Art of Performing Risk Assessments
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1 Clinical Practice Compliance Conference Art of Performing Risk Assessments October 2016 Ali Pabrai, MSEE, CISSP (ISSAP, ISSMP) Member FBI InfraGard AGENDA Cyber Risk = Disruptive Business Risk Breaches: banks, retailers, healthcare Cyber attack lifecycle Standards: Risk Assessment Preparation: Risk Assessment Assessing Controls: Risk Assessment Firewalls to Encryption Vulnerability Assessments & Pen Tests Establishing an Enterprise Cyber Security Plan A Checklist December 31, 2016 The Risk! 1
2 THE WALL STREET JOURNAL. Likely Sources of Cyber Attack # Required Activities STATUS Yes No 1. Criminal syndicates, 59%. 2. Employee, 56% 3. Hactivists, 54% 4. Lone-wolf hacker, 43% 5. External contractor, 36% 6. State-sponsored attacker, 35% Your Response? THE WALL STREET JOURNAL. High Security Priority in 2016! # Required Activities STATUS Yes No 1. Data leakage/data loss prevention, 56% 2. Business continuity/disaster recovery, 55% 3. Identity & access management, 47% 4. Security awareness & training, 44% 5. Incident response capabilities, 44% 6. Security operations (e.g. encryption, patching), 41% Your Response? THE WALL STREET JOURNAL. Challenges to Information Security Operations # Required Activities STATUS Yes No 1. Budget constraints, 62% 2. Lack of skilled resources, 57% 3. Lack of executive awareness or support, 32% 4. Lack of quality tools for managing information security, 28% 5. Management & governance issues, 28% 6. Compliance/regulation issues, 23% Your Response? 2
3 CYBER ATTACKS: GLOBAL & SOPHISTICATED Iran, North Korea, China, Russia Use common SQL injection, spear phishing & sophisticated malware to gain initial access Next, used privilege escalation exploits to compromise additional systems & move deeper inside the compromised firm Verizon Data Breach Investigations Report % of cases, took attackers minutes to compromise systems that are typically not discovered until weeks or months later 63% of data breaches involved leveraging weak, default or stolen passwords New technologies, including IoT, threaten to give attackers new opportunities new attack surfaces 95% of web app attacks where criminals stole data were financially motivated RESULTS OF A RECENT CYBER ASSESSMENT! 141 High Risk 247 Medium Risk 18 Low Risk HIGH Probability of Successful Attack THREAT Remote Code Execution Unsecured PII System configuration issues Buffer Overflow Vulnerability IMPACT Complete Control of the System Breach Loss of Data Denial of Service Attack or Complete Control of the System RANSOMWARE CYBER ATTACKS Prepared 3
4 HIPAA FINES 2016 COST OF BREACHES: EIGHT FIGURE RISK! CYBER ATTACK LIFECYCLE 4
5 Standards COMPLIANCE MANDATES ISO PCI DSS NIST ISO 27001: A GLOBAL STANDARD ISO 27002: 2013 Information Security Policies Organization of Information Security Human Resource Security Asset Management Access Control Cryptography Physical & Environmental Security Operations Security Communications Security System Acquisition, Development & Maintenance Supplier Relationships Information Security Incident Management Information Security Aspects of Business Continuity Management Compliance 5
6 PCI DSS: IMPORTANT REFERENCE PCI DSS Requirements 12.1 Establish, publish, maintain, and disseminate a security policy that accomplishes the following: Testing Procedures 12.1 Examine the information security policy and verify that the policy is published and disseminated to all relevant personnel (including vendors and business partners) Addresses all PCI DSS requirements Verify that the policy addresses all PCI DSS requirements Includes an annual process that identifies threats, and vulnerabilities, and results in a formal risk assessment. (Examples of risk assessment methodologies include but are not limited to OCTAVE, ISO & NIST SP ) a Verify that an annual risk assessment process is documented that identifies threats, vulnerabilities, and results in a formal risk assessment. NIST & RISK ASSESSMENT Scope of Risk Assessment Threats Risk Evaluation Version History Asset Inventory Vulnerabilities Risk Treatment Executive Summary NIST SP REV 1: RISK ASSESSMENT 6
7 Preparation PREPARING FOR AN ASSESSMENT Documentation Updated? Enterprise Security Plan Risk Analysis (most recent) Risk Management Plan (addressing risks identified in the Risk Analysis) Security violation monitoring reports Vulnerability scanning plans Results from most recent vulnerability scan Network penetration testing policy and procedure Results from most recent network penetration test List of all user accounts with access to systems which store, transmit, or access PII (for active and terminated employees) Configuration standards to include patch management for systems which store, transmit, or access PII (including workstations) Encryption or equivalent measures implemented on systems that store, transmit, or access PII RISK ASSESSMENT PREPARATION Policies, Procedures & More Prevention, detection, containment, and correction of security violations Employee background checks and confidentiality agreements Establishing user access for new and existing employees List of authentication methods used to identify users authorized to access PII List of individuals and contractors with access to PII to include copies pertinent business associate agreements List of software used to manage and control access to the Internet Detecting, reporting, and responding to security incidents Physical security Encryption and decryption of PII Mechanisms to ensure integrity of data during transmission including portable media transmission 7
8 RISK ASSESSMENT PREPARATION Other Documentation Done? Organization chart to include staff members responsible for compliance including the protection of PII Examples of training courses or communications delivered to staff members to ensure awareness and understanding of PII policies and procedures Policies and procedures governing the use of virus protection software Data backup procedures Disaster recovery plan Disaster recovery test plans and results Analysis of information systems, applications, and data groups according to their criticality and sensitivity Inventory of all information systems to include network diagrams listing hardware and software used to store, transmit or maintain PII Inventory log recording the owner and movement of media and devices that contain PII CREDIBLE RISK ASSESSMENT? Security Controls Cyber threat to our nation is one of the most serious economic and national security challenge we face. President Obama 8
9 SECURITY CONTROLS & COMPLIANCE Key Security Controls Implemented Missing Firewall (Sonic Firewall TZ210) Two-factor authentication IDS (Dell SecureWorks) Antivirus protection (Webroot) Data transfer (SFTP, HTTPS) Remote access (VPN, Citrix) DLP Secure text messaging USB & portable device encryption MDM Asset management (Dell KACE) Laptop encryption (TrueCrypt at the Bios Level; Windows OS & File Vault on Mac OS) encryption (Voltage) Closing Thoughts AN ANNUAL CHECKLIST The Seven Steps to Enterprise Security TM 1 Security Responsibility Evaluate 7 2 Risk Analysis Training 6 3 Security Strategy & Policies BA Supply Chain 5 Remediate 4 9
10 ENTERPRISE CYBER SECURITY PLAN Sample Topics Key Facts Compliance Mandates to Meet Priorities Security Priorities in 2016 Compliance Priorities in 2016 Current Security Controls Security Control Deficiencies Security Control Priorities in 2016 Risk Analysis Scope & Timeline Vulnerability Assessment Scope & Timeline Penetration Testing Documentation Security Policies Summary Privacy Policies Summary Security Procedures Summary Contingency Plan Business Impact Analysis (BIA) in 2016 Disaster Recovery Plan (DRP) Incident Response Plan Breach Discovery & Reporting Tools Audit Controls Log Automation & Consolidation Tools CYBER SECURITY FRAMEWORK CHECKLIST FOR RISK ASSESSMENT # AREA STATUS YES NO Comments Document Regulations (Federal, State) & Standards That 1 Business is Mandated to Comply (Privacy, Security) With 2 Assess Policies (Privacy, Security) 3 Assess Procedures (IT, Security) 4 Review Asset Management Process & Documents 5 Review Vendor (Business Associate) Agreements 6 Assess Deployed Security Controls 7 Identify Missing Security Controls 8 Assess State of Encryption Implementation 9 Review Cloud Security for Deployed Apps & PII/EPHI 10
11 CHECKLIST FOR RISK ASSESSMENT (Cont d) STATUS # AREA YES NO 10 Conduct Technical Vulnerability Assessment (External, Internal) 11 Conduct Wireless Assessment 12 Review Firewall Architecture & Configuration 13 Review Mission Critical Applications & Their Security 14 Assess Requirements for Penetration Testing 15 Evaluate Risk Management Program 16 Assess Quality/Depth of Security Awareness Training 17 Review Information Security Skill Capabilities 18 Assess Executive Priority/Reporting Structure for Security & Compliance Comments December 31, 2016? What is the state of your enterprise security & compliance? Conduct a credible risk assessment! Compliance & Cyber Security 11
12 Las Vegas, NV Dec 6 7 Program Delivered as a Private Class Anywhere, Worldwide! From this compliance & security training program you will: Examine HITECH & the HIPAA Security Rule, including Final Rule updates Learn about FISMA, NERC CSS, & GLBA Step through the core requirements of PCI DSS Analyse ISO 27001, ISO 27002, ISO Examine California's SB 1386, SB 541, AB 1950, AB 1298, AB 211 & other U.S. State information security related regulations Walk thru NIST security standards Las Vegas, NV Dec 8 9 Program Delivered as a Private Class Anywhere, Worldwide! An Executive Cyber Security Program First executive training program designed to enable development of a cyber security program in the class. The CCSA SM training validates knowledge and skill sets in cyber security with particular focus and emphasis on the development of an applicable cyber security incident response and an enterprise cyber security program. Las Vegas Dec. 10, 2016 Orlando, FL Feb. 24, 2017 Program Delivered as a Private Class Anywhere, Worldwide! 12
13 About Your Presenter Ali Pabrai, MSEE, CISSP (ISSAP, ISSMP) Information Security & Compliance Expert Consults extensively with technology firms, government agencies and business associates Created bizshield TM a Signature Methodology - to address compliance & information security priorities Featured speaker at InfoSec conferences worldwide Presented at Microsoft, Kaiser, Intuit, E&Y, Federal & State Government agencies & many others Established the HIPAA Academy & CSCS Programs gold standard for cyber security & compliance solutions Interim CISO for large health system with 35+ locations across the USA Member InfraGard (FBI) & Ali.Pabrai@ecfirst.com 13
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