An Auditor's Perspective on Frameworks for Information Systems Security in Higher Education

1. An Auditor's Perspective on Frameworks for Information Systems Security in Higher Education Erwin “Chris” Carrow, University System of Georgia Brian Markham, University of Maryland, College Park Copyright Erwin L. Carrow & Brian Markham 2009. This work is the intellectual property of the author. Permission is granted for this material to be shared for non-commercial, educational purposes, provided that this copyright statement appears on the reproduced materials and notice is given that the copying is by permission of the author and other identified entities. To disseminate otherwise or to republish requires written permission from the author. Videos and specific graphics presented are not for public distribution.

2. Session Agenda • Key Takeaways and Introductions • What Makes Higher Education Different • Business Risk and Functional Practices • Internal Controls: Quick Overview • Frameworks for Security • Specific Guidance and Standards • Additional Audit Considerations • Q&A

3. Key Takeaways • At the end of this session you should be able to: • Identify business goals, functions, and associated roles and risk; • Understand the critical success factors during an audit; • Evaluate the internal control structure of your environment; • Know the standards and frameworks available for use in your environment;

4. Your Session Guides • Erwin “Chris” Carrow - IT Auditor, University System of Georgia Board of Regents • High level • General focus • Brian Markham - IT Compliance Specialist, University of Maryland at College Park • Low level • Specific focus

5. Auditing Higher Education: Challenges and Business Requirements Where are you at? Can seem like … HERDING CATS! EDS “Cat Herding” 1:07 minutes

6. What Makes Higher Education Similar and Yet Different? • Universities are not Corporations, but … • Herding Cats may be a common or predominate phenomena • Business functions and processes are similar • Objectives, rules and requirements are similar • Resources, e.g., people information, infrastructure, applications, etc. • Different set of risks, challenges, and regulatory mandates • “Open System” Attitude (moving target)! “Academic Freedom” is a privilege, not a right! • Diversity of administrative operational requirements • Diversity of instructional and faculty requirements • Operational and Functional sides of the house not always in agreement – leadership changes and challenges do exist! • Freedom of information • Difficulties in blocking or outlawing certain risky behaviors • Mandated safe guard information and information systems • Bottom-line: Environment must foster Learning and Research!

7. Auditors Ask the Question…What High Criticality Risks Exist? Categories of risk that may or may not apply: • Strategic : Affects the entities’ ability to achieve goals and objectives • Compliance : Affects compliance with laws and regulations, safety and environmental issues, litigation, conflicts of interest, etc. • Reputational : Affects reputation, public perception, political issues, etc. • Financial : Affects loss of assets, technology, etc. • Operational : Affects on-going management processes and procedures

8. Enterprise Risk Management -Risk Probability and Impact

9. Threats and the Facts • Privacy Right Clearinghouse • Chronology of Data Breaches 2,500,000sinceJanuary 2005 that have been reported [www.privacyrights.org/ar/ChronDataBreaches.htm] • Ponemon –HRH 2008 Privacy Breach Index Survey (Sept 2008) • Self evaluation of overall performance of organization: -- 9% gave an “A” -- 31% gave a “B” -- 26% gave a ”C” -- 29% gave a “D” – 5% gave a “F” [www.HRH.com/privacy] • 80 % believed their organizations experienced information system data breaches and loss of customer and personal information • 50% Negligence, -- 29% Third-Party, 3% Hacker, --1% other criminal activity; • 36% 1 to 4 breaches involving 100 or records; 32% 5 to 8; 31% 9 or more

10. Recognized Method for … Risk Prevention Assurance Risk Prevention “IT Trunk Monkey” 1:01 minutes

11. Regulatory Standards • FERPA, FISMA, HIPAA, PCI DSS, SOX, NCAA, A-21, A-133, PATRIOT, GLBA, ADA, CAA, CWA, OSHA, FLSA, FMLA, EEO, and possibly many others! • State, Local, and University System and Institution Guidelines • “Due Negligence” violations have cost institutions financially, but few if any individuals have gone to jail for lack of compliance • Reputational losses are the critical issue! • Avoid FUD – Fear, Uncertainty, and Doubt

12. Information Security and Compliance Responsibilities • Know and comply with Federal, State, Local, and University System and Institution Regulations • Talk to auditors, colleagues, peers, and administrators about information and information system regulatory compliance and security • Make the “alphabet soup” and security a top priority when evaluating new systems and initiatives • Understand how the regulations trickle down to through policies, standards, procedures, and the people involved (in a practical method)

13. What should a Risk Assessment identify about our environment? • What are the risks? • What are the impacts? • What is the likelihood it will happen? • Who is involved? • Are we willing to accept the risk? • What are we currently doing to mitigate this risk? Is it working like we think it should?

14. Making the Lose/Lose Situation … a Win/Win • A PERFECT information technology operational environment or risk prevention assurance system does not exist(e.g., IT Trunk Monkey)! • Priority directed to likely threats for known vulnerabilities by: • Affirming good controls and practices • Uncovering unknown vulnerabilities or inappropriate practices • Focus upon what is essential for the success of Your Institutions “Business Functions.” Which comprise of: • Business Rules or Requirements: A statement that defines or constrains some aspect of the business. It is intended to assert business structure or to control or influence the behavior of the business. • Business Standards or Practices: A related group of business processes that support some aspects of the mission of an enterprise.

15. Doing Business and Dealing with the NutsThe Old Way…! Assessing Risk? 20th Century FOX “Ice Age” 1:55 min/sec

16. Nuts Can Be ChallengingBusiness Process – Gathering and Storing NUTS and the Big Squeeze • Tasks of Dealing with the NUTS– • 1. Gather Nuts • 2. Store Nuts • 3. The Big Squeeze? Operational versus Functional needs! • What are the Associated Risks? 20th Century FOX “Ice Age”

17. In Time, Nut Requirements ChangeThe New Way …! Risk Assessment? 20th Century FOX “Ice Age 2: The Meltdown” 55 sec

18. Different Nuts, Different MethodsHistory has a Way of Repeating Itself! • Old Ways can Influence New Ways of …, • Different Business Requirements – Use of Different Methods (Variety of NUTS) • Sometimes the NUTS get Bigger and Harder to CRACK • Risk may Change or Increase! 20th Century FOX “Ice Age 2: The Meltdown”

19. Making Peanut Butter Out of NutsMoral: Life is Always Going to Be a Little Squirrelly • Business function Goals and Objectives can make the IT requirements a little NUTTY • Risk Implications associated with IT Implementations are NOT always CONSIDERED • Clearly Define the Task: Try making PEANUT BUTTER out of a difficult situation – it is easier to Store • WHERE DO YOU START? 20th Century FOX “Ice Age 2: The Meltdown”

20. Know Yourself – Know Your Enemy! The Art of War (Chinese: 孫子兵法; pinyin: Sūn Zǐ Bīng Fǎ) is a Chinesemilitarytreatise that was written during the 6th century BC by Sun Tzu. • Two Possible not Recommended Responses to the Challenge • Freak Out:Embrace Hopelessness, Hide, Ignore, Deny, and Play Computer games until the Inevitable Occurs • Idealistic andUnrealistic:Do the “Don Quixote (To Dream the Impossible Dream and Fight the Impossible Fight)” - Wear yourself out Fighting Windmills by shooting at whatever pops its head out! • Third Approach “How do you Eat the Elephant standing in the corner, Instead of Avoid it?” Take ONE BITE at a time by… • Strategizing a Response • Create a deliberate Long term Plan • Identify Short term Objectives and Milestones • Gain Key Shareholder ownership of the challenges • Test and Monitor the process with Identifiable Outcomes • Start with Business Functions – Gathering and Storing of NUTS

21. Business Functions (other Nuts) • It still comes down to …, Business Needs and Outcomes • Goals or Objectives • Rules and Requirements • Identifying critical business functions • Finance and Accounting • Financial Aid • Human Resources • Registration • Student Services • Other administrative functions • Identify the departments and who are the key personnel, e.g., Business owner, Trustees and Stewards? • Identify the systems that support these functions • How are the people and systems integrated into the business process? • What internal controls exist to mitigate risk?

22. Business Function’s Objective, Requirements, Resources, and Practices • YOU MUST KNOW … • What Business Principles are in Operation? • Reasons -Why you do things a certain Way Control Objectives for Information and related Technology (COBIT®)

23. Business Functions and their Characteristics Control Objectives for Information and related Technology (COBIT®)

24. Business Function Information from Origin to Destination • Identify how the information travels and is managed throughout the business function life cycle! • How packets of data are managed, provisioned, formatted, and transferred throughout business functions • How information is handled per its classification and intended use • Assess information and information system security from various perspectives • Who are the business owners, trustees, and stewards?

25. “Life Cycle” of Security & Process Provisioning

26. Risk Assessment Flow • The methodology for auditing the information and information systems for compliance and security is a Top Down process • Business Goals to Standards and Practices • Business Function to Information System • Leadership (administrator) to Technician or Staff member (end user) • Assess Requirements, Resources, and Processes • The approach will focus on key business functions and their associated Business Goals and Objectives as it relates to the audited entity e.g., Identity and Access Control Management (IAM),Perimeter and Network Security (NETSEC),etc. • Once identified and agreed upon for each business function, the key associated requirements, resources, and processes will be identified and assessed to determine if high or critical risk is being managed. • Focus on Control Practices, Responsibility / Accountability, associated with key activities with an expected CMMI level 3 criteria for High Risk Critical processes.

27. Principles for Consideration • 1st Top-down Risk Based identification of threats and vulnerabilities for key Business processes and related IT support processes, e.g., change management, access security, operations, etc. (General Risk Assessment) • 2nd Control of IT Risk that affect critical IT functionality in financially significantapplications and related data (Particularized Risk Assessment) • 3rdLayered Controlsto mitigate risk for application program code, databases, operating systems, and the network (Operational processes that align with precedence of Risk) • 4thRisk mitigation based upon Business and Control objectives (not the limitations of individual controls), have a Framework, structure, and methodology to support your risk strategy

28. When Assessing for Risk … • Risk assessment evaluates components of information, information system security and compliance as it relates to the business function • Assess  Mitigate / Monitor  Re-Assess • Ongoing risk management program must be in place • Business owner or key shareholder must own the process • Establish a standard for considering and negotiating risk • Annual (periodic) risk assessment deliverable with recommendations for corrective action • Clearly define and document accepted risk – someone needs to sign off on the responsibility

29. Risk Mitigation • Once risks are identified, they must be mitigated via internal controls • Internal Controls: a practice approved by management to mitigate risk or produce a desired outcome in a business process for implementing and enforcing information security and compliance • Preventive - controls to stop the problem from occurring • Detective - controls to find the problem • Corrective - controls to repair the problem after detection • Administrative - policies, standards, guidelines, and procedures • Technical - controls using hardware or software for processing and analysis • Physical - controls to implement barriers or deterrents • Document and retain artifacts. • Design  Document  Implement • Test the controls prior to implementation to validate expectations • Monitor results • Re-test controls periodically.

30. High Level IT Control Model

31. Re-Assess Risks • Risk Assessments are an on-going exercise; • Track mitigation strategies, did they work? • What “Framework(s)” are being applied? • Is there an identifiable “Structure” in place e.g., risk management program? • Is the “Methodology” recognizable, e.g., documented and not arbitrary? • Are you using Tools to monitor, manage, and validate the associated processes? • Test, re-test controls (Design and Effectiveness) • Document test results, corrective actions, changes in business needs/requirements.

32. Better Controls = Improved Security • IT Security comes down to presence and effectiveness of internal controls; • Weak controls = weak security • Audits are an evaluation of controls, audits are FREE consulting services! • All of the security practices that we utilize are really just controls, from firewalls to IPS to virus scanning. • How these controls come together ultimately determines out overall control environment (and our control gaps). • Framework?

33. Frameworks for IT Security • COBIT - High level business objectives and outcomes • ISO & NIST - Standards and checklists for consideration • Criteria - CMMI • CIS - Tools • ITIL - Process Models • Any framework is better than NO framework! • Frameworks map to structure which should produce a consistent methodology for addressing risk • Be able to explain …! • How it was derived • Why your strategy makes sense • How it manages risk

34. COBIT • Developed by the ITGI (Current v4.1) • Value of IT, Risk, and Control • Links IT service delivery to business requirements (already defined, right?) • A lifecycle; constantly adapting, improving, re-adapting • Four Responsibility Domains: • Plan and Organize (PO) • Acquire and Implement (AI) • Deliver and Support (DS) • Monitor and Evaluate (ME) • Make a grocery list of needs and then go shopping

35. COBIT Control Objectives for Information and related Technology (COBIT®)

36. COBIT Control Objectives for Information and related Technology (COBIT®)

37. ISO 27002 • Code of Practice for Information Security Management • Divides IT Security into 11 Categories (Clauses) • Defines key controls over specific sub-categories • Defines implementation guidance for each key control • 39 Control Objectives with 139 Controls • Control objectives are generic functional requirement specifications for an organization’s information and information system security management control architecture

38. ISO 27002 IS Acquisition Mgmt Organizing IT Security Incident Mgmt Compliance Asset Mgmt Security Policy ISO 27002 HR Security BCM Access Control Physical Security Comm and Ops Mgmt

39. ISO 27002 • Benefits: • ISO 27002 is a very hands-on control guideline • DIY Framework, no consultants required • Proactive – not reactive. • Certification • Less stressful audits! • How do we get to ISO 27002? • Evaluate/Implement Key Controls; • This will require policies/processes/procedures; • Executive level buy-in; • Team effort, IT Security is EVERYONES responsibility.

40. NIST • NIST offers security guidance in many areas • Special Publications • Useful high level governance standards and practices • Practically every IT security subject is covered here • Written for the Feds but very useful for any organization • Current government agency 2007 self assessment average grade is “C-”, e.g., Academic probation • http://csrc.nist.gov/publications/PubsSPs.html

41. NIST Special Publications • Life Cycle of Risk Consideration

42. Center for Internet Security (CIS) • CIS Benchmarks provide guidelines for operating systems and databases; • User originated, widely accepted, and reflect the consensus of expert users worldwide; • Compliance with these benchmarks will reduce findings and lead to more secure computing platforms • Some benchmarks include : • Windows Server • Solaris • Oracle • Exchange

43. Center for Internet Security (CIS) • Use benchmarks from CIS for standard builds of servers, databases, and applications; • A self-appraisal/audit of current systems, builds; • Hardening guide to ward off attacks; • CIS certifies automated tools. Some providers include: • Belarc • CA • ConfigureSoft • Symantec • Tenable • Tripwire

44. CMMI • An identifiable criteria by which you should be evaluated! • Capability Maturity Model Integrated created by the Software Engineering Institute (SEI) • Level 0 - 5 (Non-Existent to Optimized)

45. CMMI • Variants of the CMMI: CMM & ISO 15504 • Identifies WHERE you are at in the application of IT risk mitigation controlsand HOW to get to the next level • Levels of Application • Level 0: No Recognizable Process, though one is needed • Level 1: Process is Ad-hoc and perform by key individuals • Level 2: Process is Repeatable , but not controlled • Level 3: Process is Defined & Documented and periodically Evaluated • Level 4: Managed & Measurable; effective Internal Controls with Risk Management • Level 5: Optimized Enterprise wide risk and control program

46. CMMI • Capability Maturity Model Integrated created by the Software Engineering Institute (SEI) • Level 0 - 5 (Non-Existent to Optimized) • Auditors need to be able to do more than “take someone's word for it” • Therefore … Level 3 is a minimum requirement • Defined processes • Documented processes to identify risk and associate roles and responsibility to mitigate risk • Processes in place to periodically review and evaluate controls

47. What Does Evidence Look Like? • Definition: Evidence must be Sufficient, Reliable and Relevant • The various types of audit evidence that the IS auditor consider using include: • Observed processes and existence of physical items, e.g., A computer room security system in operation • Documentary audit evidence, e.g., Activity and control logs, System development documentation • Representations, e.g., Written policies and procedures, System flowcharts, Written or oral statements • Analysis, e.g., Benchmarking IS performance against other organizations or past periods; Comparison of error rates between applications, transactions and users • Evidence gathering procedures considered are: Inquiry, Observation, Inspection, Confirmation, Re-performance, andMonitoring • Audit evidence should be useful to form an opinion or support the findings and conclusions. • Evidence gathered should be appropriately documented and organized to support the findings and conclusions.

48. ITIL - Process Modeling • When you don’t have a good understanding of “what right looks like” • Models most “Industry Standard “ information and information system technology processes • When in doubt “check it out and test it out” • Maps to COBIT • Complimentive to NIST and ISO • Helps to provide a starting place • Caution - can be overtly complicated

49. Example of IAM - Audited Entity to be Assessed for Risk • IAM: Identity and Access Control Management • Identity Management; the management of user credentials and the means by which users might log onto and use various systems or resources, e.g., the provisioning and de-provisioning of student, faculty, staff, and outside agencies identities • Access Control; the mechanisms in place to permit or deny the use of a particular resource by a particular entity, e.g., technical or administrative controls to allow or deny access to file shares

50. Users Involved in Business Functions and Types of System Information? (Provisioning of High Risk or Critical Information) • Business Functional responsibility for assigning “Rights & Permissions” to various roles within the organization • Business Owner: Responsible for the provisioning and delegation of the processes or functions and associated privileges, e.g., Payroll, Registrar, FinAid, HR, ConEd, etc. • Trustees: Responsible to maintain trust granted by Business owner, e.g., “Worker Bees” in the associated departments that conduct day to day operations • Stewards: Responsible to service and support the business function, typically provide a technical system or infrastructure to facilitate business needs, e.g., Information Technology Services, etc. • Types of Information (Data Classification) per institution or university system standards • Unrestricted / Public: No consequence typically general information • Sensitive: typically references’ legal or externally imposed constraints that requires this restriction • Confidential: highest level of restriction, applies to the risk or harm that may result from disclosure or inappropriate use, e.g., FERPA