30(a) Security Policy: Summary of the security policy for the proposed registry

Prototypical answer:

Except where specified this answer refers to the operations of the Applicantʹs outsource Registry Service Provider, CentralNic.
30(a).1. Introduction
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 &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
Applicant has physical security measures including locked offices, visitor log, etc).
Applicant uses best practices in computer security (screen locks, password policy, & antivirus updates done regularly).
Applicant has network security (firewalls, secured wifi, secured cabling and network cabinets, network activity logging).
Applicant uses data security (encrypted storage of files and credentials).
Applicant has a Data Protection Guidelines. The following is an excerpt:
1. The first stage in establishing policies and procedures to ensure the protection of personal data is to know what data is held, where it is held and what the consequences would be should that data be lost or stolen. With that in mind, as a first step Departments should conduct an audit identifying the types of personal data held within the organisation, identifying and listing all information repositories holding personal data and their location. Risks associated with the storage, handling and protection of this data should be included in the Department’s risk register. Departments can then establish whether the security measures in place are appropriate and proportionate to the data being held while also taking on board the guidelines available in this document.
2. Access to all data centres and server rooms used to host hardware and software on which personal data is stored should be restricted only to those staff members that have clearance to work there. This should, where possible, entail swipe card and⁄or PIN technology to the room(s) in question such a system should record when, where and by whom the room was accessed. These access records and procedures should be reviewed by management regularly.
3. Passwords used to access PCs, applications, databases, etc. should be of sufficient strength to deter password cracking or guessing attacks. A password should include numbers, symbols, upper and lowercase letters.
4. Departments’ Audit Committees, when determining in consultation with Secretaries General(or CEOs, etc. where relevant) the work programme of their Internal Audit Units (IAUs), should ensure that the programme contains adequate coverage by IAUs of areas within their organisations which are responsible for the storage, handling and protection of personal data. The particular focus of any review by IAUs would be on assessing the adequacy of the control systems designed, in place and operated in these areas for the purpose of minimising the risk of any breach of data protection regulations. Risks associated with the storage, handling and protection of personal data should be included in the Department’s risk register and risk assessments should take place as part of a Department’s risk strategy exercise.
5. All staff should ensure that PCs are logged off or ‘locked’ when left unattended for any period of time. Where possible, staff should be restricted from saving files to the local disk.

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