2010 secure world boston nist

SecureWorld Expo - Boston - March 24, 2010 -Room 104

NIST, FISMA, HIPAA and Data Privacy –

Where to Begin

Candy Alexander, CISSP CISMSecureWorld Expo Boston

March 24, 2010Room 104


Topics

Setting the stage for a Case StudyUnderstanding the requirementsHow can NIST helpCloser look at NISTSummary


Setting the StageOrganization driven by multiple requirements

FIMSAHIPAA* Data Privacy (45 states and the Feds)MA 201 CMR17

Small organization with minimal resources Need to work smartIdentify 1 size to fit all requirements (framework)

Existing work based on HIPAA Privacy & Security rulesRedirect into the NIST framework to meet *all* requirements

* Additional push with new HITECH Act – Summary of changes at end of slides


Understanding the Requirements…

Need to understand business requirementsCompliance (just enough or to protect)Big budget or barely enough

Frameworks availableISO ($$$)COBIT ($$)NIST (free)Do it yourself ($?)All of these + Notification process*

Federal Contractor, we usedNIST Risk Management Framework (RMF) for SP800-53SP800-66-Rev.1


Using the NIST Risk Management Framework (RMF)*

* NIST SP800-66 Rev. 1 October 2008


Step 1 – Categorize Information and Assets

FIPS199 to identify CIA (confidentiality, Integrity and Availability) rating score

Great tool for communicating risk to businesses.PHI (Protected Health Information) the “C” and “I” should be high – availability is up to process ownerIdentify PII (Personal Identifiable Information) and business owner (supports data privacy requirements)Identify “where” in the organization PII/PHI is

(applications, folders, etc.) Supports the PHI tracking requirement for HIPAAUse NIST SP800-60 for guidance


Step 2 – Security ControlsUse FIPS 200 to identify the minimum baseline

Select controls to be used Identified in SP800-53 (Rev.3) that are appropriate to the environment (risk approach)

Document controls/requirements into a security plan for each IT System.

NIST SP800-18 Guide for Developing Security Plans for Federal Information Systems


Step 3 – Implement Security Controls

Uses various automated tools and manual processes

Operating system controlsApplication controlsSystem Development Life Cycle

Full array of publications available to provide guidance to the specific topic/requirement

See http://csrc.nist.govSpecial Pubs, FIPS pubs, IR (internal reports), and ITL (Info Tech Lab) Bulletins

http://csrc.nist.gov/


Step 4 - Assess Controls

Evaluate the controls with SP800-53AInternal AuditsExternal Audits


Step 5 – Authorize Information System

Authorization to Operate (ATO)Primarily for FISMA compliance

Essentially Designation Authority reviews controls and evaluation of controls – then authorizes use with an explicit decision to accept the risk

Not a BAD idea for getting executives to understand, review and accept the risk


Step 6 – Monitor SecurityContinuous monitoring

Threats & vulnerabilitiesControls put into place to mitigate risk

Ensure all is effective and as intended

Ensure documentation is updated

Conduct impact analysis


FISMA… Certification & Accreditation

What is Certification and Accreditation?Certification and Accreditation is a process that ensures that systems and major applications adhere to formal and established security requirements that are well documented and authorized. 1

Sound a little like MA 201 CMR17?

Obtaining the C&A removes the uncertainty of compliance

Much like a ISO, PCI and SAS70 Type II?

Auditors appreciate the structure1 e-Articles.info on ask.com


FISMA/NIST C&AC&A guidance available through SP800-37

Provides accrediting authority ( and auditors) high degree of confidence that the managerial, technical and op security controls work as intended & that the information processed, stored and transmitted with the system is protected.

Controls based on FIPS 199, 200 and NIST SP800-66 (HIPAA) and SP800-53

C&A should be completed prior to production and re-accredited when significant change occurs, as directed by the agency contract/ authorizing official or at minimum every three years.


C & A Phases

Consists of 4 distinct phases1. Initiation Phase2. Security Certification Phase3. Security Accreditation Phase4. Continuous Monitoring Phase

Each phase has a detailed list of tasks and subtasks, documents and artifacts that are used to support the next phase


Certification Package*1. Updated System Security Plan2. Completed Security Risk Assessment3. Updated Config. Mgmt Plan4. Contingency Mgmt Plan(s)5. Security Test & Eval. Report6. User Manuals7. Interconnection Security Agreements or MOUs

(Business Associates Agreements for HIPAA)8. Privacy Impact Assessments9. Federal Register System of Record Notice10. Plan of Action & Milestones*Exact contents are defined by Information System Owner


Accreditation Package

1. Security Assessment Report2. Security Accreditation Decision Letter3. System Security Plan4. Plan of Action & Milestones


HITECH Act - Tougher HIPAA

From Privacy/Security Perspective:Breach Notification (tougher requirements)Wider scope – including BAs (2/17/10)Account of disclosures (more rigorous)Enforcement (2/17/10) – increased $$$State AG’s enforcement


Questions?

Candy Alexander, CISSP [email protected]

2010 secure world boston nist

Documents

secureworld expo

action

nist sp800

controls

plan

certification

system