CIP Information Protection. Ray Sefchik CISA, CISM, CISSP Manager, CIP Compliance Monitoring February 16, 2015

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1 CIP Information Protection Ray Sefchik CISA, CISM, CISSP Manager, CIP Compliance Monitoring February 16, 2015

2 Agenda Help entities understand and prepare for the upcoming CIP standard Differences and relations to current V3 requirements Overview of Requirements Possible pitfalls to look for while implementing CIP Implementation tips 2

3 CIP General Pitfalls Identify, Assess, and Correct (IAC) FERC conditionally approved CIP on the basis that NERC s Standard Drafting Team make clarifications or remove the IAC language. This occurred in the CIP Version The recent (2/13/2015) NERC filing for approval of CIP has all of the modifications detailed during the development lifecycle BES Cyber System Pay special attention to the applicable BES Cyber Systems in each requirement 3

4 Purpose To prevent unauthorized access to BES Cyber System Information by specifying information protection requirements in support of protecting BES Cyber Systems against compromise that could lead to misoperation or instability in BES 4

5 BES Cyber System Information Information about the BES Cyber System that could be used to gain unauthorized access or pose a security threat to the BES Cyber System NERC glossary 5

6 BES Cyber System Information Includes: Security procedures/information BES Cyber Systems PACS EACMS List of devices with IP addresses Network diagrams 6

7 BES Cyber System Information Does NOT include: Individual pieces of information that by themselves do not pose a threat or could not be used to allow unauthorized access Devices names Individual IP addresses ESP names Policy statements The SDT does not intend that this requirement cover publicly available information, such as vendor manuals that are available via public websites or information that is deemed to be publicly releasable 7

8 CIP Similarities with V3 CIP R4: Information Protection CIP R7: Disposal or Redeployment 8

9 CIP Similarities with V3 CIP R1.1 CIP R1.2 CIP R2.1 CIP R4 CIP R7 CIP R2.2 9

10 CIP R1 - Intro 10

11 CIP R1 CIP R1.1 CIP R1.2 CIP R4 11

12 CIP R1.1 Language No longer a requirement to classify BES cyber system information CIP R1.1 CIP R4 12

13 CIP R1.2 Language Procedures for protecting information must now address storage, transit, and use CIP R1.2 CIP R4 13

14 CIP R1.1 Evidence Documented BES Cyber System Information method How you identify BES Cyber System Information (labels, classification)? Repository or electronic and physical locations to house BES Cyber System Information 14

15 CIP R1.2 Evidence Procedure for protecting BES Cyber System Information Storage Transit Use Records that the information was handled per your procedures Change control ticket 15

16 CIP R1 Possible Pitfalls Information Protection plan does not address storage, transit, and use of BES Cyber System Information Information Protection plan does not consider both digital and hardcopy information Information Protection plan does not consider information that may be stored on Transient Cyber Assets or Removable Media 16

17 CIP R1 Implementation Tips Consider different variables when determining how to properly protect information during transit, storage, and use Digital information stored locally How are you physically protecting hardcopy BES Cyber System Information? In a secured building? In a PSP? What does your program say you will do? Information being held by vendors or accessed by vendors 17

18 CIP R2 18

19 CIP R2.1 Focus is now on preventing unauthorized retrieval instead of data destruction CIP R2.1 CIP R7 19

20 CIP R2.2 Focus is now on preventing unauthorized retrieval instead of data destruction CIP R2.2 CIP R7 20

21 CIP R2.1 Evidence Records of sanitization actions Clearing Purging Destroying Records tracking Encryption Held in PSP 21

22 CIP R2.2 Evidence Records showing media was destroyed prior to disposal Other records of actions taken to prevent unauthorized retrieval of BES Cyber System Information 22

23 CIP Possible Pitfall Entity secures cyber assets no longer used that contain BES cyber system information in a location that is not restricted to only those individuals with access to the BES cyber system information 23

24 CIP R2 Implementation Tips Review NIST SP800-88r1 for guidance on developing media sanitation processes Where possible erase, destroy, degauss, or encrypt data as soon as possible after a device is no longer needed to reduce mishandling of devices or BES cyber system information 24

25 Additional Resources 2/13/2015 NERC Filing to FERC PETITION OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION FOR APPROVAL OF PROPOSED CRITICAL INFRASTRUCTURE PROTECTION RELIABILITY STANDARDS CIP-003-6, CIP-004-6, CIP-006-6, CIP-007-6, CIP-009-6,CIP-010-2, AND CIP NIST SP800-88r1 Guidelines for Media Sanitization NERC Glossary of Terms as of 1/29/2015 Glossary of Terms Used in NERC Reliability Standards 25

26 Questions & Answers Forward Together ReliabilityFirst

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