2010 06 gartner avoiding audit fatigue in nine steps 1d

Configuration Assessment &Change Auditing Solutions

VISIBILITYINTELLIGENCE

AUTOMATION

IT Security andCompliance Automation

Avoiding Audit Fatigue: Achieving Compliance In A Multi-Compliance World In Nine Steps

Gene Kim, CISA, TOCICO JonahCTO and Founder(Twitter: @RealGeneKim) Gartner 2010

compliance | security | control 2 Don’t Take Chances. TAKE CONTROL. IT SECURITY & COMPLIANCE AUTOMATION

Where Did The High Performers Come From?


Agenda

The problems of compliance du jour and the audit blame cycle How did the high performing IT organizations make their

“good to great” transformations? Nine practical steps overcome audit fatigue What does integration of security controls into daily operation

feel like? Additional resources

Authors Gene Kim, Founder/CTO, Tripwire, Inc. Jennifer Bayuk, Cybersecurity Program Director, Stevens Institute of Technology


“Boss, We Are Ready For The Upcoming Audits…”


“OMG. OMG. The Auditors Are Coming When?!?”


“IT Operations Not Quite As Ready As They Thought…”


“Infosec Must Do Heroics, Generating Reports And Presentations From Scratch…”


“Despite Heroics, The Business Still Fails The Audit…”


“Infosec As Professional Apologist…’”


Problems: The Real Business Cost

Scheduled value-adding work and projects are delayed because of all the urgent and unplanned audit prep work

Business continues to implement controls as a part of a one-time audit preparation project to achieve compliance, with little thought on how to maintain compliance over time

Next time requires just as much effort, instead of integrating controls into daily business and IT operational processes

The business starts treating audit prep as a legitimate value-adding project, even charging time against it

Multiple regulatory and contractual requirements result in IT controls being tested numerous times by numerous parties, requiring management to perform work multiple times


Information Security and Compliance Risks

Information security practitioners are always one change away from a security breach Front page news Regulatory fines Brand damage

High profile security failures are increasing external pressures for security and compliance Sarbanes-Oxley (SOX) Act of 2002, the Gramm-

Leach-Bliley Act, Health Insurance Portability and Accountability Act (HIPAA), emerging privacy laws, and the Payment Card Industry Data Security Standard (PCI DSS)

14

COMPLIANCESECURITYCONTROL

Going from Good to Great


Desired Outcome: Create A Higher Performing, More Nimble and More Secure IT Organization

1

10

100

1000

10,000

0 20 40 60 80 100 120 140

Operations Metrics Benchmarks:Best in Class: Server/sysadmin ratios

# S

erve

rs

Server/sysadmin ratio

Siz

e of

Ope

ratio

n

Efficiency of Operation

• Highest ratio of staff for pre-production processes

• Lowest amount of unplanned work

• Highest change success rate

• Best posture of compliance

• Lowest cost of compliance

Source: IT Process Institute (2001)

Best in Class Ops and Security


Higher Performing IT Organizations Are More Stable, Nimble, Compliant And Secure

High performers maintain a posture of compliance Fewest number of repeat audit findings One-third amount of audit preparation effort

High performers find and fix security breaches faster 5 times more likely to detect breaches by automated control 5 times less likely to have breaches result in a loss event

When high performers implement changes… 14 times more changes One-half the change failure rate One-quarter the first fix failure rate 10x faster MTTR for Sev 1 outages

When high performers manage IT resources… One-third the amount of unplanned work 8 times more projects and IT services 6 times more applications Source: IT Process Institute, May 2008


Visible Ops: Playbook of High Performers

The IT Process Institute has been studying high-performing organizations since 1999 What is common to all the high

performers? What is different between them and

average and low performers? How did they become great?

Answers have been codified in the Visible Ops Methodology


Over Ten Years, We Benchmarked 1500+ IT Orgs

Source: IT Process Institute (2008)

Source: EMA (2009)


2007: Three Controls Predict 60% Of Performance

To what extent does an organization define, monitor and enforce the following? Standardized configuration strategy Process discipline Controlled access to production systems

Source: IT Process Institute, May 2008

20


Nine Practical Steps To Overcome Audit Fatigue And The Blame Cycle


The Nine Steps To Avoid Audit Fatigue

Step 1: Align with tone at the top Step 2: Create a set of merged infosec and compliance/business

goals Step 3: Define ideal information security goal indicators Step 4: Gain an end-to-end understanding of the information flow Step 5: Agree upon control ownership, roles and responsibilities Step 6: Define the control tests so business process control

owners will agree with the results Step 7: Schedule and conduct regular control tests Step 8: Organize metrics and remediation reports Step 9: Detect and respond to significant changes to the control

environment


Step 1: Align With Tone At The Top

Ensure that compliance activity is clearly managed from the top down.


Step 2: Merge Information Security Into The Compliance/ Business Goals

Document IT governance goals and the risks to achieving those goals

Confirm that information security and compliance helps achieve those goals.

For instance: A manufacturing company must comply with a regulatory

requirement that certain chemical toxins are never released into the atmosphere in amounts over 10 particles per second.

The manufacturing control system has been designed to ensure that this toxin is released at a rate of only 1 particle per second.



What is the business objective? Ensure smooth operation of the manufacturing process, in

accordance to the business plan and all associated laws and regulations.

What are the information security and compliance risks? The manufacturing control system could fail and release more

than the allowed amount of the chemical toxin into the atmosphere.

The measurement system may not detect this release. Also, the manufacturing control measurement data could be

altered or lost, which would prevent management from validating emissions output compliance.

What is my information security goal to address this risk? We must maintain integrity over the particle release

measurement process and the measurement data.



What control will we implement to meet this goal? An access and measurement testing control process will protect the toxin

release measurement software against tampering. The control will alert operations when changes to access are detected and

when abnormal variations in the toxin measurements occur. The alert response will include automated and manual procedures that verify

that the algorithm installed in the production system is the same as the one that underwent rigorous pre-production system testing.

What does plant management (the business process owner) need to do to support this goal? The control process would require the business process owner to configure the

production system to minimize the access any given individual needs to change the algorithm and the corresponding data.

The control process would also require the business process owner to minimize the job functions that require access to the algorithms and the measurement data.


Step 3: Define Ideal Information Security Measures

Develop theoretical ideal indicators that demonstrate that information security goals are being met.

Examples # of access roles not validated by management % of accounts not matching management-defined roles % of configurations not pre-approved by management % of changes not approved by management % of systems with centralized logging


Step 4: Gain End-to-End Understanding

Do an end-to-end business process walk-through to understand and document: Where does sensitive information enter, transit, get stored, and

exit the organization? What are the risks to organizational goals and information flow? Where is reliance placed on technology to prevent and detect

control failures?



A merchant has a business process that supports a customer loyalty program. The program includes issuing branded credit cards. The consumer credit information flow starts with a customer

filling out an online application form, which is… Sent to the credit calculation application, is then… Sent to a sales application, and… Ends up in an application that runs on the desktop of every

customer service representative. What is the business goal?

To ensure that customers approved for the credit card services are capable of meeting their obligations, so that any credit extended to the customer is likely to be repaid.



What are the business, information security and compliance risks? Customer information is inaccurate Customer information is inadvertently disclosed, violating

regulatory requirements Through what applications does the information flow?

The online application form is delivered through a third-party vendor,

The credit calculation is done on cloud computing resources The sales application is run internally by IT operations The customer service application is run by a combination of

internally developed server software and desktop software on the customer service desktops.


Step 5: Agree Upon Control Ownership, Roles And Responsibilities

Clearly define roles and responsibilities for audit compliance activities at the process owner level.


Step 6: Define The Control Tests So Control Owners Will Agree With The Results

Make sure that evidence that demonstrates compliance goals have been met can be generated in an automated manner, upon demand. This will mirror the accountability spreadsheet that the auditors

will likely construct

This is what enables information security to not be left holding the bag when IT operations is disorganized or unprepared.


Step 7: Schedule And Conduct Regular Control Tests

Conduct tests of controls effectiveness frequently enough be able to rely on their effectiveness regardless of variances in audit scope and timing. Ensure that sample size is safely larger than the auditor’s

You will find unprepared IT control owners long before the audits

“Hope is not a strategy. Trust is not a control.”


Step 8: Organize Metrics And Remediation Reports

Track the completion of required remediation work, ideally to be completed well in advance of the audit. By compliance objective By business process By control owner

This will look like a PMO status report


Step 9: Detect And Respond To Significant Changes To The Control Environment

Have the situational awareness to know when the information flow or control environment has significantly changed, requiring these steps to be redone

For example, when an application is changed to allow consumer data to be downloaded to desktops instead of being viewed through pre-defined application reports).

35


What Does Integration Of Security Controls Into Daily Operations Look Like?


Find What’s Most Important First


Quickly Find What Is Different…


Before Something Bad Happens…


Find Risk Early…


Communicate It Effectively To Peers…


Hold People Accountable…


Based On Objective Evidence…


Answer Important Questions…


Ever Increasing Situational Mastery…


Show Value To The Business…


Be Recognized For Contribution…


And Do More With Less…


Higher Performing IT Organizations Are More Stable, Nimble, Compliant And Secure

High performers maintain a posture of compliance Fewest number of repeat audit findings One-third amount of audit preparation effort

High performers find and fix security breaches faster 5 times more likely to detect breaches by automated control 5 times less likely to have breaches result in a loss event

When high performers implement changes… 14 times more changes One-half the change failure rate One-quarter the first fix failure rate 10x faster MTTR for Sev 1 outages

When high performers manage IT resources… One-third the amount of unplanned work 8 times more projects and IT services 6 times more applications Source: IT Process Institute, May 2008


Tripwire VIATM

VIA Automate Compliance

Protect Sensitive Data

EliminateOutages

TAKE CONTROL.

Tripwire TM

It’s The Way…


Tripwire Enterprise Tripwire Log Center

File Integrity Monitoring

Compliance Policy Manager

Configuration Remediation

Log Manager

SecurityEvent Manager

Tripwire VIATM

VISIBILITY INTELLIGENCE AUTOMATION

Tripwire VIA™IT Security & Compliance Automation Suite


Resources

Ο From the IT Process Institute www.itpi.org Both Visible Ops Handbooks ITPI IT Controls Performance Study

Stop by the Tripwire booth for a copy of Visible Ops Security “Avoiding Audit Fatigue: Nine Steps To

Achieve Compliance In A Multi-Compliance World ” white paper

Follow Gene Kim On Twitter: @RealGeneKim [email protected] Blog: http://www.tripwire.com/blog/?cat=34

2010 06 gartner avoiding audit fatigue in nine steps 1d

Business

security breaches

audit retests

audit test

audit fatiguewhat

secure high performers

process institute

audit preparation effort

proof of compliance