Does
Compliance Provide a False Sense of Security?
The topic of compliance and security is a hot issue amongst
the cyber security community. Most organizations are aware that they need to
comply with certain industry standards, but they may not realise doing so does
not mean their networks are secure. Jim
Jaeger (Director of DoD & commercial cyber solutions for General Dynamics
Advance Information Systems) bought the topic to the forefront of the agenda in
his keynote speech at the Annual CIS Conference in 2011. He disclosed that in
virtually every security breach they had investigated, the company had been
recently certified as compliant. So why doesn’t compliance equal security?
Why Doesn’t Compliance Equal Security?
Compliance checklists such as PCI (Payment Card Industry)
and HIPAA (The Health Insurance Portability and Accountability Act) are widely
used industry standards. Although PCI standards are specific to the
requirements of the payment card industry, the diversity of companies and their
practices operating within this industry are vast. As the standards have to be ‘one size fits
all’ they can never accurately reflect the potential threats against each
individual organization. Networks can be quickly modified to adapt to these industry
wide requirements, but they will often not truly reflect the security issues of
the environment. This could mean that by merely focusing on meeting the minimum
requirements to comply, many organizations let the real threats to their
networks go undetected and unmanaged.
Some compliance standards may state that a network must
undergo a penetration test once a year and vulnerability scan once a quarter to
prove it complies. If the person
carrying out the penetration test is not an expert in all the devices in the
network, or if the scans are blocked whilst checking, then all potential
vulnerabilities may not be reported.
However as long as the results of the test come back clear then the
Quality Security Assessor, who completes the audit, can certify that
organization as compliant in that area.
Even when tests are thoroughly and professionally conducted
they are ‘point in time’ audits which may only be carried out once or twice a
year. Configuration changes and software exploits mean new vulnerabilities can
easily emerge in the intervals between manual penetration tests. While scanners
are to be deployed more often, they are only effective in giving an overview of
your network security and often do not provide you with the in depth security
analysis that you need.
Another issue facing compliance is that technology is
developing at a far greater rate than the updating of compliance standards and
documentation. This means that not only are compliance standards not specific
to each organizations requirements but are very often out of date. Hackers will
not just use the latest compliance standards in order to navigate a way to
attack your network. Hackers are dynamic in their attacks, sharing ideas
between their communities. They will use any means necessary to find the
vulnerabilities that compliance checks and scanners can leave exposed. In his
keynote speech Jim Jaeger (of GD) stated that, ‘any determined hacker can get
into any network if you only focus on that hard, crunchy outer shell of the
network.’ He went on to say that the most important lesson he had learnt in
recent years is how important the depth of security is when defending against
breaches.
Adding to the risk of external hackers attempting to get
inside your network, the threat of internal attacks is also one to consider.
Employees within your organisation, or external consultants invited into your
networks, also have the potential to open back doors to data and hide the
evidence trail by blocking ports to prevent some tools detecting changes.
Effective management of user access controls, set out by some compliance
standards, can help mediate the threat. However not only can controls be
manipulated, some employees need access to the network to complete their jobs.
By only using point in time audits and deployment of scanners, changes
implemented within the device configuration can go unnoticed until it is to too
late. Remember employees may know when your audits take place and could easily
pass this information on to an external body. If these are only done once a year
then that leaves the attacker with a massive window of opportunity. Compliance
standards have their place, but should be used as a basis for security and not
the sole solution.
What is the Best Solution?
Leaders in the industry all agree that an in-depth,
multi-layered, customized approach to network security is the best way to
achieve optimum security. The latest Strategic Security Survey from Information
Week publication (www.informationweek.com)
had a response from over 900 security professions. The results suggest that
those in charge of network security are making positive moves towards
increasing standards. For example the
percentage of respondents who conduct their own risk assessment of cloud
providers rose by 11% on the previous year and the percentage of companies who
admitted to not bothering with risk assessment at all, fell by almost half
compared to the last survey.
Michael A. Davis, author of the survey and CEO of Savid
Technologies, responded to the statistics with his own advice concerning
security strategies. He insists that the best way is to take a ‘best
practices-based approach that is customized to the environment in hand.’
Generating your own security policy that accurately reflects your organizations
security issues is essential. In addition to customization, the plan must be
dynamic. Security professionals must do this by constantly improving and
advancing their security policy, basing it on a metrics of standards and
policies set by your organization, specifically targeting the threats that are
most prevalent to you. This strategy must then be continuously monitored and
assessed not only according to how compliant it is, but how effective it is. It
is less important that your security policy ticks a number of boxes and more
important that it is successful in securing your data.
There are a wealth of security options, at many different
levels. With manual penetration tests, configuration analysis tools and
vulnerability scanners amongst them, it isn’t surprising that the survey also
reveals that 52% listed managing the complexity of security as their greatest
network security challenge. With the tighter budgets of small and medium
businesses, those IT professionals in charge of security have the added
complication of trying to find the most cost effective way of maintain a high
level of security whilst also achieving compliance.
Titania are cyber security auditing specialist in the areas of configuration analysis and compliance auditing. For more information contact us at enquires@titania.com or call us + 44 (0) 1905 888785
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