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4. Language Of Security Policies: The Specifics.
Each organization will have to conduct its own risk assessment to determine what its IT security should contain and how it should be organized. There are models of security policies available54 that set out a bare structure, and it is recognized that each organization will have its own needs and requirements and as such will have to make any policy its own and reflective of its specific concerns and goals. The format of security policies thus vary, and what follows are some specific examples of real policies to highlight the type of language used and the structure that best communicates the organizations' overarching philosophy.
JIM PATTISON GROUP
The Jim Pattison Group has multiple policies. The policies are clear and concise, and are laid out in point-form for ease of reading.
Laptop And Removable Media Security Policy
Purpose
This policy addresses the actions that must be taken by all Jim Pattison Group Corporate Office employees who have a company-issued laptop, or who are temporarily using a 'shared' company laptop, or the laptop of another employee. The majority of the requirements and/or recommendations in this policy also extend to the use of USB flash disk drives, Blackberry/PDA's, Floppy and CD/DVD R/W disks and all other forms of removable media.
Risk
Laptops and removable media are especially vulnerable to loss and theft.
Although the majority of thieves may be after the quick profit from selling the device on the black market, there is a growing number who steal laptops specifically for the sensitive data they may contain. Such information, if revealed, could cause embarrassment, loss of reputation or significant financial or commercial impact to the Jim Pattison Group.
To counter these risks laptop, PDA and removable media security must be addressed in five ways;
User responsibility; through increased user awareness of the risks and application of a security policy (this document)
Physical security; for example making sure the laptop, pda or removable media is not left unattended
Access control/authentication; locking down the devices to particular applications and only allowing authenticated users with strong passwords
Data protection; through the use of encryption or storage of all data on the network instead of on the local hard drive
Tracking/recovery. The tracking and recovery of lost or stolen laptops through the use of specialized software and authorities
The policy then goes in detail through the above five headings. The policy then considers software recommendations with respect to the following software solutions: Whole disk encryption, Port Control and enforced Removable Media encryption, Folder Level Encryption, Tracking/Recovery.
Information Security Policy
The following are excerpts from the Jim Pattison Group Information Security Policy.
The organization provides employees with Internet services and electronic communications to facilitate the fulfillment of job responsibilities. The use of these services, which hold the potential for introducing viruses, spyware, worms, and other threats, can result in data loss, exposing sensitive information and slowdowns in system and network performance.
The increase in the amount of security breaches worldwide has led to these policy changes. The external or public facing network is very secure; however our internal network is vulnerable to attack. Seeing as 80% of breaches are made from the internal network it has become necessary to establish guidelines to minimize these risks.
The topics covered in the security policy include: Internet Use, E-mail Messaging, Instant Messaging, Monitoring, Software, Passwords, Data Privacy, Data Destruction, Viruses and Spyware.
Prior to setting out in full the various topics, the policy states:
In order to facilitate protection of the network as well as to provide complete data backups, users should shut down their computers when they leave at night and especially on weekends when most hacking activities occur. An exception to this rule is Monday nights when computers should be left on so that virus, spyware and de-fragmentation utilities can be updated and run successfully. (emphasis in the text)
With respect to monitoring, the policy states:
All communications, including text and images, can be disclosed to law enforcement or other third parties without prior consent of the sender or the receiver. This means don't put anything into your e-mail messages that you wouldn't want to see on the front page of the newspaper or be required to explain in a court of law.
With respect to passwords, the policy recognizes the goal of finding "a compromise between high security and convenience for the end user." The policy sets out specific criteria and also references a separate document, Password Guidelines.
The Password Guidelines provide:
Password cracking or guessing may be performed on a periodic or random basis by the IT department or an external consultant. If a password is guessed or cracked during one of these scans, the user will be required to change it.
The Information Security Policy is not a stand-alone document. The Jim Pattison Group has an Acknowledgement of Security Policy to be signed by employees to acknowledge receipt and compliance with the Information Security Policy.
TOTAL SA
Total is one of the world's largest publicly traded integrated oil and gas companies. Total's Corporate Security Policy Statement is just that, a statement. It contains a list of 10 core principles. Some of the principles which are relevant to this discussion are:
Prevention must be the first priority. Threats analysis and risk evaluation should be carried out on a continuous basis.
Security measures and procedures must be submitted to regular inspections, validations and verifications by security specialists so as to maintain high levels of security standards in TOTAL operations world-wide.
All incidents, including security breaches and irregularities must be reported and recorded. Corrective action should be taken and followed up through the regular verifications to improve the overall security standard.
CBC/RADIO CANADA
One of CBC/Radio-Canada's Corporate Policies is Policy 2.5.1, Corporate Information Technology (IT) Security and Employee Use of IT Assets. Included in the Statement of the Policy are the following passages:
The use and security of all CBC/Radio-Canada's IT Assets are governed by this Policy. Of paramount concern and importance is CBC/Radio-Canada's ability to secure and protect its IT Assets from malfunction, reduced performance and improper use, and to maintain Data integrity and confidentiality.
Any use of or connection to CBC/Radio-Canada IT Assets including, but not limited to, the use of the Internet or E-Mail via these IT Assets, will constitute consent to the terms and conditions of this Policy. Employees do not have any personal privacy rights when using CBC/Radio-Canada IT Assets.
Most of the policy is divided under 3 headings: Application, Description, and Definitions. There are also heading for History, References, Person Responsible for Its Application and Department Responsible for Updating this Webpage.
Under the Application heading, the policy states:
It is recognized that the rules governing the use of IT Assets for a media and journalistic entity such as CBC/Radio-Canada must have some flexibility. Consequently, it is understood that for journalistic, programming or other valid business purposes, exemptions to portions of this Policy may be justified for particular employees.
Under Description, and in reference to CBC/Radio-Canada's right to limit, extend or terminate any use of and access to its IT Assets, the policy states"
In order to manage this function, the CBC Technology Department(s) designated by the Vice-President, Chief Technical Officer (CTO) must be informed of any additions, deletions or modifications to access rights to CBC/Radio-Canada IT Assets, including, but not limited to, Workstations, Networks, IT Applications, and the use of the Internet and E-Mail accounts. The required information provided should include the identity of the user, the type and level of access as well as the duration of access.
CBC/Radio-Canada may monitor its IT assets for the purpose of troubleshooting, capacity planning and the enforcement and consistent application of this Policy.
All employees are required to:
Inform their immediate supervisor if they become aware of any compromise or suspected compromise of IT security, or non-compliance to this Policy;
Include a company disclaimer as part of each message when posting to Usenet newsgroups, Internet mailing lists, etc.;
Included in the list of improper or unauthorized uses of IT Assets are:
Doing non-business-related activities that will cause congestion or, disruption of CBC/Radio-Canada IT Assets including, but not limited to: online games, online gambling, unnecessary List Serve subscriptions and E-Mail attachments, and chat rooms, such as Internet Relay Chat (IRC), Instant Messenger and similar computer conferencing chat rooms on the Internet, when not related to CBC/Radio-Canada business or without permission from the CBC Technology Department;
Signing up for "instant messaging" or contact services when not related to CBC/Radio-Canada business and without permission from the CBC Technology Department;
Connecting Workstations to CBC/Radio-Canada's Networks without permission from the CBC Technology Department(s) designated by the Vice-President CTO, to manage this function;
Interfering with, removing or bypassing any security features or devices designed to protect CBC/Radio-Canada from IT security attacks such as viruses, hackers, etc.;
CALIFORNIA ISO55
The first page of California ISO's Corporate Information Security Policy contains a table of revision history.
Under the Purpose heading, the policy states:
Information security is the protection of information from a wide range of threats in order to ensure business continuity, minimize business risk, and maximize return on investments and business opportunities. The objective of information security is to reduce the risk to the California ISO and Market Participants by protecting information, information systems and communications that deliver the information, from failures of integrity, confidentiality, and availability, whether information is in storage, processing, or transmission.
The Scope heading indicates that the policy "encompasses all employees, consultants, contractors, vendors as well as third parties who have access to or control of California ISO information." The section goes on to state:
Security controls must be used regardless of:
The media on which the information is stored (including, but not limited to paper, hard drives, diskettes, servers, databases, mobile and hand held devices, transparencies, email systems, voice mail systems, etc.).
The systems that process the information (including, but not limited to workstations, portable PC's, hand held devices, PDAs, servers, email systems, voice mail systems, databases, etc.).
The methods by which the information is moved (including, but not limited to wireless, electronically, telephone, face-to-face conversation, diskette or other removable media, etc.).
The actual section of the policy titled Policy is further broken down into 3 headings: 3.1: Information Classification and Protection, 3.2: Information Protection Roles and Responsibilities and 3.3: Information Systems and Communication Environment. 3.1 directs readers to the Corporate Information Classification Standards and Protection Procedures which identify
"information classification and information that requires enhanced protections under federal and state law, the California ISO Tariff, the California ISO Information Availability Policy, and applicable regulations."
Even though "All California ISO personnel share in the responsibility for protecting information assets" 3.2 defines and describes those groups that have particular responsibilities with regard to the protection of information assets. Those groups are grouped into 3 categories, being Stewards, Managers, and Users.
The California ISO policy also contains sections on Education and Awareness, Risk Assessments, Incident Reporting, Compliance, Contact, and Employee Acknowledgement. The Incident Reporting section goes through the procedures to undertake after the initial notification with respect to a breach, which include investigation, internal review, reporting, recommendations and lastly, corrective action. With respect to compliance measures, the policy indicates that compliance will be monitored regularly and that period internal assessments will be conducted. The policy also outlines possible disciplinary action in the event of non-compliance.
THE SANS INSTITUTE TEMPLATES56
The SANS (SysAdmin, Audit, Network, Security) Institute was established in 1989 as a cooperative research and education organization. The Sans Security Policy Project offers resources for organizations looking to create security policies. The SANS website provides templates for a number of issue-based security policies such as: Workstation Security Policy, Remote Access Policy, Email Retention Policy, Acceptable Use Policy, and Mobile Device Encryption.
Nearly all of the templates contain sections on Purpose, Scope, Policy Enforcement, and Definitions
The Workstation Security Policy provides guidance for workstation security in order to ensure the security of information on the workstation and information the workstation may have access to. It also lists appropriate measures implemented as physical and technical safeguards for all workstations such as storing all sensitivity information on network servers, complying with password policies and procedures, and complying with the Portable Workstation Encryption policy.
The Remote Access Policy defines standards for connecting to networks from any host. The policy attempts to minimize potential exposure to the company from damages which may result from unauthorized use of company resources. Damages include the loss of sensitive or company confidential data, intellectual property, damage to public image, damage to critical company internal systems, etc. The policy lists remote access implementations covered by the policy (dial-in modems, frame relay, ISDN, DSL, VPN, SSH, cable modems, etc).
The Email Retention Policy is intended to help employees determine what information sent or received by email should be retained and for how long. The information covered in these guidelines includes, but is not limited to, information that is either stored or shared via electronic mail or instant messaging technologies. The policy contains a suggested categorization of email information – administrative, fiscal, general, ephemeral – and attaches different retention guidelines for each type.
The Acceptable Use Policy outlines the acceptable uses of computer equipment. It explains why the rules are in place – "inappropriate use exposes [the company] to risks including virus attack, compromise of network systems and services, and legal issues."57 The policy also lists a number of prohibited uses, and included among them is "effecting security breaches or disruptions of network communication."58 The policy sets out examples of confidential information and provides concrete steps to take with respect to that kind of information:
All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature set at 10 minutes or less, or by logging off when the host will be unattended.
WASHINGTON UNIVERSITY IN ST. LOUIS59
The Information Security Policy of Washington University in St. Louis contains a preamble which sets out the components of its comprehensive security plan. It identifies the systems, networks and programs for which security is critical.
This plan identifies key concerns and issues faced by the University community at the application, host, and network level, and strives for a balance between the University's desire to promote and enhance the free exchange of ideas and its need for security of critical information and systems.
The policy identifies the elements of a good security policy: confidentiality, access, accountability, authentication, availability, information technology system and network maintenance. The policy also sets out and defines categories of security to which the policy applies: computer system and applications security, physical security, operational security, procedural security, network security.
Development to develop additional access policies:
Each University controlled information system must have an Access Policy that defines access rights and privileges and protects assets and data from loss or inappropriate disclosure by specifying acceptable use guidelines for users, operations staff and management.
Notification requirements:
If the operations staff believes a security incident has occurred, they will immediately notify their management. Management will assess the potential implications of the incident, notify Network Technology Services, and take any remedial and necessary action. All audit logs will be immediately duplicated and moved to secure media for further analysis.
Reporting requirement:
Owners and managers of school or department computing, network, and applications systems shall make available to management and users of the systems guidelines for reporting security violations. These guidelines will provide specific guidance on what, when, where, to whom, and within what timeframe the violation should be reported and a copy will be filed with Network Technology Services or Computing and Communications.
Footnotes
54. SANS Institute templates provided as part of the SANS Security Policy Project, online: http://www.sans.org/resources/policies/.
55. "Corporate Information Security Policy" California ISO, online: http://www.caiso.com/1c4b/1c4b9e741d2b0.pdf.
56. The SANS Security Policy Project, online: http://www.sans.org/resources/policies/.
57. Infosec Acceptable Use Policy, The SANS Security Policy Project, online: http://www.sans.org/resources/policies/.
58. Ibid.
59. "Information Security Policy" Washington University in St. Louis, online: http://www.wustl.edu/policies/infosecurity.html.
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