"...health care is among the most vulnerable industries in the country, in part because it lags behind in addressing known problems."
When it comes to application-level security, the healthcare industry is indeed lagging when compared to other industries that handle consumer sensitive information. The Payment Card Industry Data Security Standard (PCI DSS) is an information security standard for organizations that handle cardholder information. The PCI DSS certification includes requirements for security code reviews, penetration testing, and compliance validation by an external Qualified Security Assessor (QSA).
This week, the Department of Health and Human Services (HHS) issued a final omnibus rule on the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules. The rules impose the following:
- Increased and tiered civil money penalty structure for security breaches depending on "reasonable diligence", "willful neglect", and "timely correction". The penalty amount varies from $100 to $50,000 per violation with a maximum penalty of $1.5 million annually for all violations of an identical provision.
- Expansion of accountability and liability for Business Associates (BAs) and subcontractors.
- Increased privacy protections under the Genetic Information Nondiscrimination Act (GINA).
Furthermore, the Security and Privacy Tiger Team of the US Office of the National Coordinator (ONC) for health IT released a set of recommendations related to the Meaningful Use (MU) Stage 2 requirements for patients access to health record portals. The need for patient engagement as a prerequisite to a successful transformation of healthcare means that particular attention should be paid to the security needs of consumer-facing web applications.
Security in the Software Development Life Cycle (SDLC)
Unfortunately, security as a non-functional requirement, is often relegated to an afterthought in the software development life cycle (SDLC). As an afterthought, security is added to the software later or at the end of the development cycle. At that point, adding adequate security is difficult and costly, requiring significant rework. In some cases, penetration testing is not performed at all before the application is deployed into production.
This situation can be exacerbated by an interpretation of the Agile methodology that puts the emphasis on the early and frequent demonstrations to the customer of functional (as opposed to non-functional) features of the system under development.
Another issue is that developers and architects often over-rely on 3rd-party security infrastructure, as opposed to (1) developing a Threat Model for the application they are building and (2) creating a security implementation approach to address the Threat Model. 3rd-party security infrastructure can be helpful, but should serve the security implementation strategy as opposed to driving it. As Bruce Schneier, a well-known cryptographer and computer security specialist said in an article titled "Computer Security: Will We Ever Learn?":
"Security is a process, not a product. Products provide some protection, but the only way to effectively do business in an insecure world is to put processes in place that recognize the inherent insecurity in the products. The trick is to reduce your risk of exposure regardless of the products or patches."
Understanding Potential Security Vulnerabilities
Application Security is a mature discipline. Developers and architects should build a deep understanding of web application security vulnerabilities as opposed to completely relying on 3rd-party security infrastructure for addressing security concerns. The following are well documented bodies of knowledge on security vulnerabilities:
- The OWASP Top 10 Web Application Security Risks (cheat sheets explaining each of those vulnerabilities and how to address them are available on the OWASP web site):
A2: Cross-Site Scripting (XSS)
A3: Broken Authentication and Session Management
A4: Insecure Direct Object References
A5: Cross-Site Request Forgery (CSRF)
A6: Security Misconfiguration
A7: Insecure Cryptographic Storage
A8: Failure to Restrict URL Access
A9: Insufficient Transport Layer Protection
A10: Unvalidated Redirects and Forwards.
- The CWE/SANS Top 25 Most Dangerous Software Errors, the result of collaboration between the SANS Institute, MITRE, and many top software security experts in the US and Europe.
- Programming language-specific vulnerabilities such as those listed in the Cert Oracle Secure Coding Standard for Java.
- Well-documented security vulnerabilities introduced by the use of 3rd-party open source application development frameworks.
- The National Vulnerability Database
- The Common Weakness Enumeration (CWE) which is currently maintained by the MITRE Corporation with support from the National Cyber Security Division (DHS). The diagram below from the CWE web site shows a portion of the CWE hierarchical structure. Click on the image below to enlarge it.
- Obviously, developers should be on the lookout for new and emerging threats to web application security.
Application Threat Modelling
Armed with a deep understanding of potential vulnerabilities, developers and architects can build a Security Policy (who has what type of access to which resource in the system) and a Threat Model including:
- An analysis of the attack surface of the application.
- Identification of potential threats and attackers (both inside and outside the organization and its business associates and subcontractors) and their characteristics, tactics, and motivations. A threat categorization methodology such as STRIDE can be used. STRIDE defines the following threat categories: Spoofing of user identity, Tampering, Repudiation, Information disclosure (privacy breach or Data leak), Denial of Service (D.o.S.), and Elevation of privilege.
- The consequences of those attacks for patients and the healthcare organization serving them.
- Countermeasures and a risk mitigation strategy. The Application Security Frame (ASF) defines the following categories of countermeasures: Authentication, Authorization, Configuration Management, Data Protection in Storage and Transit, Data Validation/Parameter Validation, Error Handling and Exception Management, User and Session Management, Auditing and Logging.
- How the deployment environment will impact privacy and security. NIST and the Cloud Security Alliance (CSA) provide specific security guidance for cloud deployment.
- New software architectures like the Single Page Application (SPA) approach present new challenges in securing web applications. Single Page Applications are subject to common web application vulnerabilities like Cookie Snooping, Cross-Site Scripting (XSS), Cross-Site Request Forgery (CSRF), and JSON Injection. Security is mainly the responsibility of the server, although client-side frameworks like AngularJS also provide some features to enhance the security of Single Page Applications.
Developing a Security Implementation Strategy
To address the issues of secure software development in the context of Agile, the Software Assurance Forum for Excellence in Code (SAFECode) published a guide titled "Practical Security Stories and Tasks for Agile Development Environment".
Secure Coding Standards, Static Analysis, and Security Code Review
Many developers are aware of coding conventions (such as the Code Conventions for the Java Programming Language), and the benefits of peer code reviews and static code analysis (using tools like Checkstyle, PMD, FindBugs, and Sonar). These practices should be expanded to cover secure coding as well. The following resources can help:
- The Cert Oracle Secure Coding Standard for Java.
- The OWASP Code Review Guide.
- The "Fundamental Practices for Secure Software Development: A Guide to the Most Effective Secure Development Practices in Use Today" published by the Software Assurance Forum for Excellence in Code (SAFECode)
- The Payment Card Industry Data Security Standard (PCI DSS) "Information Supplement: Requirement 6.6 Code Reviews and Application Firewalls Clarified" is an example of secure code review requirements in an industry vertical.
There are secure code static analysis tools that can be particularly useful when used in combination with a secure code review process. If possible, the static code analysis should be integrated into the build and continuous integration process to provide specific secure code metrics as well as the evolution of those metrics over time.
Finally, the application should go through penetration testing before it is deployed into production. Application-level penetration testing should be done in addition to network-level penetration testing. OWASP provides a detailed Testing Guide and a number of open source and commercial penetration testing tools are available as well.