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9. Configuration Management Policy

Smylen standardizes and automates configuration management through the use of Terraform scripts as well as documentation of all changes to production systems and networks. Terraform automatically configures all Smylen systems according to established and tested policies, and are used as part of our Disaster Recovery plan and process.

9.1 Applicable Standards

9.1.1 Applicable Standards from the HITRUST Common Security Framework

  • 06 - Configuration Management

9.1.2 Applicable Standards from the HIPAA Security Rule

  • 164.310(a)(2)(iii) Access Control & Validation Procedures

9.2 Configuration Management Policies

  1. Terraform and containers are used to standardize and automate configuration management.
  2. No systems are deployed into Smylen environments without approval of the Smylen CTO.
  3. All changes to production systems, network devices, and firewalls are approved by the Smylen CTO before they are implemented to assure they comply with business and security requirements.
  4. All changes to production systems are tested before they are implemented in production.
  5. Implementation of approved changes are only performed by authorized personnel.
  6. Tooling to generate an up-to-date inventory of systems, including corresponding architecture diagrams for related products and services, is hosted on GitHub.
  7. All systems are categorized as production and utility to differentiate based on criticality.
  8. The Security Officer maintains scripts to generate inventory lists on demand using APIs provided by each cloud provider.
  9. These scripts are used to generate the diagrams and asset lists required by the Risk Assessment phase of Smylen's Risk Management procedures (§4.3.1).
  10. After every use of these scripts, the Security Officer will verify their accuracy by reconciling their output with recent changes to production systems. The Security Officer will address any discrepancies immediately with changes to the scripts.
  11. All frontend functionality (developer dashboards and portals) is separated from backend (database and app servers) systems by being deployed on separate servers or containers.
  12. All software and systems are tested using unit tests and end to end tests.
  13. All committed code is reviewed using pull requests to assure software code quality and proactively detect potential security issues in development.
  14. Smylen utilizes development and staging environments that mirror production to assure proper function.
  15. Smylen also deploys environments locally to assure functionality before moving to staging or production.
  16. All formal change requests require unique ID and authentication.
  17. Smylen does not provision servers to host applications rather all applications run in containers on ECS/EKS so systems are ephemeral and immutable.
  18. Clocks are continuously synchronized to an authoritative source across all systems using NTP or a platform-specific equivalent. Modifying time data on systems is restricted.
  19. Secrets are stored in HSM or equivalent API, separate from non-sensitive configuration data.

9.3 Provisioning Production Systems

  1. Before provisioning any systems, ops team members must file a request in the Smylen Task Management System.
  2. Task Management System access requires authenticated users.
  3. The CTO grants access to the Task Management System following the procedures covered in the Access Establishment and Modification section.
  4. The CTO, or an authorized delegate of the CTO, must approve the provisioning request before any new system can be provisioned.
  5. Once provisioning has been approved, the ops team member must configure the new system according to the standard baseline chosen for the system's role.
  6. If the system will be used to house production data (ePHI), the ops team member must add an encrypted data volume during provisioning.
  7. Once the system has been provisioned, the ops team member must contact the security team to inspect the new system. A member of the security team will verify that the secure baseline has been applied to the new system, including (but not limited to) verifying the following items:
  8. Removal of default users used during provisioning.
  9. Network configuration for system.
  10. Data volume encryption settings.
  11. Security settings that cover intrusion and malware detection.
  12. All items listed below in the operating system-specific subsections below.
  13. Once the security team member has verified the new system is correctly configured, the team member must add that system to the SecurityHub scanner configuration.
  14. The new system may be rotated into production once the CTO verifies all the provisioning steps listed above have been correctly followed and has marked the Issue with the Approved state.

9.3.1 Provisioning Linux Containers

  1. Linux containers have their baseline security configuration applied via docker configuration. These cover:
  2. Ensuring that the stack is up-to-date with security patches and is configured to apply patches in accordance with our policies.
  3. Stopping and disabling any unnecessary services and features.
  4. Configuring volumes for providers that do not have native support for encrypted data volumes, including ensuring that encryption keys are protected from unauthorized access.
  5. Configuring any authentication to require MFA.
  6. Configuring audit logging as described in the Auditing Policy section.
  7. Any additional configuration applied to the stack must be clearly documented by the ops team member in the DT request by specifying the purpose of the new container.

9.3.2 Provisioning Management Systems

  1. Provisioning management systems such as Gateways, Authentication, or VPN follows the same procedure as provisioning a production system.
  2. Critical infrastructure services such as logging, monitoring, authentication servers, or dns must be configured with security, backup and high-availability.
  3. These are approved by the CTO, or an authorized delegate of the CTO, to be in accordance with all Smylen policies, including setting appropriate:
    • Audit logging requirements.
    • Password size, strength, and expiration requirements.
    • Transmission encryption requirements.
    • Network connectivity timeouts.
  4. Critical infrastructure roles applied to new systems must be clearly documented by the ops team member in the DT request.

9.4 Changing Existing Systems

  1. Subsequent changes to already-provisioned systems are unconditionally handled by one of the following methods:
  2. Changes to Terraform or CloudFormation scripts.
  3. Changes to Docker configuration.
  4. For configuration changes that cannot be handled by Terraform, Cloudformation and Docker configuration, a runbook describing exactly what changes will be made and by whom.
  5. Configuration changes to Docker or Terraform/CloudFormation must be initiated by creating a Merge Request in GitHub.
  6. The ops team member will create a feature branch and make their changes on that branch.
  7. The ops team member must test their configuration change locally when possible, or on a development and/or staging sandbox otherwise.
  8. At least one other ops team member must review the change before merging the change into the main branch.
  9. In all cases, before rolling out the change to production, the ops team member must file an Issue in the DT project describing the change. This Issue must link to the reviewed Merge Request and/or include a link to the runbook.
  10. Once the request has been approved by the CTO, the ops team member may roll out the change into production environments.

9.5 Patch Management Procedures

  1. Smylen uses automated tooling to ensure systems are up-to-date with the latest security patches.

9.6 Software Development Procedures

  1. All development uses feature branches based on the main branch used for the current release. Any changes required for a new feature or defect fix are committed to that feature branch.
  2. These changes must be covered under 1) a unit test where possible, or 2) integration tests.
  3. Integration tests are required if unit tests cannot reliably exercise all facets of the change.
  4. Developers are strongly encouraged to follow the commit message conventions suggested by GitHub.
  5. Commit messages should be wrapped to 72 characters.
  6. Commit messages should be written in the present tense. This convention matches up with commit messages generated by commands like git merge and git revert.
  7. Once the feature and corresponding tests are complete, a pull request will be created using the GitHub web interface. The pull request should indicate which feature or defect is being addressed and should provide a high-level description of the changes made.
  8. Code reviews are performed as part of the pull request procedure. Once a change is ready for review, the author(s) will notify other engineers using an appropriate mechanism, typically via an @channel message in Slack.
  9. Other engineers will review the changes, using the guidelines above.
  10. Engineers should note all potential issues with the code; it is the responsibility of the author(s) to address those issues or explain why they are not applicable.
  11. If the feature or defect interacts with ePHI, or controls access to data potentially containing ePHI, the code changes must be reviewed by two members of Smylen's Blue Team (software security team) before the feature is marked as complete.
  12. The Blue Team members will provide a security analysis of features to ensure they satisfy Smylen's compliance and security commitments.
  13. This review must include a security analysis for potential vulnerabilities such as those listed in the OWASP Top 10 or the CWE top 25.
  14. This review must also verify that any actions performed by authenticated users will generate appropriate audit log entries.
  15. Blue Team members are required to undergo annual training on identifying the most common software vulnerabilities and will receive ongoing training on Smylen's compliance and security requirements.
  16. Once the review process finishes, each reviewer should leave a comment on the pull request saying "looks good to me" (often abbreviated as "LGTM"), at which point the original author(s) may merge their change into the release branch.

9.7 Software Release Procedures

  1. Software releases are treated as changes to existing systems and thus follow the procedure described in §9.4.