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What is GRC
An integrated collection of capabilities that organizations use to achieve objectives, address uncertainty, and act with integrity. It is integrated with the entire business.
Governance
The means by which and organization is directed and controlled (who we are and how we operate).
Risk
Taking measures to limit the chances of bad outcomes, the center of GRC in practice
People, processes, and technology
GRC involves this, and it takes input from this to ensure companies are protected from risk
Control risk
Develop treatment & response plans for each risk
Compliance
Act of ensuring a standard or set of guidelines is being followed, provides direction when starting GRC
Risk (as a concept)
Likelihood that a loss will occur; loss occurs when a threat exposes a vulnerability
Threat
Any activity that represents a possible danger, external or internal, natural or manmade, intentional or accidental
Vulnerability
A weakness in a system
Loss
Results in a compromise to business functions or assets, tangible or intangible
Tangible loss
Easy to quantify, physical, and has direct financial impact
Intangible loss
Harder to represent, non physical, example is a hit to reputation
Tangible Asset
Physical assets, are present in person
Intangible asset
Assets that are digital but still worth protecting
Principle of proportionality
Amount spent on controls should be proportional to the value of the risk
Residual Risk
Risk after risk management is applied
Inherent risk
Full risk of a vulnerability
Contingent risk
Low likelihood, high impact
Significant risk
High likelihood, high impact
Minor risk
Low likelihood, low impact
High incidence risk
high likelihood and low impact
Risk formula
Probability * impact
Unintentional threats
Environmental threats, human error threats, accidental threats, failures
Intentional threats
Greed, Anger, Desire to damage, individuals or organizations with malicious intent
Threat-vulnerability pair
Occurs when a threat exploits a vulnerability, the vulnerability provides a path for the threat
Exploit
The act of taking advantage of a vulnerability
Hubs of vulnerabilities and exploits
Blogs/forums, CVE list, Reverse engineering, dark web
NIST
creates publications and sets standards about topics and technologies
CISA
Gives guidance to companies to help with their security
HIPAA
Passed in 1996 as federal law, creates national standards to protect patient health info.
HIPAA covered entity
Health plans, healthcare clearing houses, healthcare providers
HIPAA business associate
Any person/org using or disclosing individually identifiable health info to perform or provide functions, activities, or services for a covered entity. Can include anyone that interacts with covered entities.
HHS Office of Civil Rights
Responsible for enforcement of HIPAA and imposes penalties on non-compliant companies
PCI-DSS
Set of standards that any company dealing with credit cards must abide by. Levels based on how many transactions are processed yearly
PCI-DSS Level 1
Applies to companies doing 6 million or more transactions yearly, required to have an internal audit resulting in a report on compliance, as well as submitting a PCI scan quarterly
PCI-DSS Levels 2-3
Must complete self assessment once a year and is also up for a quarterly PCI scan from an approved vendor
PCI-DSS Level 4
Self assessment and may have a quarterly scan, less than 20000 transactions yearly.
Six principles of PCI-DSS
Build and maintain secure network
Protect cardholder data
Maintain vulnerability management program
implement strong access control measures
regular monitoring of networks should occur
Maintain an infosec policy
SOX
Passed to protect public from fraudulent or erroneous practices by corporations and other business entities
SOX cyber application
Keep data safe from insider threats, cyber attacks, and security breaches
SOX data security framework
Ensure financial data security
Prevent malicious tampering of financial data
Track data breach attempts and remediation efforts
Keep logs available for auditors and demonstrate compliance in 90 day cycles
GDPR
Designed to harmonize data privacy laws across EU countries
Personal data
Any info allowing a living person to be directly or indirectly ID’d
Data controller
Maintains control over provided data; can update, modify, or delete data.
Data processors
Acts on behalf of the data controller, no control over data
GDPR principles
Lawfulness, fullness, transparency
Purposeful limitation
Data minimization
Accuracy
Storage limitation
Integrity and confidentiality
Accountability
NIST 800-37
Nist Risk Management Framework for information systems & organizations
NIST 800-30
NIST Guide for conducting Risk assessments
NIST 800-53
NIST Security & privacy controls for information systems & organizations
NIST RMF Prepare step
Ready to execute NIST RMF framework by establishing context and priorities for managing enterprise wide security and privacy risk
Goals include communication, prioritizing requirements and resource allocation, recognizing common controls and baselines, and focusing resources on high value assets
Risk context
All facets of how a risk impacts an organization and how to resolve it
NIST RMF categorize stage
Requires a full review of IT systems in use, system characteristics, and impact of an attack on confidentiality, integrity and availability
NIST RMF select stage
Select controls and allocate them to systems, document the controls in a system security plan, and continuously monitor them.
NIST RMF assess stage
Assess the selection based on candidate qualifications and knowledge, develop the assessment plan, assess the controls, report on effectiveness, remediate the findings, and develop a plan of action for more easily-remediable findings
NIST RMF authorize stage
Provides organizational accountability
NIST RMF monitoring stage
Provides situational awareness and privacy of the information system and organization
Risk owner
Usually the person who would be most affected if the risk manifested, has to decide what to do about the risk
RMP Scope
Identify the boundary of the plan and be crystal clear of what the objective is in order to avoid scope creep. Identify stakeholders and draft scope statement.
Cost benefit analysis formula
Loss before recommendation - loss after recommendation - cost of recommendation
Plan of action and milestones
A POAM is a document tracking progress and assigning responsibility allowing management to follow up on progress.
Steps of RMF
Prepare → Categorize → select → implement → assess → authorize → monitor
Members of risk assessment team
IT department, Auditors, Business Unit leaders, Legal, HR, Management
Administrative controls
Management oriented, tells you what you are/aren’t allowed to do, enforced but can’t physically stop you
Administrative controls examples
Employee management, information classification, Awareness training
Logical controls
Software or hardware components that prevent/allow access to the network
Physical controls
Prevent things from happening in the real world, things like bollards, fencing, cameras
Preventative controls
Keep undesirable events from happening
Detective controls
Identify undesirable events that are taking place
Corrective controls
Correct undesirable events that have already taken place
Single Loss Expectancy
How much the estimated impact of a single event occurring would be in $
Annual Rate of Occurrence
Numerical quantification of impact (number of times annually)
Annual Loss Expectancy
Cost quantification of impact over a year
Data collection methods
Surveys, Interviews, Vulnerability testing, pen testing
SLE formula
Asset value x exposure factor (10000 × 50% =5,000)
ALE Formula
SLE * ARO
Cost Benefit Analysis
The cost of a countermeasure against losses should not exceed the value of the losses
Value of countermeasure
ALE - cost of countermeasure
Security control
Countermeasure to avoid, detect, counteract, or minimize security risk
Measure
Proof of action to achieve a purpose
Security measure
Precaution against threats
Control
Process that addresses or lowers a risk
In place control
In place in operational system, supported by associated documentation
Planned controls
Identified in planning documentation , specific implementation date
Defense in depth
Don’t depend on a single security mechanism, have multiple mechanisms to fall back on
Assumption of breach
Design your system to be secure even as value rises and breaches are expected to occur
Fail-safe state
If a control fails, it should still deny the attacker access rather than allowing it
Simplicity
If you don’t understand how a control works, then you don’t know if its actually secure
Purpose of a risk assessment
Help management quantify risks and identify and evaluate the effectiveness of controls
Policy
A high-level document that provides overall direction without details
Procedure
Provides the detailed steps needed to implement a policy
Audit location
Normally done by an outside, independent party
Assessment location
Normally done by management team internally
FISMA
Requires federal agencies, contractors, and grantees to implement risk-based, cost-effective security controls to protect information systems
GLBA
Federal law requiring financial institutions to explain their information-sharing practices and protect sensitive customer data
FERPA
Protects privacy of student academic records, including education and health data
CIPA
Requires schools to filter internet access to prevent bad content on school devices
COPPA
Protects the information of children under 13 that use the internet
Identity governance
Securing identities for all users, applications, and data
Identity governance and administration
Managing user accounts from beginning to end
Grouping user access into roles that make sense for various jobs
Allowing users to make requests for things they need
Perform reviews of the access that had been granted
Privileged access management
Allow users to check out privileges rather than hold them 24/7, and holding non-user credentials in a “vault”