Using Continuous Monitoring Information Technology to Meet Regulatory Compliance. Presenter: Lily Shue Director, Sunera Consulting, LLC
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1 Using Continuous Monitoring Information Technology to Meet Regulatory Compliance Presenter: Lily Shue Director, Sunera Consulting, LLC
2 Outline Current regulatory requirements in the US Challenges facing financial institutions or organizations maintaining customer information Tools and approaches use to meet the compliance challenges 2
3 Current Regulatory Requirements in the US The Gramm-Leach-Bliley Act (GLBA) of 1999 requires 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 3
4 Current Regulatory Requirements in the US Other Regulatory Requirements Sarbanes Oxley (controls) HIPAA (patients information) FISMA (US Federal Information Security Management) 4
5 What Organizations Must Do to Meet These Challenges? Financial institutions and organizations must Collect and archive cross-platform log data real time Compress logs for efficient long-term storage Simplify search and retrieval of specific logs for analysis and forensic investigations Automatically identify important audit events and alerts appropriate individuals Provide an easier and more affordable way to automate log & event management for compliance file integrity monitoring for compliance 5
6 What Organizations Must Do to Meet These Challenges? Financial institutions and organizations must Maintain an ongoing information security monitoring and risk assessment program to comply with the regulatory requirements Log data collections; review, archival, reporting and alerting of customer non-public-information (NPI) Monitor file integrity Sarbanes Oxley HIPAA FISMA Etc 6
7 What Organizations Must Do to Meet These Challenges? Corporate and IT governance at financial institutions must now extend the continuous monitoring from applications/business processes to: Monitoring and maintaining an inventory of NPI databases/files Monitoring unauthorized access and providing alerts on a real-time basis 7
8 What Organizations Must Do to Meet These Challenges? Systems (in-house developed or acquired) must have: Appropriate security controls Controls to mitigate the risks posed by internal users disclosure or alteration of sensitive information in storage and transit An inventory of all databases/files containing customer nonpublic-information (NPI) Measures to: Monitor access to NPI Monitor and control downloading of NPI outside the institution Implement malicious code prevention 8
9 Why So Difficult? With the current information technologies capabilities, users can now create files and databases containing NPI to meet business requirements It would be next to impossible to manually monitor and maintain an inventory of databases/files containing NPI 9
10 How Organizations Meet These Challenges? Financial Institutions and organizations are implementing automated tools to: Collect, aggregate and maintain all log data from all sources Protect customer information by providing visibility across the entire IT infrastructure to detect, repair and remediate operational issues Collect real-time alerts of violations related to: Compliance mandates unauthorized creation and transferring of files with NPI Security threat identification and suspected intrusion Operational problems Activities taken place inside database servers to ensure data security 10
11 How Organizations Are Meeting These Challenges? Financial Institutions and organizations are implementing automated tools to: Monitor change and configuration management of assets Monitor security controls Monitor updates and reporting Monitor and detect changes or event activity associated with potential security attacks and intrusion s into customer information systems 11
12 How Organizations Meet These Challenges? Automated monitoring tools include: In-house developed applications Third party software vendor tools 12
13 Summary Corporate and IT governance at financial institutions must now extend their continuous monitoring program from applications/business processes to: Monitoring and maintaining an inventory of NPI databases/files Monitoring unauthorized access and providing alerts on a real-time basis Securing all customer NPI IT must implement automated tools to meet the regulatory compliance requirements In house developed tools 3 rd party continuous monitoring tools/software 13
14 Questions? 14
15 Thank You 15
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