ALTA Best Practice Framework Pillar #3 Security And Privacy
ALTA Best Practice Framework Pillar #3 Information Security and Privacy Implementing a Plan to Protect NonͲpublic Personal Information Jeff Foltz, CISO 1 1 2 2 02/2015
Reference Material for Pillar #3 Assessment Preparation Workbook (Excel Spreadsheet) – https://www.youtube.com/watch?feature player embedded&v -2tlpAF-c94 ALTA BestPractices Policy and Procedure Creation Guidance.pdf Best Practices protect NPI.pdf checklist NPI network.pdf Title and Settlement Company BestPractices V 2.0.pdf 3 3 ALTA Best Practices Framework version 2 The ALTA Best Practices Framework has been developed to assist lenders in satisfying their responsibility to manage third party vendors. The ALTA Best Practices Framework is comprised of the following documentation needed by a company electing to implement such a program. 1.ALTA Best Practices Framework: Title Insurance and Settlement Company Best Practices 2.ALTA Best Practices Framework: Assessment Procedures 3.ALTA Best Practices Framework: Certification Package (Package includes 3 Parts) 4 4 02/2015
Networking and the Internet: A brief Synopsis 1962 Information Processing Techniques Office (IPTO) created with Defense Advanced Research Projects Agency (DARPA) with a mandate to interconnect the United States Department of Defense's main computers at Cheyenne Mountain, the Pentagon, and SAC HQ. Goal: connecting separate physical networks to form one logical network that would survive in the event of nuclear war. 1982 (TCPIP) suite created and replaced NCP to enable a global network. The internet was born! The Problem: Security was never built into the original models. Only availability and sustainability! 5 5 Current Threat Landscape Malware Ransomware Mobile Malware Botnets Phishing attacks Spam Advanced Persistent Threats Nation State Threats Hacktvists Geo-Political 6 6 02/2015
Identity Theft Resource Center:2014 Data Breach Category Summary This week's total, of 761 breaches, represents a 25.6 percent increase over the same time period last year (606 breaches). Stats only on entities that provided #’s!!!!! 7 7 Identity Theft Resource Center: 2014 Data Breach Category Summary This week's total, of 761 breaches, represents a 25.6 percent increase over the same time period last year (606breaches). JPMorgan Chase 1 million Staples 1.2 Million Michael’s Stores 2.6 .Million Neiman Marcus 1.1 Million Department of Public Health and Human Services 1 Million Texas Health and Human Services (Xerox) 2 Million Home Depot 56 million IRS 1.4 Million Good Will 800,000 Variable Annuity Life Insurance 774,000 Sony 47,000 8 8 02/2015
RealͲEstate Process: Rife for Identify Theft 9 9 Key Stakeholders for successful Program Information Security – Policy, controls, logistical, Incident Response Physical Security – Policy, Facilities, Monitoring Risk Team – Assess risks and controls Learning / Training Team – Disseminate the information Human Resources – Policy and hiring / Termination practices Legal / Compliance – Laws, regulations Executive Management 10 10 02/2015
ALTA Mission Statement ALTA seeks to guide its membership on best practices to protect consumers, promote quality service, provide for ongoing employee training, and meet legal and market requirements. – These practices are voluntary and designed to help members illustrate to consumers and clients the industry’s professionalism and best practices to help ensure a positive and compliant real estate settlement experience. – These best practices are not intended to encompass all aspects of title or settlement company activity. ALTA is publishing these best practices for the mortgage lending and real estate settlement industry. – ALTA accepts comments from stakeholders as the Association seeks to continually improve these best practices. A formal committee of ALTA members regularly reviews and makes improvements to these best practices, seeking comment on each revision. 11 11 Voluntary or new De Facto standard? "Why is a lender going to allow a noncompliant title agent to close their deals, when you have the opportunity of having somebody who is compliant with the Best Practices close a transaction?" 12 12 02/2015
ALTA Definitions Non-public Personal Information: Personally identifiable data such as information provided by a customer on a form or application, information about a customer’s transactions, or any other information about a customer which is otherwise unavailable to the general public. NPI includes first name or first initial and last name coupled with any of the following: – Social Security Number, – Driver’s license number, – State-issued ID number, – Credit card number, – Debit card number, or – other financial account numbers. – Litmus Test: Can the information be used to conduct identify theft of the individual or entity? – If YES – Then it is considered NPI 13 13 ALTA Definitions Background Check: A background check is the process of compiling and reviewing both confidential and public employment, address, and criminal records of an individual or an organization. Background checks may be limited in geographic scope. This provision and use of these reports are subject to the limitations of federal and state law. Settlement: In some areas called a “closing.” The process of completing a real estate transaction in accordance with written instructions during which deeds, mortgages, leases and other required instruments are executed and/or delivered, an accounting between the parties is made, the funds are disbursed and the appropriate documents are recorded. 14 14 02/2015
ALTA Pillar #3 Best Practice: Adopt and maintain a written privacy and information security program to protect Non-public Personal Information as required by local, state and federal law. Purpose: Federal and state laws (including the Gramm-Leach-Bliley Act) require title companies to develop a written information security program that describes: The procedures they employ to protect Non-public Personal Information. The program must: 1. 2. 3. Be appropriate to the Company’s size and complexity, Include the nature and scope of the Company’s activities, Address the sensitivity of the customer information the Company handles. A Company evaluates and adjusts its program in light of relevant circumstances, including changes in the Company’s business or operations, or the results of security testing and monitoring. 15 15 Safeguarding Basics: CIA Triad NA Confidentiality – To prevent sensitive information from reaching the wrong people, while making sure that the right people can access it Integrity – Maintaining and assuring the accuracy, consistency and trustworthiness of data over its entire life-cycle Availability – The information must be available when it is needed Non-repudiation – Involves associating actions or changes to a unique individual Authentication – Ensure that the data, transactions, communications or documents (electronic or physical) are genuine 16 16 02/2015
Special challenges for the CIA triad: Big data poses extra challenges to the CIA paradigm because of the sheer volume of information that needs to be safe guarded, the multiplicity of sources it comes from and the variety of formats in which it exists. Duplicate data sets and disaster recovery plans can multiply the already high costs. – – Furthermore, because the main concern of big data is collecting and making some kind of useful interpretation of all this information, responsible data oversight is often lacking. Whistleblower Edward Snowden brought that problem to the public forum when he reported on the NSA’s collection of massive volumes of American citizens’ personal data. Internet of Things security (IoT) is also a special challenge because the IoT consists of so many Internet-enabled devices other than computers, which often go unpatched and are often configured with default or weak passwords. Unless adequately protected, IoT things could be used as separate attack vectors or part of a thingbot. In a recent proof-of-concept exploit, for example, researchers demonstrated that a network could be compromised through a Wi-Fi-enabled light bulb. – In December 2013, a researcher discovered that hundreds of thousands of spam emails were being logged through a security gateway. Proofpoint traced the attacks to a botnet made up of 100,000 hacked appliances. 17 17 8 Procedures to meet this best practice: 1) Physical security of Non-public Personal Information. – Restrict access to Non-public Personal Information to authorized employees who have undergone Background Checks at hiring. – Prohibit or control the use of removable media. – Use only secure delivery methods when transmitting Non-public Personal Information. 2) Network security of Non-public Personal Information. – Maintain and secure access to Company information technology – Develop guidelines for the appropriate use of Company information technology. – Ensure secure collection and transmission of Non-public Personal Information. 3) Disposal of Non-public Personal Information. – Federal law requires companies that possess Non-public Personal Information for a business purpose to dispose of such information properly in a manner that protects against unauthorized access to or use of the information. 4) Establish a disaster management plan. 5) Appropriate management and training of employees to help ensure compliance with Company’s information security program. 6) Oversight of service providers to help ensure compliance with a Company’s information security program. – Companies should take reasonable steps to select and retain service providers that are capable of appropriately safeguarding Non-public Personal Information. 7) Audit and oversight procedures to help ensure compliance with Company’s information security program. – Companies should review their privacy and information security procedures to detect the potential for improper disclosure of confidential information. 8) Notification of security breaches to customers and law enforcement. – Companies should post the privacy and information security program on their websites or provide program information directly to customers in another useable form. When a breach is detected, the Company should have a program to inform customers and law enforcement as required by law. 18 18 02/2015
Best Practice Pillar 3 (BP3) Overview of Criteria Questionnaire contains 157 Total questions 1. INFORMATION SECURITY PROGRAM MANAGEMENT 23 2. RISK IDENTIFICATION and ASSESSMENT 11 3. EMPLOYEE TRAINING, MANAGEMENT and RESPONSIBILITIES 11 4. INTERNAL INFORMATION SECURITY 60 5. RETENTION and DESTRUCTION of PERSONAL INFORMATION 8 6. OVERSEEING SERVICE PROVIDERS 22 7. DATA BREACH INCIDENT REPORTING 10 8. BUSINESS CONTINUITY and DISASTER RECOVERY 12 19 19 BP#3 Assessment Instructions 20 20 02/2015
Information Security Glossary Term Definition Authentication Process of identifying an individual, usually based on a username and password, which is a means to determine that individual is who he or she claims to be. Formal process for directing and controlling alterations to the information processing environment (includes alterations to desktop computers, the network, servers and software), with the objective of reducing the risks posed by changes to the information processing environment and improving the stability and reliability of the processing environment as changes are made. A control that reduces the risk that an existing or potential control weakness will result in a failure to meet a control objective (e.g., avoiding misstatements). Compensating controls are ordinarily controls performed to detect, rather than prevent, the original misstatement from occurring. Change Management Compensating Control Control Exception Instances where a control has been intentionally modified (e.g. to enhance functionality) or is not fully implemented. Data Loss Prevention (DLP) Software that is designed to detect potential data breach / data ex-filtration transmissions and prevent them by monitoring, detecting & blocking sensitive data while in-use (endpoint actions), in-motion (network traffic), and at-rest (data storage). The use of mathematical calculations and algorithmic schemes to transform plaintext into cypher text, a form that is nonreadable to unauthorized parties. The recipient of an encrypted message uses a key which triggers the algorithm mechanism to decrypt the data, transforming it to the original plaintext version. Control or controls that: - provide reasonable assurance that material errors will be prevented or timely detected - covers a risk of material misstatement (it is indispensable to cover its control objective) - if it fails, it is highly improbable that other control could detect the control absence - that covers more than one risk or support a whole process execution - must be tested to provide assurance Procedures and/or processes to document acceptance of risk; typically employed when and organization or individual risk owner have determined that the cost of managing a certain type of risk is acceptable, because the risk involved is not adequate enough to warrant the added cost it will take to avoid that risk. SSAE 16, also called Statement on Standards for Attestation Engagements 16, is a regulation created by the Auditing Standards Board (ASB) of the American Institute of Certified Public Accountants (AICPA) for redefining and updating how service companies report on compliance controls. The SSAE 16: - requires the management of the service company to provide a written assertion to the auditor that their description accurately represents their organizational “system.” - is the reporting standard for all service auditors’ reports from June 15th, 2011, and beyond. SSAE 16 was preceded by SAS 70, which had been in effect since April 1992. Encryption Key Control Risk Acceptance Procedures SSAE 16 21 21 INFORMATION SECURITY PROGRAM MANAGEMENT 23 Criteria Corresponding Assessment Procedure Question Response 1Ͳ10 YES Control/ Control/ Procedure Procedure Compliance NOT NOT Documented Documented NO 3.01 1 Does your Company have a written Information Security and Privacy Policy and Program? Does your Company's Information Security and Privacy Policy specifically address the protection of Personal Information? Does your Company conduct background checks on employees and temporary staff who have access to Personal Information? 3.01 2 3.07a 3 3.05 4 Has your Company created an Acceptable Use of Information Technology policy? This policy lays out the ways and circumstances under which employees may use Company owned technology (e.g., acceptable use of the Internet, email, and information resources). 3.06 5 Does your Company have policies and procedures that restrict access to Personal Information to authorized employees (this is called logical access restrictions)? These restrictions can include password protection and should be applied to all systems including network, database, and individual application layers. 3.08a 6 3.07e 7 3.07e 8 3.11b 9 Has your Company created a Clean Desk policy to ensure that files, documents and computer files containing Personal Information are stored in a secure manner when an employee leaves their workstation for the day or an extended period of time? 3.17a 10 Has your Company created a Record Retention and Disposal policy? This policy should set out the minimum amount of time a file should be retained and require appropriate destruction of files. Has your Company created a policy and procedure restricting the use of removable media (e.g., USB ports, CD/DVD writeable drives)? Does your Company require each employee to have a User ID and password for accessing your technology systems? Does the password policy specify that user passwords should not contain common words, user ID, or first/last name? 22 22 02/2015
INFORMATION SECURITY PROGRAM MANAGEMENT Background Checks – What Kind? Criminal? Financial? Acceptable Use Policy – What can and can’t an employee do Removable Media Policy – Is Read Only acceptable? Unique user ID (Non-repudiation) – Generic and default accounts should not be used or monitored closely Clean Desk Policy – Public locations, Cleaning staff, Bonded, etc. Record Retention and Disposal Policy – Both Paper and Electronic – DOD Wipe, Certificate of Destruction, Smartphones 23 23 InSecure Communications Ͳ Email 24 24 02/2015
Secure Communications Ͳ Email Secure Email – Use HTTPS to encrypt – Use TLS (Tunnel Layer Support) Other ways to send – Compress it and password protect it – “Zip and Encrypt” – Password Protect Documents (AES 256) Communicate the password “Out-of-band” – Call the person to share the secret – Use Multi-factor authentication (MFA) – Send the password in a different email (less Secure) 25 25 INFORMATION SECURITY PROGRAM MANAGEMENT Corresponding Assessment Procedure 23 Criteria Question Response 11Ͳ23 YES IS BP IS BP 3.02 IS BP IS BP IS BP 3.01 3.01 3.15a 3.15a 3.15b 3.16 3.16ab Control/ Control/ Procedure Procedure Compliance NOT NOT Documented Documented NO 11 Has the Information Security and Privacy policy been approved by Management or the Board of Directors? Has the Information Security and Privacy policy been communicated and/or made available to all the 12 company's staff and do you require all employees to acknowledge receipt of the policy? Does the Information Security and Privacy Policy emphasize the importance of security and the employees' 13 roles in properly securing data? Has your Company designated one employee (e.g. Privacy Officer) who is responsible for coordinating and overseeing the Information Security and Privacy policy? You may wish to create an Information Security 14 Committee consisting of cross-functional representatives (e.g. Legal, Information Technology, Operations) to assist the Privacy Officer in providing direction and advice on Information Security and Privacy Program. 15 Does your Information Security and Privacy Policy specify penalties for violation of the policy? Does your Information Security and Privacy Policy have procedures for obtaining limited exceptions from 16 the Information Security and Privacy Policy? On an annual basis, does the Privacy Officer or Information Security Committee review the Information 17 Security and Privacy Policy and make updates to reflect changes in operations, legal and regulatory requirements, industry best practices, and available technology? 18 Are changes in the Information Security and Privacy Policy recorded and tracked? 19 Has your Company developed a Customer Privacy Policy to be provided to each customer? 20 Do you track when your Privacy Policy is given to each customer? 21 Does your Privacy Policy touch on all the issues present in the Model Privacy Statement? 22 Does your Company maintain a website? 23 Does your Company website include the Privacy Statement? If so, what personal information is collected? 26 26 02/2015
Tracking Requirements Develop an Exception Tracking Process – Require valid business justifications for exceptions to policy – Review Exceptions on a periodic basis – Evaluate the duration an exception can be considered valid – Do NOT allow for permanent exceptions Typical exceptions can last from 1 month to 1 year. All exceptions should be reviewed annually to have a re-validation or removal from exemption status Track the Privacy policy if required to be provided – Automated approaches should be employed – Ensure that all lines of business are involved so that no oversights occur 27 27 RISK IDENTIFICATION and ASSESSMENT Corresponding Assessment Procedure 11 criteria Question Response YES 3.03 3.03b 3.03a 3.03b 3.04 3.04 3.04a 3.04c IS BP 3.04c IS BP Control/ Control/ Procedure Procedure Compliance NOT NOT Documented Documented NO On a regular basis, does your Company review your operations to identify and assess external and internal risk(s) to the Personal Information your Company stores? This assessment should review the types of 1 Personal Information your company stores, the location of that information and how that information can be accessed by authorized and unauthorized users. Does this risk assessment include thinking through individual internal and external risk and assessing their 2 impact and likelihood? This could include thinking through which non-employees have access to your office and what information is stored in a networked computer, etc. (Threat Modeling) Is this risk assessment performed on all locations, systems, and methods used for storing, processing, transmitting, and disposing of Personal Information? Critical areas for review can include, but are not limited 3 to, employee training and management; information systems, including network and software design; information processing, storage and disposal; detecting, preventing and responding to attacks, intrusions or other system failures. Does your Company account for unique risks presented by employee access to files outside of the office? 4 This should consider the information's sensitivity and how the employee will access the material outside of the office. Are key controls that your Company has in place to prevent improper access of Personal Information 5 identified as part of the risk assessment process? 6 On a regular basis, are these key controls tested by an independent party? (Penetration Tests) 7 Does management review the results of this testing? 8 Are vulnerabilities noted and, where possible, changes made to your systems to reduce the risk? 9 Do you have a procedure for determining which risks cannot currently be addressed? 10 Are risk mitigation activities monitored and tracked? Does the Privacy Officer work with stakeholders, as appropriate, to assess risks to Personal Information 11 associated with information systems, including network and software design, information processing, and the storage, transmission and disposal of Personal Information? 28 28 02/2015
Risk Assessments Measuring Risk – Risk can be determined as a product of threat, vulnerability and asset value Determine the Risk (Traditional approach) Current Risk Management Framework – – Risk Likelihood * Impact Risk ((Vulnerability * threat) / Counter measure) * asset value Choose a Framework – NIST 800 – CoBit – ISO 27000 – ITIL 29 29 EMPLOYEE TRAINING, MANAGEMENT and RESPONSIBILITIES 11 criteria Corresponding Assessment Procedure Question Response YES Control/ Control/ Procedure Procedure Compliance NOT NOT Documented Documented NO Are new employees and temporary contract personnel provided a copy of the Information Security and Privacy Policy as part of the hiring process? Are new employees and temporary contract personnel required to sign an attestation that they have read and understand the Information Security and Privacy Policy and the potential consequences of non-compliance, prior to accessing Personal Information? IS BP 1 3.02 2 IS BP 3 Are new employees and temporary contract personnel provided their responsibilities under the Information Security and Privacy Policy as well as other applicable security policies and procedures, and the potential consequences of noncompliance? 3.05 4 Do employees and temporary contract personnel certify, in writing, their acceptance of the Acceptable Use of Information Technology Assets policy (e.g., acceptable use of the Internet, email, and Company information resources)? 3.05 5 Are employees and temporary contract personnel (as applicable) required to re-certify the Acceptable Use of Information Technology Assets policy (e.g., acceptable use of the Internet, email, and Company information resources) on a periodic basis (at least annually)? 3.02 6 Are new employees provided training regarding the importance of information security and Personal Information during orientation that includes, but is not limited to, the proper use of computer information and passwords, control information and procedures to prevent Personal Information disclosure to unauthorized parties, and methods for proper disposal of documents containing Personal Information? 3.02 7 3.01 8 3.02 9 3.01 10 3.07b 11 Do company supervisors provide temporary workers with training regarding the identification and protection of Personal Information to protect against disclosure to unauthorized parties? Are employees and temporary contract personnel (as applicable) required to repeat Information Security and Personal Information training on a periodic basis (e.g. at least annually)? Is successful completion and refresh of Information Security and Personal Information training tracked and documented? Are training activities and documents modified, as circumstances dictate, based on the risks perceived, scope and types of activities, and access to Personal Information? Does the Company have procedures for termination of employees who violate the Information Security and Privacy Policy? 30 30 02/2015
EMPLOYEE TRAINING 31 31 INTERNAL INFORMATION SECURITY 60 criteria Corresponding Assessment Procedure Question Response 1Ͳ10 YES Control/ Control/ Procedure Procedure Compliance NOT NOT Documented Documented NO 3.11a 1 Does your company have protections in place to prevent unauthorized access to physical files and systems storing or processing Personal Information? 3.11a 2 If you have a data center or server room, is access restricted to only individuals whose access is necessary to perform legitimate business functions? 3.07b 3 3.07d 4 IS BP 5 IS BP 6 Are restricted areas clearly identified with additional security measures (e.g., badge access or locked door) as appropriate to prevent unauthorized access? 3.09b 7 Are security controls (password protection, encryption, etc.) for physical media used to prevent unauthorized access, misuse, or corruption of Personal Information while in transit? 3.09a 8 Is encryption or password protection enabled for electronic media (email, database access, etc.) to protect Personal Information both while in motion (electronic transmission) and at rest (e.g., stored)? IS BP 9 Are employees required to report, immediately, the loss or theft of a laptop or other supported media device to applicable authorities (Information Technology or Privacy Officer)? IS BP 10 If you have badge or key fob access to your offices, are rights revoked upon employment termination? Does your company review physical security requirements on an annual basis? Have you reviewed and incorporated your contractual and legal requirements into your physical security? Is equipment stored offsite and protected in accordance with the data's sensitivity? 32 32 02/2015
Data at rest, Data in motion, Data in Use Data at Rest – On local PC Hard drive – In Data Bases – On Network Shares – On Tape Backups Data in Motion – From PC to Server – From Web browser to Website – From Business 2 Business Data in Use – In PC RAM – In Web Browser Cache 33 33 INTERNAL INFORMATION SECURITY 60 criteria Corresponding Assessment Procedure Question Response 11Ͳ20 YES 3.09 11 IS BP 12 3.04 3.04 13 14 3.09 15 3.10a 16 3.10b 3.07e 3.07e IS BP Control/ Control/ Procedure Procedure Compliance NOT NOT Documented Documented NO Are security controls in place to protect the computer network, which considers the sensitivity of Personal Information? Does the Privacy Officer on a regular basis update systems by, among other things, implementing patches or other software fixes designed to mitigate known security flaws? Are firewalls used to protect all network entry points? Have procedures and security controls been developed and implemented to safeguard network connections? Is a data loss prevention (DLP) tool or other system that monitors, backups, and prevents unauthorized access to electronic files in place to protect Personal Information for all three stages of data (in use, in motion/ transmission and at rest)? Are network intrusion detection and prevention systems (firewall) in place to detect unauthorized intrusions into your network and systems from unknown sources? Are network based intrusion detection and prevention systems configured to detect and log intrusion events 17 and alert appropriate individuals? 18 Are unique user IDs issued to all individuals accessing systems that store or process Personal Information? Are your systems containing Personal Information configured to record the user ID of people who access 19 those files? 20 Do your systems lock or shut down a user's workstation or access after a defined period of inactivity and require a password be re-entered by the user before the session may be resumed? 34 34 02/2015
INTERNAL INFORMATION SECURITY 60 criteria Corresponding Assessment Procedure Question Response 21Ͳ40 YES 3.07d 21 3.10c 3.07e 3.10a 3.10a IS BP 22 23 24 25 26 IS BP 27 IS BP IS BP IS BP IS BP 28 29 30 31 IS BP 32 IS BP IS BP IS BP IS BP IS BP 33 34 35 36 37 3.07c 38 IS BP 3.07e 39 40 Control/ Control/ Procedure Procedure Compliance NOT NOT Documented Documented NO Does your company determine employee access to Personal Information based on the employees job functions and the sensitivity of the information? Is access logging enabled for the Company's critical application and data storage servers? Does your access logging capture important user events (system logon and logoff, data field changes)? Are log files reviewed n a regular basis to detect security breaches Are system audit logs retained to assist in access control monitoring or investigations? Does your access system prevent users from reusing any of their prior six passwords? Does your access system require passwords that are at least six or more alphanumeric and special characters? Does your access system lock out user accounts after five invalid login attempts? Are users required to change th
1.ALTA Best Practices Framework: Title Insurance and Settlement Company Best . 2.ALTA Best Practices Framework: Assessment Procedures 3.ALTA Best Practices Framework: Certification Package (Package includes 3 Parts) 4 4 02/2015. Networking and the Internet: A brief Synopsis † 1962 Information Processing Techniques Office
The ALTA Best Practices Framework has been developed to assist lenders in satisfying their responsibility to manage third party vendors. The ALTA Best Practices Framework is comprised of the following documentation needed by a company electing to implement such a program. 1.ALTA Best Practices Framework: Title Insurance and Settlement .
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When it comes to the ALTA Best Practices Framework, respondents’ opinions were generally positive, with 54 percent viewing ALTA Best Practices as ALTA’s attempt to provide a mechanism for self-regulation, 49 percent believing that ALTA Best Practices are something every settlement professional should follow and 51 percent seeing ALTA
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