Every audit is about deeply understanding a technology platform and the people who are responsible for it. That process is as unique as the project itself, but we tend to ask a standard set of questions to ensure that nothing gets overlooked.
Drawing data out
- What does your log pipeline look like? (e.g. Fluentd, Logstash, Elasticsearch)
- How long are logs retained for?
- What’s the log latency from capture to analysis?
- What data is redacted from the logs and where in the pipeline?
- What container-level, host-level or environment-level data is logged?
Application log analysis
- What technologies do you use to analyse logs? (e.g. Kibana)
- Who supports the application?
- Are the developers involved and if so at what ‘line’?
- Who has access to application logs (in different environments)?
- What IDs are related log entries joined by?
- Who is responsible for the logs, their readability, utility and insights?
Security log analysis
- How are attacks detected?
- Once detected, how is an attack understood?
- How are threat actors identified and blocked?
- Do you receive or subscribe to any threat analysis services? If so, how do you act on that information?
- Do you conduct any pattern analysis on logs to identify new threats?
- Which (IdP) systems on your network conduct user authentication (validating who they are) and authorisation (giving them permission to do things)?
- Are all access attempts on IdP systems logged?
- Who is responsible for reviewing, categorising and (where appropriate) verifying failed access attempts?
- How do you profile application performance?
- What technologies do you use for APM? (e.g. Stackify, Dynatrace)
- Where are the known bottlenecks in your application?
- When do you conduct optimisation?
- What source control do you use? (e.g. GitHub)
- What’s your branching strategy?
- Where are different branches deployed?
- How are production branches identified?
- What systems refer to your source control system?
- How does the build process work?
- What software orchestrates the build process? (e.g. Jenkins)
- What artifacts are produced by the build?
- How are tested changes merged into the codebase?
- Is there a static/dynamic code review performed on each merge?
- Are any code quality tests run as part of a merge?
- What tools are used to handle configuration management? (e.g. Puppet, Ansible, Chef)
- What configuration logs are kept?
- Can administrators directly access production systems?
- How much manual intervention is required during environment provisioning?
Artifact management (e.g. Artifactory)
- How are static assets handled?
- How is the code versioned?
- How are tags/identifiers/names used to connect artifacts with source versions?
- Where are version:environment deployment logs kept?
Deployments and environments
- What environments do you maintain for the product/project?
- What is the path to live through those environments?
- Are there any shared environments used by multiple projects or their administration?
- How are new environments provisioned?
Continuous Deployment (e.g. Jenkins)
- How are builds deployed to production?
- Does the deployment process vary for dev, test, staging or production?
- What deployment strategies do you use into production? (e.g. Rolling/Canary/Recreate)
- How do you handle breaking changes? (e.g. a breaking schema update on the database)
Container hosting (e.g. Docker)
- Do you use containers in dev?
- Do you use containers in production?
- Upon what image do you base your containers?
- How are containers built?
- How do you orchestrate your containers in production? (e.g. Kubernetes, Docker Swarm)
- What degree of control do you have over the orchestration layer?
- How do you handle platform updates?
- How is access controlled to the platform?
Machines and services
Subscribed service provisioning (e.g. CloudFormation for AWS RDS/Lambda/DynamoDB)
- What subscription-based services do you use in favour of building/running/managing yourself?
- To what extent are you dependent upon those services?
- What SLAs do you have in place with those vendors?
- How do you manage the risks associated with vendor lock-in?
- What tools do you use for machine provisioning? (e.g. Terraform)
- Is that provisioning idempotent (reliably repeatable as exactly once) or are there uncontrolled environmental/human influences?
- How is your infrastructure versioned?
- How is provisioning state handled? (e.g. local, S3 bucket, other - Atlas)
- For self-managed hosts, how are operating systems and application servers patched?
- How do you stage those patches before releasing into production?
- To what extent are you exposed to upstream changes? (e.g. NPM left-pad chaos)
- If using a gold OS build, how are older systems up-levelled to the latest gold build?
Secure base operating system
- For self-managed hosts, where do you source the base operating system image?
- What hardening do you undertake of the image?
- What additional tools do you install on all hosts?
- Do you maintain your own gold build, or if not how do you standardise at the OS level?
- What information is classified as secret?
- Where are secrets stored?
- What technology is used to store and protect secrets? (e.g. Vault or KMS)
- How are limited-lifetime secrets (e.g. certificates) rotated?
- Who is allowed access to the secret management system?
- How are machines granted access to secrets?
- Where else are secrets persisted and in what state (encoded/encrypted)?
Off-cloud access and LAN integration (e.g. AWS DirectConnect)
- How do engineers access your production systems?
- What separation exists between your local area network (LAN) and the production network?
- What kind of external access is available to your staff? How is that restricted?
People and processes
[Maintenance] User management
- Who has access to your production systems?
- Under what situations is access granted?
- How is access controlled?
- How are maintenance users separated from application users?
- Can administrators masquerade as application users or perform operations as-if them?
- Is the system broken into services and if so, at what granularity? (e.g. Monolith, microservices, nano-services)
- When segmenting a system
- Is the system architecture horizontally scalable?
- How do you decouple your services?
- What jobs/tasks/operations are handled asynchronously?
- How do you handle sync-async transitions when users (synchronous web requests) encounter those asynchronous tasks?
- How do you assess good vs bad architecture?
- How does are requirements identified and managed?
- Who performs business analysis and what level of domain knowledge do they have?
- How is change managed, who originates a ‘change’ and tracks it?
- What does knowledge management mean to you team?
- Ticket management
- How are incidents managed?
- Do you perform retrospective analysis (or RCA) on incidents?
- Do you rate the severity of each incident?
- What response times do you aim to hit for an incident? How do these vary by severity?
- What is your service Recovery Point Object (RPO, how old can the data be from the backups)?
- What is your service Recovery Time Object (RTO, how quickly can you recover from a disaster)?
- Is your incident management process linked to your Security Log Analysis and Data Integrity Management/data breach detection processes?
- How empowered are your architects, developers, testers and other engineers to make technical decisions?
- What kind of governance process exists to manage technical decision making?
- How are decisions evaluated, logged and disseminated?
- Who is responsible for assessing the business impact of technical decisions?
General Data Protection Regulation (GDPR)
- Where and how is your data stored?
- If you store backups, where and how are they stored?
- How is data encrypted in-transit and at-rest?
Data privacy and consent
- What types of data are being captured and which of these is kept?
- How do you identify personal data?
- Have you included in your data management processes all employee data too?
- How long is the personal data retained for?
- Do you maintain a clear set of terms and conditions that cover data privacy? How often is this reviewed?
- Do you have a log of when each user accepted those terms, by version?
- What provision do you make for users requesting access to their data?
- What provision do you make for users to request the removal of their data?
- Do you follow privacy-by-design, and if so how does that relate to your Governance and Software Architecture processes?
- Do you have data on children? How do you verify their age and get guardian approval?
- Who is authorised to view/edit/delete the data?
- What physical safeguards exist to limit that access to those who are authorised?
- What virtual/digital safeguards exist to limit that access to authorised users?
- Who is the Data Controller and the Data Protection Officer?
- Who is responsible in the organisation for GDPR regulations and compliance?
- Can you provide a document to clearly explain all data flows and touch points with your systems or staff?
- Do you maintain a current list of the outsourcers and partner who collect, manage, process or in some other way have access to data on your behalf?
- Does this list include all the Cloud services your staff use on a daily basis?
- Do you have a clear understanding of their policies and procedures for handling data?
- How do you handle shadow IT (services that are used without being run/managed by your central IT function)?
- How do you manage staff training around your IT systems and their regulatory or compliance obligations?
- What mechanisms do you have in place to detect data breaches?
- Do you have a communication plan in place to enact in the event of a data breach?
Payment Card Industry Data Security Standard (PCI DSS)
- Does the service interact in any way with card payment processing?
- Does it control how consumers are redirected to a validated third-party service provider?
- Have you reviewed the relevant Self-Assessment Questionnaire (SAQ) for PCI compliance?
- Do you already know which SAQ classification you fall into:
- SAQ A. Card-not-present, all cardholder data functions are fully outsourced
- SAQ A-EP. Partially outsourced eCommerce using a third-party website for payment processing
- SAQ B. Imprint or standalone machines (including B-IP and P2PE), no electronic cardholder data storage (not applicable to eCommerce channels).
- SAQ C. Payment Application Systems connected to the Internet or Web-based virtual terminals (C-VT), no electronic cardholder data storage (not applicable to eCommerce channels).
- SAQ D. All other merchants/service providers
- How do you manage service providers with whom cardholder data is shared/made accessible?
- What legal documentation do you maintain with/for them?
- How do you engage them? What due diligence do you conduct?
- How do you monitor their compliance? (e.g. annual assessment)
- How do you distribute your PCI DSS requirements across those service providers?
Choosing between SAQ A and SAQ A-EP can be difficult, but there is help in the Understanding SAQs guidance.
- Do all elements of payment pages originate from the third-party service provider?
- How does the system link to or embed the third-party payment processing service provider?
- How and where is the payment form created?
- Do you store any cardholder data, such as Primary Account Number (PAN), expiration date, cardholder name or CV2?
- If so, do you store it electronically or in hardcopy? Name all the places where this data is stored.
- Do you receive any reports or receipts featuring cardholder data?
- For each physical data storage location:
- How are the media secured?
- How do you restrict physical access to the media?
- How is distribution controlled?
- How is the media classified, transmitted, approved for access or transmission, destroyed after use, stored prior to destruction etc.?
- For each electronic storage location (including storage locations managed by a third-party service provider):
- How do you define the Cardholder Data Environment (CDE)?
- If hosted on a non-networked computer, how is the host machine isolated?
- If hosted on a networked computer, how is the network segmented?
- If hosted by a networked third-party:
- How is your office network segmented?
- How is the system segmented from the third-party service provider?
- Which employees have access to cardholder data?
- What audit process wraps their access to it?
- What credentials are required for their access?
- How are those credentials secured (e.g. password requirements)? How and when are they rotated?
- Do you have a policy that covers information security?
- How often are staff trained in information security and how is that logged?
- How do you meet the SAQ A requirements?
- 9 Restrict physical access to cardholder data
- 12 Maintain a policy that addresses information security for all personnel?
SAQ A-EP and SAQ D
- In addition to SAQ A above, how do you meet the SAQ A-EP/D requirements?
- 1 Install and maintain a firewall configuration to protect data
- 2 Do not use vendor-supplied defaults for system passwords and other security parameters
- 3 Protect stored cardholder data
- 4 Encrypt transmission of cardholder data across open, public networks
- 5 Protect all systems against malware and regularly update anti-virus software or programs
- 6 Develop and maintain secure systems and applications
- 7 Restrict access to cardholder data by business need to know
- 8 Identify and authenticate access to system components
- 10 Track and monitor all access to network resources and cardholder data
- 11 Regularly test security systems and processes
There is no substitute for a thorough compliance assessment against GDPR and PCI DSS conducted by a Qualified Security Assessor (QSA), but these questions are a useful indicator of a business’s readiness. Any formal PCI assessment should begin with the PCI DSS Self-assessment questionnaire.
- Do you provide any recommendations, guidelines or rigid technical standards to your development teams?
- What Key Performance Indicators (KPIs) do you monitor for the technical team’s output?
- Who decides the distribution of functional responsibility across the code?
- How are those design decision disseminated?
- What design patterns are used in the code?
- How do you ensure consistency of approach in a multi-developer team?
- What log-levels does the code issue messages at?
- How verbose and accurate are those messages at each level?
- How relevant are the messages, specifically in relation to user journeys, tests, documented requirements, operation needs?
- What level of unit test coverage is acceptable?
- What is the current level of test coverage?
- Do you practice test-driven development?
- What is the balance between unit tests and integration tests?
- Who performs system testing?
- How are user acceptance tests written and executed and by whom?
- What standards do you enforce around commenting?
- What value do you ascribe to doc blocks or inline comments?
- What documentation do you maintain and how does that link to the source?
- Tabs or spaces? (Only kidding)
If you’d like Lightenna to audit some part of your digital estate, or conduct some due diligence on an investment that you’re considering, please get in touch.