Information protection policy

For any given risk, Executive Management can choose to accept the risk based upon the relative low value of the asset, the relative low frequency of occurrence, and the relative low impact on the business. Or, leadership may choose to mitigate the risk by selecting and implementing appropriate control measures to reduce the risk. In some cases, the risk can be transferred to another business by buying insurance or out-sourcing to another business. The reality of some risks may be disputed. In such cases leadership may choose to deny the risk.

 

Controls

When Management chooses to mitigate a risk, they will do so by implementing one or more of three different types of controls.

 

Administrative

Administrative controls (also called procedural controls) consist of approved written policies, procedures, standards and guidelines. Administrative controls form the framework for running the business and managing people. They inform people on how the business is to be run and how day to day operations are to be conducted. Laws and regulations created by government bodies are also a type of administrative control because they inform the business. Some industry sectors have policies, procedures, standards and guidelines that must be followed – the Payment Card Industry (PCI) Data Security Standard required by Visa and Master Card is such an example. Other examples of administrative controls include the corporate security policy, password policy, hiring policies, and disciplinary policies.

 

Administrative controls form the basis for the selection and implementation of logical and physical controls. Logical and physical controls are manifestations of administrative controls. Administrative controls are of paramount importance.

 

Logical

Logical controls (also called technical controls) use software and data to monitor and control access to information and computing systems. For example: passwords, network and host based firewalls, network intrusion detection systems, access control lists, and data encryption are logical controls.

An important logical control that is frequently overlooked is the principle of least privilege. The principle of least privilege requires that an individual, program or system process is not granted any more access privileges than are necessary to perform the task. A blatant example of the failure to adhere to the principle of least privilege is logging into Windows as user Administrator to read Email and surf the Web. Violations of this principle can also occur when an individual collects additional access privileges over time. This happens when employees' job duties change, or they are promoted to a new position, or they transfer to another department. The access privileges required by their new duties are frequently added onto their already existing access privileges which may no longer be necessary or appropriate.

 

Physical

Physical controls monitor and control the environment of the work place and computing facilities. They also monitor and control access to and from such facilities. For example: doors, locks, heating and air conditioning, smoke and fire alarms, fire suppression systems, cameras, barricades, fencing, security guards, cable locks, etc. Separating the network and work place into functional areas are also physical controls.

 

An important physical control that is frequently overlooked is the separation of duties. Separation of duties ensures that an individual can not complete a critical task by himself. For example: an employee who submits a request for reimbursement should not also be able to authorize payment or print the check. An applications programmer should not also be the server administrator or the database administrator – these roles and responsibilities must be separated from one another.

 

Defense in depth

Information security must protect information throughout the life span of the information, from the initial creation of the information on through to the final disposal of the information. The information must be protected while in motion and while at rest. During its lifetime, information may pass through many different information processing systems and through many different parts of information processing systems. There are many different ways the information and information systems can be threatened. To fully protect the information during its lifetime, each component of the information processing system must have its own protection mechanisms. The building up, layering on and overlapping of security measures is called defense in depth. The strength of any system is no greater than its weakest link. Using a defence in depth strategy, should one defensive measure fail there are other defensive measures in place that continue to provide protection.

Recall the earlier discussion about administrative controls, logical controls, and physical controls. The three types of controls can be used to form the basis upon which to build a defense-in-depth strategy. With this approach, defense-in-depth can be conceptualized as three distinct layers or planes laid one on top of the other. Additional insight into defense-in- depth can be gained by thinking of it as forming the layers of an onion, with data at the core of the onion, people the next outer layer of the onion, and network security, host-based security and application security forming the outermost layers of the onion. Both perspectives are equally valid and each provides valuable insight into the implementation of a good defense-in-depth strategy.

 

Security classification for information

An important aspect of information security and risk management is recognizing the value of information and defining appropriate procedures and protection requirements for the information. Not all information is equal and so not all information requires the same degree of protection. This requires information to be assigned a security classification.

 

The first step in information classification is to identify a member of senior management as the owner of the particular information to be classified. Next, develop a classification policy. The policy should describe the different classification labels, define the criteria for information to be assigned a particular label, and list the required security controls for each classification.

Some factors that influence which classification information should be assigned include how much value that information has to the organization, how old the information is and whether or not the information has become obsolete. Laws and other regulatory requirements are also important considerations when classifying information.

The type of information security classification labels selected and used will depend on the nature of the organisation, with examples being:

In the business sector, labels such as: Public, Sensitive, Private, Confidential.

In the government sector, labels such as: Unclassified, Sensitive But Unclassified, Restricted, Confidential, Secret, Top Secret and their non-English equivalents.

In cross-sectoral formations, the Traffic Light Protocol, which consists of: White, Green, Amber and Red.

All employees in the organization, as well as business partners, must be trained on the classification schema and understand the required security controls and handling procedures for each classification. The classification of a particular information asset has been assigned should be reviewed periodically to ensure the classification is still appropriate for the information and to ensure the security controls required by the classification are in place.

 

Access control

Access to protected information must be restricted to people who are authorized to access the information. The computer programs, and in many cases the computers that process the information, must also be authorized. This requires that mechanisms be in place to control the access to protected information. The sophistication of the access control mechanisms should be in parity with the value of the information being protected – the more sensitive or valuable the information the stronger the control mechanisms need to be. The foundation on which access control mechanisms are built start with identification and authentication.

 

Identification is an assertion of who someone is or what something is. If a person makes the statement "Hello, my name is John Doe" they are making a claim of who they are. However, their claim may or may not be true. Before John Doe can be granted access to protected information it will be necessary to verify that the person claiming to be John Doe really is John Doe.

Authentication is the act of verifying a claim of identity. When John Doe goes into a bank to make a withdrawal, he tells the bank teller he is John Doe (a claim of identity). The bank teller asks to see a photo ID, so he hands the teller his driver's license. The bank teller checks the license to make sure it has John Doe printed on it and compares the photograph on the license against the person claiming to be John Doe. If the photo and name match the person, then the teller has authenticated that John Doe is who he claimed to be.

 

There are three different types of information that can be used for authentication: something you know, something you have, or something you are. Examples of something you know include such things as a PIN, a password, or your mother's maiden name. Examples of something you have include a driver's license or a magnetic swipe card. Something you are refers to biometrics. Examples of biometrics include palm prints, finger prints, voice prints and retina (eye) scans. Strong authentication requires providing information from two of the three different types of authentication information. For example, something you know plus something you have. This is called two factor authentications.

 

On computer systems in use today, the Username is the most common form of identification and the Password is the most common form of authentication. Usernames and passwords have served their purpose but in our modern world they are no longer adequate. Usernames and passwords are slowly being replaced with more sophisticated authentication mechanisms.

 

After a person, program or computer has successfully been identified and authenticated then it must be determined what informational resources they are permitted to access and what actions they will be allowed to perform (run, view, create, delete, or change).

Authorization to access information and other computing services begins with administrative policies and procedures. The policies prescribe what information and computing services can be accessed, by whom, and under what conditions. The access control mechanisms are then configured to enforce these policies.

 

Different computing systems are equipped with different kinds of access control mechanisms - some may even offer a choice of different access control mechanisms. The access control mechanism a system offers will be based upon one of three approaches to access control or it may be derived from a combination of the three approaches.

 

The non-discretionary approach consolidates all access control under a centralized administration. The access to information and other resources is usually based on the individuals function (role) in the organization or the tasks the individual must perform. The discretionary approach gives the creator or owner of the information resource the ability to control access to those resources. In the Mandatory access control approach, access is granted or denied basing upon the security classification assigned to the information resource.

 

Examples of common access control mechanisms in use today include Role-based access control available in many advanced Database Management Systems, simple file permissions provided in the UNIX and Windows operating systems, Group Policy Objects provided in Windows network systems, Kerberos, RADIUS, TACACS, and the simple access lists used in many firewalls and routers.

 

To be effective, policies and other security controls must be enforceable and upheld. Effective policies ensure that people are held accountable for their actions. All failed and successful authentication attempts must be logged, and all access to information must leave some type of audit trail.

 

Cryptography

Information security uses cryptography to transform usable information into a form that renders it unusable by anyone other than an authorized user; this process is called encryption. Information that has been encrypted (rendered unusable) can be transformed back into its original usable form by an authorized user, who possesses the cryptographic key, through the process of decryption. Cryptography is used in information security to protect information from unauthorized or accidental disclosure while the information is in transit (either electronically or physically) and while information is in storage.

 

Cryptography provides information security with other useful applications as well including improved authentication methods, message digests, digital signatures, non-repudiation, and encrypted network communications. Older less secure application such as telnet and ftp are slowly being replaced with more secure applications such as ssh that use encrypted network communications. Wireless communications can be encrypted using protocols such as WPA/WPA2 or the older (and less secure) WEP. Wired communications (such as ITU-T G.hn) are secured using AES for encryption and X.1035 for authentication and key exchange. Software applications such as GnuPG or PGP can be used to encrypt data files and Email.

 

Cryptography can introduce security problems when it is not implemented correctly. Cryptographic solutions need to be implemented using industry accepted solutions that have undergone rigorous peer review by independent experts in cryptography. The length and strength of the encryption key is also an important consideration. A key that is weak or too short will produce weak encryption. The keys used for encryption and decryption must be protected with the same degree of rigor as any other confidential information. They must be protected from unauthorized disclosure and destruction and they must be available when needed. PKI solutions address many of the problems that surround key management.

Process

The terms reasonable and prudent person, due care and due diligence have been used in the fields of Finance, Securities, and Law for many years. In recent years these terms have found their way into the fields of computing and information security. U.S.A. Federal Sentencing Guidelines now make it possible to hold corporate officers liable for failing to exercise due care and due diligence in the management of their information systems.

 

In the business world, stockholders, customers, business partners and governments have the expectation that corporate officers will run the business in accordance with accepted business practices and in compliance with laws and other regulatory requirements. This is often described as the "reasonable and prudent person" rule. A prudent person takes due care to ensure that everything necessary is done to operate the business by sound business principles and in a legal ethical manner. A prudent person is also diligent (mindful, attentive, and ongoing) in their due care of the business. In the field of Information Security, Harris[9] offers the following definitions of due care and due diligence:

 

"Due care are steps that are taken to show that a company has taken responsibility for the activities that take place within the corporation and has taken the necessary steps to help protect the company, its resources, and employees." And, [Due diligence are the] "continual activities that make sure the protection mechanisms are continually maintained and operational."

 

Attention should be made to two important points in these definitions. First, in due care, steps are taken to show - this means that the steps can be verified, measured, or even produce tangible artifacts. Second, in due diligence, there are continual activities - this means that people are actually doing things to monitor and maintain the protection mechanisms, and these activities are ongoing.

 

Security governance

The Software Engineering Institute at Carnegie Mellon University, in a publication titled "Governing for Enterprise Security (GES)", defines characteristics of effective security governance. These include:

• An enterprise-wide issue
• Leaders are accountable
• Viewed as a business requirement
• Risk-based
• Roles, responsibilities, and segregation of duties defined
• Addressed and enforced in policy
• Adequate resources committed
• Staff aware and trained
• A development life cycle requirement
• Planned, managed, measurable, and measured
• Reviewed and audited

 

Change management

Change management is a formal process for directing and controlling alterations to the information processing environment. This includes alterations to desktop computers, the network, servers and software. The objectives of change management are to reduce the risks posed by changes to the information processing environment and improve the stability and reliability of the processing environment as changes are made. It is not the objective of change management to prevent or hinder necessary changes from being implemented.

 

Any change to the information processing environment introduces an element of risk. Even apparently simple changes can have unexpected effects. One of Managements many responsibilities is the management of risk. Change management is a tool for managing the risks introduced by changes to the information processing environment. Part of the change management process ensures that changes are not implemented at inopportune times when they may disrupt critical business processes or interfere with other changes being implemented.

 

Not every change needs to be managed. Some kinds of changes are a part of the everyday routine of information processing and adhere to a predefined procedure, which reduces the overall level of risk to the processing environment. Creating a new user account or deploying a new desktop computer are examples of changes that do not generally require change management. However, relocating user file shares, or upgrading the Email server pose a much higher level of risk to the processing environment and are not a normal everyday activity. The critical first steps in change management are (a) defining change (and communicating that definition) and (b) defining the scope of the change system.

 

Change management is usually overseen by a Change Review Board composed of representatives from key business areas, security, networking, systems administrators, Database administration, applications development, desktop support and the help desk. The tasks of the Change Review Board can be facilitated with the use of automated work flow application. The responsibility of the Change Review Board is to ensure the organizations documented change management procedures are followed. The change management process is as follows:

Requested: Anyone can request a change. The person making the change request may or may not be the same person that performs the analysis or implements the change. When a request for change is received, it may undergo a preliminary review to determine if the requested change is compatible with the organizations business model and practices, and to determine the amount of resources needed to implement the change.

Approved: Management runs the business and controls the allocation of resources therefore, Management must approve requests for changes and assign a priority for every change. Management might choose to reject a change request if the change is not compatible with the business model, industry standards or best practices. Management might also choose to reject a change request if the change requires more resources than can be allocated for the change.

Planned: Planning a change involves discovering the scope and impact of the proposed change; analyzing the complexity of the change; allocation of resources and, developing, testing and documenting both implementation and backout plans. Need to define the criteria on which a decision to back out will be made.

Tested: Every change must be tested in a safe test environment, which closely reflects the actual production environment, before the change is applied to the production environment. The backout plan must also be tested.

Scheduled: Part of the change review board's responsibility is to assist in the scheduling of changes by reviewing the proposed implementation date for potential conflicts with other scheduled changes or critical business activities.

Communicated: Once a change has been scheduled it must be communicated. The communication is to give others the opportunity to remind the change review board about other changes or critical business activities that might have been overlooked when scheduling the change. The communication also serves to make the Help Desk and users aware that a change is about to occur. Another responsibility of the change review board is to ensure that scheduled changes have been properly communicated to those who will be affected by the change or otherwise have an interest in the change.

Implemented: At the appointed date and time, the changes must be implemented. Part of the planning process was to develop an implementation plan, testing plan and, a back out plan. If the implementation of the change should fail or, the post implementation testing fails or, other "drop dead" criteria have been met, the back out plan should be implemented.

Documented: All changes must be documented. The documentation includes the initial request for change, its approval, the priority assigned to it, the implementation, testing and back out plans, the results of the change review board critique, the date/time the change was implemented, who implemented it, and whether the change was implemented successfully, failed or postponed.

Post change review: The change review board should hold a post implementation review of changes. It is particularly important to review failed and backed out changes. The review board should try to understand the problems that were encountered, and look for areas for improvement.

Change management procedures that are simple to follow and easy to use can greatly reduce the overall risks created when changes are made to the information processing environment. Good change management procedures improve the over all quality and success of changes as they are implemented. This is accomplished through planning, peer review, documentation and communication.

ISO/IEC 20000, The Visible OPS Handbook: Implementing ITIL in 4 Practical and Auditable Steps[10] (Full book summary),[11] and Information Technology Infrastructure Library all provide valuable guidance on implementing an efficient and effective change management program information security.

 

Business continuity 

Business continuity is the mechanism by which an organization continues to operate its critical business units, during planned or unplanned disruptions that affect normal business operations, by invoking planned and managed procedures.

 

Unlike what most people think business continuity is not necessarily an IT system or process, simply because it is about the business. Today disasters or disruptions to business are a reality. Whether the disaster is natural or man-made, it affects normal life and so business. So why is planning so important? Let us face reality that "all businesses recover", whether they planned for recovery or not, simply because business is about earning money for survival.

 

The planning is merely getting better prepared to face it, knowing fully well that the best plans may fail. Planning helps to reduce cost of recovery, operational overheads and most importantly sail through some smaller ones effortlessly.