How Secure Is Your Data? Financial Management and Human Resources Forum Atlanta – October 7, 2013 Data Security – Essential for Trust Robert E. Berdelle 2013 Finance and HR Forum Brian A. Gallagher 3 Atlanta October 7, 2013 The Speed of Trust by Stephen M R Covey The 5 Waves of Trust Self Trust Relationship Trust Organizational Trust Market Trust Societal Trust Trust begins with each of us personally, continues to our relationships, expands to our organizations, extends into our marketplace relationships and encompasses our global society at large. To build trust with others, we must first start with ourselves. 4 Atlanta October 7, 2013 The Speed of Trust CHARACTER COMPETENCE • Integrity: honesty, walking your talk, ethics • Capabilities: talents, skills, knowledge to produce results • Intent: motives, agendas, mutual benefit 5 Atlanta October 7, 2013 • Results: track record, performance, getting the right things done U.S. Trust Trends – United Way, Red Cross, Organizational Metric - Trust Salvation Army, and the Charitable Sector 95% 85% 75% 65% 55% 45% 35% United Way Charitable Organizations Red Cross Salvation Army U.S. NGO's (Edelman's Trust Barometer) 2001 36% 2002 79% 82% 86% 93% 41% 2003 75% 84% 84% 92% 49% 2004 77% 86% 89% 91% 47% 2005 76% 82% 85% 92% 55% 2006 79% 83% 86% 92% 54% 2007 75% 79% 85% 89% 57% 2008 81% 83% 88% 90% 63% 2009 71% 71% 89% 90% 45% 2010 70% 74% 89% 90% 63% 2011 69% 70% 86% 90% 55% 2012 70% 74% 89% 89% 58% Tracker: Q. For the next list of charitable organizations that I read, I would like you to tell me how much trust you have in the organization to accomplish what they say they will do. (Top 2 Box, 4-point scale, General Population, age 18+) Edelman: Q. Below is a list of institutions. For each one, please indicate how much you trust that institution to do what is right using a 9point scale where one means that you “do not trust them at all” and nine means that you “trust them a great deal”. (NGOs, Top 4 Box, Informed Publics ages 25-64) 6 Atlanta October 7, 2013 6 Data Security - Essential for Trust • United Way Strategy – Enhance Corporate and Individual Engagement More personal donor information is essential Companies require employee information to be secure and confidential Imperative for United Ways to competently handle donor information • Two United Way Initiatives: 1) 2) 7 Atlanta UWW data security assessment Engaged Clifton Larson Allen Controls review and penetration/vulnerability testing Recommend corrective actions FIC initiative to create best practices document for UW network October 7, 2013 United Way Worldwide Financial Issues Committee (FIC) Data Security Update Financial Management and Human Resources Forum Atlanta – October 7, 2013 What Led to the Work? FIC Meeting – New Orleans March 2013 As United Ways, we want more information about our donors – are we being proactive enough to show the companies we are going to “secure” it? Companies who are running our United Way campaigns are asking what steps are being taken to secure their employee information Higher expectations/demand for protection of personal information (not just credit card information – PCI Compliance) 9 Atlanta October 7, 2013 Scope of Project Document Structure Best Practice Not a Policy What Information Is At Risk? 10 Atlanta October 7, 2013 Scope of Project (cont.) Table of Contents – DRAFT Executive Summary – Donor Expectations and Trust What Information Is At Risk? o Information Protected by Federal and State Laws (US focused) o Constituent Information o United Way (Local or Worldwide) Information o Information Governed by Contracts, Grants, etc., with Companies/Agencies Risk Assessment 11 Atlanta o Physical Data Center o Access to Local Information o Third Party Service Providers o Storage Media o PCI Compliance October 7, 2013 Scope of Project (cont.) Table of Contents – DRAFT Internal Controls to Mitigate Risks o Limiting Access to Information o Encryption o Internal Controls o Antivirus Deployment o Employee Onboarding/Offboarding Policy o Mobile Devices Other Risk Management Issues 12 Atlanta o Insurance o Response to an Information Breach o Security Awareness Training o Security Review Plan o Incident Response Plan October 7, 2013 Scope of Project (cont.) Table of Contents – DRAFT Other Risk Management Issues (cont.) o IT Policies and Procedures Document o Network Diagram and Documentation o Business Continuity/Disaster Recovery Plan Assessment Tools o Self-Assessment Questionnaire o Performance Matrix o Resources Appendix o 13 Atlanta Sample Polices October 7, 2013 Team Assigned Finance Professionals o Amy Maziarka, Co-Chair, United Way of the Greater Chippewa Valley o Mark Erickson, Co-Chair, United Way of Palm Beach County o Ray Berry, United Way of Pioneer Valley o Kathy Doty, United Way of Greater Toledo o Patricia Latimore, United Way of Massachusetts Bay & Merrimack Valley o Darren Minks, United Way of the Plains o Taryn Vidovich, Orange County United Way IT Professionals 14 Atlanta o Chris Keightley, United Way Worldwide o Michael Parker, United Way for Southeastern Michigan o Chris Reese, Orange County United Way o Javier Torner, CSU San Bernardino o Brian Weber, United Way Worldwide October 7, 2013 ©2012 CliftonLarsonAllen LLP Data Security Awareness Presentation Gil Bohene CISA, CRISC, CISM – Partner Laura Faulkner - Senior IT Consultant, CliftonLarsonAllen, LLP Atlanta 1515 October 7, 2013 ©2012 CliftonLarsonAllen LLP General Control Reviews • Information Technology General Control Review (IT GCR): – An IT General Controls Review is focused on processes that support the proper management of information technology assets and the protection of information from a best practices perspective • Benefits: – Provide an overview of the operating environment including locations, contacts, personnel resources, services, business processes, application systems and technical infrastructure. – Identify IT control weaknesses and breakdowns i.e. perform gap analysis for desired controls – Improve overall IT infrastructure • Deliverable: – Detailed GCR report that contains specific finding and recommended remediation for one aspect of application access controls including assignment of risk, priority, and level of effort. 16 ©2012 CliftonLarsonAllen LLP Technical IT Services • Internal Vulnerability Assessments (IVA): – The Internal Vulnerability Assessment will be a technical evaluation of the key devices (file servers, mail servers, production servers, routers, switches, etc.) that reside on your trusted business networkPromotes deeper knowledge of the client’s business. • External Penetration Testing (EPT): – The External Network Penetration Test is designed to aggressively test your network perimeter to identify exposure to security breaches from outside your network. • Deliverable: – Our deliverable report will provide your network administrators with detailed recommendations for how to address specific findings and harden IT infrastructure. – Identify potential vulnerabilities inside/outside the network that might be used to: – Gain unauthorized access to sensitive confidential information. – Modify or destroy data. – Operate trusted business systems for non-business purposes. 17 ©2012 CliftonLarsonAllen LLP IT General Control Approach • Approach and execution – Interview key staff – Review documentation – Observe current processes and testing controls within the organization. • Scope – 10 Key Information Technology domains were assessed – – – – – – – – – – 18 Governance controls Server controls Network controls Software controls Application controls Workstations User Access controls Business Continuity Planning (BCP) Disaster Recovery Planning (DRP) Physical Security & Environmental controls ©2012 CliftonLarsonAllen LLP General Control Reviews - Scope 19 ©2012 CliftonLarsonAllen LLP Internal Vulnerability Assessment Approach • Approach and execution - Based on two (2) phases: 1. Penetration Testing – based on limited access, we apply hacker like tools and techniques 2. Configuration auditing - validates the issues identified during the first phase and further tests system configurations • Scope – 3 Information Technology domains are assessed ◊ Authentication ◊ Patch management ◊ Configuration 20 ©2012 CliftonLarsonAllen LLP External Penetration Testing Approach • Approach and execution - Based on four (4) phases: 1. 2. 3. 4. Discovery– find your “entry” points Reconnaissance- gather specifics about the systems Scanning- locate potential vulnerabilities that would allow access Penetrate- try to gain access by exploiting the vulnerabilities • Scope – 3 Information Technology domains are assessed ◊ Authentication ◊ Patch Management ◊ Configuration 21 ©2012 CliftonLarsonAllen LLP What does this mean for your Organization? • You’re only as strong as your weakest link – Employees – Vendors – Customers/Donors • Have an ongoing discussion about RISK – – – – 22 Review your controls Identify weaknesses Secure what you can Knowledge is key ©2012 CliftonLarsonAllen LLP Best Practices to consider… • Access Control – Assign access permissions based on the theory of least privilege – Segregation of duties • Assign user accountability – Limit generic or shared accounts • Implement strong password policies – – – – – 23 Minimum 8 characters 24 passwords remembered i.e. no re-use of last 24 passwords Expiration of 90 days Complexity enabled Lockout policy ©2012 CliftonLarsonAllen LLP Best Practices, etc. • Vendor Management – Identify your critical vendors – Assign risk – Perform due diligence • Change Management – Changes should be documented and approved prior to implementation • Network Administration – Stay current on patches/updates – Restrict external access as much as possible – Implement monitoring 24 ©2012 CliftonLarsonAllen LLP Best Practices, etc. • Disaster Recovery/Business Continuity – Identify the critical processes that drive your business – Develop your “what if” scenarios – Determine your recovery strategies • Physical Security – Restrict physical access to data center – Implement environmental controls 25 ©2012 CliftonLarsonAllen LLP Conclusion • Identify what’s critical • Be PROACTIVE, not reactive • Use a different perspective • Educate yourself and your employees THANK YOU! Presenter - Laura Faulkner 26 ©2012 CliftonLarsonAllen LLP CONTACT INFORMATION Laura Faulkner – 612.397.3090 [email protected] Gil Bohene – 571.227.9500 [email protected] 27 ©2012 CliftonLarsonAllen LLP Security Awareness Training Michael Parker UW for Southeastern Michigan Financial Management and Human Resources Forum Atlanta – October 7, 2013 What is “Security Awareness”? Security awareness is “the knowledge and attitude members of an organization possess regarding the protection of the physical and especially, information assets of that organization.” • Organizational-wide culture, with behavioral change component • Includes people, process and technology 29 Atlanta October 7, 2013 Why do we need Security Awareness Training? • Organizational value statement – drives credibility and transparency • Ethical responsibility to our constituents • Compliance with federal and state laws (HIPAA, PCI, PII, etc.) • Contractual mandates by companies we work with • Risk management 30 Atlanta October 7, 2013 Elements of successful security awareness programs • C-Level support – buy-in is critical • Partnering with key departments – mutual interests can drive support • Creativity – materials, communication, events • Metrics – use of attitude surveys, # of security related incidents • Emphasize “how to” rather than “don’t do this” • 90 day plans focusing on 3 topics vs. annual plan – reinforces knowledge, changes behaviors • Multiple forms of training materials – online systems, newsletters, posters, games, etc.; tailored to generational differences 31 Atlanta October 7, 2013 Typical topics covered in awareness training programs 32 • The nature of sensitive material and physical assets individuals may come in contact with • Employee and contractor responsibilities in handling sensitive information, including review of nondisclosure agreements • Requirements for proper handling of sensitive material in physical form, including marking, transmission, storage and destruction • Proper methods for protecting sensitive information on computer systems, including password policies, encryption and network access • Other computer security concerns, including malware, phishing, social engineering etc. • Workplace security, including building access, wearing of security badges, reporting of incidents, forbidden articles, websites, etc. • Consequences of failure to properly protect information, including potential loss of employment, economic consequences to the firm, damage to individuals whose private records are divulged, and possible civil and criminal penalties Atlanta October 7, 2013 Typical content covered in training General security awareness (all employees) • High level review of network logins/passwords, viruses/malware, mobile data, physical security, phishers, acceptable use policies, incident response, security services, risk management, encryption, backups Security awareness for managers • Lead by example, security management practices, legal issues Security awareness for IT professionals • Common forms of attack, network security, disaster recovery, best practices Security awareness for web application developers • Open Web Application Security Project (OWASP) Top Ten list 33 Atlanta October 7, 2013 Typical content covered in training, continued Physical security • Workplace violence, theft, physical access controls, emergencies Data and records retention • Document creation, laws, best practices for retention and destruction Privacy awareness - public/non-public information, laws, best practices PCI requirements and compliance HIPAA/HITECH – PHI (protected health information) 34 Atlanta October 7, 2013 Handling Security Breaches Notification considerations • Legal requirements • UWW requirements • Constituent response • Media response Incident Response Plans – covers physical and network breaches • Notification contact lists • Assessment phase • Response determination • Containment phase 35 Atlanta October 7, 2013 Handling Security Breaches, continued • Documentation – logs of who, what, where, pictures, etc. • Evidence preservation – pictures, damage • Damage assessment – costs/values • Notification – insurance, legal, police • Evaluation of plan 36 Atlanta October 7, 2013 Questions??