NIST proposes a Secure Software Development Framework to address software supply chain attacks

Applying software updates and patches as soon as possible is a cyber security best practice, but what if an update contains malicious code inserted by a hacker? Software supply chain attacks are a serious and growing problem for both private-sector organizations and the federal government. Among other incidents, Chinese nation-state hackers successfully breached numerous third-party contractors working for the U.S. Navy on multiple occasions over an 18-month period.

The Navy contractor attacks and similar incidents were the impetus for the federal government barring agencies from purchasing certain vendors’ software and hardware. However, these bans don’t address the root of the problem, which is that security must be baked into the software development lifecycle (SDLC) from the very beginning. This is why NIST has proposed a Secure Software Development Framework (NIST SSDF).

What’s in the NIST SSDF?

While there are many SDLC frameworks, few specifically address secure software development; they were designed to speed up and bring order to the development process, not ensure security. Instead, project managers are left to integrate secure development practices on their own.

The proposed NIST SSDF does not introduce any new practices. It curates high-level secure software development best practices from a number of existing sources. So that the framework is flexible, it does not specify how to implement its recommendations. Implementation will look different in every organization, as data environments, security objectives, and priorities greatly differ.

The proposed framework includes 19 best practices for secure software development, grouped under four categories.

Prepare the organization. The best practices in this category are about aligning the organization’s people, processes, and technology to build a strong foundation for secure software development. It outlines practices such as ensuring that security requirements for software development are known at all times so they can be taken into account throughout the SDLC; making sure that everyone involved in the SDLC knows what their roles and responsibilities are regarding secure development; and using automation to improve the accuracy, consistency, and comprehensiveness of security practices.

Protect the software. Software must be secured against tampering and unauthorized access, both intentional and accidental. The best practices in this category address how to secure source code for in-house projects and provide recommendations to aid end users in ensuring that the software they acquire is legitimate and has not been tampered with.

Produce well-secured software. The best practices in this category seek to maximize software security and minimize vulnerabilities in each release. Many developers have not been educated in secure development practices and end up unknowingly producing insecure code. In addition to addressing secure software development practices for in-house projects, it provides recommendations for verifying that third-party software meets security requirements.

Respond to vulnerability reports. This step focuses on identifying potential vulnerabilities in each successive release, addressing them, and preventing similar problems in future releases.

NIST hopes that the recommendations in the SSDF benefit both sellers and buyers in the software supply chain. Sellers who adopt secure software development practices will address the root causes of supply chain cyberattacks by minimizing potential vulnerabilities in each release and mitigating the impact of undiscovered vulnerabilities. Buyers can adapt these practices and incorporate them into their software acquisition processes.

The public comment period for the draft NIST SSDF began on June 11 and ends on August 5, 2019.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.

Let’s examine the role of the 3PAO in the FedRAMP assessment process.

The Federal Risk and Authorization Management Program (FedRAMP) was designed to support the federal government’s “cloud-first” initiative by providing a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. All cloud service providers (CSPs) that work with the U.S. government must comply with FedRAMP, and during the assessment process, all of these CSPs will work with a FedRAMP third-party assessment organization, or 3PAO, such as Lazarus Alliance.

What is a FedRAMP 3PAO?

A FedRAMP 3PAO is an independent assessor that has been certified to help cloud service providers and government agencies meet FedRAMP compliance regulations. CSPs who are pursuing certification through the FedRAMP JAB P-ATO process must partner with an accredited 3PAO for their FedRAMP security assessment. A 3PAO is optional for CSPs pursuing FedRAMP Agency authorization.

The 3PAO accreditation process is quite rigorous, requiring auditors to meet very high standards for quality and technical competence. To accredit 3PAOs, FedRAMP partners with the American Association for Laboratory Accreditation (A2LA). The A2LA assessment process evaluates the 3PAO’s technical competence and assesses their compliance with the general requirements of ISO/IEC 17020:2012 and FedRAMP specific requirements.

FedRAMP 3PAOs must be reassessed and recertified annually.

The role of the 3PAO during a FedRAMP assessment

The FedRAMP certification process begins with the preparation of the System Security Plan (SSP) document, in which the CSP describes all of the information security controls they are currently using and their implementation. Due to the potential for a severe conflict of interest, a 3PAO is not allowed to prepare an SSP for a CSP and then perform the CSP’s FedRAMP assessment; the CSP must prepare their own SSP prior to the commencement of the assessment.

During the FedRAMP assessment, a 3PAO:

• Assesses the CSP’s system’s operational security capabilities and prepare a Readiness Assessment Report (RAR), if the CSP is seeking a “FedRAMP Ready” designation prior to commencement of the formal assessment
• Develops the Security Assessment Plan (SAP), a customized account of the security assessment methodology, in conjunction with the CSP
• Performs the CSP’s security assessment
• Documents the results of the security assessment in the Security Assessment Report (SAR) and supporting documents

The SSP, SAP, and SAR make up the authorization package, which is submitted to the authorizing party (either the JAB or the agency) for review and approval.

After their initial certification is approved, CSPs enter what FedRAMP calls “continuous monitoring.” To maintain their certification, they must have their cloud systems reassessed annually, as well as whenever they make certain changes to their systems, to ensure that the systems still meet FedRAMP requirements. These reassessments must also be performed by a 3PAO.

To make it easier for our FedRAMP clients to prepare their SSP, Lazarus Alliance includes, at no additional cost, access to the IT Audit Machine (ITAM) FedRAMP SSP module from Continuum GRC. ITAM has self-help modules that walk the CSP through the process of preparing an SSP, and Lazarus Alliance also uses ITAM to perform the actual FedRAMP 3PAO assessment. By automating as much of the process as possible, we’re able to dramatically cut the time requirements and costs of FedRAMP certification and put it within reach of most CSPs.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.

New HIPAA fines will be based on an organization’s “level of culpability”

Following a record year for HIPAA settlements that saw the U.S. Department of Health and Human Services (HHS) collect $28.7 million in HIPAA fines, HHS has reduced the maximum annual HIPAA fine in three out of the four penalty tiers. However, HHS’ move doesn’t mean that healthcare organizations are now free to take a laissez-faire approach to compliance or cyber security.

More culpability = higher HIPAA fines

For years, healthcare organizations have been complaining about eye-popping HIPAA fines in the wake of breaches that were not their fault. The adjusted fines address this issue by making willfully negligent organizations pay more than those who exercise due diligence. The new HIPAA penalty tiers are effective now and are as follows:

• Tier 1 (no knowledge of violation): $100 to $50,000 per violation; capped at $25,000 per year
• Tier 2 (reasonable cause): $1,000 to $50,000 per violation; capped at $100,000 per year
• Tier 3 (willful neglect, corrected): $10,000 to $50,000 per violation: capped at $250,000 per year
• Tier 4 (willful neglect, not corrected): $50,000 per violation; capped at $1.5 million per year

While the maximum HIPAA fines have gone down significantly, these are still hefty chunks of change, especially for small and medium-sized organizations with tight budgets. It’s also important to note that the annual cap is per year for every year the violation persists.

There’s more at stake than just HIPAA penalties

HIPAA compliance does not automatically equate to cyber security, and healthcare organizations have a lot more to worry about than just being slapped with HIPAA penalties, which are assessed only in a minority of cases, anyway. Even if a healthcare organization faces no HIPAA fine or only a small one, it is still subject to:

• Other compliance mandates, such as PCI DSS.
• The theft of confidential business information or employee data.
• State data privacy laws, such as the law Washington State just enacted, halving the time organizations have to notify victims of a breach from HIPAA requirements and broadening the definition of what would be considered breached information.
• Civil lawsuits filed by angry patients, including class action suits.
• Bad PR and brand damage that could lead to lost business and difficulty recruiting talent.
• Difficulties with current or future M&A transactions; no organization wants to inherit another’s cyber security or compliance problems.
• Incident response and mitigation costs, including system restoration, replacement of hardware, and the price of identity theft solutions for breach victims.

Healthcare organizations can also be victimized by cyber attacks that do not involve data breaches or HIPAA penalties but are quite costly and destructive, such as ransomware and cryptojacking malware. Ransomware, which has plagued the healthcare industry for several years, can be used to disable medical IoT devices or lock providers out of electronic health records and other critical systems, putting patients’ health and lives at risk.

The cyber security landscape is dynamic, and new threats are emerging literally daily. HIPAA is important, but it should not be healthcare organizations’ only compliance or cyber security concern, and fines should not be the only motivating factor to defend against cyber abuse.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.