Data Security Lifecycle 2.0: Functions, Actors, and Controls

In our last post we added location and access attributes to the Data Security Lifecycle. Now let’s start digging into the data flow and controls. To review, so far we’ve completed our topographic map for data: This illustrates, at a high level, how data moves in and out of different environments, and to and from different devices. It doesn’t yet tell us which controls to use or where to place them. That’s where the next layer comes in, as we specify locations, actors (‘who’), and functions: Functions There are three things we can do with a given datum: Access: View/access the data, including copying, file transfers, and other exchanges of information. Process: Perform a transaction on the data: update it, use it in a business processing transaction, etc. Store: Store the data (in a file, database, etc.). The table below shows which functions map to which phases of the lifecycle: Each of these functions is performed in a location, by an actor (person). Controls Essentially, a control is what we use to restrict a list of possible actions down to allowed actions. For example, encryption can be used to restrict access to data, application controls to restrict processing via authorization, and DRM storage to prevent unauthorized copies/accesses. To determine the necessary controls; we first list out all possible functions, locations, and actors; and then which ones to allow. We then determine what controls we need to make that happen (technical or process). Controls can be either preventative or detective (monitoring), but keep in mind that monitoring controls that don’t tie back into some sort of alerting or analysis merely provide an audit log, not a functional control. This might be a little clearer for some of you as a table: Here you would list a function, the actor, and the location, and then check whether it is allowed or not. Any time you have a ‘no’ in the allowed box, you would implement and document a control. Tying It together In essence what we’ve produced is a high-level version of a data flow diagram (albeit not using standard programming taxonomy). We start by mapping the possible data flows, including devices and different physical and virtual locations, and at which phases in its lifecycle data can move between those locations. Then, for each phase of the lifecycle in a location, we determine which functions, people/systems, and more-granular locations for working with the data are possible. We then figure out which we want to restrict, and what controls we need to enforce those restrictions. This looks complex, but keep in mind that you aren’t likely to do it for all data within an entire organization. For given data in a given application/implementation you’ll be working with a much more restrictive subset of possibilities. This clearly becomes more involved with bigger applications, but practically speaking you need to know where data flows, what’s possible, and what should be allowed, to design your security. In a future post we’ll show you an example, and down the road we also plan to produce a controls matrix which will show you where the different data security controls fit in. Share:

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Say Hello to Chip and Pin

No, it’s not a Penn & Teller rip-off act – it’s a new credit card format. On August 9th Visa announced that they are going to aggressively encourage merchants to switch over to Chip and Pin (CAP) ‘smart’ credit cards. Europay-Mastercard-Visa (EMV) developed a smart credit card format standard many years ago, and the technology was adopted by many other countries over the next decade. In the US adoption has never really happened. That’s about to change, because Visa will give merchants a pass on PCI compliance if they adopt smart cards, or let them assume 100% of fraud liability if they don’t. Why the new push? Because it helps Visa’s and Mastercard’s bottom lines. There are a couple specific reasons Visa wants this changeover, and security is not at the top of their list. The principal benefit is that CAP cards allow applications to be installed and run on the card. This opens up new revenue opportunities for card issuers, as they bolster affinity programs and provide additional card functionality. Things like card co-branding, recurring payments, coupons, discounted pricing from merchants, card-to-card gifting, and pre-paid transit tokens are all examples. Second, they feel that CAP opens up new markets and will engender broader use of the cards. The smart card industry in general is worried about loss of market share to smart phones that can provide the same features as CAP-based smart cards. In fact we see payment applications of all types popping up, many of which are (now) sponsored by credit card companies to avoid market share erosion. Finally, the card companies want to issue a single card type, standardizing cards and systems across all markets. Don’t get me wrong – Security absolutely is a benefit of CAP. ‘Smart’ credit cards are much harder to forge, offering much better security for ‘card present’ transactions, as the point-of-sale terminal can electronically validate the card. And the card can encrypt data locally, making it much easier to support (true) end-to-end encryption so sensitive data is not exposed while processing payments. Most smart cards do not help secure Internet purchases or card-not-present transactions over the phone. What scares me about this announcement is that Visa is willing to waive PCI DSS compliance for merchants that switch 75% or more of their transaction to CAP-based smart cards! Vissa is offering this as an incentive for large merchants to make the change. The idea is that the savings on security, audit preparation, and remediation will offset the costs of the new hardware and software. Visa has not specified whether this will be limited to the POS part of the audit, or if they mean all parts of the security specification, but the press release suggests the former. Merchants have resisted this change because the terminals are expensive! To support CAP you need to swap out terminals at a hefty per-terminal cost, upgrade supporting point-of-sale software, and alter some payment processing systems. Even small businesses – gas stations, fast food, grocery stores, etc. – will require sizable investment to support CAP. Pricing obviously varies, but tends to run about $1,000 to $1600 per terminal. Small merchants who are not subject to external auditing will not benefit from the audit waiver that can save larger merchants so much, so they are expected to continue dragging their feet on adoption. One last nugget for thought: If EMV can enforce end-to-end encryption, from terminal to payment processor, will they eventually disallow merchants from seeing any card or payment data? Will Visa fundamentally disrupt the existing card application space? Share:

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Incite 8/10/2011: Back to the Future

Getting old just sucks. OK, I’m not really old, but I feel that way. I think I’m suffering from the fundamental problem Rich described a few weeks ago. I think I’m 20, so I do these intense exercise programs and athletic pursuits. Lo and behold, I get hurt. First it was the knees. My right knee has bothered me for years. And I was looking at the end of my COBRA health benefits from my last employer, so I figured I’d get it checked out before my crap insurance kicked in (don’t get me started on health insurance). Sure enough there was some inflammation. Technically they called it patellar tendinitis. My trusty doctor proscribed some anti-inflammatories and suggested a few weeks of physical therapy to strengthen my quads to alleviate the issue. But that took me out of my pretty intense routines for a few months. That wouldn’t normally be a huge problem, but softball season was starting, and I had lost some of my fitness. OK, a lot of my fitness. I was probably still ahead of most of the old dudes I play with, but all the same – when you aren’t in shape, you are more open to injury. You know how this ends. I plant the wrong way crossing home and I can feel the jolt through my entire body. My middle back and shoulder tighten up right away. It wouldn’t be the first time I’ve pinched a nerve, so I figure within a day or two with some good stretching it’ll be fine. I take a trip and three days later try some yoga. Yeah, that didn’t work out too well. I made it through 10 minutes of that workout before saying No Mas. Since when did I become Roberto Duran? Oh crap, this may be a bit more serious than I figured. It probably didn’t help that the next day we loaded up the family truckster and drove 7 hours to see the girls at camp. When I woke up the next day I could hardly move. I’m not one to complain, but I was pretty well immobile. Once we got to Maryland, I got a deep tissue massage. No change. My doctor called in some relaxants. I tried to persevere. No dice. I flew home to see my doc, who thought there was a disc problem. An MRI would confirm. And confirm it did. I have a degenerative disk (C5-6 for those orthopedists out there). It took about two weeks but finally settled down. I’m going to try to rehab it with more PT and more stretching and less impact. I don’t want to do shots. I definitely don’t want to do surgery. So I’ve got to adapt. P90X may not be the best idea. Not 6 days a week, anyway. I can build up a good sweat doing yoga, and maybe I’ll even buy that bike the Boss has been pushing for. Or perhaps take a walk. How novel! I’m not going to settle for a sedentary existence. I like beer and food too much for that to end well. But I don’t need to kill myself either. So I’m searching for the middle ground. I know, for most of my life I didn’t even know there was a thing called middle ground. But as I get older I need to find it. Because life is a marathon, not a sprint. I can’t go back to the future in a broken down DeLorean, now can I? -Mike Photo credits: “Lateral X-Ray of Neck Showing Flexion | Donald Corenman, MD | Spine Surgery Colorado” originally uploaded by neckandback Incite 4 U Long live speeds and feeds: Coming from a networking background, I have a serious disdain for vendors differentiating based on speed. Or how many signatures something ships with. Or any other aspect of the device with little bearing on real world performance. After the 40gbps IPS rhetoric died down a few years ago, I hoped we were past the “my tool is bigger than yours” marketing. Yeah, not so much. Our pals at Check Point dive back into the speeds/feeds muck with their new big box, and NetworkWorld needs a visit from the clue bat for buying into the 1Tbps firewall. Check Point did map out a path to 1tbps, but it’ll take them 4 years to get there. But hey, a 1tbps firewall generates some page views. By the way, there are a handful of customers that even need 100gbps of perimeter throughput. But long live the speeds and feeds! – MR I guess the parents were also in the room: When I worked for the State of Colorado, my first real IT job was as a systems and network administrator at the University of Colorado in Boulder. I had a wacky boss who wasn’t the most stable of individuals. When I got my Classified Staff status he informed me that I now didn’t have to worry about being fired. I quote, “even if you have sex with a student on a desk in front of the class, they’ll just suspend you with pay”. (When he finally went off the deep end it took them years of demotions to finally get him to quit). I’ve always thought of PCI QSA (assessment) companies that way. It has always seemed that no matter what they did, there weren’t any consequences. I wouldn’t say that’s changing, but a company called Chief Security Officers is the first to have its QSA status revoked. No one is saying why, but I suspect less than satisfactory performance, with consistency. – RM CSA Vendor Guide: CSA is offering a Security Registry for Cloud providers in order to help customers compare cloud security offerings across vendors. The CSA has a questionnaire for each provider – basically an RFP/RFI – and will publish the results for customers. The good news is that this will provide some of the high-level information that is really hard to find – or entirely absent

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