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Communicating Compliance Requirements Accurately Is Critical

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It's one thing to instruct programmers to write security-responsible code and to demand that administrators maintain it; it's another for them to actually know what that means. Someone has to start the "compliance" ball rolling. Who exactly does that, and how do the compliance requirements get filtered down through an organization?

Compliance Begins at the Top

Somewhere in an organization, someone realizes that unless "things" occur, the organization isn't going to be in compliance. This epiphany may occur with the CEO, the board of directors, the organization's legal counsel, or the director of IT. It doesn't really matter where the idea comes; what matters is that upper-level management agrees with it, approves plans for it, and funds it. Once upper management decides that the organization must be in "compliance," they typically appoint one person to be in charge of said compliance. At this point, there is often no definition of what exactly the organization must be in compliance with, and most certainly, there are no implementation details available for programmers or system administrators.

The person anointed to be in charge of compliance may be the Chief Security Officer, the Chief Compliance Officer, the director of IT, or some other person (hereafter referred to as "the appointee"). It doesn't actually matter who the appointee is as long as this person has upper-level management support, funding, and power to effect the changes required by the organization to become compliant. Depending on the size of the organization, the appointee may work alone on the task of bringing the organization into compliance. Or, in larger organizations, the appointee typically forms a committee to address compliance issues. Unfortunately, in some organizations, management heaps this responsibility onto an already overworked system administrator!

(Note: Numerous aspects of "compliance" exist. For example, one aspect of SOX compliance means that the finance department must follow general accepted accounting principles, etc. This article focuses on data compliance issues.)

Determining What Compliance Means to an Organization

An organization's IT compliance requirements hinge on the data stored on the systems. Obviously, if data stored on the system falls under the definition of Electronic Protected Health Information (EPHI) under the Health Insurance Portability and Accountability Act (HIPAA), the organization must follow HIPAA's IT-compliance requirements. If credit card information is stored on the system, the organization must comply with the Payment Card Industry's (PCI) Data Security Standards. The first thing the appointee must do is determine the type of data stored on the organization's systems so the process of determining what the organization must comply with can begin.

In addition, some compliance requirements are based on an organization's specific industry segment. For example, the finance industry has specific data retention policies. If the appointee isn't familiar with these industry requirements, speaking with the organization's director of IT, legal counsel, and database administrator (DBA) should provide enough information or pointers to documentation to be able to derive the compliance requirements.

Much less obvious, but still important to discover, are laws enacted by the states in which the organization operates. For example, over 25 states have enacted "breach notification" laws. These laws require that organizations that retain state residents' private information notify those residents if the data is compromised. Unfortunately, states have not been consistent in writing these laws, so the appointee will need to read the law for each state in which the organization does business. Also, if the organization is multi-national, the appointee will need to research the data privacy and breach notification laws of the appropriate countries. The organization's legal counsel may be able to help clarify questions in this area as well as determine how the laws apply to the organization.

What can easily be missed in this analysis is data that falls outside of any regulatory or legal-compliance requirements but is critical to the organization. The organization itself needs to have compliance requirements for this type of data.

Classification of Data

The appointee's analysis should lead to a formal classification of data if this hasn't already been done. This information is then documented in the organization's security policy, and examples are provided in the standard for each operating system. The documentation defines each level of data and identifies how each level of data is to be handled. The exact terminology used for each level is unimportant as long as it is easily understood by those reading the documentation and those tasked with ongoing data classification. It is also unimportant how many levels are defined. You need as many as necessary to distinguish between levels of data. Too many levels and things will be too complex. Too few and the appropriate controls cannot be applied to the data. Here are some examples of levels or classifications of data:

  • Private—Private data includes social security numbers (SSNs), bank accounts, etc. It is important that the policy state the organization's definition and provide examples of private data. I've seen this definition vary between organizations. Having a specific definition eliminates the guesswork for the system administrators and programmers working with the data.
  • Credit card numbers—This definition includes what part of the credit card information can be stored, which parts must be masked when displayed, etc. If these details are not in the policy itself, a reference to where these details are kept needs to be provided. This is vital information that programmers can then refer to when writing applications that deal with credit card numbers.
  • Company-restricted—This data is restricted to a subset of employees. Salary information is an example.
  • Company-confidential—This data can be viewed by all employees but is not for general use. The company's financial information may be an example.
  • Public—This data can be viewed or used by employees or the general public. A retail price list is an example.

As part of the definition, the following should also be provided:

  • Who (what role) has access to the data—An example of information provided by this statement is "private data is to be accessed only through the application providing the information unless the data owner grants specific approval."
  • How the data is secured—An example of this statement is "access to private data is to be 'deny by default.' " This is where the corresponding operating system standard is vital. Compliance cannot be attained unless this statement is implemented properly. Each operating system standard needs to provide examples of properly securing each type of data using the respective operating system terminology and user interfaces.
  • How long the data is retained—This is where industry-specific retention periods should be documented. Lacking specific regulations, organizations should determine the retention period based on the needs of the business.
  • What method should be used to dispose of the data—Examples of information that should be provided for this are "all hard-copy reports containing private data should be cross-cut shredded." Or "deleting databases containing private data must be rendered unreadable." The operating system standard should further expand on this topic. For example, the standard for Windows may describe the "scrubbing" or "bleaching" software that is to be used when deleting private data from a PC.
  • Whether the data needs to be encrypted—If the data needs to be encrypted, the method of encryption must be described. This should also include whether the data in transmission needs to be encrypted (using an SSL session, for example). The corresponding operating system standard should describe the methods (third-party software, hardware, or integrated operating system functions) used to encrypt the data.
  • What use of the data is appropriate—For example, the policy might state that "use of private data is strictly limited to those whose job responsibility it is to maintain the data." All access to private data—even through application interfaces—must be approved by the data owner. This statement prevents a department outside of HR from having a programmer write a program that provides all employees' social security numbers without first getting approval from the HR director (that is, the owner of the data).

Keeping Up

To ensure that the appointee stays current with the latest compliance requirements, he or she must spend time reading and doing research. For example, trade publications for the organization's industry segment often have articles on new or changing regulations as well as warnings about upcoming compliance deadlines. General-information security publications and publications specifically targeted at the Chief Security Officer often publish compliance-related articles.

In addition, the appointee needs to keep up with where the organization is going with technology. Expanding the business into e-commerce, for example, has obvious compliance implications if the business starts to collect and retain customers' credit card numbers.

Maintaining Compliance

An organization's compliance status can start to degrade because of, for example, personnel changes, a disgruntled employee who circumvents the process because he "can't get the job done any other way," or a new application that collects customers' private data is proposed for the organization's Web site.

To maintain compliance, the appointee needs to work with the DBA and/or programming staff to understand new and changing applications. In addition, the appointee—together with system administrators and programming managers—needs to develop tests and tools that can easily verify that system and application configuration settings remain in compliance with the policy and that processes developed when compliance was first addressed are still being followed. For example, application objects should be examined to ensure they maintain the approved security settings. Objects will have the correct settings if the change management process is followed (properly configured, change management software takes care of this for the programmer). However, a programmer who has the capability may bypass the change management process. Regularly checking the application's configuration confirms compliance with the organization's policy as well as the change management process.

In addition, the entire security policy needs to be reviewed and approved by upper management and new or updated sections disseminated to the appropriate groups. This exercise should occur at least annually or whenever a major technology shift or organizational change occurs. For example, if the organization creates a Web site that collects and retains credit card numbers, the organization's data classification section must be updated. Furthermore, the appropriate operating system's standard must include the requirements of complying with the PCI data security standards.

Most organizations have a policy specifically written for every employee to read and sign. This often occurs during new-employee orientation. But management in IT has an additional responsibility to ensure that new employees in their area are educated on the parts of the policy and corresponding standards that pertain specifically to them.

Communication Is Key

The changes that IT must go through to resolve data compliance issues usually require significant effort. Staying in compliance also requires effort. In particular, it requires good communication between the appointee, system administrators, and the programming staff to ensure all parties continue to understand all aspects of their organization as well as any regulatory issues that affect their organization's data compliance requirements.

Carol Woodbury is co-founder of SkyView Partners, Inc., a firm specializing in security policy compliance and assessment software as well as security services. Carol is the former Chief Security Architect for AS/400 for IBM in Rochester, Minnesota, and has specialized in security architecture, design, and consulting for more than 15 years. Carol speaks around the world on a variety of security topics and is coauthor of the book Experts' Guide to OS/400 and i5/OS Security

Carol Woodbury

Carol Woodbury is President and CTO of DXR Security and has over 30 years’ experience with IBM i Security. She started her career as Security Team Leader and Chief Engineering Manager for iSeries Security at IBM in Rochester, MN. Since leaving IBM, she has co-founded two companies – SkyView Partners and DXR Security - both focused on helping organizations achieve their IBM i Security goals. Her practical experience together with her intimate knowledge of the system combine for a unique viewpoint and experience level that cannot be matched.

Carol is known world-wide as an author and award-winning speaker on security technology, specializing in IBM i Security topics. She has written seven books on IBM i Security. Carol has been named an IBM Champion since 2018 and holds her CISSP, CRISC and PCIP security certifications.


MC Press books written by Carol Woodbury available now on the MC Press Bookstore.

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    SB PowerTech WC GenericMalicious programs can bring entire businesses to their knees—and IBM i shops are not immune. It’s critical to grasp the true impact malware can have on IBM i and the network that connects to it. Attend this webinar to gain a thorough understanding of the relationships between:

    • Viruses, native objects, and the integrated file system (IFS)
    • Power Systems and Windows-based viruses and malware
    • PC-based anti-virus scanning versus native IBM i scanning

    There are a number of ways you can minimize your exposure to viruses. IBM i security expert Sandi Moore explains the facts, including how to ensure you're fully protected and compliant with regulations such as PCI.

     

     

  • Fight Cyber Threats with IBM i Encryption

    SB PowerTech WC GenericCyber attacks often target mission-critical servers, and those attack strategies are constantly changing. To stay on top of these threats, your cybersecurity strategies must evolve, too. In this session, IBM i security expert Robin Tatam provides a quick recap of IBM i security basics and guides you through some advanced cybersecurity techniques that can help you take data protection to the next level. Robin will cover:

    • Reducing the risk posed by special authorities
    • Establishing object-level security
    • Overseeing user actions and data access

     

     

     

  • 10 Practical IBM i Security Tips for Surviving Covid-19 and Working From Home

    SB PowerTech WC GenericNow that many organizations have moved to a work from home model, security concerns have risen.

    During this session Carol Woodbury will discuss the issues that the world is currently seeing such as increased malware attacks and then provide practical actions you can take to both monitor and protect your IBM i during this challenging time.

     

  • How to Transfer IBM i Data to Microsoft Excel

    SB_HelpSystems_WC_Generic3 easy ways to get IBM i data into Excel every time
    There’s an easy, more reliable way to import your IBM i data to Excel? It’s called Sequel. During this webinar, our data access experts demonstrate how you can simplify the process of getting data from multiple sources—including Db2 for i—into Excel. Watch to learn how to:

    • Download your IBM i data to Excel in a single step
    • Deliver data to business users in Excel via email or a scheduled job
    • Access IBM i data directly using the Excel add-in in Sequel

    Make 2020 the year you finally see your data clearly, quickly, and securely. Start by giving business users the ability to access crucial business data from IBM i the way they want it—in Microsoft Excel.

     

     

  • HA Alternatives: MIMIX Is Not Your Only Option on IBM i

    SB_HelpSystems_WC_GenericIn this recorded webinar, our experts introduce you to the new HA transition technology available with our Robot HA software. You’ll learn how to:

    • Transition your rules from MIMIX (if you’re happy with them)
    • Simplify your day-to-day activities around high availability
    • Gain back time in your work week
    • Make your CEO happy about reducing IT costs

    Don’t stick with a legacy high availability solution that makes you uncomfortable when transitioning to something better can be simple, safe, and cost-effective.

     

     

  • Node Webinar Series Pt. 1: The World of Node.js on IBM i

    SB Profound WC GenericHave you been wondering about Node.js? Our free Node.js Webinar Series takes you from total beginner to creating a fully-functional IBM i Node.js business application.
    Part 1 will teach you what Node.js is, why it's a great option for IBM i shops, and how to take advantage of the ecosystem surrounding Node.
    In addition to background information, our Director of Product Development Scott Klement will demonstrate applications that take advantage of the Node Package Manager (npm).
    Watch Now.

  • The Biggest Mistakes in IBM i Security

    SB Profound WC Generic The Biggest Mistakes in IBM i Security
    Here’s the harsh reality: cybersecurity pros have to get their jobs right every single day, while an attacker only has to succeed once to do incredible damage.
    Whether that’s thousands of exposed records, millions of dollars in fines and legal fees, or diminished share value, it’s easy to judge organizations that fall victim. IBM i enjoys an enviable reputation for security, but no system is impervious to mistakes.
    Join this webinar to learn about the biggest errors made when securing a Power Systems server.
    This knowledge is critical for ensuring integrity of your application data and preventing you from becoming the next Equifax. It’s also essential for complying with all formal regulations, including SOX, PCI, GDPR, and HIPAA
    Watch Now.

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  • Backup and Recovery on IBM i: Your Strategy for the Unexpected

    SB HelpSystems SC 5413Robot automates the routine tasks of iSeries backup and recovery, saving you time and money and making the process safer and more reliable. Automate your backups with the Robot Backup and Recovery Solution. Key features include:
    - Simplified backup procedures
    - Easy data encryption
    - Save media management
    - Guided restoration
    - Seamless product integration
    Make sure your data survives when catastrophe hits. Try the Robot Backup and Recovery Solution FREE for 30 days.

  • Manage IBM i Messages by Exception with Robot

    SB HelpSystems SC 5413Managing messages on your IBM i can be more than a full-time job if you have to do it manually. How can you be sure you won’t miss important system events?
    Automate your message center with the Robot Message Management Solution. Key features include:
    - Automated message management
    - Tailored notifications and automatic escalation
    - System-wide control of your IBM i partitions
    - Two-way system notifications from your mobile device
    - Seamless product integration
    Try the Robot Message Management Solution FREE for 30 days.

  • Easiest Way to Save Money? Stop Printing IBM i Reports

    SB HelpSystems SC 5413Robot automates report bursting, distribution, bundling, and archiving, and offers secure, selective online report viewing.
    Manage your reports with the Robot Report Management Solution. Key features include:

    - Automated report distribution
    - View online without delay
    - Browser interface to make notes
    - Custom retention capabilities
    - Seamless product integration
    Rerun another report? Never again. Try the Robot Report Management Solution FREE for 30 days.

  • Hassle-Free IBM i Operations around the Clock

    SB HelpSystems SC 5413For over 30 years, Robot has been a leader in systems management for IBM i.
    Manage your job schedule with the Robot Job Scheduling Solution. Key features include:
    - Automated batch, interactive, and cross-platform scheduling
    - Event-driven dependency processing
    - Centralized monitoring and reporting
    - Audit log and ready-to-use reports
    - Seamless product integration
    Scale your software, not your staff. Try the Robot Job Scheduling Solution FREE for 30 days.

  • ACO MONITOR Manages your IBM i 24/7 and Notifies You When Your IBM i Needs Assistance!

    SB DDL Systems 5429More than a paging system - ACO MONITOR is a complete systems management solution for your Power Systems running IBM i. ACO MONITOR manages your Power System 24/7, uses advanced technology (like two-way messaging) to notify on-duty support personnel, and responds to complex problems before they reach critical status.

    ACO MONITOR is proven technology and is capable of processing thousands of mission-critical events daily. The software is pre-configured, easy to install, scalable, and greatly improves data center efficiency.