The New York Stock Exchange takes a data-centric approach to secure its valuable asset – trade data, reports
By Ericka Chickowski, Secure Computing
17 October 2006
NYSE & ARCHIPELAGO:
Security + Business
One of the biggest merger announcements to hit Wall Street was the one involving the New York Stock Exchange and Archipelago Holdings. When the deal went final in March of this year, the newly formed NYSE Group began transitioning technology executives — including Sunil Seshadri, vice president of information security, IT risk management and compliance, and chief technology officer Steve Rubinow — from Archipelago over to the new business.
It also had to begin to formulate how the company would approach security. According to Rubinow it has been a matter of meshing two distinct policies into something that was cohesive, affordable and compliant with SOX and other regulations.
“It’s fair to say that Arca had one security model and New York had a different security model — neither good nor bad, just different,” Rubinow says. “And when we put the two of them together, just like with the technology strategy, we had to say ‘What are the best aspects of both security models?’ and then overlay cost considerations.”
“At the end of the day everybody looks at what the business dependency is on data that we have,” says Seshadri, vice president of information security, IT risk management and compliance for NYSE Group. “Historically, with organizations there has been a tremendous amount of focus on securing the perimeter — keeping the bad guys out. But at the end of the day, what is it they’re trying to reach? They’re trying to reach some set of confidential or sensitive data at the backend.”
At NYSE, there are hundreds of millions of transactions that pass through company systems each trading day. The well-being of hundreds of corporations, and the economy as a whole, depend on the integrity of this transaction data, which is why Seshadri and his team have taken pains to ensure they know exactly who has access to this data and what they are doing with it in real time.
Currently, Seshadri uses database auditing to keep track of electronic trading facilitated by the NYSE Arca division, which was formed as a result of the NYSE-Archipelago Holdings merger earlier this year. Before the deal, Archipelago was completely Sarbanes-Oxley (SOX) 404 compliant through the use of the auditing tools and other oversight measures. He plans to bring the same tools to the floor trading databases of the NYSE Group by the end of 2007 in order to meet the newly formed company’s deadline for SOX compliance.
This kind of oversight is critical in lines of business such as those at the stock exchange, where the temptation for an employee to go rogue can be extremely high. According to Ellen Libenson of Symark, an identity management and access control vendor, simply putting the tools for accountability in place can be a powerful deterrent.
“Everybody is human, everyone is subject to temptation at some point in their [lives],” she says. “And if you have a fox in the henhouse, it’d be nice to never find that out the hard way. If everybody’s access is documented and they know there is accountability, then they are less likely to cross that line.”
According to Seshadri, the monitoring activity is as important as the access management issues. “For a lot of companies it comes down to ‘Do the right people have access to their information?'” he says. “I think they are able to answer that from an entitlement standpoint, but the question then becomes, ‘Are these right people doing the right things?'”
Seshadri and his security team rely on database auditing tools to make certain that privileged users don’t abuse their rights. “When someone like a database administrator makes a change — be it to a database structure, a schema, a trigger or a value in a table — all of that is actively recorded,” he says.
The information security department is kept up to date on these changes through a continuous reporting structure and, in the event of a violation or problem, through an email alert that is sent only a few seconds after the event occurs. To ensure accountability, there is also a process for logging program change management — all of which flows through Seshadri’s department.
“We have a process with the folks on the backend where when they make a change to a program, they tie into a specific change management work order process so that there is an independent group — the information security group — that now has a line outside into the changes that are happening to financial information,” he says.
The key to all of this financial data tracking and alerting comes down to a good policy that lays out the hierarchy of data and what to keep closest tabs on.
“You set up roles and rules based on the type of data, who can access it and what can they do,” says Cliff Pollan, CEO of Lumigent, which is the vendor NYSE uses for database auditing.
Strong policies will lay the foundation for a strong overall data-centric security stance, Pollan says. He explains that tracking privileged users through the database is the first step to securing the data. But practitioners will likely need other point solutions to handle problems that can happen once users move beyond those applications — for example, if a user cuts and pastes information from the database, they’ll need content filtering to track the data once it leaves the database.
“Often people are constraining access to the data through the application, so the reason that they’re more concerned about direct access or more privileged access is that they are getting comfortable with the fact that it is a different problem once you force everyone through the application,” he explains.
At that point it could become a content leakage problem, he says, which will need to be monitored by complementary tools.
Ken Davis of Oakley Networks agrees. “You have to simultaneously approach the problem from the other side. How do you monitor the behavior of those users while they’re accessing that information and those resources, and then have policies in place that identify when that access is inappropriate, and then do something about it?” says Davis.
Oakley specializes in behavior analysis and monitoring, which can help a business check to see if a user is doing something like cutting and pasting from a sensitive application into a less sensitive spot, or doing a print screen when sensitive information is on the monitor. These types of activities can’t be solely monitored by database monitoring. Separately, products such as those made by Lumigent and Oakley can be useful, but together they can be extremely empowering to an information security professional.
“There are the downstream pieces that this needs to fit into,” Pollan says. “As it gets further away from the database, there are other technologies you start to use. The reason people care about where it starts, is because that’s where the asset is. You should be able to say, ‘We know where it started, it is in a payload somewhere in the network,’ and then watch that payload as it goes through the network.”
Seshadri at NYSE concurs, pointing out that the best practice is a layered, but focused, approach. For his organization, this means not only using the best data-centric techniques, but also keeping the good elements of a network-centric approach. In effect, his organization takes an inside-out line of defense, starting where the data is most vulnerable and moving outward.
“We’re looking for a model that is a happy medium between a data-centric and a network-centric security model,” he says.
Clearly, the New York Stock Exchange by necessity is ahead of the security curve. Though analysts, as a result of regulations such as Sarbanes-Oxley, are predicting a shift toward a more data-centric approach to data security, there is still a way to go before the average organization moves beyond securing just the underlying IT infrastructure.
“I think people are waking up to the fact that there has to be a sustainable mechanism in place to monitor the who, when, what, where, how,” Seshadri says. “Who is accessing sensitive information? When are they accessing it? What is it that they are accessing? Where from? And how are they doing it? And do we have an appropriate controlled structure to answer those questions, be it internal to the company or any other regulatory agencies on the outside?”
By answering those questions, either through third-party tools or homegrown solutions, business will not only get a handle on data security, they’ll also likely improve their operations.
“Not only does it prevent outright fraud and theft of data, I think, in general, it just helps someone run their company better,” Libenson says. “You can prove who is doing what. If you log and track, you can easily go back and find out where a mistake was made.”