It’s All About the Data!David C. Frier, CISSP

Security Practice LeadCIBER, Upstate NY

Oct. 21, 2010

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CIBER Profile

• CIBER is a $1Billion Global IT Services Company that Builds, Integrates and Supports Business Applications and IT Infrastructures for Business and Government

Consistent growth and profitability since 1974 More than 8,500 employees NYSE (CBR) - Headquartered in Denver 85 Offices in 18 countries US and Offshore Development Centers Global IT Operations Centers – US & Europe Global practices supported by local resources Fortune 500 and mid-market leaders/challengers Focus on quality: ISO 9001, CPMM, SAS 70

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Frier Profile

• Frier is a less-than-$1Billion IT Professional who Builds, Integrates and Supports Business Applications and IT Infrastructures for Business and Government

Consistent growth since 1957 (first up then out) (DCF) - Headquartered in Rochester IT Operations first established in 1979 IT Security, Operations, Architecture Project Management and Consulting Training and IT Evangelism CISSP, CRISC (pending)

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Outline

• What is in scope of Data Protection?• What Threats exist?• Who Cares?• What is included in Data Protection?• Is Data Protection Effective• One approach for Data Classification

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– Regulated Data• HIPAA• PCI• GLBA

– PII/SPI• Under Safe Harbor• Subject to Breach Disclosure laws

– Strategic Data• IP• Sales & Marketing Data• Financial (SOX)• M&A, Recruiting, other non-public plans

Data Protection – what is in scope

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• Lost or Stolen Devices– Laptops and removable storage most common

• Disposal – Incorrect disposal of disk and tape media

• Criminal Attacks– Hacking more than physical theft

• Network Exposure– Misconfigured web presence– Email attachments

• Malicious Insiders

Threats to Data

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Who cares about Data Protection Programs?

Source: Business Case for Data Protection, Ponemon Institute, July 2009

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• Data Loss Prevention- Network • Data Loss Prevention-

Endpoint• Data Loss Prevention- Storage • Content Discovery (Process) • Email Filtering • Database Activity Monitoring • Full Drive Encryption • USB/Portable Media

Encryption or Device Control

• Enterprise Digital Rights Management

• Database Encryption • Application Encryption • Web Application Firewall • Backup Tape Encryption • Entitlement Management • Access Management • Data Masking • Network Segregation • Server/Endpoint Hardening

Enterprise Data Protection – what is included

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• Perceived Effectiveness ¹– CEOs: 58%– Other C-Levels: 48%

• Which Controls are Most Effective²Data Loss Prevention- NetworkData Loss Prevention- EndpointData Loss Prevention- StorageContent Discovery (Process)Email Filtering

Are Corporate Data Protection Programs Effective?

2 – Source: Securosis 2010 Data Security Survey, Securosis, LLC, … 20101 – Source: Business Case for Data Protection, Ponemon Institute, July 2009

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• Which Controls are Least Effective?Email FilteringUSB/Portable Media Encryption or Device ControlDatabase Activity MonitoringBackup Tape EncryptionContent Discovery (Process)

Notice anything odd?

Why Are Corporate Data Protection Programs Effective?

Source: Securosis 2010 Data Security Survey, Securosis, LLC, … 2010

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Do you know what you are charged to protect?

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Who recognizes this?

Kings play chess on finely grained sand

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Did you take zoology in school?

Kings play chess on finely grained sand

• Kingdom• Phylum• Class• Order• Family• Genus• Species

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• Use a Taxonomy • From Kingdoms, the highest level, down to individual

reports and documents• Seven layers may seem like a lot

– …but it’s easy to find pockets where you need more

Data Classification

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• Start with “Public” and “Non-Public”• You might add a third for customer-privileged

information

• Most Data protection effort will focus on Non-Public

The point of the taxonomy is to successively sharpen the focus of the enterprise data protection efforts

Data Classification -- Kingdoms

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• This is a good layer for your data owner organizations– Yes: All data must have an owner. – Owners make the decisions about what level of protection

is needed– Typically, data owners are the groups that own the

processes that create/update/delete the data• From here down you will see categories repeated

– This is the way to express the matrix nature of some of these designations across the top-down hierarchy

Data Classification -- Phyla

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Data Classification -- Classes

• At the Class level you can apply the levels-of-sensitivity classifications

– Confidential– Sensitive– “Company only”

These are suggestions only… the important thing is to be consistent across all the data with what you do at a given level

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• With Order, start to divide up the data into groups of related business processes

– Example: within the HR phylum, • Payroll• Benefits• Performance Mgt.• Recruiting

– Each of these may be in different classes for sensitivity– Class designations will often repeat across phyla but that’s

OK

Data Classification -- Orders

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• For Family, get to the application or system level– For example, within the Benefits order

• One app manages Health Care• Another manages PTO• Another for Tuition Reimbursement• etc.

– It is also likely that this isolates specific business processes

– “Applications” in this context may be modules within larger enterprise systems

Data Classification -- Families

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• Genus is a particular data type– Reports – Databases– Feed files

• Species is instances of those types– “The weekly payroll register”– “The monthly healthcare claims report”

Data Classification – Genus & Species

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Let’s look at that payroll report

• Kingdom – Non-public • Phylum – HR • Class – Confidential • Order – Payroll • Family – ADP interface • Genus – Reports• Species – Payroll report

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• Classification and handling decisions may be made wherever appropriate

– For example, a single massive database may power an enterprise HRIS that is classified at the Order level

– And that database might not be safe to have try to support multiple levels of security, so you decide to take the “worst case” approach.

• You may not need all the levels – But if you give yourself the room you will get this done to

enough detail to make informed decisions

Data Classification – Put it to use

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• Determine Regulatory Scope• Prioritize Coverage• Phase-in Programs• Get below-C Mgt. Buy-In• Communicate why you are acting to protect this and

not that (yet)

Data Classification – Put it to use

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Remember!

It’s all about the data!

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• Ponemon Reports– http://www.ponemon.org/data-security

• Securosis Survey– http://www.imperva.com/resources/analyst.html

• CIBER– http://www.ciber.com/

• Frier– dfrier@ciber.com

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