Townsend Security Data Privacy Blog

Compliance regulations and security best practices require the encryption of sensitive financial data and the protection of encryption keys with proper key management.  

The financial industry includes banks, credit unions, and other financial organizations, including venture capital firms, private equity firms, investment banks, global investment firms, bank holding companies, mutual funds, exchanges, brokerages, and bank technology service providers, among others. In order to meet compliance regulations, information security programs must be in place to ensure customer information is kept confidential and secure, protected against potential threats or hazards to personal information (cyber-attack, identity theft) and protected against unauthorized access to or use of a customer's personal information. For business owners, database administrators, or developers who need to protect their customers’ sensitive data with encryption; storing the encryption keys within the same database puts that information at risk for a breach.

If you fall within the financial sector, the following will apply:

The Gramm-Leach-Bliley Act (GLBA) - 15 USC 6801 - of 1999 first established a requirement to protect consumer financial information.

TITLE 15 , CHAPTER 94 , SUBCHAPTER I , Sec. 6801. US CODE COLLECTION
Sec. 6801. - Protection of nonpublic personal information

(a) Privacy obligation policy
It is the policy of the Congress that each financial institution has an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers' nonpublic personal information.

(b) Financial institutions safeguards
In furtherance of the policy in subsection (a) of this section, each agency or authority described in section 6805(a) of this title shall establish appropriate standards for the financial institutions subject to their jurisdiction relating to administrative, technical, and physical safeguards.

The Federal Financial Institutions Examination Council (FFIEC) supports the GLBA mission by providing extensive, evolving guidelines for compliance and evaluating financial institutions. Financial services regulations on information security, initiated by the GLBA, require financial institutions in the United States to create an information security program to:

• Ensure the security and confidentiality of customer information
• Protect against any anticipated threats or hazards to the security or integrity of such information
• Protect against unauthorized access to or use of customer information that could result in substantial harm or inconvenience to any customer

Federal Reserve Board Regulations - 12 CFR - CHAPTER II - PART 208 - Appendix D-2
-- Interagency Guidelines Establishing Standards For Safeguarding Customer Information--

… III. Development and Implementation of Information Security Program

… C. Manage and Control Risk

Each bank shall:

… c. Encryption of electronic customer information, including while in transit or in storage on networks or systems to which unauthorized individuals may have access.

Enforcement of these financial industry compliance guidelines fall to five agencies: the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Office of Thrift Supervision (OTS). In collaboration, these agencies have developed a series of handbooks that provide guidance, address significant technology changes and incorporate a risk-based approach for IT practices in the financial industry. The "Information Security Booklet" is one of several that comprise the FFIEC Information Technology Examination Handbooks, and references encryption in detail.

Summary: Financial institutions should employ encryption to mitigate the risk of disclosure or alteration of sensitive information in storage and transit. Encryption implementations should include:

• Encryption strength sufficient to protect the information from disclosure until such time as disclosure poses no material risk
• Effective key management practices
• Robust reliability
• Appropriate protection of the encrypted communications endpoints

To meet the growing need for NIST validated and FIPS 140-2 compliant encryption and key management, the data security experts at Townsend Security provide a certified key management system (Alliance Key Manager) which provides secure key storage and retrieval options for a variety of Enterprise and open source platforms.  Now when nonpublic personal and financial information is collected or stored in a database it can easily be encrypted and the encryption keys properly managed.

To learn more, download the ebook: Encryption Key Management Simplified

Additional Resources:

Federal Financial Institutions Examination Council (FFIEC)

FFIEC Information Technology Examination Handbooks

Gramm-Leach-Bliley Act (GLBA)

Federal Reserve System (FRB)

Federal Deposit Insurance Corporation (FDIC)

National Credit Union Administration (NCUA)

Office of the Comptroller of the Currency (OCC)

Office of Thrift Supervision (OTS)

Two Factor Authentication (2FA) and a look at the compliance regulations that require identity verification for remote access.

The use of two factor authentication provides an added layer of security beyond just a username and password. Because passwords can be guessed, stolen, hacked, or given away, they are a weak layer of security if used alone. Since frequent access happens from outside of the network, remote login is considered high-risk and requires additional steps to confirm user identity. Protecting access with two factor authentication adds identity assurance and significantly reduces risk of unauthorized access in the retail, healthcare, and financial industries.

Payment Card Industry Data Security Standards (PCI DSS)

The PCI Security Standards Council has stated that they will continue to change and evolve compliance regulations over time as attacks change. In PCI DSS section 8.3 the requirement states that organizations must “incorporate two factor authentication for remote access (network-level access originating from outside the network) to the network by employees, administrators, and third parties.”  The objective of this requirement is to ensure that merchants implement strong access control measures so that authorized individuals with network and computer access can be identified, monitored, and traced.

Requirement 8: Assign a unique ID to each person with computer access. Assigning a unique identification (ID) to each person with access ensures that each individual is uniquely accountable for his or her actions. When such accountability is in place, actions taken on critical data and systems are performed by, and can be traced to, known and authorized users.

Note: These requirements are applicable for all accounts, including point-of-sale accounts, with administrative capabilities and all accounts used to view or access cardholder data or to access systems with cardholder data.

Requirement 8.3: Incorporate two factor authentication for remote access (network-level access originating from outside the network) to the network by employees, administrators, and third parties.

Note: Two factor authentication requires that two of the three authentication methods (something you know - something you have - something you are) be used for authentication. Using one factor twice (for example, using two separate passwords) is not considered two factor authentication.

Health Insurance Portability and Accountability Act (HIPAA) and the Health Information Technology for Economic and Clinical Health (HITECH) Act

HIPAA was an act signed in 1996 by President Bill Clinton, meant to improve the efficiency of the healthcare system by encouraging the use of Electronic Data Interchange (EDI) when accessing Protected Health Information (PHI). Covered entities must develop and implement policies and procedures for authorizing PHI access in accordance with the HIPAA Security Rule Administrative Safeguards 164.308(a)(4) [Information Access Management: Access Authorization] and Technical Safeguards 164.312(d) [Person or Entity Authentication] and the HIPAA Privacy Rule at §164.508 [Uses and disclosures for which an authorization is required].

The HIPAA Security Rule requirements have most recently been expanded via the HITECH Act, which establishes mandatory federal security breach reporting requirements with expanded criminal and civil penalties for non-compliance. To remain HIPAA compliant and avoid fines for HITECH Act non-compliance, strict control over access to patient records must be demonstrated.

HIPAA/HITECH requirements regarding the transmission of health-related information include adequate encryption [164.312(e)(2)(ii) when appropriate, and 164.312(a)(2)(iv)], authentication [164.312(d)] or unique user identification [164.312(a)(2)(i)] of communication partners. By selecting Two Factor Authentication (2FA), users would be required to combine something they know, something they have, or something they are; thereby providing more secure access to PHI files. Protected Health Information can be account numbers, medical record numbers and geographic indicators among other private consumer information. It is important that only those health care workforce members who have been trained and have proper authorization are granted access to PHI.

Gramm-Leach-Bliley Act (GLBA) & Federal Financial Institutions Examination Council (FFIEC)

The Federal Financial Institutions Examination Council (FFIEC) is charged with providing specific guidelines for evaluating financial institutions for GLBA (Gramm-Leach-Bliley Act) regulations compliance. The FFIEC also provides guidance around the use of two factor authentication to strengthen systems in the financial industry and strengthen banking websites against financial fraud with the document, “Authentication in an Internet Banking Environment” (v.3). For banks offering internet-based financial services, the guidance document describes enhanced authentication methods that regulators expect banks to use when authenticating the identity of customers using online products and services, as follows:

• Financial institutions offering internet-based products and services to their customers should use effective methods to authenticate the identity of customers using those products and services. Furthermore, the FFIEC considers single-factor authentication (as the only control mechanism) to be inadequate for high-risk transactions involving access to customer information or the movement of funds to other parties.
• The implementation of appropriate authentication methodologies should start with an assessment of the risk posed by the institutions’ Internet banking systems. The authentication techniques employed by the financial institution should be appropriate to the risks associated with those products and services.
• Account fraud and identity theft are frequently the result of single-factor (e.g. ID/password) authentication exploitation.
• Where risk assessments indicate that the use of single factor authentication is inadequate, financial institutions should implement multi-factor authentication, layered security, or other controls reasonably calculated to mitigate those risks.

The FFIEC is a government agency which works with many other government agencies to unify how financial institutions should be supervised. The guideline documents recommend banks treat the FFIEC as baseline compliance for safe online authentication and transaction verification. Since all single factor authentication techniques can be easily compromised, financial institutions should not rely solely on any single control for authorizing high risk transactions, but rather institute a system of layered security with multi-factor authentication.

Although there are varying levels of enforcement, guidelines vs. laws vs. fines, it is clear that two factor authentication plays a critical security role in both compliance and following best practices. This trend will only grow within various industries and throughout the overall data security environment.

Townsend Security offers Easy to Deploy, Cost Effective Two Factor Authentication Solution for the IBM i Platform

Alliance Two Factor Authentication brings mobile SMS and voice verification to the IBM i platform. The solution was built to solve large scale problems in a cost-effective manner and appropriately addresses the concerns raised in the various guidelines and standards listed above. Remote access to networks containing critical payment, patient information, or financial records can be protected with the Alliance 2FA solution using your mobile phone to receive authentication codes.

For more information, request our 2FA Resource Kit! 

Secure system logging on the IBM i (AS/400) can not only help you meet compliance requirements, it can help you stop a data breach before it happens!  Intruders may start with a password hack that gives them access deeper into the system.  There is usually a long trail, visible within system logs. Everything from the original breach can be detected and identified with proper monitoring of the system logs.  What really is driving the need to collect and monitor system logs centers around how often breaches are easily detected with log management.  For example:

• Less than 1% of the breaches were discovered through active log analysis
• Forensics showed 69% of these breaches were detectable via log evidence

PCI Section 10 requires logging for anyone who collects credit card data

Requirement 10:  
 “Track and monitor all access to network resources and cardholder data”

• 10.1 Establish a process for linking all access to system components (especially access done with administrative privileges such as root) to each individual user.
• 10.2 Implement automated audit trails for all system components to reconstruct the following events:
• 10.3 Record at least the following audit trail entries for all system components for each event:
• 10.4 Using time-synchronization technology, synchronize all critical system clocks and times
• 10.5 Secure audit trails so they cannot be altered.
• 10.6 Review logs for all system components at least daily.
• 10.7 Retain audit trail history for at least one year, with a minimum of three months immediately available for analysis.

GLBA / FFIEC recommends data security logs of actions that could affect financial reporting or fraud for financial institutions.

• Network and host activities typically are recorded on the host and sent across the network to a central logging facility.
• The logging facility may process the logging data into a common format. That process is called normalization. Normalized data frequently enables timely and effective log analysis.

(This Link provides more information about FFIEC recommendations for logging)

HIPAA / HITECH ACT requires system logs of access to Protected Health Information (PHI) in the medical sector

• LOG-IN MONITORING (A) - § 164.308(a)(5)(ii)©

…the covered entity must implement: “Procedures for monitoring log-in attempts and reporting discrepancies.”

• Access controls - § 164.312(b)

(section b) Standard: Audit controls. Implement hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use electronic PHI.

There are other compliance regulations and protocols that apply, but they all say about the same thing … you should be collecting system logs, you should be monitoring them, and you should take action based on anomalies that you find in them.  It is not enough to assert that you are doing the right thing; you have to be able to prove it with system logs that are independent from the original system files and verifiable.

System logging is important across all operating systems, but we are going to look at IBM i with greater detail due to it’s complexity.  Because the IBM i system can handle multiple applications, it doesn’t log information like others do.  The IBM i collects logs simultaneously from multiple sources and deal with large volumes: Up to 3,500 events per second…250 Million of events per day!  The essence of good reporting is externalizing the systems logs and collecting them in a central repository which helps remove the risk of tampering. Compliance regulations recognize the need to watch all users – including the most powerful users, because network originated threats to the IBM i are often not noticed or quickly responded to by IT security professionals without close monitoring of system logs.

Creating the QAUDJRN (Security Audit Journal) on the IBM i

QAUDJRN is not created or enabled by default on the IBM i platform.  If you have not set it up, you are not yet collecting system logs.  To implement system logging you create the journal and journal receiver, then set system values that control options about what information is collected. Once the values are set, the collection process begins.  QAUDJRN is non-modifiable and date-stamped and a large amount of useful information can be collected in each event.  However just running system log reports on the security audit journal are not enough. Centralizing events and monitoring them off the IBM i platform are crucial. The events need to be consolidated and correlated in a separate location (usually a SIEM Console) in order to see the whole picture and understand potential attacks on your system.  

Take Away:
If you are properly collecting and monitoring your system logs, you can detect a breach before data is lost.

To delve deeper into this topic, we are sharing this newly recorded webinar in which, security expert Patrick Townsend talks about system logging on the IBM i today and how the capabilities of Alliance LogAgent can provide you with a high performance, affordable solution that will communicate system logs securely between your IBM i and Security Information and Event Management (SIEM) Console.

As always, we welcome your questions and comments posted here!