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Article

When Compliance Is at Odds with Security

Create a culture of compliance where security becomes the primary driver

Users are the weakest link when it comes to information security. Without intending to, they cost more money in security breaches than outside hackers. This is why all regulations require the demonstration of strong access security. But focusing purely on regulatory compliance proofs as a standard of security can cause one to lose sight of the intended goal.

Falling into the Compliance Rut
In a typical organization, IT administrators face an alphabet soup of regulatory requirements that have been put in place in an effort to protect sensitive information. And even in businesses that are not externally regulated, there are often compliance initiatives underway that require meeting some type of standard. There is a real temptation to define success as getting a passing mark on a list of criteria against which the security of the organization is going to be measured. However, in trying to pass an ever-growing and evolving list of tests, IT personnel may find themselves getting away from their real jobs - security. This is particularly true when the organization attempts to handle each standard on an individual basis and winds up getting preoccupied with creating or applying specific controls for each one. As individual standards change or requirement specifications are released, this approach of wearing two hats may quickly challenge security professionals' sanity.

Today, when asking security solution buyers "what problem(s) are you hoping to solve?" the reply is frequently, "I need a product with a HIPAA reporting package (or PCI, etc)." As a result, every software solution vendor worth their salt now has a HIPAA and/or other reporting packages to sell. But the reality is that these reporting packages are most often just an extracted and renamed set of best security practices, which - if implemented comprehensively - would more than satisfy any compliance standard AND provide a more saner approach to security.

Bottom line: compliance may not be the best end goal and security professionals should not get distracted by all the hype about solutions that purport to produce compliance.

Beyond Philosophy
While the points made above are important, it's instructive to go beyond the abstract issues and discuss how to put them into practice. Here are two additional, yet potentially controversial, recommendations to consider.

When selecting solutions to solve compliance or security challenges, choose those that deliver security domain capabilities (e.g., access security, DMZ security, web security, etc.) instead of ones that attempt to be a tool to use in multiple security domains. If you are concerned about access, an access security solution will always be able to employ methods that get you better information, context and answers with infinitely better performance than a solution that relies on an infrastructure and architecture intended to be a generic security information-gathering solution. I can use the word "always" because domain solutions are designed to answer questions that are crucial to that domain instead of being designed to gather data, which may be useful in many domains. Different methods are used. Data is analyzed differently. Information is presented differently. A solution whose goal is "compliance" may be great for a chief compliance officer, but will do little or nothing to advance the capabilities of access security or any other security specialty.

Access security solutions (like other domain security solutions) have the advantage of bringing together the data that is needed to both demonstrate compliance and provide context for IT action. For example, the ability to determine how access is derived (effective rights) is important for answering many compliance questions. But perhaps more importantly, it is also crucial for determining how best to prevent insecure events from reoccurring by identifying a root cause (explicit grants vs. group memberships, for example), which can be fixed as opposed to a symptom that can be band-aided. A broader security information management solution does not bring this context to the event data; they are concerned with how generic event data is harvested, organized and archived and far less or not at all concerned with how an access security professional has to do his/her job.

One final recommendation - audit continuously. There is a great analogy that a leading security luminary once made: Auditing is the most effective form of security - akin to police work in the real world. In the real world, the fact that police will investigate crimes and will tend to solve most of them is the best deterrent to future crime. Effective auditing is the digital equivalent of police investigation.

Rather than contemplate an approach to compliance that is based on responding to breaches or errors as they arise, decide instead to audit continuously. By auditing continuously, I mean define a desired state, audit your current state against that, develop event controls to maintain desired state, and audit desired state again at some interval. It may sound cumbersome and potentially expensive, but it is, in fact, the least expensive approach. This is because it leads to incremental process and control improvements over time, which serves as a much better deterrent to insecurity in the future than waiting for a major security event with all its cost and downtime implications.  And, it is something that can be effectively automated to ensure that its resource impact is purely positive.

Next-Generation Compliance
In the end, the ultimate goal is to identify sensitive information or access, de-risk it, and provide audit trailsof critical access rights changes and uses. Continuous security audit solutions will need to deliver a set of best-practice policies and include contextual event response so that businesses have the answers (not just data), they need to truly evaluate their state of security and respond to events appropriately, rather than simply collecting mountains of event data.  By moving beyond checkbox compliance and generic event management solutions, businesses can become self-auditing and create a culture of compliance where security becomes the primary driver and compliance becomes a byproduct of providing sound security.

More Stories By David Rowe

David Rowe is the CEO of NetVision, a privately funded company providing compliance and control solutions for enterprise access auditing. An experienced IT security and management entrepreneur, Rowe has held director, advisor and executive-level roles with startups including Imperva, Cerberian, PS’Soft, Doyenz, and Avinti and has helped raise more than $50M growing, launching and re-launching companies.

Previously, Rowe served as chief marketing officer for Trend Micro, where he was accountable for strategy, marketing, product management, business and channel development for the global company during a period of growth from $300M to $600M. Rowe spent twelve years at Intel as a business unit manager and director of marketing, products and business development in the U.S., Japan, Europe, and Israel.

Rowe holds a master’s degree in business administration from the Ross School of Business at the University of Michigan.

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