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Oracle Auditing for Risk Management and Regulatory Compliance

Oracle Tips by Burleson Consulting
November 2004

 

For complete details on Oracle auditing and Oracle forensics, see these recommended books:

 


 

This whitepaper is a comprehensive overview of database auditing best practices and methods for the IT manager.  With the introduction of rigorous Federal laws, the IT manager must plan to fully monitor and audit access to mission-critical and confidential information, all while maintaining a complete and reliable auditing framework. 

 

Managers have realized that the information gleaned from audit trails of database activity can be the company’s single largest data resource.  They also recognize that their audit trails provide a temporal “third dimension” of their information, a valuable time-series view of their production systems that contains all-important behavioral aspects of their data access.  While there are various approaches to auditing critical database platforms, implementing an enterprise class solution that provides a comprehensive auditing and reporting capability is not an easy task.  We’ll begin with a summary of the most important concerns of the IT manager and then examine various methods of implementing a successful enterprise auditing solution.

 

The main points of this whitepaper address the issues of the highest concern for IT management. 

·         Avoiding business risk and meeting the demands of customers and business partners – While the laws demand a thorough and comprehensive approach to privacy and auditing, the most important reason for protecting your data integrity is your professional reputation.  The standards are high, and it is necessary to have a complete top-down auditing and protection solution to work with other businesses.  Your partners must cover themselves and they are not likely to have the time, money or patience to audit a complicated home-grown solution.  Remember, the driving force is your business need and your customer demands for data integrity and privacy. 

 

·         Satisfying the auditors – Implementing best practices including segregation of duties – When considering the Build vs. Buy approach, it should be carefully considered that systems administrators, database administrators and developers cannot have direct access to the auditing solution because exposures result when they have intimate knowledge of the internals of the audit mechanism. Any auditing solution must have the capability of providing for segregation of duties to ensure that these users can be denied access to the resulting audit trail to ensure the integrity of audit reports generated by the system.

 

·         Avoiding civil and criminal penalties - Data asset management practices must address business, operational, legal and compliance needs.  Many Federal laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Sarbanes Oxley Act (SOX) and the Gramm Leach Bliley Act (GLBA) change the way that databases are secured and audited and some of these federal regulations impose severe criminal penalties for non-compliance and malfeasance with protected data.  Non-compliance with these regulations can also expose your company to multi-million dollar civil lawsuits from customers if their private information has been improperly disclosed.

 

·         Choosing the right auditing approach – Many database vendors (e.g., Microsoft, Oracle) offer product-specific utilities to enable auditing, but these audit and trace tools are generally meant to be used only sporadically for investigative and forensic activity.  Piecemeal solutions to auditing are difficult to scale, generally impose significant performance impact on the systems, and are very difficult to manage.  Approaching auditing and privacy efforts at the application layer leaves direct access to the database unaudited, and results in incomplete coverage and a hodge-podge of in-house and third-party audit logs that are impossible to manage and reconcile. 

These are just a few of the IT managers’ concerns in this brave new world of security, privacy and regulatory compliance.  Your customers and business partners expect you to have a complete privacy auditing solution.  Let’s take a closer look at the issues and see how you can protect yourself from common pitfalls and implement a comprehensive and manageable solution.

Developing a Corporate-wide Auditing Framework
 

The IT manager must view Auditing as a homogenous system, spanning all applications and database platforms.  This is especially important with the new Federal laws that put the onus of maintaining the security and auditing policy on the custodians of the data, the IT management.  The Federal laws do not specify or require specific technologies or standards to be followed, and it is your responsibility to decide the best possible approach to assure compliance. However, it is precisely the implementation that requires an exercise of due diligence to select a rigorous security policy.

 

For any large company, manageability, reliability and scalability are the critical success factors of an auditing solution:

·         Performance – The solution must have a minimal performance impact with low maintenance and upgrade overhead.

 

·         Manageable – The SA, DBA and developer staff cannot be involved in the auditing or have any privileged access rights.  The solution must be segregated, unified and platform independent.  The solution must be flexible and easy to extend and maintain as IT database requirements change.  The system should include centralized ability to configure and deploy across numbers of servers, and regardless of database platform.

 

·         Provide business value – The solution must be usable by security and auditing personnel as well as line of business owners with a clear and understandable reporting capability.
 

·         Complete – The solution must be complete and comprehensive.  Because many applications span database platforms, it should have a unified interface for all databases, regardless of platform.  It must be reliable and have an automated and secure mechanism for long-term archival management.  Successful companies view their privacy and auditing as a system in-itself, not as a strap-on to existing systems.

Ensuring a Complete Enterprise Solution
 

Creating an auditing architecture from diverse data sources and applications is a huge challenge.  The IT manager must ensure that every important aspect of privacy, security and auditing are covered and they must do so while ensuring that their solution in easy to manage and scalable.  A n effective auditing solution must have these characteristics:

 

·         Reliability and completeness

·         Real-time notification of critical events

·         Consolidation of audit data streams

·         Reporting value and ease of reporting

·         Long-term retention of audit trails

·         Manageability and scalability

 

While simple in concept, these requirements are extremely complex and difficult to implement, especially with the huge volumes of data that must be archived.   Because auditing is required by both IT best practices and U.S. Federal laws, IT managers typically adopt products designed specifically for this purpose.

Reliability and Completeness
 

Many IT shops fail to realize that a haphazard “sampling” approach to auditing is insufficient. A continuous audit is required and the audit must be archived for long-term access. 

 

This is not an easy task.  In cases where you must audit the viewing of confidential data you might need to archive a volume of data greater than the size of the whole database, everyday, 365 days a year.  With many shops archiving hundreds of gigabytes of data every day, it becomes critical that all of the archived data be accessible and complete. 

 

For example, HIPAA requirements clearly state that user accesses to the database be recorded and monitored for possible abuse. Remember, this intent is not only to catch hackers but also to document the accesses to medical databases by authorized end-users.  In today’s litigious society, prudent companies capture the “who”, “where”, “what”, “when” and “why” for all access to confidential information.  The “why” aspect is critical because authorized end-users may access confidential information for unsavory purposes.

 

The data volumes of audit information can be staggering.  Larger shops may capture trillions of bytes of auditing information every week, archive and store this data for several years, and have an automated mechanism to easily extract information about any individual in their database.

 

A comprehensive solution must also have the ability to audit all possible points of entry to the data.  It must audit access from the operating system (at the data file level), from the database management layer, the network and from the application layer (Figure 1).

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  

 Figure 1 – The multi-layer data exposure issue

 

 

In a typical organization, data access occurs at many levels - - - at the end user presentation layer, at the middle tier, at the application server layer, at the web server layer, at the standalone application screens and finally, at the database level directly. A properly compliant security implementation knows that it is almost impossible to clearly identify and secure all the remote data access points and that proper security and auditing is firmly in-place at the data source. Attempting to audit data from multiple remote layers is suicide, especially when hackers have learned to access information from outside the application layer, accessing the data directly from within the database or accessing the data files directly from the server.

 

The ability to capture data access at the data source is an absolute requirement for reliable data auditing.  While all legitimate data access is done via the application malicious hackers rarely access the system via the application screens.  Instead they access the data directly from the files on the operating system or gather the data directly from the database layer.  We also see hackers gathering confidential information directly from the web cache layer, using buffer overflow techniques to grab information from outbound HTML pages.

 

Even at the database layer there are opportunities to bypass the application.  Ad-hoc query tools such as SQL*Plus, Crystal Reports and ODBC tools provide backdoors for legitimate users to bypass application layer auditing.  

Consolidation of Audit Data Streams
 

Very few IT shops have a single database source and it can be a nightmare to try to consolidate auditing archives from heterogeneous database platforms.  Each database product manages archives in differing formats and cross-database issues can be impossible to resolve without centralization.  Audits from different database products are archived with different character sets, different formats and different organizations (Figure 2).

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 2 – The problem of auditing diverse data

 

 

Here the problem is consolidating audit information along two dimensions, the multi-layer dimension and the multi-product dimension.  The key to success in this type of heterogeneous environment is to simplify the sources for data collection and to collect audit information at the source, the database layer.  For those using relational databases such as Oracle, SQL Server and Sybase, using the traditional “grant” access to authorize end-users allows them to access the data via alternative methods such as ODBC interfaces.

 

For example, it is nearly impossible to track data viewing at the “intrusion” levels (i.e. ODBC, Crystal Reports, SQL*Plus) with application-layer auditing tools.  Even if we attempt to close backdoors, there is no guarantee that all data access will happen from within the application. 

 

By auditing the data disclosure at the source, we eliminate the need to track access from multiple points and we greatly simplify the data auditing model (Figure 3).

 

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 3 – Cross-product data auditing

 

Now that we have ensured that all data access auditing is done at the source of the data, our only remaining issue is dealing with audits from multiple data sources.  This is especially problematic for shops with a mix of database architectures such as relational databases (Oracle), object-oriented databases (Ontos), network databases (CA-IDMS) and hierarchical databases (IMS).

 

Regardless of the database architecture or specific product, all data audits must capture this information:

 

·         Who – A full identification of the person viewing or modifying the data

·         Where – A log showing the specific application procedure and method used to access the data

·         When – A reliable date-time-stamp, globalized to Greenwich Mean Time (GMT)

·         What – A full listing of all data entities that were viewed or modified

·         Why – Context-based information describing how the data was disclosed

 

By using a database independent vendor package you can put the audit logs in an identical format and provide a unified audit trail for the all-important reporting interface.

 

Remember, the audit trail is a database too, and for most shops it is the single largest data repository for the entire company.  Just as you purchase a database product that is designed to meet your application needs, many companies choose an auditing solution that is specifically designed for the needs of auditing (Figure 4).

 

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 Figure 4 – A unified database for managing audit information

 

Now that we see the high-level architecture of the privacy auditing collection and consolidation mechanism, let’s dive deeper and explore how these giant audit databases are managed. 

Minimizing Auditing Performance Overhead
 

Creating an unobtrusive auditing solution is a primary requirement for many shops.  Those companies who have tried to cobble-together auditing using generic database tools often find a huge overhead.  For example, Oracle shops are often tempted to use database “triggers”, a generic mechanism that fires an event when a database object is changed.  The overhead of using database triggers is significant and can double the resources required to perform database updates, resulting in declining performance and unnecessary hardware stress.

 

A more reasonable alternative is a passive solution that uses data recovery mechanisms.  For example, all relational databases have update logs that are archived and used in cases where disk recovery is required.  These logs are the ideal source for auditing changes to the database because they do not add additional processing.  We also find that successful enterprise auditing solutions utilize these logs in order to achieve the auditing goal within the absolute minimum overhead.

 

Now, let’s take a look at the characteristics of a successful enterprise data auditing solution. 

Real-time Notification of Critical Events
 

A comprehensive solution will allow for the ad-hoc definition of alert threshold events and provide a mechanism for real-time notification via e-mail, text mail or pager (Figure 5).  Successful companies apply sophisticated filters to the audit trails at data capture time and spot suspicious trends and patterns in data access.  Many of these companies report that the system pays for itself in just a few months in cost savings from early-warning fraud detection.

 

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 Figure 5 – Critical real-time exception notification

 

Archiving Issues with Data Audits
 

Remember, your audit trails will be your single largest data management responsibility, eclipsing your online systems by orders of magnitude.  To fully appreciate the data volumes and complexity of privacy auditing, lets take a look at the issues for a typical company.  Consider a financial database with 500 end-users and one terabyte of information.  Because each end-user is constantly viewing personal financial information as a legitimate part of their job, every week, the audit trail must be able to archive viewing details of over 100 times the size of the original database, in some cases over 300,000,000,000,000 bytes of archived data.

 

Even though disk become cheaper every year, the expense of archiving trillions of bytes per week on online storage is cost-prohibitive.  They are forced to develop a mechanism to archive these vast volumes of data using semi-automated mechanisms.

 

Audit Trail archive processing uses a tertiary storage (tape) jukebox and a tape management system to clearly label the header of every audit tape.  The archiving process involves special hardware, complex interfaces and built-in error checking.  As each online audit disk requires archiving, an automated process will:

 

1 – Fetch and label a new tape

2 - Copy the disk onto tape media

3 – Re-process the audit tape:

 

a) Check the media for parity errors

b) Make a copy of the tape for off-site archiving and storage

c) Apply data mining programs to locate unobtrusive trends and provide real-time alerts

 

4 – Re-initialize the online disk

 

This archiving mechanism must be seamless, complete and have built-in redundancy and error checking.  When we add-in the additional dimension of data from multiple databases and auditing from multiple access layers, the problem can become unfathomable.

 

But it gets worse.  Archiving the data is just the front-end and you must also develop the ability to allow timely access to the archived data.  Let’s take a closer look at how this works. 

Long-term Retention of Audit Trails
 

Long-term data retention is often mandated by business practices and legal requirements and the auditing of data access has imposed a huge burden on many companies.  The archival storage of audit trails is often 95% of the company’s data, yet it is only accessed 1% of the time (Figure 6).

 

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 6 – The anomaly of archival data

 


This data anomaly also presents challenges due to the temporal nature of the audit capture and the low volume of access.  Once lost, the data can never be reclaimed, and the sheer volume of data often means that media verification (duplicitous parity checks) is prohibitive.

 

Many IT managers have come to realize that their point-in-time production databases only tell a small part of the story and the real value of their database is the temporal dimension.  Let’s take a look at how establishing a time-series interface allows complete reporting, data mining and fraud detection capabilities. 

Reporting Value with Data Audits
 

In addition to meeting compliance regulations, many companies discover that they have a valuable data resource in their audit trails.  Home-grown solutions often lack an easy-to-use interface and analyzing the valuable hidden information in the audit trails is often impossible.   Ad-hoc interfaces are usually non-existent, and it can be extremely difficult to apply data mining techniques to detect unobtrusive patterns of fraud and access violations.  What’s needed is an enterprise reporting capability that provides the means to derive business value from the audit data. 

 

Any online database is  nothing more than a fixed, point-in-time snapshot of the current information.  To get the whole picture you must add a temporal dimension to the database, and develop mechanisms to harvest your time-series information (Figure 7).

 

In the following chart capitalization needs to be fixed (lower case “t” in “To” in headline.  Lower case “t” in “Trends”

 

  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Figure 7 – Time, the third dimension of Database Management

 

 

Even though disk costs fall 10x every year, online access to petabytes of audit data is prohibitive and this presents special challenges to the IT manager.  To confound the issue, simultaneous requests present a unique challenge because of the linear limitations of tertiary storage.  To minimize human intervention, the reporting solution must have these characteristics:

 

·         An easy-to-use interface

·         A mechanism to audit the audit request

·         A complex status-tracking facility

·         A notification and delivery mechanism for the completed report

·         The ability to access audit information from the application layer, database layer and server layer

·         The ability to access audit data from multiple database products

 

The reporting mechanism must be able to serve the needs of requests from the external community and support your in-house reporting needs.  The sheer volume of auditing data makes this reporting unique.  Answering this simple query might take hours, require mounting thousands of tapes, and involve reading trillions of bytes of data from multiple databases.

External Reporting
 

Your customers and clients may request complete audit trails of access to their confidential information.  In financial and medical systems, Federal laws mandate that your company be able to service these requests, providing complete reports in a timely manner.

 

For example, in a health care database, any patient may request a report showing all users who have viewed their confidential patient information, including who they were, what they viewed, when they viewed the data and why they needed to see their information. 

 

We also have the important business need to have access to the third dimension of your production database.  The value of the temporal dimension of the database can be worth millions of dollars and internal reporting capabilities provide a competitive edge to many companies.

Internal Reporting
 

Internally, the reporting mechanism must also allow interfaces for in-house reporting, especially in the areas of financial and marketing management.  These in-house reporting facilities fall into two general categories:

 

·         Decision Support – A mechanism to model “what if” questions, simulation modeling and hypothesis testing.

 

·         Data Mining –Support for multivariate correlation analysis, fraud detection, trend identification and signature analysis.

 

As your largest database, your audit trails contain valuable hidden information.  Because the audit trails provide a time-series view of your online systems they contain information about the patterns and behavior of the end-users and a time-series view of how the data has changed over time.

 

Using standard data mining products you can interface with your audit trail database to determine “typical” processing patterns and quickly identify suspicious patterns of data usage.  Data mining products are the result of decades of refinement and are very sophisticated in their ability to spot patterns and trends.  The programs are constantly analyzing your audit data, seeking statistically significant data patterns and trends. 

 

The huge benefits of data mining programs are often quite surprising.

 

·         Savings from Early Warnings - Financial institutions have discovered the hidden value in their audit trails for proactive fraud detection.  By analyzing patterns of known fraud from the audit trails, IT management can apply detection mechanisms to the online system, sending immediate alarms of untypical data access patterns, often preventing the fraud before any financial loss occurs.  This technique has saved banks and credit companies millions of dollars, and easily justifies the expense of purchasing an enterprise auditing solution.

 

·         Optimizing Employee Productivity - Companies can also use their audit trails to track employee productivity.  The audit trails provide an excellent unobtrusive measure of end-user value to the company and this information can be used to spot sub-optimal workers by comparing their data viewing behavior with those of known, productive employees. 

 

Sadly, many companies are unable to reap the benefits of data mining because they do not have a standardized, unified audit trail.  This is