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1 TrustED Briefing Series: Since 2001, TrustCC has prvided IT audits and security assessments t hundreds f financial institutins thrugh ut the United States. Our TrustED Briefing Series are white papers r checklists t help Banks and Credit Unins cmply with regulatry requirements and IT best practices. Tp 25 IT Cntrls T Audit - June 2011 The cntrls listed belw were extracted frm the typical TrustCC IT Audit General Cmputer Cntrls Audit Prgram. They represent the mst imprtant cntrls fr regulatry cmpliance and IT security. 1. Bard Apprved Plicies Have an Infrmatin Security Plicy: Imprtance f infrmatin The need t prtect it Rles and respnsibilities Reviewed and apprved by management and the Bard (r a sub- cmmittee) 2. Supprting Standards Have Supprting Standards (Specifics): Infrmatin Security BCP Vendr Management Change Management, etc. Bard (r a sub- cmmittee) apprval nt required 3. Acceptable Use Certificate Emplyees & Cntractrs shuld acknwledge, by signing a frm, apprpriate use plicies and practices upn hire and at least nce a year. Security Awareness Training shuld be prvided at least annually. 4. Designated IT Officer A security fficer shuld be designated by the Bard and shuld be primarily respnsible t ensure apprpriate security practices are implemented. Shuld have a primary r secndary reprting relatinship that is independent f IT s risks can be escalated when necessary. 5. Infrmatin Security Risk Assessment Infrmatin Security Risk Assessments shuld: Cpyright 2011 TrustCC Page 1

2 Identify reasnable freseeable threats t infrmatin systems. Assess the likelihd and ptential damage f these threats. Assess the sufficiency f plicies, prcedures, and measures in place t cntrl risks. 6. Change Management All significant changes t hsts and systems shuld be authrized, tested and apprved befre implementatin in t a prductin envirnment. 7. Lgging and Mnitring Servers, firewalls, and select ther devices shuld create audit lg entries fr nn- standard activities and security events. The lg entries shuld be cnslidated fr archival and reprting. The lg entries shuld be regularly reviewed and investigated as apprpriate. 8. Regular Vulnerability Scanning Systems shuld be peridically scanned by vulnerability identificatin sftware, such as Nessus. Vulnerabilities shuld be investigated and remediated. 9. Cmputer Incident Respnse Plan (CIRP) Yu shuld have a dcumented CIRP that identifies key persnnel t participate in an investigatin. The IRP shuld be tested. 10. Independent Vulnerability and Penetratin Testing Yu shuld have Vulnerability and penetratin testing perfrmed by an independent and cmpetent 3rd party. Internal vulnerability and penetratin testing and scial engineering testing shuld be perfrmed annually. External vulnerability testing shuld be perfrmed at least quarterly. 11. Assigning Respnsibilities Patch management shuld be smene s primary respnsibility. Managing anti- virus shuld be smene s primary respnsibility. Reviewing lg/alerts shuld be smene s primary respnsibility. 12. Patch Management All systems shuld be running the mst current Operating System. Patches shuld be applied as sn after release as pssible, generally within 7 t 21 days. Cpyright 2011 TrustCC Page 2

3 13. Certified Systems Deplyed Cnfiguratin standards fr each system type (servers, wrkstatins, laptps, ruters, firewalls) shuld be used t ensure cmpliance. Ideally the standards are expressed as a checklist. Systems shuld be certified as cmpliant with standards at implementatin by having the administratr sign a frm. 14. Stringent Firewall Rules Firewall rules shuld be cnfigured t deny all inbund and utbund packets except thse specifically necessary fr authrized activities. All rules permitting access shuld be as specific and restrictive as pssible. 15. Wireless Netwrking Wireless netwrks shuld be segmented frm the cre netwrk. Prtect wireless with strng WPA2 keys that change at least every six mnths r whenever any ne that knws the key terminates. Ideally, access frm the wireless netwrk t the internal netwrk shuld ccur ver a VPN cnnectin. 16. Authenticatin Passwrds shuld fllw these criteria: 8 characters r mre Changed at least every 45 days Cmplexity Required (upper, lwer, num, special) Lck ut n 4th invalid attempt Users shuld be trained t NEVER share passwrds and t use unique passwrds fr wrk and fr persnal purpses. 17. Business Cntinuity Plan A business cntinuity plan shuld: Include a business impact analysis (see belw) Define recvery strategies fr critical and imprtant systems Reference recvery prcedures Define BCP teams with varying respnsibilities Define testing requirements and methds (see belw) 18. Business Impact Analysis Prir t dcumenting a BCP, a Business Impact Analysis (BIA) shuld be cmpleted. The BIA identifies systems and prcesses that are priritized based n criticality. The BIA shuld include identificatin f threats (natural, human and technical) and their impact and likelihd. Cpyright 2011 TrustCC Page 3

4 The BIA shuld utline system and business prcess dependencies. 19. BCP Testing Regular BCP testing shuld be regularly perfrmed t ensure cntinuity f peratins. Testing types include: Table tp scenari testing Unit - Specific hst recvery testing System - Entire segments f hsts 20. Bard Reprting Reprting t the Bard (r sub- cmmittee) shuld include: IT Plicies IT Strategic Plan GLBA prgram status including the custmer / member infrmatin security risk assessment Business Cntinuity Plan (with DR) and testing results Incident Respnse Plan Vendr Management Prgram Status IT Audit and Security Assessment Findings 21. Encryptin Laptp hard drives shuld be encrypted. Backup tapes shuld be encrypted. File transfers shuld be encrypted. s with sensitive infrmatin shuld be encrypted. 22. Infrmatin Retentin and Dispsal After the apprpriate retentin perid has expired, papers and media with sensitive infrmatin shuld be shredded as a part f the dispsal prcedure. 23. Applicatin Security Applicatins shuld be peridically evaluated fr cmpliance with security standards: Access based upn jb functin Passwrd strength standards Secure cnfiguratin 24. Sftware Licensing Sftware licensing cmpliance prcedures shuld be implemented t ensure nging cmpliance with third- party sftware licensing requirements. A peridic inventry f sftware shuld be perfrmed t ensure cmpliance Cpyright 2011 TrustCC Page 4

5 25. Vendr Oversight Critical vendrs with persistent access t sensitive infrmatin shuld be regularly evaluated fr cmpliance with security standards. Ideally the evaluatin will include a review f an independent attestatin such as a SAS70 (nw SSAE16 SOC 1 and 2) Cntact TrustCC TrustCC wuld lve the pprtunity t cmpete t earn yur business. Every financial institutins needs security and vulnerability testing, why nt get a prpsal frm TrustCC, a leading prvider f such services. The TrustCC apprach is scalable and flexible t address the needs f any cmmunity r reginal financial institutin. TrustCC s standard services include many extras that cst extra with cmpetitrs and TrustCC fees are very cmpetitive. Please Cntact: Tm Schauer, CEO Cpyright 2011 TrustCC Page 5

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