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Chapter 1
Security Governance Through Principles and Policies
Apply Security Governance Principles
ОглавлениеSecurity governance is the collection of practices related to supporting, defining, and directing the security efforts of an organization. Security governance is closely related to and often intertwined with corporate and IT governance. The goals of these three governance agendas are often the same or interrelated. For example, a common goal of organizational governance is to ensure that the organization will continue to exist and will grow or expand over time. Thus, the common goal of governance is to maintain business processes while striving toward growth and resiliency.
Some aspects of governance are imposed on organizations due to legislative and regulatory compliance needs, whereas others are imposed by industry guidelines or license requirements. All forms of governance, including security governance, must be assessed and verified from time to time. Various requirements for auditing and validation may be present due to government regulations or industry best practices. Governance compliance issues often vary from industry to industry and from country to country. As many organizations expand and adapt to deal with a global market, governance issues become more complex. This is especially problematic when laws in different countries differ or in fact conflict. The organization as a whole should be given the direction, guidance, and tools to provide sufficient oversight and management to address threats and risks with a focus on eliminating downtime and keeping potential loss or damage to a minimum.
As you can tell, the definitions of security governance are often rather stilted and high level. Ultimately, security governance is the implementation of a security solution and a management method that are tightly interconnected. Security governance directly oversees and gets involved in all levels of security. Security is not and should not be treated as an IT issue only. Instead, security affects every aspect of an organization. It is no longer just something the IT staff can handle on their own. Security is a business operations issue. Security is an organizational process, not just something the IT geeks do behind the scenes. Using the term security governance is an attempt to emphasize this point by indicating that security needs to be managed and governed throughout the organization, not just in the IT department.
Alignment of Security Function to Strategy, Goals, Mission, and Objectives
Security management planning ensures proper creation, implementation, and enforcement of a security policy. Security management planning aligns the security functions to the strategy, goals, mission, and objectives of the organization. This includes designing and implementing security based on a business case, budget restrictions, or scarcity of resources. A business case is usually a documented argument or stated position in order to define a need to make a decision or take some form of action. To make a business case is to demonstrate a business-specific need to alter an existing process or choose an approach to a business task. A business case is often made to justify the start of a new project, especially a project related to security. It is also important to consider the budget that can be allocated to a business need–based security project. Security can be expensive, but it is often an essential element of reliable and long-term business operation. In most organizations, money and resources, such as people, technology, and space, are limited. Due to resource limitations like these, the maximum benefit needs to be obtained from any endeavor.
One of the most effective ways to tackle security management planning is to use a top-down approach. Upper, or senior, management is responsible for initiating and defining policies for the organization. Security policies provide direction for all levels of the organization’s hierarchy. It is the responsibility of middle management to flesh out the security policy into standards, baselines, guidelines, and procedures. The operational managers or security professionals must then implement the configurations prescribed in the security management documentation. Finally, the end users must comply with all the security policies of the organization.
The opposite of the top-down approach is the bottom-up approach. In a bottom-up approach environment, the IT staff makes security decisions directly without input from senior management. The bottom-up approach is rarely used in organizations and is considered problematic in the IT industry.
Security management is a responsibility of upper management, not of the IT staff, and is considered a business operations issue rather than an IT administration issue. The team or department responsible for security within an organization should be autonomous. The information security (InfoSec) team should be led by a designated chief security officer (CSO) who must report directly to senior management. Placing the autonomy of the CSO and the CSO’s team outside the typical hierarchical structure in an organization can improve security management across the entire organization. It also helps to avoid cross-department and internal political issues.
Elements of security management planning include defining security roles; prescribing how security will be managed, who will be responsible for security, and how security will be tested for effectiveness; developing security policies; performing risk analysis; and requiring security education for employees. These efforts are guided through the development of management plans.
The best security plan is useless without one key factor: approval by senior management. Without senior management’s approval of and commitment to the security policy, the policy will not succeed. It is the responsibility of the policy development team to educate senior management sufficiently so it understands the risks, liabilities, and exposures that remain even after security measures prescribed in the policy are deployed. Developing and implementing a security policy is evidence of due care and due diligence on the part of senior management. If a company does not practice due care and due diligence, managers can be held liable for negligence and held accountable for both asset and financial losses.
A security management planning team should develop three types of plans, as shown in Figure 1.3.
Figure 1.3 Strategic, tactical, and operational plan timeline comparison
Strategic Plan A strategic plan is a long-term plan that is fairly stable. It defines the organization’s security purpose. It also helps to understand security function and align it to goals, mission, and objectives of the organization. It’s useful for about five years if it is maintained and updated annually. The strategic plan also serves as the planning horizon. Long-term goals and visions for the future are discussed in a strategic plan. A strategic plan should include a risk assessment.
Tactical plan The tactical plan is a midterm plan developed to provide more details on accomplishing the goals set forth in the strategic plan or can be crafted ad-hoc based upon unpredicted events. A tactical plan is typically useful for about a year and often prescribes and schedules the tasks necessary to accomplish organizational goals. Some examples of tactical plans are project plans, acquisition plans, hiring plans, budget plans, maintenance plans, support plans, and system development plans.
Operational Plan An operational plan is a short-term, highly detailed plan based on the strategic and tactical plans. It is valid or useful only for a short time. Operational plans must be updated often (such as monthly or quarterly) to retain compliance with tactical plans. Operational plans spell out how to accomplish the various goals of the organization. They include resource allotments, budgetary requirements, staffing assignments, scheduling, and step-by-step or implementation procedures. Operational plans include details on how the implementation processes are in compliance with the organization’s security policy. Examples of operational plans are training plans, system deployment plans, and product design plans.
Security is a continuous process. Thus, the activity of security management planning may have a definitive initiation point, but its tasks and work are never fully accomplished or complete. Effective security plans focus attention on specific and achievable objectives, anticipate change and potential problems, and serve as a basis for decision making for the entire organization. Security documentation should be concrete, well defined, and clearly stated. For a security plan to be effective, it must be developed, maintained, and actually used.
Organizational Processes
Security governance needs to address every aspect of an organization. This includes the organizational processes of acquisitions, divestitures, and governance committees. Acquisitions and mergers place an organization at an increased level of risk. Such risks include inappropriate information disclosure, data loss, downtime, or failure to achieve sufficient return on investment (ROI). In addition to all the typical business and financial aspects of mergers and acquisitions, a healthy dose of security oversight and increased scrutiny is often essential to reduce the likelihood of losses during such a period of transformation.
Similarly, a divestiture or any form of asset or employee reduction is another time period of increased risk and thus increased need for focused security governance. Assets need to be sanitized to prevent data leakage. Storage media should be removed and destroyed, because media sanitization techniques do not guarantee against data remnant recovery. Employees released from duty need to be debriefed. This process is often called an exit interview. This process usually involves reviewing any nondisclosure agreements as well as any other binding contracts or agreements that will continue after employment has ceased.
Often, security governance is managed by a governance committee or at least a board of directors. This is the group of influential knowledge experts whose primary task is to oversee and guide the actions of security and operations for an organization. Security is a complex task. Organizations are often large and difficult to understand from a single viewpoint. Having a group of experts work together toward the goal of reliable security governance is a solid strategy.
Two additional examples of organizational processes that are essential to strong security governance are change control/change management and data classification.
Change Control/Management
Another important aspect of security management is the control or management of change. Change in a secure environment can introduce loopholes, overlaps, missing objects, and oversights that can lead to new vulnerabilities. The only way to maintain security in the face of change is to systematically manage change. This usually involves extensive planning, testing, logging, auditing, and monitoring of activities related to security controls and mechanisms. The records of changes to an environment are then used to identify agents of change, whether those agents are objects, subjects, programs, communication pathways, or even the network itself.
The goal of change management is to ensure that any change does not lead to reduced or compromised security. Change management is also responsible for making it possible to roll back any change to a previous secured state. Change management can be implemented on any system despite the level of security. It is a requirement for systems complying with the Information Technology Security Evaluation and Criteria (ITSEC) classifications of B2, B3, and A1. Ultimately, change management improves the security of an environment by protecting implemented security from unintentional, tangential, or affected diminishments. Although an important goal of change management is to prevent unwanted reductions in security, its primary purpose is to make all changes subject to detailed documentation and auditing and thus able to be reviewed and scrutinized by management.
Change management should be used to oversee alterations to every aspect of a system, including hardware configuration and OS and application software. Change management should be included in design, development, testing, evaluation, implementation, distribution, evolution, growth, ongoing operation, and modification. It requires a detailed inventory of every component and configuration. It also requires the collection and maintenance of complete documentation for every system component, from hardware to software and from configuration settings to security features.
The change control process of configuration or change management has several goals or requirements:
■ Implement changes in a monitored and orderly manner. Changes are always controlled.
■ A formalized testing process is included to verify that a change produces expected results.
■ All changes can be reversed (also known as backout or rollback plans/procedures).
■ Users are informed of changes before they occur to prevent loss of productivity.
■ The effects of changes are systematically analyzed.
■ The negative impact of changes on capabilities, functionality, and performance is minimized.
■ Changes are reviewed and approved by a CAB (change approval board).
One example of a change management process is a parallel run, which is a type of new system deployment testing where the new system and the old system are run in parallel. Each major or significant user process is performed on each system simultaneously to ensure that the new system supports all required business functionality that the old system supported or provided.
Data Classification
Data classification, or categorization, is the primary means by which data is protected based on its need for secrecy, sensitivity, or confidentiality. It is inefficient to treat all data the same way when designing and implementing a security system because some data items need more security than others. Securing everything at a low security level means sensitive data is easily accessible. Securing everything at a high security level is too expensive and restricts access to unclassified, noncritical data. Data classification is used to determine how much effort, money, and resources are allocated to protect the data and control access to it. Data classification, or categorization, is the process of organizing items, objects, subjects, and so on into groups, categories, or collections with similarities. These similarities could include value, cost, sensitivity, risk, vulnerability, power, privilege, possible levels of loss or damage, or need to know.
The primary objective of data classification schemes is to formalize and stratify the process of securing data based on assigned labels of importance and sensitivity. Data classification is used to provide security mechanisms for storing, processing, and transferring data. It also addresses how data is removed from a system and destroyed.
The following are benefits of using a data classification scheme:
■ It demonstrates an organization’s commitment to protecting valuable resources and assets.
■ It assists in identifying those assets that are most critical or valuable to the organization.
■ It lends credence to the selection of protection mechanisms.
■ It is often required for regulatory compliance or legal restrictions.
■ It helps to define access levels, types of authorized uses, and parameters for declassification and/or destruction of resources that are no longer valuable.
■ It helps with data life-cycle management which in part is the storage length (retention), usage, and destruction of the data.
The criteria by which data is classified vary based on the organization performing the classification. However, you can glean numerous generalities from common or standardized classification systems:
■ Usefulness of the data
■ Timeliness of the data
■ Value or cost of the data
■ Maturity or age of the data
■ Lifetime of the data (or when it expires)
■ Association with personnel
■ Data disclosure damage assessment (that is, how the disclosure of the data would affect the organization)
■ Data modification damage assessment (that is, how the modification of the data would affect the organization)
■ National security implications of the data
■ Authorized access to the data (that is, who has access to the data)
■ Restriction from the data (that is, who is restricted from the data)
■ Maintenance and monitoring of the data (that is, who should maintain and monitor the data)
■ Storage of the data
Using whatever criteria is appropriate for the organization, data is evaluated, and an appropriate data classification label is assigned to it. In some cases, the label is added to the data object. In other cases, labeling occurs automatically when the data is placed into a storage mechanism or behind a security protection mechanism.
To implement a classification scheme, you must perform seven major steps, or phases:
1. Identify the custodian, and define their responsibilities.
2. Specify the evaluation criteria of how the information will be classified and labeled.
3. Classify and label each resource. (The owner conducts this step, but a supervisor should review it.)
4. Document any exceptions to the classification policy that are discovered, and integrate them into the evaluation criteria.
5. Select the security controls that will be applied to each classification level to provide the necessary level of protection.
6. Specify the procedures for declassifying resources and the procedures for transferring custody of a resource to an external entity.
7. Create an enterprise-wide awareness program to instruct all personnel about the classification system.
Declassification is often overlooked when designing a classification system and documenting the usage procedures. Declassification is required once an asset no longer warrants or needs the protection of its currently assigned classification or sensitivity level. In other words, if the asset were new, it would be assigned a lower sensitivity label than it currently is assigned. When assets fail to be declassified as needed, security resources are wasted, and the value and protection of the higher sensitivity levels is degraded.
The two common classification schemes are government/military classification (Figure 1.4) and commercial business/private sector classification. There are five levels of government/military classification (listed here from highest to lowest):
Figure 1.4 Levels of government/military classification
Top Secret The highest level of classification. The unauthorized disclosure of top-secret data will have drastic effects and cause grave damage to national security.
Secret Used for data of a restricted nature. The unauthorized disclosure of data classified as secret will have significant effects and cause critical damage to national security.
Confidential Used for data of a private, sensitive, proprietary, or highly valuable nature. The unauthorized disclosure of data classified as confidential will have noticeable effects and cause serious damage to national security. This classification is used for all data between secret and sensitive but unclassified classifications.
Unclassified The lowest level of classification. This is used for data that is neither sensitive nor classified. The disclosure of unclassified data does not compromise confidentiality or cause any noticeable damage.
An easy way to remember the names of the five levels of the government or military classification scheme in least secure to most secure order is with a memorization acronym: U.S. Can Stop Terrorism. Notice that the five uppercase letters represent the five named classification levels, from least secure on the left to most secure on the right (or from bottom to top in the preceding list of items).
Items labeled as confidential, secret, and top secret are collectively known as classified. Often, revealing the actual classification of data to unauthorized individuals is a violation of that data. Thus, the term classified is generally used to refer to any data that is ranked above the unclassified level. All classified data is exempt from the Freedom of Information Act as well as many other laws and regulations. The US military classification scheme is most concerned with the sensitivity of data and focuses on the protection of confidentiality (that is, the prevention of disclosure). You can roughly define each level or label of classification by the level of damage that would be caused in the event of a confidentiality violation. Data from the top-secret level would cause grave damage to national security, whereas data from the unclassified level would not cause any serious damage to national or localized security.
Commercial business/private sector classification systems can vary widely because they typically do not have to adhere to a standard or regulation. The CISSP exam focuses on four common or possible business classification levels (listed highest to lowest and shown in Figure 1.5):
Figure 1.5 Commercial business/private sector classification levels
Confidential The highest level of classification. This is used for data that is extremely sensitive and for internal use only. A significant negative impact could occur for a company if confidential data is disclosed. Sometimes the label proprietary is substituted for confidential. Sometimes proprietary data is considered a specific form of confidential information. If proprietary data is disclosed, it can have drastic effects on the competitive edge of an organization.
Private Used for data that is of a private or personal nature and intended for internal use only. A significant negative impact could occur for the company or individuals if private data is disclosed.
Confidential and private data in a commercial business/private sector classification scheme both require roughly the same level of security protection. The real difference between the two labels is that confidential data is company data whereas private data is data related to individuals, such as medical data.
Sensitive Used for data that is more classified than public data. A negative impact could occur for the company if sensitive data is disclosed.
Public The lowest level of classification. This is used for all data that does not fit in one of the higher classifications. Its disclosure does not have a serious negative impact on the organization.
Another consideration related to data classification or categorization is ownership. Ownership is the formal assignment of responsibility to an individual or group. Ownership can be made clear and distinct within an operating system where files or other types of objects can be assigned an owner. Often, an owner has full capabilities and privileges over the object they own. The ability to take ownership is often granted to the most powerful accounts in an operating system, such as the administrator in Windows or root in Unix or Linux. In most cases, the subject that creates a new object is by default the owner of that object. In some environments, the security policy mandates that when new objects are created, a formal change of ownership from end users to an administrator or management user is necessary. In this situation, the admin account can simply take ownership of the new objects.
Ownership of objects outside of formal IT structures is often not as obvious. A company document can define owners for the facility, business tasks, processes, assets, and so on. However, such documentation does not always “enforce” this ownership in the real world. The ownership of a file object is enforced by the operating system and file system, whereas ownership of a physical object, intangible asset, or organizational concept (such as the research department or a development project) is defined only on paper and can be more easily undermined. Additional security governance must be implemented to provide enforcement of ownership in the physical world.
Security Roles and Responsibilities
A security role is the part an individual plays in the overall scheme of security implementation and administration within an organization. Security roles are not necessarily prescribed in job descriptions because they are not always distinct or static. Familiarity with security roles will help in establishing a communications and support structure within an organization. This structure will enable the deployment and enforcement of the security policy. The following six roles are presented in the logical order in which they appear in a secured environment:
Senior Manager The organizational owner (senior manager) role is assigned to the person who is ultimately responsible for the security maintained by an organization and who should be most concerned about the protection of its assets. The senior manager must sign off on all policy issues. In fact, all activities must be approved by and signed off on by the senior manager before they can be carried out. There is no effective security policy if the senior manager does not authorize and support it. The senior manager’s endorsement of the security policy indicates the accepted ownership of the implemented security within the organization. The senior manager is the person who will be held liable for the overall success or failure of a security solution and is responsible for exercising due care and due diligence in establishing security for an organization.
Even though senior managers are ultimately responsible for security, they rarely implement security solutions. In most cases, that responsibility is delegated to security professionals within the organization.
Security Professional The security professional, information security (InfoSec) officer, or computer incident response team (CIRT) role is assigned to a trained and experienced network, systems, and security engineer who is responsible for following the directives mandated by senior management. The security professional has the functional responsibility for security, including writing the security policy and implementing it. The role of security professional can be labeled as an IS/IT function role. The security professional role is often filled by a team that is responsible for designing and implementing security solutions based on the approved security policy. Security professionals are not decision makers; they are implementers. All decisions must be left to the senior manager.
Data Owner The data owner role is assigned to the person who is responsible for classifying information for placement and protection within the security solution. The data owner is typically a high-level manager who is ultimately responsible for data protection. However, the data owner usually delegates the responsibility of the actual data management tasks to a data custodian.
Data Custodian The data custodian role is assigned to the user who is responsible for the tasks of implementing the prescribed protection defined by the security policy and senior management. The data custodian performs all activities necessary to provide adequate protection for the CIA Triad (confidentiality, integrity, and availability) of data and to fulfill the requirements and responsibilities delegated from upper management. These activities can include performing and testing backups, validating data integrity, deploying security solutions, and managing data storage based on classification.
User The user (end user or operator) role is assigned to any person who has access to the secured system. A user’s access is tied to their work tasks and is limited so they have only enough access to perform the tasks necessary for their job position (the principle of least privilege). Users are responsible for understanding and upholding the security policy of an organization by following prescribed operational procedures and operating within defined security parameters.
Auditor An auditor is responsible for reviewing and verifying that the security policy is properly implemented and the derived security solutions are adequate. The auditor role may be assigned to a security professional or a trained user. The auditor produces compliance and effectiveness reports that are reviewed by the senior manager. Issues discovered through these reports are transformed into new directives assigned by the senior manager to security professionals or data custodians. However, the auditor is listed as the last or final role because the auditor needs a source of activity (that is, users or operators working in an environment) to audit or monitor.
All of these roles serve an important function within a secured environment. They are useful for identifying liability and responsibility as well as for identifying the hierarchical management and delegation scheme.
Control Frameworks
Crafting a security stance for an organization often involves a lot more than just writing down a few lofty ideals. In most cases, a significant amount of planning goes into developing a solid security policy. Many Dilbert fans may recognize the seemingly absurd concept of holding a meeting to plan a meeting for a future meeting. But it turns out that planning for security must start with planning to plan, then move into planning for standards and compliance, and finally move into the actual plan development and design. Skipping any of these “planning to plan” steps can derail an organization’s security solution before it even gets started.
One of the first and most important security planning steps is to consider the overall control framework or structure of the security solution desired by the organization. You can choose from several options in regard to security concept infrastructure; however, the one covered on the CISSP exam is Control Objectives for Information and Related Technology (COBIT). COBIT is a documented set of best IT security practices crafted by the Information Systems Audit and Control Association (ISACA). It prescribes goals and requirements for security controls and encourages the mapping of IT security ideals to business objectives. COBIT 5 is based on five key principles for governance and management of enterprise IT: Principle 1: Meeting Stakeholder Needs, Principle 2: Covering the Enterprise End-to-End, Principle 3: Applying a Single, Integrated Framework, Principle 4: Enabling a Holistic Approach, and Principle 5: Separating Governance From Management. COBIT is used not only to plan the IT security of an organization but also as a guideline for auditors.
Fortunately, COBIT is only modestly referenced on the exam, so further details are not necessary. However, if you have interest in this concept, please visit the ISACA website (www.isaca.org), or if you want a general overview, read the COBIT entry on Wikipedia.
There are many other standards and guidelines for IT security. A few of these are Open Source Security Testing Methodology Manual (OSSTMM), ISO/IEC 27002 (which replaced ISO 17799), and the Information Technology Infrastructure Library (ITIL) (see www.itlibrary.org for more information).
Due Care and Due Diligence
Why is planning to plan security so important? One reason is the requirement for due care and due diligence. Due care is using reasonable care to protect the interests of an organization. Due diligence is practicing the activities that maintain the due care effort. For example, due care is developing a formalized security structure containing a security policy, standards, baselines, guidelines, and procedures. Due diligence is the continued application of this security structure onto the IT infrastructure of an organization. Operational security is the ongoing maintenance of continued due care and due diligence by all responsible parties within an organization.
In today’s business environment, prudence is mandatory. Showing due care and due diligence is the only way to disprove negligence in an occurrence of loss. Senior management must show due care and due diligence to reduce their culpability and liability when a loss occurs.