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Compliance & the Role of Security Patch & Vulnerability Management

Differentiating between higher-risk systems and higher risk vulnerabilities

IT security professionals who are already managing the bottom-line expectations of their boardrooms while guarding their organizations against myriad security threats have a new "C-level" challenge - that of compliance. These professionals must now meet voluntary and mandatory regulations such as Sarbanes-Oxley, the Gramm-Leach-Bliley Act, the Federal Information Security Management Act (FISMA), and the Health Insurance Portability and Accountability Act (HIPPA).

A critical piece of the compliancy puzzle and an instrumental component already supporting the enterprise IT security posture, patch and vulnerability management is quickly becoming a multi-faceted solution that IT security professionals are employing to address this challenge.

However, determining the exact role of automated patch and vulnerability management and policy and how it supports and meets voluntary and regulatory compliance has become the question. Here we offer an answer to help the security professional understand the role of patch and vulnerability management in supporting auditable compliance - the state of compliancy at which an organization's IT control and security status and reporting ultimately meet the requirements of many of today's corporate policies and regulatory acts. Moreover, it's important to know that as a security professional the ability to achieve a state of auditable compliance is real and attainable.

The Dual Dilemma: Security and Compliancy
IT departments need to secure their infrastructure against threats such as viruses and worms and manage their network's availability. They also must demonstrate to auditors the adequacy of this security through measurement and process. The roadmap to regulatory compliance (see Figure 1) shows how the three technical competencies of an enterprise IT security program - command and control, threat mitigation, and audit and monitoring - strongly support the business goals of management, security and availability.

According to Yankee Group analyst Phoebe Waterfield, "management" is the Achilles' heel of many organizations and is central to demonstrating regulatory compliance. For example, she says, keeping up with critical patches for desktops, servers, and applications demonstrates effective management of IT systems and controls. Moreover, there's an urgent need for more effective processes to ensure that critical patches and fixes are applied to higher-risk systems in a timely manner. To this end, many organizations are now turning to strategic security solutions like patch and vulnerability management to improve systems security management processes and meet the burden of proof regulations impose.

Systems Management Under Security Scrutiny
The most frequent question organizations ask about regulations is how to interpret them and apply real-world security solutions to meet compliance. Regulations don't stipulate any specific security tools or products. Instead, they ask each organization to demonstrate how they are protecting the information contained in IT systems to a level commensurate with its value. For example:

  • Applying adequate security protections for customer data according to stated corporate security and privacy policies
  • Following best practices to secure a network's perimeter and access to systems on the network
  • Protecting confidential information and limiting access to personally identifiable information
The lack of specificity in regulations creates uncertainty about what compliance means, what auditors are looking for, and what vulnerabilities are considered unacceptable risks. IT departments can judge their general compliance readiness using the roadmap depicted in Figure 1. More than likely, some of these areas lack definition in most organizations.

The most common missing component is security management. This is a serious issue because it prevents IT personnel from demonstrating and reporting the effectiveness of the security components already in place. For example, a business may have a systems management tool such as Microsoft's SMS and use it for keeping endpoints such as workstations, laptops, and servers updated with the latest patches. However, this tool doesn't provide the necessary reports that give an accurate and timely picture of which systems are missing patches. It's no longer enough for organizations to patch; they must now prove that systems are patched to a reasonable level and measure how effective patching processes are at reducing vulnerabilities on their network. Figure 2 shows how manual or less than best-of-breed patch management processes leave systems exposed for long periods of time.

Malicious code threats propagate in days, not weeks. For example, according to Yankee Group research, the Nimda and Slammer worms spread worldwide in less than an hour, but the signature updates to protect networks weren't available for 24 hours. Then enterprises had to get these updates out on their networks to be protected. The impact and cost of virus and worm infections are largely attributed to unpatched and misconfigured systems running a vulnerable service. According to Gartner, over 90% of security exploits are carried out through vulnerabilities for which there are known patches.

Regulations Demand IT Control and Command
Regulations require organizations to demonstrate compliance through risk management and sufficient IT controls. Regulations don't always cite specific controls, so provided below are descriptions of how auditors are interpreting the law and some emerging standards that are used for industry benchmarking.

Sarbanes-Oxley Act
The Sarbanes-Oxley Act (SOX) is the single most important piece of legislation affecting public corporations since the U.S. securities laws of the early 1930s. The act charges managers of public companies with the task of certifying that they have an operational system of internal controls over financial reporting. SOX followed in the wake of several major accounting scandals and raised heads because it holds corporate executives directly responsible for the accuracy of the financial statements their companies make to the Securities and Exchange Commission (SEC). Section 404 of Sarbanes-Oxley deals with IT systems. It requires an annual evaluation of the internal controls protecting the systems used to prepare a company's financial statements. Companies must vouch for the veracity of their financial data and, significantly, the effectiveness of these internal security controls. Sarbanes-Oxley was supposed to come into effect in November 2004. However, the SEC recently pushed this deadline back a year, a relief to many publicly traded U.S. companies that now must make significant changes in their infrastructures to meet SOX IT control requirements.

The Federal Information Security Management Act (FISMA)
The Federal Information Security Management Act, enacted in December 2002, requires that federal agencies ensure the effectiveness of the information security controls protecting federal operations and assets. FISMA specifies what agencies must do to strengthen security. It's an agency-wide information security policy specifying how to classify data as confidential and how to protect data and systems according to their criticality. It mandates a set of internal audit activities, including periodic testing of IT security controls and submitting an annual report on FISMA compliance to the National Institute of Standards and Technology (NIST). Federal agencies are specifically required to report how they ensure all systems are patched in a timely manner.

More Stories By Sean Moshir

Sean Moshir is chairman and chief executive officer of PatchLink Corporation, a company he founded in 1991. During the course of his career, Sean has focused exclusively on strategic security software and services that supports business continuity with an emphasis on patch, vulnerability, and compliance (PVC) management functionality and support.

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