Data Access Accountability - Who Did What to Your Data When? - A Lumigent Data Access Accountability Series White Paper

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Data Access Accountability
Who Did What to Your Data When?

Dr. Murray S. Mazer
Chief Technology Officer
Lumigent Technologies, Inc.

A Lumigent® Data Access Accountability™ Series White Paper

                                         Lumigent Technologies, Inc.
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Overview
   Enterprises today are reliant on database technology to run their business. The often mission-critical
   data assets in these databases need to be safeguarded from inappropriate access and data changes.
   The need to protect data security and privacy has become of paramount concern to most organiza-
   tions. Reasons for this may include customer or supplier requirements, business practices, security
   policies, and government regulations. At the same time that business and IT management are con-
   cerned with addressing these requirements, the IT staff has an ongoing operational need to manage
   data integrity and availability.

   Regardless of how this need is driven, the requirement can be characterized as a need for “data
   access accountability” — or, knowing who’s doing what to which data, and by what means.

   Meeting these challenges requires an effective audit trail and timely alerting on key events. This in
   turn requires a number of capabilities: capturing a record of data access and permissions changes,
   managing the captured information for lengthy periods, flexibly analyzing the information, producing
   reports, and detecting conditions of interest for timely notification, all the while avoiding perform-
   ance overhead on your critical systems.

   Capturing a record of data access is a key step, yet common approaches have important flaws that
   miss certain kinds of activity, introduce a false sense of security, and interfere with runtime data-
   base performance. Many organizations, aware of these shortcomings, choose not to implement these
   kinds of safeguards, leaving these organizations unable to respond to their business needs.

   Lumigent has introduced Entegra™ as a solution for data access accountability. Entegra provides a
   complete record of data activity with active monitoring and alerting, answering the questions regard-
   ing “who did what to which data when, and by what means?” Entegra provides a solution that can
   reduce the operational and implementation costs and risks associated with other approaches. This
   white paper examines the need for data access accountability and the alternative approaches to
   meeting that need. To facilitate evaluation of solutions for data access accountability, a checklist
   of questions and issues to be considered is offered.

The Problem
   Databases are a critical component of today’s systems, and data integrity is a paramount concern
   for anyone responsible for those databases. The task of safeguarding data assets is multi-faceted,
   but a central aspect is ensuring that: 1) data is changed only in intended ways, and 2) only the
   proper parties view the data.

   Implementing suitable privacy and security policies and mechanisms is an important step, but it does
   not address two important realities:

       1) even authorized users will sometimes access data inappropriately, whether deliberately or
          accidentally, and

       2) flaws in policy and implementation can introduce vulnerability, enabling unintended data
          access or database changes.
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These realities speak to the importance of data access accountability, that is, the ability to deter-
mine who did what to which data when, and by what means. This capability allows an organization to:

•   comply with government regulations regarding the security and privacy of certain kinds of data
    (e.g., HIPAA, GLBA, FDA Title 21 CFR Part 11, EU DPA )

•   comply with internal corporate processes; understand and improve internal business processes

•   detect and analyze breaches in user and application behavior, intentional or accidental

•   perform forensic analysis for detecting fraud, outsider intrusion, and employee misbehavior

•   rapidly respond to violations and vulnerabilities

•   verify strategic partner activities

•   verify third-party application behavior

•   answer ad hoc business questions

•   satisfy external due diligence for strategic relationships or customer confidence.

Technology is key to meeting these challenges. An organization with any of these requirements
should engage in a problem analysis lifecycle similar to the following:

•   identify applicable strategic and regulatory requirements
•   analyze existing policies and technologies to
    identify aspects of inadequate coverage
•   update policies and procedures toward compli-
    ance                                                    IT requirements for
                                                            data access accountability
•   educate staff and partners on new policies and
    procedures                                              •   be notified when someone changes data-
•   identify changes to technology infrastructure to            base schema or permissions
    support implementation and verification of new          •   keep a record of all changes to schemas
    policies and procedures                                     and permissions
                                                            •   know what data was changed, when, and
•   implement new systems
                                                                by whom
•   validate the behavior of the new systems.
                                                            •   know who has viewed certain data and
                                                                when
In the end, because technical systems are involved in
storing data, technical systems must be involved in         •   generate periodic reports on who accessed
                                                                certain tables
safeguarding the data. To address this the IT staff
will have the following requirements.                       •   investigate suspicious behavior on certain
                                                                tables
                                                            •   know who modified a set of tables over a
                                                                period of time
                                                            •   automate procedures across multiple
                                                                servers
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Elements of an Effective Solution
         How a data access accountability solution captures the appropriate data for an audit trail is as impor-
         tant as determining what data should be captured. Once the appropriate level of detail for the audit
         trail is determined, an effective solution should provide confidence that: all the relevant activities
         that create, modify or delete data will be captured, and activities will not inadvertently be omitted
         from the audit trail.

An effective solution providing data access accountability must include
these capabilities:

Capture data access                 automatically track whenever data is modified or viewed by any means on
                                    target databases, preferably with control over the granularity of data tracked

Capture structural changes          automatically track changes both to the permissions that control data
                                    access and to database schema (to ensure ongoing integrity of the struc-
                                    tures storing data)

Manage captured information         automatically collect the tracked information from multiple databases into an
                                    easily managed, long term, common repository

Centralized configuration &         provide a straightforward way to configure auditing of all of the target
management of all servers           servers, specify the activities of interest, the repository for managing the
                                    information, and the schedule for transferring data

Flexible information analysis       provide flexible and efficient means for processing the stored information to
                                    identify activities of interest

Produce reports                     ad hoc and periodic exporting of analysis results in a variety of formats, for
                                    display, printing, and transmission

Detecting conditions of             automatically monitoring for conditions of interest and generating
interest for notification           selected alerts.

Capturing Data Activity — The Key to an Effective
Solution
         Current approaches to data access accountability are subject to common pitfalls that may, over
         time, create potential compliance risk or increase the costs of implementing compliance with the
         business requirement or regulation. These approaches include application modification, mid-tier
         portals, and trigger-based collection at the data source.

         Application modification

         This entails changing the source code of every application that might be used to access the data of
         interest. Each application is changed so that it captures data modification and viewing information
         and stores it for further processing.
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Because each application must be modified, application modification can substantially increase the
implementation cost of compliance with data auditing requirements. This may be especially true
where legacy systems must be brought into compliance. In addition, because the approach requires
each application to be modified and does not capture activity outside the modified application, this
approach reduces confidence in the ability to capture a complete audit trail. The audit trail may be
incomplete because operations not handled by the modified applications may be missed, or because
the audit does not record access directly to the underlying database.

The application modification approach may create security vulnerability or risk because of the inabili-
ty to capture changes to permissions and schema. Recording who creates, modifies or deletes data
is critical to establishing responsibility and accountability for actions initiated. If the audit trail does
not capture changes to permissions, it becomes possible to alter who has legitimate authorization to
create, modify or delete data. If the audit trail does not capture changes to schema, the door is open
to unauthorized alteration of what data is captured.

In summary then, the application modification approach has several implications:

•   each application must be modified (or, if that is not possible, the application must be replaced)
•   planning, implementing, and testing these changes is costly and time-consuming, and it is diffi-
    cult to guarantee complete coverage
•   access outside of the modified applications (e.g., via a database administrative console) is not
    captured, implying incomplete coverage
•   changes to permissions and schema cannot be captured by this means.

Mid-tier portal

Some application architectures funnel access to data through a shared portal that is responsible for
backend access. This portal could be modified to capture and store data access information.

As with the application modification approach, the mid-tier portal approach to Data Access
Accountability may pose potential compliance risks. Operations and access outside of the portal
enabled applications may not be captured by the audit trail. And implementation costs may increase,
because other approaches to creating audit trails would be needed where data were not created,
modified or deleted through portal-enabled applications. This limitation of the portal approach may
make it an especially inappropriate solution for many legacy systems that contain data subject to the
data auditing requirement.

Because the portal approach does not capture changes to permissions and schema, critical security
risks or vulnerabilities may arise. Like the risks and vulnerabilities associated with application modifi-
cation, the portal approach creates the potential for unauthorized changes to levels of access or to
unauthorized alterations to the scope of content captured for auditing requirements.

In summary, while the portal approach avoids the modification of individual applications, it has three
substantial drawbacks:

•   it only works for portal-enabled applications
•   it cannot capture access outside of that passing through the portal
•   it cannot capture changes to permissions and schema.
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   Trigger-based collection at the data source

   Most users dread the traditional way of capturing data modifications, using triggers (special-purpose
   application logic) on the database. Triggers have a number of drawbacks:

   •   they are often hard to write correctly
   •   they add substantial runtime performance overhead (because they execute in line with transac-
       tions, reducing throughput)
   •   fear of this overhead leads DBAs to minimize the number of modifications recorded or the period
       over which they are recorded
   •   they cannot capture data views
   •   they cannot capture changes to schema and permissions.

   Non-trigger tracking at the data source

   In this approach, non-trigger audit agents are associated with each database server containing
   important data. These audit agents are responsible for harvesting information about data-related
   activity, and because they operate at the database server, they capture all relevant data activity,
   regardless of the application used. In addition, applications need not be modified to accommodate
   this approach. The audit agents harvest information through two primary means:

   •   reading the database transaction log, which each database maintains in the normal course of its
       operation, for data modifications. This does not interfere with the timely execution of transac-
       tions, because the analysis can be time-shifted or carried out on machines other than the one
       hosting the target database.
   •   using the database’s built-in event notification mechanism to obtain a record of permission
       changes, schema changes, and data views.

Introducing Lumigent® Entegra™
   An effective data access accountability solution should enable an organization to meet their data
   auditing requirements while avoiding the common pitfalls of current approaches. Entegra provides
   both a complete record of data activity and active monitoring and alerting, enabling answers to the
   questions “who did what to which data when, and by what means?” These capabilities help the IT
   staff and DBAs to solve the previously identified business problems and operational needs, and form
   the core of sound data integrity and accountability practices.

   In the Entegra approach, non-trigger audit agents are associated with each database server where
   data access and data changes need to be captured. These audit agents are responsible for harvest-
   ing information about data activity, and because they operate at the database server level, they cap-
   ture all relevant data activity regardless of the application used. The design features and capabilities
   of Entegra reduce the potential for increased costs and risks associated with other approaches to
   data access accountability.
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The following components appear in a fully configured Entegra deployment:

•   Audit Agent: attached to a database server, the audit agent is responsible for harvesting desired
    information about data modification, data viewing, and structural activity on that server. The
    audit agent is application independent, though tailored for each database platform. Together with
    the Management Console component, this enables Entegra to be configured to capture data for
    the audit trail as determined by the applicable predicate rule and type of operation relevant to
    the electronic records. The audit agent
    also provides real-time notification of
                                                   A complete record of data activity
    structural changes.
                                                    provides:
•   Repository: the repository receives and
    stores the information reaped from the          •   Compliance – Archival record of access to data and
    audit agent(s). Together with the                   of schema and permissions changes
    Archive component, this prevents the            •   Verification – Validate activity on data and schema
    audit trail from obscuring existing             •   Security – Reliable independent source of access
    records and enables copies of the audit             and change history to identify responsible application
    trail to be produced for review.                    and user
•   Management Console: the console deter-          •   Investigation – Enable damage assessment, fraud
    mines the schedule and configuration of             detection, forensics
    each audit agent for harvesting and
    transferring information to the reposito-       Active monitoring and alerting provides:
    r y. Together with the Audit Agent com-
                                                    •   Security – Reliable notification of changes to permis-
    ponent, this enables Entegra to be con-
                                                        sions, which can provide validation of proper activity
    figured to capture data for the audit
                                                        or an early indication of malicious intent, violations,
    trail as determined by the applicable               and vulnerabilities
    predicate rule and type of operation rel-
                                                    •   Integrity – Reliable notification of change to structure
    evant to the electronic records.
                                                        permits verification of correct implementation and
•   Report server with browser interface: the           rapid response to incorrect changes.
    report server provides secure mecha-
    nisms for processing the repository for
    query, analysis, and reporting. The report engine provides a familiar, richly featured, web-based
    user interface for highly interactive analysis of the repository information. This enables analysis
    of data activity and copies of audit trails to be produced for review.
•   Archive: the archive provides long-term storage of access information from multiple repositories.
    Together with the Repository component, this prevents the audit trail from obscuring existing
    records and enables copies of audit trails to be produced. The archive can be maintained for any
    given amount of time, which may be dictated by the data auditing requirement.
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Conclusion
   The ideal technology solution to address compliance and regulatory requirements depends on an
   effective data capture capability. The best approach minimizes performance overhead while providing
   a complete audit of data access, as well as active monitoring and alerting. A number of approaches
   may be considered, though many have shortcomings that negatively impact system performance
   and/or require additional technical resources.

   All things considered...

   In parallel with the development of policies, procedures, and technical requirements, it is critical to
   evaluate solutions that effectively capture and audit data access.

   The following checklist is offered to facilitate evaluation of data access accountability solutions:

   •   Is data access capture complete (no backdoors through which a user may access data without
       being detected)?
   •   What is the cost of deployment?
   •   Does the solution use triggers (may impact performance)?
   •   Does the solution require application software modification (time-consuming)?
   •   Is it easy to administer?
   •   Is there a single console for configuration and scheduling across multiple database platforms?
   •   Is there a common repository and long-term archival support?
   •   Does it provide a complete modification history?
   •   Does the solution “alert” on critical database changes (schema and permissions)?
   •   Does the approach support multiple platforms?

   About the Author:

   Dr. Murray S. Mazer is co-founder, Vice President, and CTO of Lumigent Technologies, creators of the
   award-winning Log Explorer® technology. Dr. Mazer has 20 years of experience at early stage and
   established companies. He is an inventor and expert witness in several different software technology
   areas. Dr. Mazer received his Ph.D. from the University of Toronto for his work within the database
   group. He can be reached at murray.mazer@lumigent.com.

   For more information please visit www.lumigent.com

   © 2002, Lumigent Technologies, Inc. All rights reserved.
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