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Data Privacy in Small and Medium Companies Review and Recommendations

September 7, 2008

Since IT staff has greater access to data than non-IT workers, the impact and risk of data theft committed by IT employees tends to be higher. Data integrity and security must begin with solid data privacy principles and practices designed to improve internal processes and protect the enterprise’s critical information assets.
Some of the recommendations in this research note are better suited for larger enterprises that have the resources to put more stringent controls into place. However, smaller enterprises can also benefit from the compensating controls laid out in this research note.

Topics discussed include:
» How disgruntled IT staff can cause more damage to the enterprise’s data assets than regular line workers.
» The legislative requirements of data privacy and related laws.
» A three-pronged plan of attack for delineating access control, including segregation of duties, least privilege, and identity management software.

Even though perimeter defenses are critical for preventing external attacks, internal threats must be acknowledged and addressed. Align the enterprise’s employee access controls with a privacy mindset to mitigate threats of data loss or theft.

Management Point

Much attention is paid to data security and availability. However, many enterprises are legislated to maintain data privacy. Ensuring privacy means preventing unauthorized IT staff from accessing, modifying, copying, or deleting sensitive information such as credit card numbers, trade secrets, and other critical information assets. Acts of data theft and sabotage perpetrated by insiders is experienced throughout all industries and company sizes, but is one that is not widely reported by affected enterprises unless compelled by law to do so.
Stolen data can cost the enterprise in terms of lost business, loss of shareholder confidence, legal fees, and computer forensic fees. For example, a case of data theft committed by an employee cost two recruiting firms an estimated $3 million between them. There is also the risk of hefty fines if the data theft is a violation of legislative requirements.
IT staff usually has greater access to data, and is thus able to cause more damage if so inclined. Consider this fictitious scenario:
1. Kim is a junior Database Administrator (DBA) responsible for maintaining a financial database. This database is used to disburse checks to customers. Kim requires read-only access to do his job and should not have the ability to actually change customer records.
2. One day, Kim decides that he would like to change a customer record to his own name and address, thereby allowing him to issue checks to himself. Kim then gains access to the database, directly altering the information in a customer record and bypassing controls present at the application layer.
3. Because Kim is accessing the file at the database level, rather than the application level, no audit trail of his action exists. Management is required to sign off on all checks, but because management signs hundreds of checks per day, Kim’s fraudulent actions are not intercepted.
The requirement for management signoff is a perfect example of a ineffective manual control. An auditor would immediately label Kim’s ability to alter customer data – as well as the IT system’s inability to document, log, and audit this occurrence – a material weakness and produce a negative audit result for the enterprise.
In a privacy-focused IT environment, Kim would be blocked from the database in the first place due to rigorous access controls based on segregation of duties or least privilege. Even if Kim does try to access the database, his access rights are configured according to duty segregation policy. The system will therefore log the occurrence automatically, generate an alert, and notify management immediately.
From there, the appropriate actions can be taken against Kim, as per corporate security incident handling policies. This demonstrates how a change in process can transform a weak data privacy control into a preventive and automated mode that is highly effective.

Key Considerations

Addressing the issue of data privacy requires a three-pronged attack:
1. Segregation of duties.
2. Least privilege.
3. Identity management software.
Such an approach helps ensure that duties and areas of responsibility are separated to reduce opportunities for unauthorized or unintentional modification or misuse of the organization’s assets, while the ID management tools enforce policy at the technology level.
Data privacy is called for in governance frameworks such as COBIT and ISO 17799, but is also a requirement of several privacy and fraud-related laws:
» Sarbanes-Oxley (publicly traded companies)
» FISMA (federal government and government contractors) » Basel II (international banks)
» PCI DSS (merchants and credit card service providers) » GLBA (banks and financial services institutions)
» HIPAA (healthcare providers and payment plans)
Segregation of duties is conducted for the purposes of determining who has access to the enterprise’s systems and processes, and where potential conflicts may exist. Conflicts arise when an employee’s job responsibilities overlap into another area, possibly allowing financial fraud to occur. Ensuring proper segregation of duties minimizes these conflicts, enhances data privacy, and creates compliance with Section 404 of Sarbanes-Oxley.
» Segregation of duties is considered a type of internal control. Failure to adequately demonstrate the effectiveness of internal controls could lead to a negative audit outcome. In the case of non- traded companies (i.e. those that aren’t governed by SarbOx), duty segregation should be viewed as a best practice that will improve security and help eliminate conditions wherein employee fraud could transpire.

» But segregation of duties can also be used for IT departments at an operational level to improve error rates and increase reliability. For example, an application development team may have its duties segregated so that code writing, testing, and deployment are each conducted separately by three individuals, thus helping to ensure code integrity.Least privilege, on the other hand, is not a requirement but is considered a security best practice. Least privilege is a principle of security in which IT staff is granted the absolute minimal level of access rights required to complete their duties. Least privilege requires the mapping of access rights to business requirements.
» Intermittent elevation of access rights for IT workers will sometimes be required for a certain project. Still other IT staff will require full access to their machines’ capabilities. Applying least- privilege principles to access policies in general will allow IT to customize security mechanisms according to business needs.
» On the vendor side, Microsoft is currently promoting its Least-Privileged User Account (LUA) concept, which will be supported by the upcoming Vista operating system. The LUA construct acknowledges that new user accounts are set to “Administrator” as the default setting in Windows installations. LUA removes this danger by resetting user accounts to limited access configurations.
Identity (ID) management is a technology component that will be needed to help enforce, automate, and log user activities as they relate to data access and privacy. Identity management is a broad term meaning a system or solution that identifies individuals within the network, and then controls their access to network resources by associating user rights and restrictions with the established identity.
» ID management software typically encompasses a combination of password synchronization/reset/recovery, single sign-on, digital certificates, tokens, and policy-based access management software.
» The main value of ID management is that it eliminates manual user provisioning and access rights processes. In order to achieve this value, focus efforts on automatic process facilitation based on business, IT, and user needs.
» ID management also brings new efficiencies such as fewer calls to the help desk, shorter call resolution time lapses, faster authorization and signoff, and so on.


1. Create and/or amend policies and job descriptions. Policy must drive and direct worker roles, responsibilities, and obligations as they relate to data privacy.
» Non-disclosure and non-competition forms (to protect sensitive data, corporate assets, trade secrets, etc.).
» Systems administrator code of conduct (for establishing a professional code of ethics for IT staff using sensitive data).
» Account privileges and expiry policy (for closing old network IDs, e-mail accounts, etc.).
» Job description templates such as Chief Privacy Officer, Corporate Compliance Officer, IT Controls Auditor, and Security Analyst (to define roles and responsibilities for creating and preserving data privacy).
» Employee manual (encompassing technology acceptable use policies).
2. Apply the principle of least privilege, with caution. Issues with the least privilege approach are twofold. First, least privilege requires the enterprise to plan and test limited access configurations, which can raise costs significantly. Costs may include help desk support, custom programming, additional tools, and changes to policies or procedures. Secondly, some applications will not work properly unless they are operating in administrator mode. This can create productivity issues for power users accustomed to browsing and downloading at will. Furthermore:
» Least privilege must be a component of an effective security model. Some users simply should not have access rights to disable desktop firewalls, delete registry keys, and so on. Security strategy is about taking control and responsibility away from the users and giving them back to the business. From a technology perspective, least privilege means that if users are restricted completely from certain access rights, then those users do not require protection in the form of some type of security software.
» Least privilege involves a shift in focus. Least privilege requires IT management to adopt a mindset that embraces holistic security. For example, acceptable use policies would have to be rewritten to incorporate least privilege values. In-house developers would also have to integrate least privilege into their work.
» User accounts must be appropriately organized. One way to tackle least privilege is to log and monitor data transfer activity throughout the enterprise, and then restrict employees to transferring data from designated folders only. This process can be administered by combining patch management and policy enforcement software.
» Deploying least privilege may cost money, but enforcement is free. File transfers and application usage are traceable using audit trails. Configure the network to look for such activity and log these transactions for auditing purposes. To do this, IT administrators are using free security tools such as Regmon and FileMon from Sysinternals. Regmon monitors applications accessing the Windows Registry, while FileMon monitors and displays file system activity. IT can also deploy a group policy across all domains to prevent all non-administrator accounts from downloading software.
3. Update access rights on a regular basis. Close monitoring of access rights is critical in any enterprise, but is also crucial for proper segregation of duties. Regular auditing and updating of user accounts will ensure that all accounts belong to legitimate account holders and that no former account holders have access rights once they have left the enterprise. Audit all access rights for:
» Company-based desktop and laptop PCs with approved software suites. » IP accounts for e-mail and Web browsing, including intranet.
» Access to shared production server and main shared applications server. » VPN access to the above services.
4. SMEs must deploy compensating controls. ISACA concedes that multiple job roles may be filled by a single person in a small IT shop. Situations such as these should be covered by compensating controls. Compensating controls are used to mitigate risk when appropriate segregation of duties cannot occur due to an SME’s limited resources or smaller IT department size. If this is the case, deploy compensating controls that are considered sufficient and acceptable, such as:
» Audit trails of data transactions (i.e. who initiated them, when, why, and how). » Reconciliation of financial applications.
» Exception reporting and handling oversight at the managerial level.
» Unalterable transaction logs or a journal of all transactions processed. » Supervisory reviews of procedures to detect errors and irregularities. » Independent reviews of procedures to detect errors and irregularities.
5. Create a job duty matrix. For reference on what an IT job matrix should look like, see Exhibit 2.2 in “Segregation Of Duties Within Information Systems” from the Information Systems Audit and Control Association (ISACA). This document will explain how to segregate duties amongst IT staff. Bear in mind that matrices will differ from company to company, depending on the size of the IT department and the enterprise’s level of IT complexity.
» Duty segregation involves isolating, separating, or shifting critical responsibilities or access to systems. Critical responsibilities are defined as any combination of duties that could be used in concert to misappropriate data in such a way that the fraud would go undetected within a certain timeframe.
6. Invest in ID management tools. ID management provides a high level of control redundancy by allowing IT to mitigate data breaches and reduce or eliminate material damage that can result from those breaches. Since compliance is the main watchword for many enterprises, an ID management initiative should have the capability to be audited internally. This will help bring close scrutiny to holes in risk management, as well as hasten regulatory compliance via thorough documentation of security controls.
» An ID management solution can cost anywhere from between $20 and $50 per user, often for a minimum of 1,000 users per year. Implementation can take from six to twelve months to complete, depending on the size of the company.
» ID management vendors include Computer Associates, Courion, HP, IBM, Novell, and RSA Security.
7. Microsoft Active Directory shops should use available tools. Active Directory is a proven method for deploying access rights and role-based access control across the enterprise. In addition, the Group Policy Management Console add-on for Windows Server 2003 performs such tasks as file deployment, application deployment, logon/logoff scripts and startup/shutdown scripts, domain security, IPsec, and so on. Group Policy is available for free to Windows Server shops, and is also being integrated into Microsoft’s Desktop Optimization Pack for Software Assurance.

One Comment leave one →
  1. September 8, 2008 1:34 pm

    Hi. I’d like to clear up some misnomers about Group Policy and what it’s capable of. My name is Jeremy Moskowitz, I’m one of 12 Group Policy MVPs, and I run First, the article implies that you can “deploy a group policy across all domains.” That is not generally accurate, because GPOs do not “flow” between domains. However, they can be added to each domain if desired. Second, there are a LOT of policy settings (about 2400 “regular” settings, about 150 security settings, and countless “preferences”) so even I don’t claim to know all of them. However, nothing off the top of my head will “prevent all non-administrator accounts from downloading software.”

    Next, let’s make sure we really understand the Group Policy Management Console (discussed in the last paragraph) and the relation to what’s built in vs. Microsoft’s new Desktop Optimization Pack for SA.

    The GPMC was born in 2001 as a way to create a “one stop shop” for all GP functions. Functions like creating, deleting, linking and editng. All in one place. The GPMc has traditionally been available for XP and 2003 (when you use them as your management station.) And now, the GPMC is also built-in to Server 2008 and available for Vista (within the Remote Server Admin Toolkit — RSAT tools.)

    Lastly, Group Policy itself is not “beeing integrated in to Microsoft’s Desktop Optimization Pack for Software Assurance.” Rather a tool called AGPM or “Advanced Group Policy Management” is one of 6 tools in MDOP. This particular tool has one goal: put “process” around your GPO deployment. That way, multiple admins won’t be editing the same GPOs. You also get the ability to check out history of deployed GPOs and can rollback if necessary.

    I hope this clears up a lot. For those interested in learning more about GP, please consider joining the free newsletters at

    Thanks. Jeremy Moskowitz, GP MVP

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