SDR Guide to Complete the SDR
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- Emil Parsons
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1 I. General Information You must list the Yale Servers & if Virtual their host Business Associate Agreement (BAA ) in place. Required for the new HIPAA rules Contract questions are critical if using 3 Lock Data. II. Data Classification and Criticality Data classification is needed to decide which SDR forms to use. If ephi is used the Above Risk Threshold is required. This generates a survey that is for every year. This is not the same as the SDR Questions on file shares. This creates a new possible place for unauthorized usage. Questions on who controlling access, logging access, reviewing access is then not just in the application, O/S or DB. Processing Credit Cards must be a Yes even if using a Hosted Order Page. If a HOP then fill out a SDR Light. However must have a WebInspect scan of the URL. Note that if using high risk data then pay attention to the data not only in production but in development and testing for: Obfuscation, Encryption, or De-identification Who is the Information/Data Steward is to ensure that there is an application owner that will take responsibility for the data. III. System Application Design (Internal or External) Model This area is about where the data is being used. What are the interfaces, mechanisms for transmitting data (including transmission of report output), the data protected in transit (e.g., encryption, private communication line, etc.). Who is creating the data? -We care as could be a higher risk as areas not in our control Is Yale acting as a Data Repository for Non-Yale data? There could be cause additional regulatory requirements or legal obligations. Authentication Access: Web and application servers should never execute as Administrator, root, sa, sysman, Supervisor, or any other privileged account. Are users controls revalidated after a long period of time of being logged in? Is the access granted by the application based on a direct query of the security credential store? When user accounts are created they should not be created with the highest privilege and then moved down. Separate accounts should be used to perform administrative access versus operational business functions. Application Access should use standard authentication code. When possible avoided custom authorization code. If custom code is required ensure that if an exception is thrown, the user is logged out or at least prevented from accessing the protected resource or function. Looking for the 3 people/areas that request the access, approve the access, and create the access.
2 Role Based Access and Segregation of Duties (SOD) Segregation of Duties (SOD) - No single individual should have control over two or more phases of a transaction or operation. So security is split into activities which are assigned to different individuals. This helps to prevent the risk of fraud: o fraud is more difficult because it requires collusion of two or more persons; and o It is much more likely that innocent errors will be found. Typical Roles that need to be explained due to job function by access controls are: o Role\Access\Application Administrator o System Administrator o User Functionalities Database Web applications should access the database through one or more limited accounts that do not have schema-modification privileges unless required. Database access should be performed through parameterized stored procedures (or similar) to allow all table access to be revoked (i.e. select, drop, update, insert, etc). Database access accounts should be done using a low privilege database account that does not hold any SQL roles above user (or similar). Hosted By Consider the enterprise s dependence on third-party suppliers for security requirements, and mitigate continuity, confidentiality and intellectual property risk by implementing such measures as escrow, legal liabilities, penalties and rewards. Consider including in agreements to review and receive SAS 70, network penetration test, or other third-party reviews. Assess the professional capability of third parties. Ensure that they provide a contact person who possesses the authority to act upon enterprise security requirements and concerns IV. Internal System Application Architecture Data Transmission Security Typically looking for a VPN with encryption, PGP usage, Secure Sockets Layer (SSL), or some other type of encryption. Data At Rest Security DB field encryption OS permissions Access Controls Lists (ACL) Backup If not using centralized backup then security over the Local Backup storage device needs to be looked at.
3 Question on how data is backed up. Looking to ensure if anything happens we can recover. Logging What are you logging? In Windows you can have it set to log, but objects have to be defined. Reassess what security exceptions need to be monitored on an ongoing basis Evaluate how well the security mechanisms are operating and check for weaknesses by using such measures as intrusion detection, penetration and stress testing, and testing of contingency plans Document all violations and exceptions and ensure that they are acted upon Alerting mechanism to notify appropriate individuals that security events related to system access have occurred. Logs need to be available for audits, forensics, or prosecution Security events are not logged at the application level Without logging and monitoring the database then there is no detection for security breaches and systemic malfunctions. WebSite Questions Try to avoid improper client side authorization tokens (cookies, hidden form parameters, or request headers) as any information transmitted from the client is open to manipulation. Does the web application access the database via SA or other administrative account? Does the web application access the database via accounts using more privileges than required? Has the website been scanned? Remember if there are SQL injection or Cross Site scripting errors found the application won t go live.
4 Risks the SDR Document is trying to Identify and Control Data Classification and Criticality Improper classification of information causes inappropriate controls over the information s relative value and the appropriate controls required to prevent allowing unlawful disclosure of private information. No controls in information handling procedures Over-classification might slow down the business process due to the extra precautions required for secure handling and storage. Private Data is regarded as no longer confidential and inappropriate controls are now used Reassigned asset has confidential data/sensitive data accessible to an unauthorized user. The unauthorized exposure of sensitive data may result in legal proceedings against Yale and diminish the integrity of the Yale brand name or diminish the integrity of the data. Data being used currently is not encrypted or has weak encryption (encryption strength not appropriate). Yale and its contractors have a limit on collection, storage, or use of PHI to the minimum necessary to support services. Security responsibilities, confidentiality agreements and the contract of employment are not part of the job responsibility. Risk of theft, fraud, and misuse of company assets The process of reporting security incidents, weaknesses and software malfunctions is not defined. System Application Design (Internal or External) Model To ensure traffic is filtered by the firewall. To ensure confidential data is not moved into a less secure environment. 3 Lock data is not secure in Yale s possession at all times and throughout all business processes or system operations. Connections being used do not meet legal requirements. Processes/procedures have not been implemented to ensure 3rd party connections are appropriately authorized, documented, and managed Inappropriate access to the network itself. Lack of network redundancy can result in loss of network availability that may have a serious, perhaps a financial impact, on the business or service. Network management and security/control domains aren't in place No documentation of system and network changes can cause issues during support of the networks. No policy or communication outlining remote connecting requirements for the user or machine. Remote access is uncontrolled or unmanaged Trojan or backdoor services may be mistakenly downloaded from the Internet using the Web or e- mail, may be placed on compromised host by an attacker, or may be otherwise "planted" on a host for later use by the attacker. VPN client technology is not used during remote connectivity. Remote users do not have to create a strong VPN tunnel allowing their transmissions to be weak. If data is electronically not encrypted during transmission then it is susceptible to being sniffed and seen Access and Authentication Unauthorized access to Intellectual Property & Trade Secrets (Source Code, Research and Development Data, etc) The user may gain information that could be used to compromise the security of the domain, or perform actions that may affect the security and production.
5 Risks the SDR Document is trying to Identify and Control Failure to protect the environment against unauthorized access could result in loss of data integrity and possible data corruption resulting in external users being unable to access systems/data, and thus potentially expose Yale to a breach of agreement. Group or shared accounts obscure the actual identity of the person using the account, potential for inappropriate access. Strong authentication features are not enabled/supported Temporary, generic, guest or anonymous accounts are not monitored and used frequently. System unsuccessful logon attempt feature is not enabled or do not exist. System access is not integrated with an incident response capability Unauthorized users view, delete, or modify sensitive or proprietary information Informal or inadequate access administration monitoring processes over privileged accounts Sensitive system configuration files could be changed or deleted unauthorized or inappropriately. The longer an account does not have a password change the more people will know the accounts password Confidentiality violation, data lost or data corruption either by virus infection, worm, Trojan attack programs etc
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