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    Information Technology Risk Assessment

    Caitlyn Raymond International Registry

     April 2012

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     © 2012 Grant Thornton LLP. All rights reserved.

    Contents

    Page

    Executive Summary 2

    Environment Overview 5

    Findings Overview 9

    Detailed Findings 11

     Appendix 26 

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    Executive Summary

    Grant Thornton, LLP was engaged by the Caitlin Raymond International Registry (“CRIR”) to perform

    an information technology risk assessment based on the ISO 27002 security standard. This assessment

     was conducted between February and April 2012 and was intended to provide CRIR with information

    about risks that could affect the availability of its technology and information systems or theconfidentiality and integrity of the information contained within them. During this assessment Grant

     Thornton conducted:

      Interviews with key stakeholders and technology staff

      Detailed system and application configuration reviews

      Network vulnerability scanning

      Onsite hands-on system configuration reviews

    Our assessment determined that CRIR has done a good job developing and maintaining proprietary

    applications to that support the organization’s business operations. However, we identified a number

    of issues within the underlying technology infrastructure that prevent a significant risk to the

    organization. These issues stem from recent staffing changes that have left the organization with

    inadequate internal resources to support the network or server infrastructure. Specifically, CRIR’s

    application development team is attempting to perform server and network administration –  tasks that

    they do not have the skillset or time to complete effectively.

     As a result, CRIR’s technology infrastructure is aging and not well maintained. Some of the hardware,

    software and operating systems supporting critical applications are over ten years old and are no longer

    supported by the manufacturers. Servers or network devices have been not been built with secure

    configurations and are susceptible to common vulnerabilities. Regular maintenance activities including

    patching, backups and vulnerability management are either not being performed or are beingperformed ineffectively.

     To address these issues with the technology infrastructure, we suggest that Caitlyn Raymond takes

    action immediately. First, the organization should look to hire a minimum or one, but ideally two

    network / system administrators whose sole focus is to support the technology infrastructure. Next,

    the organization should plan a technology refresh, replacing unsupported hardware, software and

    operating systems with updated technology.

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     As an alternative to hiring new staff to support the technology infrastructure, Caitlyn Raymond could

    also look to outsource its data center and support functions to a 3rd party hosting and managed services

    provider. The organization could also look to merge these functions with UMass Memorial, and allow

    the technology teams at the hospital handle these critical tasks.

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    Project Scope and Approach

    In the spring of 2012, Grant Thornton was contracted by the Caitlyn Raymond International Registry

    to conduct a risk assessment of its technology infrastructure and applications based on the ISO 27002

    information security standard. The focus of the assessment was the infrastructure and core functionality

    of CRIR with an emphasis on the ‘Intranet’ application and supporting technologies including webbased services, databases and communications technology, as these govern the majority of CRIR

    business functions including its Donor and Patient transactions.

    ISO 27002 is an internationally recognized standard for information security that evaluates risks to the

    confidentiality, integrity and availability of information assets. The standard is comprised of a number

    of high-level sections, as described below:

      Information risk management policies and procedures

      Security institution

       Asset classification and control  Personnel security

      Physical and environmental security

      Communication and operations management

       Access control

      Systems development and maintenance

      Business continuity management

      Compliance

    Grant Thornton conducted its assessment of Caitlyn Raymond’s technology infrastructure through a

    combination of the following activities:

      Conducting interviews with key functional and technical personnel

      Performing hands-on system configuration reviews

      Reviewing documentation provided by Caitlyn Raymond

      Using automated tools to collect information on device configuration

      Performing vulnerability scans using automated tools

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    Environment Overview

    CRIR Overview

    CRIR is a nonprofit organization affiliated with UMass Memorial Medical Center in Massachusetts.

    CRIR was originally established in 1986 as a unit within the Division of Hematology-Oncology of the

    Department of Pediatrics at the University of Massachusetts Medical Center specifically as acoordinating center for conducting national and international searches for unrelated donors.

    CRIR maintains Hub Status in Bone Marrow Donors Worldwide and the European Marrow Donor

    Information System, maintains an affiliation with the National Marrow Donor Program, and is a

    member registry of the World Marrow Donor Association (WMDA).

     Today, The Caitlin Raymond International Registry accesses 89 bone marrow donor registries and cord

    blood banks worldwide and has performed a search for more than 64,000 patients. Since its inception,

    the Caitlin Raymond International Registry has remained a comprehensive resource for patients and

    physicians conducting a search for unrelated bone marrow or cord blood donors.

    Information Technology Overview

    Caitlyn Raymond’s information technology department has built a proprietary application that allows

    employees to administer patients and donors in an efficient and effective manner.

     This system was originally developed in the 1980’s using RBase. In the late 1990’s, MS Access was

    introduced as a front-end and patient and donor data was moved into a MS SQL database. Recently, a

     web-based front-end has replaced Access as the primary application interface providing a more flexible

    and secure framework.

     This application, referred to internally as ‘The Intranet’ is a complex system with numerous modulesand acts like as an ERP (enterprise resource planning system) system for the organization. The intranet

    supports both front-office operations --- i.e. managing donor and patient registration and matching --

    as well as back-office functions such as the general ledger, AP / AR and an IT ticketing system. The S

    full list of modules can be found below:

      Collection of Stem Cells: Donor and patient receiving

      Donor Testing Services: Test and register new Donors

      Intranet: Administration of Modules

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      IS Module: IS Project / Inventory Devices / "Internal SharePoint"

      Recruitment: User for recruiting new donors

      Report Tracker: Used to track documents from within the application

      Sample Processing: Management of DNA samples from new donors   Ticketing System: IT or operations related tickets

      Finance Modules: Finance

    Users of “The Intranet” are only allowed to access particular modules based on their logon credentials.

    During our assessment, we walked through the user authentication process and evaluated the security

    controls in place to prevent unauthorized access. A high-level description of the authentication process

    can be found below:

    At Log in :  

     Validate user’s credentials:

      Checks if the user’s password has expired and needs to be changed 

      Checks if the user account is blocked, due to failed login attempt

    o  One failed login attempt, the account is blocked for 15 seconds

    o   Two failed login attempts, the account is blocked for 45 seconds

    o   Three failed login attempts, account is blocked for 15 minutes and IT staff is notified

     via email

      Creates new session: both the session start and session regenerate ID are used.

      Creates a hashed user agent and session string to be stored in session data and user cookies

       The session data is stored in a database protected with a username and password.

    When appl ication Page loads:

      Checks session expiration

      Sets session's time to 90 minutes

       Verifies the user agent matches the session data and cookies

      Prevents SQL injection by using custom SQL statement before change commands are

    permitted.

      Checks if the IP address is within defined range

      User Authentication is verified

      User permissions for content are verified

      Updates corresponding tables

    At Session Close:

      Session connections are terminated

      Deletes session cookie

      Deletes hashed session information from database

      User is returned to the login page.

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    In our opinion, the controls that Caitlyn Raymond’s application development team has implemented to

    prevent users from accessing data without authorization are adequate. In general, CRIR has taken the

    best practice of using a layered authentication and multiple techniques to mitigate misuse and this has

    significantly reduced risk of compromise to the “Intranet” application.

    Network Diagram

     To support this application, Caitlyn Raymond operates a single data center located within its office

    facility in Worcester, Mass. A network diagram can be found below:

     As can be seen in the diagram above, Caitlyn Raymond’s network is a flat, layer-2 network. Users,

    servers and publicly accessible systems all reside on the same logical network and route by default to aLinksys edge / core firewall / router.

    Caitlyn Raymond’s public website is not hosted out of the Worcester, Mass data center, but instead is

    hosted at Rackspace, a 3rd party hosting provider. Email services are also outsourced to a cloud-based

    provider.

    Caitlyn Raymond’s VoIP phone system is provided by and managed by the UMass Memorial Medical

    Center and utilizes a separate layer two switched network.

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    Server Inventory

     The table below provides an inventory of servers supported by Caitlyn Raymond’s information technology team:

    Host NameOperating

    SystemWarranty?

    Purchase

    DateServer Type CPU Memory Disk Function

    Comedian WinXP Y Aug-10HP Compaq

    dc5850 AMD Phenom II

    X4 810 1.75GB 220GB EMDIS Application

    Marvin Suse Linux N Aug-05DELL

    PowerEdge2800

    (2) 3.0 GHz/2MB Cache

    2GBDDR2

    36GB, 36GB,73GB, 73GB,

    73GB, 73GB SCSI

    Not working - MySQL MNetwork Backup to USB

    Minerva WinXP N 2003 DealDepot Intel Celeron 512MB 40GB Workstation for Rebe

    MycroftUbuntuLinux

    N Jun-08 Vision

    (2) AMD Athlon(tm) 64X2 Dual Core

    Processor 4400

    2GBDDR2

    3x250GB Dev Intranet and Dev M

    NagasakiUbuntuLinux

    N Jun-08 Vision

    (2) AMD Athlon(tm) 64X2 Dual Core

    Processor 4400

    2GBDDR2

    3x250GBLive MySQL, CUPS Pr

    Server, Network BackuUSB HD

    NAS N Jul-09 ReadyNAS 2TB Dual Gig RMNW

    Network Storage (G

    Server1Win2KServer

    N Sep-02DELL

    PowerEdge1500SC

    (2) 1.4 GHz/512Cache

    512 MBSDRAM

    (2) 18GB 10KRPM Ultra 160

    SCSI

    Network Print Server, DDHCP, Anti-virus Server

    Server, Active Directo Automated Tasks

    TerminatorUbuntuLinux

    N Apr-08 Vision(2) AMD

    Opteron(tm)1212

    2GBDDR2

    3x250GB Not running

    Terminator2UbuntuLinux

    N Apr-08 Vision(2) AMD

    Opteron(tm)1212

    2GBDDR2

    3x250GB Live Intranet

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    Findings Overview

    Risk categories

    Based upon our review of the overall the control environment of the company, we have identified

    number of findings. Each of these findings has been classified as high, medium or low risk based on

    the following definitions:

      High  –  A high risk finding is assigned to vulnerabilities that have a high threat or impact

    potential and could allow unauthorized privileged access, grant the ability to alter systems in

    some way or leave the organization vulnerable to losses of sensitive information and the

    potential financial penalties in the event of a breach. It is recommended that these findings are

    corrected immediately.

      Medium  –  A medium risk finding is assigned to vulnerabilities that pose a moderate level of

    risk to the organization and could allow a threat access to systems with unprivileged access.

    Medium risk findings generally represent systematic organizational problems that often lead to

    the introduction of new high risk technical findings if they are not corrected.

      Low –  A low risk finding are areas that do not meet the best practicies put forth in the ISO

    standard but do at the same time pose little to no imdediate risk to the environement. If low

    risk findings are not corrected, they often lead to the introduction of new medium and high

    risk technical and administrative findings.

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    Summary of Findings

    Grant Thornton identified numerous issues within the Caitlyn Raymond technology infrastructure. A

    summary can be found in the tables below:

    Policy, Process and Organizational Issues Risk

    1 No Information security policy Med

    2 Information security responsibilities not defined Low

    3 Information security processes, standards, and guidelines not established Med

     Technical Issues Risk

    4 Use of out-of warranty, out-of date or unsupported hardware High

    5 Use of consumer based products in an enterprise environment High

    6 No patch or vulnerability management for operating systems or applications High

    7 No server configuration standards / system hardening High

    8 Use of unnecessary or undocumented services and applications Med

    9 Use of “administrator”/ “root” account to manage systems High

    10 Remote access to Linux systems with “root” account is enabled  High

    11 Use of weak / or default passwords High

    12 IT administrators unable to access network devices Low

    13 Broken processes for identity and authentication management Med

    14 No system-state backups being taken High

    15 Backup tapes stored in IT administrator’s homes  High

    16 No disaster recovery plan / business continuity management Med

    17 UPS devices not properly configured / maintained Low

    18 Network diagram does not exist Med

    19 Insecure wireless networking configuration High

    20 No centralized logging / monitoring system Med

    21 No network segmentation Med

    22 Changes to Windows systems are made directly in production Low

    23 No change control process Med

    24 Insecure administrative access to 3rd party hosted web application server High

    25 Use of insecure protocols for data transfer / system management Med

    26 Desktop operating systems used to support server functions Med

    27 Access to financial system controlled by Access Database front-end Med28 Sensitive data not encrypted Med

    People Issues Risk

    29 IT personnel lack server and network administration skills High

    30 Understaffed High

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    Risk vs. Mitigation Effort

    In the chart below we have mapped each of the findings in a three by three matrix based on risk andmitigation effort. We recommend that Caitlyn Raymond address the high-risk findings with a low

    mitigation effort first. These findings are located in the upper-left hand corner of the chart.

    From there, we suggest working through the findings starting in the upper-left corner and workingdown to the lower-right.

    LOW MEDIUM HIGH  Use of “administrator” or “root”

    account to manage systems  Remote access to Linux systems

     with “root” account is enabled   Use of weak / default passwords  No system state backups are taken  Backup tapes stored in IT

    administrators homes  Insecure wireless configuration  Insecure administrative access to

    3rd party / hosed web applications

      Use of consumer based productsin an enterprise environment

      No patch of vulnerabilitymanagement for operating systemsor applications

      No server configuration standards/ system hardening

     

      Use of out-of warranty orunsupported hardware, softwareand operating systems

      IT personnel lack server andnetwork administration skills

      Understaffed

      Broken process for identity andauthentication management

      Network diagram does not exist  No change control process  Use of insecure protocols for data

    transfer / system management  Sensitive data not encrypted 

      No Information Security Policy  Information Security Processes,

    Standards and Guidelines notEstablished

      Desktop operating systems used tosupport server functions

      Use of unnecessary orundocumented services andapplications

      No network segmentation

      No disaster recovery plan /business continuity management

      No centralized logging /monitoring system

       Access to financial systemcontrolled by Access Databasefront-end

      IT administrators unable to accessnetwork devices

      UPS devices not properlyconfigured / maintained

      Changes to Windows systems aremade directly in production

      Information securityresponsibilities not defined

       R   i  s   k

    Mitigation Effort

       L   O   W

       M   E   D   I   U   M 

       H   I   G

       H

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    Detailed Findings

     The detailed findings below list the findings categories in detail. The intention is to call out the

    underlying cause for vulnerability in the CRIR environment and present remediation options along with

    estimated cost and manpower associations for remediation.

    Policy, Process and Organizational Issues

    1.  No Information Security Policy  Medium

    Description Caitlyn Raymond does not have an information security policythat describes:

      Its approach to addressing information security issues  Organizational roles and responsibilities as they relate to

    information security   Acceptable use of information technology systems and

    assets  Other

    Risk Analysis Policies are the corner stone for information security andcompliance in any organization. Without an information securitypolicy, an organization does not have a basis for identifying,

    assessing and managing risks.

    Remediation Cost/Effort Medium

    Recommendations CRIR can look to leverage the information security policies thathas already been developed for the UMass Memorial MedicalCenter to build a security policy of its own and distribute it to allemployees.

    Ongoing Effort  The security policy will need to be reviewed on an annual basis toensure it remains applicable to new technologies and emergingthreats.

    2.  Information Security Responsibilities not Defined  LowDescription Caitlyn Raymond does not define information security roles and

    responsibilities for all members of the organization. Typically,these roles and responsibilities are defined in an informationsecurity policy as described in Finding #1 above.

    Risk Analysis  Without clearly defined roles and responsibilities for informationsecurity within the CRIR environment there are several criticalsecurity and administration tasks that are not taking place.

    Remediation Cost/Effort Medium

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    Recommendations CRIR needs to define information security roles and respon

    sibilities for all employees

    Ongoing Effort Information security roles should be periodically reviewed and

    updated to ensure they remain consistent with changes inorganizational technology as well as new and emerging threats.

    3.  Information security processes, standards, and guidelines notestablished 

    Medium

    Description Caitlyn Raymond has not defined operational procedures to beexecuted by information technology that support informationsecurity. Examples of policies and procedures that should bedeveloped include:

       Acceptable Use Policy  Backup and Restoration Procedures  Patch Management Procedures   Vulnerability Management Procedures  Identity and Authentication Management Procedures  Password Policy and Reset Procedures  Incident Response Policy  Others

    Risk Analysis  Without defined Processes, standards and guidelines theadministration of servers and the network is conducted in a wayin which security and risk within the environment can not bemeasured or controlled by CRIR staff.

    Remediation Cost/Effort Medium

    Recommendations Security Processes, standards and guidelines should bedocumented in the sites policies and procedures and staff shouldbe made aware of their responsibilities. All areas of administrationshould be documented for example, patch management, serverupdates, creating and deleting new users. It is very likely thatUHMV already has this done CRIR should use this as a go by fortheir own environment.

    Ongoing Effort  This should be reviewed anytime updates are made to the sitessecurity policy.

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    Technical Issues

    4.  Use of out-of warranty, out-of date or unsupported hardware andsoftware 

    High

    Description Caitlyn Raymond is utilizing hardware, software and operatingsystems that are no longer supported by the manufacturers. Thisincludes numerous out-of-warranty servers and network devicesas well as the use of the Windows 2000 / Ubuntu 8.1 operatingsystems.

    Risk Analysis Using out-of-date hardware not only affects system performance,but also leaves the organization susceptible to a sustained outagein the event that a system component fails and replacement partsare not readily available.

    Using out-of-support operating systems leaves the organizationsusceptible to newly discovered vulnerabilities which are nolonger patched by the vendor.

    Remediation Cost/Effort High

    Recommendations CRIR should develop a plan to replace the hardware, softwareand operating systems that are no longer under warranty or are nolonger supported by their vendors.

    Ongoing Effort In addition, we recommend that CRIR builds a formalizedprocess for system lifecycle management that plans for regularhardware, software and operating system upgrades to ensure that

    they do not fall out of support in the future.

    5.  Use of consumer based products in an enterprise environment  High

    Description CRIR has deployed a consumer grade Linksys device as its corerouter / edge firewall. Linksys is intended for home use and isnot robust enough for a corporate environment

    Risk Analysis Consumer grade networking equipment does not have thegranular security features needed for a corporate environment.

    Remediation Cost/Effort Medium

    Recommendations Replace network equipment with business class devices.Ongoing Effort Once replaced CRIR should make sure only business class

    devices are used moving forward.

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    6.  No patch or vulnerability management for operating systems orapplications 

    High

    Description Patches and updates are not being applied to servers,

     workstations and other devicesRisk Analysis By not applying patches, Caitlyn Raymond is leaving itself

     vulnerable to exploits from internal and external sources thatcould result in a breach of sensitive patient or donor data orsystem unavailability.

    Remediation Cost/Effort Medium

    Recommendations Develop a formal patch and vulnerability management plan,defining when and how patches will be tested and deployed.

    Ongoing Effort  The patch management and vulnerability management programshould be periodically reviewed to make sure it is functioningcorrectly.

    7.  No server configuration standards / system hardening  High

    Description CRIR has not developed system configuration standards forservers or network devices that harden them to prevent mostcommon information security vulnerabilities.

    Risk Analysis Servers that are installed “out of the box” without going througha formal hardening procedure could enter the network missingcritical software of firmware patches or even anti-virus definitionsincreasing the threat to the network

    Remediation Cost/Effort Medium

    Recommendations Create a checklist of security requirements that needs to befollowed and use it when setting up any new equipment.

    Ongoing Effort Hardening procedures should be periodically evaluated to ensurethey are current and best fit the organization.

    8.  Use of unnecessary or undocumented services and applications  Medium

    Description Servers and network devices on the Caitlyn Raymond networkhave numerous services enabled and configured that are notbeing utilized, including FTP, telnet, HTTP and many others.

    Risk Analysis Services are access points to your network, when no longerrequired they are often left unmonitored and vulnerable creating alarger threat footprint for compromise. Services not in use alsotake up valuable system resources.

     As an example in we included the output of open services for thedomain controller which had a large amount of services in useincluding ‘Gopher’ and ‘Pop2’ which have not been requiredservices for several years.

    Remediation Cost/Effort Medium

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    Recommendations Disable unnecessary services and if possible determine why theservice was enabled to begin with.

    Ongoing Effort Periodic review of open services should be conducted

    9.  Use of “administrator”/ “root” account to manage systems  High

    Description Caitlyn Raymond uses the root and / or administrator account tomanage systems instead of using unique usernames attributable toeach individual.

    Risk Analysis  Administrator and Root accounts are generic accounts that arenot traceable back to an individual system administrator and oftengrant much higher levels of access than needed for basicadministration.

    Remediation Cost/Effort Low

    Recommendations  Admins should have personal accounts set up to log in and dobasic administrative tasks. The password to the root and / oradministrator accounts should be long, complex and should onlybe accessed in the event of a disaster / emergency.

    Ongoing Effort Once in place no follow on effort should be required

    10.  Remote access to Linux systems with “root” account is enabled  High

    Description Linux systems at Caitlyn Raymond are configured to allow remoteaccess using the “root” account. This configuration enables an

    attacker who has compromised the system to gain full control.Risk Analysis  The Root account should be restricted to prevent system

    compromise and damage to system. The Root account has accessto modify all aspects of the operating system any mistakes made

     will modify the system.

    Remediation Cost/Effort Low

    Recommendations  Authorized users should use sudo to run operations that requireroot level privileges. Use of sudo allows accountability forchanges to the system. Since the user needs to take and log in tothe part of the system they wish to change the chance formistaken modifications is greatly reduced.

    Ongoing Effort Once in place CRIR should ensure sudo is used for all remoteadministration.

    11.  Use of weak / or default passwords  High

    Description Many systems on the Caitlyn Raymond network have beenconfigured with weak or default administrative passwords.

    Risk Analysis  Weak and or default passwords are easily compromised by

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    malicious users granting them unauthorized access to systems andnetwork resources.

    Remediation Cost/Effort Low

    Recommendations CRIR should change all default passwords, and require allaccounts including service accounts require strong passwords ofat least 8 characters and a mix of capital, lower case, number andspecial character

    Ongoing Effort Once in place CRIR should remain enforce passwordrequirements.

    12.  IT administrators unable to access network devices  Low

    Description IT administrators at Caitlyn Raymond have no understanding ofhow to access switches and other network devices. Not only

     were the management IP addresses unknown, but usernames,passwords and console access were unavailable as well.

    Risk Analysis  With no level of access for the current staff the devices arecompletely unmanaged and are not being administered in any

     way.

    Remediation Cost/Effort Low

    Recommendations Network staff should have full access and control over allnetwork devices. The staff should console into each device, viewthe configuration , note management IP addresses and set upuser-level access as appropriate.

    Ongoing Effort Moving forward when anything is added to the network staff

    should have appropriate access levels.

    13.  Broken processes for identity and authentication management Medium

    Description Formalized processes for adding and removing system accountshave not been developed. In some instances, systemadministrators no longer with the company have accountsenabled.

    Risk Analysis  Without strong identity and authentication managementprocesses in place, an organization leaves itself susceptible to acompromise of information by a former employee.

    Remediation Cost/Effort Low

    Recommendations Remove or archive accounts from users that are no longer neededmake sure all files and data that is saved has proper permissionsset.

    Ongoing Effort Periodic review should be conducted to prevent this frombuilding up in the future. This should be defined in processes andprocedures.

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     would experience an extended outage.

    Remediation Cost/Effort High

    Recommendations CRIR should work with UHMV to determine if there is an

    existing location that CRIR could restore their servers and criticaldata to and that staff could work from until the primary site wasavailable again.

    Ongoing Effort Once developed the plan should be reviewed by IT and executivemanagement at least yearly to ensure it covers all CRIR recoveryneeds.

    17.  UPS devices not properly configured / maintained Low

    Description  The UPS devices in the Caitlyn Raymond data center are notconfigured properly and have not had regular annual maintenancedone since their implementation.

    Risk Analysis Improper configuration / maintenance could cause UPS units tofail at time of incident. There is currently no generator backup forthe CRIR environment.

    Remediation Cost/Effort Medium

    Recommendations  Work to properly configure the UPS systems to failover togenerator power or do a graceful takedown of the network oncebattery power has dropped. If it is determined that outages due topower must be prevented, CRIR should work to have thenetwork place on a generator backup system.

    Ongoing Effort Power management will need to be re-evaluated whenever

    network changes occur

    18.  Detailed documentation of the network and communications linksdo not exist

    Medium

    Description Caitlyn Raymond does not have a network diagram ordocumentation of network device configuration.

    Risk Analysis  Without documentation of the network and the communicationlinks it would be very difficult for CRIR to trouble shoot anycommunication/networking issues with the network.

    Remediation Cost/Effort LowRecommendations Grant Thornton has provided a detailed Visio diagram as part of

    this assessment

    Ongoing Effort  The Visio diagram should be updated anytime change takes place

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    19.  Insecure wireless networking configuration High

    Description Caitlyn Raymond has a wireless access point on its network buthas not applied basic system security parameters that would

    prevent unauthorized access.

     Note: This device is currently unused by CRIR personnel.

    Risk Analysis  The wireless implementation was a commercial wireless routerusing WPA for authentication. WPA is easily cracked usingreadily available free utilities, which could allow unauthorizedaccess to the network.

    Remediation Cost/Effort Low

    Recommendations It was determined that wireless was no longer needed by the staffat CRIR and powered off. If the device is not required it shouldbe permanently removed from the network.

    Ongoing Effort If it is determined in the future that wireless is needed a businessclass device that uses more robust security should be purchasedand used.

    20.  No centralized logging / monitoring system Medium

    Description Caitlyn Raymond has not deployed a centralized system forlogging system access or event logs.

    Further, no process for reviewing system access or event logs

    stored locally on individual servers or network devices has beenput in place.

    Risk Analysis  Without centralized event logging and monitoring, ITadministrators will not be able to detect malicious activity on theCRIR network or easily determine the root cause of system andnetwork issues.

    Remediation Cost/Effort High

    Recommendations Deploy centralized logging and monitoring system that will alertIT administrators when key events occur and provide accessreports to management on a regular basis.

     Alternatively, Caitlyn Raymond could leverage any logging andmonitoring system already deployed by the UMass MemorialMedical Center or turn to a 3rd party service to provide thisfunctionality.

    Ongoing Effort Monitoring and logging will need to be periodically evaluated andupdated to ensure it is best meeting the organizations needs

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    21.  No network segmentation Medium

    Description Caitlyn Raymond has deployed a flat, layer two network without VLANs. Regular users have not been placed in a different

    segment than IT administrators, servers or publicly accessiblesystems.

    Risk Analysis  Without network level segmentation, IT administrators arecontrol which systems users on the internal network have accessto. Effectively all users have the ability to access all CRIR systemsusing any available service.

    Remediation Cost/Effort Medium

    Recommendations Implement multiple VLANs to separate traffic. At a minimum, adonor, patient, server, IT and DMZ VLAN should be deployedalong with the associated access control lists.

    Ongoing Effort Network segmentation will need to be evaluated anytime an

    organizational or network change takes place.

    22.  Changes to Windows systems are made directly in production Medium

    Description Caitlyn Raymond updates its Microsoft Windows environment without first testing changes in a development environment.

    Risk Analysis Updating systems in production prior to testing could causesystems instability or failure. If a mistake is made or a patch doesnot install correctly it will directly affect the production network.

    Remediation Cost/Effort Low

    Recommendations  Test all changes to the production systems in a lab environmentbefore applying. Use of VMware or other virtualizationtechnologies can simplify this effort.

    Ongoing Effort Once a test environment is in place, CRIR should ensure testingprior to deployment to the production network is done movingforward.

    23.  No change control process Medium

    Description  A formal change control is not in place for server, operatingsystems, network devices or applications.

    Risk Analysis Network systems need periodic updates and configurationchanges for proper operations. Without an appropriate process ingoverning how and when systems and network changes can takeplace changes that are needed could be missed or changes that areimplemented incorrectly could damage the network.

    Remediation Cost/Effort Low

    Recommendations Develop a change control program listing how and when changes

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    can take place on the network including documentation forapproval and back out procedures in case the change needs to beundone.

    Ongoing EffortChange control should be periodically reviewed and modified tobest fit CRIR operations.

    24.  Insecure administrative access to 3rd party hosted web applicationserver

    High

    Description Caitlyn Raymond has not set up secure access to applicationshosted with 3rd parties, including its email system and public website.

    Risk Analysis Insecure communication protocols used for remoteadministration can be intercepted by an attacker. Use of any cleartext or unencrypted protocols over the internet provides an openattack vector for compromise.

    Remediation Cost/Effort Low

    Recommendations  Administrator should use a secure protocol such as SSH forsecure remote administration

    Ongoing Effort CRIR should periodically review communication protocols andmake certain they are providing appropriate security

    25.  Use of insecure protocols for data transfer / system management Medium

    Description Caitlyn Raymond uses telnet, FTP, HTTP and other unencryptedprotocols to manage server and network resources.

    Risk Analysis  Weak encryption protocols such as older versions of SSL and weak communications protocols such as Telnet and FTP are inuse throughout the CRIR network. Weak encryption can be easilyintercepted and monitored.

    Remediation Cost/Effort Low

    Recommendations Insecure management protocols should be disabled. Onlyencrypted communication protocols should be used to manageserver and network devices.

    Ongoing Effort CRIR should periodically review what is being used for networktraffic encryption and communications and make sure it is bot up

    to date and secure.

    26.  Desktop operating systems used to support server functions Medium

    Description  The MDIS and Terminal Server systems at Caitlyn Raymondutilize Windows XP to support a server based function.

    Risk Analysis Desktop software does not have the security or stability of serverclass software and has a higher risk of compromise or failure

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    Remediation Cost/Effort Medium

    Recommendations Desktop operating systems should be replaced with serversoftware.

    Ongoing Effort  When services are deployed CRIR should make sure that thesystem they are on supports it.

    27.  Access to financial system controlled by Access Database front-end Medium

    Description Caitlyn Raymond’s financial system has not been converted to a web-based format and is still accessible using an Access Database

    Risk Analysis  Access is not scalable or secure enough to be deployed as a frontend solution. The version of Access being used is no longersupported by the vendor.

    Remediation Cost/Effort High

    Recommendations CRIR should continue moving forward with plans to replace theaccess front end with the solution they are using for the rest ofthe “Internet” application. 

    Ongoing Effort  Application staff should continue to replace solutions as theybecome obsolete.

    28.  Sensitive data not encrypted Medium

    Description Donor and patient data stored in databases and flat files

    throughout the Caitlyn Raymond network is not encrypted.

    Risk Analysis Sensitive data especially sensitive data containing PII (personallyidentifiable information) and financial data will be the primarytarget if systems are compromised.

    Remediation Cost/Effort Low

    Recommendations Sensitive data should be stored in encrypted folders or beencrypted at the file level. This will add an additional layer ofsecurity should a system compromise take place. There are severalfree solutions available to CRIR for example Truecrypt forencrypted storage or GPG for file level encryption

    Ongoing Effort CRIR should periodically review where sensitive data resides onthe network and ensure it is being secured.

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    People Issues

    29.  IT personnel lack server and network administration skills High

    Description CRIR Servers are not being adequately supported due to lack ofsystems expertise and training of the staff. Servers at CRIR areshowing signs of failure due to years of being run by staff that

     was not trained on systems administration and what is required tomaintain server functionality.

    Risk Analysis  Almost all of the findings identified earlier in this report areattributable to a lack of system / network administration skills

     with the IT function at CRIR.

    Remediation Cost/Effort High

    Recommendations Staff needs to be either be properly trained on serveradministration or additional staff will need to be brought in tomanage the network. A second option is to allow the UMassMemorial Medical Center or 3rd party service providerto take overthe responsibility for server and network management.

    Ongoing Effort  As technology changes, training, will need to be conducted toensure staff remains knowledgeable on operations andadministration of servers.

    30.  Understaffed High

    Description  There are not enough resources available to adequately managethe network. The current structure has two staff memberssplitting their time between network and server operations andtheir primary assignment of managing the ‘Intranet’ application 

    Risk Analysis  Almost all of the findings identified earlier in this report areattributable to a lack of system / network administration skills

     with the IT function at CRIR.

    Remediation Cost/Effort High

    Recommendations CRIR should consider hiring at least one additional resource thatis trained in network and server administration. A second optionfor CRIR to consider is to outsource the network and server

    administration roles this can be done within the UMass MemorialMedical Center system or with a 3rd party service provider.

    Ongoing Effort Staffing size should complement the size of CRIR operations and will need to be assessed whenever organizational changes takeplace.

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     Appendix A: Tools Utilized

    Assessment Tools

    Tool  Function  CRIR Service 

    Burp Suite Burp Suite is an integrated

    platform for performing

    security testing of web

    applications.

    Burp Suite was used to test

    security of the “Internet”

    application at CRIR. The results of

    testing did not uncover any

    notable findings.

    OWASP-ZAP

    (Open Web Application

    Security Project – Zed Attack

    Proxy)

    The Zed Attack Proxy (ZAP) is

    an integrated testing tool for

    finding vulnerabilities in web

    applications. ZAP containsautomated scanners as well as

    a set of manual tools to find

    security vulnerabilities.

    OWASP-ZAP was used to test the

    “Internet” application at CRIR for

    security and security bypass

    vulnerabilities. The results oftesting did not uncover any

    notable findings.

    Data Collection Scripts Basic system scripts used to

    automate the collection

    process for gathering system

    configurations. System

    configurations are reviewed for

    vulnerabilities and compliance.

    Data collection scripts were

    provided to CRIR to collect data

    from the Windows and Linux

    systems on the CRIR network. The

    data returned from the scripts was

    used to perform systems

    configuration review of the CRIR

    systems.

    Nessus Vulnerability Scanner Nessus is a network

    vulnerability scanner used to

    identify possible vulnerabilities

    on computer networks.

    Nessus was used to scan the CRIR

    network. The scan uncovered 163

    unique vulnerabilities related to

    outdated systems and software as

    well as missing system patches

    and maintenance.

    Nmap

    (Network Mapper)

    Nmap is a scanning tool used

    to discover hosts and services

    on a computer network.

    Nmap was used to identify

    unmanaged switches on the CRIR

    network.

    TCPView TCPView is a Windows

    program that will show you

    detailed listings of all TCP andUDP endpoints on your system,

    including the local and remote

    addresses and state of TCP

    connections.

    TCPView was run to identify

    running services on the CRIR

    network. TCPView was able toidentify an excessive number of

    services running on the CRIR

    network.

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     Appendix B: Outsourcing Analysis

    One potential solution that will address many of the issues uncovered during this assessment is to

    outsource the data center and management of the technology infrastructure to the UMass Memorial

    Medical Center. In this model, Caitlyn Raymond’s existing IT team will be able to focus on doing what

    they do best –  developing and managing applications and databases to support the international

    registry. Server, network and data center support will be the responsible of UMass’s infrastructure

    team and be folded into their existing processes.

     While Grant Thornton absolutely recommends this model for IT management as a solution for Caitlyn

    Raymond, there are a number of caveats that must be considered.

    Technology Refresh Still Required

    Even if Caitlyn Raymond migrates its technology infrastructure into UMass’s datacenters, the

    underlying technology infrastructure will still need to be refreshed. This will include upgrading

    hardware, software and operating systems as well applying secure configurations to all devices.

     As a part of this process, Caitlyn Raymond will need to evaluate different options for their technology

    including the use of physical vs. virtual servers, directly attached storage vs. NAS / SAN, utilization of

    cloud based technologies, shared vs. stand-alone database structures and a host of other key design

    choices.

    If this exercise is not completed, Caitlyn Raymond will be essentially picking up a problem and moving

    it to another location without addressing the underlying issues.

    Requirements Definition

     While it is expected that UMass would take on the responsibility of managing and maintaining Caitlyn

    Raymond’s technology infrastructure in this outsourced model, the registry will still be responsible for

    defining requirements for key IT processes for the hospital. For example, backup and patching

    schedules, system access policies, data classification systems, system configuration standards and

    numerous other items will still need to be developed by Caitlyn Raymond and communicated to

    UMass.

    Responsibility Matrix

    If Caitlyn Raymond does choose this model for IT management, the responsibility for addressing each

    of the findings in this report will be split between itself and the UMass Memorial Medical Center. In

    the chart below, we’ve assessed which entity will be responsible for addressing each finding:

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    Policy, Process and Organizational Issues Responsibility

    1 No Information security policy CRIR / UMASS

    2 Information security responsibilities not defined CRIR / UMASS

    3 Information security processes, standards, and guidelines not established UMASS

     Technical Issues Responsibility

    4 Use of out-of warranty, out-of date or unsupported hardware CRIR

    5 Use of consumer based products in an enterprise environment CRIR

    6 No patch or vulnerability management for operating systems or

    applications

    UMASS

    7 No server configuration standards / system hardening CRIR / UMASS

    8 Use of unnecessary or undocumented services and applications CRIR

    9 Use of “administrator”/ “root” account to manage systems CRIR / UMASS10 Remote access to Linux systems with “root” account is enabled  CRIR / UMASS

    11 Use of weak / or default passwords UMASS

    12 IT administrators unable to access network devices UMASS

    13 Broken processes for identity and authentication management UMASS

    14 No system-state backups being taken UMASS

    15 Backup tapes stored in IT administrator’s homes  UMASS

    16 No disaster recovery plan / business continuity management CRIR / UMASS

    17 UPS devices not properly configured / maintained UMASS

    18 Network diagram does not exist UMASS

    19 Insecure wireless networking configuration UMASS20 No centralized logging / monitoring system UMASS

    21 No network segmentation UMASS

    22 Changes to Windows systems are made directly in production UMASS

    23 No change control process UMASS

    24 Insecure administrative access to 3rd party hosted web application server UMASS

    25 Use of insecure protocols for data transfer / system management CRIR / UMASS

    26 Desktop operating systems used to support server functions CRIR

    27 Access to financial system controlled by Access Database front-end CRIR

    28 Sensitive data not encrypted CRIR

    People Issues Responsibility

    29 IT personnel lack server and network administration skills UMASS

    30 Understaffed UMASS

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     This proposal is the work of Grant Thornton LLP, the U.S. member firm of Grant ThorntonInternational Ltd, and is in all respects subject to negotiation, agreement and signing of specificcontracts. The information contained within this document is intended only for the entity or person to which it is addressed and contains confidential and/or proprietary material. Dissemination to thirdparties, copying or use of this information is strictly prohibited without the prior written consent of