Annual Report on the Status of the Information Security Program
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1 October 2, 2014 San Bernardino County Employees Retirement Association 348 W. Hospitality Lane, Third Floor San Bernardino, CA
2 Table of Contents I. Executive Summary... 3 A. Overview... 3 B. Designation of Representatives... 3 C. Scope of Program... 3 II. Risk Assessment and Risk Analysis... 4 A. Risk Assessment... 4 B. Risk Analysis... 4 III. Third Party Service Providers... 5 A. Overview... 5 B. Controls and Safeguards... 5 IV. Independent Assessment... 6 A. Security Audit... 6 B. Testing... 6 V. Security Breaches or Violations... 7 A. Security Incidents... 7 B. Management Response... 7 VI. Enhancements... 8 A. Overview... 8 B. Adjustments to the Program
3 I. EXECUTIVE SUMMARY Annual Report on the Status of the A. OVERVIEW SBCERA s written (the Program ) is mandated by the Federal Trade Commission s Safeguards Rule and the Gramm Leach Bliley Act ( GLBA ). The Program: 1. Ensures the security and confidentiality of covered records. 2. Protects against any anticipated threats or hazards to the security of such records, and 3. Protects against the unauthorized access or use of such records or information in ways that could result in substantial harm or inconvenience to customers. The Program incorporates policies and procedures and is in addition to any policies and procedures that may be required pursuant to other federal and state laws and regulations. This report describes the overall status of the Program and discusses material matters related to: Risk assessment and risk analysis Third party service providers Independent assessment Security breaches or violations Enhancements B. DESIGNATION OF REPRESENTATIVES Chief Security Officer (CSO) staff are designated as the Program Officer responsible for coordinating and overseeing the Program as well as preparing an annual report on the status of the Program. The Program Officer may designate other representatives of the Institution to oversee, coordinate particular elements of the Program, as well as prepare the annual report on the status of the Program. Any questions regarding this annual report or the interpretation of this document should be directed to the Program Officer or his or her designees. C. SCOPE OF PROGRAM The scope of the Program is identified in the Summary prepared by the Program Officer or his or her designees. 3
4 II. RISK ASSESSMENT AND RISK ANALYSIS A. RISK ASSESSMENT Our scope included an assessment and analysis of our Information Technology network infrastructure, software, human resources, staff, and other assets for risks. We evaluated and assessed external and internal risks to the security, confidentiality, and integrity of non-public financial information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information. Our most recent Risk Assessment Report identified: Assets. We identified and classified IT related assets that provide value to the organization. Examples of tangible assets identified include buildings, employees, computer and network servers, etc. Examples of intangible assets include intellectual property, custom software, and customer data. Threats. Once the assets were determined we identified threats to the assets. Threats included natural threats (acts of God), accidental or unintentional threats (worker illness, equipment failure), and intentional threats such as asset theft and asset tampering (malicious damage). Vulnerabilities. For each threat, we identified one or more vulnerabilities. Vulnerabilities include a bug, flaw, weakness, or exposure of an application, system, device, or service that could lead to a failure of confidentiality, integrity, or availability. B. RISK ANALYSIS Once our assets, threats, and vulnerabilities were identified, we evaluated the likelihood of the event and the potential impact or loss. During our analysis we considered: Cost of downtime Loss of information Breach of legislation Impact on image and reputation Loss of business opportunity Other factors we felt were relevant Our most recent Risk Analysis Report identified safeguards and controls that manage and reduce our risks: Preventive controls prevents errors and irregularities. Detective controls detect errors and irregularities that have occurred and assure correction. Corrective controls procedures to resume operations. 4
5 III. THIRD PARTY SERVICE PROVIDERS A. OVERVIEW SBCERA relies on external providers for a variety of services. Over the past year important third party service providers included: Advanced Office Solutions, printer support Corodata, document storage EMF, fire detection and suppression Enghouse, VoIP support Levi, Ray & Shoup, application support Sikich, application support Sire a Hyland Software Product, application support Sonoran, VoIP support UPS Security, building security Western Audio Visual, VTC equipment support B. CONTROLS AND SAFEGUARDS The Program Officer established procedures for identifying and assessing risks related to the use of third party service providers. Our Risk Analysis Report identified controls and safeguards used to manage and reduce our risks related to such service providers. Selected controls included: Policies. The Vendor Management Policy established the authority for the use of appropriate vendors provided guidelines for vendor selection and management. Agreements. Agreements included confidentiality clauses that ensured the protection of sensitive information. 5
6 IV. INDEPENDENT ASSESSMENT A. SECURITY AUDIT On an annual basis, independent security audits are used as a detective safeguard to identify mistakes or intentional failures in following prescribed procedures. These assessments are particularly important when duties cannot be appropriately segregated. Such reviews help detect errors or irregularities and include a review of systems and processes to ensure they are sufficient and effective: Documentation, access controls, training logs. Agreements with service providers. Software is supported by vendor with current support agreement. Network segmentation, firewall configuration. Access controls, authorization, password change frequency, evaluate password complexity. Reactivation procedures for accounts locked out due to invalid logon attempts. Backup Plan, backup procedures, and backup logs. Patch management on servers and workstations. Anti-malware software detects malicious code on servers and workstations. Workstation controls, screen savers, monitors positioning. Incident response plan, procedures, and capacity planning and testing. B. TESTING The following independent testing procedures are used to evaluate the sufficiency and adequacy of our controls and safeguards: External network security assessment of firewalls and other public network addresses. Web application security assessment of websites. Social engineering assessment evaluates effectiveness of staff security education and awareness training. 6
7 V. SECURITY BREACHES OR VIOLATIONS A. SECURITY INCIDENTS We are not aware of any security incidents or violations that occurred during the past year. B. MANAGEMENT RESPONSE Management will continue to ensure that monitoring systems and audit trails are implemented and maintained to detect and identify security breaches or violations. 7
8 VI. INFORMATION SECURITY PROGRAM ENHANCEMENTS A. OVERVIEW The Program Officer evaluated and adjusted the Program based on the risk identification and assessment activities undertaken pursuant to the Program, as well as material changes to our organization s operations or other circumstances that had a material impact on the Program. B. ADJUSTMENTS TO THE PROGRAM The Program Officer s Risk Action Plan Report identified a prioritized list of the top risks to be addressed. The Risk Action Plan Report is updated on an on-going basis as tasks are completed and new tasks are added to the List. The List is also used as a reporting tool providing current status to management. 8
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