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A Practical Guide to Security Assessments
6. Is the MSSP’s Security Operations Center (SOC) physically secure? Does
it meet the client’s physical security standards?
Guidance:
The MSSP’s SOC should meet certain physical security stan-
dards. The best way to determine this is to do a walkthrough of the facilities
before signing any contract. If a contract has already been signed, physical
security should be audited as part of a regular audit program. Because of
the nature of the MSSP’s business, the SOC should meet fairly rigorous
standards. To put it into perspective, the MSSP’s SOC is an extension of
the company’s network — if the SOC goes down, so does the company’s
network (potentially). The importance of the MSSP being secure is critical
to the well-being of the company’s network.
Risk:
If the MSSP is not physically secure, a risk exists that the company’s
information assets are not secure.
Client Response:
7. Does the MSSP have a tested business continuity/disaster recovery plan?
Has the company’s own business continuity and disaster recovery plan
been updated to reflect the MSSP?
Guidance:
As part of the initial due diligence effort and the ongoing audit
process, the company should ensure that the MSSP has a tested business
continuity and disaster recovery plan in place. Similar to the earlier ques-
tion about physical security, the SOC’s ability, or lack thereof, to become
operational after a disaster is critical to your company. In addition, the
company’s own business continuity/disaster recovery plan should be up-
dated to reflect that the company is using a MSSP.
Risk:
The risk associated with MSSPs not having a business continuity/di-
saster recovery plan is that the company loses a critical portion of its infor-
mation security infrastructure in the event that the MSSP suffers a disaster.
Client Response:
8. Does the client have any data retention requirements as they relate to the
security data collected by the MSSP? If so, are they addressed in the contract,
and does the MSSP retain the data according to those requirements?
AU1706_book.fm Page 408 Tuesday, August 17, 2004 11:02 AM
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409
Guidance:
When developing a contract with a MSSP, the company should
review its own internal policies to understand the data retention require-
ments and determine whether any of the data collected by the MSSP are
subject to them. For example, companies may have a policy of retaining
security-related log data for potential investigations. As part of the moni-
toring procedures, the company should ensure that data is retained per the
contract. This question should tie into the data retention questionnaire ear-
lier in the book as well as any data retention policy the company might
have. See the Data Classification and Data Retention appendices (Appen-
dices D and E, respectively) for more detailed questions.
Risk:
Without making the appropriate provisions in the LMSSP contract
for retention of data, the company
may not retain key system-related infor-
mation per the company’s internal requirements.
Client Response:
9. What is the financial condition of the MSSP? Does it have enough funds
and future revenues to sustain operations over the long term?
Guidance:
Documented cases exist of MSSPs that have gone bankrupt
and left their customers high and dry. As part of the selection process, it is
absolutely critical to ensure that the MSSP has the ability to sustain itself
financially for at least the duration of the contract and preferably, even fur-
ther out. The MSSP should also be financially stable enough to afford qual-
ity staff and have a good SOC. When assessing financial viability, look for
what type of funding the MSSP has received or, if it is a publicly traded
company, look at its financials, which are available on the Internet. In
addition, look at the management team leading the MSSP and research
what kind of track record they have had with other companies they have
led. The financial situation of a MSSP should be reviewed not only during
initial selection but also on an ongoing basis as part of the audit process.
Risk:
The risk associated with not critically examining the financial con-
dition of a MSSP is that the company may choose a MSSP that is not
financially stable. If the MSSP goes out of business or is forced to cut cor-
ners due to lack of funds, the security posture of the company can be sig-
nificantly weakened.
Client Response:
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A Practical Guide to Security Assessments
10. What measures does the MSSP have in place to ensure that their other
customers do not have access to the company’s data?
Guidance:
Depending on how the MSSP has the service set up, customers
might have some level of access into the Security Operations Center. The
company must ensure that access controls are set up so that one company
cannot see another company’s information — e.g., network addresses,
general IT architecture–related information. The expectation that the com-
pany’s data is kept confidential should be formalized, and confidentiality
of data should be addressed in the contract. This is a more significant issue
if the MSSP has any competitors of the company as customers.
Risk:
The risk associated with inadequate access controls in the MSSP is
that it can lead to unauthorized access to the company’s sensitive information.
Client Response:
11. If the company is subject to any legal or regulatory requirements related
to security, is the MSSP meeting those requirements?
Guidance:
There are new regulatory requirements with security implica-
tions, which must be adhered to. Laws such as the Health Insurance Port-
ability and Accountability Act (HIPAA) and the Gramm–Leach–Bliley Act
(GLBA) have been fully implemented.
As security concerns become more
prevalent, it is likely that other laws and regulations will spring up. The
MSSP should have expertise with regulations and work with the company
to ensure that the MSSP contract and services address these requirements.
It is important to note that ultimately, the company, whether or not it has a
contract with a MSSP, is responsible for ensuring that legal requirements
are met. Therefroe, the company should actively work with the MSSP to
ensure compliance with relevant requirements.
Risk:
The risk associated with the MSSP not addressing legal regulatory
requirements is potential fines for the company as well as potential damage
to the reputation of the company in the event of a security breach.
Client Response:
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Appendix O
411
12. Does the MSSP have information security policies and procedures?
Guidance:
The MSSP should have an information security program with
a foundation of policies and procedures. As part of the due diligence pro-
cess, the company should have asked to see their policies and procedures.
As a follow-on question, the MSSP should be able to answer how it en-
sures compliance with security policies and procedures — i.e., what type
of enforcement takes place. The MSSP should also have a mechanism for
ensuring that its policies and procedures are up to date based on new secu-
rity threats.
Risk:
The MSSP should have a top-notch information security program.
The risk associated with not having one is that the MSSP may have a less
than adequate information security program, which can result in weakened
security for the company.
Client Response:
13. Since the inception of the contract, has any significant turnover occurred
at the MSSP and is there a qualified staff to run the MSSP?
Guidance:
A MSSP is as good as the staff that runs it. No matter how good
the technology, the quality of the staff ultimately determines the quality of
service provided by a MSSP. When determining the quality of staff, some
things to look for include certifications such as the Certified Information
Systems Security Professional (CISSP
)
or specific vendor certifications,
the experience level of the staff, and the management team. Its important
to note that MSSP analysts are not just looking at a monitor and reporting
results; they are conducting security analysis and research, which is one of
the “value adds” of a MSSP. When reviewing the staff credentials, it is also
important to note what type of turnover the MSSP has. A high turnover rate
may indicate problems with the MSSP. Relative to turnovers, it is critical
for the MSSP to have a strong employee termination process to ensure that
employees that leave the MSSP have their access removed. In a MSSP en-
vironment, where the analysts are very tech savvy, risks related to disgrun-
tled employees are very significant. Reviewing the staffing with a MSSP
should be an ongoing process and not something that is just done at the time
of the contract inception.
Risk:
The risk if the MSSP has significant turnover and unqualified staff
is that the company may receive inadequate security services. In addition,
a weak termination process combined with a disgruntled employee can re-
sult in a number of negative impacts for the company.
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A Practical Guide to Security Assessments
Client Response:
14. Has the MSSP had a SAS 70 or some other independent review performed?
What were the results, and were findings addressed?
Guidance:
One way to determine the security posture of the MSSP is to
see if it has been audited or reviewed by a third party. One popular review
is the SAS 70 (Statement of Auditing Standards) which is a standard
developed by the AICPA (American Institute of Certified Public Accoun-
tants). A SAS 70 review looks at the internal controls that a service
organization (in this case, the MSSP) has in place and determines whether
these controls mitigate risk as intended. The SAS 70 is an internationally
recognized standard that only qualified individuals can perform. Only
independent firms with the appropriate credentials can issue a SAS 70
opinion.
Risk:
Not applicable. This question is to determine whether the company
has had an independent review done. A clean SAS 70 report is a favorable
sign for the MSSP.
Client Response:
15. Does the MSSP have a change management policy and procedure and
are they followed?
Guidance:
One of the key information security policies that the MSSP
should have in place is change management. Having this policy in place
and following it indicates that the MSSP is careful about its environment
and that only tested and approved changes are allowed in production.
Risk:
Without proper change management, a risk exists that unauthorized
and untested changes may be introduced into the production environment,
which could result in the MSSP having an unstable environment.
Client Response:
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