Management of Information Security

Chapter 4

Information Security Policy

Each problem that I solved became a rule which served afterwards to solve other problems
-- RENE DESCARTES (15961650) DISCOURS DE LA METHODE

Learning Objectives
Upon completion of this chapter, you should be able to:

Define information security policy and understand its central role in a successful information security program Know the three major types of information security policy often used and what goes into each type
Develop, implement, and maintain various types of information security policies

Management of Information Security

Introduction
This chapter focuses on information security policy:
What it is How to write it How to implement it

How to maintain it

Management of Information Security

Introduction (Continued)
Policy: essential foundation of effective information security program:
The success of an information resources protection

program depends on the policy generated, and on the attitude of management toward securing information on automated systems. You, the policy maker, set the tone and the emphasis on how important a role information security will have within your agency. Your primary responsibility is to set the information resource security policy for the organization with the objectives of reduced risk, compliance with laws and regulations and assurance of operational continuity, information integrity, and confidentiality.
Management of Information Security 4

Why Policy?
A quality information security program begins and ends with policy Policies are least expensive means of control and often the most difficult to implement Some basic rules must be followed when shaping a policy:
Never conflict with law Stand up in court Properly supported and administered Contribute to the success of the organization Involve end users of information systems
5

Management of Information Security

Figure 4-1 The Bulls-eye Model

Management of Information Security

Policy Centric Decision Making

Bulls-eye model layers:
Policies: first layer of defense Networks: threats first meet organizations network Systems: computers and manufacturing systems Applications: all applications systems

Policies are important reference documents for internal audits and for resolution of legal disputes about management's due diligence
Policy documents can act as a clear statement of management's intent
Management of Information Security 7

Figure 4-2 Policies, Standards, & Practices

Management of Information Security

Policy, Standards, and Practices

Policy: plan or course of action that influences and determines decisions Standards: more detailed statement of what must be done to comply with policy Practices, procedures and guidelines: explain how employees will comply with policy For policies to be effective, they must be:
Properly disseminated Read Understood Agreed-to
9

Management of Information Security

Policy, Standards, and Practices (Continued)

Policies require constant modification and maintenance In order to produce a complete information security policy, management must define three types of information security policy:
Enterprise information security program policy Issue-specific information security policies Systems-specific information security policies
Management of Information Security 10

Enterprise Information Security Policy (EISP)

Sets strategic direction, scope, and tone for organizations security efforts Assigns responsibilities for various areas of information security Guides development, implementation, and management requirements of information security program
Management of Information Security 11

EISP Elements
EISP documents should provide :
An overview of corporate philosophy on security
Information about information security organization and information security roles
Responsibilities for security shared by all members of the organization Responsibilities for security unique to each role within the organization
Management of Information Security 12

Components of the EISP

Statement of Purpose: What the policy is for Information Technology Security Elements: Defines information security Need for Information Technology Security: justifies importance of information security in the organization Information Technology Security Responsibilities and Roles: Defines organizational structure References Information Technology standards and guidelines
Management of Information Security 13

Example EISP - CCW

Protection Of Information: Information must be protected in a manner commensurate with its sensitivity, value, and criticality Use Of Information: Company X information must be used only for business purposes expressly authorized by management Information Handling, Access, And Usage: Information is a vital asset and all accesses to, uses of, and processing of Company X information must be consistent with policies and standards
Management of Information Security 14

Example EISP CCW (Continued)

Data And Program Damage Disclaimers: Company X disclaims any responsibility for loss or damage to data or software that results from its efforts to protect the confidentiality, integrity, and availability of the information handled by computers and communications systems Legal Conflicts: Company X information security policies were drafted to meet or exceed the protections found in existing laws and regulations, and any Company X information security policy believed to be in conflict with existing laws or regulations must be promptly reported to Information Security management
Management of Information Security 15

Example EISP CCW (Continued)

Exceptions To Policies: Exceptions to information security policies exist in rare instances where a risk assessment examining the implications of being out of compliance has been performed, where a standard risk acceptance form has been prepared by the data Owner or management, and where this form has been approved by both Information Security management and Internal Audit management Policy Non-Enforcement: Management's nonenforcement of any policy requirement does not constitute its consent
Management of Information Security 16

Example EISP CCW (Continued)

Violation Of Law: Company X management must seriously consider prosecution for all known violations of the law Revocation Of Access Privileges: Company X reserves the right to revoke a user's information technology privileges at any time Industry-Specific Information Security Standards: Company X information systems must employ industry-specific information security standards
Management of Information Security 17

Example EISP CCW (Continued)

Use Of Information Security Policies And Procedures: All Company X information security documentation including, but not limited to, policies, standards, and procedures, must be classified as Internal Use Only, unless expressly created for external business processes or partners Security Controls Enforceability: All information systems security controls must be enforceable prior to being adopted as a part of standard operating procedure
Management of Information Security 18

Issue-Specific Security Policy (ISSP)

Provides detailed, targeted guidance to instruct organization in secure use of technology systems Begins with introduction to fundamental technological philosophy of organization Serves to protect employee and organization from inefficiency/ambiguity Documents how technology-based system is controlled Identifies processes and authorities that provide this control Serves to indemnify organization against liability for inappropriate or illegal system use
Management of Information Security 19

Issue-Specific Security Policy (ISSP)

Every organizations ISSP should:
Address specific technology-based systems Require frequent updates Contain an issue statement on the organizations position on an issue E-mail, use of Internet and World Wide Web, specific minimum configurations of computers to defend against worms and viruses, prohibitions against hacking or testing organization security controls, home use of company-owned computer equipment, use of personal equipment on company networks, use of telecommunications technologies, use of photocopy equipment
Management of Information Security 20

ISSP topics could include:

Components of the ISSP

Statement of Purpose Scope and Applicability Definition of Technology Addressed Responsibilities Authorized Access and Usage of Equipment User Access Fair and Responsible Use Protection of Privacy Prohibited Usage of Equipment Disruptive Use or Misuse Criminal Use Offensive or Harassing Materials Copyrighted, Licensed or other Intellectual Property Other Restrictions
Management of Information Security 21

Components of the ISSP (Continued)

Systems Management Management of Stored Materials Employer Monitoring Virus Protection Physical Security Encryption Violations of Policy Procedures for Reporting Violations Penalties for Violations Policy Review and Modification Scheduled Review of Policy and Procedures for Modification Limitations of Liability Statements of Liability or Disclaimers
Management of Information Security 22

Implementing ISSP
Common approaches:
Number of independent ISSP documents
Single comprehensive ISSP document Modular ISSP document that unifies policy creation and administration

Recommended approach is modular policy, which provides a balance between issue orientation and policy management
Management of Information Security 23

Systems-Specific Policy (SysSP)

Systems-Specific Policies (SysSPs) frequently do not look like other types of policy They may often be created to function as standards or procedures to be used when configuring or maintaining systems SysSPs can be separated into:
Management guidance

Technical specifications
Combined in a single policy document
Management of Information Security 24

Figure 4-3 Password SysSP

Management of Information Security

25

Management Guidance SysSPs

Created by management to guide the implementation and configuration of technology Applies to any technology that affects the confidentiality, integrity or availability of information Informs technologists of management intent

Management of Information Security

26

Technical Specifications SysSPs

System administrators directions on implementing managerial policy Each type of equipment has its own type of policies Two general methods of implementing such technical controls:
Access control lists
Configuration rules
Management of Information Security 27

Access Control Lists

Include user access lists, matrices, and capability tables that govern rights and privileges Can control access to file storage systems, object brokers or other network communications devices Capability Table: similar method that specifies which subjects and objects users or groups can access Specifications are frequently complex matrices, rather than simple lists or tables Level of detail and specificity (often called granularity) may vary from system to system
ACLs enable administrations to restrict access according to user, computer, time, duration, or even a particular file
Management of Information Security 28

ACLs
In general ACLs regulate:
Who can use the system
What authorized users can access When authorized users can access the system Where authorized users can access the system from How authorized users can access the system Restricting what users can access, e.g. printers, files, communications, and applications
Management of Information Security 29

ACLs (Continued)
Administrators set user privileges, such as:
Read
Write Create Modify Delete

Compare
Copy
Management of Information Security 30

Configuration Rules
Configuration rules are specific configuration codes entered into security systems to guide execution of system when information is passing through it Rule policies are more specific to system operation than ACLs and may or may not deal with users directly Many security systems require specific configuration scripts telling systems what actions to perform on each set of information processed
Management of Information Security 31

Figure 4-6 Firewall Configuration Rules

Management of Information Security

32

Combination SysSPs
Often organizations create a single document combining elements of both Management Guidance and Technical Specifications SysSPs While this can be confusing, it is very practical Care should be taken to articulate required actions carefully as procedures are presented

Management of Information Security

33

Figure 4-7 IDS Configuration Rules

Management of Information Security

34

Figure 4-7 IDS Configuration Rules (Continued)

Management of Information Security

35

Guidelines for Policy Development

Often useful to view policy development as a two-part project
1. Design and develop policy (or redesign and rewrite outdated policy)

2. Establish management processes to perpetuate policy within organization

The former is an exercise in project management, while the latter requires adherence to good business practices
Management of Information Security 36

The Policy Project

Policy development or re-development projects should be well planned, properly funded, and aggressively managed to ensure completion on time and within budget When a policy development project is undertaken, the project can be guided by the SecSDLC process

Management of Information Security

37

Investigation Phase
The policy development team should:
Obtain support from senior management, and active involvement of IT management, specifically CIO Clearly articulate goals of policy project Gain participation of correct individuals affected by recommended policies Be composed from Legal, Human Resources and end-users Assign project champion with sufficient stature and prestige Acquire a capable project manager Develop detailed outline of and sound estimates for the cost and scheduling of the project
Management of Information Security 38

Analysis Phase
Analysis phase should include the following activities:
New or recent risk assessment or IT audit documenting the current information security needs of the organization Key reference materialsincluding any existing policies

Management of Information Security

39

Design Phase
Design phase should include:
How policies will be distributed
How verification of distribution will be accomplished Specifications for any automated tools

Revisions to feasibility analysis reports based on improved costs and benefits as design is clarified
Management of Information Security 40

Implementation Phase
Implementation Phase: writing the policies

Make certain policies are enforceable as written

Policy distribution is not always as straightforward Effective policy
Is written at a reasonable reading level

Attempts to minimize technical jargon and management terminology

Management of Information Security 41

Figure 4-9 Readability Statistics Example

Management of Information Security

42

Maintenance Phase
Maintain and modify policy as needed to ensure that it remains effective as a tool to meet changing threats Policy should have a built-in mechanism via which users can report problems with the policy, preferably anonymously

Periodic review should be built in to the process

Management of Information Security 43

Figure 4-10 VigilEnt Policy Center

Management of Information Security

44

The Information Security Policy Made Easy Approach (ISPME)

Gathering Key Reference Materials

Defining A Framework For Policies

Preparing A Coverage Matrix Making Critical Systems Design Decisions Structuring Review, Approval, And Enforcement Processes
Management of Information Security 45

Figure 4-11 Coverage Matrix

Management of Information Security

46

ISPME Checklist
Perform risk assessment or information technology audit to determine your organization's unique information security needs Clarify what policy means within your organization so that you are not preparing a standard, procedure, or some other related material Ensure that roles and responsibilities related to information security are clarified, including responsibility for issuing and maintaining policies Convince management that it is advisable to have documented information security policies
Management of Information Security 47

ISPME Checklist (Continued)

Identify top management staff who will be approving final information security document and all influential reviewers Perform risk assessment or information technology audit to determine organization's unique information security needs Clarify what policy means within your organization so that you are not preparing a standard, procedure, or some other related material Ensure that roles and responsibilities related to information security are clarified, including responsibility for issuing and maintaining policies
Management of Information Security 48

ISPME Checklist (Continued)

Convince management that it is advisable to have documented information security policies Identify top management staff who will be approving final information security document and all influential reviewers Collect and read all existing internal information security awareness material and make a list of the included bottom-line messages Conduct a brief internal survey to gather ideas that stakeholders believe should be included in a new or updated information security policy
Management of Information Security 49

ISPME Checklist (Continued)

Examine other policies issued by your organization, such as those from Human Resources management, to identify prevailing format, style, tone, length, and cross-references Identify audience to receive information security policy materials and determine whether they will each get a separate document or a separate page on an intranet site Determine extent to which audience is literate, computer knowledgeable, and receptive to security messages
Management of Information Security 50

ISPME Checklist (Continued)

Decide whether some other awareness efforts must take place before information security policies are issued Using ideas from the risk assessment, prepare a list of absolutely essential policy messages that must be communicated If there is more than one audience, match the audiences with the bottom-line messages to be communicated through a coverage matrix. [] Determine how the policy material will be disseminated, noting the constraints and implications of each medium of communication
Management of Information Security 51

ISPME Checklist (Continued)

Review compliance checking, disciplinary, and enforcement processes to ensure they all can work smoothly with new policy document Determine whether number of messages is too large to be handled all at one time, and if so, identify different categories of material that will be issued at different times Have an outline of topics to be included in the first document reviewed by several stakeholders Based on comments from stakeholders, revise initial outline and prepare a first draft []
Management of Information Security 52

ISPME Checklist (Continued)

Have first draft document reviewed by stakeholders for initial reactions, presentation suggestions, and implementation ideas Revise draft in response to comments from stakeholders Request top management approval on policy Prepare extracts of policy document for selected purposes Develop awareness plan that uses policy document as a source of ideas and requirements
Management of Information Security 53

ISPME Checklist (Continued)

Create working papers memo indicating disposition of all comments received from reviewers, even if no changes were made Write memo about project, what you learned, and what needs to be fixed so that next version of policy document can be prepared more efficiently, better received by readers, and more responsive to unique circumstances facing your organization

Prepare list of next steps that will be required to implement requirements specified in policy document
Management of Information Security 54

ISPME Next Steps

Post Polices To Intranet Or Equivalent

Develop A Self-Assessment Questionnaire

Develop Revised user ID Issuance Form Develop Agreement To Comply With Information Security Policies Form Develop Tests To Determine If Workers Understand Policies

Assign Information Security Coordinators

Train Information Security Coordinators
Management of Information Security 55

ISPME Next Steps (Continued)

Prepare And Deliver A Basic Information Security Training Course Develop Application Specific Information Security Policies Develop A Conceptual Hierarchy Of Information Security Requirements Assign Information Ownership And Custodianship Establish An Information Security Management Committee Develop An Information Security Architecture Document
Management of Information Security 56

SP 800-18: Guide for Developing Security Plans

NIST Special Publication 800-18 offers another approach to policy management Policies:
Living documents that constantly change and grow Must be properly disseminated (distributed, read, understood and agreed to) and managed

Management of Information Security

57

SP 800-18: Guide for Developing Security Plans (Continued)

Good management practices for policy development and maintenance make for a more resilient organization In order to remain current and viable, policies must have:
Individual responsible for reviews Schedule of reviews Method for making recommendations for reviews Indication of policy and revision date
Management of Information Security 58

A Final Note on Policy

Lest you believe that the only reason to have policies is to avoid litigation, it is important to emphasize the preventative nature of policy Policies exist first, and foremost, to inform employees of what is and is not acceptable behavior in the organization Policy seeks to improve employee productivity, and prevent potentially embarrassing situations
Management of Information Security 59

Summary
Introduction

Why Policy?
Enterprise Information Security Policy Issue-Specific Security Policy System-Specific Policy Guidelines for Policy Development
Management of Information Security 60