Security Policy |

Security Policy

Omnibond will operate and store its production systems in a cloud service that is approved by management and must adhere to the infrastructure requirements as outlined in NIST.SP.800-171r2. Each system that contains customer CUI will be secured in the following manner and as outlined in the NIST publication mentioned above. The key aspects of this are outlined below. The processes outlined will be followed. Additionally we will comply with FAR 52.204-21-0.

Policy Review Date
21 February 2021

Access Control

Limit system access to authorized users, processes acting on behalf of authorized users, and devices (including other systems).
Limit system access to the types of transactions and functions that authorized users are permitted to execute.
Control the flow of Controlled Unclassified Information (CUI) in accordance with approved authorizations.
Separate the duties of individuals to reduce the risk of malevolent activity without collusion.
Employ the principle of least privilege, including for specific security functions and privileged accounts.
Use non-privileged accounts or roles when accessing nonsecurity functions.
Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.
Limit unsuccessful logon attempts
Provide privacy and security notices consistent with applicable CUI rules. Notices will be used on login of systems that contain data that requires it based on the customers access requirements.
Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity
Terminate (automatically) a user session after a defined condition.
Monitor and control remote access sessions.
Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.
Route remote access via managed access control points.
Authorize remote execution of privileged commands and remote access to security-relevant information.
Authorize wireless access prior to allowing such connections. Email approval should be given before access to the Omnibond wireless network from management.
Protect wireless access using authentication and encryption.
Control connection of mobile devices. Only authorized and vetted devices will be allowed to access Omnibond’s Network.
Encrypt CUI on mobile devices and mobile computing platforms. Generally no CUI should reside on small mobile devices at Omnibond, if they are, the data should be encrypted. Generally CUI should reside in servers and services that reside in approved clouds and only by specific permission resides elsewhere.
Verify and control/limit connections to and use of external systems.
Limit use of portable storage devices on external systems.
Control CUI posted or processed on publicly accessible systems.

Awareness and Training

Ensure that managers, systems administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems.
Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities.
Provide security awareness training on recognizing and reporting potential indicators of insider threat.

Audit and Accountability

Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity. Systems and services that host and run omnibond systems with CUI will have the audit logs centralized through the cloud logging system and retained for at least 30 days
Ensure that the actions of individual system users can be uniquely traced to those users, so they can be held accountable for their actions. For systems that contain CUI, logging will be enabled for privileged activities.
Review and update logged events.
Alert in the event of an audit logging process failure.
Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.
Provide audit record reduction and report generation to support on-demand analysis and reporting.
Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.
Protect audit information and audit logging tools from unauthorized access, modification, and deletion.

Configuration Management

For systems holding CUI establish and maintain baseline configurations and inventories of organizational systems (including cloud services and instance, software, and documentation) throughout the respective system development life cycles.
Establish and enforce security configuration settings for information technology products employed in organizational systems.
Track, review, approve or disapprove, and log changes to organizational systems. Changes will be approved by sending emails to the associated support email list and a change discussion for scheduling for appropriate times based on the change required.
Analyze the security impact of changes prior to implementation. During the email change discussions, security implications will be reviewed.
Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems. Physical security will be provided by the Cloud vendors, logical access will be restricted based on a least privilege access based on system requirements.
Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities.
Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.
Apply deny-by-exception policy to prevent the use of unauthorized software or deny-all, permit-by-exception policy to allow the execution of authorized software.
Control and monitor user-installed software. User installed software will be reviewed during the change management process.

Identification and Authentication

Identify system users, processes acting on behalf of users, and devices.
Authenticate (or verify) the identities of users, processes, or devices, as a prerequisite to allowing access to organizational systems. This will be reviewed during the change management process.
Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.
Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts.
Prevent reuse of identifiers for a defined period of 60 days. If the functions of groups or roles need to change the policy is to delete those then recreate with a different name within 60 days.
Disable identifiers after 3 months of inactivity.
Enforce a minimum password complexity and change of characters when new passwords are created. For Single Factor Authentication.
Prohibit password reuse for a specified number of generations if using single factor authentication.
Allow temporary password use for system logons with an immediate change to a permanent password.
Store and transmit only cryptographically-protected passwords.
Obscure feedback of authentication information.

Incident Response

Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities. Omnibond will use the on-call rotations of the various products, the on-call person will be the security officer on call for the products, customers and services provided by that group’s products. If security incidents occur immediate notification per internal security policy, for security suspicious activities and events. If a breach is suspected or confirmed the notifications as outlined by the respective agreements will be followed. Throughout the process logs and other potential evidence will be retained outside of standard deletion processes.
Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization. Notification outside of the company will reside with the CEO Office and will be according to the regulations and agreements in place.
Test the organizational incident response capability.

Maintenance

Perform maintenance on organizational systems.
Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance. Maintenance will be performed after it has gone through the change management process. Or emergency maintenance will be performed with confirmation from another on the on-call group for that application.
Ensure equipment removed for off-site maintenance is sanitized of any CUI. Any data storage service that does not leverage base level encryption as underlying storage will require writing over the data 3 times.
Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems. Generally this will require validating checksums and only installing from known safe locations.
Require multi-factor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete
Supervise the maintenance activities of maintenance personnel without required access authorization.

Media Protection

Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.
Limit access to CUI on system media to authorized users.
Sanitize or destroy system media containing CUI before disposal or release for reuse.
Mark media with necessary CUI markings and distribution limitations.
Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.
Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.
Control the use of removable media on system components.
Prohibit the use of portable storage devices when such devices have no identifiable owner.
Protect the confidentiality of backup CUI at storage locations.

Personnel Security

Screen individuals prior to authorizing access to organizational systems containing CUI.
Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

Physical Protection

Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals.
Protect and monitor the physical facility and support infrastructure for organizational systems.
Escort visitors and monitor visitor activity
Maintain audit logs of physical access. When accompanying an approved visitor, the visit must be logged per company internal access policy.
Control and manage physical access devices.
Enforce safeguarding measures for CUI at alternate work sites.

Risk Assessment

Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI.
Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.
Remediate vulnerabilities in accordance with risk assessments.

Security Assessment

Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.
Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.
Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.
Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.

Systems and Communications Protection

Monitor, control, and protect communications (i.e., information transmitted or received by organizational systems) at the external boundaries and key internal boundaries of organizational systems.
Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems.
Separate user functionality from system management functionality.
Prevent unauthorized and unintended information transfer via shared system resources.
Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.
Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).
Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection to resources in external networks (i.e., split tunneling).
Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.
Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.
Establish and manage cryptographic keys for cryptography employed in organizational systems.
Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.
Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.
Control and monitor the use of mobile code.
Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.
Protect the authenticity of communications sessions.
Protect the confidentiality of CUI at rest

System and Information Integrity

Identify, report, and correct system flaws in a timely manner.
Provide protection from malicious code at designated locations within organizational systems.
Monitor system security alerts and advisories and take action in response.
Update malicious code protection mechanisms when new releases are available.
Perform periodic scans of organizational systems and real-time scans of files from external sources as files are downloaded, opened, or executed. Google mail used by Omnibond automatically scans email attachments, other sources of downloads should be vetted for freedom from harmful software.
Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks. Google email automatically quarantines suspicious messages.
Identify unauthorized use of organizational systems.

Asset Management

All computational assets are to be maintained and managed through the business office. The business office oversees inventory of assets and who they are assigned to.
All company and customer computational assets including data will be returned within 24hours of resignation or termination whether an employee or consultant.

Employee Acceptable Use Policy
Employees, Consultants and Visitors will not actively or passively engage in the following activities using Omnibond’s computational resources:

Provide access to Omnibond[s network and computing resources to any other person or entity.
Access another user’s account and/or misrepresent one’s identity.
Allow another person to access my account or share my password.
Use computing resources for private profit not related to Omnibond activities.
Intentionally impede the legitimate use of computing facilities by other people.
Use computing resources for junk mail or mass mailing.
Violate any law, regulation, or contract
Publish information that is threatening, harassing, abusive, defamatory or libelous
Publish or distribute illegally copied music, movies, software or other Intellectual Property, or otherwise infringe upon the copyrights of other persons or entities
Publish any information or software used to circumvent software licensing or registration
Advocate or solicit violence or criminal behavior
Use computing resources to generate private profit not related to Omnibond activities.

Technology Disaster Recovery

All production assets will reside in the cloud, for production assets, images of critical instances or binaries will be maintained in different regions with configuration options to bring up in case of a disaster or failure of a cloud region.