Cyber Essentials: Why your organisation should 'Get Badged'! Title VI-404576-TM Version Author Issue Date 1 Michael Shuff 29 Jan 2015 Cyber Essentials: Why your organisation should 'Get Badged'! Page 1 Summary Cyber Essentials is a UK Government initiative launched in June 2014 with industry backing. It allows companies to gain one of two available Cyber Essentials badges. Certification became mandatory from October 2014 onwards to be eligible for certain UK Government contracts. There are five technical controls stipulated in Cyber Essentials Requirements: 1. Boundary firewalls and internet gateways 2. Secure configuration 3. Access control 4. Malware protection 5. Patch management This white paper explains the reasoning behind Cyber Essentials and answers the question: Should my company become badged? Contents 1 2 3 4 5 6 Introduction ..................................................................................................................................... 2 What is the Cyber Essentials Scheme - and will Business buy in? ................................................... 3 2.1 How does the scheme operate? Is it a 'Standards framework'? ............................................. 3 2.2 What is the Government's purpose in fostering Cyber Essentials? ........................................ 3 2.3 Why is the UK Government promoting 'cyber security assurance'? ....................................... 4 2.4 So what is wrong with ISO27001 when setting higher standards? ......................................... 5 2.5 Does Cyber Essentials involve any form of Risk Assessment?................................................. 5 2.6 Why do we need Cyber Essentials if ISO27001 is an option?.................................................. 6 2.7 What types of cyber threat does Cyber Essentials hope to combat? ..................................... 7 Technical Requirements for Basic Protection from Cyber Attack ................................................... 8 Cyber Essentials Controls: what they are, and what they're not! ................................................... 9 4.1 'Control Themes' presented in the Cyber Essentials Requirements ..................................... 10 4.2 Secure configuration and User access control ...................................................................... 11 4.3 Malware protection and Patch management ....................................................................... 15 How does Cyber Essentials deal with cloud service provision?..................................................... 18 5.1 Who will test cloud services for compliance with Cyber Essentials? .................................... 18 Conclusions .................................................................................................................................... 19 1 Introduction In 2014, the UK Government launched an initiative to improve cyber security by encouraging companies doing business in the UK to acquire a "badge" proving they met security requirements. There are two levels of badge: "Cyber Essentials" and "Cyber Essentials Plus". A badge is good for one year, and an external certifying body independently awards certificates. The cost of certification is modest: not more than £400 for the basic level and Page 2 around £3,000 for the Plus level. This white paper looks at the scheme and asks whether there is value in certification. The paper considers why the UK Government did not re-use an existing information security standard such as ISO/IEC 27001. Finally, with the increasing popularity of the Cloud, the paper asks whether Cyber Essentials is appropriate for assuring the IT security of cloud-based applications. 2 What is the Cyber Essentials Scheme - and will Business buy in? The Jury is assembling. What will businesses make of the Government's ideas on cyber security controls, and is Cyber Essentials worth the cost? The UK Government's Cyber Essentials Scheme announced in April 2014 aims to drive awareness of the risks posed by cybercrime, and help smaller enterprises delivering products or services to the UK public sector to defend their IT systems, networks and customers' data from attacks. Government is widely encouraging its adoption and has made it mandatory for Central Government contracts advertised after 1 October 2014 which feature characteristics involving handling of personal information and provision of certain ICT products and services. Details are set out in Annex A of the HMG Procurement Policy Note – Use of Cyber Essentials Scheme certification. Action Note 09/14 25 September 2014 2.1 How does the scheme operate? Is it a 'Standards framework'? Briefly, no. Government has developed the Cyber Essentials Scheme with industry to provide a clear statement of the basic technical controls that all organisations should implement to mitigate the risk from common internet based threats. However, and despite words to the effect that it would be a "kite-marked" standard, Cyber Essentials is a Scheme and definitely not a British Standard (BS). The scheme's requirements fall within the context of the Government’s 10 Steps to Cyber Security. The documentation so far produced by BIS maps the five Cyber Essentials controls to controls in the ISO27001, ISAME and ISF Standards. The British Standards Institution (BSI) have collaborated on the project (at least in the early stages), as has CREST, who (in their own words) "...were engaged by CESG, the Information Security arm of GCHQ, to develop an assessment framework to support the scheme, which forms a key deliverable of this strategy". Hence, based on the credibility of the various partner organisations, we can assume that the Assurance Framework will offer, as BIS suggests "a mechanism for organisations to demonstrate to customers, investors, insurers and others that they have taken these essential precautions". 2.2 What is the Government's purpose in fostering Cyber Essentials? To begin, more or less, at the beginning. In 2011, the UK Government launched The UK Cyber Security Strategy - 'Protecting and promoting the UK in a digital world'. The strategy stated the Government's declared aim to improve the information available to people buying security products by encouraging the development of [sic erat scriptum] security ‘kitemarks’. Page 3 BIS was tasked to work with domestic, European and global and commercial standards organisations to stimulate the development of industry-led standards and guidance. This would help customers to navigate the market and differentiate companies with appropriate levels of protection and good cyber security products. Action 24 stated the aim: Action 24: Encourage industry-led standards and guidance that are readily used and understood, and that help companies who are good at security make that a selling point. Fast forward three years: then Universities and Science Minister, David Willetts, said at the launch of the Cyber Essentials Scheme in June 2014: "Cyber Essentials is an easy to use cost effective way to help businesses and the public sector protect themselves against the risks of operating online. ... Organisations will now be able to easily demonstrate they are cyber safe - reassuring their clients, boosting confidence and profitability. I encourage all organisations to adopt it." However, by the time of the launch hosted by the ICAEW IT Faculty at Chartered Accountants’ Hall in the City of London, Cyber Essentials was less of a 'standards framework' in the sense of ISO27001, and more an MOT test for cyber security hygiene. Gone was any reference to the "kite-marked" cyber security standards concept heralded in the 2011 Strategy. What remained was the idea that the cyber security control requirements would be 'readily used and understood' and that they would be a selling point for organisations that are good at putting in place effective security. This is the Cyber Essentials Scheme; aptly named since the mandated controls are essential to secure any IT system connected to the Internet. 2.3 Why is the UK Government promoting 'cyber security assurance'? The Government ICT Strategy also sets out how Government is working to make its own critical data and systems secure and resilient from cyber threat. This is important in understanding what is, I suggest, the primary motivation for introducing the Cyber Essentials Scheme and why it is important for the organisations supplying government to take notice. Government is working with industry to develop rigorous cyber security and IA standards for ICT products and services supplied to Government and its Public Services Network. In particular, they are in the process of raising the standard of cyber security that Government can expect from suppliers for sensitive defence equipment. Just as they already have in place certain requirements on contractors’ physical security, the growth of services supplied to Government that use the internet now means that it makes sense for them to look again at their cyber security requirements. It is worth bearing in mind here that, these days, some of the companies providing services to Government are frankly tiny compared say to the Big Four professional services firms or the likes of Capita, Serco and G4S. They include organisations that qualify for membership of the Federation of Small Businesses, classified in the business size categories of micro: 0-9 employees, small: 10-49 employees, and medium: 50-249 employees. Then there is the issue of the patchy uptake of ISO27001 and other information security standards by large organisations that would already be expected to have some knowledge or experience of Page 4 cyber security. Just like their smaller counterparts, and despite the risks that they run, many it seems have only a limited capability to implement the full range of controls necessary to achieve robust cyber protection. The Cyber Security Strategy talks about modelling best practice on cyber security in reference to Government's own ICT systems, in an effort to set strong standards among suppliers to government to ensure they "raise the bar". 2.4 So what is wrong with ISO27001 when setting higher standards? ISO27001 is seen as too complicated and costly for smaller organisations and, judging by the level of uptake, and resisted by too many large organisations to be a realistic alternative to Cyber Essentials. The simple piece of evidence for this assumption is that there were only 1,923 accredited certificates issued to ISO27001 in the UK in 2013 from a total of 22,293 worldwide. However, at the start of 2014, there were 5.2 million businesses in the UK with small firms accounting for 99.3 per cent of all private sector businesses. ISO27001 has been around for 10 years and its predecessor, BS 7799 was published by BSI Group back in 1995. From a politician's viewpoint, this standard doesn't appear to be popular with the majority of organisations - certainly when compared to ISO 9001 with a respectable 44,985 certificates in the UK, and 1,129,446 globally. Some would argue that ISO 9001 has been around a lot longer, hence the number of certificates issued to date is markedly higher than ISO 27001. ISO 9000 was first published in 1987. It was based on the BS 5750 series of standards, once again, from BSI, that were proposed to ISO in 1979. Even so, if annual growth rates for ISO 27001 stick around the 14% mark, as was the case in 2013, it will be 20+ years before ISO 27001 achieves a third of the certificates issued to the ISO 9001 Standard on a global basis. Cyber criminals are not going to wait around while this process continues. As far as basic hygiene goes, I agree with the Government and GCHQ: businesses need a steer in terms of IT controls and penetration testing - and they need it now, before the damage done by cyber threats worsens. With Cyber Essentials, any fears over certification costs are not justified. For example, ISAME Consortium is offering a self-assessment route to certification against the Cyber Essentials Scheme costing only £300 +VAT. The price is right for smaller organisations with limited budgets for cyber security - assuming they are serious about bidding for Government work. Of course, meeting the scheme's requirements may cost them a lot more. Then so would a data breach resulting from inadequate cyber security! 2.5 Does Cyber Essentials involve any form of Risk Assessment? A question that I posed to BIS and GCHQ at the ISO27001 User Group in August this year. The short answer was "We're doing that bit for you". The slightly longer but no less controversial answer would appear to be: "Risk management is the fundamental starting point for organisations to take action to protect their information. However, Page 5 given the nature of the threat, Government believes that action should begin with a core set of security controls that all organisations – large and small – should implement. Cyber Essentials defines what these controls are." [From the Cyber Essentials Scheme, Summary, June 2014, Addressing the Threat, page 3]. So, no requirement for a risk assessment. However, is that good news? Should we care that Government is stepping in to define what 'core security' should be like in your organisation (assuming that you do some business with Government and want to continue doing so in the future)? Moreover, is the 'cyber threat' serious enough to justify a Government Scheme? Leaving aside the Media hype, I would recommend that you read Sir Iain Lobban, then Director GCHQ, who contributed a thought-provoking article entitled "Countering the cyber threat to business" to the Spring 2013 edition of the Institute of Directors Big Picture policy journal. Sir Iain outlines for a business audience in non-technical terms the nature and scale of the threat to businesses from cyberspace, why cyber security should be at the top of boards' agendas and the role GCHQ is playing in helping counter the threats. You can read the full article in the Spring 2013 back issue of Big Picture. Just follow the link on the IoD's website: http://www.iod.com/influencing/big-picture/big-picture-archive/big-picture-spring-2013 In my view, the Cyber Essentials Scheme is long overdue. It is only designed to be a voluntary undertaking for most organisations unless they fall within the categories listed in Annex A of the Policy document (see above). Hence, it is unlikely to be taken as seriously as it should be by the Boards of the UK's smaller enterprises, many of whom assume that they are too small to attract the interest of professional cyber criminals. They miss the point that they can be a gateway to confidential data held on their clients' computer systems. In addition, a great deal of today's automated hacking software randomly identifies system vulnerabilities by attempting an intrusion via the Internet and then exploiting IT security weaknesses. The fact that few people have spotted your physical office address or that your company website attracts low numbers of visitors does not make you safe. Rather, the opposite is generally true, because your sense of security is completely false; therefore: your cyber risk assessment processes and mitigation measures are likely to be equally unrealistic when it comes to understanding the nature of the threats posed to data on your systems. 2.6 Why do we need Cyber Essentials if ISO27001 is an option? In simple terms: not enough organisations are ISO 27001 certified, and, theoretically, the management system framework - however valuable - allows organisations to opt out of controls specified in Cyber Essentials. Page 6 In practice, few if any organisations adopting ISO 27001 would be foolhardy enough to choose a control set that does not cover the fundamental technical issues relating to internet security in particular; however, that is a story for another day. Cyber Essentials is here to stay. As stated, the UK Government clearly believes that ISO 27001 is simply too big and unwieldy a Standard for most organisations to invest in accredited certification. In my experience, the fear factor regarding ISO 27001 adoption, especially when it comes to the risk assessment aspect and the selection of suitable information security controls, is not justified when the right expert help is available. However, the basic technical control set defined in the Cyber Essentials Scheme does fill an important 'gap in the market'; enabling organisations, particularly SMEs, to understand and properly address the most important technical aspects of cyber security protection. It also fits nicely into IASME’s wider governance approach to information assurance for smaller organisations. About which, more later. Even then of course, small organisations under 50 employees (including single employee businesses), and even some medium-sized organisations, may need to obtain further guidance and support to ensure the technical controls presented in these requirements can be implemented adequately. 2.7 What types of cyber threat does Cyber Essentials hope to combat? Cyber Essentials focuses on basic cyber hygiene. The theory is: your organisation will be better protected from the most common cyber threats if you have a set of controls which, when properly implemented, comply with the scheme's requirements. These controls will provide organisations with protection from the most prevalent threats coming from the Internet. In particular, those resulting from malware and hacking strategies which require low levels of attacker skill, and which are widely available online. The Scheme has two progressive levels: “Cyber Essentials” is an independently validated selfassessment submission, whilst “Cyber Essentials Plus” additionally requires a comprehensive, independent technical assessment to validate that the selected security controls have been implemented effectively. Cyber Essentials is FREE to download and any organisation can use the guidance to implement the five essential security controls, but some may want or need to gain independent assurance that they have fully deployed the controls. Organisations that have been successfully independently assessed or tested through the scheme’s assurance framework will attain a Cyber Essentials certification badge. This will help you demonstrate to customers, partners or clients that your company takes cyber security seriously - boosting reputations and providing a competitive selling point. Therefore, to sum up this introduction to the Cyber Essentials Scheme: Cyber Essentials is relatively inexpensive compared to implementing ISO 27001:2013 and does have significant attractive features for SMEs. The most obvious being that not all of your competitors in a particular market sector will be certified Cyber Essentials compliant and displaying the distinctive badge. Those who do are saying that they are good at protecting client data at least at a basic level make that a selling point. Page 7 Cyber Essentials offers a sound foundation of basic hygiene measures that all types of organisations in the UK can implement and potentially build upon. Government believes that implementing these measures can significantly reduce an organisation's vulnerability. However, it does not offer a silver bullet to remove all cyber security risk; for example, it is not designed to address the more advanced, targeted attacks and hence organisations facing these threats will need to implement additional measures as part of their security strategy. What Cyber Essentials does do is define a focused set of controls that will provide cost-effective, basic cyber security for organisations of all sizes. As such, it has value. 3 Technical Requirements for Basic Protection from Cyber Attack Standardised approaches to cyber security will be a feature of the IT world in 2015 and beyond. There is simply too much cybercrime activity on the internet that traces back to organised gangs and rogue Governments opposed to Western economic and geo-political dominance to ignore the problem; even if red tape and tick boxes are not what the 'deregulators' say they want. However, of course, by May 2015 we may be seeing an even tougher line emerging as UK politicians across the parties spot the potential in messages that reflect the ordinary citizens' concerns about data leaks and phishing scams. Criminal gangs today are trading personal identities wholesale. The pendulum in America is swinging in favour of standards frameworks. On December 5, 2014, the National Institute of Standards and Technology (NIST, part of the U.S. Commerce Department) issued an update to its Framework for Improving Critical Infrastructure Cybersecurity. Since then, the growing consensus among industry regulators and U.S. lawyers is that the Framework is becoming the de facto standard for private sector cyber security as viewed [Source: 'CIOs Ignore the NIST Cybersecurity Framework at Their Own Peril', Wall Street Journal: CIO Journal: December 18, 2014]. Cyber Essentials will go partway to addressing the cyber threats tackled by the framework; but will the five technical Requirements of the UK scheme be sufficient to protect confidential data? Perhaps more importantly, if the UK Government rejects ISO27001:2013, shouldn't they be aiming higher than a low-cost Scheme designed only to address phishing attacks using malware infection and hacking attacks that exploit known vulnerabilities in Internet connected servers and devices? The answer, I suggest, could well be a simple 'yes'. However, politically it is difficult (impossible?) to force the adoption of complex and often costly standards-based approaches in what is a fragile economic recovery phase. One suspects though the U.S.A. and Europe will legislate by next decade to compel standardisation and compliance through certification. Watch this space! Mandatory standardisation is what has happened in India. Under Sec 43A, the ITA (Information Technology Act) defines what “Sensitive Personal Information” is; and the “Reasonable Security Practice” that a company should follow to protect it. The current phrasing can easily be interpreted to make adopting ISO 27001 a matter of legal compliance. While sub-rule 2 does allow for use of an alternate ISMS that meets the requirements, 'reasonable' security practices involve the use of a standards framework. Page 8 The UK Data Protection Act says that: "Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data." UK Law has yet to define exactly what the "appropriate" measures are, but one suspects that future EU Regulations will do this in a similar way to India's ITA with reference to Standards. At the moment, the Data Protection Act, made law way back in 1998 (since which time, a great deal has changed in terms of technology and culture), means you must have appropriate security to prevent the personal data you hold being accidentally or deliberately compromised. In particular, you will need to: design and organise your security to fit the nature of the personal data you hold and the harm that may result from a security breach; be clear about who in your organisation is responsible for ensuring information security; make sure you have the right physical and technical security, backed up by robust policies and procedures and reliable, well-trained staff; and be ready to respond to any breach of security swiftly and effectively. At this point, the observant among you will have spotted that the Cyber Essentials control themes fall far short of these DPA requirements as defined by the Information Commissioner. Therefore, we must recognise from the outset that whatever value Cyber Essentials Requirements bring to the party, the existing requirements of UK Law mean that organisations must address other information security requirements to comply with the Law. So what will Cyber Essentials provide you with in terms of a control set? And is it worth relying on in place of a more comprehensive cyber security or information security standard like the NIST Framework or ISO 27001? 4 Cyber Essentials Controls: what they are, and what they're not! Cyber Essentials might not stop a determined cyber-attack emanating from a rogue state, but it can help to prevent your organisation being a soft target when it comes to automated hacking tools and opportunists. The Cyber Essentials Scheme is designed to assist every UK organisation in defending against "the most common forms of cyber-attack emanating from the internet using widely accessible tools which require little skill from the attackers". Firstly, specific types of attack are identified and secondly the most basic technical controls an organisation needs to have in place are described. OK. What are the basic technical measures that the Scheme promotes? The control themes set out in the Cyber Essential Requirements document are relevant to organisations of all sizes. The "exposed technology" is familiar to us all: i.e. computers that are Page 9 capable of connecting to the internet, including desktop PCs, laptops, tablets and smartphones, and internet connected servers including email, web and application servers. The Government (almost certainly through evidence presented by the police and the secret work of GCHQ and other national defence agencies?) has developed a detailed knowledge of the basic but successful cyber-attacks against UK businesses and citizens of which, the large majority would have been mitigated by full implementation of the controls under the following, selected categories. 4.1 'Control Themes' presented in the Cyber Essentials Requirements To mitigate the threats identified in the Government's research, Cyber Essentials requires implementation of the following controls for basic technical cyber protection: Boundary firewalls and internet gateways Objectives Information, applications and computers within the organisation’s internal networks should be protected against unauthorised access and disclosure from the internet, using boundary firewalls, internet gateways or equivalent network devices. One or more firewalls (or equivalent network device) should be installed on the boundary of the organisation’s internal network(s). As a minimum: 1. The default administrative password for any firewall (or equivalent network device) should be changed to an alternative, strong password. 2. Each rule that allows network traffic to pass through the firewall (e.g. each service on a computer that is accessible through the boundary firewall) should be subject to approval by an authorised individual and documented (including an explanation of business need). 3. Unapproved services, or services that are typically vulnerable to attack (such as Server Message Block (SMB), NetBIOS, tftp, RPC, rlogin, rsh or rexec), should be disabled (blocked) at the boundary firewall by default. 4. Firewall rules that are no longer required (e.g. because a service is no longer required) should be removed or disabled in a timely manner. 5. The administrative interface used to manage boundary firewall configuration should not be accessible from the internet. In situations where the administrative interface needs to be accessible from the internet (e.g. because it is supported by a remote administrator or external service provider) the interface should be protected by additional security arrangements. This could include using a strong password, encrypting the connection (e.g. using SSL), restricting access to a limited number of authorised individuals, and only enabling the administrative interface for the period it is required. Commentary: Basic stuff, sure, but necessary and often misunderstood. Firewalls are not always properly configured. Tools used by penetration testers can, and often do, find default passwords and common passwords that are an easy target for a dictionary attack. And just like operating systems and servers, if you don’t keep your firewall regularly patched or filtered for the latest known vulnerabilities, or even configured to monitor for irregular patterns in traffic, then you've spent money (sometimes a lot of money) giving yourself and your organisation a false sense of security. Page 10 Patching is dealt with by Control 5: Patch Management - albeit in a general way that doesn't provide you with much of a checklist to work from. The problems with new network technology like wireless networks and remote access devices that can be used to circumvent network perimeter security devices like firewalls and IDS, are not specifically addressed here either; and as every IT manager worth their salt knows to their cost, the days of feeling at ease behind boundary firewalls are gone. Control 1 is important though in ensuring that what protection firewalls can provide is properly configured. For example, that strong passwords (>8 characters, numbers and systems) are used and changed every 60 days, that traffic is monitored and controlled, and that those services which are '...more vulnerable to attack than others' are blocked at your office firewall assuming there's no business case for permitting access. 4.2 Secure configuration and User access control The second Cyber Essentials Requirement references 'secure configuration'. At this point, I am reminded of The Security Configuration Benchmarks that are distributed free of charge to propagate their worldwide use and adoption as user-originated, de facto standards. The CIS Benchmarks are described as "consensus-based, best-practice security configuration guides both developed and accepted by government, business, industry, and academia". The Benchmarks are recommended technical control rules/values for hardening operating systems, middleware and software applications, and network devices. There are used by thousands of enterprises as the basis for security configuration policies and the de facto standard for IT configuration best practices. Download here: https://benchmarks.cisecurity.org/about/ How does the CES Requirement 2 compare with the CIS Benchmarks? 2. Secure configuration Objectives Computers and network devices should be configured to reduce the level of inherent vulnerabilities and provide only the services required to fulfil their role. Computers and network devices cannot be considered secure upon default installation. A standard, ‘out-of-the-box’ configuration can often include an administrative account with a predetermined, publicly known default password, one or more unnecessary user accounts enabled (sometimes with special access privileges) and pre-installed but unnecessary applications (or services). Default installations of computers and network devices can provide cyber attackers with a variety of opportunities to gain unauthorised access to an organisation’s sensitive information, often with ease. By applying some simple security controls when installing computers and network devices (a technique typically referred to as system hardening), inherent weaknesses can be minimised, providing increased protection against commodity cyber attacks. Page 11 Basic technical cyber protection for secure configuration Computers and network devices (including wireless access points) should be securely configured. As a minimum: 1. Unnecessary user accounts (e.g. Guest accounts and unnecessary administrative accounts) should be removed or disabled. 2. Any default password for a user account should be changed to an alternative, strong password. 3. Unnecessary software (including application, system utilities and network services) should be removed or disabled. 4. The auto-run feature should be disabled (to prevent software programs running automatically when removable storage media is connected to a computer or when network folders are accessed). 5. A personal firewall (or equivalent) should be enabled on desktop PCs and laptops, and configured to disable (block) unapproved connections by default. Commentary: For SME organisations employing <50 people, among the first things that I would definitely recommend checking are the default configurations of routers, including converged wireless routers with access points (AP) and often an Ethernet switch, which offer little security in their default setting. Wireless routers are very common in micro-businesses and home office set-ups in particular; hence I would have named these devices by saying: Computers and network devices (including wireless routers/wireless access points) should be securely configured ... It is good practice to begin 'hardening' your configuration by ensuring that your router is secure as this is one of the best initial lines of defence. Consult the user’s guide, which will direct you to a predefined URL or IP address where you can do the following: Configure the wireless network to use WPA2-AES encryption for data confidentiality. Change the default login username, if permitted (refer to the user’s guide), and password. (The default passwords are published in manufacturer’s publications and are readily accessible.) Conduct MAC address filtering (a form of whitelisting, or identifying wirelessly connected computers you trust). Change the default wireless SSID. I would also have stressed that many wired networks base their security on physical access control, trusting all the users on the local network, but if wireless access points are connected to the network, anybody within range of the AP (which typically extends farther than the intended area) can attach to the network. Your security stance will be compromised if it is easy to attack your network using unencrypted wireless access points. 'Control' in management means setting standards, measuring actual performance and taking corrective action. Control is a continuous process. Page 12 I would have added to the Cyber Essentials Requirements that you should remove unnecessary software and disable nonessential services, and modify unnecessary default features to eliminate opportunities for attack, on a continuous basis. Your system technology is constantly evolving and new software/software upgrades can introduce security vulnerabilities - see below. Only through system hardening measures can you hope to maintain an optimum level of protection when connected to the internet; and even then unmitigated vulnerabilities will be exploited by the hackers. From the initial installation onwards, review the features that came enabled by default on your computer and disable or customise those you don't need or plan on using. As with nonessential services, be sure to research these features before disabling or modifying them. Recent operating systems are configured more securely by default and are preferred. However, all systems should be continuously hardened. Besides the operating system, some user-installed applications provide network services to communicate with other devices. In many cases these services are required for the intended operation of the device, and are therefore permitted. However, some applications install gratuitous network services that are either not required or are configured to provide network access when only local access is required. Hence, it will not be enough to apply this requirement once a year or every 6 months and still be confident that you have these issues under control. Cyber security is not a steady state. The next topic is access control. In computer security, general access control includes authorisation, authentication, access approval, and audit. Cyber Essentials Control 3. User access control adopts elements of this definition in the Requirements, including a regular review of special access privileges. It stops short though of calling the process an 'audit'. 3. User access control Objectives User accounts, particularly those with special access privileges (e.g. administrative accounts) should be assigned only to authorised individuals, managed effectively and provide the minimum level of access to applications, computers and networks User accounts with special access privileges (e.g. administrative accounts) typically have the greatest level of access to information, applications and computers. When privileged accounts are compromised their level of access can be exploited resulting in large scale corruption of information, affected business processes and unauthorised access to other computers across an organisation. To protect against misuse of special access privileges, the principle of least privilege should be applied to user accounts by limiting the privileges granted and restricting access. Basic technical cyber protection for secure configuration User accounts should be managed through robust access control. As a minimum: 1. All user account creation should be subject to a provisioning and approval process. 2. Special access privileges should be restricted to a limited number of authorised individuals. Page 13 3. Details about special access privileges (e.g. the individual and purpose) should be documented, kept in a secure location and reviewed on a regular basis (e.g. quarterly). 4. Administrative accounts should only be used to perform legitimate administrative activities, and should not be granted access to email or the internet. 5. Administrative accounts should be configured to require a password change on a regular basis (e.g. at least every 60 days). 6. Each user should authenticate using a unique username and strong password before being granted access to applications, computers and network devices. 7. User accounts and special access privileges should be removed or disabled when no longer required (e.g. when an individual changes role or leaves the organisation) or after a pre-defined period of inactivity (e.g. 3 months). Commentary: The first step towards securing a small business network - or indeed any other kind of computer network - is to understand what vulnerabilities an attacker is likely to exploit. You put yourself in the position of an attacker. What is your primary task once you have 'infiltrated' (i.e. got into) a network? It is not really a brainteaser question: just ask yourself what you would do in the real world to gain access to valuable data assets? Your job the moment you are in the system is to initiate escalation of privileges, which is how an attacker attempts to gain more access from the established foothold that they have created. After an escalation of privileges has occurred, there is little left in the system's defences to stop an intruder from whatever intent that attacker has. Attackers employ many different mechanisms to achieve an escalation of privileges (too many for this post!), but primarily they involve compromising existing accounts, especially those with administrator equivalent privileges. In most cases the bad guys need hours to compromise (>75% of the cases) where the good guys rarely get their job done in less than months (incredibly, only about 25% of the breaches are detected in days or less). [Source: The 2014 Verizon DBIR Report: Time-to-Compromise vs. Time-toDiscovery] After an attacker has compromised a network to the point where a critical account with high privileges is compromised, the entire network can never be considered as completely trustworthy again unless it is flattened and completely recreated. Therefore, the level of security for all manner of accounts is a very important aspect of any network security initiative. In the words of Microsoft Developer Network: "The matter of managing the security for all account types in a network is very important to managing risk for a midsize business network. Internal and external threats must be taken into account, and the solution to these threats must balance the need for security with the functionality a midsize business demands from their network resources." As a small business grows, the number of all types of accounts increases, and so too do the number of exploitable vulnerabilities. However, this is often forgotten in the priorities set by management in the commercial pressure to expand. Personally, I consider the control themes in this Requirement to be one of the most useful aspects of Cyber Essentials. Administrative accounts should only be used to perform legitimate administrative activities, and should not be granted access to email or the internet. SMEs and quite a few large Page 14 organisations need to understand the cyber risks associated with administrative, service, application-related, and default accounts. At this point it is worth remembering that the National Security Agency (NSA) is the font of information security wisdom for the US defence and intelligence communities. Yet, despite this obvious reason for cyber security, NSA's network security was apparently so weak that a single administrator was able to hijack the credentials of a number of NSA employees with high-level security clearances and use them to download data from the agency's internal networks - so the problem really exists. The administrator referred to here was, allegedly, Edward Snowden! [Source: Sysadmin security fail: NSA finds Snowden hijacked officials’ logins, Ars Technica, Sean Gallagher - Aug 29 2013, 10:40pm GMTDT]. Perhaps it isn't just the smaller enterprises that need Cyber Essentials? 4.3 Malware protection and Patch management Malware protection software is a necessary cyber security requirement. We all have knowledge of malware threats in one form or another and experience teaches us to be wary of certain links and email attachments. Cyber Essentials starts with the assumption that computers connected to the internet are vulnerable to attack from malware and therefore malware protection is seen as a key feature of basic cyber hygiene requirements. 4. Malware protection Objectives Computers that are exposed to the internet should be protected against malware infection through the use of malware protection software. Malware, such as computer viruses, worms and spyware, is software that has been written and distributed deliberately to perform unauthorised functions on one or more computers. Computers are often vulnerable to malicious software, particularly those that are exposed to the internet (e.g. desktop PCs, laptops and mobile devices, where available). When available, dedicated software is required that will monitor for, detect and disable malware. Computers can be infected with malware through various means often involving a user who opens an affected email, browses a compromised website or opens an unknown file on a removable storage media. Basic technical cyber protection for malware The organisation should implement robust malware protection on exposed computers. As a minimum: 1. Malware protection software should be installed on all computers that are connected to or capable of connecting to the internet. Page 15 2. 3. 4. 5. Malware protection software (including program code and malware signature files) should be kept up-to-date (e.g. at least daily, either by configuring it to update automatically or through the use of centrally managed deployment). Malware protection software should be configured to scan files automatically upon access (including when downloading and opening files, accessing files on removable storage media or a network folder) and scan web pages when being accessed (via a web browser). Malware protection software should be configured to perform regular scans of all files (e.g. daily). Malware protection software should prevent connections to malicious websites on the internet (e.g. by using website blacklisting). The scope of malware protection in this document covers desktop PCs, laptops and servers that have access to or are accessible from the internet. Other computers used in the organisation, while out of scope are likely to need protection against malware as will some forms of tablets and smartphones. Website blacklisting is a technique used to help prevent web browsers connecting to unauthorised websites. The blacklist effectively contains a list of malicious or suspicious websites that is checked each time the web browser attempts a connection. Commentary: Cyber Essentials assumes that 'robust malware protection' will help to protect your system. That protection comes from 'malware protection software' (the Objectives section avoids the outdated term 'antivirus'). The aim of course is to protect against human nature and the inevitable introduction of commonly found types of malicious software to a system. There's no mention here of highly sophisticated, targeted, zero-day and persistent advanced malware threats that Advanced Malware Protection (AMP) for Networks is designed to provide - at a price few could afford. Malware is commonly spread by people clicking on an email attachment or a link that launches the malware. Therefore, the best general advice to any organisation is: tell your staff about the risks before you get infected! Don’t open attachments or click on links unless you’re certain they’re safe, even if they come from a person you know. Some malware sends itself through an infected computer. While the email may appear to come from someone you know, it really came from a compromised computer. Relying purely on your malware protection software is not a good idea. You should take steps to raise staff awareness of the external threats, and what steps they can take as individuals to avoid malware infection. Personally, I would like to have seen a reference to training employees in cyber security awareness and incident reporting rather than total reliance on software tools: both are important in reducing the risk of data breach. Page 16 Likewise, there should be a 'health warning' about advanced persistent threats to dispel the notion that Cyber Essentials controls are effective against 100% of the malware attacks perpetrated by determined hackers. However, what Control 4 attempts to do is probably a realistic goal for 'essential security' given the limited aims of Cyber Essentials certification. And so, finally, we arrive at the fifth and final Cyber Essentials Control: 5. Patch management Objectives Software running on computers and network devices should be kept up-to-date and have the latest security patches installed. Any computer and network device that runs software can contain weaknesses or flaws, typically referred to as technical vulnerabilities. Vulnerabilities are common in many types of popular software, are frequently being discovered (e.g. daily), and once known can quickly be deliberately misused (exploited) by malicious individuals or groups to attack an organisation’s computers and networks. Vendors of software will typically try to provide fixes for identified vulnerabilities as soon as possible, in the form of software updates known as patches, and release them to their customers (sometimes using a formal release schedule such as weekly). To help avoid becoming a victim of cyber attacks that exploit software vulnerabilities, an organisation needs to manage patches and the update of software effectively. Basic technical cyber protection for patch management Software should be kept up-to-date. As a minimum: 1. Software running on computers and network devices that are connected to or capable of connecting to the internet should be licensed and supported (by the software vendor or supplier of the software) to ensure security patches for known vulnerabilities are made available. 2. Updates to software (including operating system software and firmware) running on computers and network devices that are connected to or capable of connecting to the internet should be installed in a timely manner (e.g. within 30 days of release or automatically when they become available from vendors). 3. Out-of-date software (i.e. software that is no longer supported) should be removed from computer and network devices that are connected to or capable of connecting to the internet. 4. All security patches for software running on computers and network devices that are connected to or capable of connecting to the internet should be installed in a timely manner (e.g. within 14 days of release or automatically when they become available from vendors). Commentary: Reasonable steps in a sensible approach. I particularly like the reference to removal of out-of-date software. If you don't need it, get rid of it - fast! There's no point in leaving redundant, unpatched application software on a system to help the hacker in their job. De-cluttering improves security. Page 17 Defining time limits for applying software updates - i.e. within 30 days of release or automatically when they become available from the vendor, - and, for security patches, 14 days or automatically, for software running on computers or network devices, is, I think, a useful security benchmark. Less helpful, there are no specific remarks about patching and updating Firewalls, IDS and NIDS (Network Intrusion Detection Systems) that often get a low priority in relation to applying OS patches but are in constant need of attention and monitoring. The alternatives to doing this yourself or building a dedicated in-house team are: (a) outsourcing to a systems security or networking company experienced at dealing with installations and on-going configurations of devices on a daily basis; or (b) using cloud services from public cloud providers like Google Inc. and Amazon Inc. to host services and applications, thereby side-stepping with the need for a complex, time-consuming and expensively-owned network architecture. But how then do you provide assurance that external service providers, especially for cloud services, comply with Cyber Essentials requirements? 5 How does Cyber Essentials deal with cloud service provision? As the Cyber Essentials Scheme Assurance Framework document states: "Many organisations use cloud services or other externally provided IT services." Cloud services of course vary considerably. Cyber Essentials applies in different ways depending on whether the applicant retains responsibility for implementation of the relevant set of controls, or whether the cloud service provider has the responsibility. If externally provided IT services are included within the scope of a Cyber Essentials assessment, then: For Cyber Essentials, the organisation will need to attest that its service provider’s system delivering that service meets the Cyber Essentials requirements for which the service provider is responsible. Existing evidence (such as that provided through PCI certification of a cloud service and appropriately scoped ISO 27001 certifications) may be considered as part this process. For Cyber Essentials Plus, the organisation will need to ensure that its service provider’s system delivering that service is tested as meeting the Cyber Essentials requirements for which the service provider is responsible. [Source: Cyber Essentials: Assurance Framework, [PDF] June 2014, section on Cloud Services, p. 10]. 5.1 Who will test cloud services for compliance with Cyber Essentials? Penetration testers and ethical hackers are increasingly used to evaluate the security of cloud-based applications, services, and infrastructures. In my view, the popularity of penetration testing (“pen testing”) will increase as public cloud services change the world of physical server-based IT into a virtual one. The type of cloud will dictate though whether pen testing is possible. For the most part, Platform as a Service (PaaS) and Infrastructure as a Service (IaaS) clouds will permit pen testing. Page 18 However, Software as a Service (SaaS) providers are not likely to allow customers to pen test their applications and infrastructure, - even if they are applying for cyber Essentials - with the exception of third parties performing the cloud providers’ own pen tests for compliance or security. Infrastructure as a Service (IaaS) providers (such as Amazon, Rackspace, or ElasticHosts) can offer your organisation use of their "bare metal" infrastructure to develop and deploy applications on any platform or OS (almost). They do not usually provide automatic OS updates, however. Even for the Cloud users, Patch Tuesdays could remain part of the landscape! 6 Conclusions These are the key messages that you should take away: Cyber Essentials is not a ‘kite mark’ or a standard, but the badge could still be of significant commercial value for companies doing business in the UK It is called “Essentials” for a reason: do not expect the control set to be exhaustive compared to e.g. ISO / IEC 27001:2013. Think of it as following the “80/20 rule” The scheme looks most suited to SMEs. The cost is not exorbitant and the time commitment is ‘do-able’. Larger organisations might look to ISO 27001 instead Badging is for your company and its internal IT systems. The scheme is not very applicable to any form of IT or software-as-a-service (SaaS) Cloud service providers should look elsewhere (for example, the UK Government’s Cloud Service Security Principles) The decision not to include risk assessment in Cyber Essentials is a risk in itself The advice is free and worth reading. Especially if you augment it with other free resources such as the Security Configuration Benchmarks When evaluating your network for vulnerabilities, don’t overlook the internet router / wireless access point as a primary point of attack Training staff is as important as badging the organisation. Don’t overlook it! Page 19 Company Information Registered Office : Cognidox Limited St John’s Innovation Centre Cowley Road Cambridge CB4 0WS UK Registered in England and Wales No. 06506232 Email [email protected] Telephone +44 (0) 1223 911080 Smart Document Management CogniDox helps teams in Engineering, Marketing, Sales, Operations and other departments to capture, share and publish product and design documentation. This easy-to-use tool helps break down the barriers to find information, share solutions and enjoy a faster, more productive development workflow inside your company. In addition, CogniDox helps you manage and publish documents and other content to licensed customers. It reduces technical support load and accelerates your customers' time to market. www.cognidox.com Page 20
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