CROSS-WALK ANALYSIS OF NIST, CIS, CSA
BY: ANTONIO NOLAND , MONTEZ BELL, ARAMIDE OSO, ANISH GANGA, BEN LIFSHITZ
Planet Fitness
Center for Internet Security�(CIS)
CIS Benchmarks
CIS Benchmarks Explained
Inventory and Control of Enterprise Assets
Inventory and Control of Software Assests
Data Protection
CIS Benchmarks Explained
Secure
Account
Access
CIS Benchmarks Explained
Continuous Vulnerability Management
Audit Log Management
Email and Web Browser Protections
CIS Benchmarks Explained
Malware Defenses
Data Recovery
Network Infrastructure Management
CIS Benchmarks Explained
Network Monitoring and Defense
Security Awareness and Skills Training
Service Provider Management
CIS Benchmarks Explained
Application Software Security
Incident Response Management
Penetration Testing
NIST Framework
3 Key Components
NIST Framework Core
NIST Publications
NIST Framework Profiles
Target Profile
Current Profile
Gap Analysis
NIST Implementation Tiers
Partial
Little to no prioritization to risk
Risk Informed
Aware of the risk, but do not have the controls in place
Repeatable
Have policies in place, repeated
Adaptive
Constantly changing and adapting to the landscape
Cloud Security Alliance �(CSA)
CSA Characteristics and Models
CSA Characteristics and Models Explained
Characteristics
Cloud computing requires all these characteristics. If it lacks any of them, it is likely not a cloud.
Resource Pooling: The most fundamental characteristic. Collects all resources and pools them together. It then allocates them to different consumers.
On-Demand Self Service: Consumers can manage recourses without human administrating.
Broad Network Access: Resources are available over a network without any need for physical access.
Rapid Elasticity: Consumers can expand resources from the pool automatically.
Measured Service: Ensures Consumers only use what is needed. The client only pays for what they use
Service Models
There are 3 service models describing the different foundational categories of cloud services:
Software as a Service: a full application that is managed and hosted by the provider. Accessed with web browser, mobile app, or client app.
Platform as a Service: Provides development or application platforms such as databases, application platforms, file storage, and collaboration. With PaaS, you do not manage the underlying servers, networks, and infrastructures.
Infrastructure as a Service: Offers access to a resource pool of fundamental computing infrastructure, such as compute, network, or storage.
Deployment Models
These are how the technologies are deployed and consumed, and how they are applied across the entire range of service models.
Public Cloud: Available to the public or a large industry group and is owned by an organization selling cloud services
Private Cloud: Operated for a single organization. It may be managed by the organization or by a third party and may be located on or off premises.
Community Cloud: Cloud shared by several organizations and supports a specific community that has shared concerns.
Hybrid Cloud: Composed of two or more clouds (private, community, or public) that remain unique entities but are bound together. Commonly used to describe a non-cloud data center bridged to a cloud provider.
CSA Security Scope
How do they compare? (Similarities)
Differences
Framework | Guidance Criteria | Target Industry | Core Function |
NIST | Risk Based Guidance Framework (some ambiguity) You can apply all of the standards or apply a few within the framework based on your organization’s needs and goals. Ranked by Low, Moderate, and High | Federal Sector | NIST provides security objectives. Essentially, it helps your organization think about its risk and then helps point you in the right direction to better understand how to identify and respond to these risks, for example, in terms of access control, response, authentication, etc. It provides you with information to help you look at all of your critical assets, and then apply NIST guiding statements to those assets. |
CIS V8 | Maturity-Driven Framework | All | CIS is more explicit. It doesn’t just give you a generalized objective. It provides you with explicit control, which is worded in such a way you understand how to adopt and implement it. |
CSA | A new operational model and set of technologies for managing shared pools of computing resources. | Cloud Sector | The Cloud Security Alliance (CSA) promotes implementing best practices for providing security assurance within the domain of cloud computing and has delivered a practical, actionable roadmap for organizations seeking to adopt the cloud paradigm. |
Planet Fitness Framework Analysis
Our selection process involved looking at the NIST CSF, NIST 800-53 as a starting point. We defined the must have , nice to have requirements and we considered the CIS Framework is more closely aligned with the industry and business size and risk profile for Planet Fitness.
Planet Fitness buys workout equipment and supplements from multiple different providers. Additionally, Planet Fitness locations have inventory for the staff, most importantly, computers. These computers are part of Planet Fitness' assets and must be properly maintained and secured. ��
The CIS framework aims to help organizations actively manage ALL assets. This is done through a multi-step process which eventually helps organizations detect the totality of assets that need to be monitored and how to protect them. Members of Planet Fitness have extremely sensitive PII data entered into these computers, and the CIS framework is the most ideal as it has a very in-depth, multistep process to help secure this information.
Planet Fitness Framework Analysis
Assessment Criteria | Rationale: | Industry Benchmark | Planet Fitness Rating | Areas for Improvement / Achievement |
Service Provider Management (Control 15) | For Planet Fitness, selecting which Manage Services Provider (MSP) to partner with is critical. The increased popularity of MSPs has given rise to a greater pool of providers with a varying range of expertise and experience. Because of the sensitive data that gyms contain it is essential to choose an aligned MSP. | Gyms in this category are not at optimal levels concerning vendor management and security. At a minimum, all gyms have personal information relating to their employees and some amount of personal information on their members and guests A single gym can easily process and store hundreds or thousands of financial transactions, including credit card data and banking information. | Moderate | After review of partnerships and key service providers, Planet Fitness ranks higher in this category compared to others however, while they have a lot of partnerships, the focus is on services offered rather than trusted providers in the industry such as key partnerships with leading privacy and health advocates. Limited data on their policy of sharing data with MSPs and the extent of data is protected and controlled. |
Application Software Security (Control 16) | Planet Fitness uses Salesforce. This includes shield platform encryption, event monitoring, and field audit trails. Although these features are implemented through Salesforce, Planet Fitness is urged to implement additional software security following the CIS framework. | Typically, gyms do not take the security of their software seriously. They do not believe they need to specialize in that since they mainly just provide a space for people. These companies are also vague with how they secure their software. | Needs Improvement | Planet Fitness incorporates some of its software security from a third-party system (Salesforce). This software keeps track of all digital activity between the club, its members, and perspective members. While this is helpful, Planet Fitness still needs to implement and customize additional security on their software. |
Data Protection (Control 3) | Planet fitness processes a huge amount of sensitive customer information, and the protection of this data is vital to the company image and its customers. | Gyms typically have data that is encrypted at rest and while moving. This minimizes the opportunity for attackers to intercept plaintext. With such high amounts of customer PII gym franchises must ensure that unused data is properly disposed of. Any cloud data should be thoroughly protected through the CSP or through security mechanisms put in place by the company. | Good | Planet fitness processes a lot of customer PII and they encrypt and dispose of that data in a secure fashion. However, to insure further security they can implement greater endpoint security, with mechanisms such as firewalls and security detection/prevention devices. Currently they use Salesforce to handle their data processing and put the security in the hands of the service provider. However, the on premise devices that planet fitness handles need to implement further security controls and mechanisms. |
Planet Fitness Analysis Cont.
Assessment Criteria | Rationale: | Industry Benchmark | Planet Fitness Rating | Areas for Improvement / Achievement |
Security Awareness and skills training (Control 14) | The employees at Planet Fitness have access to sensitive information collected from their customers and need to be trained on how to reduce the chances of breaches. | Gyms do not really put a big emphasis on security training because they believe that it is not as important for gyms as it is for big companies. | Good | While planet fitness has an online platform that delivers its security awareness courses, the company needs to also train their employees to identify and report attacks, best handle data collected, and adopt best authentication practices. |
Inventory and Control of Enterprise Assets (Control 01) | Planet Fitness stores extremely sensitive PII on computer inventory and orders thousands of equipment machinery every year. | Gyms in this class are moderate in terms of controlling sensitive data, several news outlets have reported on sensitive data leakage with employees related to data controls. | Moderate | Planet Fitness needs to better establish and maintain an accurate inventory of all enterprise assets that have the potential to store or process data. This must include all software apps and web servers They must ensure all unauthorized assets are addressed and removed promptly. |