How comfortable are you having a conversation that starts “the spreadsheet you emailed is going to cost us four million dollars”? Probably not very comfortable – but it’s where current data handling practices will lead us. Privacy laws are penalising loss of control of data – not actual harm to subjects of the data. This is why controlled handling needs to be an operational capability for any organisation handling personal data.
The CRM system is a great example of the problem – it generally has the crown jewels of personal data, and easy download capability. The standard response to “joe needs a list of customers for x” is to cut a spreadsheet full of personal information, and email it.
Every system the data touches after that makes a couple of uncontrolled copies – backups, replications, shares, edits. It’s like cancerous cells – a few here and there multiply to become a much larger problem. Under GDPR, it’s a 4% of revenue sized problem when the data is emailed to the wrong person.
The key to removing the problem is providing capability to handle data without downloading it. Simply, your employees need to be able to run their business process end-to-end without downloading and emailing a spreadsheet. If they can’t, you’ve got a carcinogenic problem within your organisation.
This post is going to be a bit dry, it is written to provide an accurate overview of specifically where you can find multi-factor authentication controls in the 2017 Australian Government Information Security Manual (ISM). It is accurate as at the 3rd of March 2017. If you are in a security or IT decision-making role, and are considering whether multiple factors of authentication should be part of your security apparatus, the ISM provides both a minimum standard for accreditation, and guidance that can be used to inform your risk assessment. Each control is contextual, and doesn’t apply to every situation – you should seek a qualified opinion from a member of the IRAP program to ensure that you are assessing the right controls.
The minimum standard is imposed through controls that are listed as “must” for compliance purposes. In areas where some consideration of control vs. ease of access is appropriate, the controls are listed as “should”. What is clear from the ISM is that for system administrative activities, it is not considered acceptable to act without multiple factors of authentication. In some individual user access scenarios though, multiple-factors are listed as “should”. This lessening of controls for end users provides scope for each agency to consider the level of risk associated with access to the system, the level of burden that it is appropriate for users of that system to bear, and the level of operational complexity that the additional factors add.
As always, prior to looking at controls, the grade of information the service will carry needs to be decided. The cost of achieving each higher classification rises substantially, and each successive classification focuses more on access control than ease of access. From a risk perspective, more consideration of whether “should” should become “must” should also be considered. Appropriately qualified security and risk management personnel should be engaged to advise on these matters.
From a pure control standpoint, the controls focused on multi-factor authentication are listed below, each applies to all classifications –
- 0974 – “Agencies should use multi-factor authentication for all users.”
- 1039 – “Agencies should use multi-factor authentication for access to gateways.”
- 1173 – “Agencies must use multi-factor authentication for” – system and database administrators, privileged users, positions of trust and remote access.
- 1384 – “Agencies must ensure that all privileged actions must pass through at least one multi-factor authentication process.”
- 1401 – “Agencies using passphrases as part of a multi-factor authentication must ensure a minimum length of six alphabetic characters with no complexity requirement.”
Some discussion of Multi-factor authentication can also be found in the “Access Control” section of the ISM – Principles manual.
All the documentation you need can be found at https://www.asd.gov.au/infosec/ism/index.htm
The 2017 ISM – Controls can be found at – https://www.asd.gov.au/publications/Information_Security_Manual_2017_Controls.pdf
The 2016 ISM (the latest) – Principles can be found at – https://www.asd.gov.au/publications/Information_Security_Manual_2016_Principles.pdf