Agenda What is Compliance? Risk and Compliance Management What is a Framework? ISO 27001/27002 Overview Audit and Remediate Improve and Automate

What was Compliance? GLBA HIPAA PCI SB1386 FISMA NERC/FERC SOX FDA 21 CFR Part 11

What is Compliance? Compliance should be a program based on defined requirements Requirements are fulfilled by a set of mapped controls solving multiple regulatory compliance issues The program is embodied by a framework Compliance is more about policy, process and risk management than it is about technology

Risk & Compliance Mgmt Regulations Control Framework Partners/ Customers Regulations Control Framework Assessments Policy and Awareness Audits Treat Risks Improve Controls Automate Process Risk Assessment

Risk and Compliance Approaches Minimal Sustainable Optimized Annual / Project-based Approach Minimal Repeatability Only Use Technologies Where Explicitly Prescribed in Standards and Regulations Minimal Automation Proactive / Planned Approach Learning Year over Year Use Technologies to Reduce Human Factor Leverage Controls Automation Whenever Possible Regulatory Requirements are Mapped to Standards A Framework is in Place Compliance and Enterprise Risk Management are Aligned Process is Automated

Identify Drivers Partners/ Customers Regulations Risk Assessment

Managing compliance is fundamentally about managing risk. Identify Drivers Compliance is NOT just about regulatory compliance. Regulatory compliance is a driver to the program, controls and framework being put in place. Managing compliance is fundamentally about managing risk.

Identify Drivers Risk Assessment Partners / Customers Identify unique risks and controls requirements Partners / Customers Partners represent potential contractual risk Customer present privacy concerns Regulations – regulatory risk is considered as part of overall risk

Develop Program Regulations Control Framework Partners/ Customers Policy and Awareness Risk Assessment

What is a Control? Control is defined as the policies, procedures, practices and organizational structures designed to provide reasonable assurance that business objectives will be achieved and undesired events will be prevented or detected and corrected. *Source: ITGI, COBIT 4.1

What is a Framework? A framework is a set of controls and/or guidance organized in categories, focused on a particular topic. A framework is a structure upon which to build strategy, reach objectives and monitor performance.

Why use a framework? Enable effective governance Align with business goals Standardize process and approach Enable structured audit and/or assessment Control cost Comply with external requirements

Frameworks and Control Sets ISO 27001/27002 COBIT ITIL NIST Industry-specific – i.e. PCI Custom

ISO 27001/27002 Information Security Framework Requirements and guidelines for development of an ISMS (Information Security Management System) Risk Management a key component of ISMS Part of ISO 27000 Series of security standards

Adopted as international standard in 2005 A Brief History of ISO 27001 BS 7799-1 Code of Practice BS 7799-2 Specification Adopted as international standard in 2005 ISO/IEC 27001 Revised in 2002

A Brief History of ISO 27002 BS 7799-1 Code of Practice BS 7799-2 Adopted as international standard as ISO 17799 in 2000 BS 7799-1 Code of Practice Revised in 2005 Renumbered to 27002 in 2007 ISO/IEC 27002 BS 7799-2 Specification Information Technology Code of Practice for Information Security Management Revised in 2002

Shared Control Objectives ISO 27001 and 27002 ISO 27001 Requirements Auditable Certification ISO/IEC 27001 Shared Control Objectives ISO 27002 Best Practices More depth in controls guidance ISO/IEC 27002

ISO 27001 – Mgmt Framework Information Security Management Systems – Requirements (ISMS) Process approach Understand organization’s information security requirements and the need to establish policy Implement and operate controls to manage risk, in context of business risk Monitor and review Continuous improvement

ISO 27001 Plan Act Do Check Establish ISMS Maintain and Implement and Improve ISMS Implement and Operate ISMS Act Do Monitor and Review ISMS Check

ISO 27002 – Controls Framework ISO 27002 Security Control Domains Risk Assessment and Treatment Security Policy Organizing Information Security Asset Management Human Resources Security Physical and Environmental Security Communications and Operations Management Access Control Information Systems Acquisition, Development and Maintenance Information Security Incident Management Business Continuity Management Compliance

Protected Information Building a Framework Assessment & Treatment Risk Security Policy Information Organizing Management Asset Resources Human Environmental Physical and Communications and Operations Control Access Development and Maintenance IS Acquisition, Security Incident Continuity Business Compliance Operational Controls Technical Management Protected Information ISO 27002: Code of Practice for Information Security Management

Practical Uses for Certification Regulatory Compliance “Best Practice” approach to handling sensitive data and overall security program Internal Compliance Implement security as an integrated part of the business and as a process Third Party Compliance Provide proof to partners of good practices around data protection. Strengthen SAS 70 approach.

ISO 27000 Series of Standards ISO/IEC 27000:2009 - Overview and vocabulary ISO/IEC 27001:2005 - Requirements ISO/IEC 27002:2005 - Code of Practice ISO/IEC 27003 - ISMS Implementation Guidance* ISO/IEC 27004 - Measurement* ISO/IEC 27005:2008 - Risk Management ISO/IEC 27006:2007 - Auditor Requirements ISO/IEC 27007 - ISMS Audit Guidelines* *In Development

Frameworks Comparison Strengths Focus COBIT Strong mappings Support of ISACA Availability IT Governance Audit ISO 27001/27002 Global Acceptance Certification Information Security Management System ITIL IT Service Management NIST 800-53 Detailed, granular Tiered controls Free Information Systems FISMA

PCI Data Security Standard Controls Mapping PCI PCI Data Security Standard 1. Install and maintain a firewall configuration to protect data 2. Do not use vendor-supplied defaults for system passwords and other security parameters 3. Protect stored data 4. Encrypt transmission of cardholder data and sensitive information across public networks 5. Use and regularly update anti-virus software 6. Develop and maintain secure systems and applications 7. Restrict access to data by business need to know 8. Assign a unique ID to each person with computer access… Corporate Policy SOX Framework of Controls GLBA PCI

Controls Mapping Corporate Policy Framework of Controls SOX GLBA PCI

Controls Mapping Benefits: Alignment of corporate policy PCI GLBA SOX Policy Benefits: Alignment of corporate policy Custom interpretation of regulations Framework of Controls Single assessment effort provides complete view

Logging and Monitoring PCI – Requirement 10 ISO 17799 – Section 10.10

Audit and Remediate Regulations Control Framework Partners/ Customers Assessments Policy and Awareness Audits Treat Risks Risk Assessment

Organization Example IT Service Desk Information Security ITIL IT Service Desk ISO 27001/27002 Information Security CMMi Software Delivery Internal Audit COBIT

How aligned are your controls? Controls Alignment How aligned are your controls? Assessment (Information Security, IT Risk Management) Internal Audit (IT/Financial Audit) External Audit (Regulatory and Non-Regulatory)

Remediation Priorities Where are our greatest risks? What controls are we fulfilling? How many compliance requirements are we solving?

Improve and Automate Regulations Control Framework Partners/ Customers Assessments Policy and Awareness Audits Treat Risks Improve Controls Automate Process Risk Assessment

Controls Hierarchy Vs. Vs. Manual Automated Detective Preventive Require human intervention Vs. Rely on computers to reduce human intervention Detective Preventive Designed to search for and identify errors after they have occurred Designed to discourage or preempt errors or irregularities from occurring Vs.

Automated and Preventive Logging and Monitoring Not Efficient Efficient Reviewing logs for incidents An automated method of detecting incidents Not Effective Effective Missing the incident due to human error Preventing the incident from occurring in the first place

Automate the Process How do you currently measure compliance? Reduce documents, spreadsheets and other forms of manual measurement Create dashboard approach Governance, Risk and Compliance toolsets

GRC Automation Enterprise Multi-Function Single Function Enterprise Scope Highly Configurable Multiple Functions (Risk, Compliance, Policy) Sophisticated Workflow Enterprise Multi-Function Functionality More Limited More “out of the box” Modest Workflow Single Function Specific Process Specific Standard or Regulation Simple Workflow

Director, Risk and Compliance Management Questions? Evan Tegethoff Director, Risk and Compliance Management etegethoff@accuvant.com