Overview of the Audit Logging & Monitoring Policy
The Audit Logging & Monitoring Policy exists to provide a structured approach to capturing, storing, and analyzing the digital footprints left by users interacting with an organization's IT environment. It aims to safeguard the integrity, confidentiality, and availability of data by keeping a vigilant eye on system activities and user behaviors. The policy outlines the procedures for logging events, monitoring systems, and responding to anomalies, thereby helping organizations to comply with legal requirements, maintain operational security, and support forensic investigations.
Key Points of the Policy
The policy is comprehensive and covers a wide range of areas. Below is a summary of the key points, each illustrating a critical aspect of audit logging and monitoring:
Notice of Monitoring Inform all relevant parties that their actions on company systems may be monitored and require their consent.
Log Records Ensure each audit record contains a unique user ID, data subject ID, function performed, and timestamp.
Key Events Maintain logging for critical events such as data access, system changes, and security alarms.
Data and System Access Generate audit records for all access to critical data or systems, detailing the access method and source/destination.
System Activities Log all activities involving sensitive data, ensuring the security of the audit records.
Sensitive Data Disclosures Record all disclosures of sensitive data, including the type, date, recipient, and sender.
Privileged User Activity Monitor and log the activities of privileged users, capturing detailed information about each event.
System Management Events Create audit records for system management events like startups, shutdowns, and policy changes.
Sent and Received Messages Log all messages containing sensitive data, excluding the content of the messages.
Inventory of Auditable Events Maintain an updated inventory of auditable events and review it annually or after significant changes.
Auditable Events Rationale Document the rationale behind the selection of auditable events and update it regularly.
Protection of Logs Safeguard logs and log facilities against unauthorized access and tampering.
Monitoring Procedures and Protocols
The policy also details the procedures and protocols for monitoring, which are crucial for ensuring that the logging mechanisms are effective and that the data captured is used appropriately:
Risk Category Assign a risk category to all auditable events and define log review frequency.
Monitoring Procedures Document the process for audit log reviews, including roles, responsibilities, and qualifications.
Selectable Criteria Store audit records to allow for event review based on selectable criteria.
Irregularities or Anomalies Monitor for system irregularities that may indicate security issues.
Activities Subject to Monitoring Define the activities that will be monitored, such as privileged operations and access attempts.
Privileged User Monitoring Regularly review logged events related to privileged user activities.
System and Network Administration Activities Use an IDS to monitor administration activities for critical systems.
Inbound/Outbound Communication and FIM Include communication and file integrity monitoring in the activities.
Log Aggregation Aggregate logs centrally for review.
Automated Systems for Key Events Use automated systems to monitor and analyze logs for key events.
Automated Systems for Monitoring Activities Implement systems to review security system activities daily.
Automated Systems Real-Time Analysis Support near real-time analysis and alerting of critical events.
Systematic Alerting Alert technical personnel of suspicious activities for investigation.
SIEM Use SIEM tools to aggregate, correlate, and analyze logs from multiple sources.
Physical Security Incidents Respond to physical security incidents and coordinate with the incident response team.
Legal Requirements Ensure all legal requirements for monitoring are met.
Audit Reduction and Report Generation Support audit reduction and report generation in auditing systems.
Monitoring Assessment Test log monitoring processes annually and remediate any deficiencies.
Segregation of Duties and Retention
The policy also emphasizes the importance of segregating duties to prevent unauthorized or unintentional modifications and outlines the retention periods for audit logs:
SOD Protocols Implement protocols to limit risks by segregating duties.
All Users Subject to Monitoring Ensure all users are monitored and cannot access critical systems undetected.
Identification of Incompatible Duties Identify and segregate incompatible duties.
Job Descriptions Define job descriptions that support duty segregation.
Security Audit Conduct security audits independently.
Initiation and Authorization Separate event initiation from authorization.
Access Control Administration Limit access for individuals responsible for access controls.
SDLC functions Separate SDLC functions among different individuals or groups.
Mission Critical Functions Divide mission-critical functions among separate individuals.
Audit Log Retention Period Retain audit logs for a specified period for accessibility and archival.
Sensitive Data Extracts Regularly evaluate sensitive data extracts for continued necessity.
In conclusion, the Audit Logging & Monitoring Policy is a vital tool for organizations to protect their data and systems. It provides a framework for tracking and analyzing user activities, ensuring that any inappropriate behavior is detected and addressed promptly. For organizations looking to implement or update their own policy, we offer a template that can be purchased to streamline the process.
