Confidentiality Information Assurance Policy 95 803 Danny Lungstrom

Confidentiality Information Assurance Policy (95 -803) Danny Lungstrom Senthil Somasundaram 03/27/2006

Overview of Security Goals of IT Security – CIA Triad Confidentiality Integrity Availability

CIA Triad Confidentiality Secure Integrity Availability Ref: Security In Computing - Charles Pfleeger

Confidentiality Defined Confidentiality ensures that computer-related assets are accessed only by authorized parties. That is, only those who should have access to something will actually get that access. Access means not only reading but includes viewing, printing (or) simply knowing that a particular asset exists. Also known sometime as secrecy (or) privacy. Ref: Security In Computing - Charles Pfleeger

Risks Types Of Risk Legal Risks Financial Risks Loss of trust Operational Risks Numerous costs involved including losing customer's trust, legal fees, fines Reputational Risks Fines, liability lawsuits, criminal prosecution Failed internal processes – insider trading, unethical practices, etc. Strategic Risks Financial institutions future, mergers, etc.

Threats to Confidentiality Access to confidential information by any unauthorized person Intercepted data transfers Physical loss of data Privileged access of confidential information by employees Social engineered methods to gain confidential information Unauthorized access to physical records Transfer of confidential information to unauthorized third parties Compromised machine where attacker is able to access data thought to be secure

Threats in the Case Study • • Scheduling information regarding national level speakers/sensitive private meetings highly restricted Concerns over unauthorized access as a result of leaks – includes leaks to press as well as opposition/protest groups Concerns over “leaks” via IT from opposition groups within the national organization Loss of trust in decisions made at event – Can include public exposure of sensitive data Loss of privacy, yielding decreased impact on event, decreased participation with organization – Individuals of prominence can lose privacy – can include a physical security risk (schedules, timetables, etc. ) – Such a loss may not directly impact event – impact delayed – Can result in loss of Sponsorship, financial support, public perception of competence

Threats from Case Study Common theme: leaking private data Strict access controls are crucial to protecting the confidential information Those who should have access to the confidential information should be clearly defined These people must sign a very clear confidentiality agreement Should understand importance of keeping the information private

Financial Importance Financial losses due to loss of trade secrets According to Computer Security Institute's 6 th “Computer Crime and Security Survey” “the most serious financial losses occurred through theft of proprietary information” 34 respondents reported losses of $151, 230, 100 That's $4. 5 million per company in 1 year!!!

Trade Secrets As name implies, must be kept secret No registration/approval or standard procedure Somewhat protected if company takes measures to ensure its privacy Quick and easy No formal process, just ensure only those that should know about it do Limited protection Not protected against reverse engineering or obtaining the secret by “honest” means

Trade Secrets (2) Why trade secrets? Filing for a patent makes the information public Quick How to protect Enforce confidentiality agreements Label all information as “Confidential” for the courts How long do trade secrets remain secret? Average is 4 to 5 years Expected to decrease in the future with advancements in reverse engineering processes

Best Kept Trade Secrets Coca-cola Coca-Cola decided to keep its formula secret, decades ago! Only known to a few people within the company Stored in the vault of a bank in Atlanta The few that know the formula have signed very explicit confidentiality agreements Rumor has it, those that know the formula are not allowed to travel together If Coca-cola instead patented the syrup formula, everyone could be making it today KFC's 11 secret herbs and spices

Phishing Scams Tricking people into providing malicious users with their private/financial information Financial losses to consumers: $500 million to $2. 4 billion per year depending on source 15 percent of people that have visited a spoofed website have parted with private/personal data, much of the time including credit card, checking account, and social security numbers

Phising Example

Help Protect Yourself Don't use links from emails for sites where personal/financial information is to be disclosed Browse to the website yourself Use spam filtering to avoid much of the mess Check for HTTPS and a padlock on bottom bar Don't solely rely on Educate yourself about the risks! Check your credit report periodically

Legal Requirements HIPAA Gramm-Leach Bliley FERPA Confidentiality/Non-disclosure Agreements ISP/Google subpoenaed examples

HIPAA Numerous regulations on access to a person's health information Ensure patient access to records Allow them to modify inaccuracies Written consent required to disclose records Ensure not used for non-medical purposes (job screening, loans, insurance) Proper employee training on respecting confidentiality of patients

What HIPAA Doesn't Do Does not restrict what info can be collected, person just has to be informed Doesn't require extremely high levels of privacy during medical visits, just reasonable Some sort of barrier (curtains) No public conversations Secure documents No post-it note passwords

Gramm-Leach Bliley Act Protection for consumer's personal financial information All financial institutions must have a policy in place that identifies how information will be protected Must also identify foreseeable threats in security and data integrity

Gramm-Leach Bliley Act (2) Financial Privacy rule Institution must inform individuals as to any information collected, the purpose of the collection, and what is going to be done with it The individual may refuse Safeguards rule Security policy portion of act, as described earlier Pretexting Protection (social-engineering) Institutions must take measures to protect against social-engineering, phishing, etc.

FERPA Family Educational Rights and Privacy Act Instructor regulations Cannot provide a child's grade to anyone other than child/parent (no websites) Cannot share info on child's behavior at school except to parents Cannot share info on child's homelife Child's instructor must do the grading, not a volunteer or someone else

ISPs Subpoenaed What rights do ISP subscribers have to confidentiality? ISPs being forced to turn over names Verizon vs. RIAA User vs. Comcast Verizon won the appeal Comcast gets sued from both ends RIAA vs. Grandma 83 year old Gertrude – shared over 700 rock/rap songs, but. . . RIAA decides to drop case. . . Blames time it takes to get user info

Do. J vs. User Privacy COPA (Children's Online Protection Act) Do. J subpeonaed nearly all major ISPs and search engines Search engines required to turn over searches Google says this could link back to specific users demanded production of "[a]ll queries that have been entered on [Google's] search engine between June 1, 2005 and July 31, 2005"

Google vs. Do. J Is Google only pretending to care? Only fighting the subpoenas in order to better reputation with the public? “Google's on our side” But, they mine an enormous amount of data on anyone that uses any of their services Protecting their own trade secrets

Bigger Problem These enormous databases exist Choice. Point forced to pay $15 million by FTC 163, 000 consumer's information stolen from their database If anyone gets ahold of any portion of these databases, they have an unimaginable wealth of private information on an endless amount of people Names, SSNs, credit history, employment history, etc. Led to at least 800 cases of identity theft http: //www. privacyrights. org/ar/Chron. Data. Breaches. htm

Giant Eagle Example Giant Eagle's Loyalty Program Nearly 4 million active users in 2005 User's purchases at both the grocery store and gas station are knowingly monitored, but still 4 million think the invasion of privacy is worth the savings Can even link the card to fuel perks, enable check cashing and video rental service! Also use card at 4, 000 hotels, Avis, Hertz, Alamo, numerous local retailers, sporting events, museums, zoos, ballets, operas, etc. Basically as much info as you're willing to give them they'll take. . . and use for what else?

Giant Eagle (2) From the privacy policy: Giant Eagle does not share your personal information or purchase information with anyone except: As necessary to enable us to offer you savings on products or services; or As necessary to complete a transaction initiated by you through the use of your card;

Writing Policies Ask numerous questions before beginning What information is confidential? Who should be allowed to access this information? Longer the time frame, the harder to keep confidential What type of security policy is needed? Create a list and have them sign confidentiality agreements How long is it to remain confidential? The broader the definition the better (for the discloser) What sort of organization is it for? What level of confidentiality is necessary for the given organization?

Further Risk Assessment Basic questions: Who, what, when, where, why, how? Who? Who should have access, who shouldn't Ensure they must properly authenticate in order to access information, so that “who” is ensured non-repudiation

Further Risk Assessment (2) What? When? What needs to be kept confidential? How long must it remain secure? Where? Where is this confidential data going to be safely stored? File server, workstation, removable media, laptop, etc.

Further Risk Assessment (3) Why? Law FERPA, HIPAA, etc. Specified in end-user agreement User trust How? What means are to be used to ensure it's protection? Access controls, encryption, physical barriers, etc.

Types of Security Policies Military Security (governmental) Policy Commercial Security Policies Clark-Wilson Commercial Security Policy (Integrity) Separation of Duty (Integrity) Chinese Wall Security Policy (Confidentiality)

Military/Government Security Policies Goal: Protect private information Uses ranking system on levels of confidentiality Need-to-know rule Compartmentalized Combination of (rank; compartment) is its classification Clearances are required for different levels of classification Access based on dominance Combination of sensitivity and need-to-know requirements

Information Sensitivity Ranking Most Sensitive Top Secret Compartment 1 Compartment 2 Secret Confidential Restricted Top Secret Unclassified Secret Confidential Compartment 3 Least Sensitive Restricted Unclassified Ref: Security In Computing - Charles Pfleeger

Commercial Security Policies Less rigid and hierarchical No universal hierarchy Varying degree of sensitivity E. g. Public, Proprietary and Internal No formal concept of clearance Access not based on dominance, as there are no clearances

Chinese Wall Policy Conflicts of interest Effects those in legal, medical, investment, accounting firms Person in one company having access to confidential information in a competing company Based on three levels for abstract groups Objects Company Groups Files Collection of files Conflict Classes Company groups with competing interests

Chinese Wall Policy (2) Access control policy Individual may access any information, given that (s)he has never accessed any information from another company in the same conflict class So, once individual has accessed any object in a given conflict group, they are from then on restricted to only that company group within the conflict group, the rest are off-limits

Chinese Wall Illustrated Company A Company B Company C Company D Company E Company F Initially Company A Company B Company C Company F Company D Company E After choosing B and D Ref: Security In Computing - Charles Pfleeger

Writing the CA After considering these various questions, it is time to actually write the policy Contents should include: Obligation of confidentiality Restrictions on the use of confidential information Limitations on access to the confidential information Explicit notification as to what is confidential These things should all be considered when writing the policy for the case study

Access controls Locking down an OS Principle of Least Privilege Password Management User policies what if someone calls and needs password anti-social engineering

OS Lockdown Step 1 Identify protection needed for various files/objs Separate information/data into categories and decide who needs what type of access to it Distinguish between local and remote access Step 2 Create associated user groups Groups derived from first step above Simply create these groups and assign appropriate members

OS Lockdown (2) Step 3 Setup access controls General practices Deny as much as possible Disable write/modify access to any executables Restrict access to OS source/configuration files to admin Only allow appends to log files Analyze access control inheritance UNIX/Linux specific No world-writable files Mount file system as read-only Disable suid Make kernel files immutable

OS Lockdown (3) Step 4 Install/configure encryption capabilities Depending on how confidential information is, either use OS encryption or add 3 rd party software to do the job Necessary if OS access controls are not overly configurable Step 5 Continue to monitor! Make sure things are as expected Source: CERT. org

Database Access Databases often house an enormous amount of desired data about people (CC#s, SSNs, etc. ) Must pay special attention to access Defense in depth Only allow specific users access Encrypt information in database Encrypt information in transfer Limit these users as much as possible IPSec, SSL, TLS Patch!

Password Policies Confidential information is protected by some means of authentication, often passwords How confidential the password protected information is depends on the strength of the password used Tips: Not dictionary based More than 8 characters (the more the merrier) Combination of letters, numbers, and special chars Not related to user Not related to login name Don't reuse the same password for all accounts!

Encryption for Confidentiality When to use Anytime you wouldn't want anyone/everyone to see what you're doing Various solutions Financial transactions Personal e-mails Anything confidential PGP, S/MIME, PKI, Open. VPN, SSH, SFTP, etc. Drawbacks/difficulties May not be allowed Not always user friendly Not what used to

Regulated Encryption Should their be more stringent guidelines for using various encryption techniques? Many in gov't said yes after 9/11 and pushed for reform Senator Judd Gregg pushed to require that the gov't be given the keys to decrypt everyone's messages if necessary Much debate, as terrorist may encrypt messages, and not even NSA can decrypt (so they say) Would this help? Would the terrorists use encryption methods that the gov't could decrypt and would they provide them with keys? Or is this just a privacy invasion for all non-terrorists?

Email Policy Popular encryption methods PGP Entrust Hushmail S/MIME Should employees be allowed to encrypt messages at work? May want to secure confidential business trade secrets or other work-related data Would you want work related info sent out on a postcard? May just want to email friends and not be monitored

Email Policy Clearly define proper use of e-mail at work What is allowed and what is not State any monitoring activity in confidentiality notice – ensure users know they are being monitored if they are Specify authorized software that can be used for e-mail Disallow running executable files received as attachments Could allow for further breaches Define e-mail retention policy

Network policies Separate servers based on services and levels of confidentiality required A public file server or database should not also house confidential information Case study: Various services needed Separate confidential from public Separate by which groups are to be allowed access

Event Network Operations (8 -9 Servers, ~200 PCs) Organization (10+ Servers, ~400 PCs) Financial Human Resources Contracting Communications Public Relations Network Operations Podium Scheduling Voting Communications Sponsor Access Participant Access Venue Internet Media Source: 95 -803 course slides

Break Time! Josh was supposed to bake cookies, but he misplaced his apron - sorry

Confidentiality • • • Device and Media Control Backups Physical Security Personnel Security Outsourcing/Service Providers Incident Response

Device & Media Control • Device and Media Control Ref: www. securewave. com

Device & Media – Issues • What are the issues? – – Growing Pain!!! Number of devices on the raise Increased security risk Technology race for faster, smaller, cheaper and higher capacity devices • Less than 5 minutes to copy 60 GB data • 2 GB memory can hold up to 400, 000 pages – Devices are cheap but the information may be expensive

Risks

Privacy Vs Security

Smart Phones

Policy – Device & Media • Define a device and media control policy • What to consider? – Ban the use of all mobile media? – Governing may be more practical then prohibiting the mobile devices – Identify and list authorized devices/media – Define their acceptable method of usage – Keep track of devices connected to your network – Associate devices to valid users

Policy – Device & Media(2) • What to consider? – – Password protection on all mobile devices Disallow storing of sensitive information on mobile devices Encryption Govern the use of personal devices on corporate environment – Take into account the convergence of data and telecom – Train and educate your employees on protection of devices and media

Device & Media Disposal • Define a policy for device & media disposal – Ensure complete sanitization before the equipment/media is re-used (or) disposed – Provide guidelines on standard for media sanitization – Monitor media disposal by third party – NIST guidelines for media sanitization http: //csrc. nist. gov/publications/drafts/DRAFT-sp 800 -88 -Feb 3_2006. pdf

Case Study Options (1) • Device & Media Control Policy Options – Classify the information to be protected – Prohibit copying classified confidential information to mobile devices including laptops/PDA/USB storage etc – Provide printing/e-mailing/download options only for nonconfidential data – Enforce encryption of data on all storage media – Identify and specify authorized type of devices that can be connected to network

Case Study Options (2) • Device & Media Control Policy Options – Require wireless devices be registered before getting connected to the network – Disable any direct external mobile device attachments to network with highly confidential information – Provide only dump terminals for public/media access so that no external devices can be attached to network – Ban use of cell phones during private sessions

Backups • Backups security often overlooked • Why are they important? – Due to concentration of data the degree of confidentiality is as high as original data – Confidentiality requirements for information apply to backed up data – HIPAA requires compliance methodologies for backups also. – Archives/Business History

Backups (2) • Security factors – – Storage of backup data Transfer of backup data Security of networks used to backup data Software & Media

Backups – Policy (1) • What to consider? – – – Procedure for backups Allowable software and storage media Encryption of confidential data Guidelines for storage Guidelines to protect the documents with information about backups – encryption keys, location etc… – Patches for backup software

Backups – Policy (2) • What to consider? – – – Inventory Testing Security of networks used for backups Garbage collection of obsolete backups Sanitization of backup media before disposal Transportation methods • Procedures http: //csrc. nist. gov/fasp/FASPDocs/contingency-plan/Backup-And. Recovery. pdf

Physical Security • Why is it required? – – First line of defense preventing loss of confidentiality Physical attacks requires minimal effort Protects information assets from unauthorized access All security policy enforcements will be a non-factor without physical security – Security lapses increases risk of both insider and outsider attacks – Protects confidential information assets from natural and environmental hazards

Physical Security (2) • Privacy Vs Security • Appropriate levels • What can we do? – Consider multilayer security approach – Environment of authorized personnel only – Physical barriers like fence, guards, alarms and surveillance video etc. . – Maintain an inventory of computer hardware and label them for identification – Limit access to your hardware

Physical Security (3) • What can we do? – Deploy your servers with confidential information only in physically secure locations – Restrict physical access to your information assets by third parties. – Document visit procedures and method of access for third parties – Conduct periodical physical security audits for compliance – Enforce security practices to prevent dumpster diving – National Industry Security Program Operating Manual – NISPOM http: //www. fas. org/sgp/library/nispom 2006. pdf

Insider Threat

Personnel Security • Importance? – Insider threats are real – Employee security practices play a vital role in protecting confidential information • What to consider? – Employment terms needs to include role and responsibility of employee in protecting confidential information – Employment terms must state penalties for violation – Carry out background checks – Training on security – Training on protection of trade secrets and intellectual property rights – Employees are also part of corporate assets – Protect and safeguard employees

Outsourcing • Confidentiality Issues – – Reduction in cost but increases risk Dependence on service providers Can the vendors be trusted with handling confidential data? Vendors may be handling data and dealing with information systems of competing companies – Offshore – Can US regulations be enforced on third world countries? – Non-disclosure agreements in offshore projects – Can all institutions outsource?

Outsourcing (2) • Mitigation of Risks – Define goals, scope and risks – Assess information risk Vs benefits – Evaluate service provider’s capability to handle confidential information – Determine contractors ability to comply with security requirements – BITS – IT Service Provider Service Expectations Matrix http: //www. bitsinfo. org/downloads/Publications%20 Page/bitsxmatrix 2004. xls

Outsourcing (3) • Evaluate Service Providers (BITS Method) – – – – – Security Policy Organizational Security Asset Classification & Control Personnel Security Physical & Environment Security Communications and Ops Management Systems Development and Maintenance Business Continuity Regulatory Compliance Ref: www. bitsinfo. org

Outsourcing (4) • Privacy and Confidentiality Considerations – Review privacy policy of the service provider for adequacy – Understand how the policy is implemented and communicated – Review privacy policy employee training and tracking – Review service providers employee confidentiality agreements – Review service provider policy for employee privacy policy violations Ref: www. bitsinfo. org

Outsourcing (5) • Privacy and Confidentiality Considerations – Review adequacy of privacy for service providers contract staff – Review procedures to retain, protect and destroy non-public information – Access service providers diligence in legal, regulatory and compliance areas – Comparing the company’s privacy policy with service providers policy and identifying gaps – More http: //www. bitsinfo. org/downloads/Publications%20 Page/bits 2003 framework. pdf Ref: www. bitsinfo. org

Options For Case Study • Service Provider Policy Considerations – Evaluate the vendors privacy policy including the venue of the event for adequacy – Require vendors to prove compliance before the finalization of contract – Have all third parties/vendors sign NDA – Ensure through background checks before hiring contract staff for the event – Include all confidentiality agreements in contract and severe penalty clause for lapses

Incident Response (1) • Purpose? – Effective and quick response necessary to limit the damage – Regulations calls for corporate incident policies and procedures – Policy and plan required to assess the damage and respond appropriately – Plan for recovery from the damage and business continuity – Improves your chances of survival after breach

Incident Response (2) • Policy Considerations – – – – Define incident reporting and handling work flow Identify incident handlers and their responsibilities Educate and train your employees on incident reporting Legal Compliance Procedures to contact law enforcement Evidence collection CERT Handbook http: //www. sei. cmu. edu/publications/documents/03. reports/03 hb 002. html

Trust • Reason? – – – Confidentiality relies highly on trust Employer trusts employee Employer trusts service providers Trust hardware Trust software • Is it sufficient? – Trust but deploy controls/procedures to validate trust

Conclusion • • • Confidentiality – Not optional!! Legal and regulatory compliance Secure all the doors to confidential information Policy and controls will provide relative security Policy and controls will improve chances of survival No Guarantee!!!

Questions