Tuesday, July 12, 2011
Reminder: PCI DSS 2.0 is asking for Vulnerability Risk Rating
Posted by yinal at 0 comments
Labels: compliance, PCI, vulnerability_management
Sunday, August 16, 2009
IT Governance, Risk and Compliance (ITGRC) Tools August 2009
For 2011 list follow this link
Here are the updated links for the IT-GRC vendors, IT-GRC wanna be GRC vendors, and some IT based risk management tool/software providers.
There is still a thin line between IT, Financial and ERP GRC solution providers.
I have noticed that SAP has created its own GRC context where GRC means a lot of other things... SoD- Segregation of Duties, entitlements management, users access/authorization for applications/transactions, audit managment, role management etc.Basically a dull extention of IT audit controls. SAP's Virsa and SUN's Vaau acqusitions are good examples of this trend. That is not GRC -- that is mediocre IT controls audit. The term GRC is used without any consideration. This statement is also valid for the other usual suspects l(Oracle, PeopleSoft, Hyperion, JD Edwards,)
Here is a quick M&A update from last post:
Brabeion is acquired by Archer (Big News)
Controlpath is acquired by Trustwave.
Paisley is acquired by ThomsonReuters
Iconium is acquired by Logicalis
IBM dropped their own suite and working with Modulo
Favored GRC has a new name Highpoint GRC
Achiever is gone
I looked at ACL, Approva,Aveksa,Opentext,SecurityWeaver, Xpandion, Spatiq solutions,, I will be checking these vendors in the future, these solutins tend to manage ERP security only)..
IT-GRC solution Providers:
Agiliance
http://www.agiliance.com/
Archer ( acquired Brabeion)
http://www.archer-tech.com/solutions/index.html
Trustwave GRC
https://www.trustwave.com/GRC.php
Symantec (Control Compliance Suite)
http://eval.symantec.com/mktginfo/enterprise/fact_sheets/b-datasheet_control_compliance_suite_9.0-11_2008_14121573.en-us.pdf
Compliance Spectrum
http://www.compliancespectrum.com/
Modulo
http://www.modulo.com/home.jsp
NeIQ
http://www.netiq.com/solutions/scm/default.asp
eIQ Networks SecureVue
http://www.eiqnetworks.com/products/SecureVue/SecureVue_Technology.shtml
CA GRC
http://www.ca-grc.com/
Relational Security - RSAM
http://www.relsec.com/rsam_overview.htm
Logicalis grace (acquired Iconium Assets)
http://www.uk.logicalis.com/business_issues/governance_grace.asp
Lumension (acquired Security-Works)
http://www.lumension.com/landing.spring?contentId=154643
Oracle (formerly Logical Apps and Oracle GRC Manager)
http://www.oracle.com/solutions/corporate_governance/it-grc-management.html
Proteus
http://www.infogov.co.uk/proteus_enterprise/index.php
BPS
http://www.bpsinc.com/
Avedos
http://www.avedos.com/257-Home-EN.html
BWise
http://www.bwise.com/
Neupart
http://www.neupart.com/
Metric Stream
http://www.metricstream.com/
Nemea
http://www.nemea.us/
Highpoint
http://www.highpointgrc.com/
Paisley (now Thomson Reuters)
http://www.paisley.com/
OpenPages
http://www.openpages.com/Solutions/Technology_17.asp
Qumas
http://www.qumas.com/products/index.asp
IDS Scheer
http://www.ids-scheer.com/us/en/ARIS/ARIS_Solutions/Governance_Risk__Compliance_Management/139893.html Axentis
http://www.axentis.com/offerings/solutions/itgovernance
Methodware
http://www.methodware.com/it-security/
Protiviti
http://www.protiviti.com/grc-software/Pages/default.aspx
Cura Software
http://www.curasoftware.com/pages/content.asp?SectionId=7&SubSectionID=48
Mega
http://www.mega.com/index.asp/l/en/c/grc
ControlCase
http://controlcase.com/it-grc.htm
McAfee Risk and Compliance Manager (formerly McAfee Preventsys),
http://www.mcafee.com/us/local_content/white_papers/dashboard_reporting_it_grc.pdf
Greenlightcorp (SAP GRC)
http://www.greenlightcorp.net/sap_grc_cross_platform.html
Trintech -Financial GRC only
http://www.trintech.com/
SAI global
http://www.saiglobal.com/compliance/grc-software/
SAP
http://www.sap.com/solutions/sapbusinessobjects/large/governance-risk-compliance/index.epx
eFortresses
http://www.efortresses.com/Compliantz.htm
Simeio Solutions GRCAXS (IT GRC module)
http://www.simeiosolutions.com/
Compliance 360 ( eGRC )
http://www.compliance360.com/news.asp
There are also dedicated Risk Management Tools which will soon identify themselves (maybe they already do) for IT GRC marketspace
Callio
http://www.callio.com/
Casis
http://www.clearpriority.com/ (clearpriority)
Strategic Thought Active Risk Manager
http://www.strategicthought.com/riskmanagement.html
Cobra
http://www.riskworld.net/
Citicus
http://www.citicus.com/oursoftware.asp
Alion – Countermeasures (makers of Buddy System)
http://www.countermeasures.com/
Siemens – CRAMM
http://www.cramm.com/
Acuity Stream
http://www.acuityrm.com/
EAR/Pilar
http://www.ar-tools.com/en/index.html
GStool (mainly German)
https://www.bsi.bund.de/cln_136/EN/topics/ITGrundschutz/ITGrundschutzGSTOOL/itgrundschutzgstool_node.html Sigea GxSGSI (this site is in Spanish only)
http://www.gxsgsi.es/
RA2
http://www.aexis.de/index.php?site=static&staticID=4
RiskPAC
http://www.cpacsweb.com/riskpac.html
Risicare (French)
http://www.risicare.fr/
Riskwatch
http://www.riskwatch.com/
ISmart
http://www.biznet.com.tr/english/ismart_info.htm
Resolver
http://www.resolver.ca/
RMStudio
http://www.riskmanagementstudio.com/
RiskConnect
http://www.riskonnect.com/riskonnect_products.html
PTA Risk Assessment Tools and Technology
http://www.ptatechnologies.com/
Avedos Risk2Value
http://www.avedos.com/111-Short-Facts.html
Non-IT Risk Software
http://www.riskworld.com/SOFTWARE/sw5sw001.htm
I still need time to add URL links for the well known risk assessment methodologies. A little bit googling will take you to the right resources if you want to build your won system using a methodology or a framework.
Methodologies for Risk Assessment and Management listed below can be used at IT operations... Endless discussion for quantifying the risks... I like ISO 27000 series to lead, but each case is different.
ISO 14971 – Risk Management for Medical Technologies
NIST 800-30 Risk Management Guide for IT Systems - National Institute of Standards and Technology
OCTAVE (Carnegie Mellon)
The Institute of Risk management (IRM) The Risk Management Standard
ISO 13335-2 Information Security Risk Management, To be replaced by ISO/IEC IS 27005
BS 7799-3:2006 Information security management systems. Guidelines for information security risk management
BSI Grundschutz Handbuch
ENISA Regulation (2004)
PARA - Practical application of risk analysis
PTA - Practical Threat Analysis for Securing Computerized Systems
Austrian IT Security Handbook
Federal Financial Institutions Examination Council’s (FFIEC) IT handbook covers information security risk assessment
Threat and Risk Assessment Working Guide from The Government of Canada Security Policy
CRAMM - British Office of Government Commerce or The CCTA's (Central Computer and Telecommunications Agency) Risk Analysis and Management Method
Afhankelijkheids- en Kwetsbaarheidsanalyse (Dutch A&K)
EBIOS (French Government)
FRAP: Facilitated Risk Assessment Process
ISF –IRAM : Information Security Forum Ltd. Information Risk Analysis Methodologies . Also check FIRM (Fundamental Information Risk Management), SARA (Simple to Apply Risk Analysis) , SPRINT (Simplified Process for Risk Identification)
CLUSIF MEHARI - Club de la Sécurité de l'Information Français
Calpana CRISAM
Securitree from Ameneza
OSSTMM RAV (RAV stands for Risk Assessment Values)
SOMAP - Security Officers Management and Analysis Project
FAIR Factor Analysis of Information Risk
DRAM Delphic Risk Assessment Method
Buddy System
AS/NZS 4360 (2004) Risk Management. Australia/New Zealand standard for risk management
There are also Compliance Management/SIM/SIEM solutions which partially present GRC.
Here are a few links:
Tivoli Security Compliance Manager
http://www-01.ibm.com/software/tivoli/products/security-compliance-mgr/
Novell Compliance Management Platform
http://www.novell.com/products/compliancemanagementplatform/
Easy2comply (formerly Dynasec)
http://www.easy2comply.com/
AlertLogic
http://www.alertlogic.com/
NetForensics
http://www.netforensics.com/compliance/
Arcsight
http://www.arcsight.com/solutions/solutions-compliance/
RSA enVision
http://www.rsa.com/solutions/compliance/datasheets/9373_ISOENV_DS_0408-lowres.pdf
Intellitactics
http://www.intellitactics.com/int/solutions/compliance.asp
Actually all SIM SIEM vendors have a compliance management solution. For their list you can check the following post:
http://security.24kasim.org/2008/12/differentiation-of-log-management.html
Posted by yinal at 2 comments
Labels: compliance, GRC
Friday, July 31, 2009
PCI Reporting Requirements for Merchants
Facts:
- Check your PCI Merchant levels and validation requirements from the following post: http://security.24kasim.org/2009/06/pci-levels-for-merchants-2009.html
Amex
Level 1-
If compliant, Attestation of Compliance –AOC- (recommended) or exec summary of onsite security assessment report (QSA/internal) annually and quarterly network scan
If not compliant, AOC (recommended) or exec summary of onsite security assessment report and Remediation Plan annually and quarterly network scan and Remediation Plan
Level 2-
Quarterly Network Scans (and Remediation Plan if not compliant)
AOC (Recommended) or Executive Summary
In EU: PCI SAQ
Level 3- Level 4 -
No reporting Required for Amex at L3 and L4
Discover
Level 1 –
Network Merchants:
If compliant Appendix D of PCI DSS requirements and Security Assessment Procedures v1.2 - Attestation of Compliance –AOC-
If not fully compliant must also complete the Action Plan for Nono-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form to Discover twice a year
Level 2:
Network Merchants:
If compliant Attestation of Compliance –AOC- from applicable SAQ
If not fully compliant must also complete the Action Plan for Non-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form to Discover twice a year
Level 3:
Network Merchants:
If compliant Attestation of Compliance –AOC- from applicable SAQ
If not fully compliant must also complete the Action Plan for Non-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form to Discover twice a year
Level 4:
Network Merchants
If compliant Attestation of Compliance –AOC- from applicable SAQ maybe required
If not fully compliant must also complete the Action Plan for Non-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form or Level 4 Merchant Action Plan to Discover twice a year
JCB
JCB has no reporting requirements at this time
MasterCard
Level 1-
Acquirers register compliant merchants in the MasterCard Registration Program (MRP)
Acquirers report status of all merchants quarterly
Level 2-
Acquirers annually register compliant merchants in the MasterCard Registration Program (MRP)
Acquirers report status of all merchants quarterly
Level 3 –
Acquirers register compliant merchants in the MasterCard Registration Program (MRP)
Acquirers report status of all merchants quarterly
Level 4-
No requirements
Visa Inc
Level 1-
At least a twice a year , a statement of merchant compliance / non-compliance
Annual AOC form
Upon request a copy of Report on Compliance (ROC)
Level 2-
At least a twice a year , a statement of merchant compliance / non-compliance
Annual AOC form
Upon request a copy of Report on Compliance (ROC)
Level 3-
At least a twice a year , a statement of merchant compliance / non-compliance
Level 4-
Set by the acquirer
Visa Europe
Level 1-
Annual statement of merchant compliance
For merchants in progress, quarterly update until compliance confirmed
Upon request a copy of Report on Compliance (ROC) including indication of scan completion
Level 2-
Annual Statement of compliance / non-compliance
For merchants in progress, quarterly update until compliance confirmed
Level 3-
Quarterly statement of compliance / non-compliance for merchants above 20000 transactions/year. Annual statement for merchant below 20000 transactions/year
Level 4:
Annual statement of compliance / non-compliance for merchants processing < 1 million Visa transactions/year.
Service Providers are not merchants so if you are providing card processing for 3rd parties (Payment Service Provider) PSP or if you are a TPP (Third Party Processor) PCI levels, validation and reporting requirements are different. The charts above are for merchants only.
Posted by yinal at 0 comments
Labels: compliance, PCI
Monday, June 1, 2009
PCI Levels and Validation Requirements for Merchants 2009
This topic is always in the air so here are the official numbers for 2009 from PCI Security Standards Council the official governing body on the PCI requirements for merchants:
Facts:
- Payment Brands determine Merchant PCI levels. Payment Brands are Visa, Mastercard, Discover , Amex etc. They do have the last word on this topic
- Transaction volume is determined by Acquirer
- Transaction volume is aggregate number of transactions (chain stores do count if cards are processed centrally)
Amex
Level 1- Over 2.5 Million Amex card transactions/year, or any merchant who is Level 1 according to another Payment Brand
Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans
Level 2- 50000-2.5Million Amex transactions/year, or any merchant who is Level 2 according to another Payment Brand
Action: EU only annual SAQ, Quarterly ASV scans
Level 3- Less than 50000 AMEX transactions/year
Action Quarterly ASV scans (recommended) , EU only SQA (recommended)
Level 4- N/A
Action: None
Discover
Level 1 - Over 6 Million Discover card transactions/year, anybody who Discover thinks that they level 1 (discretionary) or any merchant who is validated/reported as Level-1 to another Payment Brand
Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans
Level 2- 1-6 Million Discover transactions/year, or any merchant who is validated/reported as Level-2 to another Payment Brand
Action: Annual SAQ, Quarterly ASV scans
Level 3- 20000-1 Million Discover transactions/year, or any merchant who is validated/reported as Level-3 to another Payment Brand
Action: Annual SAQ, Quarterly ASV
Level 4- Everybody else with Discover card processing
Action: Determined by Acquirer, Annual SAQ, Quarterly ASV recommended
JCB
Level 1 - Over 1 Million JCB card transactions/year or anybody who is compromised
Action: Annual Onsite QSA audit, Quarterly ASV scans
Level 2- Less than 1 Million JCB transactions/year
Action: Annual SAQ, Quarterly ASV scans
Level 3- N/A
Action: none
Level 4- N/A
Action: None
MasterCard
Level 1- Over 6 Million Mastercard card transactions/year, or any merchant who is Level 1 according to another Payment Brand or anybody who is compromised
Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans
Level 2- 1-6 Million Mastercard transactions/year, or any merchant who is validated/reported as Level-2 to another Payment Brand
Action: Annual SAQ, Quarterly ASV scans
Level 3- 20000-1 Million Mastercard “e-commerce” transactions/year, or any merchant who is validated/reported as Level-3 to another Payment Brand
Action: Annual SAQ, Quarterly ASV
Level 4- All other Mastercard merchants
Action: Compliance validation is at discretion of acquirer: Annual SAQ, Quarterly ASV recommended
Visa Inc
Level 1- Over 6 Million Visa card transactions/year (all transactions not just e-commerce), or any global merchant who is identified as Level 1 by Visa by any Visa Region
Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans and attestation of compliance form
Level 2- 1 Million to 6 Million Visa card transactions/year (all transactions not just e-commerce),
Action: Annual SAQ, Quarterly ASV scans and attestation of compliance form
Level 3- 20000-1 Million Visa “e-commerce” transactions/year
Action: Action: Annual SAQ (In Canada SAQs require QSA reviews), Quarterly ASV
Level 4- Merchants processing less than 20000 e-commerce transactions/year or merchants processing up to 1M any channel Visa transactions/year
Action: Compliance validation is at discretion of acquirer: Annual SAQ, Quarterly ASV recommended
Visa
Level 1- Over 6 Million Visa card transactions/year (all transactions not just e-commerce), or compromised merchants
Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans and attestation of compliance form
Level 2- 1 Million to 6 Million Visa card transactions/year (all transactions not just e-commerce),
Action: Annual SAQ, Quarterly ASV scans and attestation of compliance form
Level 3- 1 (one) to 1 Million Visa “e-commerce” transactions/year
Action: Annual SAQ, Quarterly ASV or use PCI DSS certified processor for all transactions
Level 4- Merchants processing up to 1 Million any channel Visa transactions/year
Action: Compliance validation is at discretion of acquirer: Annual SAQ, Quarterly ASV recommended
Of course all parties who process store or transmit credit cards must follow PCI requirements (PCI-DSS) regardless of their levels.
I will cover reporting requirements for merchants in another post.
Posted by yinal at 1 comments
Labels: compliance, PCI
Monday, November 17, 2008
What is 201 CMR 17:00?
Question:
What is 201 CMR 17:00?
Answer:
201 CMR 17:00 is yet another bigger brother telling us to the right thing…
The requirements simply enforce security of state of Mass residents’personal information… You may presume that the data is already secure. Well, that is wrong, just listen to the complaints for the requirements,
If you have a business and you do carry “personal information” about a Massachusetts resident then you must take care of the requirements listed in 201 CMR 17:00
The Office of Consumer Affairs and Business Regulation (OCABR) issued a comprehensive set of final (yes it is always final :) regulations establishing standards for how businesses protect and store consumers’ personal information as of September 22 2008. There is an executive order signed by Mass governor Deval L, Patrick related with this regulation., the irony is that it ends with “God Save the Commonwealth of Massachusetts”
The 201 CMR 17:00 standard is related with the M.G.L c. 93H because with the "general law chapter 93H –security breaches" there comes the enforcement leg of the regulation.
Implementation deadline is January 1, 2009 but an extension to May 2009 is hughly expected. Companies will be required to conduct internal and external security reviews and complete employee training
Of course most the technology associations, CPAs oppose to the regulation. They all have their reasons (not enough time, slow investment , harsh economic times etc). Mass CPA web site states that the compliance deadlines have been extended to May 1, 2009 (Jan 1, 2010 for 3rs party verifications and encryption). It is scary to know that the personal information is staying “clear” until then.
So what is it? “Every person that owns, licenses, stores or maintains personal information about a resident of the Commonwealth shall develop, implement, maintain and monitor a comprehensive, written information security program applicable to any records containing such personal information”
Personal information is defined with the following:Resident’s first name and last name or first initial and last name in combination of the one or more of the following data elements:
1. Social Security number
2. Driver's License number
3. Financial Account number (credit card, debit card)
4. Any means of access information for personal financial information
After a quick read, I came up with the following short/dirty to-do list for the 201 CMR 17:00 requirements:
1. Verification of current information security management system or framework
2. Assessment of current asset inventory for customer owned systems
3. Assessment of current information security roles and workflow
4. Assessment of policy enforcement for existing policies.
5. Verification of an information security risk management framework. Review of internal and external risk assessments.
6. Assessment of risk mitigation plan
7. Assessment of options for employee awareness programs for information security
8. Delivery of required policies matrix
9. Assessment of current employee termination procedures. Verification of enforcement
10. Assessment 3rd party business partners’ access to customer owned personal information. Cross-verification of 3rd party privacy policies
11. Assessment of workflow for personal information data collection. Verification of need-to-know principle
12. Assessment of access to personal information at customer facilities. Verification of need-to-know principle
13. Assessment of data classification for personal information at customer facilities.
14. Assessment of access logging for personal information
15. Verification of annual audit plan for personal information
16. Assessment of incident management
17. Assessment of patch management
18. Assessment of desktop/server firewall agent management, and enforcement
19. Assessment of encryption for all transmitted records and files containing personal information
20. Assessment authentication and authorization controls for personal information
21. Assessment of unique identifiers for personal information access (e.g. usernames)
22. Assessment account (password) management policy
23. Assessment of antivirus and malware policies, controls and enforcement.
My recommendation is the follow a larger framework such as ISO 27001 since there will be more compliance requirements in the future. ISO 27001 covers almost all requirements of 201 CMR 17:00
let me know if you have any questions,
- yinal
Posted by yinal at 2 comments
Labels: compliance