Regulatory Compliance Using Identity Management
 Abstract |
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Regulations such as Sarbanes-Oxley, FDA 21-CFR-11 and HSPD-12 require
stronger security, to protect sensitive business processes. Regulations
such as Gramm-Leach-Bliley, HIPAA, PIPEDA and the EU Privacy Protection
Directive 2002/58/EC require stronger security, to protect the
privacy of investors, patients, consumers and citizens, respectively.
Security in every multi-user application depends on authentication, authorization and audit infrastructure (AAA). In turn, this infrastructure depends on complete, current and accurate data about users. In particular, dormant and orphan accounts must be reliably deactivated, and privilege creep must be addressed. Identity management systems enable reliable maintenance of data about users and their security rights. In turn, this supports reliable AAA and therefore regulatory compliance.
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Introduction
Corporations and non-profit organizations, such as Universities or Government agencies, are increasingly subject to regulations that have an impact on IT governance. Regulations such as Sarbanes-Oxley, FDA 21-CFR-11 and HSPD-12 require stronger security, to protect sensitive business processes. Regulations such as Gramm-Leach-Bliley, HIPAA, PIPEDA and the EU Privacy Protection Directive 2002/58/EC require stronger security, to protect the privacy of investors, patients, consumers and citizens, respectively.
The common theme in all of these regulations is that IT security is crucial, to protect both corporate governance and privacy. Since every multi-user computer system depends on authentication, access controls and audit logs (AAA) for its security, it follows that the regulatory environment mandates an effective AAA infrastructure.
AAA is not new: one form of AAA or another has been embedded into every multi-user application since early mainframes in the 1960s. The weakness in most systems is not their ability to authenticate users, control their access rights and audit their actions, but rather in the fact that these run-time decisions depend on accurate and reliable user data. As the number of users in a typical enterprise IT environment has grown, and as the number of systems and applications has multiplied, it has become increasingly difficult to maintain accurate and reliable data about very user on every system.
Identity management systems are intended to overcome this problem, by automating user administration processes, so that data about users, how they are authenticated, and what rights they have can be maintained more efficiently and reliably.
This document outlines a variety of problems that can arise with user profile data, the impact of those problems on the efficacy of an enterprise AAA infrastructure, and the solutions that an identity management system can bring to bear to eliminate those problems.
The remainder of this document is organized as follows:
- Identity Management System Components
Describes the elements of an identity management system that may be deployed in an enterprise network.
- Authentication
Describes user authentication processes, how they can fail, and what identity management systems can do to eliminate these failures.
- Authorization
Describes access authorization processes, how they depend on user profile data, and what identity management systems can do to ensure that user profile data is accurate and reliable.
- Audit
Describes access audit processes, their limitations and how those limitations can be overcome using an identity management system.
- Summary
A summary of the concepts presented earlier.
Identity Management System Components
Enterprise Identity Management
This document focuses primarily on identity management inside the enterprise, managing internal users -- employees, contractors, vendors, etc. Internal users are qualitatively different than external users, in that they are relatively few (thousands, not millions), and complex (having tens of login accounts and user objects each, many of which may be inaccurate, uncorrelated or obsolete).
Without an identity management system, users are managed by separate administrators, using separate software tools, and often separate business processes, on each system. This is illustrated in Figure [link].
Managing Each Application in its own Silo (1)
An identity management system is used to externalize the administration of user objects, replacing processes that are implemented within each system and application with new processes that apply uniformly to all users, on all systems. This simpler process is illustrated in Figure [link].
Externalizing the Management of Users and Entitlements (2)
Business Processes
As illustrated in Figure (_label_fig:idm-processes), an identity management system connects to multiple, existing systems where user objects are stored, and manages them cohesively. It does this as the end-product of one or more business processes, which drive changes to user definitions.
Identity management systems may implement any of the following business processes:
- Identity synchronization:
Detect changes to personal data, such as phone numbers or department codes, on one system and automatically make matching changes on other systems for the same user. - Auto-provisioning:
Detect new user records on a system of record (such as HR) and automatically provision those users with appropriate access on other systems and applications. - Auto-deactivation:
Detect deleted or deactivated users on an authoritative system and automatically deactivate those users on all other systems and applications. - Self-service requests:
Enable users to update their own profiles (e.g., new home phone number) and to request new entitlements (e.g., access to an application or share). - Delegated administration:
Enable managers, application owners and other stake-holders to modify users and entitlements within their scope of authority. - Authorization workflow:
Validate all proposed changes, regardless of their origin and invite business stake-holders to approve them before they are applied to integrated systems and applications. - Consolidated reporting:
Provide data about what users have what entitlements, what accounts are dormant or orphaned, change history, etc. across multiple systems and applications.
Functional Components
Breaking processes down further, enterprise identity management systems may expose some subset of the following functions:
- User provisioning:
- Automation / meta directory, to propagate changes from systems of record to managed systems.
- Self service workflow, enabling users to request and authorize changes.
- Consolidated administration, to enable central security staff to manage users across multiple systems.
- Delegated administration, to enable local security staff to manage some users, on some systems.
- Privilege audit:
- Enable or require managers to review and clean up the rights of their subordinates.
- Enable application owners to review and clean up the list of users who can sign into their applications and their entitlements within those applications.
- Enable security group owners to review and clean up the list of users who belong to their groups.
- Password / authentication factor management:
- Synchronize passwords between systems.
- Enable self-service and assisted password reset.
- Enroll and update answers to security questions.
- Enroll and maintain strong authentication factors, such as biometric samples or hardware tokens.
- Single / reduced sign-on:
- Reduce the number of times that users must enter their login IDs and passwords to access various applications.
- Reporting:
- Extract a matrix connecting users to resources and privileges.
- Report on access change history -- who request and authorized changes and when they were applied to target systems.
- Identify anomalies, such as orphan and dormant accounts.
- Virtual directory:
- Consolidating multiple and possibly heterogeneous directories into a single, global view.
Identity and access management systems are closely related to access management systems, which may consolidate or strengthen user authentication processes (i.e., single, strong sign-on) and may enforce authorization policies at run-time. These include:
- Strong authentication, using smart cards, tokens and biometrics.
- Web single sign-on (Web-SSO), typically using cookies to maintain session state, but increasingly using federation protocols such as SAML and WS-Security.
- Web access management (Web-AM), typically integrated with Web-SSO, which enforce runtime decisions about whether users should be allowed to access specific servers, URLs or application features.
Authentication
Overview
Users typically sign into systems and directories by typing a personal login ID and password. In most organizations, if a user forgets his password, or inadvertently mistypes it often enough to trigger an intruder lockout, the user may call the help desk, identify himself, and request a new password.
Vulnerabilities
This process can create multiple security vulnerabilities, exposing sensitive systems and data to access by unauthorized users:
- Weak passwords: Short, simple or static passwords can be cracked by password guessing programs, or by patient intruders.
- Too many passwords: Users with too many passwords will write them down, and so reduce systems security to be equivalent to physical security. In many organizations, a large physical perimeter means that physical security is very weak.
- Caller authentication: Help desks often fail to reliably authenticate callers, and so can be convinced by an intruder to mistakenly reset an intended victim's password. Many help desks authenticate callers by asking for some part of their social security numbers or birth-dates -- neither of which are hard for an intruder to acquire.
- Credential proliferation: In many help desks, a large number of support staff have administrative rights to managed systems, required to provide the password reset service. This is contrary to security best practice, which is to minimize the number of people with administrative rights (reducing the attack surface). Turnover among support staff also creates security security concerns.
- Audit logs: Few systems log administrative password resets, or attribute them to specific support staff. Consequently, there is no accountability for who reset whose password, when and why, as would be required in response to a security incident.
Security Benefits of Identity Management
All of the above problems can be addressed by an effective identity management system:
- Weak passwords: Password synchronization systems can
enforce a strong password policy, including minimum length,
frequent expiry, history and complexity whenever a user changes
passwords. This ensures that passwords are difficult to
crack, and expire long before the time required to crack them.
Strong authentication products also works to eliminate weak passwords, typically requiring that users submit multiple authentication factors.
- Too many passwords: Both password synchronization and single
signon systems eliminate the need for users to remember multiple
passwords. A single, strong, regularly changed password
is much more secure than multiple passwords written down.
- Caller authentication: Self-service and assisted password
reset systems can be configured to implement a robust process
for authenticating users who forgot or locked out their password.
This may include a prompting users to answer a combination of
user-defined and standard questions, or resort to another
authentication factor, such as a hardware token or biometric
sample, prior to a password reset.
- Credential proliferation: By delegating the right to
reset passwords, separately from other privileges, password
reset systems eliminate the need to give support staff
administrative rights.
- Audit logs: Password reset systems can audit all password resets, both self-service and assisted.
Summary
Vulnerabilities in a typical password-based authentication infrastructure can be eliminated using a combination of:
- Password synchronization.
- Self-service and assisted password reset.
- Single signon.
- Multi-factor authentication.
Authorization
Overview
Most systems control user access to data by first authenticating users (see previous section), and then checking each attempted user action against a privilege model.
Users gain access to sensitive systems and data first by having a login account on the system in question, and secondarily by having specific privileges on that system. Users may be granted privileges directly, or in relation to specific resources (e.g., folders, shares, printers, screens, menus, etc.). Users may acquire privileges by virtue of membership in a security group, which itself has been assigned privileges.
Most large systems rely heavily on user groups to manage privileges, since assigning fine-grained rights individually to many users is too onerous. As a result, the rights a user has across multiple systems in an organization can usually be expressed as a function of which accounts the user has, and what security groups the user belongs to on each system.
Vulnerabilities
The authorization infrastructure in most systems and applications is technically effective, but relies on data about user rights, which may be inaccurate:
- Login accounts:
Accounts may be orphaned -- meaning
that their users have left the organization, or dormant
-- meaning that the user no longer needs them.
Accounts may be active, but have no known owner, which eliminates the possibility of making users accountable for their actions.
- Security group memberships: Users may be assigned
inappropriate privileges, either due to failure to
standardize access rights in conformance with
policy, or in compliance with out-of-date policies.
Users may belong to groups which grant them no-longer-needed privileges. This is a result of privilege accumulation, whereby users gain new rights as their responsibilities change, but where their old (and no longer needed) rights are not reliably deactivated. This compromises the security principle of least privilege.
- Conflicting privileges: Users may have multiple privileges, which are reasonable individually but violate the need for separation of duties in combination. A traditional example for this is a user who can both submit purchase orders and issue payments, thereby circumventing traditional accounting controls.
Security Benefits of Identity Management
The above problems can be addressed by an effective identity management system:
- Orphan accounts:
One function of any enterprise identity management system is to construct enterprise-wide user profiles, which connect user objects on multiple systems to single owners. Orphan accounts can be identified once this process is complete, as they are the accounts with no known owners.
Typically a user provisioning system will be used to first deactivate orphan accounts, and wait to see their (legitimate) owners complain. After some time, orphan accounts can be removed, reducing the security "attack surface" and possibly also software licensing costs, where they are tied to the number of user objects.
- Dormant accounts:
A user provisioning system can be used to identify dormant accounts, by inspecting the last-login-time attribute of each user. Dormant accounts can be eliminated in the same way as orphan accounts.
On systems where there is no record of last login time, accounts can be connected to user profiles, and if the primary login account in the profile is inactive, it may be assumed that all other accounts are likewise dormant.
- Standardized privileges:
By creating accounts through the user provisioning system, rather than directly using a variety of native user administration tools, organizations can enforce standards regarding login account configuration, to ensure that new users get appropriate privileges when their login IDs are created.
- Privilege accumulation:
A privilege auditing system can be used to periodically review the rights of all users. Managers, application owners and group owners can identify and remove inappropriate privileges, that were either improperly assigned or retained beyond their relevance.
The same system can also be used to identify orphan and dormant accounts.
- Separation of duties:
A user provisioning system can be used to prevent users from acquiring inappropriate privilege combinations. It can also be used to report on such combinations where they exist prior to deployment of the system, so that some or all of the offending privileges can be removed.
Summary
The combination of a user provisioning system and a privilege auditing system can be used to find and remove:
- Orphan and dormant accounts.
- Inappropriate privileges, whether accumulated over time or improperly granted at account creation time.
- Inappropriate combinations of rights, that would violate rules requiring separation of duties.
Audit
Overview
Audit logs are intended to make users accountable for their actions. Various regulations that impact IT security require logging of changes to financial data, attempts to access private information, various authorizations and digital signatures.
The degree to which common systems and applications log events of interest is variable. For example, most systems record failed login attempts and user lockouts, but not all systems record successful user logins. Financial and clinical systems log authorizations and signatures, but other systems don't. Many systems do not log user administration actions, such as the creation of new users, changes to user privileges or deactivation of user access.
In almost all cases, audit logs are internal to systems and applications. Events on different systems may be difficult or impossible to correlate, as would be required in a forensic audit to establish a pattern of activity. Beyond local storage, a challenge for event correlation is that users often have different login IDs on different systems, and so audit logs on one system cannot be readily connected to those on another.
Vulnerabilities
Limited, system-specific audit logs present some security challenges to enterprises who must protect multiple, sensitive systems:
- Event correlation: It is difficult to match security
events on one system to those on another if user identifiers
are different and not otherwise correlated.
- Privilege audit: It is difficult to quickly answer
the question "who has the following privileges?" when the
privileges span multiple systems.
- Privilege history: It is impossible to quickly answer
the question "who had the following privileges at a given
date?" when systems do not log privilege changes.
- Record of authorization: Most systems do not audit
security change requests or authorization, since these happen
out of band with respect to the administrative user interface.
Moreover, use of generic administrator accounts and limited
audit capabilities mean that most systems cannot even report
on when a given privilege was assigned to a user, or by whom.
- Appropriate privileges: Systems and applications cannot determine whether privileges granted to their own users are appropriate. Instead, administrators are presumed to assign privileges in a manner appropriate to business requirements.
Security Benefits of Identity Management
An identity management system can resolve all of these audit challenges:
- Event correlation: Login ID reconciliation is
pre-requisite to the deployment of any enterprise identity
management system. Consequently, data from any enterprise
identity management system can be used to correlate
event logs between multiple systems and applications.
- Privilege audit and history: A user provisioning system, configured
to monitor and manage privileges on multiple systems, can
be used to report on current and historical privileges.
- Record of authorization: Where the user provisioning
system is used to request and authorize security changes (e.g.,
using a workflow engine), it can report on this change history.
Where changes are made through an automated process, it can
at least report on which system of record triggered changes.
Where a consolidated or delegated user administration model
is used, the user provisioning system can report on which
administrator initiated the change.
- Appropriate privileges: A privilege audit system engages business stakeholders, such as managers, application owners and group owners, to review privileges and make an informed decision about whether they are appropriate.
Summary
A user provisioning system, combined with a privilege auditing system, can significantly improve the ability of an organization to create accountability, and to find and remove inappropriate security privileges.
Summary
Regulations increasingly demand that corporations and non-profit organizations implement sound IT security to protect privacy and ensure sound governance.
Most systems and applications already incorporate authentication, authorization, and audit (AAA) infrastructure with which to do this. Unfortunately, AAA infrastructure is vulnerable to weaknesses in security-related business processes and to improper user privilege definitions.
An identity management system, including user provisioning, password synchronization and reset and privilege audit can be used to address shortcomings in security business processes and inappropriate user privileges, which would otherwise undermine a AAA infrastructure.
These identity management features can be supplemented by strong authentication technology, single signon and web access management systems.
References
- Hitachi ID Systems is an enterprise identity management software vendor:
- Hitachi ID Identity Manager is a user provisioning solution from Hitachi ID Systems:
... http://Hitachi-ID.com/products/core/idsynch.html
- Hitachi ID Password Manager (formerly P-Synch) is a password synchronization and password reset solution from Hitachi ID Systems:
... http://Hitachi-ID.com/products/core/psynch.html
- Hitachi ID Access Certifier is a privilege audit solution from Hitachi ID Systems: