Sarbanes-Oxley Compliance Resource Kit

Understanding and insuring compliance with the Sarbanes-Oxley Act can be a formidable undertaking. It is a complex piece of legislation, and one which demands a serious and planned approach.

However, this need NOT be a daunting task. The Sarbanes-Oxley Compliance Kit is designed specifically to educate, explain, and guide you through the process. It includes a whole series of resources intended to help simplify, and set you on the right path... to help you achieve full compliance as painlessly as possible.

Sarbanes-Oxley Section 404 mandates that:

Enterprises have an enterprise wide security policy;

Enterprises have enterprise wide classification of data for security, risk, and business impact;

Enterprises have security related standards and procedures;

Enterprises have formal security based documentation, auditing, and testing in place;

Enterprise enforce separation of duties; and

Enterprises have policies and procedures in place for Change Management, Help Desk, Service Requests, and changes to applications, policies, and procedures.

To meet these needs the Sarbanes Oxley Compliance Resource Kit, which comes in four editions (Standard, Silver, Gold, and Platinum) contains:

Security Policies (all editions);

Threat & Vulnerability Assessment Tool (all editions);

Business & IT Impact Questionnaire Risk Assessment Tool (all editions);

Safety Program Template (all editions);

Disaster Recovery Template (all editions);

Outsourcing guide update to reflect what you vendors need to do (all editions);

Internet and IT Job Descriptions (Silver, Gold, and Platinum Editions) and;

IT Service Management Template (Platinum Edition) includes:

Service Request Policy and Standard

Help Desk Policy, Procedure, Standard, and Service Level Agreement

Change Control Standard, Quality Assurance Standard, and Management Workbook

Documentation Standard

Version Control Policy and Standard

Sensitive Information Standard

Blog and Personal Web Site Policy

Travel and Off-Site Meetings Security Policy

Internet, e-mail and electronic communication Policy

Security Manual

The plan includes everything needed to customize the Internet and Information Technology Security Manual to fit your specific requirement. The electronic document includes proven written text and examples for your security plan.

Disaster Recovery Plan (DRP)

This Disaster Recovery Plan (DRP) can be used as a template for any enterprise. DRP is sent to you via e-mail in WORD and/or PDF format. Included is a 13 page Business Impact Questionnaire as well as a 3 page Job Description for the Disaster Recovery Manager.

IT Job Descriptions

The Internet and IT Position Descriptions are in Word for Windows format. Includes positions from CIO and CTO to Wireless and Metrics Managers.

The IT Service Management Template

The IT Service Management Template contains policies, standards, procedures and metrics for Change Control, Help Desk and Service Request processing. ITSM template also contains several easy to implement forms and conforms with ITIL.

Practical Guide for IT Outsourcing

The guide is 91 packed pages and includes everything needed to plan for, negotiate, and manage an outsourcing process within an enterprise.

Safety Program Template

Safety Programincludes everything needed to customize the Safety Program to fit your specific requirement. The Safety reflects the latest issues associated with the most recent legislation (Sarbanes Oxley).

CIO and Compliance News

Big brother compliance requirement killed in Hawaii

01/28/2012

Lawmakers in Hawaii on Thursday killed a bill that would have required Internet service providers to collect the detailed browsing histories of Internet users in the state and store the data for at least two years. The bill would have required anyone providing access to the Internet in Hawaii to maintain "consumer records" of every Internet user's subscriber information and data such as the IP addresses, domain names and host names of the sites they visit. It would have covered not only ISPs but also libraries, coffee shops and employers.

One of those opposing the bill was the U.S. Internet Service Provider Association, which earlier this week sent a letter to the committee's chairman. The bill was overbroad, raised a "myriad privacy concerns," and would be hugely expensive to comply with, wrote the ISP association's Executive.
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Disaster Recovery Planning is Required for Business Continuity Planning

01/08/2012

Disaster Recovery Plans are part of a larger, more extensive planning process known as Business Continuity Planning. Disaster Recovery plans should be tested frequently so that the as many individuals as possible are familiar with the specific actions they will need to take when a disaster occurs. Disaster Recovery plans must also be adaptable and updated frequently, e.g. if new people, a new branch office, or new hardware or software are added to an organization they should promptly be incorporated into the organization's disaster recovery plan. Enterprises must consider all these facets of their organization as well as update and practice their plan if they want to maximize their recovery after a disaster.

Disaster Recovery and Business Continuity Planning are the process an organization uses to recover access to their enterprise operations; software, data, and/or hardware that are needed to resume the performance of normal, critical business functions after the event of either a natural disaster or a disaster caused by humans. While Disaster Recovery and Business Continuity plans, or DRPs & BCPs, often focus on bridging the gap where data, software, or hardware have been damaged or lost, one cannot forget the vital element of work force that composes much of any organization. A building fire might predominantly affect vital data storage; whereas a pandemic or epidemic illness is more likely to have an effect on staffing. Both types of disaster need to be considered when creating a Disaster Recovery and Business Continuity Plans. Thus, enterprises should include in their DRPs & BCPs contingencies for how they will cope with the sudden and/or unexpected loss of key personnel as well as how to recover their data.
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Disaster Rcovery Plan First Steps

12/21/2011

Companies of all sizes have realized how critical it is to have a DR plan in place, and many have given top priority to developing one. But organizations need to know that developing a DR plan is not an overnight process but rather something that takes thorough consideration and numerous steps.

Janco's Disaster Recovery - Business Continuity Templated can help get you on the right track with creating a disaster recovery as over 3,000 enterprises around the globe of all sizes already have.

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Public cloud poses a major security risk for CIOs

11/10/2011

Using some clouds like Amazon's EC2 (Elastic Compute Cloud) can pose a security threat to organizations and individuals alike, according to researchers. Some third parties evidently are not following best security practices when using preconfigured virtual machine images available in public catalogs, leaving users and providers open to such risks as unauthorized access, malware infections, and data loss.

The underlying message is that for all the power and opportunity of public clouds, providers and users alike need to approach with caution and embrace best security practices. Cloud infrastructure providers can't be expected to assess the security of every image, bit, and transaction that occurs on their machines any more than an apartment landlord can be responsible for everything that happens within his or her complex -- that is, what tenants do behind closed doors in the spaces they rent.

These vulnerabilities leave users exposed to malware, as well as to unsolicited connections, which malicious hackers could use to gather information about usage and to collect IP target addresses for future attacks through a backdoor.

A malicious hacker could use tools such asextundeleteandWinundelete to recover previously deleted data.

Researchers' stressed the importance of users being properly trained in using public cloud server images. Although public cloud server images are highly useful for organizations, if users are not properly trained, the risk associated with using these images can be quite high. The fact that these machines come pre-installed and pre-configured may communicate the wrong message, i.e., that they can provide an easy-to-use 'shortcut' for users that do not have the skills to configure and setup a complex server. The reality is quite different. Many different security considerations must be taken into account to make sure that a virtual image can be operated securely.
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How to maximize data protection

11/05/2011

The top must-do tasks for maximizing data protection.

Audit Data Access - IT should keep a current list of data business owners and the folders and SharePoint sites under their responsibility. By having this list - at the ready, IT can expedite a number of the previously identified tasks, including verifying permissions revocation and review, and identifying data for archival. The net effect is a marked increase in the accuracy of data entitlement permissions and, therefore, data protection.
Inventory Permissions and Directory Services Group Objects - Effective management of any data set is also impossible without understanding who has access to it. Access controls lists and groups (in Active Directory, LDAP, etc.) are the fundamental protective control mechanism for all unstructured and semi structured data platforms, yet too often IT cannot easily answer fundamental data protection questions like, - Who has access to a data set? and - What data sets does a user or group have access to? Answers to these questions must be accurate and accessible for data protection and management projects to succeed.
Prioritize Which Data Should Be Addressed - While all data should be protected, some data needs to be protected much more urgently than other data. Some data sets have well known owners and well defined processes and controls for their protection, but many others are less understood. With an audit trail, data classification technology, and access control information, organizations can identify active and stale data, data that is considered sensitive, confidential, or internal, and data that is accessible to many people. These data sets should be reviewed and addressed quickly to reduce risk.
Remove Global Access Groups from ACLs (like "Everyone") - especially where sensitive data is located - It is not uncommon for folders on file shares to have access control permissions allowing - Everyone, or all - domain users‖ (nearly Everyone) to access the data contained therein. SharePoint has the same problem (with authenticated users). Exchange has these, as well as - Anonymous User‖ access. This creates a significant security risk; for any data placed in that folder will inherit those - exposed permissions, and those who place data in these wide-open folders may not be aware of the lax access settings. When sensitive data, like credit card information, intellectual property, or HR information are in these folders, the risks can become very significant. Global access to folders, SharePoint sites, and mailboxes should be removed and replaced with rules that give access to the explicit groups that need it.
Identify Data Owners - IT should keep a current list of data business owners and the folders and SharePoint sites under their responsibility. By having this list - at the ready,‖ IT can expedite a number of the previously identified tasks, including verifying permissions revocation and review, and identifying data for archival. The net effect is a marked increase in the accuracy of data entitlement permissions and, therefore, data protection.
Perform Regular Data Entitlement (ACL) Reviews and Revoke Unused and Unwarranted Permissions - Every file and folder on a Windows or UNIX file system, every SharePoint site, and every mailbox and public folder has access controls assigned to it which determine which users can access the data and how (i.e. read, write, execute, list). These controls need to be reviewed on a regular basis and the settings documented so that they can be verified as accurate by data business owners and security policy auditors.
Users with access to data that is not material to their jobs constitute a security risk for organizations. Most users only need access to a small fraction of the data that resides on file servers. It is important to review and then remove or revoke permissions that are unused.
Align Security Groups to Data - Whenever someone is placed in a group, they get file system access to all folders that list the group on its ACL. Unfortunately, organizations have completely lost track of what data folders contain which Active Directory, LDAP, SharePoint or NIS groups. This uncertainty undermines any access control review project, any Role Based Access Control (RBAC) initiative. In Role Based Access Control methodology, each role has a list of associated groups into which the user is placed when they are assigned that role. It is impossible to align the role with the right data if the organization cannot verify to what data a group provides access.
Audit Permissions and Group Membership Changes - Access Control Lists are the fundamental preventive control mechanism in place to protect data from loss, tampering, and exposure. IT requires the ability to capture and report on access control changes to data - especially for highly sensitive folders. If access is incorrectly assigned or changed to a more permissive state without good business reason, IT and the data business owner must be quickly alerted, and be able to execute remediation.
Directory Groups are the primary entities on Access Control Lists (Active Directory, LDAP, NIS, etc.); membership grants access to unstructured data (as well as many applications, VPN gateways, etc.). Servers also have their own - local groups that should be audited. Users are added to existing and newly created groups on a daily basis. Without an audit trail of who is being added and removed from these groups, enforcing access control processes is impossible. Ideally, group membership should be authorized and reviewed by the owner of the data or resource to which the group provides access.
Lock Down, Delete, or Archive Stale, Unused Data - Much of the data contained on unstructured and semi-structured platforms is stale. By archiving stale or unused data to offline storage or deleting it, IT reduces risk that stale data will be accessed by inappropriate parties, and makes the job of managing the remainder simpler and easier while freeing up expensive resources.
Clean Up Legacy Groups and Access Control Artifacts - Unneeded complexity slows down performance and makes mistakes more likely. Organizations create so many groups that they often have as many as they do users - many are empty, unused or redundant. Some groups contain other groups, which contain other groups, with so many levels of nesting (that they sometimes create circular a reference when they contain a group that contains itself). Access control lists often contain references to previously deleted users and groups (also known as - Orphans). These legacy groups and misconfigured access control objects should be identified and remediated.

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Ten commandments of security management

10/27/2011

The ten commandments of security management are:

Limit access to information to those who need to have it -- People can't misuse information that they don't have.

Conduct frequent and deep security audits Identify who has access to what and how their actions could weaken the protection of valuable data/information.

Set limits to information access do not exclude all information from access data exclusion locks down access and limits set authorizations so specific people can do specific things under specific circumstances.

Limit admin to as few individuals as possible -- very few individuals need them to do their jobs.
Ignore organizational hierarch when setting access capabilities access and authorization should be based upon responsibilities, not

position.

Make Security Invisible -- Minimize extra commands, screens, pop-ups for employees; if an action is allowed, just let it happen.

Analyze Security End back doors -- Compliance logs reveal threat patterns, and show how security steps are hurting productivity.

Monitor information access and updates-- User-initiated app updates can invite vulnerabilities.

Educate everyone on security policies and procedures The more that people know about the rules the better

Make security best practices the watch word for everyone -- IT and the general workforce must address the constantly changing nature of security breaches.
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Disaster Recovery Must Do Steps

10/16/2011

The must do things that your company must do to make sure the disaster recovery and business continuity plan will work when they are need are:

Distribute the disaster recovery and business continuity plan or a HandiGuide'® to all decision makers and key operating employees who will need access to it when the event occurs.
Define the chain of command with single leader but do not limit the people who would have to implement the disaster recovery business continuity plan when the event occurs if that leader is unavailable.
Conduct frequent tests and address all areas where shortcomings are found.
Conduct the tests in an unannounced mode
Validated that mission critical data is at sites other than the primary data center
Establish a communication plan that can be implemented after the disaster.

HandiGuide is a Janco Associates registered trademark
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Records Management Policy is Key to e-discovery

10/10/2011

This explosion of electronic communications has opened new and creative ways of conducting business, but it has also created new challenges in the way litigation and investigations are conducted. Since communications and other records relevant to any legal matter are often found in electronic format, the methods for collecting, processing and reviewing potentially relevant evidence has changed. The process of finding, identifying, holding, searching, reviewing, producing and presenting electronic data to be used as evidence in a legal or investigative matter is called electronic discovery, or simply e-discovery.

The scope of an e-discovery effort can include any form of ESI, but the overwhelming majority of e-discovery is performed against email systems and data. In fact, email data has quickly become the de facto standard for prima facie evidence and affirmative defense in litigation or investigative matters. Unfortunately, searching against email systems often results in enormous amounts of data, which must then be processed and reviewed for relevance, typically by paralegals and attorneys who charge by the hour. Therefore, email processing and review is typically the most costly part of an e-discovery project.
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