NCUA Regulatory Compliance

Access Rights Administration

According to FFIEC:

Financial institutions should have an effective process to administer access rights. The process should include:

• Assigning users and devices only the access required to perform their required functions,
• Updating access rights based on personnel or system changes,
• Reviewing periodically users' access rights at an appropriate frequency based on the risk to the application or system ...

Encryption and Key Management

FFIEC also notes:

• Encryption
  Financial institutions should employ an encryption strength sufficient to protect information from disclosure until such time as the information's disclosure poses no material threat. …. Decisions regarding what data to encrypt and at what points to encrypt the data are typically based on the risk of disclosure ….Encryption may also be used to protect data in storage. The implementation may encrypt a file, a directory, a volume, or a disk.
• Encryption Key Management
  Since security is primarily based on the encryption keys, effective key management is crucial. Effective key management systems are based on an agreed set of standards, procedures, and secure methods that address Source: ISO 17799, 10.3.5.2

Security Monitoring

In addition, FFIEC offers guidelines for security monitoring.

Financial institutions should gain assurance of the adequacy of their risk mitigation strategy and implementation by:

• Monitoring network and host activity to identify policy violations and anomalous behavior;
• Monitoring host and network condition to identify unauthorized configuration and other conditions which increase the risk of intrusion or other security events;
• Analyzing the results of monitoring to accurately and quickly identify, classify, escalate, report, and guide responses to security events; and
• Responding to intrusions and other security events and weaknesses to appropriately mitigate the risk to the institution and its customers, and to restore the institution's systems.

Limit Access to Only Those Who Need to See the Data to Do Their Jobs

Thales’ Vormetric Data Security Platform and SafeNet Multi-Factor Authentication provide state of the art user access control.

• Separation of privileged access users and sensitive user data. With the Vormetric Data Security Platform, administrators can create a strong separation of duties between privileged administrators and data owners. The Vormetric Data Security Platform encrypts files, while leaving their metadata in the clear. In this way, IT administrators—including hypervisor, cloud, storage, and server administrators—can perform their system administration tasks, without being able to gain privileged access to the sensitive data residing on the systems they manage.
• Separation of administrative duties. Strong separation-of-duties policies can be enforced to ensure one administrator does not have complete control over data security activities, encryption keys, or administration. In addition, the Vormetric Data Security Manager supports two-factor authentication for administrative access.
• Granular privileged access controls. This Thales solution can enforce very granular, least-privileged user access management policies, enabling protection of data from misuse by privileged users and APT attacks. Granular privileged user access management policies can be applied by user, process, file type, time of day, and other parameters. Enforcement options are very granular; they can be used to control not only permission to access clear-text data, but what file-system commands are available to a user.
• SafeNet multi-factor authentication from Thales secures access to corporate networks, protecting the identities of users, and ensuring that a user is who he or she claims to be.

Protect the Data a Rest

Thales protects the data itself through Vormetric Transparent Encryption with integrated Key Management for data at rest, Application Encryption, Tokenization with Dynamic Masking and more. These techniques make the data meaningless and worthless without the tools to decrypt it.

Protect the Data in Motion

Thales' SafeNet FIPS-certified network encryption devices offer proven high-assurance network security for your sensitive data in motion, including real-time video, and voice.

Monitor Access to Data

Thales enables the credit union to monitor and identify extraordinary data access. Vormetric Security Intelligence provides detailed management logs that specify which processes and users have accessed protected data. The detailed management logs specify when users and processes accessed data, under which policies, and if access requests were allowed or denied. The management logs will even expose when a privileged user submits a command like 'switch users' in order to attempt to imitate, and potentially exploit, the credentials of another user.

Sharing these logs with a security information and event management (SIEM) platform helps uncover anomalous patterns in processes and user access, which can prompt further investigation. For example, an administrator or process may suddenly access much larger volumes of data than normal, or attempt to do an unauthorized download of files. These events could point to an APT attack or malicious insider activities.