Compliance and Governance | Vulnerability Management

Eventually, the progress in remediation has to be monitored by someone to maintain good governance. In an organization of less than 10,000 hosts, it is often sufficient for this individual to be the person responsible for scanning. However, in larger organizations, it is preferable to have a compliance group perform this function. Additionally, Compliance would monitor the configuration and operation of the system on a regular basis.

Figure 1 shows how the compliance organization uses the current operations documentation, process documentation, and scan results to verify compliance. These three pieces of data have an important relationship. Operations documentation tells the compliance group what activities were undertaken by the VM group. Compliance should verify that VM activities are conducted in accordance with policy.

 

Figure 1: Compliance data flow.

Process documentation defines in unambiguous detail the steps to perform the VM function. It is against this documentation that the compliance function will verify the operations activities and supporting output documents. The process documentation itself should be checked against policy to assure conformity. In some cases, this step is not necessary in the compliance monitoring function because compliance may be a part of the creation of the VM process. In that case, an external audit is occasionally warranted.

Finally, the scan results data is detailed in reports from the vulnerability scans. These reports should reflect the level of compliance achieved by each IT group responsible for remediation. Later, we will discuss in some detail the content of these reports and their relevance in a mature, successful VM program.

1 System Audit

Another critical step in the governance of VM is auditing. During an annual audit of security mechanisms, it is advantageous to have an external party review the configuration and operation of the system. The elements of any audit should include the following:

• Process: Auditors should verify that there are no critical flaws in the scanning, remediation, and verification processes. The auditor should provide recommendations on improvements.
• Scope: With an understanding of the structure and application of existing network segments, auditors must verify that a complete and appropriate set of targets is scanned. Depending on the program charter and policy, the list of targets may include vendors or business partners. In addition to existing targets, it is important to recognize that organizations, systems, and networks are dynamic. Changes to the environment will change the scope of scan targets. Processes and configurations of scanners should be sufficient to adapt to this changing environment.
• Training of operators: Those working on the technical details of the system must be sufficiently well-versed in its operation. Not only must they understand operations, they also have to understand how vulnerabilities work, the threats associated with them, and the risks posed to a company realizing those threats. Knowledge of operating systems, networks, protocols, and various relevant applications is highly desirable.
• Policy alignment: Do the VM operations align with current policy? As we discussed earlier, VM processes are derived from policy, which is derived from program charter or business objectives. Over time, policy can drift and no longer meet the program requirements. This is not through negligence but a natural tendency of individuals to adapt to a changing environment without the perspective of overall impact to the program charter.

As circumstances gradually change in networks and systems to respond to the changing business environment, the business needs will no longer be reflected in the policy. For example, the business may typically sell its products through personal sales contacts. Therefore, there are no policies regarding proper use of encryption or handling of customer financial data. Then, they discover untapped markets that are accessible online. The current policy may state that electronic payment data must be exchanged through bank transfers and not through company systems. However, in the newly adopted online sales model, customers provide payment information, which is handled by company computer systems. Now, numerous vulnerability and compliance issues in encryption, network design, and system configuration arise. Since the policy has never been amended, it is difficult to discover and remediate compliance problems in these systems. Furthermore, the systems in question may be out of scope for VM altogether.