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#CiscoChampion Radio S2|Ep 18. Securing ACI

CiscoChampion200PXbadge#CiscoChampion Radio is a podcast series by Cisco Champions as technologists. Today we’ll be talking about securing ACI with Cisco Technical Marketing Engineer Carly Stoughton.

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Carly Stoughton, @_vCarly, Cisco Technical Marketing Engineer

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Batman, TrustSec, and PCI

One of my passions is around PCI compliance. I know that sounds oxymoronic. How can someone actually be passionate about something as dry as compliance? Well, for the sake of argument, I prefer delusional rationalization. I think of myself as Batman! I don’t have his intelligence, money, car, or cape (well, I do have the cape, but that is another story), but I DO want to fight injustice where I can. I do think that there are bad guys out there trying to steal my family’s hard earned money. PCI compliance is the leading method for securing the world’s payment systems. The bad guys are real, security is getting harder, and I want to fight on the side of good.

The problem with fighting crime with compliance is that it can be so complex. The general strategy to minimize the complexity of PCI compliance is to use segmentation. Segmentation typically involves putting credit card applications and devices onto its own network, and use traditional firewalls to secure the perimeter. Although effective, this method brings about its own headaches around management. Firewall rulesets can become tedious and complex. Readdressing an entire enterprise with the sole driver of compliance is Herculean. Over time, if not properly managed and sustained, this method, can lead to bloat, misconfiguration, or worse, a breach.

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9 of 9 HIPAA Network Considerations

The HIPAA Omnibus Final Rule is now in effect and audits will continue in 2014. The Department of Health and Human Services’ Office for Civil Rights has stated several times that both Covered Entities and Business Associates will be audited.  And the scope of Business Associates has greatly expanded.  I wrote another blog directed towards these new Business Associates.  This final blog of this series focuses on covered entities that work with business associates.

  1. HIPAA Audits will continue
  2. The HIPAA Audit Protocol and NIST 800-66 are your best preparation
  3. Knowledge is a powerful weapon―know where your PHI is
  4. Ignorance is not bliss
  5. Risk Assessment drives your baseline
  6. Risk Management is continuous
  7. Security best practices are essential
  8. Breach discovery times: know your discovery tolerance
  9. Your business associate(s)must be tracked

The HIPAA Omnibus Final Rule changed the Business Associate definition, and also makes Business Associates obligated to comply with HIPAA.  You most likely will have more business associates than previously, and those business associates that have access to your network and/or your PHI data are obligated to be HIPAA compliant.    The Ponemon Institute’s Third Annual Benchmark Study on Patient Privacy and Data Security (December 2012), reveals that 42% of the breaches involved a third party “snafu”.

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8 of 9 HIPAA Network Considerations

Discovering a breach where ePHI has been stolen certainly falls into the ‘not a good day at work’ category.  It can be catastrophic for some, especially if the compromise occurred months ago and wasn’t detected.  Or if a 3rd party discovered the breach for you, which occurs more often than we think, 47-51% from 2010 – 2012 based on the Ponemon Institutes 3rd Annual Benchmark Study on Patent Privacy and Data Security.

On our list of 9 HIPAA Network Considerations, we are onto topic #8, Breach discovery times: know your discovery tolerance.

  1. HIPAA Audits will continue
  2. The HIPAA Audit Protocol and NIST 800-66 are your best preparation
  3. Knowledge is a powerful weapon―know where your PHI is
  4. Ignorance is not bliss
  5. Risk Assessment drives your baseline
  6. Risk Management is continuous
  7. Security best practices are essential
  8. Breach discovery times: know your discovery tolerance
  9. Your business associate(s)must be tracked

From the 2013 Verizon Data Breach Investigations Report, two thirds of the compromises were not discovered for months, or longer.  What is your tolerance for “not knowing?”  Can that discovery time tolerance be justified through reasonable due diligence, or are you back at the “ignorance is bliss” phase (blog #4), which could be interpreted as Willful Neglect in the case of a breach of PHI?

Source: Verizon 2013 Data Breach Investigations Report

Source: Verizon 2013 Data Breach Investigations Report

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7 of 9 HIPAA Network Considerations

The HIPAA Omnibus Final Rule is now in effect and audits will continue in 2014. At the HIMSS Privacy and Security Forum in Boston on Sept. 23, Leon Rodriguez, director of the Department of Health and Human Services’ Office for Civil Rights said to those who are wondering how the new rule will be enforced: “You’ll see a picture of where we’ll spend our energies” based on previous enforcement actions.  Enforcement actions to date have focused on cases involving major security failures, where a breach incident led to investigations that revealed larger systemic issues, Rodriguez said.

On our list of 9 HIPAA Network Considerations, it is timely that our topic in this blog is on #7, Security best practices are essential.

  1. HIPAA Audits will continue
  2. The HIPAA Audit Protocol and NIST 800-66 are your best preparation
  3. Knowledge is a powerful weapon―know where your PHI is
  4. Ignorance is not bliss
  5. Risk Assessment drives your baseline
  6. Risk Management is continuous
  7. Security best practices are essential
  8. Breach discovery times: know your discovery tolerance
  9. Your business associate(s)must be tracked

The general rule for the HIPAA Security Rule is to ensure the confidentiality, integrity, and availability of ePHI that is created, received, maintained, or transmitted [45 CFR 164.306(a)].  Protect against threats to PHI.  That relates directly to network security best practices.  In the 2012 HIPAA audits, security had more than its share of findings and observations, accounting for 60% of the HIPAA audit findings and observations, even though the Security Rule accounted for only 28% of the audit questions.  At the NIST OCR Conference in May, OCR presented the summary below.

7 of 9

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