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Learn about the importance of information security as a process, the role of an ISMS, and the standards organizations can aspire towards. Discover how an ISMS can help manage information security effectively and the key stages in developing an ISMS.
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COMP3371Cyber Security Richard Henson University of Worcester February 2018
Week 2: Developing an Information Security Management System (ISMS) • Objectives: • Explain why security is a process, and not just something that can be “bought” • Explain the term ISMS and how it relates to information security policy • Explain the standards an organisation can aspire towards as it develops security controls and its ISMS
Why do Organisations find Cyber Security difficult? • Each organisation is different • each has its own unique way of handling information! • Can’t just copy each other… • even with “off the shelf” software may well use it in their own way • At least one employee needs to be given responsibility & training before they can start…
Why can’t they just outsource the whole thing? • Last week’s management misconception: • data has no value • This week: • security is a process not a “thing” • US gov realised many years ago that security can’t be “done”… • Problem: took them a long time to admit that!
How can an ISMS help? • ISMS = system for managing information security in an organisation • should be in place for all organisations • Many still see information/cyber security as something they can just spend a little money on now and then • annual budget needed to run a system!
Developing an ISMS • Stage 1: senior management accepts responsibility • that means accepting they need an information security policy • Next stage is to write the policy! • then to implement policy successfully, a system needs to be in place
Information Assurance (IA) • A term introduced by US government to acknowledge that 100% information security was no longer possible… • IA is strategic… • Policy and set of organisational processes to effectively manage information security • ISMS is largely operational • putting policies into practice and checking the practice
An ISMS that is “fit for purpose” • Organisation needs to know… • [or acknowledge through the work of an analyst] • all aspects of how data is managed • Requires an understanding of processes and associated data • can then identify data flows, storage, etc… • risk assessment essential (importance of each…) • determine how much effort is needed to protect each of the data flows, data stores, etc. …
International Standard for IA and ISMS(ISO 27001) • Developed in UK as BS7799 • before the millennium (!) • Became International in 2005 • revised in 2013 • regarded as the “gold standard” • 80% of certificates held in Japan (!)
Information Assurance Standards and Certification • ISO27001 lists over 100 controls • unless explicitly stated/justified, assumes all controls are needed • risk assessment needed… no point spending money on controls where they are not needed but exemptions need justifying… • Other information assurance standards have been developed to encourage appropriate ISMS development and use
PCI DSS: Approach to Security Controls; less focus on ISMS • System devised by Credit Card Companies (i.e. banks…) • https://www.pcisecuritystandards.org/ • Guidelines for a number of years… • Now with v3 a sting in the tail for the SME • heavy fines possible • can be refused business merchant facilities… • Will affect small businesses WORLDWIDE selling online directly to consumers
Requirements for PCI DSS compliance? (1) • 12 controls (11 Technical) • Install and maintain a firewall configuration to protect cardholder data • Do not use vendor-supplied defaults for system passwords and other security parameters • Protect stored cardholder data • Encrypt transmission of cardholder data across open, public networks • Use and regularly update anti-virus software or programs
What is needed for PCI DSS compliance? (2) • Develop and maintain secure systems and applications • Restrict access to cardholder data by business need-to-know • Assign a unique ID to each person with computer access • Track and monitor all access to network resources and cardholder data • Regularly test security systems and processes • Maintain a policy that addresses information security for employees and contractors
PCI DSS issues • Is it realistic? • Is it essential? • How can it be policed? • Discussion in groups…
IASME • Standard developed for UK SMEs • same basic principles as ISO27001 • emphasis on risk assessment to reduce controls actually needed • requires some scrutiny of an organisation’s processes • more streamlined than ISO27001 • more relevant to SMEs • number of templates available to help with policy and procedure development
IASME & Cyber Essentials • IASME potentially uses 100+ controls… • designed to be more SME friendly • BUT.. ISMS development tricky for SMEs… • GCHQ introduced Cyber Essentials • now a minimum for government contracts • useful starting point! • BUT requires only 5 controls… all essentially technical • no formal requirement for an IS policy • some documented process expected… • encourages thinking about policy, procedures, ISMS
Reality of Information Security Policy? • Colleagues conducted a study (2009): • https://staffweb.worc.ac.uk/hensonr/Information%20Assurance%20Market%20Research%20v3JAAB.ppt • about 60% of businesses had a policy • consistent with a government-funded survey the previous year • BIG PROBLEM!
What is Policy? • Aseries of statements… what the organisation would like to do, and aspires to do • not effective until implemented! • What would an organisation like to do about security... Over to you!
Policy and System! • Where to start • What others have done? • What advisers advise? • Use a template and change the name? • Writing policy is easy… • writing a policy capable of implementation is the difficult bit!
Policy and the SME (like Ticketmania or FixDomestic): • Why do they need an information security policy? • Who would write it? • who would approve it • Over to you… • Remember it needs to be capable of implementation?
Policy and Technology • Policy implementation always a headache for organisations to implement • requires employee training • may cause employee unrest • Technologies can be used to implement policies • degree of success in the latter depends on: • communication of policies (and WHY!) • understanding of technologies
Creating a Policy • Same principles apply as with ANY change in organisational policy • MUST come from the top!!! • Possible implementation issues also needs to be: • identified • communicated to employees • Problem: Senior Management generally don’t understand IT… • unlikely to want to stand in front of employees and discuss… wheel an “expert” in?
Information Security Policy matters • Threats… • who will quantify? • Head of IT? (or outsourcer) • External Consultant? • both? • Who will suggest strategies to mitigate against those threats? • as above? • Who will make the policies? • Senior Management • (with guidance…)
Managing Information Security as a Process • First step… • identify all systems that carry information and decide what controls are in place to protect them • test those controls for potential security breaches • identify what has been forgotten • secure as appropriate through further controls • Next step: • once secure, develop a strategy to MANAGE this process over time... • implement that strategy
Informatiom Security Strategy: Where to start? • Can’t START with technology • need to start with ISSUES that need addressing • policy to address them should follow • Should be primarily “top down” • concerned with policies, not technical matters… • can be supplemented by “bottom up” approach
IT Manager, and Implementation • Needs to be able to do it right… • likely to need a big budget! • Big responsibility on the IT manager to convince senior management: • that the policy (change) really is necessary! • that the organisation won’t suffer financially • the consequences of NOT changing
Going beyond Creating a Policy… • According to the latest figures, many now businesses say they DO have an information security policy • big questions… is it implemented??? will it be? by when? • One possible approach… • implement through getting ISO27001, PCI-DSS, IASME or other information assurance standard
Information Security Management • Oversee implementation of policy • will be never ending! • Can’t begin to evolve into an ISMS until policy has been agreed and signed off…
Policy… making a start(1) • Produce a draft… • what is needed • Think how that could be put into action… • set of agreed procedures to protect data • accept that administering them is an organisational level matter • acknowledge the iterative nature of checking implementation & agree a rate of iteration (e.g. yearly) • Now have the makings of policy with ISMS • first stage towards ISO27001 (if they wish?)
Making a start(2) • Appoint someone with institutional responsibility • in control of the policy-making, and evolution • Role should NOT be outsourced! • need to provide advice, expertise, implement procedures • need realistic budget that takes into account the resource and human cost…
GDPR and Organisational Responsibility • Some of the changes from DPA when GDPR was announced • https://staffweb.worc.ac.uk/hensonr/GDPAfactsopinions.pdf • Quote: “An in-house Data Protection Officer (DPO) role for organisations that require regular and systematic monitoring of peoples’ personal data on a large scale”
Role of DPO • Needed under GDPR if • “core activities” consist of processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale;” • or consist of processing on a large scale of “special categories of data” or “data relating to criminal convictions and offences.” • Estimation: an additional 28000 DPOs will be needed across the EU to cover this (!) https://iapp.org/news/a/study-at-least-28000-dpos-needed-to-meet-gdpr-requirements/
The Costs of securing data • Hardware/software cost • fixed and easily determined • Human resource cost • cost of Information Security supremo • cost the organisation of using staff to implement and enforce data security procedures • more difficult to quantify • cost of testing knowledge off/retraining employees
Costs of Securing Data • Isolated LAN, with no internet connectivity • no need to worry about data in and data out via the Internet • less stringent procedures may be needed/enforced • employees could still mess up or steal data • LAN connected to the Internet: • “secret” data? highly rigorous procedures, implemented frequently – very expensive • no real secrets (political or commercial) more infrequent cycle, less exhaustive procedures • much cheaper…
The Costs of Data Breach? • Groups again…
The Costs of Data Breach • People not able to work… • Organisation not able to communicate effectively with customers… • Embarrassment of reporting in the media • loss of reputation • Fines, etc., by FCA or ICO • Fall in stock market price • Increase in insurance premiums • Not getting future contracts…
Information Security Procedures • In groups, discuss: • possible procedures the organisation could set up… • how expensive such procedures might be to implement… • how “realistic” procedures could be laid out in a policy…
Writing that Policy (1) • Written as a “Management Report” e.g. • http://www.computerweekly.com/answer/Information-security-policy-template-and-tips • Should be agreed by SMT and reflect: • their objectives for security of information • top-down… • strategy for achieving those objectives • requires liaison to find out what is feasible
Writing… (2) • Why not just buy a “security-policy-in-a-box” ? SMT won’t have the time! • needs to be explained in detail by a security professional • once understood… • needs to be formally agreed upon by SMT
Writing… (3) • Even if WAS possible to for management to endorse an off-the-shelf policy… • not the right approach to attempt to teach management how to think about security! • their organisation is unique!
Writing… (4) • First step should be to find out how management views security • security policy… set of management mandates • “top-down” only provides requirements for the security professional to obey… • too restricting without liaison first… (needs some “bottom-up” input
Writing (5) • As a result of discussion with SMT… • Develop top-level IS policy • Includes all topics for policy, but does not break them down into the sort of detail needed for implementation • Example: top level • Example PCI-DSS: http://www.lse.ac.uk/intranet/LSEServices/IMT/about/policies/documents/PCI-DSS-Information-Security-Policy.pdf
Writing (6): What to include… • What are your security objectives, and how do you measure them? • What types of information do you handle, and how do the different types of information need to be protected? • How do you assess risks and select security controls?
What to include… cont • How do you manage and report incidents, and learn from them? • Who is responsible for security? • What is acceptable employee use for Internet, email and other communication channels?
Writing (7) • To implement a top level policy… • need to liaise with relevant staff and create operational policy • e.g. acceptable passwords • e.g. acceptable use of email • Operational policies can be shared with employees during a training session… • not just an email with link… (!)
How achieving a Information Assurance “badge” could help with implementing policy… • Whatever the business: • any new work will have a cost • that cost needs to be qualified • More cost means less profit… • what is the ROI of achieving a high level of information security? • badge can be used to impress (potential) customers
Potential Financial Benefits of Information Assurance? • Need to be sold to senior mgt… • less risk of losing valuable (even strategically important…) data • less likely to get embarrassing leaks, which could even get to the media (!) • less likely to fall foul of the law (!) • Evidence from an ever growing set of examples of businesses who have done both of the above • lost customers AND share price dropped…