In this post, we outline two main compliance obligations relevant to Australia - the OIAC Privacy Act and the ASD ISM. For those familiar with other international compliance obligations, such as the GPG13 (Good Practice Guide) provided by the UK or HIPAA (Health Insurance Portability and Accountability Act) provided by the US, they will find the following information useful, especially when handling data and subsequent file transfers with Australian customers.
The following is just an introductory overview focusing on how SFTPPlus can help organizations with these obligations.
The Office of the Australian Information Commissioner (OIAC) administers the Privacy Act 1988. This Act is an Australian law which regulates the handling of personal information about individuals.
According to the OIAC, the Privacy Act includes thirteen Australian Privacy Principles (APPs). These APPs set out standards, rights and obligations for the handling, holding, use, access and correction of personal information including sensitive information. For more details, please refer to the
OIAC website <https://www.oaic.gov.au/privacy-law/>_.
By ensuring that there is data in-motion encryption, such as the use of SFTP and FTPS in file transfers, organizations and businesses can ensure further security for their file transfers in order to help meet certain obligations indicated within the Privacy Act 1988.
The Australian Signals Directorate (ASD), an intelligence agency in the Australian Government Department of Defence, has provisioned the Information Security Manual (ISM). Originally for government agencies to apply in order to protect ICT systems, the manual can also be of use for the private sector.
For the full documentation and details, please go to the
ASD website <https://www.asd.gov.au/infosec/ism/>. This page is based on the
2017 ISM Manual that was updated in November 2017 <https://www.asd.gov.au/publications/Information_Security_Manual_2017_Controls.pdf>.
While the manual itself encompasses a wide range of topics from access controls to the use of ICT equipment, we have mapped components (SOPs) that is of direct or indirect relevance to file transfers involving SFTPPlus.
The following are Standard Operating Procedures (SOPs) as listed from page 36 of the ISM.
Procedure to be included: Authorising access rights to applications and data.
The SFTPPlus features that will help organizations meet this SOP include; ability to authorize access based on an existing authentication method (such as LDAP or operating system), ability to authorize or via an SFTPPlus application account.
Another example of rolling out proper access authorization is via permissions. User permissions can be set in the application based on extension (such as only making .exe files read-only) and directory (such as only allowing full control for certain folders).
Procedures to be included: Reviewing system audit trails and manual logs, particularly for privileged users.
For each server event that is emitted, this is logged within an audit trail that is available for SFTPPlus administrators. The example log below is of a user authenticating::
| 30014 2018-04-02 10:50:42 Process Unknown 127.0.0.1:50668 New SSH connection made. | 20137 2018-04-02 10:50:42 single-server-uuid 127.0.0.1:50668 Account "erica" of type "os" authenticated as "erica" by os authentication "Operating System Accounts" using ssh-key.
Note that details such as the date, time, type of connection, type of authentication, account name and more are included in this audit log.
Procedures to be included: Managing the review of media containing information that is to be transferred off-site. Managing the review of incoming media for viruses or unapproved software.
For the thorough review of media containing sensitive information, it is expected that SFTPPlus be integrated with a DLP (data leak prevention) software and other related policies to help prevent data leaks.
For the review of incoming media, SFTPPlus can also be integrated with antivirus checks as part of a file transfer process.
Our own customers are already integrating with a number of software that monitors and protects the boundary as part of their file transfer infrastructure.
System integrity audit
Procedures to be included: Reviewing user accounts, system parameters and access controls to ensure that the system is secure. Checking the integrity of system software. Testing access controls.
The text configuration
server.ini file is available to review all configurations - from the authentication methods, configuration parameters and configuration options right through to the services being used.
The SFTPPlus Local Manager also includes the ability to review any changes made, before applying it to the system.
Procedures to be included: Managing the ongoing security and functionality of system software, including; maintaining awareness of current software vulnerabilities, testing and applying software patches /updates / signatures, and applying appropriate hardening techniques
SFTPPlus upgrades are designed to minimize disruption.
Page 250 of the
ISM <https://www.asd.gov.au/publications/Information_Security_Manual_2017_Controls.pdf>_ details these conditions under which TLS can be used, including FTP over TLS (or in other words, FTPS).
FTPS service </documentation/sftpplus/latest/configuration/ftp-service.html>_ can be configured to ensure meeting this conditions - such as using
tls v1.2. To meet the requirement of meeting Perfect Forward Secrecy as determined in page 251 of the ISM, SFTPPlus administrators can explicitly state which SSL ciphers to use. These are cipher suites that implement Perfect Forward Secrecy - Diffie–Hellman key exchange (DHE-RSA, DHE-DSA) or elliptic curve Diffie–Hellman (ECDHE-RSA, ECDHE-ECDSA). Administrators can use the
secure configuration option to only ensure the SSL Cipher Suite configuration for the FTPS service is updated to only use the secure ciphers as recommended by the OpenSSL library.