30(a) Security Policy: Summary of the security policy for the proposed registry
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Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic.
CentralNicʹs Information Security Management System (ISMS) complies with ISO 27001. CentralNic is working towards achieving full ISO 27001 certification and has secured the services of Lloydʹs Register Quality Assurance (LRQA), a UKAS accredited certifier for its ISO 27001 certification. A letter from LRQA confirming this engagement is included in Appendix 30(a).1. Stage One of this process is scheduled during May 2012, with Stage Two occurring in July 2012. 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 §42;), 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
Applicant’s existing security policies restrict access to confidential data relating to the TLD to shareholders and officers. These records will be stored on CentralNic’s secure servers. Applicant will be using CentralNic’s access credentials, which include IP-based access, secure passwords and an encrypted network connection using SSL.
Applicant will securely store access credentials in its private offices with access restricted to officers of the company. CentralNic will provide the necessary processing facilities related to the TLD, including servers and networks and provide the Applicant with secure remote access. Unauthorized access to these facilities will be prevented by a two factor authentication system with ad hoc and regular access audits. Physical documents are locked in secure, private offices.
Applicant’s facilities have extensive physical security in place. Applicant’s building remains locked at all times with a 24-hour alarm system and rotating cameras situated at multiple areas in the interior and exterior of the building, and at all points of entry as well as at digital and physical storage points. Key access is restricted to essential personnel. Internal and external cameras provide full coverage of all workstations and servers. Cameras are connected to a secure DVR system to record unauthorized access.
Computer and Network Security
Applicant abides by computer security best practices, requiring monitor screen locks and password protection. Applicant’s computer equipment is password protected on a secure network with antivirus and software patching programs in place. Antivirus monitoring updates are conducted on a daily basis. All security software is kept up to date under Applicant’s existing security policies.
Applicant has network security in place. Applicant’s network infrastructure includes secured, underground cable conduits. Wireless network access is encrypted and requires authorization from approved personnel. Network access is restricted to MAC approved computers. Portable media is secured and must be checked out with an officer to leave premises. Every user has a unique user name and password. Existing password policies require password updating every 90 days.
LAN & Wireless Security
The Applicant’s office LAN contains no servers. This drastically simplifies our network topology. We are not running any servers to the outside world. Thus, we have no need for open inbound ports or DMZs. We have restricted the firewall to allow no inbound initiated traffic. There are no ports open for outsiders to get on to our office network. Specifically, there are no SSH, DNS, RDP, HTTP, SSL, POP3, IMAP, SMTP, or VPN inbound ports allowed to our office LAN, thereby effectively eliminating a major source of attack vectors on our office LAN.
Only approved wired⁄wireless devices can get on our LAN. All unapproved device attempts to get on the network our logged for review. We regularly review the list of approved devices. Devices approved for use on the LAN, must have all OS patches and updates, and anti-virus software that updates daily. No personal devices are ever allowed on the LAN, only devices which have been procured through our approved corporate vendors.
We have changed all passwords and SSIDs of our network infrastructure from their defaults. The wireless access points permit only WPA2 devices.
All proposed changes to the network infrastructureʹs configuration are vetted by Applicant’s security team, and only changes they approve are allowed. The security team is responsible for maintaining the schematic diagram of our network and updating it with approved changes.
Employees are given unique passwords. Upon each employee’s departure from the company, that access is removed. Ongoing training for employees is conducted with the objective of increasing their awareness of compliance requirements and the ramification of breaches. We monitor and terminate any attempts by employees to breach these requirements.
Applicant will continue to work with CentralNic and other security experts to continually enhance site and network security measures in addition to policy development, employee training, and enhanced physical security measures.
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