HIPAA Security Regulations: Assessing Vendor Capabilities and Negotiating Agreements re: PKI and Security



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HIPAA Security Regulations: Assessing Vendor Capabilities and Negotiating Agreements re: PKI and Security March 2, 2001 Cy D. Ardoin, Ph.D.

2 Agenda Quick View of Security Strategy for Security Quick View of PKI Strategy for PKI

Quick View of Security Range of Attacks 3 Script Kiddy Hacker Industrial Espionage Electronic Warfare Methods Runs tools Good tools Some homegrown Good tools Many homegrown Good tools Most homegrown Motivation Wants to brag about the break-in Anger, Revenge, Profit Profit, Compromise Business, Trade Secrets Profit, Damage Industry, Damage Critical Infrastructure Funding No Funding No Funding Funding proportional to profit potential Funding by foreign government may be proportional to profit Stealth Quick In and Out Stealthy, trying to not be seen Very Stealthy, will not be seen Very Stealthy, will not be seen Avenues Internet mostly, Phone sometimes Internet or Phone Internet, Phone, Social Engineering, Physical, Electronic Internet, Phone, Social Engineering, Physical, Electronic

4 Strategy for Security Establish a Security Program Policy, Procedures, Mechanisms (Security Controls) Assign Authority and Responsibility (Security Officer) Focus on Critical Data (e.g. Medical Records and Financial Data) Train employees and contractors Monitor Activities and Report Problems Periodic Evaluation of the Program Maintain the Security Posture

5 Vendor Capabilities Shop around, meet with three or more vendors Vendor investigation Experience, stability, reputation, independence, etc. More than automated tools - good people are needed Know the methodology to be used Clearly state restriction on behavior and scope of work Penetration tests require protection of both parties Recommendations must be practical Vendors should not play the role of Security Officer

6 Quick View of PKI Public Key Infrastructure Support the implementation of a set of security functions Privacy Non-Repudiation Digital Signatures Authentication Data Integrity

7 Quick View of PKI PKI product vendors Offer several options to implement security functions Entrust VeriSign Xcert Baltimore Netscape

8 Quick View of PKI Certificate Management Functions Key/Certificate Generation Certificate Authority Certificate Format

9 Quick View of PKI Policies and Protocols Security Protocols 60 Hz 50 Hz 220 V Encryption Algorithm 120 V Key Management Policies Key Revocation

10 Strategy for PKI What is the business need for PKI? How do you acquire the services? Major topics to consider in developing a strategy Build or Buy Registration Naming Separate Keys Types of Certificates Tokens Federal PKI and others Number of users

11 Strategy for PKI Develop Requirements as a baseline for vendors Who controls the registration process Who can define the fields in the certificates PKI shall satisfy the Class 3 criteria of the Federal PKI model Define the standards, ITU, IETF, ANSI, PKCS Define the CA requirements CA will support registration, key generation, certificate generation, certificate revocation, certificate renewal, CRL generation and distribution, certificate and RRL archiving, on-demand private key recovery (for encryption keys), certificate and CRL retrieval.

12 Strategy for PKI Specify Algorithms (SHA-1 and PKCS #1 RSA to sign certificates and CRLs) Specify Key Lengths Hierarchy of the PKI (all subscribers fall under a specific subtree of the hierarchy) Certificate generation (X.509 version 3) Define standard certificates (e-mail, encryption, code signing, server, etc) CRL requirements Registration Requirements Archiving Requirements Token Requirements

13 Strategy for PKI Estimate the number of users Get pricing and support data from vendors Compare Vendors to the Baseline Document Develop a PKI Certificate Policy Begin a prototype and staged deployment

14 Don t Forget Interoperability prototype interoperability with other organization Integration PK-enabling applications may be difficult prototype using several vendor products before making a large investment into software development Technical/Usability different environments will have different demands for authentication mechanisms - a single solution for strong authentication will not work in a complex environment

15 A Few References NIST SP 800-12 An Introduction to Computer Security; The NIST Handbook. NIST SP 800-14 Generally Accepted Principals and Practices for Securing Information Technology Systems. NIST SP 800-18 Guide for Developing Security Plans for Information Technology Systems. X.509 Certificate Policy For The Federal Bridge Certification Authority (http://www.cio.gov/docs/fbca_policy_document_1-17-01.htm)

16 Mitretek Systems Cy Ardoin Senior Manager Information Security & Privacy Center 7525 Colshire Drive McLean VA 22102-7400 Phone: 703-610-1946 Fax: 703-610-1699 Email: cy.ardoin@mitretek.org