baseline

PECB MS : Building your data protection foundation by using the ISO/IEC 27701 core components

I had a great opportunity working with PECB MS, writing an article on building a #dataprotection foundation, using #ISO27701,.. perfectly fit for small business #SMB/#smebusiness.

Your data protection is a very strong #marketing tool to become the #trustedpartner of your customers.

No doubt: Get started! Doing nothing will cost you.

You can find the article over here:

Enjoy!

And even better, get in touch if you want to have a chat building your data protection.

Me on LinkedIN

Extended mapping of CIS Controls to ISO27001 security controls

Introduction

The CIS (Center for Information Security) Controls list is a very well known list of security measures to protect your environment against cyberattacks.
The Center for Information Security provides a handy XLS sheet for download to assist in your exercise.

Here is the link: https://www.cisecurity.org/controls/cis-controls-list/

Many companies use this controls list already, but also require to map their CIS security controls to ISO27001, for various reasons.

Implementing security controls with regards to the NIS directive, is one of them, eg when you’re implementing OT…

ISO27001 controls mapping

For that purpose the CIS provided a XLS mapping between the CIS controls and ISO27001.

You can download the sheet from the CIS website: https://learn.cisecurity.org/controls-sub-controls-mapping-to-ISO-v1.1.a

Security note for the security freaks, apparently the document is hosted on the pardot(dot)com Salesforce website, which might be blocked by Adlist domain blockers as it’s used for marketing campaigns, you might need to unblock it, or use Tor browser…)

Alternatively, it’s available from the CIS Workbench community at: https://workbench.cisecurity.org/files/2329 (registration might be needed to access the download)

FYI, the previous version (2019, v1) of the mapping had quite some gaps. Therefor I’ve submitted a suggestion for an updated CIS-ISO27001 mapping.
And after review, a new version (1.1) with updates has been published on the CIS workbench.

Direct download for version 1.1 available at: https://workbench.cisecurity.org/files/2329/download/3615

Still some gaps

You’ll notice that the update (1.1) version has still some gaps. And I’ll leave to the discretion of the CIS review work group to argument these gaps.


But I’m convinced you can map the CIS controls for 100% to ISO27001, in one way or another, meaning use ALL ISO27001 controls in certain extent (sometimes a subset, equally or a superset of it, combining controls.)

But the license for use of the CIS controls mapping does not allow redistribution of modified materials…

Disclaimer (the small print)

Here’s the License from the mapping file:

Their work (quote) “is licensed under a Creative Commons Attribution-Non Commercial-No Derivatives 4.0 International Public License (the link can be found at https://creativecommons.org/licenses/by-nc-nd/4.0/legalcode

To further clarify the Creative Commons license related to the CIS ControlsTM content, you are authorized to copy and redistribute the content as a framework for use by you, within your organization and outside of your organization for non-commercial purposes only, provided that (i) appropriate credit is given to CIS, and (ii) a link to the license is provided. Additionally, if you remix, transform or build upon the CIS Controls, you may not distribute the modified materials. Users of the CIS Controls framework are also required to refer to (http://www.cisecurity.org/controls/) when referring to the CIS Controls in order to ensure that users are employing the most up-to-date guidance. Commercial use of the CIS Controls is subject to the prior approval of CIS® (Center for Internet Security, Inc.).”

So I CANNOT distribute the XLS as modified material (Why not?).

Extending the mapping

If you still want to build an extended version of the mapping on your own, you download the 1.1 version and add these items to the list:

CIS sectionCoverageISO27001 Control
2.2=A.12.5.1
2.5=A.8.1.1
2.8small subsetA.12.5.1
2.10small supersetA.9.4.1/A.8.2
3.1small subsetA.12.6.1
3.2small subsetA.12.6.1
3.4small subsetA.12.6.1
3.5small subsetA.12.6.1
3.6small subsetA.12.6.1
4.1small supersetA.8.1.1/A.9.2.3 
6.5small subsetA.12.4.1 
6.6small subsetA.12.4.1 
6.8small subsetA.12.4.1 
7.3small subsetA.12.2.1
7.5small supersetA.8./A.13.1.1
7.6small subsetA.13.1.1
8.3small subsetA12.2.1
9.5small subsetA.13.1.1
10.2small subsetA.12.3.1
10.5=A.12.3.1
11.1small subsetA.13.1.1
11.2small subsetA.13.1.1
11.6small subsetA.13.1.1
12.1small subsetA.13.1.1
12.5small subsetA.13.1.1
12.10small subsetA.13.1.1
13.2small subsetA.11.2.5
14.7small subsetA.8.2.3
16.2small subsetA.9.3.1
16.3small subsetA.9.3.1
16.9small subsetA.9.2.1
16.10small subsetA.9.2.1
16.12= A.12.4.1
16.13= A.12.4.1
17.1=Clause 7.2
18.3=A.12.5.1
18.4= A.12.5.1
18.7= A.14.2.9
18.10small subsetA.14.2.5 
18.11small subsetA.14.2.5 
19.3small subsetA16.1.1
19.6small subsetA16.1.2
19.7small subsetA16.1.1
19.8small subsetA16.1.4
20.1small subsetA18.2.3
20.2small subsetA18.2.3
20.3small subsetA18.2.3
20.4small subsetA18.2.3
20.5small subsetA18.2.3
20.6small subsetA18.2.3
20.7small subsetA18.2.3
20.8small subsetA18.2.3

Planning for ISO Certification using CIS Controls?

When you look at it from a different angle and you would like to build a plan to certify your ISO27001 implementation, we need to turn around the mapping, and look for the gaps in the ISO27001 security controls AND CLAUSES, when doing the CIS control mapping.


And then you’ll notice the explicit difference in approach between CIS controls and ISO27001 controls.
CIS controls are focusing on technical implementation to harden your cybersecurity, while ISO27001 is a management system that needs these controls, but requires a management layer to support these technical controls. CIS controls are lacking this management layer.
If you compare both systems in a table the story gets clear:

The “red” areas require extra work to make it ISO27001 compliant.

And as always, if you have suggestions of feedback to improve this article, let me know, I’ll fix it on the fly.

A quick walk-through of the new ISO29184 – Online Privacy notices and consent

Source and download: https://www.iso.org/standard/70331.html

With the publication of the GDPR in 2016, it quickly became clear that it would massively impact the direct marketing sector, simply because direct marketing runs on personal data.

On 25 may 2018, the GDPR came into force, changing the global mindset on data protection (and privacy by extension).

Anno 2020, 2 years after the publication, many enterprises, large and small still struggle to apply the data protection regulation and best practices.

And for the direct marketing companies, this is a particular difficult topic, after 4 years.

So, maybe, the newly (june 2020) published standard can provide a practical help to implement consent management. Please remind that the GDPR is a regulation/law… not a best practice with hints and tips.

For hints & tips and practical advice on GDPR, check the EDPB (previously known as WP29) website: https://edpb.europa.eu/our-work-tools/general-guidance_en (Check the Our Work & Tools menu).

While there has been a lot of guidance, communication & education on implementing a direct marketing that is compliant with GDPR and ePrivacy/eCommunication regulation and directives.

Even, for other markets than direct marketing where managing personal data is optional (meaning, not part of core business), you can use this guide to manage privacy or data protection notices for your newsletters and website.

Side note

The ISO 29184 is strictly and only about privacy notices and consent, it’s not an in depth guide for direct marketing, but it’s an essential part of it.

If you need more information on the EU ePrivacy/eCommunications directive , see here: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=celex%3A32002L0058

ISO 29184 content walk through

Document structure

After the mandatory basic chapters (Foreword, 1. Scope), the document hints to ISO 29100 in chapter 2 (Normative References) and 3. (Terms and definitions.

Important note here is that the definition of “explicit consent” has been updated to match the GDPR requirement for unambiguous affirmative consent.

Chapter 5 contains the “general requirements and recommendations”.

A major requirement (and typical for ISO compliance like in ISO9001 and ISO27001) is that you need to document the implementation of each control in this standard.

The content is structured in 5 chapters (Level 2)

  1. Overall objective
  2. Notice
  3. Contents of notice
  4. Consent
  5. Change of conditions

To read the full details, you know what to do,…

But it’s interesting to see the technical/operations controls required in this standard

General conditions on privacy notice

  • Provide information to all interested parties about your privacy practices, including
    • the identity and registered address of the data controller, and
    • contact points where the subject (in this standard the subject is called “PII principal”)
  • Provide clear and easy to understand information
    • with regards the target audience,
    • which are usually NOT lawyers or data protection specialists),
    • taking care of the expected language of your audience
  • You must determine and document the appropriate time for providing notice
    • Remember the Art. 13 and Art 14 definitions in GDPR
    • By preference, you should notify the subject immediately before collecting PII (and/or consent)
  • You must provide notices in a appropriate way
    • by preference in more than 1 way,
    • to make sure the subject can find and consult the notices,
    • digitally and in a easy accessible method
    • also after initial contact
    • As also defined in many GDPR guidelines, the consent standard refers to a multilayer approach (avoiding to provide too much information at the same time, but provide the details when needed)
  • Make sure that the privacy notice is accessible all the time.

Notice content

  • make sure you’re absolutely clear, honest and transparent about your personal data processing
  • Define, document and describe clearly
    • the processing purpose
    • each element of the processing (remember the processing definitions defined in Art. 4 of GDPR)
    • the identification of the data controller
    • the data collection details, incl
      • methods used
      • details of data collected
      • type of collection (direct, indirect, observation, inference…)
      • timing and location of collection
    • use of data, including
      • direct use without data transformation
      • reprocessing data
      • combining, like enrichment
      • automated decision making
      • transfer of data to 3rd party
      • data retention (incl backup)
    • data subject rights
      • access request
      • authentication to provide access
      • timelines
      • any fees that apply
      • how to revoke consent
      • how to file a compliant
      • how to submit a inquiry
    • Evidence about consent provided (and changed) by the subject
    • the legal basis for processing PII/personal data
    • the risks related with the data and the plausible impact to the subject privacy

Consent management

  • Identify if whether consent is appropriate
    • Remember that there are other purposes and reasons for processing data, which usually have a more stable, more solid background, like
      • contracts
      • compliance with legal obligations and regulations
      • vital interest,
      • public interest
      • (legitimate interest, which is usually way more difficult to enforce or to convince the subject)
    • Informed and freely given consent
      • how do you guarantee that the subject is providing consent without any feeling of coercing, force, conditions, …
      • Independence from other processing or consent
        • Remember the GDPR guidelines where you CANNOT force consent as
    • Inform the subject which account this processing is related to
      • provide a clear description of the identifier (userID, mail, login, …)

ISO29184 also introduces the consent lifecycle, meaning that is it’s not sufficient to provide notice at first contact with the subject, but you also need to maintain, to update and to renew it on a regular basis, taking into account that the conditions of consent might change (or might have changed after initial consent).

The last part of the ISO 29184 are annexes with interesting user interface examples.

The perfect document set

To make the online privacy and consent management work, this ISO/IEC 29184 will not do on itself as the standard links to the following documents:

  • (FREE, EN – FR) ISO 27000: ISMS vocabulary
  • (*) ISO27001: ISMS, Information Security Management Systems
  • (*) ISO27002: Code of practice for ISO 27001)
  • ISO27701: PIMS, Privacy Information Management System, the privacy or data protection extension of ISO27001
  • (FREE, EN – FR) ISO29100: Privacy framework
  • ISO29151: Code of Practices – Privacy Framework (the ISO27002 version of ISO29100)
  • ISO29134: PIA, Privacy Impact Assessment (foundation of the DPIA in GDPR)

References

Free downloads

ISO Public documents: https://ffwd2.me/FreeISO

If not available for free download, then you’ll need to purchase the ISO standards documents from the ISO e-shop or from the national standards organisation (like NBN for Belgium, NEN for Netherlands, …)

Note-to-self: MNM van KSZ (Minimale normen – Sociale Zekerheid)

Minimale Normen / Normes Minimales van de KSZ (Kruispuntbank van de Sociale Zekerheid) gebaseerd op de ISO27001/ISO27002

“De toepassing van de minimale normen informatieveiligheid en privacy is verplicht voor instellingen van sociale zekerheid overeenkomstig artikel 2, eerste lid, 2° van de wet van 15 januari 1990 houdende oprichting en organisatie van een Kruispuntbank van de Sociale Zekerheid (KSZ). Bovendien moeten de minimale normen informatieveiligheid en privacy eveneens toegepast worden door alle organisaties die deel uitmaken van het netwerk van de sociale zekerheid overeenkomstig artikel 18 van deze wet. Tenslotte kan het sectoraal comité van de sociale zekerheid en van de gezondheid de naleving van de minimale normen informatieveiligheid en privacy ook opleggen aan andere instanties dan de hogervermelde.  ”

Bookmark:

(NL) https://www.ksz-bcss.fgov.be/nl/gegevensbescherming/informatieveiligheidsbeleid

(FR) https://www.ksz-bcss.fgov.be/fr/protection-des-donnees/politique-de-securite-de-linformation

(edit)

Opmerking: voor alle duidelijkheid, op zich zijn deze documenten geen nieuwigheid maar buiten de SZ zijn deze normen minder gekend… vandaar dat het toch nuttig is om ze bij te houden als geheugensteun en referentie. Je komt er sneller mee in contact als je denkt…

Note-to-self: logging policy considerations

Few days ago I got a question from a security officer for guidance on event and system logging.

What I can recommend: a good guideline and indication is this from OWASP.
You know OWASP is THE reference for software security …. with their OWASP top 10 etc.

Check this: https://owasp.org/www-project-cheat-sheets/cheatsheets/Logging_Cheat_Sheet

Another reference from NIST see below, very handy.

These are fairly complete in terms of guideline.

What you should pay special attention to from a policy point of view is

Special accounts

  •  Sensitive accounts
    • Highly priviliged accounts
    • Admin accounts
    • Service accounts
    • …
  • Sensitive systems
    • Domain controllers
    • Application servers
    • …
  • Sensitive data
    • HR data
    • Finance data
    • Legal data
    • …

Regarding the classification of accounts, check these:

For the users you also have to think carefully about events

  • Large volume of failed logons from sensitive users, may indicate
    • Attack
    • Denial of service
    • Hacking
  • Attack on the password database, large volumes of password change attempts …
    •  Smart password ‘testers’ will stay just below the blocking limit ..
  • Successful logons from special accounts at abnormal places or times
  • Changing the rights of sensitive accounts
    • Promotion of regular users to admins or other sensitive accounts in AD or central database

CLASSIFICATION

Make sure you have a data, user and system classification policy.
Define roles and / or categories.
Which objects are “not important”, “not sensitive”, sensitive, important, critical.
The protection must be tailored to the category type.

STORAGE

In addition, you should also write a policy on saving data.
This often poses a logistical problem with disk space.

If you know that sometimes attacks are only detected after 200-300 days, you should be able to do a forensic investigation in that period.
But that does not have to be on live data, if it is in backup, that is also good.

In terms of operational data you have to decide how much should be available immediately, for immediate consultation.
For example, that can be 1 month. (if the system can save so much)

BACKUP

Ensure that a backup can be guaranteed for a year (combination of full / differential and / or incremental backups or virtual snapshots …)
This is not a fixed period, but depending on risk management this may be more or less.

IMPORTANT: Time synchronization

Also make sure that you require NTP time synchronization, so that the clocks are exactly matched to each other on all systems.
Log analysis is impossible without correct timing.

SECURITY

Ensure that logs on source systems cannot be deleted by administrators.
Ensure that the logs following are shielded from system owners;
Ideally, you are obliged to store logs centrally (for example in a SIEM system).

Secure backups

Consider managed encryption of data and backups (not ransomware or malware).

Healthy logging and healthy backups

Make sure to test backups and restores!

Check the logs and backup for malware.

LOG CENTRALIZATION

Store logs centrally with sufficient storage capacity, security and backup.

LOG MANAGEMENT

A good management process and regular inspection must become mandatory.
Ensure monitoring for special events or special trends (sudden growth or sudden decrease or disappearance of logs)

Arrange forensic surveillance / detention if a burglary or data breach may need to be reported to the government / DPA / police.

The NIST documentation below provides useful hints and tips about the type of systems, routers, switches, firewalls, servers …

LEGISLATION

Take into account legislation such as GDPR or ePrivacy or others that impose your obligations (legal, judicial, international, fed gov, …)

EXPERIENCE

View and learn from past incidents and known use cases or accidents, which give a clear hint of what protect first.

PDCA – plan-do-check-act

Require a regular review of the policy and the rules, ensure that the guidelines are updated to the requirements and changing situations.

It is difficult if you find out after the facts that your log is not working properly.

Other references

And this is also a reference (NIST)

Note-to-self: 2019 …cost of a data breach…

Many InfoSec and data protection or privacy courses reference 3 authoritative yearly reports that show interesting numbers, statistics and trends about breaches year over year.

And these are extremely useful to talk about to your management…

Interesting to know they all have been updated for 2019.

1. Verizon DBIR

(The Verizon Data breach Investigations Report, DBIR)

https://enterprise.verizon.com/resources/reports/2019-data-breach-investigations-report.pdf (click the view only option)

2. IBM-Ponemon – Cost of a data breach report 2019

https://www.ibm.com/downloads/cas/ZBZLY7KL

(You can always use the official link and give away your privacy…at https://www.ibm.com/security/data-breach)

3. IAPP-EY Annual Governance Report 2019

(IAPP members get it for free)

Hint: the IAPP link below also shows reports of previous years.

https://iapp.org/resources/article/iapp-ey-annual-governance-report-2019/

V2018 also available from the EY website: https://assets.ey.com/content/dam/ey-sites/ey-com/en_gl/topics/financial-services/ey-iapp-ey-annual-privacy-gov-report-2018.pdf

Useful resources for GDPR starters

I realise, this braindump will never be finished, so come back once in a while to check for updates. Work in progress… (updated 2021-02-23)

But let’s turn around the thing a bit, you certainly must have smart ideas or articles on GDPR for starters that belong on this list! Let me know and I’ll add it to the list.
Of course, with the proper credits!

DISCLAIMER: These resources are provided / authored by different people, companies, vendors, each of them copyrighted by the original owner.
The resources below are just a collection or interesting documentation, need to have, without any preference or commercial interest for any party.

Table of contents

First of all, before you start with GDPR you must have read the GDPR text.
It’s not as bad (you mean: legalese) as you might suspect.

GDPR official text

You might want to have it a bit more condensed to start.

Vocabulary / Grammar

Do not get confused: European Council vs Council of the European Union vs Council of Europe

More info at:

– http://www.caneurope.org/publications/blogs/1295-what-is-the-european-council-or-the-council-of-the-european-union%C2%A0

– https://www.coe.int/en/web/about-us/do-not-get-confused

GDPR Table of contents

Once you get through the legal texts… you’ll quickly understand that the GDPR text itself at least lacks 1 important thing: A table of contents (TOC).

This TOC by Intersoft Consulting might help: bookmark https://gdpr-info.eu/

It provides a nice overview of the GDPR Recitals (= reasons the articles of the GDPR have been adopted).

There are 173 recitals, the and the TOC provides a quick topic overview at https://gdpr-info.eu/recitals/.

Also the site provides an overview of the GDPR structure

  • 11 Chapters
  • Sections per chapter
  • 99 Articles (spread over sections / chapters

GDPR Library by EC

https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en

GDPR Adequacy decisions

Working Party 29

http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:31995L0046

“The composition and purpose of Art. 29 WP was set out in Article 29 of the Data Protection Directive, and it was launched in 1996.”

https://en.wikipedia.org/wiki/Article_29_Data_Protection_Working_Party

The European Data Protection Board (EDPB) will replace the Article 29 Working Party under the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

WP29 articles

Newsroom overview: http://ec.europa.eu/newsroom/article29/news.cfm
Guidelines: http://ec.europa.eu/newsroom/article29/news.cfm?item_type=1360

WP 29 Advisory

The Article 29 Working Party Issues Final Guidelines on Data Protection Officers (“DPO”) is available here.

More info

  • Bird & Bird article, explaining
    1. Accountability means that DPO assessments need to be kept up-to-date and can be requested at anytime
    2. No “a la carte” DPO appointments
    3. Big data now an example of ‘regular and systematic monitoring’
    4. Preferably, the DPO should be located within this EU
    5. There can only be one DPO, but supported by a team
    6. Duty to ensure the confidentiality of communications between the DPO and employees
    7. Senior managers including Head of HR, Marketing or IT individuals are barred from serving as the DPO
    8. The GDPR does not prevent the DPO from maintaining records of processing
  • For a redline comparison with the earlier draft, click here.

ISO Standards related to GDPR

ISO29100 (Privacy Framework)

PIA: ISO 29134

Get the ISO29100 privacy standard for free at:

http://standards.iso.org/ittf/PubliclyAvailableStandards/c045123_ISO_IEC_29100_2011.zip

ISO27001 (Information Security)

Mandatory ISO27001 documents: ISMS mandatory documentation checklist

Mapping GDPR to ISO27001 schema

Implementing GDPR with ISO27001

https://pecb.com/oldwebinar/26-may-2018-from-gdpr-to-sustainable-gdp

GDPR at a glance

https://www.twobirds.com/~/media/pdfs/gdpr-pdfs/bird–bird–guide-to-the-general-data-protection-regulation.pdf (Credits for Moritz Anders).

Data access request

As published on LinkedIn: The Nightmare Letter: A Subject Access Request under GDPR (By: Constantine Karbaliotis)

You can download the docx Word version in EN (here) and in NL translated version (here).

Useful Tools

Open Source

Monarc – Risk Assessment: http://Monarc.lu

CNIL – DPIA Tool 

CNIL guides for PIA: https://www.cnil.fr/en/PIA-privacy-impact-assessment-en

Implementation Guidance

Visualisation sheet

Have a look what Jonas Holdensen has published, a marvelous sheet to provide a visualization on GDPR.

Also he has provided a nice overview on the DPO requirements & tasks under GDPR.

If you prefer the file in pdf or word, then download the file here: www.kortlink.dk/rhpx

GDPR Privacy Courses (work in progress)

Region Provider Course URL
WW IAPP CIPT, CIPP/E, CIPM, https://iapp.org/train/gdprready/
WW PECB PECB Certified Data protection Officer https://pecb.com/en/education-and-certification-for-individuals/gdpr
BE DP Institute Data Protection Officer Certificatie Training https://www.dp-institute.eu/nl/opleidingen/
WW IT Governance GDPR https://www.itgovernance.co.uk/data-protection-dpa-and-eu-data-protection-regulation
WW Cranium GDPR & Privacy

And some more

Legislative background

Note-to-self: MVA Learning Path – Security for the Chief Security Officer (CSO)

From a LinkedIn connection (thx Jeff and congratz on the achievement) I received an interesting pointer to a set of courses on MVA, Microsoft Virtual Academy.

An MVA ‘learning path’ is a combination of learning courses.
Just recently MVA published the ‘Security for the Chief Security Officer (CSO)’ learning path.

Check it out at : https://mva.microsoft.com/learning-path/security-for-the-chief-security-officer-cso-21

It combines 6 courses (better make sure to access them from the learning path):

  1. How to Harden Your Enterprise in Today’s Threat Landscape
  2. Cybersecurity Reference Architecture
  3. Planning for a Security Incident
  4. Cloud Security from the Field
  5. Securing Privileged Access
  6. Introduction to Azure Security Center

BTW: have a look on the ‘security’ based content on Microsoft Virtual Academy, you’ll be surprised how much you can (continue to) learn.

See: https://mva.microsoft.com/search/SearchResults.aspx#!q=security

Last Updated: 2020-12-29

That alphabet of Security starts with I of “Identity”

It’s an understatement to say security is moving fast, it’s changing very rapidly and the pressure to keep up with it, increases too.

From various angles, people in IT (as in Information Technology), are under fire to keep the infrastructure secure. Cloud is getting mature, new features pop up every week.
It’s almost a contradiction, but also legislation is catching up to close the holes regarding the protection of people’s security and privacy.

In many cases, the first reaction of customers, management, ITPros, Developers, DevOps,… is to look for the ultimate and ideal tool that will help to plug the security hole.

But if you only focus on the tooling, you’ll discover rather sooner than later, it is not sufficient to get your security watertight.
One of the basic reasons is that tools can’t be implemented properly without involving people and processes. I don’t need to explain the PPT (people-proces-technology) or PPP (people-proces-products) triade, right?

Lots of security management approaches and certifications handle this triad (ISO27001, CISSP, … I’ll cover that another time.

(credits: smart picture of ITGovernance.co.uk)

Rather than diving into the search for a tool, you better take a step back and consider first.

What’s the primary function of security?
Protecting an item that you want to keep (safe), right?

[The reason (“why”) for keeping it safe = the CIA triad, Confidentiality, Integrity and Availability]

When you think about the processes (“how”) to secure  an asset (anything that is worth securing), there are 3 basics actions you need to define

  • authorization: what you can do with the asset (the CRUD stuff, create/read/update/delete)
  • identification: who needs the authorization?
  • authentication: the method to proof your identity (using passwords, passes, cards, 2FA, MFA, …)

This is essentially the foundation of my credo “no security without identity”

Just by interpreting the basic components of security, you directly hit the “PROCESS” part of the PPT triad.
Now, here’s were most technical people get into trouble… not knowing how to put this in practice.

But let me ask you a simple question: within the normal, usual businesses or companies, where does the identity process typically start?
Yes, correct, HR (Human Resources)

The second question: can you name at least 2 typical high-level HR processes (for people).
Answer: something like “hire” and “fire”, or synonyms like “onboarding/off-boarding”, “termination”, “end-of-life” (but that sounds pretty dramatic when talking about people…).

These 2 events announce the beginning and the end of a lifecycle, the identity lifecycle.
And to make it complete, you also need to define the life-in-between as people change over time.

BTW, just a small side step here: this does not apply to humans only, but any other asset in your environment has pretty much the same cycle and it does not matter if it’s considered “IT” or not… computer, certificates, smart cards, disks, tapes, … but also cars, documents, …

This idea to consider the lifecycle as universal, is a great approach to explain the “identity lifecycle” to non-techies that get involved in the identity lifecycle processes.

This is the common ground you can use to talk to HR people, business managers, Executive level, …

Now, if you look on the internet for pictures on identity lifecycle management, you’re smashed with a lot of complex schemas…

google_identitylifecycle

Many of results are variations of 3 essential processes

hire-change-fire1

Depending on your background you might name them differently, like:

1AA.png

For the sake of simplicity, when teaching IDM and security workshops I usually only keep the keywords “Hire”, “Change” and “Fire”.
Short and easy to remember for most people.

For your understanding, the circle approach  would assume you start over again after the “Fire” block, but that’s not always the case. The cycle might stop.
So, the approach below is easier to visualize for most people.

Clockwise:

  1. Starting the cycle at (1),
  2. updating the identity at (2),
  3. exiting the cycle at (3)

hire-change-fire2

As I mentioned, earlier, virtually any IT or asset related proces is basically working like this.

Now, let’s take it a step further… How does identity management control security?

A first thing to consider is the typical length of the hire-change-fire modules.

How many tasks/steps does it usually take to complete each of the 3 steps?
Keep the asset in mind and keep it simple…

Typical actions in a hire process:

  • signing contract
  • getting an network/AD account
  • getting an email address
  • getting building access
  • IT stuff (laptop, …)
  • …

Pretty straight forward…
How much time would it take, in simple cases to start working?  Hours if not days.

What about the change process? For example, you get promotion to team lead or head of department…

  • hand over your tasks to peers
  • get ramped up on new job
  • in some cases, there is segregation of duties, getting rid of existing rights permissions
  •  getting access to new environment
  • changing communications channels (notifications to stakeholders of change)
  • …

In reality, this usually takes a few weeks.

And what are the typical things your consider for the “fire” process?

  • informing stakeholders/customers
  • disabling the account
  • changing password
  • lock account
  • removing access
  • extracting documentation form personal storage
  • move documents to manager or team
  • handing over ownership
  • knowledge transfer
  • data backup/archiving
  • cleaning the mailbox
  • deleting the account (* not always allowed for various reasons)
  • sending legal / tax documents
  • and more…

As you can understand, this entire termination process might take months… In many situations the termination process must be executed in different steps, like:

  • Disabling the account till x+30 days (for example, revert in case the person gets a renewal)
  • Removing access on x+60 days
  • Kill mailbox on X+90
  • Remove the account on X+1y (or even: never)

In some cases accounts must be kept for legal reasons or tracking/cybersecurity reasons…

The further you go in the lifecycle, you need to combine more tasks, and tasks or decisions get more complex.

Overall you can distinguish 2 properties of these processes: duration and complexity. Both go up.

complexity

procesduration

Now, when considering security, why is this important?
Instead of discussing the impact of successful processes, it’s easier to find out what happens if it fails.

WHAT IF… (the process fails)??

Let’s run through the cycle again….

What if the “Hire” process fails?

  • you can’t access the building
  • you do not get an account
  • you can’t logon
  • you can’t access documents
  • …

Basically, on your first (few) day(s) you can’t work. Sorry!
But what’s the balance for security: just great, because the risk is nearly 0, except for a bad start and a bit of reputation damage..
At the end: you can’t do any harm, essentially.

In case of the “change” process, a larger part of the tasks and operations will impact the security posture.

When your “change” process fails,  for example

  • you can still access your old documents
  • you get more access (eg collecting access of your old and new role)
  • you start collection sensitive accesses over time
  • managers don’t know
  • user profiles get copied from existing colleagues in the same team (no ‘reset’ or the permissions before the new ones are assigned)
  • …

So for this second piece of the circle, the impact might be significant, over time.

But for the “end-of-life” the story is completely different, a failing “deprovisioning” scenario has major impact on the business and IT process

  • accounts stay active
  • accounts not being disabled
  • access not removed
  • active accounts not detected
  • account with highly privileged access still active
  • accounts being deleted too soon
  • unauthorized users that have access to critical resources
  • hackers go undetected for a long time, using sleeping accounts
  • hardware not returned,
  • data stolen,
  • over-use of budgets to software licenses that are not revoked
  • access badges allow unauthorized access to your building and environment
  • failure to ‘deprovision’ old hard disks properly expose your company data to interested (unauthorized) parties…
  • …,

It’s clear that a failing deprovisioning/end-of-life process has major impact on your enterprise security.

risk.png

And hackers or disgruntled employees like that.

Of course you can imagine the benefits of an efficient and effective end-of-life process. It’s the opposite.

Does that require you implement an automated identity management?
No.

That’s where ISO27001 and eg GDPR surprises a lot of people.

Once you’ve got the basic processes in place you can discuss tooling, not the other way around.

questforsecurity

You have
no security without managing your identity.

you want
no identity without security.

Did I mention  that I’ll be presenting more of this fun stuff on TechoRama 2017.
Check it out here: http://sched.co/9M94

I’m very proud to present a session on the ABC of identity: Maximizing security with 10 simple processes.