Posted by Robbie Forkish on Mon, Jan 04, 2010
Ronald Reagan famously said "Trust, but verify". He could very well
have been talking about entitlement management systems, which manage
authorization to critical applications and other IT resources. Such systems are
trusted to maintain control over entitlements (also called privileges or access
rights). However, the systems themselves rarely have verification or assessment
capabilities. This may be adequate for smaller organizations or enterprises
where roles change infrequently. But the dynamic nature of most
enterprises -- with layoffs, restructurings, aggressive use of contractors and
other service providers -- makes assessment not only prudent, but necessary to
ensure effective access controls and audit compliance.
Entitlements
Deloitte, in The
6th Annual Global Security Survey, reports that excessive entitlements,
also known as excessive access rights, was the top audit finding over the past
year -- for the second year in a row! In other words, a fundamental access control
that represents a compliance exposure and security vulnerability was the top
audit finding in 2007 and, despite all the attention that garnered, was also
the top audit finding in 2008 (the latest year for which survey data exist).
Since all major regulatory frameworks, including SOX, PCI
DSS, GLBA, NERC and HIPAA, require access controls, many thousands of companies
are obligated to prevent excessive access rights and yet, according to the
Deloitte survey, have failed to effectively do so.
Not only is excessive access rights the top audit finding, but IDC
states that such vulnerabilities result in major financial exposure -- and
that up to 60% of rights on most systems are expired and therefore dormant. The
problem is that IT and security staff at most companies don't know that dormant
accounts exist -- or more precisely, they suspect they exist but don't know how to
find or remediate them.
Why is this a hard problem to solve?
Access Controls in the Real World
A paper
written by a team at Dartmouth describes observations from field study
research of both retail and investment banks. The study was more in-depth than
most surveys we hear about; for example, the study team was embedded for three
weeks in the security group of an investment bank. The report focuses primarily
on internal access controls and the risks of over-entitlement, and they
directly address the challenge of effectively managing access controls.
What they found was that the frequent shifting of staff may from one department
or role to another often results in users accumulating entitlements over time.
Part of the problem is this: Entitlement management systems assume that an
employee's direct supervisor can make informed decisions about what
entitlements are required to do their job. But as the Dartmouth team points
out:
"As more
organizations take on a matrix structure, it becomes less evident who reports
to whom and who is responsible for permitting and terminating data access."
This leads to ambiguous and
unwieldy structures for assigning entitlements, or privileges, as shown in
Figure 1:
Figure 1: Privileging
in traditional hierarchical corporate structures (left) vs. in dynamically,
"matrixed" organizations (right). An arrow represents a supervising
relationship (directed graph). Note that on the left, each person has exactly
one direct supervisor, whereas on the right, each may have two or more.
And even if the corporate structure and reporting relationship is clear in
all cases, the degree of scale and complexity makes entitlement management a
big problem as shown in Figure 2:
Figure 2: Complexity and dynamicism in
entitlement systems. The number of applications, entitlements and users make it
a large-scale problem, and the number of daily modifications makes it a
fast-moving target.
The biggest challenge isn't the massive number of entitlements and users,
however, but the highly dynamic nature of employees and organizational
structure within the firm.
Conventional wisdom holds that role-based access control (RBAC) systems are
the answer. By allowing organizations to segregate the massive numbers of
employees and entitlements into work groups, RBAC systems make the entitlement
management process more effective. But the size, complexity and dynamic nature
of many large enterprises make role-based access control challenging, to say
the least. Quoting from the Dartmouth study:
"At one very
large retail bank that we interviewed, the CISO had recently completed an RBAC
project creating 11,000 roles across the firm to control access to nearly
22,000 applications. Developing the roles took a team two years and the ongoing
review process was expected to be significant."
In the real world, access rights are constantly changing, for legitimate
reasons: employees are hired and terminated; contractors come and go; service
providers and outsource firms require access on a project basis with often
unclear timelines; federated identity management systems expand the concept of
trusted user beyond the enterprise boundary; departments and whole companies
undergo reorganizations; mergers and acquisitions result in major
restructurings; layoffs lead to rapid and sometime undocumented role changes;
and employees transferring within a company inevitably have to overlap
responsibilities (and access) between their old and new jobs. Unclear and
imperfect communications between HR, line-of-business (LOB) staff, and IT
exacerbate the problem.
Managing
Entitlements
Andrew Jaquith, an analyst at Forrester, in his book Security
Metrics states:
"Today's
information security battleground is all about entitlements-who's got them,
whether they were granted properly, and how to enforce them."
Companies large and small employ different approaches to entitlement
management, with equal lack of success. Mostly, they do manual reviews of
entitlements prior to audits by going through HR records, reviewing application
logs, and interviewing LOB managers-a process inevitably referred to as a fire
drill. Other approaches to entitlement management include development of custom
reports for SEIM and log management systems, network-based user activity
monitoring, and RBAC systems.
The management challenge is to determine what's a reasonable target level of
excessive access rights in terms of percentage of overall rights granted, and
then ensure that solutions are in place to consistently keep actual excessive
access rights on or below the target. It's more expensive to establish an
excessive access rights target of 2% than of 4%, for example. Therefore,
management must determine what level constitutes "enough" security, doesn't
break the budget or put an undue burden on IT or line-of-business staff, and
yet meets the compliance requirements as measured by auditors. What auditors
are looking for is a sustainable, measureable process that demonstrates
visibility (can the company detect when and where it has excessive access
rights?) and the ability to remediate problems when they occur (can the company
eliminate excessive access rights within a reasonable amount of time from their
detection?).
Top Audit
Findings
As the Deloitte survey reports, current approaches
have failed to achieve the desired and necessary level of compliance -- not just
for excessive access rights, but for access controls in general.
Figure 3: Top internal
and external findings for 2007 and 2008, ranked by percentage of respondents
citing findings in each category, taken from the Deloitte survey.
Here's an explanation of each of the findings:
Excessive access rights. Note that despite the improvement from
2007, excessive access rights remained the top audit finding in 2008 as noted
above. Part of the reason that excessive access rights has been the top finding
for the past two years is that auditors have raised the standard, from evidence
of the existence of a process to
evidence that the process is effective.
Segregation of duties. Segregation of
duties, also referred to as separation of duties and abbreviated SoD, is one of
the most fundamental concepts of security and control, and also one of the most
difficult to achieve.
Access control compliance with procedures.
This audit issue is closely related to excessive access rights; access control
is required to prevent users without appropriate rights from accessing audited
resources.
Lack of audit trails/logging, lack of
documentation of controls, and lack of review of audit trails. These three
top findings are grouped together because they represent the facet of access
audit where technology and process come together. Application logs, which
represent the most effective way to determine user access activity, are an
essential tool for ensuring that access controls are compliant. And reports
that list who has access to what, along with who should have access to what,
become critical components of how access controls are documented.
Excessive developers' access to production
systems and data. This audit finding is challenging to address, because
it's unrealistic in most operating environments to completely block developers
from accessing production systems for troubleshooting and critical maintenance
operations. The objective, then, is not to prevent such access but to note when
it's risen to an "excessive" level.
Lack of clean-up of access rules following a
transfer or termination. Few if any organizations effectively manage rights
and access rules in a real-world environment with re-org, restructurings,
layoffs, role re-definitions and transfers-especially transfers. Because
transfers are not a discrete event so much as a process where an employee has
overlapping responsibilities between new job and old job-and therefore must
maintain access rights for both jobs.
It's clear from the Deloitte survey that access controls are problematic.
While organizations are reasonably effective in ensuring that only authorized
users may log in to critical resources, they fail to consistently determine
which users should be authorized to
access those resources. Meanwhile, auditors have learned where to look in order
to find users with excessive access rights and other access control violations;
hence, an increasingly high rate of audit findings.
Is Perfect
Access Control Possible?
The well-known security guru, Bruce Schneier, in a recent
article entitled Is Perfect
Access Control Possible?, discusses many of these same points and
concludes:
"In
the end, a perfect access control system just isn't possible; organizations are
simply too chaotic for it to work."
Schneier refers to the Dartmouth study's finding that 50-90%
of users are over-entitled in large organizations. Over-entitlement leads to
risk, and therefore attracts the attention of auditors as explained in the
Dartmouth study:
"It may not seem problematic for employees
to have access to systems they never use or are unaware of. However, such
access introduces risk. The root of the problem is that unnecessary or
uncontrolled access can lead to unintended data editing, accidental disclosure,
or internal misuse. That is why Sarbanes-Oxley auditors will flag unnecessary
access as a weakness."
Auditors have learned in recent years how to find and flag
excessive access rights, which is the top cause of audit findings. And not only
is audit compliance an issue, but as noted above in the IDC report excess
entitlements represent a huge financial liability. Thus, imperfect access
controls represent a security vulnerability, a financial liability, and a
compliance exposure. Despite these compelling motivations, we find from
research by Deloitte, IDC, Forrester, Dartmouth and Bruce Schneier that
present-day access controls are largely ineffective, especially in highly
dynamic organizations.
What does the future hold for access control? New
technologies are on the horizon that, by taking an approach referred to as
Identity and Access Assessment (IdAA), enable visibility into the effectiveness
of access controls. Such solutions perform data mining to analyze access
activity over time and thus identify access control issues for remediation.
Cloud
Compliance
Cloud Compliance is
developing an IdAA solution to improve the efficacy of compliance solutions
and reduce the cost of achieving compliance. We combine the economies of cloud computing
with fundamental performance management principles to provide easy, low cost
analysis of access rights to prevent audit findings and ensure access control
compliance with regulations such as SOX, GLBA, PCI DSS, HIPAA and NERC. Our
solution enables customers to identify access audit deficiencies before
auditors arrive, and without manual process costs that otherwise
dominate.
Here's how it works: Cloud Compliance employs SaaS-based
data mining analytics that examines users' access activity to identify and
report on excessive access rights and other access controls. The Cloud
Compliance solution can assess your organization's identity and access controls
in five simple steps:
1. Point
your browser to the Cloud Compliance SaaS site
2. Using
Cloud Compliance's automatic wizard, select which resources and applications
you wish to assess. This is a matter of identifying the SSO system, SIEM, MSSP
(if you have a log retention service), or the targeted application servers' log
files and entitlements data.
3. Upload
entitlements info and log data to the Cloud Compliance SaaS site.
4. Review
the graphical analytics to determine performance versus benchmarks, and to
remediate any policy violations
5. Repeat
steps 3 and 4 periodically. The amount of time between assessments represents
the maximum lag time between when a violation occurs and when it's identified.
It's that easy!
Our innovative ability to measure, report and ultimately
remediate potential audit findings enables our customers to resolve compliance
problems prior to an audit. In addition, Cloud Compliance's graphical analytics
highlight trends and identify root causes to compliance issues, by audited
application, or by business unit, providing valuable insight into potential
security vulnerabilities. Furthermore, due to our global visibility as a
cloud-based SaaS solution, we capture statistics industry-wide that our
customers can access for setting their own policy benchmarks. Finally, the
Cloud Compliance SaaS solution requires no software to install, maintain and
operate, no appliances to deploy, no consultants, advisors or professional
services to deploy, and no huge upfront capital expense to incur.
For further information, see the Cloud Compliance use case
demo at http://www.cloud-compliance.com/product/demo/.
Cloud
Compliance Security
As with all cloud-based services, security can be a concern.
That's especially true for services that address compliance issues and access
vulnerabilities. Cloud Compliance employs the Amazon EC2 (Elastic Compute
Cloud) service which has extensive and comprehensive physical and logical
controls, including:
§
State of the art intrusion detection systems
§
Authorized staff must pass two-factor
authentication at least twice
§
Immediate deprovisioning of admin when no longer
has business need
§
Extensive background check of staff with
potential access to customer data
§
All admin access logged and audited
§
Network security: DDoS, MITM, and firewall
§
Firewall requires customer's X.509 certificate
and key to authorize changes
§
API calls to launch and terminate instances and
perform other functions require X.509 certificate
§
S3 (storage) read permissions controlled by ACL
§
S3 authentication using HMAC-SHA1 signatures
§
Storage device decommission based on NIST 800-88
(media sanitation)
§
AWS recurring SAS-70 Type II certification
Cloud Compliance encrypts data in transit as well as data at
rest (there's also an option that precludes the need to store any log or entitlement data
at all). And it's worthwhile pointing out that the Cloud Compliance solution
does not require access to personal identifying information (PII); only a
non-sensitive subset of entitlement data and log records are required.
Compliance
Made Easy
Cloud Compliance's Identity and Access Assessment service is
easy to adopt and provides immediate results. We solve access control issues
that go by many names: excessive access rights; least privilege policy
violations; excessive privileges; dormant accounts; and excessive entitlements. These access control issues have
been identified, studied and reported on by major audit firms such as Deloitte,
analysts such as Forrester and IDC, academic research teams such as from
Dartmouth, and enterprises around the world. Yet, until Cloud Compliance, there
was no effective solution available. Now, with our SaaS-based IdAA, achieving
access audit compliance is not only possible -- it's easy.
Note: A PDF of this post can be found here.
Posted by Robbie Forkish on Fri, Sep 11, 2009
Deloitte reports that excessive access rights was the top audit finding for the most recent two years surveyed. Not only is it the top audit finding, but IDC states
that excessive access rights result in the biggest financial exposure
for organizations—and up to 60% of rights on most systems are expired
and therefore dormant. The problem is that IT and security staff at
most companies don’t know that this condition exists—or more precisely,
they suspect it exists but don’t know where.
Compounding the problem for these companies is that auditors have in
recent years learned that by spot-checking recent transfers and
terminations, they are more than likely to uncover excessive access
rights. This has contributed to the high rate of audit findings in
recent years.
Conventional wisdom holds that the solution to this issue is better
Identity Management (IdM) systems with role-based access control (RBAC)
capabilities and a user interface that can be understood by
line-of-business managers, who could then be counted on to keep access
rights current and accurate. Unfortunately LOB managers are often
reluctant partners in this enterprise; the path of least resistance for
them is to keep existing rights when in doubt. And the high rate of
audit findings suggests the weakness of this approach.
Whether companies have an IdM system or not, they most likely prepare for audits by manually
analyzing HR records and job descriptions in conjunction with role
definitions and entitlements. This quarterly or annual process is
invariably referred to by customers as a fire drill. In many cases,
contractors or temp workers are brought in for this task—adding to the
expense but rarely improving the outcome as measured by audit findings.
In the real world, access rights or entitlements are constantly
changing, for legitimate reasons: employees are hired and terminated;
contractors come and go; service providers and outsource firms require
access on a project basis with often unclear timelines; federated
identity management systems expand the concept of trusted user beyond
the enterprise boundary; departments and whole companies undergo
reorganizations; mergers and acquisitions result in major
restructurings; layoffs lead to rapid and sometime undocumented role
changes; and employees transferring within a company inevitably have to
overlap responsibilities (and access) between their old and new jobs.
Unclear and imperfect communications between HR, line-of-business
staff, and IT exacerbate the problem.
There is no perfect IdM system and there’s no foolproof rights
management process. Since the systems and processes for managing rights
inevitably fall short of 100% accuracy, some kind of feedback or
assessment mechanism is required to achieve least privilege objectives
and improve IT audit performance. That’s why Cloud Compliance
is developing the industry’s first Identity and Access Assessment
(IdAA) system—to provide feedback that identifies, reports on and helps
remediate excessive access rights and other access audit issues.
Cloud Compliance will address the IdAA challenge with a unique,
innovative SaaS solution. Our cloud-based analytics assesses log-based
access activity for selected applications, typically those that are
audited or that access sensitive data such as personal identifying
information (PII). We identify dormant (aka zombie) accounts, and
provide tools for isolating high rates of dormancy by group, business
unit or by application. Such tools enable root cause identification,
and provide the necessary insight for remediation and process
improvement. Furthermore, due to our global visibility as a
multi-tenant SaaS solution, we capture statistics industry-wide that
our customers can access for setting their own policy benchmarks.
Finally, in contrast to software-based IdM solutions, the Cloud
Compliance SaaS solution requires no software to install, maintain and
operate, no appliances to deploy, no consultants, advisors or
professional services to deploy, and no huge upfront capital expense to
incur.
Ronald Reagan famously said “Trust, but verify”. Many IdM systems
are trusted to maintain entitlement and access rights. But the systems
themselves rarely have verification capabilities. They would benefit
greatly from an Identity and Access Assessment solution that provided
verification, and in doing so improved audit performance and regulatory
compliance.