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Trend Micro

Data Protection

Solutions for

privacy, disclosure

and encryption

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I. INTRODUCTION

Enterprises are faced with addressing several common compliance requirements across multiple geographies and industries. These include protecting confidential data in common usage scenarios, notifying relevant parties when this data is disclosed, and securing this information with data loss prevention and encryption technologies. Factors—such as finding accurate, usable, and cost-effective solutions to meet these requirements—can make the difference between achieving compliance goals and leaving the

organization vulnerable to data loss and non-compliance. Trend Micro Data Protection solutions for data loss prevention (DLP) and email encryption are designed to help organizations meet their compliance requirements easily and cost-effectively.

II.

PRIVACY, DISCLOSURE, AND ENCRYPTION

In simple terms, “compliance” is the adherence to an accepted policy or set of requirements. In terms of meeting global compliance requirements, compliance means protecting confidential data and establishing controls to ensure that requirements are met on an ongoing basis. For more information about the regulatory landscape and specific requirements, please see “Regulatory Compliance – Global Privacy, Disclosure and Encryption Issues”, a Trend Micro white paper.

Confidential Data Types Description

PII: Personality Identifiable Information

Social security number/national identification number, drivers license number, address, phone number

PCI: Payment Card Industry Credit card numbers, Card Verification Value (CVV), expiration date

PHI: Protected Health Information Medical diagnosis codes, disease names, medication names, patient names PFI: Personal Financial Information Financial account number, credit score

Figure 1: Protected data types and data requirements

PRIVACY REQUIREMENTS

Safeguarding the privacy of an individual’s personal, medical, and financial data is of utmost concern to enterprises, especially when it comes to regulatory compliance. Regulations that have been put in place to protect individuals’ privacy usually require that data associated with that individual not be visible or

accessible to unauthorized users. While requirements for HIPAA Privacy and Security Rules tend to be more vague on implementation details, subsequent and related guidelines—such as NIST 800-66 and the

HITECH Act—have stepped in to provide more implementation guidance for enforcing privacy. Monitoring systems for sensitive content can help enforce privacy. If sensitive content is detected, enterprises may choose how to react, whether to report it, block the possible breach, or encrypt the data.

DISCLOSURE REQUIREMENTS

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data belonging to a “resident of California whose unencrypted personal information was, or is reasonably believed to have been, acquired by an unauthorized person.” To address these notification requirements, enterprises must first be able to detect data breaches through regular monitoring of systems that handle confidential data. A recent Massachusetts law (201 CMR 17.00) validates this approach with its requirement for encryption and “reasonable monitoring of systems, for unauthorized use of or access to personal information”.

ENCRYPTION REQUIREMENTS

Regulators are increasingly calling out encryption as a specific technology required for securing confidential data. In some cases, encryption technology is also accepted as a compensating control for when data breaches cannot be prevented, allowing organizations to avoid costly breach disclosure requirements (exemption provisions). For common business processes such as email, DLP can be used to block unauthorized data transmissions, while encryption can enforce the privacy of communications between business entities and individuals—both for legitimate communications and accidental disclosure. Encryption of confidential data sent via email is mandated by many regulations, while others strongly encourage encryption as a means for avoiding breach disclosure requirements.

Direct mandates. PCI DSS mandates encryption of credit card data where it is transmitted (PCI DSS Req. 4) and stored (PCI DSS Req. 3). Similarly, US States including Nevada (NRS 597.970) and Massachusetts (201 CMR 17.00), require encryption of transmitted data for personal records.

Exemption. The HITECH Act (US, Healthcare) states encryption as the technology that can secure PHI, or render ePHI “unusable, unreadable, or indecipherable to unauthorized individuals such that breach notification is not required.”

III.

IDENTIFYING SUSTAINABLE COMPLIANCE SOLUTIONS

A good place to begin an effective compliance strategy is by following a risk-based approach to implementing and auditing IT controls. In practice, this means focusing on business systems where confidential data is likely to be handled (such as email and end user systems) and on network storage locations (such as databases and file servers). This also means focusing on employees—or insiders—who routinely download, create, paste, copy to USB, or attach sensitive data to their emails sent to internal and external users. Once these target systems and users have been identified, it is essential to educate these individuals on important practices—such as acceptable use of this confidential data, document official and ad-hoc processes, and automate controls through proven products. In fact, these areas of focus are known as the three P’s of an effective compliance strategy—people, processes, and products.

Security products are necessary to safeguard confidential data, which is increasingly available in electronic format and handled through the aforementioned business systems. The healthcare industry in particular is poised to see drastic increases in confidential data records due to the recent HITECH Act of 2009, which reinforces the mandate for Electronic Medical/Health Records (EMR / EHR) by 2014.

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These challenges are further complicated by the variety of rules highlighted across global regulations and enterprise security policies. Policy-based solutions are necessary to:

ƒ Monitor different data types such as PII, PHI, PFI, and PCI

ƒ Monitor different user activity such as email, web, instant messaging; copy/paste, printing, copy files to USB/CD/DVD from end-user applications. These channels or protection points often fall into three classes of data—or “data modalities”. They are Data in Motion (DIM), Data in Use (DIU), and Data at Rest (DAR)

ƒ Monitor different types of users, to determine their authorization to handle these data types ƒ Enforce different controls, such as audit, block, quarantine, or encrypt

Securing the sheer volume of enterprise data—especially given the distributed nature of confidential data— can present significant operational challenges. This is why solutions that protect privacy, prevent breaches, and encrypt email communications must be:

ƒ Accurate in their ability to detect confidential data across email, end-user systems, and network storage systems

ƒ Usable so that both administrators and users can easily implement and use the solution ƒ Cost-effective through integration with existing infrastructure and low overhead from previous

generation solutions ACCURACY IS CRITICAL

The ability to detect confidential data is the core element of many regulations. Discovery and monitoring functions must accurately detect content, while at the same time ensuring high catch rates and low false negatives (where the system fails to recognize sensitive data). Enterprises need to be able to identify confidential data without blocking legitimate business processes, such as emails to business partners. The optimal solution must also be intelligent enough to detect portions of restricted content in an otherwise approved action. For example, users often copy and paste regulated content—such as a person’s name, address, or social security number—into emails or USB devices. Compliance solutions should be able to detect and block these actions while allowing the legitimate copy of non-confidential data to devices.

USABILITY IS KEY TO ACHIEVING DESIRED RESULTS

Compliance solutions will not be effective if they are too difficult to use, deploy, or manage. If these solutions are not easy to use, there is a high probability that they will:

ƒ Not be used and therefore leave the organization vulnerable ƒ Be used incorrectly, placing the organization in danger of violation

ƒ Be used inefficiently, requiring too much time or too many resources to manage, thereby increasing total cost of ownership beyond the solution’s value

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Another challenge for encryption is making the determination of which data is confidential and which is not. It is unrealistic to expect users to make this determination in the course of conducting business, increasing the likelihood of compliance violations. To increase compliance and avoid the loss of confidential data, the compliance solution should automatically detect and encrypt confidential data prior to leaving the network perimeter.

COST EFFECTIVENESS RESULTS FROM EFFICIENCY

Data protection solutions that integrate with existing infrastructure can help reduce the costs associated with provisioning new data protection technologies. For example, because most enterprises already have already deployed an email antispam and antivirus solution, adding a compatible email encryption solution can avoid unnecessary hardware costs and improve application performance. This increases efficiencies of scale, since detection and encryption of confidential data are occurring in a single, seamless workflow.

For cumbersome processes like encryption key management, a compliance solution that provides key management as a hosted service may be more cost-effective than an on-premise solution. This approach can be provisioned as needed and does not require the same investment in hardware and IT resources for deployment and management.

IV. THE TREND MICRO ADVANTAGE

Training employees and adapting processes are essential elements of a compliance strategy. Success, however, also depends on implementing proven, policy-based endpoint or network data loss prevention (DLP) and email encryption solutions—while also ensuring that they are accurate, usable, and cost-effective. Trend Micro delivers solutions that are optimized to address compliance and more, by helping to protect users and confidential data from the growing threat of web-based attacks—such as viruses, malware, and malicious techniques used to steal data. Trend Micro solutions provide layered security, whether at the gateway or endpoint, and are powered by the Trend Micro™ Smart Protection Network—a next-generation, cloud-client content security infrastructure helps detect and contain threats before they reach the business.

Business Need Trend Micro Solution

Educate employees on proper data usage

policies, with real-time alerts ƒ Trend Micro™ Data Loss Prevention Protect confidential data from misuse by

“authorized insiders”, whether accidental or malicious

ƒ Trend Micro Email Encryption

ƒ Trend Micro Data Loss Prevention

Protect sensitive data, whether in use, at rest or in motion across both endpoint and gateway layers

ƒ Trend Micro Data Loss Prevention

ƒ Trend Micro Email Encryption

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Business Need Trend Micro Solution

Protect datacenter servers from attack, regardless of whether they are physical or

virtual ƒ Trend Micro Deep Security Continuously monitor for active, data-stealing

malware infections and receive early warning notifications of malware outbreaks

ƒ Trend Micro Threat Management Services

Protect user endpoints with antivirus, anti-malware, anti-spyware, personal firewall, and host intrusion prevention system

ƒ Trend Micro OfficeScan™

ƒ Trend Micro Endpoint Security Platform

ƒ Trend Micro Threat Management Services

ƒ Trend Micro Deep Security

Provide messaging, web, and endpoint security; Protection against inappropriate content, spam and phishing, spyware, rootkits, bots, viruses and trojans, web threats, worms, and network attacks

ƒ Trend Micro Enterprise Security Suite

ƒ Trend Micro ScanMail™ for Exchange/Domino

ƒ Trend Micro InterScan™ Web/Messaging Security

Figure 3: Trend Micro Data Protection Solutions – Extended

TREND MICRO DATA LOSS PREVENTION

Data loss prevention (DLP) solutions are designed to protect sensitive information such as customer, employee, and patient data as well as intellectual property. This is generally accomplished by monitoring and preventing information leaks across multiple threat vectors, including email, webmail, instant messaging, USB drives, and CD/DVDs. However, many solutions that are designed to monitor and block sensitive data have shortcomings. Less than ideal solutions will:

ƒ Scan data at endpoints too slowly ƒ Handle a limited number of documents ƒ Fail to detect data in multiple languages ƒ Do not support partial data matching

ƒ Cannot identify and protect sensitive data when users are offline

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It is important to secure protection points that cover three data modalities:

ƒ Data at Rest. The Trend Micro solution scans endpoints and file systems for confidential data, giving enterprises visibility into where their confidential data is being stored and accessed.

ƒ Data in Use. Trend Micro DLP also monitors data in use across numerous communications channels such as USB-based removable storage, CDs, DVDs, and printers.

ƒ Data in Motion. Trend Micro DLP provides protection for channels that include email, webmail, instant messaging, and FTP.

These protection points can be enabled at the endpoint or network and can include the following actions: log, warn user, capture forensic data, require user justification, or block. This helps to improve compliance over time, as users are educated at the point of the violation—a pop-up screen explains the organization’s policy and prompts for justification of the prohibited action.

While implementing controls is part of the compliance challenge, validating these controls against the data protection policy plays an even bigger role: it’s core to the audit process. Compliance audits, such as those required by PCI DSS, require tamper-proof activity logs to prove that controls are in place and are effective for protecting confidential data. Trend Micro DLP provides these logs, as well as compliance reports that highlight violations and the confidential data that was detected. This helps to greatly mitigate risk over time.

TREND MICRO EMAIL ENCRYPTION

Email encryption solutions enable organizations to enforce compliance requirements and to ensure that confidential information is delivered securely. However, using traditional encryption solutions to protect email and attachments from unwanted eavesdropping, tampering, and spoofing is often complex—placing

additional burdens on IT management.

Trend Micro Email Encryption solutions are easy to use within an existing email infrastructure. They provide universal reach by allowing organizations to deliver private email to any recipient without burdensome recipient pre-registration or certificate management of Public Key Infrastructure (PKI) technology. Encrypted content is simply pushed from senders to recipients like any other email. While the solution is offered in both hosted and on-premise versions, hosted encryption goes further in maintaining public keys, securing private keys, and managing certificate revocation lists on behalf of customers. The Trend Micro hosted service enables even small or medium-sized businesses to cost-effectively address encryption requirements.

Trend Micro also addresses usability and accuracy concerns by removing the dependence on end users to enforce the encryption of their confidential emails. Policy-based email encryption automatically encrypts and decrypts emails based on administrator-defined policies—using content filtering capabilities from a

messaging security gateway solution, such as Trend Micro Hosted Email Security.

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V.

TRUST A SECURITY INDUSTRY LEADER

Trend Micro data protection solutions address privacy, breach disclosure, and encryption requirements with Email Encryption and Data Loss Prevention solutions. These solutions address common IT compliance challenges with accuracy, usability, and cost-effectiveness. As a global leader in Internet content security, Trend Micro focuses on securing the exchange of digital information. Based on extensive content security expertise, Trend Micro correlates threat data from an average of more than 5 billion dynamically rated websites, spam sources, and files every day. Thousands of companies continue to trust their data protection to Trend Micro—a company with 20 years of experience dedicated to content security and expertise based on a history of innovation.

To learn more about Trend Micro solutions for addressing regulatory compliance, contact your Trend Micro representative or visit www.trendmicro.com.

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