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7/25/2019
10:00 AM
Chad Cragle
Chad Cragle
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Answer These 9 Questions to Determine if Your Data Is Safe

Data protection regulations are only going to grow tighter. Make sure you're keeping the customer's best interests in mind.

Since the EU's General Data Protection Regulation went into effect, California and New York have successfully passed the California Consumer Privacy Act (CCPA) and Stop Hacks and Improve Electronic Data Security (SHIELD) regulations, respectively. There are 12 more states getting approval on data protection legislation currently, and that number is expected to grow.

As more disparate legislation is introduced across the US, what organizations must do to avoid costly regulatory fines will only become more complicated. Answer these questions, and you'll sleep a little better at night. Those that have a plan of attack or are already executing on these guidelines should feel confident that their enterprise is keeping the customer's best interests in mind.

● Do you incorporate "privacy and security by design" in your environment?
Privacy and security by design are methodologies based on proactively incorporating privacy and data protection from the very beginning. This approach follows seven principles for implementing growing processes within your IT and business environments. Advocating privacy and security early on in your design process for specific technologies, operations, architectures, and networks will ensure you are building a mature process throughout the design life cycle.

● Is sensitive data encrypted during transit and at rest?
Encryption keys are vital to the protection of transactions and stored data. Key management should be deployed at a level commensurate with the critical function that those keys serve. I strongly recommend encryption keys be updated on a regular basis and stored separately from the data. Essentially, data is always being pushed and pulled and protecting that information as it moves across boundaries should require strong encryption at rest and while in transit.

● Is access to data on a need-to-know basis?
Data should always be classified as sensitive versus nonsensitive and should only be accessed by authorized employees who have a legitimate business reason to access it. Using role-based permissions and "need-to-know" restrictions will help protect your data. It's wise and highly recommended to always use nonshared usernames and passwords with multifactor authentication, which will verify each user. Furthermore, an access review should be conducted at least once per year; this will ensure the appropriate access is given to the correct people.

● Do you have a disaster recovery and backup location?
Having a disaster recovery (DR) and backup environment is a must in today's digital world. DR and business continuity (BC) plans must be in place, and all relevant personnel should be apprised of their roles. DR and BC plans should be tested on an annual basis, followed by lessons learned. Separating your production and backup locations by a few hundred miles will ensure greater data security in the event of a natural or man-made disaster.

● Are vulnerability, risk, penetration, and other audit assessments conducted?
Assessments should be continuously completed throughout the year. Your team should be performing assessments focused on the information system and operational areas within your environment. It's important to conduct these assessments on all assets, internally and externally. Your analysis should be completed in a five-step phase:

  • Identify and prioritize assets
  • Identify threats
  • Identify vulnerabilities
  • Analyze controls
  • Understand the likelihood of an incident and know the impact that threat could have on your systems.

● Is a process in place to delete or destroy data?
Whoever is handling your data should have a data retention schedule. Building out a schedule will ensure you are deleting data within the scoped time period. After you've defined the data retention schedule and you understand what can be deleted, you should follow security best practices around properly deleting and destroying data. Following industry standards such as the National Institute of Standards and Technology (NIST) will ensure your employees know how to and when to destroy and delete data. Any method that conforms to the NIST 800-88 guidelines for data sanitization should be approved for use.

● Do you have an established incident response team and data breach plan?
Your enterprise should have a robust incident response (IR) and data breach plan in place, and they should be tested annually. It should be the IR team's responsibility to manage the IR process, defend against attacks and prevent further damage from occurring when an incident does occur, implement improvements that prevent attacks from reoccurring, and report the outcome of any security incidents.

Your internal plan should be developed based on industry leaders and cover these three phases:

  • Phase I: Detection, assessment, and triage.
  • Phase II: Containment, evidence collection, analysis and investigation, and mitigation.
  • Phase III: Remediation, recovery, and post-mortem. Notifying customers in a timely manner of a breach is mandatory, and this should be spelled out in your agreement.

● Are you logging security events?
Logging should be enabled in order to establish a sufficient audit trail for all access to sensitive data. Logging should be performed at the application level, too. Automated audit trails should be implemented to reconstruct system events and they should be secured so they cannot be altered in any way. File integrity monitoring should be used to ensure you are maintaining confidentiality, integrity, and availability of all customer data.

● Are you keeping your privacy up to date?
Your enterprise needs to be up-front about the information it's collecting. You should be closely following the latest security and privacy regulations to avoid any legal issues. Your privacy policies must be available to all customers if your organization is collecting any data about them (e.g., IP addresses, location, etc.). Your privacy policy should involve all major key stakeholders, legal team, marketing team, and security.

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Chad Cragle has professionally practiced IT security now for over a decade. He started as an IT security auditor and has a proven track record of leading audits and requirement-gathering efforts for several businesses and IT units. Chad is proficient in threat and ... View Full Bio
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Ajfreeland
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Ajfreeland,
User Rank: Apprentice
8/6/2019 | 12:45:17 PM
TLS 1.3 Encryption
Loved the point about encryption at rest and in transit. TLS 1.3 has some very good improvements for securing data in motion. Nubeva has a new method for out of band decrypted visibility for TLS 1.3. It's called Symmetric Key Intercept. Check it out in on Nubeva's website.
tdsan
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tdsan,
User Rank: Ninja
7/29/2019 | 11:41:57 PM
Re: Answers to the questions posed
Also in the case of Accenture Federal, and Attunity and others, encryption at rest would have addressed a number of the problems, if the S3 bucket was open to the public. So encryption at rest is extremely important especially when you talk about valid PII docs found in various S3 hacks. Todd
tdsan
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tdsan,
User Rank: Ninja
7/29/2019 | 11:37:42 PM
Re: Answers to the questions posed
When legal comes into play it is usually out of our hands so it is left up to them to make that determination. Todd
Dr.T
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Dr.T,
User Rank: Ninja
7/29/2019 | 8:12:44 PM
Re: Answers to the questions posed
we perform simulations every 6 months This is really a good practice. Congrats.
Dr.T
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Dr.T,
User Rank: Ninja
7/29/2019 | 8:11:18 PM
Re: Answers to the questions posed
Data is never destroyed, it is put on tape, Data on hand poses liabilities, if you can get rid of it you should since it is better for you.
Dr.T
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Dr.T,
User Rank: Ninja
7/29/2019 | 8:09:58 PM
Re: Answers to the questions posed
IPv6 AES256 ESP/AH VPN IPSec Technology is there to achieve this but we tend to not pay attention encryption at rest.
Dr.T
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Dr.T,
User Rank: Ninja
7/29/2019 | 8:08:48 PM
Re: Answers to the questions posed
utilize hardened ACLs and NSG, DISA Stigs This a good thinking. Makes sure ACLs are not all over the place but as needed basis.
Dr.T
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Dr.T,
User Rank: Ninja
7/29/2019 | 8:07:29 PM
Good questions
Yes, they are all good questions. I am think not a single question can determine the success rather combinations of them.
tdsan
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tdsan,
User Rank: Ninja
7/26/2019 | 9:13:46 PM
Answers to the questions posed

Do you incorporate "privacy and security by design" in your environment?
  • Yes, we employ hardened images, invoke SELinux, configure IPTables/UFW, utilize hardened ACLs and NSG, DISA Stigs (admx) and review "Security Center" as part of our mitigation and remediation plan.

Is sensitive data encrypted during transit and at rest?
  • Yes, we utilize IPv6 AES256 ESP/AH VPN IPSec connections to our regional offices.

 Is access to data on a need-to-know basis? 
  • It just depends on who is asking, if it is an executive or the owner of the application, then that is part of an ongoing discussion, if it is just some person who is inquiring, then it is dependent on who they are working for?

Do you have a disaster recovery and backup location? 
  • Yes, we replicate between three different cloud providers (SQL databases using Transactional Replication - asynchronous).

Are vulnerability, risk, penetration, and other audit assessments conducted?
  • Yes, this is done quarterly and sometimes randomly.

Is a process in place to delete or destroy data? 
  • No, Data is never destroyed, it is put on tape, moved off the system and held for 7 years or however long legal needs it. If the tapes become unusable, then they are removed and replaced once the data becomes obsolete.

Do you have an established incident response team and data breach plan? 
  • Yes, we perform simulations every 6 months and the plan is adjusted and changed based on the data and response times we have gathered.

Are you logging security events? 
  • Yes, we utilize SELinux for Unix/Linux machines in the DMZ, the tools help us identify who is trying to access ssh (logwatch is used to capture log information ("logwatch --filename logwatch-`date '+%m-%d-%Y'`.html --detail Med --range Today --mailto <email>")  and post it on docker so the group can review it; for Windows machines, we pull the logs into a single repository with specific EventIDs. Our SIEM device is tied into our network devices where this information is pulled in real-time, the NGIPS is used to make determinations if the event is a false-positive or an actual threat, we are looking into BluVector and Carbon Black to help make better determinations using ML as a basis for making decisions.

Are you keeping your privacy up to date? 
  • This is where legal comes into play, we let them handle that aspect, we work under their guidance, it is posted on the internal network

T

 
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