Top Ten Security Vulnerabilities in z/os & RACF Security. Philip Emrich Senior Professional Services Consultant

Transcription

1 Top Ten Security Vulnerabilities in z/os & RACF Security Philip Emrich Senior Professional Services Consultant 1

2 Legal Notice Copyright 2015 Vanguard Integrity Professionals, Inc. All Rights Reserved. You have a limited license to view these materials for your organization s internal purposes. Any unauthorized reproduction, distribution, exhibition or use of these copyrighted materials is expressly prohibited. Trademarks The following are trademarks of Vanguard Integrity Professionals Nevada: Vanguard Administrator Vanguard Advisor Vanguard Analyzer Vanguard SecurityCenter Vanguard SecurityCenter for DB2 Vanguard Offline Vanguard Cleanup Vanguard PasswordReset Vanguard Authenticator Vanguard incompliance Vanguard IAM Vanguard GRC Vanguard QuickGen Vanguard Active Alerts Vanguard Configuration Manager Vanguard Configuration Manager Enterprise Edition Vanguard Policy Manager Vanguard Enforcer Vanguard ez/token Vanguard Tokenless Authenticator Vanguard ez/piv Card Authenticator Vanguard ez/integrator Vanguard ez/signon Vanguard ez/password Synchronization Vanguard Security Solutions Vanguard Security & Compliance Vanguard zsecurity University 2

3 Trademarks The following are trademarks or registered trademarks of the International Business Machines Corporation: CICS CICSPlex DB2 eserver IBM IBM z IBM z Systems IBM z13 IMS MQSeries MVS NetView OS/390 Parallel Sysplex RACF RMF S/390 System z System z9 System z10 System/390 VTAM WebSphere z Systems z9 z10 z13 z/architecture z/os z/vm zenterprise Java and all Java-based trademarks are trademarks of Sun Microsystems, Inc. in the United States, other countries, or both. UNIX is a registered trademark of The Open Group in the United States and other countries. Microsoft, Windows and Windows NT are registered trademarks of Microsoft Corporation. Other company, product, and service names may be trademarks or service marks of others. 3

4 About Vanguard The Cybersecurity Experts Founded: Business: years of Securing Lives and Businesses Mature Enterprise Cyber Security, Professional Services, Education and Customer Support Customers: Large Enterprises with employees Markets: Financial, Insurance, HealthCare, Education, Transportation and Government Agencies Manufacture: We manufacture and develop in the U.S.A. to ensure the highest standards of quality Operate: Global company with a global customer base, serving diverse markets, providing long-term stability HQ Las Vegas, Nevada R&D Orange, California Intl. HQ United Kingdom 4

5 Agenda The Need for Best Practices for z/os Security 1 This part introduces the need to assess z/os systems for vulnerabilities and the reasons for doing regular vulnerability assessments. Vanguard s most Frequently Encountered Significant Exposures 2 This part covers the Top Ten most frequently encountered Severe or High risk exposures encountered in assessment of z/os systems Vanguard has conducted for our clients. Assessment and Remediation 3 This part discusses the overall assessment process and remediation of exposures identified. 5

6 The Issues Is your mainframe critical to your enterprise? Is it central to your Disaster Recover Plan Does it host mission critical applications and data What would be the immediate and long term impact of a system outage The level of security controls for your mainframe must be sufficient for the criticality of the data and business processes hosted on it. 6

7 The Issues System z/os workloads are going UP in terms of data stored and transactions processed, NOT down. This is the opposite of the public or common perception. If you have a z/os system in your network, that is the bank vault everything else is just an ATM. 7

8 The Mainframe Mainframe at 50: Why the mainframe keeps on going For the past 50 years, the mainframe has been the technological workhorse enabling government policy and business processes. In fact, 80% of the world's corporate data is still managed by mainframes. " 80% of the world s corporate data is still managed by mainframes." In a video interview with Computer Weekly's Cliff Saran, IBM Hursley lab director Rob Lamb said the mainframe has kept up with the shifts in computing paradigms and application systems, such as the move to the "If web you and are mobile using technology. a mobile application today "The platform is continually reinventing itself to remain relevant for cloud and mobile computing and to be able to run the most popular application server packages," he said. another, there is a four in five chance that there Yet while it appears to be middle-aged technology, in terms of reach it seems the mainframe is a mainframe touches behind almost everything that transaction." in modern life, according to Lamb. If you are using a mobile application today that runs a transaction to check your bank balance or transfer money from one account to another, there is a four in five chance that there is a mainframe behind that transaction," he said. And the amount of processing run on the mainframe dwarfs the internet giants. "Every second there are 6,900 tweets, 30,000 Facebook likes and 60,000 Google searches. But the CICs application server, which runs on the IBM mainframe, processes 1.1 million transactions per second that's 100 billion transactions a day," he said. IBM will be formally celebrating the 50 th anniversary of the System/360 on 8 April that runs a transaction to check your bank balance or transfer money from one account to Source: Computer Weekly; Interview with Rob Lamb, IBM Hursley lab director, March 24,

9 Mainframe Survey of 350 CIOs Global Survey Reveals Companies at Risk From Inadequate Planning for Generational Shift in Mainframe Stewardship " The survey makes it clear that CIOs see the mainframe playing a central role in the future of the digital enterprise. Key survey findings from 350 enterprise CIOs: 88% believe the mainframe will be a key business asset over the next decade 78% see the mainframe as a key enabler of innovation 70% are concerned about knowledge transfer and risk 39% have no explicit plans for addressing mainframe developer shortages 88% agreed that the mainframe will 70% are surprised by how much additional work and money is required to ensure new platforms and applications match the security provided by the mainframe continue to be a key business asset over DETROIT, June 10, 2015 (GLOBE NEWSWIRE) -- Compuware Corporation, the world's leading mainframe-dedicated software company, today released the findings from a survey the next decade " of 350 CIOs regarding the use and management of mainframe hardware and software in the enterprise. The survey uncovered a profound disconnect between the continued importance of the mainframe to the business and the actions CIOs are taking to protect their investments in the platform. Growing workloads, ongoing innovation The survey makes it clear that CIOs see the mainframe playing a central role in the future of the digital enterprise. 88% agreed that the mainframe will continue to be a key business asset over the next decade, and 81% reported that their mainframes continue to evolve running more new and different workloads than they did five years ago. In particular, survey respondents cited the advantages of the mainframe in processing Big Data. The overwhelming majority of respondents also see mainframe code as valuable corporate intellectual property (89%) and see the mainframe as a key enabler of innovation (78%). CIOs also see the mainframe as superior to other platforms from a cost/benefit perspective. 70% reported that they have been surprised by how much additional work and money is required to ensure new platforms and applications match the security provided by the mainframe. Enterprises at risk Despite the central role the mainframe continues to play in the digital enterprise, the survey reveals that inadequate investment in the mainframe is putting companies at risk in multiple ways. For example, while 75% of CIOs recognize that distributed application developers have little understanding of the mainframe and 70% are concerned that a lack of documentation will hinder knowledge transfer and create risk, 4 out of 10 have not put formal plans in place to address the coming generational shift in mainframe stewardship as their most experienced platform professionals retire. By the same token, advancement of mainframe applications ranked lowest on the survey when it came to allocation of human resources on the mainframe despite the fact that respondents claimed to value those applications as key corporate IP. The survey also revealed that the mainframe remains "siloed" from the rest of IT, even though CIOs also recognize the increasing importance of utilizing the mainframe in concert with other enterprise IT resources. Source: Nasdaq GlobeNewswire, Compuware Corporation, June 10,

10 The Situation Mainframes: The Past will Come Back to Haunt You Philip Young, aka Soldier of Fortran While most IT security teams tend to lump mainframe systems into the category of legacy systems unnecessary or impossible to scrutinize during regular audits, that couldn't be farther from the truth. I see them described as legacy all the time: 'Oh, we don't need to implement this policy because it's a legacy system.' Calling a mainframe legacy is like calling Windows 2012 Server legacy because parts of the Window NT kernel are still in the code. Or it's like calling my car legacy because it's still got tires. A website was released with a number of tools to aid with the hacking of a mainframe, including VERY SPECIFIC mainframe vulnerabilities. (ACEE zapper, USS elevated permission code, TN3270 sniffers)

11 The Logica and Nordea Hack Pirate Bay co-founder Gottfrid Svartholm Warg was charged with hacking the IBM mainframe of Logica, a Swedish IT firm that provided tax services to the Swedish government, and the IBM mainframe of the Swedish Nordea bank, according to the Swedish public prosecutor Henrik Olin. A large amount of data from companies and agencies was taken during the hack, according to Olin, including a large amount of personal data, such as personal identity numbers of people with protected identities. Only one of the attempts to transfer money from eight Nordea bank accounts succeeded, according to Olin. The intruders managed to do that by hacking the mainframe that was located in Sweden. HQ Las Vegas, Nevada R&D Orange, California They attempted to steal over $900K from Nordea customers accounts. 11

12 Cost of a Data Breach 2015 Cost of Data Breach Study: Global Analysis " According to our research, the average total cost of a data breach for the 350 companies participating in this research increased from 3.52 to $3.79 million 2. The average cost paid for each lost or stolen record containing sensitive and confidential information increased from $145 in 2014 to $154 in this year s study." Part 1. Introduction 2014 will be remembered for such highly publicized mega breaches as Sony Pictures Entertainment and JPMorgan Chase & Co. Sony suffered a major online attack that resulted in employees personal data and corporate correspondence being leaked. The JPMorgan Chase & Co. data breach affected 76 million households and seven million small businesses. IBM and Ponemon Institute are pleased to release the 2015 Cost of Data Breach Study: Global Analysis. According to our research, the average total cost of a data breach for the 350 companies participating in this research increased from 3.52 to $3.79 million2. The average cost paid for each lost or stolen record containing sensitive and confidential information increased from $145 in 2014 to $154 in this year s study. In the past, senior executives and boards of directors may have been complacent about the risks posed by data breaches and cyber attacks. However, there is a growing concern about the potential damage to reputation, class action lawsuits and costly downtime that is motivating executives to pay greater attention to the security practices of their organizations. In a recent Ponemon Institute study, 79 percent of C-level US and UK executives surveyed say executive level involvement is necessary to achieving an effective incident response to a data breach and 70 percent believe board level oversight is critical. As evidence, CEO Jamie Dimon personally informed shareholders following the JPMorgan Chase data breach that by the end of 2014 the bank will invest $250 million and have a staff of 1,000 committed to IT security.3 For the second year, our study looks at the likelihood of a company having one or more data breach occurrences in the next 24 months. Based on the experiences of companies participating in our research, we believe we can predict the probability of a data breach based on two factors: how many records were lost or stolen and the company s industry. According to the findings, organizations in Brazil and France are more likely to have a data breach involving a minimum of 10,000 records. In contrast, organizations in Germany and Canada are least likely to have a breach. In all cases, it is more likely a company will have a breach involving 10,000 or fewer records than a mega breach involving more than 100,000 records. In this year s study, 350 companies representing the following 11 countries participated: United States, United Kingdom, Germany, Australia, France, Brazil, Japan, Italy, India, the Arabian region (United Arab Emirates and Saudi Arabia) and, for the first time, Canada. All participating organizations experienced a data breach ranging from a low of approximately 2,200 to slightly more than 101,000 compromised records4. We define a compromised record as one that identifies the individual whose information has been lost or stolen in a data breach. 1This report is dated in the year of publication rather than the fieldwork completion date. Please note that the majority of data breach incidents studied in the current report happened in the 2014 calendar year. 2Local currencies were HQ converted Las to Vegas, U.S. dollars. Nevada R&D Orange, California 3 New JPMorgan Chase Breach Details Emerge by Mathew J. Schwartz, Bankinfosecurity.com, August 29, The terms cost per compromised record and per capita cost have equivalent meaning in this report. Source: Ponemon Institute Research Report, May,

13 Business Realities The Need to Implement Security Best Practices Information Security Compliance is a top organizational initiative Laws, Regulations, and Standards require validation of proper implementation of IT internal controls. IT Internal Control failures threaten the organization s image and can carry heavy fines and even executive management imprisonment. Cyber-crime activities are a serious threat and companies are expected to implement all reasonable measures to prevent successful attacks. Outside auditors can and are issuing sanctions that restrict core business activities based on IT security risks identified in their audits. Bottom Line: The Information Security organization must be proactive in their efforts to implement and maintain Security Best Practices in their HQ enterprises. Las Vegas, Nevada R&D Orange, California 13

14 Origins of Best Practices Objective Sources: HIPAA (1996) & HITECH Act 2009 Gramm-Leach-Bliley Act 1999 (GLBA) Financial Privacy Rule Safeguards Rule Sarbanes-Oxley Act of 2002 (SOX) Section 404: Assessment of internal control PCI-DSS (Payment Card Industry - Data Security Standard) PCI Standards & Documents Documents Library HQ Las Vegas, Nevada ISO/IEC R&D - Information Orange, California security management standard 14

15 Origins of Best Practices Objective Sources: DOD DISA STIGs Defense Information Systems Agency Security Technical Implementation Guides NIST (National Institute of Standards and Technology) co-hosts with DHS (Department of Homeland Security) security configuration checklists on the National Vulnerability Database HQ Las Vegas, Nevada Target Product: R&D Orange, IBM California OS390 15

16 Regulatory Compliance Payment Card Industry Data Security Standard Health Insurance Portability and Accountability Act Health Information Technology for Economic and Clinical Health HIPAA HITECH PCI DSS Compliance GLBA Gramm-Leach-Bliley Act Federal Information System Controls Audit Manual FISCAM Challenges SOX NIST STIG National Institute of Standards and Technology Security Technical Implementation Guides Sarbanes-Oxley Act The identified security issues present risk to regulatory / industry compliance standards depending on the data present within the assessed system 16

17 Origins of Best Practices Subjective Source: Vanguard Best Practices HQ Las Vegas, Nevada Professional Services Consultants with an average of 30+ years experience Based on our technical understanding of z/os and key Subsystem software Related to risks and exposures identified in hundreds of Security Assessments conducted over more than 20 years Each Security Assessments involves several hundred tests New assessment tests added as required R&D Orange, California 17

18 Vanguard's Assessment Process Analysis of over Hundreds of Assessments Private firms across numerous industries Various governmental agencies: Federal State Local Totaling over 1800 Individual Findings Over 300 unique Findings Correlated to regulations or compliance requirements Categorized by Severity and Remediation effort 18

19 Vanguard s Exposure Severity Rating SEVERE (needs immediate remediation) Immediate unauthorized access into a system Elevated authorities or attributes Cause system wide outages the ability to violate IBM s Integrity Statement HIGH (needs remediation in the near future) Vulnerabilities that provide a high potential of disclosing sensitive or confidential data cause a major sub-system outage assignment of excessive access to resources MEDIUM(needs a plan for remediation within a reasonable period) Vulnerabilities that provide information and/or access that could potentially lead to compromise the inability to produce necessary audit trails LOW (should be remediated when time and resources permit) Implementation or configuration issues that have the possibility of degrading performance and/or security administration 19

20 Vulnerability Assessment Findings Scope: Vanguard s Top Ten z/os Risks Identified in Client Security Assessments Excessive Number of User IDs with No Password Interval Inappropriate Usage of z/os UNIX Superuser Privilege UID(0) Sensitive Data Sets with UACC Greater than NONE Critical Data Set Profiles with UACC Greater than READ Started Task IDs are not Defined as PROTECTED IDs Improper Use or Lack of UNIXPRIV Profiles Excessive Access to the SMF Data Sets Excessive Access to APF Libraries Excessive Access to z/os UNIX File System Data Sets RACF Database is not Adequately Protected Data collected from hundreds of security assessments performed by Vanguard Integrity Professionals. 20

21 Top Ten Assessment Finding #1 Finding Excessive Number of User IDs with No Password Interval Explanation User IDs with no password Interval are not required to change their passwords. Risk Recommended Best Practice and Remediation SEVERE - Since passwords do not need to be changed periodically, people who knew a password for an ID could still access that ID even if they are no longer authorized users. Review each of the personal user profiles to determine why they require NOINTERVAL. Their passwords should adhere to the company policy regarding password changes. If the user ID is being used for started tasks or surrogate, it should be reviewed and changed to PROTECTED. If the user ID is being used for off platform process, then review controls for where the passwords are stored and consider converting to usage of digital certificates or other alternatives. 21

22 Top Ten Assessment Finding #2 Finding Inappropriate Usage of z/os UNIX Superuser Privilege UID(0) Explanation Risk Recommended Best Practice and Remediation User IDs with z/os UNIX superuser authority, UID(0), have full access to all UNIX directories and files and full authority to administer z/os UNIX. SEVERE - Since the UNIX environment is the z/os portal for critical applications such as file transfers, Web applications, and TCPIP connectivity to the network in general, the ability of these superusers to accidentally or maliciously affect these operations is a serious threat. No personal user IDs should be defined with an OMVS segment specifying UID(0). The assignment of UID(0) authority should be minimized by managing superuser privileges by granting access to one or more of the BPX.qualifier profiles in the FACILITY class or access to one or more profiles in the UNIXPRIV class for both personal user IDs and IDs associated with started tasks for which UID(0) is not required.. 22

23 Top Ten Assessment Finding #3 Finding Sensitive Data Sets with UACC Greater than NONE Explanation Risk Recommended Best Practice and Remediation The UACC value for a dataset profile defines the default level of access to which any user whose user ID or a group to which it has been connected does not appear in the access list. SEVERE Sensitive data sets that are protected by a RACF profile with a UACC greater than NONE allow most users with system access to read or modify these data sets. In addition, users may be able to delete any data set covered by a dataset profile that has a UACC of ALTER. Review each of these profiles and determine whether the UACC is appropriate. For those profiles where the UACC is excessive, you will have to determine who really needs access before changing the UACC. To find out who is accessing these data sets, review SMF data to determine who is accessing the data sets with the UACC. 23

24 Top Ten Assessment Finding #4 Finding Critical Data Sets with UACC Greater than READ Explanation Risk Recommended Best Practice and Remediation The UACC value for a dataset profile defines the default level of access to which any user whose user ID or a group to which it has been connected does not appear in the access list. HIGH Critical data sets that are protected by a RACF profile with a UACC greater than READ will allow most users with system access the ability to modify the data residing in these data sets. In addition, users may be able to delete any data set covered by a dataset profile that has a UACC of ALTER. Review each of these profiles and determine whether the UACC is appropriate. For those profiles where the UACC is excessive, you will have to determine who really needs access before changing the UACC. To find out who is accessing these data sets, review SMF data to determine who is accessing the data sets with greater than READ access and then issue appropriate PERMIT commands based on the review of the SMF data. 24

25 Top Ten Assessment Finding #5 Finding Started Task IDs are not Defined as PROTECTED IDs Explanation Risk Recommended Best Practice and Remediation User IDs associated with started tasks should be defined as PROTECTED which will exempt them from revocation due to inactivity or excessive invalid password attempts, as well as being used to sign on to any application. HIGH - RACF will allow the user ID to be used for the started task even if it has become revoked, but some started tasks may either submit jobs to the internal reader that will fail or may issue a RACROUTE REQUEST=VERIFY macro for the user ID that will also fail. Review all started task user IDs that are not protected. Determine if the user IDs are used for any other function that might require a password. Define the started task user IDs as PROTECTED for those tasks that do not require a password. 25

26 Top Ten Assessment Finding #6 Finding Improper Use or Lack of UNIXPRIV Profiles Explanation The UNIXPRIV class resource rules are designed to give a limited subset of the superuser UID(0) capability. When implemented properly, UNIXPRIV profiles can significantly reduce unnecessary requests for assignment of UID(0) to user IDs. Risk HIGH - Without UNIXPRIV profiles defined, administrator IDs would require superuser ability through the assignment of UID(0) or access to the BPX.SUPERUSER profile in the FCILITY class.. The ability of these superusers to accidentally or maliciously affect the operation of your z/os UNIX system environment is a serious threat. Recommended Best Practice and Remediation Review the users activity that are currently defined as SUPERUSERs to determine if granular profiles may be defined in the UNIXPRIV class that will authorize their activity. Refine the access list and define more granular profiles based upon the superuser functions that the users with UID(0) need. 26

27 Top Ten Assessment Finding #7 Finding Excessive Access to SMF Data Sets Explanation Risk Recommended Best Practice and Remediation SMF data collection is the system activity journaling facility of the z/os system. With the proper parameter specifications it provides an audit trail of system activity and also serves as the basis to ensure individual user accountability. HIGH - The ability to READ SMF data enables someone to identify potential opportunities to breach your security. If UPDATE or higher access is granted, a risk of audit log corruption exists. Appropriate access control for the unloaded data is also critical to ensure a valid chain of custody. Ensure that access authority to SMF collection files is limited to only appropriate systems programming staff and and/or batch jobs that perform SMF dump processing and ensure that any UPDATE or higher accesses are being logged. 27

28 Top Ten Assessment Finding #8 Finding Excessive Access to APF Libraries Explanation Risk Recommended Best Practice and Remediation Authorized Program Facility (APF) libraries are an integral part of the z/os architecture to enable maintenance of the integrity of the z/os operating system environment. Libraries designated as APF allow programs to execute with the authority of z/os itself, so the ability to modify these libraries must be strictly controlled. SEVERE - UPDATE or higher access to an APF library can allow an individual to create an authorized program which can bypass security controls and execute privileged instructions. UPDATE or higher access should be limited to senior systems support staff. Review the protection of all APF libraries. APF libraries should be protected by RACF profiles that cover only one or more APF libraries, e.g. a fully qualified generic profile. Remove or change inappropriate access list entries and ensure that any UPDATE activity is logged to SMF. 28

29 Top Ten Assessment Finding #9 Finding Excessive Access to z/os UNIX File System Data Sets Explanation Risk Recommended Best Practice and Remediation For the z/os UNIX environment, there are z/os data sets that contain operating system components and data sets that contain HFS file systems with application system and user data. All of these UNIX file system data sets require proper protection in RACF to enforce desired access controls. HIGH - Anyone that has at least READ access to the z/os File System data sets can make a copy and possibly view the contents of the z/os UNIX files. Determine which users have a legitimate need to access the z/os File System data sets. Then create profiles with appropriate access lists and set the UACC value for these profiles to NONE. 29

30 Top Ten Assessment Finding #10 Finding RACF Database is not Adequately Protected Explanation Risk Recommended Best Practice and Remediation The RACF database contains extremely sensitive security information. No access to the RACF database is required for normal administration activities using either RACF commands or the RACF provided ISPF panels. SEVERE - Any user who has read access to the RACF database or any backup copy could make a copy and then use a cracker program to find passwords for user IDs and could obtain a list of user IDs and resources. Review the protection for the RACF database and any backup copies and remove any access list entries granting access higher than NONE, other than to senior RACF administrators and system staff responsible for running RACF database utilities. 30

31 2016 Top Ten z/os Vulnerabilities The percentage numbers represent the percentages of environments in which Vanguard has found this configuration error in over 200 environments in the last 8 years. 74% Excessive Number of User ID s with no Password Interval SEVERE 60% Inappropriate Usage of z/os UNIX Superuser Privilege, UID(0) SEVERE 54% Sensitive Data Set Profiles with UACC Greater than NONE SEVERE 54% Critical Data Set Profiles with UACC Greater than READ HIGH 53% Started Task IDs are not Defined as PROTECTED IDs HIGH 52% Improper Use or Lack of UNIXPRIV Profiles HIGH 44% Excessive Access to the SMF Data Sets HIGH 42% Excessive Access to APF Libraries SEVERE 42% Excessive Access to z/os UNIX File System Data Sets HIGH 40% RACF Database is not Adequately Protected SEVERE 31

32 2015 Top Ten z/os Vulnerabilities The percentage numbers represent the percentages of environments in which Vanguard has found this configuration error in over 200 environments in the last 8 years. 73% Excessive Number of User ID s with no Password Interval SEVERE 60% Inappropriate Usage of z/os UNIX Superuser Privilege, UID(0) SEVERE 52% Sensitive Data Set Profiles with UACC Greater than NONE SEVERE 52% Critical Data Set Profiles with UACC Greater than READ HIGH 51% Started Task IDs are not Defined as PROTECTED IDs HIGH 51% Improper Use or Lack of UNIXPRIV Profiles HIGH 40% RACF Database is not Adequately Protected SEVERE 39% Excessive Access to APF Libraries SEVERE 38% General Resource Profiles in WARN Mode SEVERE 33% Production Batch Jobs have Excessive Resource Access SEVERE 32

33 Vulnerability Assessment Objectives Improve Security Posture on z/os Insure effective security control implementation Assess security configuration settings which could create exposure conditions Remediate exposures to improve existing level of security 33

34 Vulnerability Assessment Process Data Collectection This is the data collection phase to be able to assess the environment. Data Analysis This is the data analysis phase where the data collected is analyzed for any potential vulnerabilities. Report This is the report phase where the consultant creates a findings reports and discusses the findings and recommendations with the customer Remediation This is remediation phase where the Vanguard consultant explains the results of the data analysis and provides remediation advice. 34

35 Conclusion Questions? 35

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