Why Choose JED Consulting Services LLC?
• The HIPAA Security Rule provides the "what" in regard to requirements with which health care organizations must comply, yet we're often asked "how can we implement safeguards that fulfill the intent of the rule?" and "what else should HCO's be doing to protect patient and hospital assets?". This company is purposefully built to provide an effective answer.
• Our Health Care Security Group dissects the Security Rule and highlights important security controls to identify and mitigate both the insider and external based attacks.
If you are an information security professional working in health care, our company will provide you with practical advice for stopping even the most advanced attacks that may target the organization.
Our initial focus was on existing threats to health care information systems and data. We will examine 'why' and 'how' patient information is being targeted, as well as evolving trends, including, but not limited to the commercialization of malicious software, medical identity theft, and insider threats. JED also provides clients with an overview of the HIPAA Security Rule and its context, with close attention paid to the rules structure, safeguards, and the implementation specifications governing ePHI. This information will remove ambiguity and get of how to defend patient data and other sensitive information. The section concludes with a discussion on security frameworks, controls, and practical countermeasures.
Who in your organization has done an analysis of recent breach data? Who has focused on sensitive asset identification and hardening? Do we have a foundation for a data loss prevention ("DLP") program?
JED Consulting Services begins with examining the risk analysis requirement of the Security Rule, §164.308(a)(1)(ii)(A) along with relevant audit findings and important considerations for developing a defensible risk management process. Physical and technical safeguards are also examined. Have we then transition to a review of electronic health records ("EHR") security, often a prized target by criminals, and EHR application assessment and hardening? JED Health Care Security group concludes by discussing the current state of medical device security and risk management processes.
Hands-on exercises covered include log monitoring and analysis techniques, vulnerability assessment, asset encryption, and configuration analysis. Additional labs may be added, time permitting.
What can we do to Implement and audit the critical controls we have focused on since 1989?
• Apply a security framework based on actual threats that is measurable, scalable, and reliable in stop- ping known attacks and protecting organizations' important information and systems
• Understand the importance of each control, how it is compromised if ignored, and explain the defensive goals that result in quick wins and increased visibility of network and systems
• Identify and utilize tools that implement controls through automation
• Learn how to create a scoring tool for measuring the effectiveness of each controls the effectiveness of each control
• Employ specific metrics to establish a baseline and measure the effectiveness of security controls
• Understand how critical controls map to standards such as NIST 800-53, ISO 27002, the Australian Top 35, and more
• Audit each of the critical security controls, with specific, proven templates, checklists, and scripts provided to facilitate the audit process
We will cover an introduction and overview of the Critical Security Controls, laying the foundation for the rest of the engagement. For each control the following information will be covered, and we will follow the same outline for each control:
1. Overview of the Control
2. How it is Compromised
3. Defensive Goals
4. Quick Wins
5. Visibility & Attribution
6. Configuration & Hygiene
8. Overview of Evaluating the Control
9. Core Evaluation Test(s)
10. Testing/Reporting Metrics
11. Steps for Root Cause Analysis of Failures
12. Audit/Evaluation Methodologies
13. Evaluation Tools
14. Exercise to Illustrate Implementation Or Steps for Auditing a Control
• Critical Control 1: Inventory of Authorized and Unauthorized Devices
o Any time a new device is installed on a network, the risks of exposing the network to unknown vulnerabilities or hampering its operation are present.
o Malicious code can take advantage of new hardware that is not configured and patched with appropriate security updates at the time of installation.
o Attackers can use these vulnerable systems to install backdoors before they are hardened. In automating critical control 1, it is critical for all devices to have an accurate and up-to-date inventory control system in place.
o Any device not in the database should be prohibited from connecting to the network.
o Some organizations maintain asset inventories by using specific large-scale enterprise commercial products or by using free solutions to track and sweep the network periodically.
o To evaluate the implementation of Control 1 on a periodic basis, the evaluation team will connect hardened test systems to at least 10 locations on the network.
o This will include a selection of subnets associated with DMZs, workstations, and servers.
• Critical Control 2: Inventory of Authorized and Unauthorized Software
o An organization without the ability to inventory and control its computers' installed programs makes its systems more vulnerable to attack.
o Furthermore, poorly controlled machines are more likely to be running software that is unneeded for business purposes, introducing potential security flaws.
o Compromised systems become a staging point for attackers to collect sensitive information.
o In order to combat this potential threat, an organization should scan a network and identify known or responding applications.
o Commercial software and asset inventory tools are widely available.
o The best tools provide an inventory check of hundreds of common applications, pulling information about the patch level of each installed program.
o This ensures that it is the latest version and that it leverages standardized application names, like those found in the Common Platform Enumeration (CPE) specification.
o In addition to inventory checks, tools that implement whitelists (allow) and blacklists (deny) of programs are included in many modern end-point security suites.
o To evaluate the implementation of Control 2 on a periodic basis, the team must move a benign software test program that is not included in the authorized software list on 10 systems on the network.
o The team must then verify that the software is blocked and unable to run.
• Critical Control 3: Secure Configurations for Hardware and Software on Laptops, Workstations, and Servers
o Default configurations of software are often geared to ease-of-deployment and ease-of-use and not security, leaving some systems exploitable in their default state.
o Attackers attempt to exploit both network-accessible services and client software using various forms of malware.
o Without the ability to inventory and control installed and running, enterprises make their systems more vulnerable.
o Organizations can implement this control by developing a series of images and secure storage servers for hosting these standard images.
o Configuration management tools can be employed to measure the settings of the installed software and to look for deviations from the standard image configurations used by the organization.
o To evaluate the implementation of Control 3 on a periodic basis, an evaluation team must move a benign test system (one that does not contain the official hardened image, but does contain additional services, ports, and configuration files changes) onto the network.
o The evaluation team must then verify that the systems generate an alert or e-mail notice regarding the changes to the software.
• Critical Control 4: Continuous Vulnerability Assessment and Remediation
o Soon after new vulnerabilities are discovered and reported by security researchers or vendors, attackers engineer exploit code and launch it against targets of interest.
o Any significant delays finding or fixing software with critical vulnerabilities provides ample opportunity for persistent attackers to break through and gain control of vulnerable machines.
o A large number of vulnerability scanning tools are available to evaluate the security configuration of systems.
o The most effective vulnerability scanning tools compare the results of the current scan with previous scans to determine how the vulnerabilities in the environment have changed over time.
o All machines identified by the asset inventory system must be scanned for vulnerabilities.
o To evaluate the implementation of Control 4 on a periodic basis, the evaluation team must verify that scanning tools have successfully completed their weekly or daily scans.
• Critical Control 5: Controlled Use of Administrative Privileges
o The most common method attackers use to infiltrate a target enterprise is through an employee's own misuse of administrator privileges.
o An attacker can easily convince a workstation user to open a malicious e-mail attachment, download and open a file from a malicious site, or surf to a site that automatically downloads malicious content.
o If the user is logged in as an administrator, the attacker has full access to the system.
o Built-in operating system features can extract lists of accounts with super-user privileges, both locally on individual systems and on overall domain controllers.
o These accounts should be monitored and tracked very closely.
o To evaluate the implementation of Control 5 on a periodic basis, an evaluation team must verify that the organization's password policy is enforced and administrator accounts are carefully controlled.
o The evaluation team does this by creating a temporary, disabled, limited privilege test account on ten different systems.
o It then attempts to change the password on the account to a value that does not meet the organization's password policy.
• Critical Control 6: Maintenance, Monitoring, and Analysis of Audit Logs
o At times, audit logs provide the only evidence of a successful attack.
o Many organizations keep audit records for compliance purposes but rarely review them.
o When audit logs are not reviewed, organizations do not know their systems have been compromised. Attackers rely on this.
o Most free and commercial operating systems, network services, and firewall technologies offer logging capabilities.
o Such logging should be activated, and logs should be sent to centralized logging servers.
o The system must be capable of logging all events across the network.
o The logging must be validated across both network and host-based systems.
o To evaluate the implementation of Control 6 on a periodic basis, an evaluation team must review the security logs of various network devices, servers, and hosts.
• Critical Control 7: Email and Web Browser Protections
o Web browsers and email clients are very common points of entry and attack because of their high technical complexity and flexibility, and their direct interaction with users and within the other systems and websites.
o Content can be crafted to entice of spoof users into taking actions that greatly increase risk and allow introduction of malicious code, loss of valuable data, and other attacks.
o Organizations must minimize the attack surface and the opportunities for attackers to manipulate human behavior through their interaction with web browsers and email systems.
• Critical Control 8: Malware Defenses
o Malicious software is an integral and dangerous aspect of Internet threats.
o It targets end users and organizations via Web browsing, e-mail attachments, mobile devices, and other vectors.
o Malicious code may tamper with a system's contents, capture sensitive data, and spread to other systems.
o To ensure anti-virus signatures are up-to-date, effective organizations use automation.
o They use the built-in administrative features of enterprise endpoint security suites to verify that anti-virus, anti-spyware, and host-based Intrusion Detection Systems (IDS) features are active on every managed system.
o They also run automated assessments daily and review the results to find and mitigate systems that have deactivated such protections or do not have the latest malware definitions.
o The system must identify any malicious software that is either installed, attempted to be installed, executed, or attempted to be executed, on a computer system.
o To evaluate the implementation of Control 8 on a periodic basis, the evaluation team must move a benign software test program appearing to be malware onto a system and make sure it is properly discovered and remediated.
• Critical Control 9: Limitation and Control of Network Ports, Protocols, and Services
o Attackers search for remotely accessible network services that are vulnerable to exploitation.
o Many software packages automatically install services and turn them on as part of the installation of the main software package.
o When this occurs, the software rarely informs a user that the services have been enabled.
o Port scanning tools are used to determine which services are listening on the network for a range of target systems.
o In addition to determining which ports are open, effective port scanners can be configured to identify the version of the protocol and service listening on each discovered open port.
o The system must be capable of identifying any new unauthorized listening network ports that are connected to the network.
o To evaluate the implementation of Control 9 on a periodic basis, the evaluation team must install hardened test services with network listeners on ten locations on the network, including a selection of subnets associated with DMZs, workstations, and servers.
• Critical Control 10: Data Recovery Capability (validated manually)
o When attackers compromise machines, they often make significant changes to configurations and software.
o Sometimes attackers also make subtle alterations of data stored on compromised machines, potentially jeopardizing organizational effectiveness with polluted information.
o Once per quarter, a testing team should evaluate a random sample of system backups by attempting to restore them on a test bed environment.
o The restored systems should be verified to ensure that the operating system, application, and datum from the backup are all intact and functional.
• Critical Control 11: Secure Configurations for Network Devices such as Firewalls, Routers, and Switches
o Attackers penetrate defenses by searching for electronic holes in firewalls, routers, and switches.
o Once these network devices have been exploited, attackers can gain access to target networks, redirect traffic on that network (to a malicious system masquerading as a trusted system), and intercept and alter information while in transmission.
o Organizations can use commercial tools that will evaluate the rule set of network filtering devices, which determine whether they are consistent or in conflict and provide an automated check of network filters.
o Additionally, these commercial tools search for errors in rule sets. Such tools should be run each time significant changes are made to firewall rule sets, router ACLs, or other filtering technologies.
o To evaluate the implementation of Control 11 on a periodic basis, an evaluation team must make a change to each type of network device plugged into the network.
o At a minimum, routers, switches, and firewalls need to be tested. If they exist, IPS, IDS, and other network devices must be included.
• Critical Control 12: Boundary Defense
o By attacking Internet-facing systems, attackers can create a relay point to break into other networks or internal systems.
o Automated tools can be used to exploit vulnerable entry points into a network.
o To control the flow of traffic through network borders and to look for attacks and evidence of compromised machines, boundary defenses should be multi-layered
o These boundaries should consist of firewalls, proxies, DMZ perimeter networks, and network-based intrusion prevention systems and intrusion detection systems.
o Organizations should regularly test these sensors by launching vulnerability-scanning tools.
o These tools verify that the scanner traffic triggers an appropriate alert.
o The captured packets of the Intrusion Detection Systems (IDS) sensors should be reviewed using an automated script each day, which ensures log volumes are within expected parameters, are formatted properly, and have not been corrupted.
o To evaluate the implementation of Control 12 on a periodic basis, an evaluation team must test boundary devices.
o This is done by sending packets from outside a trusted network, which ensures that only authorized packets are allowed through the boundary.
o All other packets must be dropped.
• Critical Control 13: Data Protection
o The loss of protected and sensitive data is a serious threat to business operations, and potentially, national security.
o While some data is leaked or lost as a result of theft or espionage, the vast majority of these problems result from poorly understood data practices.
o These include, but are not limited to, a lack of effective policy architectures and user error.
o The phrase "Data Loss Prevention" (DLP) refers to a comprehensive approach covering people, processes, and systems that identify, monitor, and protect data in use (e.g., endpoint actions), data in motion (e.g., network actions), and data at rest (e.g., data storage) through deep content inspection and with a centralized management framework.
o Commercial DLP solutions are available to look for exfiltration attempts and detect other suspicious activities associated with a protected network holding sensitive information.
o The system must be capable of identifying unauthorized datum leaving the organization's systems whether via network file transfers or removable media.
o To evaluate the implementation of Control 13 on a periodic basis, the evaluation team must attempt to move test datum sets (that trigger DLP systems but do not contain sensitive data) outside of the trusted computing environment via both network file transfers and via removable media
• Critical Control 14: Controlled Access Based On Need to Know
o Some organizations do not carefully identify and separate sensitive data from less sensitive, publicly available information within an internal network.
o In many environments, internal users have access to all or most of the information on the network.
o Once attackers have penetrated such a network, they can easily find and exfiltrate important information with little resistance.
o This control is often implemented using the built-in separation of administrator accounts from non-administrator accounts.
o The system must be able to detect all attempts by users to access files without the appropriate privileges and must generate an alert or e-mail for administrative personnel.
o This includes information on local systems or network accessible file shares. To evaluate the implementation of Control 14 on a periodic basis, the evaluation team must create test accounts with limited access and verify that the account is unable to access controlled information.
• Critical Control 15: Wireless Device Control
o Attackers who gain wireless access to an organization from nearby parking lots have initiated major data thefts.
o This allows attackers to bypass an organization to maintain long-term access inside a target.
o Effective organizations run commercial wireless scanning, detection, and discovery tools as well as commercial wireless intrusion detection systems.
o The system must be capable of identifying unauthorized wireless devices or configurations when they are within range of the organization's systems or connected to its networks.
o To evaluate the implementation of Control 15 on a periodic basis, the evaluation team staff must configure unauthorized but hardened wireless clients and wireless access points to the organization's network.
o It must also attempt to connect them to the organization's wireless networks. These access points must be detected and remediated in a timely manner.
• Critical Control 16: Account Monitoring and Control
o Attackers frequently impersonate legitimate users through inactive user accounts.
o This method makes it difficult for network watchers to identify attackers' behavior.
o Although most operating systems include capabilities for logging information about account usage, these features are sometimes disabled by default.
o Security personnel can configure systems to record more detailed information about account access and utilize homegrown scripts or third-party log analysis tools to analyze this information.
o The system must be capable of identifying unauthorized user accounts when they exist on the system.
o To evaluate the implementation of Control 16 on a periodic basis, the evaluation team must verify that the list of locked out accounts, disabled accounts, accounts with passwords that exceed the maximum password age, and accounts with passwords that never expire has successfully been completed daily.
• Critical Control 17: Security Skills Assessment and Appropriate Training to Fill Gaps (validated manually)
o An organization hoping to find and respond to attacks effectively relies on its employees and contractors to find the gaps and fill them.
o A solid security skills assessment program can provide actionable information to decision makers about where security awareness needs to be improved.
o It can also help determine proper allocation of limited resources to improve security practices.
o The key to upgrading skills is measurement, not with certification examinations, but with assessments that show both the employee and the employer where knowledge is sufficient and where there are gaps.
o Once the gaps have been identified, those employees who have the requisite knowledge can be called upon to mentor the employees who do not.
o The organization can also develop training programs that directly maintain employee readiness
• Critical Control 18: Application Software Security
o Criminal organizations frequently attack vulnerabilities in both web-based and non-web-based application software.
o In fact, it is a top priority for criminals. Application software is vulnerable to remote compromise in three ways:
It does not properly check the size of user input
It fails to sanitize user input by filtering out potentially malicious character sequences
It does not initialize and clear variables properly
o To avoid attacks, internally developed and third party application software must be carefully tested to find security flaws.
o Source code testing tools, web application security scanning tools, and object code testing tools have proven useful in securing application software.
o Another useful tool is manual application security penetration testing by testers who have extensive programming knowledge and application penetration testing expertise.
o The system must be capable of detecting and blocking an application-level software attack, and must generate an alert or send e-mail to enterprise administrative personnel.
o To evaluate the implementation of Control 18 on a monthly basis, an evaluation team
must use a web application vulnerability scanner to test software security flaws.
• Critical Control 19: Incident Response and Management (validated manually)
o Without an incident response plan, an organization may not discover an attack in the first place.
o Even if the attack is detected, the organization may not follow proper procedures to contain damage, eradicate the attacker's presence, and recover in a secure fashion.
o Thus, the attacker may have far higher impact on the target organization, causing more damage, infecting more systems, and possibly exfiltrating more sensitive data than would otherwise be possible.
o After defining detailed incident response procedures, the incident response team should engage in periodic scenario-based training.
o This includes, but is not limited to, working through a series of attack scenarios that are fine-tuned to the threats and vulnerabilities the organization faces.
• Critical Control 20: Penetration Tests and Red Team Exercises (validated manually)
o Attackers penetrate networks and systems through social engineering and by exploiting vulnerable software and hardware.
o Penetration testing involves mimicking the actions of computer attackers, and exploiting them to determine what kind of access an attacker can gain. Each organization should define a clear scope and the rules of engagement for penetration testing and red team analyses.
o The scope of such projects should include, at least, systems with the highest value information and production processing functionality.