How to Build the Perfect PB & J
{LANG_NAVORIGIN} Laws and Regulations
Chuck Fullerton
11/04/2004
Introduction
In today’s post 9/11 world, cyber-security is taking on a new light. Companies
and even Government agencies need to be compliant with new regulations, yet still
ensure that their company is secure in the way it handles information. Each company
will implement their security differently. With that in mind, how does each company
implement their security differently yet still maintain compliance with the needed
regulations? The answer to this question is that each company must find its “Perfect
Security” standard.
Perfect Security is a customized standard that is a perfect fit for the company and
the way it does business. Your company’s current Security can then be tested against this
Perfect Security standard to determine where the company’s actual security posture
stands compared to it. Numbers can be crunched within this process and a numerical
level of your company’s security can be computed.
A good example of this comes from the Open Source Security Testing
Methodology Manual or OSSTMM. Its use of Risk Assessment Values, or RAV’s, is an
important part of the OSSTMM Security Test. You may review the latest version of the
OSSTMM at
www.isecom.org/osstmm.
The OSSTMM can also provide guidance, ensuring that you secure all aspects of
your business. It not only covers IT security, but other areas, such as, communications,
wireless, process security (or Social Engineering testing), information, and physical
security as well.
Step One: Gather the Ingredients for Perfect Security… Mix Well
As you may have surmised, there are three main ingredients to this plan. The
first, “P”, stands for Policies. If you don’t have a Security Policy that is well defined and
in place, it is vital that one be established. It is your Policies that will protect you if, by
chance, you become a litigant in a court case. Chances are you already have a number of
policies that would be integral parts of your Security Policy in-place, thereby enabling
you to create or modify a corporate Security Policy as a start.
The next ingredient, “B”, stands for Best Practices. There are a number of Best
Practice Methodologies and standards that can be utilized. Standards, like ISO 17799,
which may meet the needs of some companies, can have portions that fulfill some of your
requirements. Feel free to implement these portions into your Security Policy. If you are
uncertain about which standard best suites your individual corporate needs, many
references are available on the Internet. You could also contact your local chapter of
ISSA to request answers to questions you may have. Be sure to take the time to research
what is best for your organization.
The final ingredient, “J”, stands for Justifications, which is made up of three parts:
Legal, Industry and Business.
Legal Justifications are the first part and
must be adhered to. These are minimum
standards that every business must comply with. Examples of Legal Justifications
include HIPAA, GLBA, SOX, COPPA, GISRA, and many others. Your company’s legal
counsel should be consulted to see which justifications are required for your organization.
One point to remember, compliance does not ensure effective corporate informational
security.
Industry Justifications are the second part and while not legally mandated, are
highly recommended. These are most commonly found in unregulated industries where
many companies have adopted justifications in order to stem the tide of Government
regulation. The pharmaceutical industry is a good example of this. While companies
won’t get fined if they choose not to follow the Industry Justifications, implementing
them could minimize the impact of future regulations that may be imposed on the
industry and it may boost the level of your security within the organization.
The final part is our Business Justifications. These are the items that must be in
place in order to do business. Examples of this include having a local web server to
allow the company to engage in e-commerce as well as an email server to help the
company communicate within and with the outside world. Any implementation of this
type of justification must comply with the Legal Justifications, and should comply with
the Industry Justifications.
Once we have collected all of this information, we need to determine what is the
Security goal for your organization and implement it into our dedicated security policy.
As this can be rather tedious, it can help to import this information into your policy as
you receive it. When this task has been completed you now have your first version of
your organization’s Perfect Security Policy.
Step Two: Taste Test it
Now that we have defined your security policy based on your “Perfect Security”,
it’s time to see how the rest of your business compares to your standard. As you begin
the actual implementation of your new policy you will, almost assuredly, find faults
within your infrastructure, and that is to be expected. By testing it, you can identify what
needs to be brought into compliance to meet these new standards.
There are many different ways to test your business against your standard. The
OSSTMM is an excellent guide to utilize to ensure a thorough testing of all aspects of
security within your organization. Many companies outsource these types of security
testing as they are rather in-depth and they may not have the employees certified or
competent to conduct them.
Consultants can help by providing experts in each area of an OSSTMM test as
well as tailoring the individual tasks of the test to fit the individual business, regardless of
size. Some consultants will even work with people on your staff to do the testing when a
certification of the OSSTMM test isn’t required such as in the case we are describing.
Smaller businesses can benefit from a knowledgeable consultant that can take the
OSSTMM and scale it for use at a smaller business.
The largest of companies should take no more than 90 days from start to reportin-
hand for this type of testing, and smaller companies should be able to have their
reports delivered in just a few short weeks.
The OSSTMM requires a reporting workshop that identifies each area in need of
improvement to resolve vulnerabilities. Each of these items should be reviewed and
fixed as quickly as time and budget allow. As each section of items in the report is
repaired it should be spot tested to verify that it is compliant with your “Perfect Security
Standard”.
Step Three: Kick it up a notch
Another benefit of an OSSTMM test is that it will point out areas of
improvement for the efficient running of your company. This will assist you in realizing
changes that could save the company money by economizing and streamlining your
processes. This type of testing also may identify other areas that could be run more
efficiently, and if deemed necessary, will give you the ability to go back to the policy and
make changes to run your business effectively.
In addition to updating your Security Policy, you can also use this opportunity to
have your technical personnel update the guidelines and procedures within each area of
the Security Policy. This is an important part of the process as this assures your
employees fully understand what your Policy dictates and know what steps to take to
follow it.
Conclusion
Now that the framework is in place, you can now go back and perform your
Security Audit for compliance purposes. An OSSTMM Certified Security test is a great
example of this. If you used the OSSTMM as your assessment test then you now know
what’s involved so there will be no surprises. The OSSTMM is quickly becoming the defacto
world standard for compliance audits. It is known throughout the world and over
150 security professionals review and submit updates to the OSSTMM on a regular basis.
The OSSTMM is compliant with a number of laws and best practices from many
different countries. It truly is a global document.
Finding your company’s Perfect Security is not a once and done thing. Your
Perfect Security Policy is a living document and must be reviewed and updated on a
regular basis. Performing this along with regular testing of your security posture will
prove that you are performing your due diligence and due care.
About the Author
Charles “Chuck” Fullerton has worked in the IT and Security fields for over 15
years. After serving in South Korea with the U.S. Army, Chuck has worked with many
different industries such as, manufacturing, education, finance, healthcare, law
enforcement and telecommunications. His philosophy on security is that “everyone has a
responsibility to maintain a level of security for themselves on the Internet. People must
learn how to secure the equipment under their control.” Chuck started the Charles W.
Fullerton Institute of Analysis to do just that. CIA was then acquired by Fullerton
Infosec, Inc. in July of 2004. Chuck also teaches Intense School’s Professional Hacking
course which prepares security professionals for the Certified Ethical Hacker
Examination.
Fullerton Infosec’s motto is “We Care about Your Security.” We are committed
to providing ethical, objective, vendor neutral security testing to our customers. We also
provide Security Policy generation and updating, Security Awareness training and will
open are Honeynet Project to clients starting towards the beginning of 2005. Chuck can
be reached via email at
cfullerton@fullertoninfosec.com.
E-Mail Link
Your IP address will be sent with this e-mail