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Educause+V4.ppt
1. An Auditor's Perspective on
Frameworks for Information Systems
Security in Higher Education
Erwin “Chris” Carrow, University System of Georgia
Brian Markham, University of Maryland, College Park
Copyright Erwin L. Carrow & Brian Markham 2009. This work is the intellectual property of the author. Permission is granted for this
material to be shared for non-commercial, educational purposes, provided that this copyright statement appears on the reproduced
materials and notice is given that the copying is by permission of the author and other identified entities. To disseminate otherwise or
to republish requires written permission from the author. Videos and specific graphics presented are not for public distribution.
2. Session Agenda
Key Takeaways and Introductions
What Makes Higher Education Different
Business Risk and Functional Practices
Internal Controls: Quick Overview
Frameworks for Security
Specific Guidance and Standards
Additional Audit Considerations
Q&A
3. Key Takeaways
At the end of this session you should be able
to:
Identify business goals, functions, and
associated roles and risk;
Understand the critical success factors during
an audit;
Evaluate the internal control structure of your
environment;
Know the standards and frameworks available
for use in your environment;
4. Your Session Guides
Erwin “Chris” Carrow - IT Auditor,
University System of Georgia Board of Regents
High level
General focus
Brian Markham - IT Compliance Specialist,
University of Maryland at College Park
Low level
Specific focus
5. Auditing Higher Education: Challenges
and Business Requirements
Where are you at? Can seem like … HERDING CATS!
EDS “Cat Herding” 1:07 minutes
6. What Makes Higher Education
Similar and Yet Different?
Universities are not Corporations, but …
Herding Cats may be a common or predominate phenomena
Business functions and processes are similar
Objectives, rules and requirements are similar
Resources, e.g., people information, infrastructure, applications, etc.
Different set of risks, challenges, and regulatory mandates
“Open System” Attitude (moving target)! “Academic Freedom” is a
privilege, not a right!
Diversity of administrative operational requirements
Diversity of instructional and faculty requirements
Operational and Functional sides of the house not always in
agreement – leadership changes and challenges do exist!
Freedom of information
Difficulties in blocking or outlawing certain risky behaviors
Mandated safe guard information and information systems
Bottom-line: Environment must foster Learning and Research!
7. Auditors Ask the Question…
What High Criticality Risks Exist?
Categories of risk that may or may not apply:
Strategic : Affects the entities’ ability to achieve
goals and objectives
Compliance : Affects compliance with laws and
regulations, safety and environmental issues,
litigation, conflicts of interest, etc.
Reputational : Affects reputation, public
perception, political issues, etc.
Financial : Affects loss of assets, technology, etc.
Operational : Affects on-going management
processes and procedures
9. Threats and the Facts
Privacy Right Clearinghouse
Chronology of Data Breaches 2,500,000 since January 2005
that have been reported
[www.privacyrights.org/ar/ChronDataBreaches.htm]
Ponemon –HRH 2008 Privacy Breach Index Survey (Sept 2008)
Self evaluation of overall performance of organization: -- 9%
gave an “A” -- 31% gave a “B” -- 26% gave a ”C” -- 29% gave a
“D” – 5% gave a “F” [www.HRH.com/privacy]
80 % believed their organizations experienced information
system data breaches and loss of customer and personal
information
50% Negligence, -- 29% Third-Party, 3% Hacker, --1% other
criminal activity;
36% 1 to 4 breaches involving 100 or records; 32% 5 to 8; 31%
9 or more
11. Regulatory Standards
FERPA, FISMA, HIPAA, PCI DSS, SOX, NCAA, A-21,
A-133, PATRIOT, GLBA, ADA, CAA, CWA, OSHA,
FLSA, FMLA, EEO, and possibly many others!
State, Local, and University System and Institution
Guidelines
“Due Negligence” violations have cost institutions
financially, but few if any individuals have gone to
jail for lack of compliance
Reputational losses are the critical issue!
Avoid FUD – Fear, Uncertainty, and Doubt
12. Information Security and
Compliance Responsibilities
Know and comply with Federal, State, Local, and
University System and Institution Regulations
Talk to auditors, colleagues, peers, and
administrators about information and information
system regulatory compliance and security
Make the “alphabet soup” and security a top priority
when evaluating new systems and initiatives
Understand how the regulations trickle down to
through policies, standards, procedures, and the
people involved (in a practical method)
13. What should a Risk Assessment
identify about our environment?
What are the risks?
What are the impacts?
What is the likelihood it
will happen?
Who is involved?
Are we willing to accept
the risk?
What are we currently
doing to mitigate this
risk? Is it working like we
think it should?
14. Making the Lose/Lose Situation …
a Win/Win
A PERFECT information technology operational environment or risk
prevention assurance system does not exist (e.g., IT Trunk Monkey)!
Priority directed to likely threats for known vulnerabilities by:
Affirming good controls and practices
Uncovering unknown vulnerabilities or inappropriate
practices
Focus upon what is essential for the success of Your Institutions
“Business Functions.” Which comprise of:
Business Rules or Requirements: A statement that defines or
constrains some aspect of the business. It is intended to assert
business structure or to control or influence the behavior of the
business.
Business Standards or Practices: A related group of business
processes that support some aspects of the mission of an enterprise.
15. Doing Business and Dealing with the Nuts
The Old Way…! Assessing Risk?
20th Century FOX “Ice Age” 1:55 min/sec
16. Nuts Can Be Challenging
Business Process – Gathering and Storing NUTS and the Big Squeeze
Tasks of Dealing with
the NUTS–
1. Gather Nuts
2. Store Nuts
3. The Big Squeeze?
Operational versus
Functional needs!
What are the Associated
Risks?
20th Century FOX “Ice Age”
17. In Time, Nut Requirements Change
The New Way …! Risk Assessment?
20th Century FOX “Ice Age 2: The Meltdown” 55 sec
18. Different Nuts, Different Methods
History has a Way of Repeating Itself!
Old Ways can Influence
New Ways of …,
Different Business
Requirements – Use of
Different Methods
(Variety of NUTS)
Sometimes the NUTS
get Bigger and Harder
to CRACK
Risk may Change or
Increase!
20th Century FOX “Ice Age 2: The Meltdown”
19. Making Peanut Butter Out of Nuts
Moral: Life is Always Going to Be a Little Squirrelly
Business function Goals and
Objectives can make the IT
requirements a little NUTTY
Risk Implications associated
with IT Implementations are
NOT always CONSIDERED
Clearly Define the Task: Try
making PEANUT BUTTER
out of a difficult situation – it
is easier to Store
WHERE DO YOU START?
20th Century FOX “Ice Age 2: The Meltdown”
20. Know Yourself – Know Your Enemy!
The Art of War (Chinese: 孫子兵法; pinyin: Sūn Zǐ Bīng Fǎ) is a Chinese military
treatise that was written during the 6th century BC by Sun Tzu.
Two Possible not Recommended Responses to the Challenge
Freak Out: Embrace Hopelessness, Hide, Ignore, Deny, and Play
Computer games until the Inevitable Occurs
Idealistic and Unrealistic: Do the “Don Quixote (To Dream the
Impossible Dream and Fight the Impossible Fight)” - Wear yourself
out Fighting Windmills by shooting at whatever pops its head out!
Third Approach “How do you Eat the Elephant standing in the corner,
Instead of Avoid it?” Take ONE BITE at a time by…
Strategizing a Response
Create a deliberate Long term Plan
Identify Short term Objectives and Milestones
Gain Key Shareholder ownership of the challenges
Test and Monitor the process with Identifiable Outcomes
Start with Business Functions – Gathering and Storing of NUTS
21. Business Functions (other Nuts)
It still comes down to …, Business Needs and Outcomes
Goals or Objectives
Rules and Requirements
Identifying critical business functions
Finance and Accounting
Financial Aid
Human Resources
Registration
Student Services
Other administrative functions
Identify the departments and who are the key personnel,
e.g., Business owner, Trustees and Stewards?
Identify the systems that support these functions
How are the people and systems integrated into the
business process?
What internal controls exist to mitigate risk?
22. Business Function’s Objective,
Requirements, Resources, and Practices
YOU MUST
KNOW …
What Business
Principles are in
Operation?
Reasons -Why you
do things a certain
Way
Control Objectives for Information and related Technology (COBIT®)
23. Business Functions and their
Characteristics
Control Objectives for Information and related Technology (COBIT®)
24. Business Function Information
from Origin to Destination
Identify how the information travels and is managed
throughout the business function life cycle!
How packets of data are managed, provisioned,
formatted, and transferred throughout business
functions
How information is handled per its classification and
intended use
Assess information and information system security
from various perspectives
Who are the business owners, trustees, and stewards?
26. Risk Assessment Flow
The methodology for auditing the information and information systems
for compliance and security is a Top Down process
Business Goals to Standards and Practices
Business Function to Information System
Leadership (administrator) to Technician or Staff member (end user)
Assess Requirements, Resources, and Processes
The approach will focus on key business functions and their associated
Business Goals and Objectives as it relates to the audited entity e.g.,
Identity and Access Control Management (IAM), Perimeter and Network
Security (NETSEC), etc.
Once identified and agreed upon for each business function, the key
associated requirements, resources, and processes will be identified
and assessed to determine if high or critical risk is being managed.
Focus on Control Practices, Responsibility / Accountability,
associated with key activities with an expected CMMI level 3 criteria
for High Risk Critical processes.
27. Principles for Consideration
1st Top-down Risk Based identification of threats and
vulnerabilities for key Business processes and related IT
support processes, e.g., change management, access security,
operations, etc. (General Risk Assessment)
2nd Control of IT Risk that affect critical IT functionality in
financially significant applications and related data
(Particularized Risk Assessment)
3rd Layered Controls to mitigate risk for application
program code, databases, operating systems, and the
network (Operational processes that align with precedence of
Risk)
4th Risk mitigation based upon Business and Control
objectives (not the limitations of individual controls), have a
Framework, structure, and methodology to support your risk
strategy
28. When Assessing for Risk …
Risk assessment evaluates components of
information, information system security and
compliance as it relates to the business function
Assess Mitigate / Monitor Re-Assess
Ongoing risk management program must be in
place
Business owner or key shareholder must own the
process
Establish a standard for considering and negotiating
risk
Annual (periodic) risk assessment deliverable with
recommendations for corrective action
Clearly define and document accepted risk –
someone needs to sign off on the responsibility
29. Risk Mitigation
Once risks are identified, they must be mitigated via internal controls
Internal Controls: a practice approved by management to mitigate risk
or produce a desired outcome in a business process for implementing
and enforcing information security and compliance
Preventive - controls to stop the problem from occurring
Detective - controls to find the problem
Corrective - controls to repair the problem after detection
Administrative - policies, standards, guidelines, and procedures
Technical - controls using hardware or software for processing
and analysis
Physical - controls to implement barriers or deterrents
Document and retain artifacts.
Design Document Implement
Test the controls prior to implementation to validate expectations
Monitor results
Re-test controls periodically.
30. High Level IT Control Model
IT Services
OS/Data/Telecom/Continuity/Networks
Business
Process
Procurement
Business
Process
Accounts
Payable
Business
Process
Accounts
Receivable/
Claiming
Business
Process
Programs
and
Operations
Executive
Manag ement
Agency Level IT Considerations
IT General Controls
Application Controls
*End User Computing*
31. Re-Assess Risks
Risk Assessments are an on-going exercise;
Track mitigation strategies, did they work?
What “Framework(s)” are being applied?
Is there an identifiable “Structure” in place e.g., risk
management program?
Is the “Methodology” recognizable, e.g.,
documented and not arbitrary?
Are you using Tools to monitor, manage, and
validate the associated processes?
Test, re-test controls (Design and Effectiveness)
Document test results, corrective actions, changes
in business needs/requirements.
32. Better Controls =
Improved Security
IT Security comes down to presence and
effectiveness of internal controls;
Weak controls = weak security
Audits are an evaluation of controls, audits are
FREE consulting services!
All of the security practices that we utilize are really
just controls, from firewalls to IPS to virus
scanning.
How these controls come together ultimately
determines out overall control environment (and
our control gaps).
Framework?
33. Frameworks for IT Security
COBIT - High level business objectives and
outcomes
ISO & NIST - Standards and checklists for
consideration
Criteria - CMMI
CIS - Tools
ITIL - Process Models
Any framework is better than NO framework!
Frameworks map to structure which should produce
a consistent methodology for addressing risk
Be able to explain …!
How it was derived
Why your strategy makes sense
How it manages risk
34. COBIT
Developed by the ITGI (Current v4.1)
Value of IT, Risk, and Control
Links IT service delivery to business requirements
(already defined, right?)
A lifecycle; constantly adapting, improving, re-
adapting
Four Responsibility Domains:
Plan and Organize (PO)
Acquire and Implement (AI)
Deliver and Support (DS)
Monitor and Evaluate (ME)
Make a grocery list of needs and then go shopping
37. ISO 27002
Code of Practice for Information Security
Management
Divides IT Security into 11 Categories (Clauses)
Defines key controls over specific sub-categories
Defines implementation guidance for each key
control
39 Control Objectives with 139 Controls
Control objectives are generic functional
requirement specifications for an organization’s
information and information system security
management control architecture
39. ISO 27002
Benefits:
ISO 27002 is a very hands-on control guideline
DIY Framework, no consultants required
Proactive – not reactive.
Certification
Less stressful audits!
How do we get to ISO 27002?
Evaluate/Implement Key Controls;
This will require policies/processes/procedures;
Executive level buy-in;
Team effort, IT Security is EVERYONES responsibility.
40. NIST
NIST offers security guidance in many areas
Special Publications
Useful high level governance standards and
practices
Practically every IT security subject is covered here
Written for the Feds but very useful for any
organization
Current government agency 2007 self assessment
average grade is “C-”, e.g., Academic probation
http://csrc.nist.gov/publications/PubsSPs.html
42. Center for Internet Security (CIS)
CIS Benchmarks provide guidelines for operating
systems and databases;
User originated, widely accepted, and reflect the
consensus of expert users worldwide;
Compliance with these benchmarks will reduce
findings and lead to more secure computing
platforms
Some benchmarks include :
Windows Server
Solaris
Oracle
Exchange
43. Center for Internet Security (CIS)
Use benchmarks from CIS for standard builds of
servers, databases, and applications;
A self-appraisal/audit of current systems, builds;
Hardening guide to ward off attacks;
CIS certifies automated tools. Some providers
include:
Belarc
CA
ConfigureSoft
Symantec
Tenable
Tripwire
44. CMMI
An identifiable criteria by which you should
be evaluated!
Capability Maturity Model Integrated created
by the Software Engineering Institute (SEI)
Level 0 - 5 (Non-Existent to Optimized)
45. CMMI
Variants of the CMMI: CMM & ISO 15504
Identifies WHERE you are at in the application of IT risk
mitigation controls and HOW to get to the next level
Levels of Application
Level 0: No Recognizable Process, though one is needed
Level 1: Process is Ad-hoc and perform by key
individuals
Level 2: Process is Repeatable , but not controlled
Level 3: Process is Defined & Documented and
periodically Evaluated
Level 4: Managed & Measurable; effective Internal
Controls with Risk Management
Level 5: Optimized Enterprise wide risk and control
program
46. CMMI
Capability Maturity Model Integrated created by
the Software Engineering Institute (SEI)
Level 0 - 5 (Non-Existent to Optimized)
Auditors need to be able to do more than “take
someone's word for it”
Therefore … Level 3 is a minimum requirement
Defined processes
Documented processes to identify risk and
associate roles and responsibility to mitigate risk
Processes in place to periodically review and
evaluate controls
47. What Does Evidence Look Like?
Definition: Evidence must be Sufficient, Reliable and Relevant
The various types of audit evidence that the IS auditor consider using
include:
Observed processes and existence of physical items, e.g., A
computer room security system in operation
Documentary audit evidence, e.g., Activity and control logs,
System development documentation
Representations, e.g., Written policies and procedures, System
flowcharts, Written or oral statements
Analysis, e.g., Benchmarking IS performance against other
organizations or past periods; Comparison of error rates between
applications, transactions and users
Evidence gathering procedures considered are: Inquiry,
Observation, Inspection, Confirmation, Re-performance, and
Monitoring
Audit evidence should be useful to form an opinion or support the
findings and conclusions.
Evidence gathered should be appropriately documented and
organized to support the findings and conclusions.
48. ITIL - Process Modeling
When you don’t have a good understanding of “what
right looks like”
Models most “Industry Standard “ information and
information system technology processes
When in doubt “check it out and test it out”
Maps to COBIT
Complimentive to NIST and ISO
Helps to provide a starting place
Caution - can be overtly complicated
49. Example of IAM - Audited Entity to be
Assessed for Risk
IAM: Identity and Access Control Management
Identity Management; the management of user
credentials and the means by which users might log
onto and use various systems or resources, e.g.,
the provisioning and de-provisioning of student,
faculty, staff, and outside agencies identities
Access Control; the mechanisms in place to permit
or deny the use of a particular resource by a
particular entity, e.g., technical or administrative
controls to allow or deny access to file shares
50. Users Involved in Business Functions and Types of
System Information?
(Provisioning of High Risk or Critical Information)
Business Functional responsibility for assigning “Rights & Permissions” to
various roles within the organization
Business Owner: Responsible for the provisioning and delegation of the
processes or functions and associated privileges, e.g., Payroll, Registrar,
FinAid, HR, ConEd, etc.
Trustees: Responsible to maintain trust granted by Business owner, e.g.,
“Worker Bees” in the associated departments that conduct day to day
operations
Stewards: Responsible to service and support the business function,
typically provide a technical system or infrastructure to facilitate business
needs, e.g., Information Technology Services, etc.
Types of Information (Data Classification) per institution or university
system standards
Unrestricted / Public: No consequence typically general information
Sensitive: typically references’ legal or externally imposed constraints
that requires this restriction
Confidential: highest level of restriction, applies to the risk or harm that
may result from disclosure or inappropriate use, e.g., FERPA
51. Example associated Key Process –
Ecommerce e.g., One Card System
COBIT high level framework for controls relating to the Ecommerce
systems
Plan and Organize (PO) — Provides direction to solution delivery(AI) and
service delivery (DS): PO1, PO4, PO5, PO6, PO8, PO9, PO10, and PO11
Acquire and Implement (AI) —Provides the solutions and passes them to
be turned into services AI5 and AI4
Deliver and Support (DS) —Receives the solutions and makes them usable
for end users: DS1, DS5 and DS11
Map the requirements to your preferred checklist, e.g. NIST or ISO
Requirements for Ecommerce Compliment other Processes
Less work required for other system implementations
No duplication of effort if requirements are properly addressed
Identity Management applies to many different other process
requirements, e.g., Applications, Operating Systems, and Databases
52. Example: Identity and Access Control
Management (IAM) COBIT Slide 1
COBIT 4.1 DS5.3 Identity Management
Ensure that all users (internal, external and temporary) and their
activity on IT systems (business application, IT environment, system
operations, development and maintenance) are uniquely identifiable.
Enable user identities via authentication mechanisms.
Confirm that user access rights to systems and data are in line with
defined and documented business needs and that job requirements
are attached to user identities.
Ensure that user access rights are requested by user management,
approved by system owners and implemented by the security-
responsible person.
Maintain user identities and access rights in a central repository.
Deploy cost-effective technical and procedural measures, and keep
them current to establish user identification, implement
authentication and enforce access rights.
53. Example: Identity and Access Control
Management (IAM) COBIT Slide 2
Logical Didactic Approach - DS5.3 Identity Management (How it is
Evaluated)
Control over the IT process of Ensure systems security that satisfies the business
requirement for IT of maintaining the integrity of information and processing
infrastructure and minimizing the impact of security vulnerabilities and incidents
By focusing on
defining IT security policies, plans and procedures, and monitoring, detecting,
reporting and resolving security vulnerabilities and incidents
Is achieved by
Understanding security requirements, vulnerabilities and threats
Managing user identities and authorizations in a standardized manner
Testing security regularly
And is measured by
Number of incidents damaging the organization's reputation with the public
Number of systems where security requirements are not met
Number of violations in segregation of duties
54. How to Measure Success?
Maturity Model – CMMI DS5 Snapshoot (Criteria)
DS5 Ensure Systems Security - Management of the process of Ensure systems security that
satisfies the business requirements for IT of maintaining the integrity of
information and processing infrastructure and minimizing the impact of security
vulnerabilities and incidents is:
0 Non-existent when The organization does not recognize the need for IT security. Responsibilities and accountabilities are not assigned … There is a
complete lack of a recognizable system security administration process.
1 Initial/Ad Hoc when The organization recognizes the need for IT security. Awareness of the need for security depends primarily on the individual. IT
security is addressed on a reactive basis. IT security is not measured. Detected IT security breaches invoke finger-pointing responses, … to IT
security breaches are unpredictable.
2 Repeatable but Intuitive when Responsibilities and accountabilities for IT security are assigned to an IT security …, although the management
authority ... Awareness of the need for security is fragmented and limited. Although security-relevant information …, it is not analyzed. IT security is
seen primarily as the responsibility and domain of IT and the business does not see IT security as within its domain.
3 Defined when Security awareness exists and is promoted by management. IT security procedures are defined and aligned with IT security policy.
Responsibilities for IT security are assigned and understood, but not consistently enforced. An IT security plan and security solutions exist as
driven by risk analysis. Reporting on security does not contain a clear business focus. Ad hoc security testing (e.g., intrusion testing) is performed.
Security training is available for IT and the business, but is only informally scheduled and managed.
4 Managed and Measurable when Responsibilities for IT security are clearly assigned, managed and enforced. IT security risk and impact analysis is
consistently performed. Security policies and procedures are completed with specific security baselines. .... User identification, authentication
and authorization are standardized. Security certification is pursued for staff members ... . Security testing is completed using standard and
formalized processes, leading to improvements of security levels. …. IT security reporting is linked to business objectives. IT security training is
conducted …. IT security training is planned and managed in a manner that responds to business needs and defined security risk profiles. Goals and
metrics for security management have been defined but are not yet measured.
5 Optimized when IT security is a joint responsibility of business and IT management and is integrated with corporate security business
objectives. IT security requirements are clearly defined, optimized and included in an approved security plan. Users and customers are increasingly
accountable for defining security requirements, and security functions are integrated with applications at the design stage. Security
incidents are promptly addressed with formalized incident response procedures supported by automated tools. Periodic security assessments are
conducted to evaluate the effectiveness of the implementation of the security plan. Information on threats and vulnerabilities is systematically
collected and analyzed. Adequate controls to mitigate risks are promptly communicated ….
55. COBIT 4.01 Standards to NIST Mapping –Integration with
other Standards (Alignment of IT Controls to Mitigate Risk)
57. Additional Considerations
Develop a strong working relationship with your
auditors
Communicate with them even when not being
audited (typically the most lonely folks on campus)!
Challenge and question their defined and
documented processes for auditing (IIA)
Understand what auditors are looking for and why
Ask them where they see the risk and why
Run questions by them (VM Ware)
Some auditors are fallible, but …, NOT Brian or Chris
(joke)!
58. Call to Action & Challenge
“Birds of a Feather, Flock Together” or
“Life is For the Birds” Be Different?
PIXAR “For the Birds” 3:16 minutes
59. Thank you for your participation
- any questions?
Higher Education is Different!
Understanding Business Risk and
Functional Practices are critical
Internal Controls must be defined,
documented, and reviewed
Chose and apply a security Framework
that provides identifiable structure and
an effective methodology to address risk
Lots of Guidance Standards, tools and
modeled process to emulate
Internal Auditors can be a valuable
resource!
60. Helpful Resources
CIS Benchmarks - http://www.cisecurity.org/benchmarks.html
IIA - www.theiia.org
ISACA - www.isaca.org
ISC(2) - www.isc2.org
ISO - www.iso.org
ITGI - www.itgi.org
NIST - csrc.nist.gov
NSA - www.nsa.gov
IASE - iase.disa.mil
Web App Consortium - www.webappsec.org
EDUCAUSE - educause.edu/security
Univ. Austin Texas Sec. - security.utexas.edu
Univ. Cornell Sec. - www.cit.cornell.edu/security
Virginia Tech Sec. - security.vt.edu
Ga. Tech Info Sec. Center - www.gtisc.gatech.edu
61. Last minute additions…
Thanks to the feedback of some of our participants, we
wanted to add the following:
While CMMI is a maturity model, it is still primarily
aimed towards software delivery. You may want to look
into CMMI for service (SVC) and acquisition. Check
them out here. The maturity model in COBIT is
separate from CMM but is the same basic idea.
The ISO 27000 series in it’s entirety is worth a look.
Check them out here.
COBIT & ITIL are less technical/IT Security related,
NIST and ISO, more so. Keep this in mind when
selecting a framework.