2010 Secure World Boston Nist

NIST, FISMA, HIPAA and
Data Privacy –
Where to Begin
Candy Alexander, CISSP CISM
SecureWorld Expo Boston
March 24, 2010
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SecureWorld Expo - Boston - March 24, 2010 -
Room 104

Topics
Setting the stage for a Case Study
Understanding the requirements
How can NIST help
Closer look at NIST
Summary

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Setting the Stage
Organization driven by multiple requirements
FIMSA
HIPAA*
Data Privacy (45 states and the Feds)
MA 201 CMR17

Small organization with minimal resources
Need to work smart
Identify 1 size to fit all requirements (framework)

Existing work based on HIPAA Privacy & Security rules
Redirect into the NIST framework to meet *all* requirements

* Additional push with new HITECH Act – Summary of changes at end of slides

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Understanding the
Requirements…
Need to understand business requirements
Compliance (just enough or to protect)
Big budget or barely enough

Frameworks available
ISO ($$$)
COBIT ($$)
NIST (free)
Do it yourself ($?)
All of these + Notification process*

Federal Contractor, we used
NIST Risk Management Framework (RMF) for SP800-53
SP800-66-Rev.1

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Using the NIST Risk Management Framework (RMF)*

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* NIST SP800-66 Rev. 1 October 2008

Step 1 – Categorize
Information and Assets
FIPS199 to identify CIA (confidentiality, Integrity and
Availability) rating score
Great tool for communicating risk to businesses.
PHI (Protected Health Information) the “C” and “I” should be
high – availability is up to process owner
Identify PII (Personal Identifiable Information) and business
owner (supports data privacy requirements)
Identify “where” in the organization PII/PHI is
(applications, folders, etc.)
Supports the PHI tracking requirement for HIPAA
Use NIST SP800-60 for guidance

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Step 2 – Security Controls
Use FIPS 200 to identify the minimum baseline

Select controls to be used
Identified in SP800-53 (Rev.3) that are appropriate to
the environment (risk approach)

Document controls/requirements into a security plan
for each IT System.
NIST SP800-18 Guide for Developing Security Plans for
Federal Information Systems

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Step 3 – Implement Security
Controls
Uses various automated tools and manual
processes
Operating system controls
Application controls
System Development Life Cycle

Full array of publications available to provide
guidance to the specific topic/requirement
See http://csrc.nist.gov
Special Pubs, FIPS pubs, IR (internal reports),
and ITL (Info Tech Lab) Bulletins
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Step 4 - Assess Controls

Evaluate the controls with SP800-53A
Internal Audits
External Audits

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Step 5 – Authorize Information
System
Authorization to Operate (ATO)
Primarily for FISMA compliance
Essentially Designation Authority reviews controls
and evaluation of controls – then authorizes use
with an explicit decision to accept the risk

Not a BAD idea for getting executives to
understand, review and accept the risk

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Step 6 – Monitor Security
Continuous monitoring
Threats & vulnerabilities
Controls put into place to mitigate risk

Ensure all is effective and as intended

Ensure documentation is updated

Conduct impact analysis

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FISMA… Certification &
Accreditation
What is Certification and Accreditation?
Certification and Accreditation is a process that ensures that
systems and major applications adhere to formal and established
security requirements that are well documented and authorized. 1
Sound a little like MA 201 CMR17?

Obtaining the C&A removes the uncertainty of
compliance
Much like a ISO, PCI and SAS70 Type II?

Auditors appreciate the structure
1 e-Articles.info on ask.com
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FISMA/NIST C&A
C&A guidance available through SP800-37

Provides accrediting authority ( and auditors) high degree of
confidence that the managerial, technical and op security
controls work as intended & that the information processed,
stored and transmitted with the system is protected.
Controls based on FIPS 199, 200 and NIST SP800-66 (HIPAA)
and SP800-53

C&A should be completed prior to production and re-accredited
when significant change occurs, as directed by the agency
contract/ authorizing official or at minimum every three years.

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C & A Phases
Consists of 4 distinct phases
1. Initiation Phase
2. Security Certification Phase
3. Security Accreditation Phase
4. Continuous Monitoring Phase

Each phase has a detailed list of tasks and
subtasks, documents and artifacts that are
used to support the next phase
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Certification Package*
1. Updated System Security Plan
2. Completed Security Risk Assessment
3. Updated Config. Mgmt Plan
4. Contingency Mgmt Plan(s)
5. Security Test & Eval. Report
6. User Manuals
7. Interconnection Security Agreements or MOUs
(Business Associates Agreements for HIPAA)
8. Privacy Impact Assessments
9. Federal Register System of Record Notice
10. Plan of Action & Milestones
*Exact contents are defined by Information System Owner
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Accreditation Package
1. Security Assessment Report
2. Security Accreditation Decision Letter
3. System Security Plan
4. Plan of Action & Milestones

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HITECH Act - Tougher HIPAA
From Privacy/Security Perspective:
Breach Notification (tougher requirements)
Wider scope – including BAs (2/17/10)
Account of disclosures (more rigorous)
Enforcement (2/17/10) – increased $$$
State AG’s enforcement

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Questions?

Candy Alexander, CISSP CISM
calexander@ltcpartners.com

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2010 Secure World Boston Nist

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