Database Auditing and Compliance
in a Mainframe Environment
Craig S. Mullins,
Corporate Technologist, NEON Enterprise Software, Inc.
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Table of Contents
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
A Look at the Regulations and Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Privileged Users. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Internal and External Threats . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
So, What is Database Auditing? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Database Auditing Techniques. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Satisfying All Stakeholders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
The Questions That Must be Answerable . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
About NEON Enterprise Software . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
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Introduction
We are all surely aware of the increasing burden of complying with government regulations. And nowhere is the
pressure to comply greater than on data stored in corporate databases. Organization must be hyper-vigilant as
they implement controls to protect and monitor their data, as well as the accesses to that data.
One of the more useful techniques to protect your company’s database data is through data access auditing,
which is a facility for tracking the use of, and modifications made to, database resources and authority. A data
access auditing capability enables companies to produce an audit trail of information with regard to their
database data. This audit trail can contain information such as what database objects were impacted, who
performed the operations, and when the activity occurred. A comprehensive audit trail of database operations,
coupled with an analysis engine to review and analyze the audit trail allows data and security professionals as
well as IT auditors to perform in-depth analysis of access and modification patterns against data in all of your
database systems. Only when armed with such details is it possible to comply with regulations, pass security
audits, and drill-down into the details to review potential vulnerabilities for effective issue resolution.
A Look at the Regulations and Requirements
Why would you need a fine-grained audit trail? Well, let’s consider a few of the regulations that can require
organizations to create database audit trails.
Many of the PCI Data Security Standard requirements emphasize the importance of real time monitoring and
tracking of access to cardholder data, as well as continuous assessment of database security health status.
HIPAA, the Health Insurance Portability and Accountability Act, directs health care providers to protect
individual’s health care information going so far as to state that the provider must be able to deliver a list of
everyone who even so much as looked at their patient’s information. Could you produce a list of everyone who
looked at a specific row or set of rows in any database you manage?
And what about the Sarbanes-Oxley Act (SOX)? The goal of SOX is to reduce fraud and conflicts of interest, to
improve disclosure and financial reporting, and strengthen confidence in public accounting. Section 404
specifies that the CFO must guarantee the accuracy of the processes used to add up the numbers. Those
processes are typically guided by computer programs that access and manipulate data in a database system. As
such, it is important to be able to track who changed database schemata and database data for SOX compliance.
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Figure 1. Industry Regulation Database Audit Requirements
Audit Requirements
SOX
PCI
HIPAA
CMS
GLBA
ISO
NERC
NIST
(CobiT)
DSS
ARS
17799
800-53
(Basell II)
(FISMA)
Access to Sensitive Data
(Successful/Failed
SELECTs)
Schema Changes (DDL)
(Create/Drop/Alter Tables,
etc.)
Data Changes (DML)
(Insert, Update, Delete)
Security Exceptions
(Failed logins, SQL errors,
etc.)
Accounts, Roles &
Permissions (DCL)
(GRANT, REVOKE)
DDL = Data Definition Language (schema changes)
Source: Guardium, Inc. —
DML = Data Manipulation Language (data value changes)
DCL = Data Control Language (authorization changes)
The chart in Figure 1 summarizes the type of database audit requirements imposed on IT by several of the
predominant industry regulations.
Privileged Users
A comprehensive database auditing solution should provide a mechanism to audit privileged users, such as
DBAs and SYSADMs. Many privileged users have blanket access to all corporate data. But you can’t just revoke
the authority of super users because the nature of their jobs requires such overarching privileges.
Because privileged users can access and modify database resources at their discretion, an organizational
approach to auditing their every action is prudent. Privileged users have broad authority, but they should not be
accessing and modifying production data without due cause.
A database auditing solution enables organizations to implement a “Trust, But Verify” policy for their privileged
users. This allows the administrators to retain the authority they need to be able to do their jobs, while at the
same time giving the organization the peace of mind that everything the privileged users are doing is tracked
for security and compliance purposes.
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Without a database auditing solution in place, privileged users are a potential compliance problem lurking
within every database implementation.
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Internal and External Threats
Database auditing is important because there are many threats to the security of your data. External agents
trying to compromise security and access your company’s data are rightly viewed as a security threat. But
industry studies show that the majority of security threats are internal – within your organization. Indeed,
internal threats can comprise 60% to 80% of all security threats. The most typical security threat comes from a
disgruntled current or ex-employee that has valid access to the DBMS. Auditing is crucial because you may need
to find unauthorized access emanating from an authorized user.
A robust auditing facility permits auditing at different levels within the database system, for example, at the
database, database object, and user levels. One of the biggest problems with existing internal DBMS audit
facilities is performance degradation. The audit trails that are produced must be detailed enough to capture
sufficient information for each auditable action. But capturing so much information, particularly in a busy
system, can cause performance to suffer. Furthermore, the audit trail must be stored somewhere, which can be
problematic when a massive number of changes occur. Therefore, a useful auditing facility must allow for the
selective creation of audit records to minimize performance and storage problems.
So, What is Database Auditing?
Database auditing is the process of monitoring access to, and modification of, selected database objects and
resources within operational databases and retaining a detailed record of the access where said record can be
used to proactively trigger actions and can be retrieved and analyzed as needed.
Database Auditing Techniques
There are several popular techniques that can be deployed to audit your database structures. The first technique
is trace-based auditing, which is usually built directly into the native DBMS, such as with DB2 for z/OS.
Commands are set to turn on auditing and the DBMS begins to cut trace records when activity occurs against
audited objects. The problems with this technique include a high potential for performance degradation when
audit tracing is enabled, a high probability that the database schema will need to be modified, and insufficient
granularity of audit control, especially for reads.
The biggest problem with this technique is the high potential for performance degradation when audit tracing is
enabled. Indeed, the IBM DB2 manuals indicate up to a 10 percent performance hit when DB2 audit traces are
started.
Another technique that can be used is to scan and parse the database transaction logs. Every DBMS uses
transaction logs to capture every database modification for recovery purposes. Software exists that interprets
these logs and identifies what data was changed and by which users.
The drawbacks to this technique include:
• No capture of read-only accesses (because reads aren’t captured on transaction logs)
• The fact that there are ways to disable logging that will cause modifications to be lost
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• Performance issues scanning volumes and volumes of log files looking for only specific information to audit
• The difficulty of retaining logs over long periods for auditing when they were designed for short-term
retention for database recovery.
The third database auditing technique used by many distributed database solutions is to sniff packets for
database requests as they cross the network. Capturing the SQL statements as they cross the network can
generate an audit trail of the database requests that go over the network. The problem is that not every request
goes across the network. This is especially the case for mainframe transactions. For example, a DB2 CICS
application, where all the work is mainframe-resident, doesn’t require TCP/IP. So this work can’t be captured by
packet sniffing. The same applies to IMS/TM and TSO requests, or any other work done directly on the
mainframe.
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The final, and recommended approach, it to employ proactive monitoring of operations at the database server
level. This technique deploys a software tap to capture all database requests as they occur. It’s important that all
database access can be audited, not just network calls. This is the only technique that works well for mainframe
auditing because most mainframe database requests don’t go out over the network. Proactive audit monitoring
doesn’t require transaction logs, doesn’t require database schema modification, and will be highly granular in
terms of specifying what to audit.
Database auditing can be a crucial component of database security and compliance with government
regulations. Be sure to study the auditing capabilities of your DBMS and to augment these capabilities with
additional tools to bolster the auditability of your databases.
Satisfying All Stakeholders
As you investigate your database auditing requirements and the solutions available, keep in mind the needs of
each of the key stakeholders involved in the auditing of your database systems: security and operations,
compliance officers and auditors, and DBAs and applications developers.
The needs of these stakeholders are outlined in the diagram in Figure 2.
Security and operations will require a secure audit trail. Auditing is no help at all if the audit trail can be
surreptitiously accessed and modified. Security personnel will also be interested in the ability to review, analyze
and report on the audit trail to ensure the enforcement of organization security policies and to determine if
policy adjustments are needed.
Figure 2. Key Stakeholder Requirements.
Compliance officers and auditor will demand separation of duties. For example, it is imperative that DBAs
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are not required to implement and maintain any database auditing solution. If you’re auditing privileged users,
you don’t want to rely on those same users to start and stop auditing traces, do you?
For regulatory compliance efforts a database auditing solution that ships with best practices reports for the
regulations you are enforcing can significantly reduce the workload of a project and therefore minimize the
timeframe needed for your organization to achieve compliance.
And do not forget the requirements of your application programmers and database administrators. A
database auditing solution should not require extra work to implement, such as requiring application program
changes or database schema modifications. Furthermore, the solution should not incur a heavy performance
penalty. The biggest concern of the DBA staff will be ensuring that the overhead required to audit data access is
minimal and does not “dim the lights”
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The Questions That Must be Answerable
As you investigate the database access auditing requirements for your organization, you should compile a list of
the types of questions that you want your solution to be able to answer. A good database access auditing solution
should be able to provide answers to at least the following questions:
1. Who accessed the data?
2. At what date and time was the access?
3. What program or client software was used to access the data?
4. From what location was the request issued?
5. What SQL was issued to access the data?
6. Was the request successful; and if so, how many rows of data were retrieved?
7. If the request was a modification, what data was changed? (A before and after image of the change should be
accessible).
Of course, there are numerous details behind each of these questions. A robust database access auditing solution
should provide an independent mechanism for the long-term storage and access of audit details. The solution
should offer the canned queries for the most common types of queries, but the audit information should be
accessible using industry-standard query tools to make it easier for auditors to customize queries as necessary.
Database auditing can be a crucial component of database security and compliance with government
regulations. Be sure to study the auditing and compliance requirements of your organization and to augment
your DBMS with third-party tools to bolster the auditability of your databases.
About NEON Enterprise Software
NEON Enterprise Software is the technology leader in enterprise data management software and services. As the
rules of business change, our solutions let you efficiently control, protect, retain and manage data to comply
with today's business and legal requirements. Founded in 1995, NEON Enterprise Software serves customers
worldwide with its dedicated team of industry experts. For more information about NEON Enterprise Software,
visit www.neonesoft.com or call 281.491.6366 or 888.338.6366.
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