How can a successful SOC2-compliant ISMS be built without power, money and allocated resources?
1. How can a successful
SOC2-compliant ISMS
be built without power,
money and allocated
resources?
Vsevolod Shabad
vshabad@vshabad.com
+7 777 726 4790
2. Briefly about me: the international octopus
IT Cybersecurity
Cloud
Technologies
Risk
Management
Compliance
Data Science
& ML
Project
Management
Culture
Changes
Fraud
Prevention
🇷🇺 🇰🇿
🇷🇸 🇧🇬
🇸🇬
🇹🇷
3. Briefly about company
•US vendor of Kubernetes orchestration software
in multi-cloud environments (AWS, Azure, GCP, …)
•Geo-distributed team (~15 people)
•Flat organisational structure led by CTO
4. What SOC2 means
ISO 27001 SOC2 (SSAE 18)
Formal title
Information security, cybersecurity
and privacy protection — Information security
management systems — Requirements
Statement on Standards
for Attestation Engagements
no. 18
Purpose Information Security Management System Trust Management System
Content
A specific set of controls
(ISO 27001 Annex A, ISO 27002)
+ include/exclude justification
A set of principles:
• Security
• Availability
• Processing Integrity
• Confidentiality
• Privacy
Compliance assessment Periodic
• Periodic (SOC2 Type 1) – processes
and politics
• Continuous (SOC2 Type 2) – controls
efficiency
Information disclosure to interested parties Not intended By NDA
6. The reasons for the supplier SOC2 certification
• Customer benefit – Due Care
for the Supply Chain Attack risks
• Supplier benefit – the prerequisite
for getting the tenders of large
corporate customers
Sonatype 8th Annual State of the Software Supply Chain report
https://www.sonatype.com/resources/2023-software-supply-chain-report
7. Three components of Security Governance
WHAT and WHY?
• Standards, Policies, Guidelines
HOW?
• Procedures (+ automation)
BY WHOM?
• Personnel
8. Information security priority raising
MISSION
VALUES
RISKS
• A general feeling of a large
accumulated technical debt
• Transparency of the sales
pipeline and current state
• Salary delays
+ Personal authority of vCISO
9. How was chosen the key asset to protect
• Discussed the importance
of focus (thanks to the Kanban
approach!)
• Inventoried the potential threat
actor groups and their interests
• Determined which assets
are most valued for them
The key asset is the
Docker image of the
supplied software
10. The threat model fragment (STRIDE approach)
Threat Desired Property Preventive control Detective Control
Spoofing Authencity Docker Content Trust DOCKER_CONTENT_TRUST = 1
Tampering Integrity SHA256 Digest Tagging ‘docker pull’ return code
Repudiation Non-Repudiability Personalized Docker Hub accounts Docker Hub Audit Logs
Information Disclosure Confidentiality No No
Denial of Service Availability Docker Hub Download Rate Limit Docker pull timeout
Elevation of Privilege Authorisation Image vulnerability check Falco runtime monitoring
Asset (object) – distributive Docker images of the supplied software
Example of Trust Service Criteria:
CC7.1 To meet its objectives, the entity uses detection and monitoring procedures to identify (1) changes to configurations that
result in the introduction of new vulnerabilities, and (2) susceptibilities to newly discovered vulnerabilities.
11. First-stage documents
• Key cybersecurity and trust principles
for XXX company
• Acceptable Use Policy
• Release Publishing Policy
• Vulnerability & Patch Management Policy
• Vulnerability Check & Triage
Procedure
• Vulnerability Remediation Procedure
• …
12. Key cybersecurity and trust principles…
…
Management Principles
• Stewardship and Accountability. Everyone is responsible for protecting the information, and individuals are held accountable.
• Risk Management. The information must not be stored without understanding and formally mitigating or accepting the risk.
• Business Ownership. All employees and independent contractors own information security. Senior managers are involved in determining
and accepting information security risks.
• Privacy. Privacy and security are not a "zero-sum game". All aspects of privacy are weighed and incorporated into security practices.
Architecture Principles
• Defense In-Depth. A system should employ multiple levels of defense such that a single breach of one sub-system does not expose
the entire system directly to an attacker.
• Least Privilege Access. A user, system, or process should only be granted the minimum set of privileges they require to perform their designated job.
• Segmentation. Sub-systems should be partitioned logically and isolated using physical devices and/or security controls.
• …
Statement of Responsibility
• CTO is a senior manager who is ultimately accountable for all information risk assessments, security strategies, planning and budgeting,
incident management, and information security implementation. CTO approves all components of the Company's ISMS and is solely accountable
for authorizing any violation of the policies, standards, and procedures of the Company's ISMS based on his reasoned judgment. CTO provides
a reasonable decision about the ISMS's scope and is solely accountable for all cybersecurity issues out of this scope.
• …
14. Key difficulties and ways to overcome
• Too many identified critical
vulnerabilities at the first launch
+ tight release deadlines
• Demonstration of Due Care
• Accepted Compromise:
• Public disclosure of the list
of open critical vulnerabilities
at the moment of new release
• CTO’s personal public commitment
• Private notification of the key
customers about open critical
vulnerabilities two weeks before
the public announce
15. Building ISMS is a marathon,
not a sprint!
https://calendly.com/vshabad
+7 777 726 4790 (cell, WhatsApp, TG)
vshabad@vshabad.com
https://linkedin.com/in/vshabad