solution should include the following capabilities:

           ✓ Protection from both conventional and new virtual
             threats
           ✓ Optimized for virtualization system performance
           ✓ Integrated with VMware and/or Citrix management
           ✓ Software-based, single agent/appliance deployment


         Cloud computing
         While most organizations are already experiencing the sav-
         ings of virtualization and private cloud computing, industry
         experts predict that many enterprises will also eventually
         adopt public cloud computing (that is, making use of pub-
         licly shared general purpose server and storage services) to
         further enable business agility and IT savings. However, in
         addition to all the security threats inherent in virtualization,
         public cloud computing poses unique security and compli-
         ance challenges to systems and data, including:

           ✓ Compliance framework and risk responsibility. Cloud
             computing creates unique compliance challenges. Service
             providers know this and, for the most part, simply pass
             liability for compliance on to you, the customer.
           ✓ Multi-tenancy. VMs for different customers with varying
             security policies may coexist with your VMs.
           ✓ Data protection. Encryption of application and system
             data is vital in a publicly shared environment.
           ✓ Lack of security visibility. Your virtual infrastructure is
             remotely located and thus real-time visibility and control
             are of concern.


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18     Conquering Compliance For Dummies

              You’re ultimately on your own for compliance and risk man-
              agement in the public cloud. To protect your total computing
              environment, choose specialized solutions that include:

                ✓ Dedicated virtualization host protection
                ✓ Volume-level data encryption to protect data at all times
                ✓ Strong remote management for systems security and
                  encryption key management



     Business Innovations
              Innovations such as mobile technology and Web sites with
              dynamic content and powerful capabilities are challenging tra-
              ditional perimeter-based security and compliance solutions.


              Web sites and portals
              Your Web site’s public exposure and ever-changing content
              make it extremely attractive to cybercriminals attempting to
              steal private customer information or sensitive company data.
              And although it is less of a motive for hackers today, a com-
              promised or defaced Web site can still do major harm to an
              organization’s reputation.

              Web sites and external portals need the same host protec-
              tion and vulnerability management as any mission-critical
              server, plus specific application vulnerability scanning, virtual
              application patching, and perhaps approved PCI scanning to
              ensure protection of your data, and more importantly, your
              reputation.


              Worker mobility
              Today’s workforce is more mobile than ever with laptop PCs,
              smartphones, and other portable devices enabling work from
              practically anywhere, at any time.

              Teleworking creates new security and compliance challenges,
              because remote employees working outside the corporate
              perimeter must be as protected as any office worker. Remote
              access security, personal use of devices, and the potential


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Chapter 3: Addressing Compliance Challenges             19
         for data leakage must be addressed. Smartphones and wire-
         less devices (such as Blackberries and iPhones) are capable
         of carrying as much (sensitive) data as a laptop PC, and are
         far more susceptible to loss or theft. How can you effectively
         manage compliance in your mobile workforce?

         Only a cloud-enabled endpoint security solution can pro-
         tect a full range of devices from Web, e-mail, and file threats
         wherever they roam. You’ll also want to investigate endpoint
         encryption and DLP — they’re becoming essential as these
         devices increasingly store protected data.



Implementation Difficulties
         Applying security and compliance controls to a highly distrib-
         uted store/branch environment or to non-standard systems can
         be difficult and cost-prohibitive. And implementing risk man-
         agement and data protection solutions that truly fit your par-
         ticular needs requires a clear strategy and strong processes.


         Risk visibility and control
         Everyone’s familiar with the constant drumbeat of software
         vulnerabilities and subsequent exploits, and it’s critical that
         you be able to rapidly and reliably discover and mitigate them.
         How can you automate this process? How do you protect sys-
         tems when patches aren’t yet available? How do you ensure
         employees follow your organization’s IT security policies?

         But managing security risks isn’t just about vulnerability and
         policy management. Even the best vulnerability management
         and security defenses can be penetrated by zero-day and tar-
         geted threats. And once they’re in, they’re difficult to detect
         with standard security tools.

         An end-to-end vulnerability management strategy involves
         multiple products and procedures to rigorously discover,
         shield, and successfully patch systems on a continual basis.
         The best place to start is with a vulnerability management
         platform that offers scanning plus overall process manage-
         ment. Consider addressing your risk visibility challenges with
         a threat management solution that offers continual network-
         level infiltration discovery and remediation.


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20     Conquering Compliance For Dummies



        Silgan Containers dramatically improves
           risk visibility and incident response
       With more than 38 manufacturing             As a result, IT has gained more con-
       plants, Silgan Containers (www.             trol of security. The increased visibil-
       silgancontainers.com) is the                ity provided by Threat Management
       largest manufacturer of metal food          Services reports has helped them
       containers in its markets. Its custom-      strengthen overall security and more
       ers include many of the biggest names       effectively enforce company poli-
       in the food industry, and the company’s     cies. Automatic remediation speeds
       continued success depends on its            incident response actions while
       uninterrupted supply lines.                 saving time for IT.
       Although Silgan has a robust, multi-        “With Threat Management Services,
       layered security solution protecting        infections are being caught and
       the company’s infrastructure, infec-        cleaned up without taking hours
       tions still occurred and IT had to          of my time,” said Draeger. “With
       devote significant resources to mon-        the overwatch provided by Threat
       itoring security status and ensuring        Management Services, we now have
       that employees were not breaking            a stronger level of confidence that
       security policies. Clean-up efforts         we have ultimate protection of cor-
       consumed valuable IT time and IT            porate assets . . . I gain the visibility
       lacked the overall risk visibility and      and control over my security posture
       control it desired.                         that I’ve never had before.”
       “We deployed the Trend Micro                The key benefits of the Trend Micro
       Threat Discovery Appliance to gain          solution include:
       insights into the state of our security,”
                                                   ✓ Continuous risk assessment:
       explained Michael Draeger, in charge
                                                     Detailed daily threat discovery
       of network and computer security for
                                                     reports and analysis expose
       all Silgan Containers sites. “Before
                                                     active threats and malicious
       we had this solution, we had no way
                                                     activity.
       to really see where our vulnerabili-
       ties were. As an extra layer on top of      ✓ Incident response: Automated
       our existing security solutions, Trend        detection and remediation cuts
       Micro Threat Management Services              management costs by 50 percent.
       tells me exactly what’s happening on
                                                   ✓ Management reporting: Security
       the network.”
                                                     posture and policy adherence
                                                     evaluation and guidance.




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Chapter 3: Addressing Compliance Challenges             21
         Non-standard systems and devices
         Many businesses depend on a range of legacy or proprietary
         systems, dedicated devices, and sensitive servers that can’t
         be directly secured by traditional anti-malware and security
         solutions. And even when third-party security software is sup-
         ported, running it on these systems may not be desirable.

         For example, MRI scanners, X-ray machines, and other
         patient care devices used in the healthcare industry are typi-
         cally closed, proprietary systems. Similarly, within the retail
         industry, point-of-sale (POS) systems and inventory control
         systems often operate on proprietary or legacy systems and
         software.

         Bring your non-standard and sensitive systems into com-
         pliance with a network-based solution that can provide a
         non-intrusive, agentless anti-virus compensating control by
         detecting active infiltrations and providing an immediate alert
         and remediation assistance.



Mitigating Information Risk
         Encryption of e-mails containing protected data is a core
         requirement, but PKI-based (public key infrastructure based)
         encryption is notoriously complex and burdensome to
         administer and use. Data Loss Prevention (DLP) can play an
         important role in regulatory and policy compliance and over-
         all information risk assessment via sensitive data discovery,
         monitoring, and blocking. But organizational and protection
         needs vary widely. For some, full endpoint protection is a
         necessity, for others, a network solution is sufficient, and for
         yet others a less-robust “DLP lite” is desired.

         Regulations focus primarily on custodial data — the private
         data that corporations keep on their customers. And although
         protecting this data is the whole point of compliance, analysts
         estimate that the value of this data is less than half that of
         the corporate IP data not covered by compliance. So a com-
         pliance-dominated data protection program may be leaving
         much of your valuable data at unwarranted risk.




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22     Conquering Compliance For Dummies

              Integrate DLP into your data protection strategy with a solu-
              tion that offers the flexibility of deployment and protection
              levels that best suit your needs. Consider identity-based
              encryption as an equally powerful, but more effective encryp-
              tion alternative to PKI solutions.



     Distributed Locations
              Industries such as hospitality, food service, retail, and,
              increasingly, healthcare are dependent on extremely distrib-
              uted branch/store environments. Each location typically has
              a simple flat, mixed-used network, POS, and other specialty
              devices, and limited, if any, local IT staffing. These challenges
              multiplied by hundreds or thousands of sites make security
              and compliance especially difficult and costly.

              Investigate host-based software solutions that provide fire-
              wall, IPS, integrity monitoring, and other protections to criti-
              cal host systems without the cost and ongoing management
              complexity of perimeter security devices.




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     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 4

 Charging Through PCI DSS
In This Chapter
▶ Getting the basics of PCI DSS
▶ Identifying and addressing PCI compliance challenges




         T    he Payment Card Industry Data Security Standard (PCI DSS
              or simply, PCI) is a worldwide industry initiative that spec-
         ifies and enforces security standards to protect sensitive card-
         holder data from theft. PCI was created by the major payment
         card brands to protect themselves (and consumers) from the
         theft and fraudulent use of the primary account number (PAN)
         and sensitive authentication data that allows us all to confi-
         dently spend our money.

         In this chapter, we explore PCI compliance requirements,
         challenges, and solutions.



Understanding PCI
Requirements
         PCI applies to any business that transmits, processes, or
         stores credit card transactions — regardless of whether
         a business processes thousands of transactions a day, or
         a single transaction a year. Compliance is mandated and
         enforced by the payment card brands (American Express,
         MasterCard, Visa, and others) and each manages its own com-
         pliance program.

         Merchants and processors are categorized into levels by the
         number of yearly transactions they manage (see Table 4-1).
         And while all levels must comply with the requirements, only


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24     Conquering Compliance For Dummies

              level 1 and 2 merchants must undergo a yearly on-site audit
              by a Qualified Security Assessor (QSA).


               Table 4-1                         Merchant Categories for PCI
               PCI Level      Transactions        Onsite          Self-        Network
                              Per Year            Audit           Assessment   Scan
               1              > 6M                Annually                     Quarterly
               2              1M – 6M             Annually*                    Quarterly
               3              20K – 1M                           Annually      Quarterly
               4              < 20K                              Annually      Quarterly
               * Master Card merchants only, at the time of this writing


              PCI version 1.2 consists of six core principles, supported by
              12 accompanying requirements, and more than 200 specific
              controls for compliance. Compared to most security regula-
              tions, PCI is both broader in scope and more precise in speci-
              fication detail. Although it is far from being a full blueprint
              for enterprise security, it is credited with raising the security
              standards and awareness of many organizations around the
              world.

              PCI is a living specification that is expanded and amended on
              a regular basis by a cross-industry working group. PCI audit
              standards are also periodically evolving to better encompass
              new technologies and to tighten enforcement criteria.

              Penalties for noncompliance are levied by the payment card
              brands and are some of the toughest among security regula-
              tions. These currently include:

                   ✓ Fines up to $25,000 per month for minor violations.
                   ✓ Fines up to $500,000 for violations that result in actual
                     lost or stolen financial data.
                   ✓ Loss of card processing authorization, making it almost
                     impossible for many businesses to function.

              See Appendix B for a mapping of core controls to PCI
              requirements.




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     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 4: Charging Through PCI DSS           25

Handling Top PCI Challenges
         Achieving and maintaining PCI compliance in a dynamic busi-
         ness and technology environment is no simple task. Building
         a security compliance solution strategy to handle the core
         controls (see Chapter 2) is essential, but you will also need to
         solve many tough compliance challenges that are covered in
         Chapter 3 and the following sections.


         Virtualization
         The topics of virtualization and cloud computing aren’t spe-
         cifically addressed by the current PCI requirements, leaving
         appropriate judgments to QSAs and their clients. But the
         complexity and dynamic nature of virtualized environments
         clearly pose security and compliance challenges beyond the
         protection capabilities of perimeter-based firewalls, intrusion
         detection and prevention systems (IDS/IPS), as well as tradi-
         tional anti-malware protection. How do you virtualize your
         systems with confidence?

         Look for a virtualization-aware solution that can secure against
         new virtualization threats but can also provide both physical
         and virtual servers with the same levels of protection, integrity
         monitoring, PCI compliance controls, and performance.


         Risk visibility and control
         The broad topic of risk management is addressed in several
         ways by the PCI standard. PCI recognizes the importance
         of vulnerability management — specifying requirements for
         continual scanning and timely patch deployment. It also rec-
         ognizes the need for policy compliance and regular security
         assessments. But automating the execution of these error-
         prone and costly processes requires a sound strategy and a
         special set of technology solutions.

         An end-to-end vulnerability management strategy involves
         multiple products and procedures to rigorously discover,
         shield, and successfully patch systems on a continual basis.




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26     Conquering Compliance For Dummies

              The best place to start is with a vulnerability management
              platform that offers scanning plus overall process manage-
              ment. Consider that virtual patching can be used as a best
              practice and compensating control to close your window of
              exposure to vulnerabilities, protect “unpatchable” systems,
              and eliminate costly ad-hoc and emergency patching.


              E-commerce Web sites
              Despite their importance to e-commerce and your company’s
              reputation, Web sites remain extremely vulnerable to attack
              and hijacking, putting both individual customers and your
              entire database at risk.

              PCI sets specific baseline scanning requirements for Web site
              security, but how can you be certain you’ve got the best pro-
              tection against sophisticated SQL injection attacks and other
              threats used to exploit your ever-changing Web content?

              Your Web site needs much more than PCI scanning to be pro-
              tected. You’ll want the same host protection and vulnerability
              management as any mission-critical server, plus specific Web
              application vulnerability scanning to ensure protection of
              your dynamic Web content.


              Distributed locations
              Network-based perimeter security is cost-prohibitive for any
              widely dispersed business such as retail, hospitality, and
              increasingly, healthcare. These distributed locations typi-
              cally have flat, multi-use networks, specialty POS and other
              devices, and little or no local IT management. How can you
              protect in-scope systems at distributed locations in a cost
              effective manner?

              Investigate host-based software solutions that provide
              firewall, IPS, integrity management, virtual patching, and
              other protections to critical host systems without the cost
              and ongoing management complexity of perimeter security
              devices and multiple agent solutions.




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     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 4: Charging Through PCI DSS                  27

       Noodles & Company – Beyond PCI
  Noodles & Company (w w w .               firewall appliances at each restau-
  noodles.com) has more than               rant. “We chose Trend Micro Deep
  230 restaurants in 18 states. The        Security because it helps us address
  company is committed to employing        the major PCI compliance require-
  the best possible security technol-      ments with features like file integrity
  ogy for protecting customers’ credit     monitoring. It helps us do all we pos-
  card information. In fact, Noodles &     sibly can to safeguard credit card
  Company doesn’t just want to meet        data.”
  PCI requirements — they want to
                                           The key benefits of the Trend Micro
  exceed them.  “We like to think of
                                           solution include:
  PCI as a baseline — we are looking
  to pass, and also pass with flying       ✓ PCI compliance and more: Trend
  colors,” said Nick Fields, a senior IT     Micro Deep Security helps
  systems administrator at Noodles &         Noodles achieve compliance
  Company. “We feel we are ahead of          and meet their demanding secu-
  a lot of the industry, and we want to      rity goals.
  stay there.”
                                           ✓ Best TCO for distributed loca-
  As the company has grown, soft-            tions: Deep Security provides a
  ware solutions became a more cost-         more cost-effective solution com-
  effective alternative to hardware          pared to hardware appliances.




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28     Conquering Compliance For Dummies




     These materials are the copyright of Wiley Publishing, Inc. and any
     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 5

      Examining HIPAA and
     Healthcare Compliance
In This Chapter
▶ Covering the basics of HIPAA, HITECH, and more
▶ Protecting ePHI data, mobile devices, medical equipment, and more




         H      ealthcare systems throughout the world are in a time
                of great transition. In the U.S., for example, government
         mandates for electronic medical records/electronic health
         records (EMR/EHR) systems are linked to increasing privacy
         and security regulations for electronic Protected Health
         Information (ePHI). Around the globe, technology advances
         are causing a growing privacy focus among government regu-
         lators. Targeting the core controls (see Chapter 2) will help
         healthcare organizations comply with the regulations they
         face, but they also must solve many tough compliance chal-
         lenges (see Chapter 3) that we cover in this chapter.

         The terms electronic medical record (EMR) and electronic
         health record (EHR) are increasingly used interchangeably.
         Technically, an EMR is the health-related information about
         an individual within a single care provider organization,
         whereas an EHR is the aggregate health-related information
         about an individual across multiple organizations. For simplic-
         ity, we refer to both as an EHR.

         Although EHR systems may ultimately lead to more efficient
         and effective patient care, they also increase the threat of
         cybercrime and large-scale breaches of ePHI. Moreover,
         increased reliance on IT and EHR systems means that a




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30     Conquering Compliance For Dummies

              security risk or vulnerability has the potential to be life-
              threatening. Compliance with security regulations will guide
              healthcare providers of all types to mitigate their risk, but
              maximizing protection of these complex operations requires a
              broader strategy.

              Healthcare organizations throughout the world are facing sim-
              ilar security and compliance challenges as those outlined in
              this chapter. Addressing core controls is an effective strategy
              to meet these and other regulations that may apply.

              In this chapter, we take a closer look at healthcare regulations
              and compliance issues. See Appendix A for details on how the
              core controls map to HIPAA and HITECH requirements.



     Regulatory Compliance in the
     Healthcare Industry
              For more than a decade, patient data privacy and security
              regulations have slowly evolved. But new, stricter privacy
              requirements, mandates for EHR modernization, and govern-
              ment funding are now driving the industry forward and sig-
              nificant investments are being made to modernize and secure
              their operations.


              Protecting ePHI with HIPAA
              The U.S. Health Insurance Portability and Accountability Act
              (HIPAA) of 1996 states that “covered entities” are required to
              employ safeguards that “ensure the confidentiality, integrity,
              and availability of all ePHI” under their control.

              HIPAA compliance applies to covered entities (including
              health insurers, healthcare clearinghouses, and healthcare
              providers), as well as their business associates.

              The HIPAA Privacy Rule consists primarily of administrative
              and physical controls and the HIPAA Security Rule consists of
              technical controls.




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     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 5: Examining HIPAA and Healthcare Compliance                         31

       Mercy Memorial Hospital System
         maximizes compliance and
             business continuity
  Founded in 1929, Mercy Memorial           solutions are powered by the Trend
  Hospital System (www.mercy                Micro Smart Protection Network
  memorial.org) today includes a            infrastructure. Together they help
  central 238-bed, full-service commu-      keep Mercy Memorial both com-
  nity hospital complex and 28 remote       pliant and secure by addressing a
  locations and offices. Although           broad range of compliance controls,
  HIPAA compliance and the protec-          enabling business innovation, and
  tion of patient information on its 200    delivering maximum protection with
  servers and 900 desktop computers         minimal complexity.
  is a must for the healthcare provider,
                                            Deploying Trend Micro Enterprise
  business continuity is also an over-
                                            Security minimized IT time spent
  arching priority.
                                            managing security, increased the
  “We must go beyond simply meeting         up-time for Web protection, and
  compliance requirements, and also         maximized the value obtained from
  integrate best practices for security     the existing virtual environment. “The
  within our business operations,” said     Trend Micro solutions have done a
  Eric Mynster, ITS operations man-         good job of safeguarding patient data
  ager for the organization. “We need       as well as maximizing our employees’
  to do everything we can to block          productivity,” says Mynster.
  threats to security and productivity.”
                                            The key benefits of the Trend Micro
  Risk assessment and prioritization is     solution include:
  an ongoing activity within the orga-
                                            ✓ Meeting compliance require-
  nization, and IT wanted a security
                                              ments: Trend Micro helps Mercy
  solution that could help with efforts
                                              Hospital achieve and exceed
  to maintain a proactive stance for
                                              healthcare compliance controls.
  compliance and overall security. “We
  were looking at many individual secu-     ✓ Minimized risks: Trend Micro
  rity products — individual anti-virus,      Enterprise Security defense-in-
  e-mail filters, spam solutions, and URL     depth provides maximum threat
  filtering — but Trend Micro offered         protection.
  us the value of a complete package,”
                                            ✓ Alignment with virtualization:
  said Mynster. “Trend Micro Enterprise
                                              With VMware Ready certifica-
  Security was extremely competitive
                                              tion, Trend Micro solutions inte-
  and covered all of our needs.”
                                              grate into today’s virtual server
  The tightly integrated offering of con-     environments.
  tent security products, services, and



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32     Conquering Compliance For Dummies


              Implementing the HIPAA Security
              Rule with NIST
              In 2008, the U.S. National Institutes of Standards and
              Technology (NIST) authored SP 800-66 Rev. 1, as a framework
              for federal agencies to achieve HIPAA compliance.

              NIST publications are considered trusted resources for
              technology implementation guidance. As a result, many non-
              government agencies can also benefit from the technical
              specifications highlighted in this guide.

              NIST SP 800-66 is freely available for download (along with
              many other great IT security resources) at http://csrc.
              nist.gov/publications/PubsSPs.html.


              Stimulating modernization and
              compliance with HITECH
              Title XIII of the American Recovery and Reinvestment Act
              (ARRA) of 2009, also known as the Health Information
              Technology for Economic and Clinical Health Act (HITECH
              Act), further reinforces the existing 2014 EHR implementation
              mandate and provides the necessary incentives to accelerate
              EHR adoption and clarify key HIPAA security requirements.
              Key provisions of the Act include:

                ✓ Funding: Most significant in the Act is actual funding
                  support for EHR conversion via ARRA funds.
                ✓ Risk assessments: Risk assessments can be both proactive
                  and reactive. The Act specifically identifies risk assess-
                  ments as necessary in determining, after the fact, whether
                  an incident is indeed a breach of unsecured ePHI.
                ✓ Breach notification requirements: The Act specifies
                  disclosure requirements for ePHI that is “not secured
                  through technology or methodology.” Not only do the
                  disclosure requirements subject the breached organiza-
                  tion to public scrutiny, but the costs associated with
                  notifying affected individuals can also be significant.




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Chapter 5: Examining HIPAA and Healthcare Compliance               33
           ✓ Safe Harbor through encryption: The Act defines
             secured ePHI as data that is either encrypted or
             destroyed. It goes further to state that if secured ePHI
             is involved in a data breach, notification requirements do
             not apply. This is a significant directive, specifically pre-
             scribing encryption as both a preferred means to enforce
             confidentiality and as a relief from breach notification
             requirements.

         HIPAA and HITECH compliance may be top of mind, but most
         large U.S. healthcare organization are also probably subject to
         a number of other regulations, administrative requirements,
         and auditing standards, such as the following:

           ✓ PCI (discussed later in this chapter and in Chapter 4)
           ✓ U.S. Federal Trade Commission (FTC)
           ✓ U.S. Department of Health and Human Services (HHS)
           ✓ Centers for Medicare and Medicaid Services (CMS)
           ✓ Office of the National Coordinator (ONC)
           ✓ Joint Commission
           ✓ Certification Commission for Health Information
             Technology (CCHIT)
           ✓ Healthcare Information Technology Standards Panel
             (HITSP)
           ✓ Healthcare Information and Management Systems Society
             (HIMSS)
           ✓ Electronic Healthcare Network Accreditation
             Commission (EHNAC)
           ✓ Genetic Information Nondiscrimination Act (GINA)
           ✓ Various state data breach laws
           ✓ International Organization for Standardization (ISO)
           ✓ Statement on Auditing Standard 70 (SAS70)

         Implementing strong core controls is the key to meeting
         these various requirements with minimal effort. Take a look
         at Appendix A to see how the core controls map to HIPAA,
         HITECH, and NIST.




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34     Conquering Compliance For Dummies



       Enabling access to electronic healthcare
           applications and data at BIDPO
       In a joint project with its affili-      “We needed this project to be as
       ated medical center, Beth Israel         secure as possible, so we did what-
       Deaconess Physician Organization         ever we could do to get this locked
       (BIDPO) (http://bidpo.org)               down,” said Gillis. “We had to make
       set out to provide a secure, robust,     sure we had no ‘Globe-able Events,’
       and cost-effective EHR infrastruc-       meaning that we’re not going to have
       ture for its 200 to 300 independent      a security breach that will appear on
       physicians at 173 locations in east-     the front page of the Boston Globe.
       ern Massachusetts. Utilization of        We needed a partner that could help
       this system allows BIDPO members         us mitigate any risk.”
       to meet all the Meaningful Use cri-
                                                The Trend Micro security solu-
       teria specified for reimbursement by
                                                tions are also helping IT comply
       ARRA.
                                                with other regulations that apply
       The project priorities included server   to their business, such as HITECH,
       virtualization, a SaaS deployment        Massachusetts Data Encryption Law
       model, and a defense-in-depth secu-      201 CMR 17.00, and ARRA.
       rity architecture to protect patient
                                                The key benefits of the Trend Micro
       data. “We created a multilayer
                                                solution include:
       security protocol, including various
       perimeter devices, from firewalls to     ✓ EHR innovation: Trend Micro
       network-based intrusion detection          solutions secure BIDPO’s inno-
       systems,” said Bill Gillis, eHealth        vative applications and deploy-
       technical director at the medical          ment model.
       center. “Our most important secu-
                                                ✓ Virtualization security and com-
       rity layer is the Trend Micro Deep
                                                  pliance: Deep Security provides
       Security software.”
                                                  unique dedicated virtualization
       Deep Security provides compre-             protection.
       hensive host security for the orga-
                                                ✓ Minimized vulnerabilities: Deep
       nization’s virtualized servers, EHR
                                                  Security shields critical systems
       applications, and patient data, giving
                                                  and applications from vulner-
       BIDPO confidence that they are
                                                  abilities until patches can be
       HIPAA compliant — and that their
                                                  deployed.
       public reputations are safe.




     These materials are the copyright of Wiley Publishing, Inc. and any
     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 5: Examining HIPAA and Healthcare Compliance               35
         Enforcing PCI DSS
         Healthcare institutions that accept credit card payments must
         also comply with the Payment Card Industry Data Security
         Standard (PCI DSS). Health insurance premiums, medical
         services, and even hospital gift shop purchases are examples
         of transactions where the security of cardholder data is
         required. Healthcare institutions are well advised to design
         and implement a security framework that addresses both
         HIPAA and PCI DSS. See Chapter 4 for more on PCI DSS.



Healthcare Security and
Compliance Challenges —
and Solutions
         Maintaining regulatory compliance and maximizing security
         effectiveness is especially demanding in today’s rapidly evolv-
         ing healthcare industry. Understanding these challenges will
         help you select and implement solutions to secure your criti-
         cal systems and data, and meet increasingly stringent regula-
         tory requirements.

         The following challenges are especially critical. (See Chapter 3
         for additional information on these and other challenges facing
         healthcare organizations.)


         Protecting patient data
         Although perimeter and content security provide important
         safeguards, HIPAA and HITECH make it clear that encryption
         is the only acceptable way to protect ePHI and avoid costly
         disclosures. Effective encryption deployment also requires a
         data loss prevention (DLP) solution to discover where ePHI is
         stored and ensure its encryption when transmitted. However,
         most encryption and DLP solutions suffer major drawbacks
         that impede their success and widespread adoption.




These materials are the copyright of Wiley Publishing, Inc. and any
dissemination, distribution, or unauthorized use is strictly prohibited.
36     Conquering Compliance For Dummies

              Integrate DLP into your data protection strategy with a solu-
              tion that offers the flexibility of deployment and protection
              levels that best suit your needs. Consider identity-based
              encryption as an equally powerful, but more effective, encryp-
              tion alternative to PKI solutions.


              Securing laptops and
              mobile devices
              Portable laptops, PDAs, and other mobile devices are quickly
              becoming mainstays in healthcare, and essential to the daily
              tasks of nurses, physicians, and other healthcare professionals.
              These devices are at extreme risk for attack and ePHI loss, but
              can’t be adequately protected by network-based solutions.

              Only a cloud-enabled endpoint security solution can pro-
              tect a full range of devices from Web, e-mail, and file threats
              wherever they roam. You’ll also want to investigate endpoint
              encryption and DLP — they’re becoming essential as these
              devices increasingly store protected data.


              Securing critical medical devices
              Computerized medical devices for patient evaluation and diag-
              nosis are increasingly a common part of the hospital network
              and so are at risk for compromise and failure due to malware
              infections or external attacks. Though protection is required
              by regulation, these systems can be prohibitive or impossible
              to secure with standard endpoint protection products.

              Bring non-standard and sensitive systems such as MRI scan-
              ners, X-ray machines, and other patient care devices into
              compliance with a network-based solution that can detect
              active infiltrations and provide an immediate alert and reme-
              diation assistance.




     These materials are the copyright of Wiley Publishing, Inc. and any
     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 6

           Top Ten Reasons to
            Use Trend Micro
           Enterprise Security
In This Chapter
▶ Seeing how Trend Micro addresses the core controls and solves
  tough compliance challenges
▶ Achieving compliance without security compromise




         S    ecurity compliance is costly, complex, ever changing —
              and still not enough to protect your company’s sensitive
         data. Trend Micro Enterprise Security offers you a better way
         to stay both compliant and secure with solutions that address
         a broad range of controls, solve tough compliance challenges,
         and deliver maximum protection at minimal cost. That’s com-
         pliance without compromise!

         Trend Micro Enterprise Security products and services
         are powered by the Smart Protection Network — a next-
         generation cloud-client infrastructure that combines cloud-
         based reputation technology, feedback loops, and the exper-
         tise of TrendLabs researchers to deliver real-time protection
         and greatly simplify security management.



Targeting Core Compliance Controls
         Trend Micro products can help you address the core compli-
         ance controls that apply directly to most security regulations.
         With Trend Micro you can secure your organization and

These materials are the copyright of Wiley Publishing, Inc. and any
dissemination, distribution, or unauthorized use is strictly prohibited.
38     Conquering Compliance For Dummies

              achieve compliance across a wide range of controls and regu-
              lations (see Figure 6-1).
                                                                                   omplexity.
                                                                               um C
                                                                       inim
                                                                    .M
                                                                ion                Web Securit
                                                              ct          t
                                                                      o in y                     y
                                                                   dp urit




                                                      te
                     Core Security




                                                    ro
                                                                      c




                                                  En
                                                 mP




                                                                                                     Meecurity
                                                 Se
                  Compliance Controls




                                                                                                      S
                                                   u




                                                                                                        ssaging
                                              Maxim
              •   IT Risk Assessment                                           TREND MICRO




                                                         ta Center
              •   Vulnerablilty & Patch Mgt                                   SMART




                                                       Da ecurity
              •   IT Policy Adherence                                        PROTECTION
                                                                             NETWORK
              •   Incident Response
              •   Sensitive Data Protection
                                                        S




                                                                                             vic ns
                                                                                                 es
                                                                                                i
                                                                                             lut




                                                                                                o
              •   Firewall, IDS/IPS
              •   Anti-virus/Anti-malware                            Da                    So Ser
              •   Anti-spam/Anti-phishing                                 ta P
                                                                               rotection   an d
              •   Logging & Reporting


              Figure 6-1: Trend Micro Enterprise Security Solutions.




     Solving Tough Compliance
     Challenges
              Trend Micro products offer unique solutions that help you
              solve tough challenges that arise from applying compliance
              controls within your particular operating environment, evolv-
              ing business and IT initiatives, and limited security budget.


              Risk visibility and control
              Trend Micro vulnerability and threat management solutions
              offer you greater risk visibility and remediation control over
              active security threats, software and systems vulnerabilities,
              changing Web content, and IT policy compliance.


              Server/desktop virtualization
              Trend Micro server and endpoint solutions provide advanced
              virtualization-aware software that secures virtualized
              desktops and servers with best-in-class protection, optimized
              performance, and critical compliance controls.

     These materials are the copyright of Wiley Publishing, Inc. and any
     dissemination, distribution, or unauthorized use is strictly prohibited.
Chapter 6: Top Ten Reasons to Use Trend Micro Enterprise Security             39
           Public cloud computing
           Trend Micro provides the secure virtual server and volume-
           level data encryption solutions that can allow you to confidently
           incorporate the public cloud into your data center strategy.


           Web sites and portals
           Trend Micro Enterprise Security keeps your Web site and
           company reputation secure with Web site application scan-
           ning, PCI scanning, best-in-class server protection, and com-
           prehensive vulnerability management.


           Non-standard systems
           Trend Micro’s unique network-based Threat Management
           Services discover any active infiltration, allowing you to
           achieve compliance and noninvasive protection for any end-
           point or server, including legacy or proprietary devices.


           Distributed locations
           Trend Micro Deep Security provides firewall, IPS, virtual patch-
           ing, integrity monitoring, and other core controls directly to criti-
           cal systems — eliminating the cost and management complexity
           of perimeter security devices at each location.


           Worker mobility
           Trend Micro OfficeScan and the Smart Protection Network
           keep wireless and mobile devices of all kinds protected from
           Web, e-mail, and other threats both on and off the corporate
           network.


           Mitigating information risk
           Trend Micro secures sensitive data with endpoint and
           network DLP, identity-based endpoint and e-mail gateway
           encryption, and content filtering solutions that emphasize
           security, management simplicity, and employee ease-of-use.


  These materials are the copyright of Wiley Publishing, Inc. and any
  dissemination, distribution, or unauthorized use is strictly prohibited.
40     Conquering Compliance For Dummies


     Compliance without Security
     Compromise
              You can employ various strategies to achieve compliance
              with applicable regulations. But will your strategy provide the
              best, or even adequate, protection of your data and reputa-
              tion? Compliance-driven organizations may use a patchwork
              of products that allow them to mark off boxes on a compli-
              ance checklist, but don’t necessarily offer best-in-class protec-
              tion levels or completeness of coverage.

              For security-driven organizations that want to truly protect
              their sensitive data and comply with regulatory requirements,
              Trend Micro Enterprise Security solutions and the Smart
              Protection Network help you achieve both compliance and
              security — without compromise.

              Real-world tests by NSS Labs (see Figure 6-2) confirm that
              Trend Micro offers highly rated protection against malware
              and other threats.


                        Mean Block Rate for Socially Engineered Malware
              100%     Block on
                       Download/
                       Execution                                                 Trend Micro
                                                                  Kaspersky
               90%                  Symantec
                                                       McAfee
                                                    Norman
                                                       F-Secure
               80%                        Average
                            Panda


                              ESET
               70%              AVG
                                                                                    Block on
                          Sophos                                                    Download

               60%                                     80%                90%            100%
                                    70%
                                                                  Source: NSS Labs Reports
              Figure 6-2: Trend Micro provides maximum protection against malware threats.




     These materials are the copyright of Wiley Publishing, Inc. and any
     dissemination, distribution, or unauthorized use is strictly prohibited.
Appendix A

          Core Compliance
        Controls – Healthcare
         Regulation Mapping
          Core Control     Applicable U.S. Healthcare Regulations &
                           Guidelines – HIPAA, HITECH, NIST
          IT Risk          HIPAA § 164.308 (a)(1) Security Management
          Assessment       Process (Includes required risk analysis and risk
                           management)
                           HITECH Breach Notification for Unsecured
                           Protected Health Information
          Vulnerability    HIPAA § 164.308 (a)(1) Security Management
          & Patch          Process (Includes required risk analysis and risk
          Management       management)
          IT Policy        HIPAA § 164.308 (a)(6) Policies and procedures to
          Adherence        address security incidents
          Incident         HITECH Breach Notification for Unsecured
          Response         Protected Health Information
                           HITECH § 13402 Notification in Case of Breach




These materials are the copyright of Wiley Publishing, Inc. and any
dissemination, distribution, or unauthorized use is strictly prohibited.
42     Conquering Compliance For Dummies


               Core Control     Applicable U.S. Healthcare Regulations &
                                Guidelines – HIPAA, HITECH, NIST
               Sensitive Data   HIPAA § 164.308 (a)(1) Security Management
               Protection       Process (Includes required risk analysis and risk
                                management)
                                HITECH Breach Notification for Unsecured
                                Protected Health Information
                                HITECH § 13402 Notification in Case of Breach
                                HIPAA §164.404 Notification to Individuals
                                (Description of type of unsecured ePHI involved in
                                the breach)
                                NIST Publication 800-66 (Guidelines for
                                Implementing HIPAA Security Rules)
                                HIPAA § 164.310(d)(1) Device and Media Controls
                                HIPAA § 164.514(d) Minimum necessary uses and
                                disclosures of PHI
                                HITECH Exemption from breach notification if PHI
                                is secured using encryption
                                HIPAA 45 CFR parts 160 and 164 (Interim Rule)
                                Encryption and destruction for rendering ePHI unus-
                                able, unreadable, or undecipherable to unauthorized
                                individuals
                                HIPAA 45 CFR parts 160 and 164 (Interim Rule)
                                Keep encryption keys on a separate device from
                                the data that they encrypt or decrypt
                                HIPAA § 164.308(b)(1) Business associate will
                                appropriately safeguard information
                                HIPAA § 164.312(e)(1) Transmission Security
                                (Guard against unauthorized access to transmit-
                                ted ePHI)
                                HIPAA § 164.306(a)(1) Protect ePHI: Facilities must
                                protect the confidentiality, availability, and integ-
                                rity of all ePHI created, received, maintained, and
                                transmitted
                                HIPAA § 164.308 (a)(6) Policies and procedures to
                                address security incidents


     These materials are the copyright of Wiley Publishing, Inc. and any
     dissemination, distribution, or unauthorized use is strictly prohibited.
Appendix A: Core Compliance Controls — Healthcare Regulation Mapping                   43
                Core Control      Applicable U.S. Healthcare Regulations &
                                  Guidelines – HIPAA, HITECH, NIST
                Firewall & IDS/   HIPAA § 164.308 (a)(1) Security Management
                IPS               Process (Includes required risk analysis and risk
                                  management)
                                  HIPAA § 164.312(a)(1) Access Control (Allow
                                  access only to those persons or software pro-
                                  grams that have been granted access rights)
                                  NIST Publication 800-66: 4.14 Access Control for
                                  HIPAA §164.312(a)(1)) (Have all applications/
                                  systems with ePHI been identified?, Where is
                                  ePHI currently housed?)
                                  HIPAA § 164.312(c)(1) Integrity (Protect ePHI from
                                  improper alteration or destruction)
                Anti-virus &      HIPAA § 164.308 (a)(5)(ii)(B) (Protection from mali-
                Anti-malware      cious software. Procedures for guarding against,
                                  detecting, and reporting malicious software)
                                  HIPAA § 164.308 (a)(1) Security Management
                                  Process (Includes required risk analysis and risk
                                  management)
                Anti-spam &       HIPAA § 164.308 (a)(5)(ii)(B) (Protection from mali-
                Anti-phishing     cious software. Procedures for guarding against,
                                  detecting, and reporting malicious software)
                                  HIPAA § 164.308 (a)(1) Security Management
                                  Process (Includes required risk analysis and risk
                                  management)
                Logging &         HIPAA § 164.308 (a)(1) Security Management
                Reporting         Process (Includes required risk analysis and risk
                                  management)
                                  HITECH Breach Notification for Unsecured
                                  Protected Health Information




      These materials are the copyright of Wiley Publishing, Inc. and any
      dissemination, distribution, or unauthorized use is strictly prohibited.
44     Conquering Compliance For Dummies




     These materials are the copyright of Wiley Publishing, Inc. and any
     dissemination, distribution, or unauthorized use is strictly prohibited.
pci compliance for dummies
pci compliance for dummies
pci compliance for dummies
pci compliance for dummies

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pci compliance for dummies

  • 1. Compliments of al Edition Trend Micro Speci Co n q u e ri n g Com pl ia nce Learn to: • Reduce the cost and complexity of security compliance • Solve the toughest regulatory compliance challenges • Maximize the real security value of your investments Kevin Faulkner Lawrence Miller
  • 2. Trend Micro Incorporated, a global leader in Internet content security and threat management, aims to create a world safe for the exchange of digital information for businesses and consumers. A pioneer in server-based antivirus with over 20 years experience, Trend delivers top-ranked security that fits customer needs, stops new threats faster, and protects data in physical, virtualized, and cloud environments. Trend Micro Enterprise Security is a tightly integrated offering of content security products, services, and solutions powered by the Smart Protection Network. Together they keep customers both compliant and secure by addressing a broad range of compliance controls, solving tough compliance challenges, and delivering maximum protection with minimal complexity. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 3. Conquering Compliance FOR DUMmIES ‰ TREND MICRO SPECIAL EDITION by Kevin Faulkner and Lawrence Miller These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 4. Conquering Compliance For Dummies®, Trend Micro Special Edition Published by Wiley Publishing, Inc. 111 River Street Hoboken, NJ 07030-5774 www.wiley.com Copyright © 2010 by Wiley Publishing, Inc., Indianapolis, Indiana Published by Wiley Publishing, Inc., Indianapolis, Indiana No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning or otherwise, except as permitted under Sections 107 or 108 of the 1976 United States Copyright Act, without the prior written permission of the Publisher. Requests to the Publisher for permission should be addressed to the Permissions Department, John Wiley & Sons, Inc., 111 River Street, Hoboken, NJ 07030, (201) 748-6011, fax (201) 748-6008, or online at http://www.wiley.com/go/permissions. Trademarks: Wiley, the Wiley Publishing logo, For Dummies, the Dummies Man logo, A Reference for the Rest of Us!, The Dummies Way, Dummies Daily, The Fun and Easy Way, Dummies.com and related trade dress are trademarks or registered trademarks of Wiley Publishing, Inc., in the United States and other countries, and may not be used without written permission. Trend Micro, OfficeScan, Trend Micro Smart Protection Network are registered trademarks of Trend Micro Inc and may not be used without permission. All other trademarks are the property of their respective owners. Wiley Publishing, Inc., is not associated with any product or vendor mentioned in this book. Portions of Appendix B are provided courtesy of PCI Security Standards Council, LLC (“PCI SSC”) and/or its licensors.  © 2007-2010 PCI Security Standards Council, LLC.  All rights reserved.  Neither PCI SSC nor its licensors endorses this product, its provider or the methods, procedures, state- ments, views, opinions or advice contained herein.  All references to documents, materials or por- tions thereof provided by PCI SSC (the “PCI Materials”) should be read as qualified by the actual PCI Materials, which are subject to change.  For current versions or questions regarding the PCI Materials, please contact PCI SSC through its web site at www.pcisecuritystandards.org. LIMIT OF LIABILITY/DISCLAIMER OF WARRANTY: THE PUBLISHER, TREND MICRO, AND THE AUTHOR MAKE NO REPRESENTATIONS OR WARRANTIES WITH RESPECT TO THE ACCURACY OR COMPLETENESS OF THE CONTENTS OF THIS WORK AND SPECIFICALLY DISCLAIM ALL WARRANTIES, INCLUDING WITHOUT LIMITATION WARRANTIES OF FITNESS FOR A PARTICULAR PURPOSE. NO WARRANTY MAY BE CREATED OR EXTENDED BY SALES OR PROMOTIONAL MATERIALS. THE ADVICE AND STRATEGIES CONTAINED HEREIN MAY NOT BE SUITABLE FOR EVERY SITUATION. THIS WORK IS SOLD WITH THE UNDERSTANDING THAT THE PUBLISHER AND TREND MICRO ARE NOT ENGAGED IN RENDERING LEGAL, ACCOUNTING, OR OTHER PROFESSIONAL SERVICES. IF PROFESSIONAL ASSISTANCE IS REQUIRED, THE SERVICES OF A COMPETENT PROFESSIONAL PERSON SHOULD BE SOUGHT. NEITHER THE PUBLISHER, TREND MICRO, NOR THE AUTHOR SHALL BE LIABLE FOR DAMAGES ARISING HEREFROM. THE FACT THAT AN ORGANIZATION OR WEBSITE IS REFERRED TO IN THIS WORK AS A CITATION AND/ OR A POTENTIAL SOURCE OF FURTHER INFORMATION DOES NOT MEAN THAT THE AUTHOR, THE PUBLISHER, OR TREND MICRO ENDORSES THE INFORMATION THE ORGANIZATION OR WEBSITE MAY PROVIDE OR RECOMMENDATIONS IT MAY MAKE. FURTHER, READERS SHOULD BE AWARE THAT INTERNET WEBSITES LISTED IN THIS WORK MAY HAVE CHANGED OR DISAPPEARED BETWEEN WHEN THIS WORK WAS WRITTEN AND WHEN IT IS READ. For general information on our other products and services, please contact our Business Development Department in the U.S. at 317-572-3205. For details on how to create a custom For Dummies book for your business or organization, contact bizdev@wiley.com. For information about licensing the For Dummies brand for products or services, contact BrandedRights&Licenses@Wiley.com. ISBN: 978-0-470-76719-1 Manufactured in the United States of America 10 9 8 7 6 5 4 3 2 1 These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 5. Introduction I n the not-too-distant past, information security and compli- ance for most organizations was the exclusive dominion of a small security staff with little or no support (or budget), engaged in a tug-of-war with users that constantly sought creative new ways to circumvent seemingly needless security measures that hindered productivity. But now that PCI, HIPAA, SOX, and a plethora of European and other privacy regulations have become a part of our modern lexicon, information security and regulatory compli- ance have become the focus of many corporate boards and senior managers — and the subject of this book! About This Book This book explains the challenges of regulatory compliance and how to address these challenges using a holistic, cost- effective approach that not only helps you achieve compli- ance across all applicable regulations but also to get real security for your organization and your valuable data. We show you how to achieve and maintain compliance by: ✓ Focusing on core cross-regulation controls ✓ Conquering the toughest compliance challenges ✓ Maximizing your protection and minimizing your costs Simply stated, that’s compliance without compromise! The contents of this custom book were provided by and pub- lished specifically for Trend Micro. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 6. 2 Conquering Compliance For Dummies Foolish Assumptions We assume that you’re reading this book because you’re responsible for ensuring that your organization complies with a myriad of government and industry regulations — and you need some help. You may be a corporate officer, executive, or other senior manager, or you may be an IT security manager, network engineer, or system administrator. We assume that you have at least a basic understanding of the key security and privacy regulations that are relevant to your industry, the technology challenges of compliance, and a desire to make your compliance programs simpler and more cost-effective. How This Book Is Organized This book consists of six short chapters, summarized below. Chapter 1: Understanding the Compliance Mandate We start by exploring the regulatory landscape and clarifying the differences between security and compliance. Chapter 2: Targeting Core Compliance Controls In this chapter, we present a comprehensive, secure-once approach to achieving cross-regulatory compliance by identi- fying common technical controls and themes. Chapter 3: Addressing Compliance Challenges In this chapter, we discuss how to deal with specific compli- ance challenges, including evolving technology trends such as virtualization, teleworking, and cloud computing. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 7. Introduction 3 Chapter 4: Charging Through PCI DSS Chapter 4 focuses on the Payment Card Industry Data Security Standard (PCI DSS), showing you how to cost effectively safe- guard your business infrastructure and cardholder data — achieving both security and compliance. Chapter 5: Examining HIPAA and Healthcare Compliance Next, we take a closer look at U.S. HIPAA and other regulatory and privacy challenges facing the healthcare industry. Chapter 6: Ten Reasons to Use Trend Micro Enterprise Security Finally, in true For Dummies form, we conclude with a list of great reasons to use Trend Micro Enterprise Security solu- tions to help you achieve compliance without compromise! Icons Used in This Book Throughout this book, we occasionally use icons to call attention to important information that is particularly worth noting. Here’s what to look for and what to expect: This icon points out information that may well be worth com- mitting to memory. This icon explains material of a technical nature and may be of more interest to a tech-savvy reader. This icon points out potential pitfalls and easily confused or difficult-to-understand terms and concepts. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 8. 4 Conquering Compliance For Dummies This icon points out helpful suggestions and useful nuggets of information that may just save you some time and headaches. Where to Go from Here Each chapter in this book is written to stand on its own. You don’t necessarily need to start at the beginning to follow a sto- ryline! Chapters 2 and 3 give you the insights you need to effec- tively tackle most any regulation worldwide, while chapters 4 and 5 target the specific requirements of PCI and HIPAA. So jump right in wherever it makes the most sense for you. At a minimum, we recommend reading Chapters 2 and 3 to gain insights into solving cross-regulation compliance chal- lenges. Finally, Chapter 6 will show you how Trend Micro Enterprise Security solutions can help you rapidly implement the cost effective, no-compromise strategies of this book. Or, you could just turn the page and start at the beginning! These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 9. Chapter 1 Understanding the Compliance Mandate In This Chapter ▶ Navigating the regulatory landscape ▶ Achieving both compliance and security W ith more than 400 regulations and over 10,000 overlapping controls in 38 countries, compliance has become a challenging and complex mandate for organiza- tions everywhere. Furthermore, the rapid pace and constantly evolving nature of technology and strategic business and IT initiatives makes attain- ing and maintaining regulatory compliance still more difficult. And finally, regulations typically lack detail, are subject to interpretation, and provide only minimum baseline security requirements. Thus, organizations can get compliance right, but still not be truly secure. In this chapter, we explore the vast expanse (and expense) of the regulatory compliance landscape and its associated challenges. The Compliance Maze Driven by the need to protect the private data (such as per- sonally identifiable information, financial data, and health records) of individual citizens from cybercriminals and iden- tity thieves, governments throughout the world and at every These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 10. 6 Conquering Compliance For Dummies level have caught the regulatory bug. Information security best practices are rapidly being codified with legal mandates that seek to ensure that corporate governance, internal con- trols, business processes, and operations of organizations in various industries are safe, sound, and secure. These regulations often require specific controls, corporate compliance programs, audits, and public disclosures, and levy stiff penalties for noncompliance. Some of the more significant information and data security regulations include: ✓ PCI DSS: Payment Card Industry Data Security Standard. A worldwide industry mandate that establishes informa- tion security requirements for organizations that process payment card transactions (such as credit and debit cards). See Chapter 4 for more on PCI DSS. ✓ EU Data Protection Directive: The EU directive and vari- ous country-specific acts protect individual information of a private or sensitive nature. ✓ FISMA: Federal Information Security Management Act. Applicable to U.S. Government agencies and contractors. ✓ GLBA: Gramm-Leach-Bliley Act. Standards required of financial institutions relating to administrative, techni- cal, and physical safeguards for customer records and information. ✓ HIPAA: Healthcare Insurance Portability and Accountability Act. Security and Privacy Rules apply to “covered entities” and their business associates in the healthcare industry. See Chapter 5 for more on HIPAA. ✓ HITECH: Health Information Technology for Economic and Clinical Health Act. Provides funding for electronic health records (EHR) and safe harbor from disclosure requirements for breached data that is encrypted, among other things. See Chapter 5 for more on HITECH. ✓ SOX: Sarbanes-Oxley. Publicly traded companies must implement a framework of computer controls. Several mandates can’t be accomplished without prudent use of technology and information security. ✓ J-SOX: Formally, the Financial Instruments and Exchange Law, J-SOX is the Japanese implementation of internal controls similar to U.S. SOX. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 11. Chapter 1: Understanding the Compliance Mandate 7 ✓ EuroSox: Comprised of two EU statutes, formally known as the Statutory Audit and the Company Reporting Directives. Requires EU member states to implement internal controls similar to U.S. SOX by 2010. ✓ MITS: Management of Information Technology Security (Canada). Monitoring, lifecycle management, technical and operational safeguards for risk mitigation, applicable to Canadian government agencies. Compliance and Security Aren’t One and the Same Being compliant doesn’t necessarily mean being safe and secure. Even the most stringent regulations define only a mini- mum baseline for good security. So it is certainly possible, if not even probable, that an organization can be fully compli- ant with all applicable legal requirements and standards for its industry, yet still be vulnerable to security breaches and incidents. Regulations and standards mandate information security best practices and governance, reassure the public at large, and set forth penalties (including fines, disclosures) for noncom- pliance. In other words, when a noncompliant organization suffers a major security breach, security regulations ensure that there will be repercussions Regulatory compliance also, at least in theory, serves a more benign purpose. Disclosure laws, in addition to “shaming” an organization into compliance, are intended to give a timely warning to individuals whose private information may have been compromised. That way, the individuals may take proac- tive steps to avoid being victimized by identity theft. Finally, regulations help to clarify the standards of due care and due diligence. Due care and due diligence are related, but distinctly different: ✓ Due care: In the practice of information security, due care relates to the steps that individuals or organizations take to perform their duties and implement security best practices and regulations. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 12. 8 Conquering Compliance For Dummies ✓ Due diligence: In the context of information security, due diligence commonly refers to risk identification and risk management practices. An organization or individual that fails to exercise due care and due diligence in the performance of their duties can be found criminally negligible and personally liable. So what is the state of enterprise security today? Trend Micro’s onsite security threat assessments of hundreds of enterprises throughout the world have shown that 100 per- cent are infiltrated by active malware — over 50 percent with data stealing malware and 77 percent with bots (see Figure 1-1). Organizations need to be aware that basic compliance controls aren’t sufficient to protect against a serious security data breach. Threats found in enterprises 100% Active malware 77% Bots 56% Data stealers 42% Worms Figure 1-1: Threats found in enterprises. And without a comprehensive security strategy and a strong understanding of regulatory issues affecting them, many organi- zations risk spending needlessly, while chasing redundant — or worse, conflicting — administrative, technical, or operational controls, in the quest for compliance. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 13. Chapter 2 Targeting Core Compliance Controls In This Chapter ▶ Getting an overview of the controls common to most regulations ▶ Covering all the controls in more depth B y focusing on the core compliance controls common to most regulations you will help reduce cost and dupli- cation of effort. If you properly secure once, you can meet a majority of individual compliance regulations without further effort. And when implemented appropriately, these controls put you well down the road toward a strong security posture. Developing and implementing clear policies and processes, and selecting the right technology solutions that support a broad range of common security mandates will help organiza- tions succeed in their quest to achieve cost-effective security and compliance. Addressing Core Controls For the most part, information security and privacy regula- tions are based on well-established information security best practices. Because many of these best practices are common across regulations, focusing your efforts on these core con- trols, and adopting a technology infrastructure that meets the intent of the various compliance mandates, will allow you to build a strong security foundation while simultaneously satis- fying many of the compliance requirements applicable to your These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 14. 10 Conquering Compliance For Dummies organization. These core compliance controls are identified and described in the following sections. The core compliance controls are directly specified or implied by a broad range of regulatory and IT standards across the globe. The core security compliance controls and a few exam- ples of applicable regulations are listed in Figure 2-1. Core Security Privacy Laws Financial Fraud Government Compliance Controls Protection IT Security • EU Data Protection • IT Risk Assessment Directive • Australia Priv. Act • SOX • US FISMA; NIST • Vulnerablilty & Patch Mgt • Canado PAPEDA • J-SOX • Canada MITS • IT Policy Adherence Credit Card Healthcare Finanacial • Incident Response Security Data Privacy Data Privacy • Sensitive Data Protection • PCI DSS • US HIPAA • US GLBA • US HITECH Act • Firewall, IDS/IPS • Anti-virus/Anti-malware IT Frameworks Other Regulation & Standards US NERC, FERC; UK,German, • Anti-spam/Anti-phishing • COBIT; COSO Swiss Data Protection; Sys Trust; • Logging & Reporting • ITIL; ISO USAe 3402 Figure 2-1: Core security compliance controls and examples of regulations. See Appendixes A and B to learn how the core controls specifically apply to HIPAA and PCI. IT Risk Assessment Maintaining an ongoing security risk assessment program helps an organization identify relevant assets that must be protected, and what threats and vulnerabilities they must be protected against. A risk assessment is a critical early (and ongoing) step in the IT risk management process. A risk assessment identifies three specific elements of risk: ✓ Assets. This includes an inventory and valuation of all organizational information assets including systems, devices, applications, data, and processes. ✓ Threats. This includes an analysis to determine actual threats, possible consequences, likelihood of occurrence, and probable frequency. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 15. Chapter 2: Targeting Core Compliance Controls 11 ✓ Vulnerabilities. This includes a vulnerability assessment to determine weaknesses and to establish a baseline for determining appropriate and necessary safeguards. Don’t confuse vulnerability assessments with vulnerability management (discussed later in this chapter). They are distinctly different concepts. Vulnerability and Patch Management Effective vulnerability management requires periodic and frequent (automated) scans of all systems, applications, and network devices to identify, prioritize, mitigate, and patch security vulnerabilities that may be exploited. A vulnerability in information security is defined as the absence or weakness of a safeguard in an information asset that makes a threat potentially more harmful or costly, more likely to occur, or likely to occur more frequently. Vulnerabilities can exist for a number of reasons, including ✓ Programming/development bugs or flaws ✓ Improper system or device configurations ✓ Human errors Additionally, new vulnerabilities are discovered, literally every day, because ✓ Flaws and weaknesses are discovered in both new and legacy information assets ✓ New flaws and weaknesses are created by changes to existing information assets, such as configuration changes, software updates, and patches Patch management must be performed regularly to ensure applications, databases, and systems are updated with the latest security patches provided by the product vendors. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 16. 12 Conquering Compliance For Dummies Virtual patching or shielding refers to using rules defined in IDS/IPS agents to stop known vulnerabilities from being exploited. Virtual patching is an excellent security practice that provides protection until patches can be deployed. It may also be accepted as a compensating control for systems that are difficult or impossible to patch in a timely manner. Effective patch management requires awareness of new vul- nerabilities and security patches, risk analysis, optional vir- tual patching, and the testing, deployment, and verification of final patches. IT Policy Adherence Assuring endpoint and server compliance with OS configura- tion and application access control policies increases security and allows organizations to clearly document compliance with security regulations and company policies. A formal, written security policy — along with supporting standards, guidelines, and procedures — forms the basis for the organization’s information security program. Incident Response A well-written incident response plan helps ensure that prop- erly trained personnel can quickly and effectively respond to a security incident in order to minimize the potential damage and return the business to normal operation. An incident response plan should include detailed procedures and technologies that will be used to rapidly address all foreseeable incidents. Sensitive Data Protection Organizations must locate, identify, classify, and protect regu- lated data, whether it is being stored (at rest), processed (in use), or transmitted (in motion). These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 17. Chapter 2: Targeting Core Compliance Controls 13 Data loss prevention (DLP) is critical to stopping accidental and malicious data leaks. A robust DLP solution helps you: ✓ Discover, monitor, block, and encrypt sensitive data. ✓ Control removable media and I/O devices such as USB drives, CD/DVD, Bluetooth, and external drives. Encryption has almost universally become the accepted standard for protecting the confidentiality of sensitive data. Encryption solutions can be hardware- or software-based, and can encrypt sensitive files on an entire disk (full-disk encryp- tion) or on an individual file or folder level (file-based encryp- tion). Under many laws and regulations, an organization that suffers a data loss incident may be able to avoid any public disclosure requirements or penalties if the data was properly encrypted. Firewalls and Intrusion Detection/ Prevention (IDS/IPS) Firewall and IDS/IPS protection is generally required for systems that process or house regulated data. These systems have traditionally been deployed at the corporate perimeter. However with increasingly mobile employees and the advent of virtualization, host-based (or endpoint) firewalls and intrusion detection/prevention systems are becoming increasingly necessary. Anti-Virus and Anti-Malware Since the early days of computing, anti-virus software has been, and remains, a basic and vital component of security. Anti-malware protects systems and data from viruses, as well as Trojans, worms, spyware, and other threats. Anti-malware can be signature-based and/or behavior-based. However, many non-standard, critical, and legacy devices may not be compat- ible with traditional anti-malware software that is typically installed directly on a system or device. Instead, network- based anti-malware solutions may be necessary. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 18. 14 Conquering Compliance For Dummies Anti-Spam and Anti-Phishing Protection from e-mail and blended e-mail/Web threats is vital to the security of employee devices and blocking the entry of malware to corporate infrastructure. Spam and phishing have evolved from the preferred method for directly spreading malware to become the preferred way to lure users to malicious Web sites where data-stealing mal- ware can be unwittingly downloaded. State-of-the-art e-mail protection solutions now include Web site reputation capa- bilities to help protect users from these dangerous embedded e-mail links. Logging and Reporting Organizations must ensure that secure log files are created and maintained on all systems and devices in order to identify and respond to security incidents and enforce policy compli- ance. Detailed reporting capabilities are needed to demon- strate compliance to management, auditors, and customers. Log files are only valuable when someone is monitoring them for unusual or suspicious activity. Additionally, active moni- toring may also be required to ensure compliance. Automated log collection and analysis tools are required to make these tasks efficient and effective. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 19. Chapter 3 Addressing Compliance Challenges In This Chapter ▶ Tackling the toughest operating environments ▶ Securing virtual and cloud infrastructures ▶ Automating visibility and risk management Y our organization’s unique operating environment, busi- ness and IT initiatives, and everyday constraints create tough challenges for your security and compliance posture that include: ✓ Risk visibility and control ✓ Server and desktop virtualization ✓ Public cloud computing ✓ Web sites and portals ✓ Non-standard and legacy systems ✓ Distributed locations ✓ Worker mobility ✓ Mitigating information risk These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 20. 16 Conquering Compliance For Dummies Evolving Technology Technology evolves quickly, but regulations don’t. Current trends include server and desktop virtualization and public cloud computing, which enable your organization to rapidly adapt to new business requirements with minimal IT infra- structure and investment. What are the risks? How can you remain compliant? Server and desktop virtualization Virtualization is one of the hottest trends in enterprise IT today. Server virtualization provides significant direct cost savings in terms of server hardware and operating expenses, and allows companies to embrace the efficiencies of a private cloud IT model. Desktop virtualization is also a rapidly grow- ing trend due to its ability to significantly reduce PC costs, management complexity, and enterprise risk. According to IDC, virtualization is now the default approach at most enterprise IT organizations, and Gartner projects that the number of virtual machines will grow ten times by 2012. But the complexity and fluidity of virtualized environments pose special security and compliance challenges, rendering perimeter-based firewalls, intrusion detection and prevention systems (IDS/IPS), as well as traditional anti-malware protec- tion insufficient to prevent attacks on virtual machines. According to Information Week, 88 percent of North American enterprises don’t have a virtualization security strategy in place — leaving them both at risk and noncompliant. Some specific security and compliance challenges associated with virtual server and desktop environments include: ✓ Inter-VM traffic. Traditional network IPS systems are blind to potentially malicious inter-VM traffic. ✓ VM mobility. Virtual machine migration provides flexibil- ity and resilience, but creates configuration and update difficulties for traditional perimeter security. ✓ Dormant VMs. Dormant VMs can’t run scanning agents, download signatures, or install patches, yet they’re still These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 21. Chapter 3: Addressing Compliance Challenges 17 vulnerable to tampering and open to immediate attack upon reactivation. ✓ Resource contention and full system scans. Standard anti- malware solutions aren’t VM-aware and thus simultaneous scanning can cause severe performance degradation. The best answer is system self-defense. Look for host-based virtualization-aware solutions that can secure both physical and virtual servers and endpoints with the same levels of pro- tection, integrity monitoring, compliance controls, and perfor- mance. A solution should include the following capabilities: ✓ Protection from both conventional and new virtual threats ✓ Optimized for virtualization system performance ✓ Integrated with VMware and/or Citrix management ✓ Software-based, single agent/appliance deployment Cloud computing While most organizations are already experiencing the sav- ings of virtualization and private cloud computing, industry experts predict that many enterprises will also eventually adopt public cloud computing (that is, making use of pub- licly shared general purpose server and storage services) to further enable business agility and IT savings. However, in addition to all the security threats inherent in virtualization, public cloud computing poses unique security and compli- ance challenges to systems and data, including: ✓ Compliance framework and risk responsibility. Cloud computing creates unique compliance challenges. Service providers know this and, for the most part, simply pass liability for compliance on to you, the customer. ✓ Multi-tenancy. VMs for different customers with varying security policies may coexist with your VMs. ✓ Data protection. Encryption of application and system data is vital in a publicly shared environment. ✓ Lack of security visibility. Your virtual infrastructure is remotely located and thus real-time visibility and control are of concern. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 22. 18 Conquering Compliance For Dummies You’re ultimately on your own for compliance and risk man- agement in the public cloud. To protect your total computing environment, choose specialized solutions that include: ✓ Dedicated virtualization host protection ✓ Volume-level data encryption to protect data at all times ✓ Strong remote management for systems security and encryption key management Business Innovations Innovations such as mobile technology and Web sites with dynamic content and powerful capabilities are challenging tra- ditional perimeter-based security and compliance solutions. Web sites and portals Your Web site’s public exposure and ever-changing content make it extremely attractive to cybercriminals attempting to steal private customer information or sensitive company data. And although it is less of a motive for hackers today, a com- promised or defaced Web site can still do major harm to an organization’s reputation. Web sites and external portals need the same host protec- tion and vulnerability management as any mission-critical server, plus specific application vulnerability scanning, virtual application patching, and perhaps approved PCI scanning to ensure protection of your data, and more importantly, your reputation. Worker mobility Today’s workforce is more mobile than ever with laptop PCs, smartphones, and other portable devices enabling work from practically anywhere, at any time. Teleworking creates new security and compliance challenges, because remote employees working outside the corporate perimeter must be as protected as any office worker. Remote access security, personal use of devices, and the potential These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 23. Chapter 3: Addressing Compliance Challenges 19 for data leakage must be addressed. Smartphones and wire- less devices (such as Blackberries and iPhones) are capable of carrying as much (sensitive) data as a laptop PC, and are far more susceptible to loss or theft. How can you effectively manage compliance in your mobile workforce? Only a cloud-enabled endpoint security solution can pro- tect a full range of devices from Web, e-mail, and file threats wherever they roam. You’ll also want to investigate endpoint encryption and DLP — they’re becoming essential as these devices increasingly store protected data. Implementation Difficulties Applying security and compliance controls to a highly distrib- uted store/branch environment or to non-standard systems can be difficult and cost-prohibitive. And implementing risk man- agement and data protection solutions that truly fit your par- ticular needs requires a clear strategy and strong processes. Risk visibility and control Everyone’s familiar with the constant drumbeat of software vulnerabilities and subsequent exploits, and it’s critical that you be able to rapidly and reliably discover and mitigate them. How can you automate this process? How do you protect sys- tems when patches aren’t yet available? How do you ensure employees follow your organization’s IT security policies? But managing security risks isn’t just about vulnerability and policy management. Even the best vulnerability management and security defenses can be penetrated by zero-day and tar- geted threats. And once they’re in, they’re difficult to detect with standard security tools. An end-to-end vulnerability management strategy involves multiple products and procedures to rigorously discover, shield, and successfully patch systems on a continual basis. The best place to start is with a vulnerability management platform that offers scanning plus overall process manage- ment. Consider addressing your risk visibility challenges with a threat management solution that offers continual network- level infiltration discovery and remediation. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 24. 20 Conquering Compliance For Dummies Silgan Containers dramatically improves risk visibility and incident response With more than 38 manufacturing As a result, IT has gained more con- plants, Silgan Containers (www. trol of security. The increased visibil- silgancontainers.com) is the ity provided by Threat Management largest manufacturer of metal food Services reports has helped them containers in its markets. Its custom- strengthen overall security and more ers include many of the biggest names effectively enforce company poli- in the food industry, and the company’s cies. Automatic remediation speeds continued success depends on its incident response actions while uninterrupted supply lines. saving time for IT. Although Silgan has a robust, multi- “With Threat Management Services, layered security solution protecting infections are being caught and the company’s infrastructure, infec- cleaned up without taking hours tions still occurred and IT had to of my time,” said Draeger. “With devote significant resources to mon- the overwatch provided by Threat itoring security status and ensuring Management Services, we now have that employees were not breaking a stronger level of confidence that security policies. Clean-up efforts we have ultimate protection of cor- consumed valuable IT time and IT porate assets . . . I gain the visibility lacked the overall risk visibility and and control over my security posture control it desired. that I’ve never had before.” “We deployed the Trend Micro The key benefits of the Trend Micro Threat Discovery Appliance to gain solution include: insights into the state of our security,” ✓ Continuous risk assessment: explained Michael Draeger, in charge Detailed daily threat discovery of network and computer security for reports and analysis expose all Silgan Containers sites. “Before active threats and malicious we had this solution, we had no way activity. to really see where our vulnerabili- ties were. As an extra layer on top of ✓ Incident response: Automated our existing security solutions, Trend detection and remediation cuts Micro Threat Management Services management costs by 50 percent. tells me exactly what’s happening on ✓ Management reporting: Security the network.” posture and policy adherence evaluation and guidance. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 25. Chapter 3: Addressing Compliance Challenges 21 Non-standard systems and devices Many businesses depend on a range of legacy or proprietary systems, dedicated devices, and sensitive servers that can’t be directly secured by traditional anti-malware and security solutions. And even when third-party security software is sup- ported, running it on these systems may not be desirable. For example, MRI scanners, X-ray machines, and other patient care devices used in the healthcare industry are typi- cally closed, proprietary systems. Similarly, within the retail industry, point-of-sale (POS) systems and inventory control systems often operate on proprietary or legacy systems and software. Bring your non-standard and sensitive systems into com- pliance with a network-based solution that can provide a non-intrusive, agentless anti-virus compensating control by detecting active infiltrations and providing an immediate alert and remediation assistance. Mitigating Information Risk Encryption of e-mails containing protected data is a core requirement, but PKI-based (public key infrastructure based) encryption is notoriously complex and burdensome to administer and use. Data Loss Prevention (DLP) can play an important role in regulatory and policy compliance and over- all information risk assessment via sensitive data discovery, monitoring, and blocking. But organizational and protection needs vary widely. For some, full endpoint protection is a necessity, for others, a network solution is sufficient, and for yet others a less-robust “DLP lite” is desired. Regulations focus primarily on custodial data — the private data that corporations keep on their customers. And although protecting this data is the whole point of compliance, analysts estimate that the value of this data is less than half that of the corporate IP data not covered by compliance. So a com- pliance-dominated data protection program may be leaving much of your valuable data at unwarranted risk. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 26. 22 Conquering Compliance For Dummies Integrate DLP into your data protection strategy with a solu- tion that offers the flexibility of deployment and protection levels that best suit your needs. Consider identity-based encryption as an equally powerful, but more effective encryp- tion alternative to PKI solutions. Distributed Locations Industries such as hospitality, food service, retail, and, increasingly, healthcare are dependent on extremely distrib- uted branch/store environments. Each location typically has a simple flat, mixed-used network, POS, and other specialty devices, and limited, if any, local IT staffing. These challenges multiplied by hundreds or thousands of sites make security and compliance especially difficult and costly. Investigate host-based software solutions that provide fire- wall, IPS, integrity monitoring, and other protections to criti- cal host systems without the cost and ongoing management complexity of perimeter security devices. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 27. Chapter 4 Charging Through PCI DSS In This Chapter ▶ Getting the basics of PCI DSS ▶ Identifying and addressing PCI compliance challenges T he Payment Card Industry Data Security Standard (PCI DSS or simply, PCI) is a worldwide industry initiative that spec- ifies and enforces security standards to protect sensitive card- holder data from theft. PCI was created by the major payment card brands to protect themselves (and consumers) from the theft and fraudulent use of the primary account number (PAN) and sensitive authentication data that allows us all to confi- dently spend our money. In this chapter, we explore PCI compliance requirements, challenges, and solutions. Understanding PCI Requirements PCI applies to any business that transmits, processes, or stores credit card transactions — regardless of whether a business processes thousands of transactions a day, or a single transaction a year. Compliance is mandated and enforced by the payment card brands (American Express, MasterCard, Visa, and others) and each manages its own com- pliance program. Merchants and processors are categorized into levels by the number of yearly transactions they manage (see Table 4-1). And while all levels must comply with the requirements, only These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 28. 24 Conquering Compliance For Dummies level 1 and 2 merchants must undergo a yearly on-site audit by a Qualified Security Assessor (QSA). Table 4-1 Merchant Categories for PCI PCI Level Transactions Onsite Self- Network Per Year Audit Assessment Scan 1 > 6M Annually Quarterly 2 1M – 6M Annually* Quarterly 3 20K – 1M Annually Quarterly 4 < 20K Annually Quarterly * Master Card merchants only, at the time of this writing PCI version 1.2 consists of six core principles, supported by 12 accompanying requirements, and more than 200 specific controls for compliance. Compared to most security regula- tions, PCI is both broader in scope and more precise in speci- fication detail. Although it is far from being a full blueprint for enterprise security, it is credited with raising the security standards and awareness of many organizations around the world. PCI is a living specification that is expanded and amended on a regular basis by a cross-industry working group. PCI audit standards are also periodically evolving to better encompass new technologies and to tighten enforcement criteria. Penalties for noncompliance are levied by the payment card brands and are some of the toughest among security regula- tions. These currently include: ✓ Fines up to $25,000 per month for minor violations. ✓ Fines up to $500,000 for violations that result in actual lost or stolen financial data. ✓ Loss of card processing authorization, making it almost impossible for many businesses to function. See Appendix B for a mapping of core controls to PCI requirements. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 29. Chapter 4: Charging Through PCI DSS 25 Handling Top PCI Challenges Achieving and maintaining PCI compliance in a dynamic busi- ness and technology environment is no simple task. Building a security compliance solution strategy to handle the core controls (see Chapter 2) is essential, but you will also need to solve many tough compliance challenges that are covered in Chapter 3 and the following sections. Virtualization The topics of virtualization and cloud computing aren’t spe- cifically addressed by the current PCI requirements, leaving appropriate judgments to QSAs and their clients. But the complexity and dynamic nature of virtualized environments clearly pose security and compliance challenges beyond the protection capabilities of perimeter-based firewalls, intrusion detection and prevention systems (IDS/IPS), as well as tradi- tional anti-malware protection. How do you virtualize your systems with confidence? Look for a virtualization-aware solution that can secure against new virtualization threats but can also provide both physical and virtual servers with the same levels of protection, integrity monitoring, PCI compliance controls, and performance. Risk visibility and control The broad topic of risk management is addressed in several ways by the PCI standard. PCI recognizes the importance of vulnerability management — specifying requirements for continual scanning and timely patch deployment. It also rec- ognizes the need for policy compliance and regular security assessments. But automating the execution of these error- prone and costly processes requires a sound strategy and a special set of technology solutions. An end-to-end vulnerability management strategy involves multiple products and procedures to rigorously discover, shield, and successfully patch systems on a continual basis. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 30. 26 Conquering Compliance For Dummies The best place to start is with a vulnerability management platform that offers scanning plus overall process manage- ment. Consider that virtual patching can be used as a best practice and compensating control to close your window of exposure to vulnerabilities, protect “unpatchable” systems, and eliminate costly ad-hoc and emergency patching. E-commerce Web sites Despite their importance to e-commerce and your company’s reputation, Web sites remain extremely vulnerable to attack and hijacking, putting both individual customers and your entire database at risk. PCI sets specific baseline scanning requirements for Web site security, but how can you be certain you’ve got the best pro- tection against sophisticated SQL injection attacks and other threats used to exploit your ever-changing Web content? Your Web site needs much more than PCI scanning to be pro- tected. You’ll want the same host protection and vulnerability management as any mission-critical server, plus specific Web application vulnerability scanning to ensure protection of your dynamic Web content. Distributed locations Network-based perimeter security is cost-prohibitive for any widely dispersed business such as retail, hospitality, and increasingly, healthcare. These distributed locations typi- cally have flat, multi-use networks, specialty POS and other devices, and little or no local IT management. How can you protect in-scope systems at distributed locations in a cost effective manner? Investigate host-based software solutions that provide firewall, IPS, integrity management, virtual patching, and other protections to critical host systems without the cost and ongoing management complexity of perimeter security devices and multiple agent solutions. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 31. Chapter 4: Charging Through PCI DSS 27 Noodles & Company – Beyond PCI Noodles & Company (w w w . firewall appliances at each restau- noodles.com) has more than rant. “We chose Trend Micro Deep 230 restaurants in 18 states. The Security because it helps us address company is committed to employing the major PCI compliance require- the best possible security technol- ments with features like file integrity ogy for protecting customers’ credit monitoring. It helps us do all we pos- card information. In fact, Noodles & sibly can to safeguard credit card Company doesn’t just want to meet data.” PCI requirements — they want to The key benefits of the Trend Micro exceed them.  “We like to think of solution include: PCI as a baseline — we are looking to pass, and also pass with flying ✓ PCI compliance and more: Trend colors,” said Nick Fields, a senior IT Micro Deep Security helps systems administrator at Noodles & Noodles achieve compliance Company. “We feel we are ahead of and meet their demanding secu- a lot of the industry, and we want to rity goals. stay there.” ✓ Best TCO for distributed loca- As the company has grown, soft- tions: Deep Security provides a ware solutions became a more cost- more cost-effective solution com- effective alternative to hardware pared to hardware appliances. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 32. 28 Conquering Compliance For Dummies These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 33. Chapter 5 Examining HIPAA and Healthcare Compliance In This Chapter ▶ Covering the basics of HIPAA, HITECH, and more ▶ Protecting ePHI data, mobile devices, medical equipment, and more H ealthcare systems throughout the world are in a time of great transition. In the U.S., for example, government mandates for electronic medical records/electronic health records (EMR/EHR) systems are linked to increasing privacy and security regulations for electronic Protected Health Information (ePHI). Around the globe, technology advances are causing a growing privacy focus among government regu- lators. Targeting the core controls (see Chapter 2) will help healthcare organizations comply with the regulations they face, but they also must solve many tough compliance chal- lenges (see Chapter 3) that we cover in this chapter. The terms electronic medical record (EMR) and electronic health record (EHR) are increasingly used interchangeably. Technically, an EMR is the health-related information about an individual within a single care provider organization, whereas an EHR is the aggregate health-related information about an individual across multiple organizations. For simplic- ity, we refer to both as an EHR. Although EHR systems may ultimately lead to more efficient and effective patient care, they also increase the threat of cybercrime and large-scale breaches of ePHI. Moreover, increased reliance on IT and EHR systems means that a These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 34. 30 Conquering Compliance For Dummies security risk or vulnerability has the potential to be life- threatening. Compliance with security regulations will guide healthcare providers of all types to mitigate their risk, but maximizing protection of these complex operations requires a broader strategy. Healthcare organizations throughout the world are facing sim- ilar security and compliance challenges as those outlined in this chapter. Addressing core controls is an effective strategy to meet these and other regulations that may apply. In this chapter, we take a closer look at healthcare regulations and compliance issues. See Appendix A for details on how the core controls map to HIPAA and HITECH requirements. Regulatory Compliance in the Healthcare Industry For more than a decade, patient data privacy and security regulations have slowly evolved. But new, stricter privacy requirements, mandates for EHR modernization, and govern- ment funding are now driving the industry forward and sig- nificant investments are being made to modernize and secure their operations. Protecting ePHI with HIPAA The U.S. Health Insurance Portability and Accountability Act (HIPAA) of 1996 states that “covered entities” are required to employ safeguards that “ensure the confidentiality, integrity, and availability of all ePHI” under their control. HIPAA compliance applies to covered entities (including health insurers, healthcare clearinghouses, and healthcare providers), as well as their business associates. The HIPAA Privacy Rule consists primarily of administrative and physical controls and the HIPAA Security Rule consists of technical controls. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 35. Chapter 5: Examining HIPAA and Healthcare Compliance 31 Mercy Memorial Hospital System maximizes compliance and business continuity Founded in 1929, Mercy Memorial solutions are powered by the Trend Hospital System (www.mercy Micro Smart Protection Network memorial.org) today includes a infrastructure. Together they help central 238-bed, full-service commu- keep Mercy Memorial both com- nity hospital complex and 28 remote pliant and secure by addressing a locations and offices. Although broad range of compliance controls, HIPAA compliance and the protec- enabling business innovation, and tion of patient information on its 200 delivering maximum protection with servers and 900 desktop computers minimal complexity. is a must for the healthcare provider, Deploying Trend Micro Enterprise business continuity is also an over- Security minimized IT time spent arching priority. managing security, increased the “We must go beyond simply meeting up-time for Web protection, and compliance requirements, and also maximized the value obtained from integrate best practices for security the existing virtual environment. “The within our business operations,” said Trend Micro solutions have done a Eric Mynster, ITS operations man- good job of safeguarding patient data ager for the organization. “We need as well as maximizing our employees’ to do everything we can to block productivity,” says Mynster. threats to security and productivity.” The key benefits of the Trend Micro Risk assessment and prioritization is solution include: an ongoing activity within the orga- ✓ Meeting compliance require- nization, and IT wanted a security ments: Trend Micro helps Mercy solution that could help with efforts Hospital achieve and exceed to maintain a proactive stance for healthcare compliance controls. compliance and overall security. “We were looking at many individual secu- ✓ Minimized risks: Trend Micro rity products — individual anti-virus, Enterprise Security defense-in- e-mail filters, spam solutions, and URL depth provides maximum threat filtering — but Trend Micro offered protection. us the value of a complete package,” ✓ Alignment with virtualization: said Mynster. “Trend Micro Enterprise With VMware Ready certifica- Security was extremely competitive tion, Trend Micro solutions inte- and covered all of our needs.” grate into today’s virtual server The tightly integrated offering of con- environments. tent security products, services, and These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 36. 32 Conquering Compliance For Dummies Implementing the HIPAA Security Rule with NIST In 2008, the U.S. National Institutes of Standards and Technology (NIST) authored SP 800-66 Rev. 1, as a framework for federal agencies to achieve HIPAA compliance. NIST publications are considered trusted resources for technology implementation guidance. As a result, many non- government agencies can also benefit from the technical specifications highlighted in this guide. NIST SP 800-66 is freely available for download (along with many other great IT security resources) at http://csrc. nist.gov/publications/PubsSPs.html. Stimulating modernization and compliance with HITECH Title XIII of the American Recovery and Reinvestment Act (ARRA) of 2009, also known as the Health Information Technology for Economic and Clinical Health Act (HITECH Act), further reinforces the existing 2014 EHR implementation mandate and provides the necessary incentives to accelerate EHR adoption and clarify key HIPAA security requirements. Key provisions of the Act include: ✓ Funding: Most significant in the Act is actual funding support for EHR conversion via ARRA funds. ✓ Risk assessments: Risk assessments can be both proactive and reactive. The Act specifically identifies risk assess- ments as necessary in determining, after the fact, whether an incident is indeed a breach of unsecured ePHI. ✓ Breach notification requirements: The Act specifies disclosure requirements for ePHI that is “not secured through technology or methodology.” Not only do the disclosure requirements subject the breached organiza- tion to public scrutiny, but the costs associated with notifying affected individuals can also be significant. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 37. Chapter 5: Examining HIPAA and Healthcare Compliance 33 ✓ Safe Harbor through encryption: The Act defines secured ePHI as data that is either encrypted or destroyed. It goes further to state that if secured ePHI is involved in a data breach, notification requirements do not apply. This is a significant directive, specifically pre- scribing encryption as both a preferred means to enforce confidentiality and as a relief from breach notification requirements. HIPAA and HITECH compliance may be top of mind, but most large U.S. healthcare organization are also probably subject to a number of other regulations, administrative requirements, and auditing standards, such as the following: ✓ PCI (discussed later in this chapter and in Chapter 4) ✓ U.S. Federal Trade Commission (FTC) ✓ U.S. Department of Health and Human Services (HHS) ✓ Centers for Medicare and Medicaid Services (CMS) ✓ Office of the National Coordinator (ONC) ✓ Joint Commission ✓ Certification Commission for Health Information Technology (CCHIT) ✓ Healthcare Information Technology Standards Panel (HITSP) ✓ Healthcare Information and Management Systems Society (HIMSS) ✓ Electronic Healthcare Network Accreditation Commission (EHNAC) ✓ Genetic Information Nondiscrimination Act (GINA) ✓ Various state data breach laws ✓ International Organization for Standardization (ISO) ✓ Statement on Auditing Standard 70 (SAS70) Implementing strong core controls is the key to meeting these various requirements with minimal effort. Take a look at Appendix A to see how the core controls map to HIPAA, HITECH, and NIST. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 38. 34 Conquering Compliance For Dummies Enabling access to electronic healthcare applications and data at BIDPO In a joint project with its affili- “We needed this project to be as ated medical center, Beth Israel secure as possible, so we did what- Deaconess Physician Organization ever we could do to get this locked (BIDPO) (http://bidpo.org) down,” said Gillis. “We had to make set out to provide a secure, robust, sure we had no ‘Globe-able Events,’ and cost-effective EHR infrastruc- meaning that we’re not going to have ture for its 200 to 300 independent a security breach that will appear on physicians at 173 locations in east- the front page of the Boston Globe. ern Massachusetts. Utilization of We needed a partner that could help this system allows BIDPO members us mitigate any risk.” to meet all the Meaningful Use cri- The Trend Micro security solu- teria specified for reimbursement by tions are also helping IT comply ARRA. with other regulations that apply The project priorities included server to their business, such as HITECH, virtualization, a SaaS deployment Massachusetts Data Encryption Law model, and a defense-in-depth secu- 201 CMR 17.00, and ARRA. rity architecture to protect patient The key benefits of the Trend Micro data. “We created a multilayer solution include: security protocol, including various perimeter devices, from firewalls to ✓ EHR innovation: Trend Micro network-based intrusion detection solutions secure BIDPO’s inno- systems,” said Bill Gillis, eHealth vative applications and deploy- technical director at the medical ment model. center. “Our most important secu- ✓ Virtualization security and com- rity layer is the Trend Micro Deep pliance: Deep Security provides Security software.” unique dedicated virtualization Deep Security provides compre- protection. hensive host security for the orga- ✓ Minimized vulnerabilities: Deep nization’s virtualized servers, EHR Security shields critical systems applications, and patient data, giving and applications from vulner- BIDPO confidence that they are abilities until patches can be HIPAA compliant — and that their deployed. public reputations are safe. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 39. Chapter 5: Examining HIPAA and Healthcare Compliance 35 Enforcing PCI DSS Healthcare institutions that accept credit card payments must also comply with the Payment Card Industry Data Security Standard (PCI DSS). Health insurance premiums, medical services, and even hospital gift shop purchases are examples of transactions where the security of cardholder data is required. Healthcare institutions are well advised to design and implement a security framework that addresses both HIPAA and PCI DSS. See Chapter 4 for more on PCI DSS. Healthcare Security and Compliance Challenges — and Solutions Maintaining regulatory compliance and maximizing security effectiveness is especially demanding in today’s rapidly evolv- ing healthcare industry. Understanding these challenges will help you select and implement solutions to secure your criti- cal systems and data, and meet increasingly stringent regula- tory requirements. The following challenges are especially critical. (See Chapter 3 for additional information on these and other challenges facing healthcare organizations.) Protecting patient data Although perimeter and content security provide important safeguards, HIPAA and HITECH make it clear that encryption is the only acceptable way to protect ePHI and avoid costly disclosures. Effective encryption deployment also requires a data loss prevention (DLP) solution to discover where ePHI is stored and ensure its encryption when transmitted. However, most encryption and DLP solutions suffer major drawbacks that impede their success and widespread adoption. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 40. 36 Conquering Compliance For Dummies Integrate DLP into your data protection strategy with a solu- tion that offers the flexibility of deployment and protection levels that best suit your needs. Consider identity-based encryption as an equally powerful, but more effective, encryp- tion alternative to PKI solutions. Securing laptops and mobile devices Portable laptops, PDAs, and other mobile devices are quickly becoming mainstays in healthcare, and essential to the daily tasks of nurses, physicians, and other healthcare professionals. These devices are at extreme risk for attack and ePHI loss, but can’t be adequately protected by network-based solutions. Only a cloud-enabled endpoint security solution can pro- tect a full range of devices from Web, e-mail, and file threats wherever they roam. You’ll also want to investigate endpoint encryption and DLP — they’re becoming essential as these devices increasingly store protected data. Securing critical medical devices Computerized medical devices for patient evaluation and diag- nosis are increasingly a common part of the hospital network and so are at risk for compromise and failure due to malware infections or external attacks. Though protection is required by regulation, these systems can be prohibitive or impossible to secure with standard endpoint protection products. Bring non-standard and sensitive systems such as MRI scan- ners, X-ray machines, and other patient care devices into compliance with a network-based solution that can detect active infiltrations and provide an immediate alert and reme- diation assistance. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 41. Chapter 6 Top Ten Reasons to Use Trend Micro Enterprise Security In This Chapter ▶ Seeing how Trend Micro addresses the core controls and solves tough compliance challenges ▶ Achieving compliance without security compromise S ecurity compliance is costly, complex, ever changing — and still not enough to protect your company’s sensitive data. Trend Micro Enterprise Security offers you a better way to stay both compliant and secure with solutions that address a broad range of controls, solve tough compliance challenges, and deliver maximum protection at minimal cost. That’s com- pliance without compromise! Trend Micro Enterprise Security products and services are powered by the Smart Protection Network — a next- generation cloud-client infrastructure that combines cloud- based reputation technology, feedback loops, and the exper- tise of TrendLabs researchers to deliver real-time protection and greatly simplify security management. Targeting Core Compliance Controls Trend Micro products can help you address the core compli- ance controls that apply directly to most security regulations. With Trend Micro you can secure your organization and These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 42. 38 Conquering Compliance For Dummies achieve compliance across a wide range of controls and regu- lations (see Figure 6-1). omplexity. um C inim .M ion Web Securit ct t o in y y dp urit te Core Security ro c En mP Meecurity Se Compliance Controls S u ssaging Maxim • IT Risk Assessment TREND MICRO ta Center • Vulnerablilty & Patch Mgt SMART Da ecurity • IT Policy Adherence PROTECTION NETWORK • Incident Response • Sensitive Data Protection S vic ns es i lut o • Firewall, IDS/IPS • Anti-virus/Anti-malware Da So Ser • Anti-spam/Anti-phishing ta P rotection an d • Logging & Reporting Figure 6-1: Trend Micro Enterprise Security Solutions. Solving Tough Compliance Challenges Trend Micro products offer unique solutions that help you solve tough challenges that arise from applying compliance controls within your particular operating environment, evolv- ing business and IT initiatives, and limited security budget. Risk visibility and control Trend Micro vulnerability and threat management solutions offer you greater risk visibility and remediation control over active security threats, software and systems vulnerabilities, changing Web content, and IT policy compliance. Server/desktop virtualization Trend Micro server and endpoint solutions provide advanced virtualization-aware software that secures virtualized desktops and servers with best-in-class protection, optimized performance, and critical compliance controls. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 43. Chapter 6: Top Ten Reasons to Use Trend Micro Enterprise Security 39 Public cloud computing Trend Micro provides the secure virtual server and volume- level data encryption solutions that can allow you to confidently incorporate the public cloud into your data center strategy. Web sites and portals Trend Micro Enterprise Security keeps your Web site and company reputation secure with Web site application scan- ning, PCI scanning, best-in-class server protection, and com- prehensive vulnerability management. Non-standard systems Trend Micro’s unique network-based Threat Management Services discover any active infiltration, allowing you to achieve compliance and noninvasive protection for any end- point or server, including legacy or proprietary devices. Distributed locations Trend Micro Deep Security provides firewall, IPS, virtual patch- ing, integrity monitoring, and other core controls directly to criti- cal systems — eliminating the cost and management complexity of perimeter security devices at each location. Worker mobility Trend Micro OfficeScan and the Smart Protection Network keep wireless and mobile devices of all kinds protected from Web, e-mail, and other threats both on and off the corporate network. Mitigating information risk Trend Micro secures sensitive data with endpoint and network DLP, identity-based endpoint and e-mail gateway encryption, and content filtering solutions that emphasize security, management simplicity, and employee ease-of-use. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 44. 40 Conquering Compliance For Dummies Compliance without Security Compromise You can employ various strategies to achieve compliance with applicable regulations. But will your strategy provide the best, or even adequate, protection of your data and reputa- tion? Compliance-driven organizations may use a patchwork of products that allow them to mark off boxes on a compli- ance checklist, but don’t necessarily offer best-in-class protec- tion levels or completeness of coverage. For security-driven organizations that want to truly protect their sensitive data and comply with regulatory requirements, Trend Micro Enterprise Security solutions and the Smart Protection Network help you achieve both compliance and security — without compromise. Real-world tests by NSS Labs (see Figure 6-2) confirm that Trend Micro offers highly rated protection against malware and other threats. Mean Block Rate for Socially Engineered Malware 100% Block on Download/ Execution Trend Micro Kaspersky 90% Symantec McAfee Norman F-Secure 80% Average Panda ESET 70% AVG Block on Sophos Download 60% 80% 90% 100% 70% Source: NSS Labs Reports Figure 6-2: Trend Micro provides maximum protection against malware threats. These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 45. Appendix A Core Compliance Controls – Healthcare Regulation Mapping Core Control Applicable U.S. Healthcare Regulations & Guidelines – HIPAA, HITECH, NIST IT Risk HIPAA § 164.308 (a)(1) Security Management Assessment Process (Includes required risk analysis and risk management) HITECH Breach Notification for Unsecured Protected Health Information Vulnerability HIPAA § 164.308 (a)(1) Security Management & Patch Process (Includes required risk analysis and risk Management management) IT Policy HIPAA § 164.308 (a)(6) Policies and procedures to Adherence address security incidents Incident HITECH Breach Notification for Unsecured Response Protected Health Information HITECH § 13402 Notification in Case of Breach These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 46. 42 Conquering Compliance For Dummies Core Control Applicable U.S. Healthcare Regulations & Guidelines – HIPAA, HITECH, NIST Sensitive Data HIPAA § 164.308 (a)(1) Security Management Protection Process (Includes required risk analysis and risk management) HITECH Breach Notification for Unsecured Protected Health Information HITECH § 13402 Notification in Case of Breach HIPAA §164.404 Notification to Individuals (Description of type of unsecured ePHI involved in the breach) NIST Publication 800-66 (Guidelines for Implementing HIPAA Security Rules) HIPAA § 164.310(d)(1) Device and Media Controls HIPAA § 164.514(d) Minimum necessary uses and disclosures of PHI HITECH Exemption from breach notification if PHI is secured using encryption HIPAA 45 CFR parts 160 and 164 (Interim Rule) Encryption and destruction for rendering ePHI unus- able, unreadable, or undecipherable to unauthorized individuals HIPAA 45 CFR parts 160 and 164 (Interim Rule) Keep encryption keys on a separate device from the data that they encrypt or decrypt HIPAA § 164.308(b)(1) Business associate will appropriately safeguard information HIPAA § 164.312(e)(1) Transmission Security (Guard against unauthorized access to transmit- ted ePHI) HIPAA § 164.306(a)(1) Protect ePHI: Facilities must protect the confidentiality, availability, and integ- rity of all ePHI created, received, maintained, and transmitted HIPAA § 164.308 (a)(6) Policies and procedures to address security incidents These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 47. Appendix A: Core Compliance Controls — Healthcare Regulation Mapping 43 Core Control Applicable U.S. Healthcare Regulations & Guidelines – HIPAA, HITECH, NIST Firewall & IDS/ HIPAA § 164.308 (a)(1) Security Management IPS Process (Includes required risk analysis and risk management) HIPAA § 164.312(a)(1) Access Control (Allow access only to those persons or software pro- grams that have been granted access rights) NIST Publication 800-66: 4.14 Access Control for HIPAA §164.312(a)(1)) (Have all applications/ systems with ePHI been identified?, Where is ePHI currently housed?) HIPAA § 164.312(c)(1) Integrity (Protect ePHI from improper alteration or destruction) Anti-virus & HIPAA § 164.308 (a)(5)(ii)(B) (Protection from mali- Anti-malware cious software. Procedures for guarding against, detecting, and reporting malicious software) HIPAA § 164.308 (a)(1) Security Management Process (Includes required risk analysis and risk management) Anti-spam & HIPAA § 164.308 (a)(5)(ii)(B) (Protection from mali- Anti-phishing cious software. Procedures for guarding against, detecting, and reporting malicious software) HIPAA § 164.308 (a)(1) Security Management Process (Includes required risk analysis and risk management) Logging & HIPAA § 164.308 (a)(1) Security Management Reporting Process (Includes required risk analysis and risk management) HITECH Breach Notification for Unsecured Protected Health Information These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.
  • 48. 44 Conquering Compliance For Dummies These materials are the copyright of Wiley Publishing, Inc. and any dissemination, distribution, or unauthorized use is strictly prohibited.