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Chapter 2
Personnel Security and Risk Management Concepts
Contribute to Personnel Security Policies
ОглавлениеHumans are the weakest element in any security solution. No matter what physical or logical controls are deployed, humans can discover ways to avoid them, circumvent or subvert them, or disable them. Thus, it is important to take into account the humanity of your users when designing and deploying security solutions for your environment. To understand and apply security governance, you must address the weakest link in your security chain – namely, people.
Issues, problems, and compromises related to humans occur at all stages of a security solution development. This is because humans are involved throughout the development, deployment, and ongoing administration of any solution. Therefore, you must evaluate the effect users, designers, programmers, developers, managers, and implementers have on the process.
Hiring new staff typically involves several distinct steps: creating a job description, setting a classification for the job, screening employment candidates, and hiring and training the one best suited for the job. Without a job description, there is no consensus on what type of individual should be hired. Thus, crafting job descriptions is the first step in defining security needs related to personnel and being able to seek out new hires. Personnel should be added to an organization because there is a need for their specific skills and experience. Any job description for any position within an organization should address relevant security issues. You must consider items such as whether the position requires the handling of sensitive material or access to classified information. In effect, the job description defines the roles to which an employee needs to be assigned to perform their work tasks. The job description should define the type and extent of access the position requires on the secured network. Once these issues have been resolved, assigning a security classification to the job description is fairly standard.
The Importance of Job Descriptions
Job descriptions are important to the design and support of a security solution. However, many organizations either have overlooked this or have allowed job descriptions to become stale and out-of-sync with reality. Try to track down your job description. Do you even have one? If so, when was it last updated? Does it accurately reflect your job? Does it describe the type of security access you need to perform the prescribed job responsibilities? Some organizations must craft job descriptions to be in compliance with SOC-2, while others following ISO 27001 require annual reviews of job descriptions.
Important elements in constructing job descriptions that are in line with organizational processes include separation of duties, job responsibilities, and job rotation.
Separation of Duties Separation of duties is the security concept in which critical, significant, and sensitive work tasks are divided among several individual administrators or high-level operators (Figure 2.1). This prevents any one person from having the ability to undermine or subvert vital security mechanisms. Think of separation of duties as the application of the principle of least privilege to administrators. Separation of duties is also a protection against collusion, which is the occurrence of negative activity undertaken by two or more people, often for the purposes of fraud, theft, or espionage.
Figure 2.1 An example of separation of duties related to five admin tasks and seven administrators
Job Responsibilities Job responsibilities are the specific work tasks an employee is required to perform on a regular basis. Depending on their responsibilities, employees require access to various objects, resources, and services. On a secured network, users must be granted access privileges for those elements related to their work tasks. To maintain the greatest security, access should be assigned according to the principle of least privilege. The principle of least privilege states that in a secured environment, users should be granted the minimum amount of access necessary for them to complete their required work tasks or job responsibilities. True application of this principle requires low-level granular access control over all resources and functions.
Job Rotation Job rotation, or rotating employees among multiple job positions, is simply a means by which an organization improves its overall security (Figure 2.2). Job rotation serves two functions. First, it provides a type of knowledge redundancy. When multiple employees are all capable of performing the work tasks required by several job positions, the organization is less likely to experience serious downtime or loss in productivity if an illness or other incident keeps one or more employees out of work for an extended period of time.
Figure 2.2 An example of job rotation among management positions
Second, moving personnel around reduces the risk of fraud, data modification, theft, sabotage, and misuse of information. The longer a person works in a specific position, the more likely they are to be assigned additional work tasks and thus expand their privileges and access. As a person becomes increasingly familiar with their work tasks, they may abuse their privileges for personal gain or malice. If misuse or abuse is committed by one employee, it will be easier to detect by another employee who knows the job position and work responsibilities. Therefore, job rotation also provides a form of peer auditing and protects against collusion.
Cross-training
Cross-training is often discussed as an alternative to job rotation. In both cases, workers learn the responsibilities and tasks of multiple job positions. However, in cross-training the workers are just prepared to perform the other job positions; they are not rotated through them on a regular basis. Cross-training enables existing personnel to fill the work gap when the proper employee is unavailable as a type of emergency response procedure.
When several people work together to perpetrate a crime, it’s called collusion. Employing the principles of separation of duties, restricted job responsibilities, and job rotation reduces the likelihood that a co-worker will be willing to collaborate on an illegal or abusive scheme because of the higher risk of detection. Collusion and other privilege abuses can be reduced through strict monitoring of special privileges, such as those of an administrator, backup operator, user manager, and others.
Job descriptions are not used exclusively for the hiring process; they should be maintained throughout the life of the organization. Only through detailed job descriptions can a comparison be made between what a person should be responsible for and what they actually are responsible for. It is a managerial task to ensure that job descriptions overlap as little as possible and that one worker’s responsibilities do not drift or encroach on those of another. Likewise, managers should audit privilege assignments to ensure that workers do not obtain access that is not strictly required for them to accomplish their work tasks.
Employment Candidate Screening
Employment candidate screening for a specific position is based on the sensitivity and classification defined by the job description. The sensitivity and classification of a specific position is dependent on the level of harm that could be caused by accidental or intentional violations of security by a person in the position. Thus, the thoroughness of the screening process should reflect the security of the position to be filled.
Employment candidate screening, background checks, reference checks, education verification, and security clearance validation are essential elements in proving that a candidate is adequate, qualified, and trustworthy for a secured position. Background checks include obtaining a candidate’s work and educational history; reference checks; education verification; interviewing colleagues, neighbors, and friends; checking police and government records for arrests or illegal activities; verifying identity through fingerprints, driver’s license, and birth certificate; and holding a personal interview. This process could also include a polygraph test, drug testing, and personality testing/evaluation.
Performing online background checks and reviewing the social networking accounts of applicants has become standard practice for many organizations. If a potential employee has posted inappropriate materials to their photo sharing site, social networking biographies, or public instant messaging services, then they are not as attractive a candidate as those who did not. Our actions in the public eye become permanent when they are recorded in text, photo, or video and then posted online. A general picture of a person’s attitude, intelligence, loyalty, common sense, diligence, honesty, respect, consistency, and adherence to social norms and/or corporate culture can be gleaned quickly by viewing a person’s online identity.
Employment Agreements and Policies
When a new employee is hired, they should sign an employment agreement. Such a document outlines the rules and restrictions of the organization, the security policy, the acceptable use and activities policies, details of the job description, violations and consequences, and the length of time the position is to be filled by the employee. These items might be separate documents. In such a case, the employment agreement is used to verify that the employment candidate has read and understood the associated documentation for their prospective job position.
In addition to employment agreements, there may be other security-related documentation that must be addressed. One common document is a nondisclosure agreement (NDA). An NDA is used to protect the confidential information within an organization from being disclosed by a former employee. When a person signs an NDA, they agree not to disclose any information that is defined as confidential to anyone outside the organization. Violations of an NDA are often met with strict penalties.
NCA: The NDA’s Evil Twin
The NDA has a common companion contract known as the noncompete agreement (NCA). The noncompete agreement attempts to prevent an employee with special knowledge of secrets from one organization from working in a competing organization in order to prevent that second organization from benefiting from the worker’s special knowledge of secrets. NCAs are also used to prevent workers from jumping from one company to another competing company just because of salary increases or other incentives. Often NCAs have a time limit, such as six months, one year, or even three years. The goal is to allow the original company to maintain its competitive edge by keeping its human resources working for its benefit rather than against it.
Many companies require new hires to sign NCAs. However, fully enforcing an NCA in court is often a difficult battle. The court recognizes the need for a worker to be able to work using the skills and knowledge they have in order to provide for themselves and their families. If the NCA would prevent a person from earning a reasonable income, the courts often invalidate the NCA or prevent its consequences from being realized.
Even if an NCA is not always enforceable in court, however, that does not mean it doesn’t have benefits to the original company, such as the following:
■ The threat of a lawsuit because of NCA violations is often sufficient incentive to prevent a worker from violating the terms of secrecy when they seek employment with a new company.
■ If a worker does violate the terms of the NCA, then even without specifically defined consequences being levied by court restrictions, the time and effort, not to mention the cost, of battling the issue in court is a deterrent.
Did you sign an NCA when you were hired? If so, do you know the terms and the potential consequences if you break that NCA?
Throughout the employment lifetime of personnel, managers should regularly audit the job descriptions, work tasks, privileges, and responsibilities for every staff member. It is common for work tasks and privileges to drift over time. This can cause some tasks to be overlooked and others to be performed multiple times. Drifting can also result in security violations. Regularly reviewing the boundaries of each job description in relation to what is actually occurring aids in keeping security violations to a minimum.
A key part of this review process is enforcing mandatory vacations. In many secured environments, mandatory vacations of one to two weeks are used to audit and verify the work tasks and privileges of employees. The vacation removes the employee from the work environment and places a different worker in their position, which makes it easier to detect abuse, fraud, or negligence on the part of the original employee.
Employment Termination Processes
When an employee must be terminated, numerous issues must be addressed. A strong relationship between the security department and HR is essential to maintain control and minimize risks during termination. An employee termination process or procedure policy is essential to maintaining a secure environment when a disgruntled employee must be removed from the organization. The reactions of terminated employees can range from calm, understanding acceptance to violent, destructive rage. A sensible procedure for handling terminations must be designed and implemented to reduce incidents.
The termination of an employee should be handled in a private and respectful manner. However, this does not mean that precautions should not be taken. Terminations should take place with at least one witness, preferably a higher-level manager and/or a security guard. Once the employee has been informed of their release, they should be escorted off the premises and not allowed to return to their work area without an escort for any reason. Before the employee is released, all organization-specific identification, access, or security badges as well as cards, keys, and access tokens should be collected (Figure 2.3). Generally, the best time to terminate an employee is at the end of their shift midweek. A early to midweek termination provides the ex-employee with time to file for unemployment and/or start looking for new employment before the weekend. Also, end-of-shift terminations allow the worker to leave with other employees in a more natural departure, thus reducing stress.
Figure 2.3 Ex-employees must return all company property.
When possible, an exit interview should be performed. However, this typically depends on the mental state of the employee upon release and numerous other factors. If an exit interview is unfeasible immediately upon termination, it should be conducted as soon as possible. The primary purpose of the exit interview is to review the liabilities and restrictions placed on the former employee based on the employment agreement, nondisclosure agreement, and any other security-related documentation.
The following list includes some other issues that should be handled as soon as possible:
■ Make sure the employee returns any organizational equipment or supplies from their vehicle or home.
■ Remove or disable the employee’s network user account.
■ Notify human resources to issue a final paycheck, pay any unused vacation time, and terminate benefit coverage.
■ Arrange for a member of the security department to accompany the released employee while they gather their personal belongings from the work area.
■ Inform all security personnel and anyone else who watches or monitors any entrance point to ensure that the ex-employee does not attempt to reenter the building without an escort.
In most cases, you should disable or remove an employee’s system access at the same time or just before they are notified of being terminated. This is especially true if that employee is capable of accessing confidential data or has the expertise or access to alter or damage data or services. Failing to restrict released employees’ activities can leave your organization open to a wide range of vulnerabilities, including theft and destruction of both physical property and logical data.
Firing: Not Just a Pink Slip Anymore
Firing an employee has become a complex process. Gone are the days of firing merely by placing a pink slip in an employee’s mail slot. In most IT-centric organizations, termination can create a situation in which the employee could cause harm, putting the organization at risk. That’s why you need a well-designed exit interview process.
However, just having the process isn’t enough. It has to be followed correctly every time. Unfortunately, this doesn’t always happen. You might have heard of some fiasco caused by a botched termination procedure. Common examples include performing any of the following before the employee is officially informed of their termination (thus giving the employee prior warning of their termination):
■ The IT department requesting the return of a notebook computer
■ Disabling a network account
■ Blocking a person’s PIN or smartcard for building entrance
■ Revoking a parking pass
■ Distributing a company reorganization chart
■ Positioning a new employee in the cubicle
■ Allowing layoff information to be leaked to the media
It should go without saying that in order for the exit interview and safe termination processes to function properly, they must be implemented in the correct order and at the correct time (that is, at the start of the exit interview), as in the following example:
■ Inform the person that they are relieved of their job.
■ Request the return of all access badges, keys, and company equipment.
■ Disable the person’s electronic access to all aspects of the organization.
■ Remind the person about the NDA obligations.
■ Escort the person off the premises.
Vendor, Consultant, and Contractor Controls
Vendor, consultant, and contractor controls are used to define the levels of performance, expectation, compensation, and consequences for entities, persons, or organizations that are external to the primary organization. Often these controls are defined in a document or policy known as a service-level agreement (SLA).
Using SLAs is an increasingly popular way to ensure that organizations providing services to internal and/or external customers maintain an appropriate level of service agreed on by both the service provider and the vendor. It’s a wise move to put SLAs in place for any data circuits, applications, information processing systems, databases, or other critical components that are vital to your organization’s continued viability. SLAs are important when using any type of third-party service provider, which would include cloud services. The following issues are commonly addressed in SLAs:
■ System uptime (as a percentage of overall operating time)
■ Maximum consecutive downtime (in seconds/minutes/and so on)
■ Peak load
■ Average load
■ Responsibility for diagnostics
■ Failover time (if redundancy is in place)
SLAs also commonly include financial and other contractual remedies that kick in if the agreement is not maintained. For example, if a critical circuit is down for more than 15 minutes, the service provider might agree to waive all charges on that circuit for one week.
SLAs and vendor, consultant, and contractor controls are an important part of risk reduction and risk avoidance. By clearly defining the expectations and penalties for external parties, everyone involved knows what is expected of them and what the consequences are in the event of a failure to meet those expectations. Although it may be very cost effective to use outside providers for a variety of business functions or services, it does increase potential risk by expanding the potential attack surface and range of vulnerabilities. SLAs should include a focus on protecting and improving security in addition to ensuring quality and timely services at a reasonable price.
Compliance
Compliance is the act of conforming to or adhering to rules, policies, regulations, standards, or requirements. Compliance is an important concern to security governance. On a personnel level, compliance is related to whether individual employees follow company policy and perform their job tasks in accordance to defined procedures. Many organizations rely on employee compliance in order to maintain high levels of quality, consistency, efficiency, and cost savings. If employees do not maintain compliance, it could cost the organization in terms of profit, market share, recognition, and reputation. Employees need to be trained in regard to what they need to do; only then can they be held accountable for violations or lacking compliance.
Privacy
Privacy can be a difficult concept to define. The term is used frequently in numerous contexts without much quantification or qualification. Here are some partial definitions of privacy:
■ Active prevention of unauthorized access to information that is personally identifiable (that is, data points that can be linked directly to a person or organization)
■ Freedom from unauthorized access to information deemed personal or confidential
■ Freedom from being observed, monitored, or examined without consent or knowledge
A concept that comes up frequently in discussions of privacy is personally identifiable information (PII). PII is any data item that can be easily and/or obviously traced back to the person of origin or concern. A phone number, email address, mailing address, social security number, and name are all PII. A MAC address, IP address, OS type, favorite vacation spot, name of high school mascot, and so forth are not typically PII.
When addressing privacy in the realm of IT, there is usually a balancing act between individual rights and the rights or activities of an organization. Some claim that individuals have the right to control whether information can be collected about them and what can be done with it. Others claim that any activity performed in public view – such as most activities performed over the Internet or activities performed on company equipment – can be monitored without knowledge of or permission from the individuals being watched and that the information gathered from such monitoring can be used for whatever purposes an organization deems appropriate or desirable.
Protecting individuals from unwanted observation, direct marketing, and disclosure of private, personal, or confidential details is usually considered a worthy effort. However, some organizations profess that demographic studies, information gleaning, and focused marketing improve business models, reduce advertising waste, and save money for all parties.
There are many legislative and regulatory compliance issues in regard to privacy. Many US regulations – such as the Health Insurance Portability and Accountability Act (HIPAA), the Sarbanes-Oxley Act of 2002 (SOX), and the Gramm-Leach-Bliley Act – as well as the EU’s Directive 95/46/EC (aka the Data Protection Directive) and the contractual requirement Payment Card Industry Data Security Standard (PCI DSS) – include privacy requirements. It is important to understand all government regulations that your organization is required to adhere to and ensure compliance, especially in the areas of privacy protection.
Whatever your personal or organizational stance is on the issue of online privacy, it must be addressed in an organizational security policy. Privacy is an issue not just for external visitors to your online offerings but also for your customers, employees, suppliers, and contractors. If you gather any type of information about any person or company, you must address privacy.
In most cases, especially when privacy is being violated or restricted, the individuals and companies must be informed; otherwise, you may face legal ramifications. Privacy issues must also be addressed when allowing or restricting personal use of email, retaining email, recording phone conversations, gathering information about surfing or spending habits, and so on.