Information security laws are still a patchwork nationwide, but an increasing number of industry organizations are finding that they need our assistance to comply with laws and other applicable requirements. The purpose of this post is to help demystify the process.
Many industry organizations are just realizing all of the requirements that apply to them. For example, the latest Payment Card Industry Data Security Standards (PCI DSS) now require compliance even from organizations that outsource their e-commerce transaction-processing functions to a third-party service provider, but where the organization’s website controls the redirection to that provider. Understanding those types of compliance requirements, as well as those mandated by federal, state. or provincial legislation, is a starting point for any assessment.
A lot of clients take comfort in my approach to assessing security. For many organizations, especially for the IT people, a security assessment can seem daunting. What if issues are found? Will we look bad in front of the assessor? All I can do is assure clients that I’m there to help, not to judge. Yes, typically issues are found, especially if it’s an organization’s first assessment or if they haven’t had an assessment in a few years. Finding issues is simply the first step toward addressing them. Some assessors spend most of their time by themselves using their assessment tools, then presenting a report that feels like an adversarial “Gotcha!” to clients. I take a very different approach, one where I’m working alongside my client, using tools and checklists in collaboration with them. This has some important benefits. Without there being any surprises at the end of the assessment, there’s less of an adversarial feeling. Also, by educating my client in the use of common and free (or inexpensive) assessment tools and other security resources, they become empowered. IT staff are left feeling more educated and valuable, rather than feeling defeated by an outsider finding issues. The best part is that, by empowering my clients to be able to perform at least some level of ongoing self-assessment, they are more likely to maintain better security in the long run.
Before the visit: Typically, I schedule two to three days for a visit with my client. A few weeks before the visit, I ask for any security-related information the organization might have: a list of websites and apps, information security policies (usually a part of an employee handbook), a list of third party service providers and parts of contracts that are relevant to security, and the office and data center internet address (IP) ranges. If some of that information isn’t available, that’s okay. If I’m going to do any testing of applications hosted by third parties, at that point I need my client to coordinate that testing with their service provider. Then I review the materials provided and perform some initial “external” testing prior to my visit. If assistance with PCI DSS compliance is requested, I work with my client to start that process as well.
During the visit: I like to start discussions with management – looking together at staffing practices, physical security, policy and procedure, contracts, and other less-technical aspects of security. Then I dive into the technology with the staff (or sometimes contractors) who are responsible for managing it. Together, we’ll look at everything from routers and firewalls all the way down to the operating systems, and everything between. If PCI DSS compliance is in progress, we will review any outstanding questions my client needs assistance with. At the end of the visit, if everyone is available, I like to bring everyone involved together to discuss findings and the process of planning issue remediation.
After the visit: Sometimes there are subsequent discussions of findings after the visit. Also, I provide a lot of phone and email support and follow up, to ensure that the organization is efficiently moving forward in their efforts to improve security and to answer questions that arise along the way.
Hopefully this post has demystified the security assessment process. When it comes to information security, our industry has a lot of work to do. I benchmark the industry regularly in a number of ways. One small measure I take is “What percent of websites are running on known insecure web server platforms?” My present benchmark for that measure is: 28% of the top 50 MLSs (by subscriber count), 46% of the top 50 brokers (by transaction volume), 40% of top local associations, and 35% of our state associations. That measure is just the tip of the iceberg, too – again, there’s a lot of work to do! Contact me, and let’s start working on it together.
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