Determining whether to fine tune or buy
Once architectural and design decisions have been made, the technical policies, controls and configurations must be set and monitored on existing systems or implemented on new ones.
Here's some good news: For most companies, the lion's share of tools needed to support control objectives for regulatory compliance are already in house. Before investing a single penny in new technology, assess the ability of what you already have.
If there is pressure to purchase a specific technology or vendor solution for compliance work, don't circumvent normal purchasing procedures. Assess every new addition to the compliance architecture with the same comprehensive, strategic approach used throughout the rest of the organization.
Recycle Existing Technology lists tools that most companies own and specifies how the tools can be used as part of the compliance process. As you read the table, think about which of these your company already has in place and whether they are being used in your compliance efforts. If they aren't, can they be? What controls in your company would they support?
While many existing tools can be re-used as part of the compliance process, they may need some tweaking to provide sufficient assurance. A good example of this is the level of data integrity associated with a piece of data. Simple Network Management Protocol (SNMP) is used to exchange management information between network devices. SNMP traps send audit and alert information to centralized network management systems. One problem is that versions 1 and 2 of SNMP don't provide a method for authentication, and the data is not protected in transit. If the SNMP data is being used to manage or report on critical network devices, an upgrade to SNMPv3 with security enhancements is in order.
Firewalls and perimeter devices are another example of tools that could need tweaking to meet compliance objectives. If a company decides a prudent compliance decision is to restrict access to a certain server or database, the firewall or gateway in front of that device could have a new rule, narrowing access to only an approved set of IP addresses or users. Or a content filtering gateway may be configured to block data, such as personal health information, that has been classified as not-for-export during the compliance work.
Something that often catches people off guard is the need to increase storage when there's an increase in logging. To keep log files to a reasonable size, assess in advance what information really has to be logged for compliance. Do all alerts need to be recorded, even if they are duplicates that could be aggregated? If not, trim the log file to only critical information and create a robust backup plan that supports search and retrieval requirements. Many auditors have time limits for presentation of data; if you can't find the correct supporting data in time, it makes little sense to store it in the first place.
While some tools can be tuned, others may need intense customization, or could even justify a new purchase.
Case in point: portals. These tools display centralized views, or network system health or compliance status. Some vendors provide overlay reports that purport to show the company's current compliance level to a variety of the regulations, such as HIPAA, SOX and GLBA. Compliance dashboards are certainly appealing in theory, but in practice they can fall far short of the business mark. Approach dashboards with caution.
If you are planning to use a vendor-supplied template, ask the vendor how the compliance policies were created and how easy it is to customize them. Because the regulations aren't prescriptive, most vendors use one of the control frameworks as a baseline for the compliance templates. They may even augment the template with information from lawyers, auditors and customers. These templates can be a great guide, but don't rely on them out of the box. They will need additional tuning from your IT and security staff.
If the tuning work isn't done upfront, dashboards can quickly become "garbage in/garbage out." Consider a database that stores personal health information and has the admin account password set to the default. If the admin account password setting isn't being monitored by the compliance dashboard, the slick-looking graphic may indicate an all-clear for HIPAA compliance but an auditor won't.
A final thought on compliance dashboards: Make sure resources have been assigned to monitor and maintain the dashboard long-term. There's no sense in spending valuable time to customize a portal only to have the critical log and alert data be ignored.
If your existing infrastructure cannot be tuned to help with compliance, your alternative is to buy a solution. Using products to automate portions of the compliance life cycle, such as system configuration, verification and reporting, helps IT get the job done efficiently. Tools are an essential part of the compliance process, but they must be configured and managed according to sound corporate risk management decisions; without them, the process would be far more costly and labor intensive. While these products won't solve all your compliance problems, they can help make the ongoing process more sustainable and effective.
Unfortunately, there is no quick fix when it comes to compliance. But if you approach it carefully by creating and laying out the policies, and determining what you have and what you can re-use, you'll meet an audit with success without breaking the bank.