As the world continues to be pressured with information security challenges, over the last 12 months, major compliance frameworks have recently been updated or are currently updating. In today’s current climate, incidents and breaches are occurring more frequently, and at a much larger scale. With this in mind, many entities have realized these threats and are beginning to closely analyze the gaps in the current frameworks (HIPAA, ISO 27001:2013, FISMA/NIST 800-53, PCI DSS v3.0). Our number one business goal is to protect any critical assets, so it’s important to understand all of these changes and the impact they have on your organization. The most notable updates have been to the HIPAA, ISO 27001, FISMA, and PCI DSS frameworks.
Why should these updates be important to you? Let’s face it – it’s the new reality. Almost every industry is having the “compliance discussion”. Security threats aren’t just for big companies anymore, and the fines and loss of business can be an unfortunate impact of not being compliant.
Let’s begin with the healthcare industry. The HIPAA law strives to address the protection of patient information. We want to keep information private. That is what we are most after. The Security Rule enables privacy by establishing the approach of how to protect information so privacy can be obtained. Last September, the Omnibus Rule became effective to strengthen the Business Associate requirement. All covered entities are now required to ensure that their Business Associates are HIPAA compliant, and these BA’s can now be held directly responsible by the Department of Health and Human Services for their compliance. Where do you begin in assessing your vendors? Conduct a risk assessment of all vendors and determine which are the most at risk and monitor accordingly.
ISO 27001 can be considered the grandfather of all information security frameworks. Most new publications reference ISO 27001 as a starting point, as this framework is internationally recognized and applicable. The ISO 27001:2013 update provides specific requirements for establishing, implementing, maintaining, and continually improving an information security management system. Your information security management process must be a system that is continually operating and improving based on changing risks. The core change is not revolution, but rather evolution. The standard has been reorganized and more harmonized and has made risk assessment focus a key change to the standard. Requirements for management commitment and preventative action have also be revised, with a greater emphasis on setting the objectives, monitoring performance, and metrics.
The FISMA Act is a set of guidelines for selecting and specifying security controls for information systems that process, store, or transmit Federal information. The Act references that NIST publishes Special Publications as important updates that should be referred to. NIST 800-53 is specifically pointed towards as a reference for how to select controls and what it is that you need to implement for your systems. NIST 800-53 expects the important element of risk assessment to determine which controls apply, to what degree they should be applied, and what areas specifically should be considered.
The payment card industry is probably what we’ve been hearing the most about. With all of the current breaches targeting retailers and service providers, the council has sought out to address the causes of these breaches and strengthen the industry. The Payment Card Industry Data Security Standard (PCI DSS) was developed to encourage and enhance cardholder data security and facilitate the broad adoption of consistent data security measures globally. PCI DSS v3.0 is an update to the security standard, and is available for implementation this year. Compliance with v2.0 is still an option only through January 2015. There were three major updates to the PCI DSS. There is a new Penetration Testing requirement that states an implemented penetration testing plan should be in place to verify that controls are operational and effective. Service Provider responsibilities have also been updated. Since security is a shared responsibility, service providers are now required to include written vendor acknowledgement for each DSS requirement for which they’re responsible. The last major change in PCI DSS v3.0 is in regards to password requirements and the enhanced awareness to ensure password security.
It’s important to ask yourself, which of these frameworks apply to me? Which apply to my vendors? Performing a Risk Assessment can help you determine what is important to you and your organization, allowing you to assess from there. Security is no longer passive. Technology is evolving quickly, along with techniques used by hackers. As the compliance frameworks continue to update, it’s important to understand that security must now be active and always evolving.