30(a) Security Policy: Summary of the security policy for the proposed registry
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|.REIT||National Association of Real Estate Investment Trusts, Inc.||nareit.com||View|
Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic.
CentralNicʹs Information Security Management System (ISMS) implements all the mandatory requirements of the EIC⁄ISO 27001:2005 standard. The scope of the management system covers all of CentralNicʹs registry systems and facilities. CentralNic is working towards achieving full ISO 27001 certification and has secured the services of Lloydʹs Register Quality Assurance (LRQA) for this certification. A letter from LRQA confirming this engagement is included in Appendix 30(a).1. Stage One of this process was successfully completed during May of this year and Stage Two of the assessment is scheduled to be completed by July 10th. CentralNic will provide a copy of the assessment report to ICANN for consideration, and a copy of the certificate once it has been issued.
The ISMS is part of a larger Management System which includes policies and procedures compliant to ISO 9001.
30(a).2. Independent Assessment
As part of ISO 27001 compliance, CentralNicʹs security policies will be subjected to annual external audit. Further details can be found in §30(b).
30(a).3. Augmented Security Levels
Applicant believes that the TLD requires no additional security levels above those expected of any gTLD registry operator. Nevertheless, Applicant and CentralNic will operate the TLD to a high level of security and stability in keeping with its status as a component of critical Internet infrastructure.
Registry systems are hardened against attack from external and internal threats. Access controls are in place and all systems are monitored and audited to mitigate the risk of unauthorised access, distribution or modification of sensitive data assets. The Authoritative DNS System has been designed to meet the threat of Distributed Denial-of-Service (DDoS) attacks by means of over-provisioning of network bandwidth, and deployment of Shared Unicast (ʺAnycastʺ) addresses on nameservers. Whois services have been designed with built-in rate limiting and include mechanisms for protection of personal information. The stability of the registry is supported by use of high-availability technologies including a ʺhotʺ Disaster Recovery site in the Isle of Man, as well as a backup provider relationship with GMO Registry in Japan.
30(a).4. Commitments to Registrars
Applicant and CentralNic will make the following commitments to the TLD registrars:
The SRS will be operated in a secure manner. Controls will be in place to prevent unauthorised access and modification of registry data.
The Whois service will prevent unauthorised bulk access to domain name registration data, and provide tools to protect personal information.
The DNS system will be designed to provide effective defence against DDoS attacks. The registry will proactively monitor the DNS system to provide early warning against threats to the stability of the TLD.
The DNSSEC system will be operated in accordance with best practices and recommendations as described in the relevant RFC documents (described in §43).
Security incidents reported by registrars, registrants and other stakeholders will be acted upon in accordance with the Security Incident Response Policy (see below).
Security vulnerabilities reported to the registry will be acknowledged and remediated as quickly as possible.
Registrars will be promptly notified of all incidents that affect the security and stability of the registry system and their customers, and will be kept informed as incidents develop.
30(a).5. Access Controls
CentralNic operates an access control policy for the registry system. For example, the web-based Staff Console which is used to administer the SRS and manage registrar accounts supports a total of ten different access levels, ranging from ʺTraineeʺ, who have read-only access to a subset of features, to ʺSystem Administratorʺ who have full access to all systems.
Underlying server and network infrastructure is also subjected to access control. A centralised configuration manager is used to centrally control access to servers. Individual user accounts are created, managed and deleted via the configuration server. Access to servers is authenticated by means of SSH keys: only authorised keys may be used to access servers. Operations personnel can escalate privileges to perform administration tasks (such as updating software or restarting daemons) using the ʺsudoʺ command which is logged and audited as described below.
Only operations personnel have access to production environments. Development personnel are restricted to development, staging and OT&E environments.
30(a).6. Security Enforcement
Security controls are continually monitored to ensure that they are enforced. Monitoring includes use of intrusion detection systems on firewalls and application servers. Attempted breaches of access controls (for example, port scans or web application vulnerability scans) trigger NOC alerts and may result in the execution of the Security Incident Response Policy (see below).
Since CentralNic operates a centralised logging and monitoring system (see sect42;), access logs are analysed in order to generate access reports which are then reviewed by NOC personnel. This includes access to servers via SSH, to web-based administration systems, and to security and networking equipment. Unexpected access to systems is investigated with a view to correcting any breaches and⁄or revoking access where appropriate.
30(a).8. Security Incident Response Policy
CentralNic operates a Security Incident Response Policy which applies to all events and incidents as defined by the policy, and to all computer systems and networks operated by CentralNic.
The Policy provides a mechanism by which security events and incidents are defined (as observable change to the normal behaviour of a system attributable to a human root cause). It also defines the conditions under which an incident may be defined as escalated (when events affect critical production systems or requires that implementation of a resolution that must follow a change control process) and emergencies (when events impact the health or safety of human beings, breach primary controls of critical systems, or prevent activities which protect or may affect the health or safety of individuals).
The Policy established an Incident Response Team which regularly reviews status reports and authorises specific remedies. The IST conduct an investigation which seeks to determine the human perpetrator who is the root cause for the incident. Very few incidents will warrant or require an investigation. However, investigation resources like forensic tools, dirty networks, quarantine networks and consultation with law enforcement may be useful for the effective and rapid resolution of an emergency incident.
The Policy makes use of CentralNicʹs existing support ticketing and bug tracking systems to provide a unique ID for the event, and means by which the incident may be escalated, information may be reported, change control processes put into effect, and ultimately resolved. The Policy also describes the process by which an incident is escalated to invoke an Emergency Response, which involves Lock-Down and Repair processes, monitoring and capturing of data for forensic analysis, and liaison with emergency services and law enforcement as necessary.
30(a).9. Role of the Network Operations Centre (NOC)
In addition to its role in managing and operating CentralNicʹs infrastructure, the NOC plays a key role in managing security. The NOC responds to any and all security incidents, such as vulnerability reports received from registrars, clients and other stakeholders; monitoring operator and security mailing lists (such as the DNS-OARC lists) to obtain intelligence about new security threats; responding to security-related software updates; and acting upon security alerts raised by firewall and intrusion detection systems.
30(a).10. Information Security Team
CentralNic maintains an Information Security Team (IST) to proactively manage information security. The IST is a cross-functional team from relevant areas of CentralNic. These key members of staff are responsible for cascading rules, regulations and information to their respective departments. They are also the first port of call for their departmental staff to report potential security incidences and breaches, the IST are all members of an internal email group used to co-ordinate and discuss security related issues.
The IST is comprised of the CEO, CTO, Operations Manager, Senior Operations Engineer and Security Engineer.
IST responsibilities include:
Review and monitor information security threats and incidents.
Approve initiatives and methodologies to enhance information security.
Agree and review the security policy, objectives and responsibilities.
Review client requirements concerning information security.
Promote the visibility of business support for information security company-wide.
Manage changes to 3rd party services that may impact on Information Security
Perform internal audits with the assistance of Blackmores.
30(a).11 Auditing and Review
ISO 27001 includes processes for the auditing and review of security systems and policies. Audits are performed annually by an independent assessor. The IST periodically reviews the ISMS and conducts a gap analysis, identifying areas where performance does not comply with policy, and where the Risk Assessment has identified the need for further work.
30(a).12. Testing of Controls and Procedures
CentralNic will conduct bi-annual penetration tests of its registry systems to ensure that access controls are properly enforced and that no new vulnerabilities have been introduced to the system. Penetration tests will include both ʺblack boxʺ testing of public registry services such as Whois and the Registrar Console, ʺgrey boxʺ testing of authenticated services such as EPP, and tests of physical security at CentralNicʹs offices and facilities.
CentralNic will retain the services of a reputable security testing company such as SecureData (who, as MIS-CDS, performed the 2009 assessment of CentralNicʹs security stance). The results of this test will be used in annual reviews and audits of the ISMS.
30(a).13. Applicant Security Policy
Controls to restrict access to confidential data relating to the TLD:
NAREIT maintains controls to assure that all financial information and sensitive data, including data relating to the TLD is restricted to authorized staff only. NAREITʹs controls are audited every year by a third party independent auditing firm.
Storage of records:
These records will be stored in both hard copy paper and electronic data format.
Controls to store and secure credentials used to access registry services and other third party systems:
These credentials will be stored in a password protected file on a secure and restricted network server which requires membership in a specific security group and a username and password to access the data.
Access logs to data and credentials:
Access to data and credentials is logged, and automatic alerts are in place to inform system administrators of any unauthorized access. The logs are also manually audited on a regular basis to assure access has not been compromised.
Information processing facilities to be used:
NAREIT will use a secure firewall protected network infrastructure with hardware redundancy, secure Windows 2008 Active Directory server and Windows 7 Ultimate workstations, secure electronic MS Exchange 2010 email server, 3 redundant high speed secure Internet connections, the Office 2010 Professional productivity suite, and Microsoft Great Plains 2010 financial accounting software in to process information in relation to the TLD.
Access controls in place to prevent unauthorised access to information processing facilities:
All of NAREITʹs servers are locked in a separate climate controlled data room within the NAREIT suite. Access to the data room is restricted to authorized staff only. All servers and staff workstations require a username and password for access and have password enabled screen savers that engage after 10 minutes of inactivity. All of NAREITʹs systems and data are stored behind a corporate firewall to prevent unauthorized access. Any remote access into the system requires security credentials and those credentials are required to be changed at a minimum of every 45 days. Access to the financial accounting system is restricted to authroized staff only.
Controls in place to ensure physical security:
Building: The office NAREIT is located in is a secure building with 24-hour on-site security presence and monitoring. Access to the building is only possible with an electronic building key card.
Offices: Once in the building, access to NAREITʹs suite is only possible through an electronic key card which has been specifically programmed to grant access to our suite. After business hours, access is even further restricted as elevator access to the 6th floor (the floor where NAREITʹs suite is located) is only possible with a specifically programmed electronic key card. Suite access doors are also remotely monitored by Kastle Systems to assure suite security. NAREIT maintains video surveillance for its suite entrances as well.
Computer Equipment: All staff workstations require a username and password for access and have password enabled screen savers that engage after 10 minutes of inactivity. All laptops must be signed out for use outside the office and are routinely re-imaged back to a standard image.
Network Equipment: All of NAREITʹs network equipment and servers are locked in a separate climate controlled data room within the NAREIT suite. Access to the data room is restricted to authorized staff only.
Network Infrastructure: Suite access is limited to authroized staff only and electronic key cards are required to access the suite where network infrastrcture is in place.
Electronic Network Storage: All application CD⁄DVDs are stored in a locked fireproof cabinet in the locked data room in the NAREIT suite.
Physical Documents: Physical documents per policy should never leave the NAREIT office. NAREIT maintains locked filing systems for hard copies of any sensitive data and access to these files are restricted to authorized personnel only.
Controls in place to restrict access to networks:
All network access resides behind a secure firewall and all network access from outside the office is restricted to authorized password protected accounts only. Wireless networks require password access and guest access is on a separate VLAN that is kept isolated from NAREITʹs main network.
Controls in place to mitigate the risks from malware:
All of NAREITʹs systems are monitored for virus and malware via a centrally managed Symantec Endpoint Protection server. Security updates are pushed directly to all clients via a centrally managed server. All workstations have locked centrally managed Windows Active Directory Group Policies in place to prevent with tampering of existing security controls.
Controls in place to mitigate the risk from unpatched vulnerabilities in software:
All worktations have locked centrally managed Windows Active Directory Group Policies in place to prevent with tampering of existing security controls. All workstations receive security and software patches and updates via a centrally managed server which automatically applies the patches and updated to all clients.
Policies in place regarding user accounts and passwords:
All user accounts have passwords that expire every 45 days with specific restrictions on password reuse and specific requirements for password length, special characters, etc.
Maintaining contacts with relevant authorities:
NAREIT is able to maintain communications with relevant authorities via telephone communications through its own secure PBX system and cellular phones, secure electronic email or web based communications, US Postal mail, delivery services (such as FedEX and UPS), and courier services.
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