R 432.639
R 432.639 Internet gaming operators and internet gaming platform provider technical and security standards (controls).
Cite as Mich. Admin. Code R 432.639
Rule 639. (1) An internet gaming operator or its internet gaming platform provider, or
both must adopt, implement, and maintain technical security standards (controls) that
meet or exceed those adopted in R 432.633(2). The technical security standards must
apply, at a minimum, to all the following critical components of the internet gaming
platform:
(a) Components that record, store, process, share, transmit, or retrieve sensitive
information (e.g., validation numbers, personal identification numbers (PIN), and
individual and authorized participant data).
(b) Components that generate, transmit, or process random numbers used to
determine the outcome of games or virtual events.
(c) Components that store results or the current state of an authorized participant’s
internet wager.
(d) Points of entry to and exit from the components provided for in subdivisions (a) to
(c) of this subrule and other systems that are able to communicate directly with
core critical internet gaming platform components.
(e) Communication networks that transmit sensitive information involving internet
gaming under the act.
(2) The following technical security standards are the minimum standards an
internet gaming operator or internet gaming platform provider must incorporate into its
internal controls:
(a) Technical security standards addressing internet gaming platform operations and
security include, but are not limited to all of the following:
(i) Internet Gaming Platform Operations and Security. The internet gaming
operator or internet gaming platform provider must adopt, implement, and
maintain procedures for, at a minimum, the following:
(A) Monitoring the critical components and the transmission of data of the
entire internet gaming platform.
(B) Maintenance of all aspects of security of the internet gaming platform to
ensure secure and reliable communications.
(C) Defining, monitoring, documenting, reporting, investigating, responding
to, and resolving security incidents.
(D) Monitoring and adjusting resource consumption and maintaining a log of
the internet gaming platform performance.
(E) Investigating, documenting, and resolving malfunctions.
(ii) Physical Location of Servers and Security. The internet gaming platform
must be housed in secure locations. Internet gaming operators and their
internet gaming platform providers must provide the board with information
on the location of all internet gaming platform servers. The secure locations
must have sufficient protection from unauthorized access and physical and
environmental hazards and be equipped with surveillance and security
systems that meet or exceed industry standards.
(iii)Internet Gaming Platform Logical Access Controls. The internet gaming
platform must be logically secured against unauthorized access.
(iv) Internet Gaming Platform User Authorization. The internet gaming platform
must be subject to user authorization requirements as required by the board.
(v) Server Programming. The internet gaming platform must be sufficiently
secure to prevent any user-initiated programming capabilities on the server
that may result in unauthorized modifications to the database.
(vi) Verification Procedures. Procedures must be in place for verifying on demand
that the critical control program components of the internet gaming platform
in the production environment are identical to those approved by the board.
(vii)
Electronic Document Retention System. The internet gaming operator or
internet gaming platform provider must establish procedures that ensure that
all reports required under the act and these rules are stored in an electronic
document retention system.
(viii) Asset Management. All assets that house, process, or communicate
sensitive information, including those comprising the operating environment
of the internet gaming platform or its components, or both, must be accounted
for and have a nominated owner or designated management official that is
responsible for each asset.
(b) The technical security standards addressing data security and backup recovery
include, but are not limited to, all of the following:
(i) Data Security. The internet gaming platform must provide a logical means for
securing individual and authorized participant data and wagering data,
including accounting, reporting, significant event, or other sensitive
information, against alteration, tampering, or unauthorized access.
(ii) Data Alteration. The alteration of any accounting, reporting, or significant
event data relating to internet wagering under the act is not permitted without
supervised access controls. If any data is changed, all information required by
the board must be documented or logged.
(iii)Backup Frequency. Backup scheme implementation relating to information
involving internet wagering under the act must occur at least once every day
or as otherwise specified by the board.
(iv) Storage Medium Backup. Audit logs, internet gaming platform databases, and
any other pertinent individual and authorized participant data and wagering
data must be stored using reasonable protection methods. The internet gaming
platform must be designed to protect the integrity of this data if there is a
failure. Redundant copies of this data must be kept on the internet gaming
platform with open support for backups and restoration, so that no single
failure of any portion of the internet gaming platform would cause the loss or
corruption of the data.
(v) Internet Gaming Platform Failure. The internet gaming platform must have
sufficient redundancy and modularity so that if any single component or part
of a component fails, the functions of the internet gaming platform and the
process of auditing those functions can continue with no critical data loss. If 2
or more components are linked, the process of all internet gaming operations
between the components must not be adversely affected by restart or recovery
of either component and upon restart or recovery, the components must
immediately synchronize the status of all transactions, data, and
configurations with one another.
(vi) Accounting and Master Resets. The internet gaming operator or internet
gaming platform provider must be able to identify and properly handle the
situation where a master reset has occurred on any component that affects
internet gaming under the act.
(vii)
Recovery Requirements. If there is a catastrophic failure when the
internet gaming platform cannot be restarted in any other way, it must be
possible to restore the internet gaming platform from the last backup point and
fully recover. The contents of that backup must contain critical information as
required by the board.
(viii) Uninterrupted Power Supply (UPS) Support. All internet gaming platform
components must be provided with adequate primary power. If the server is a
stand-alone application, it must have a UPS connected and must have
sufficient capacity to permit a methodical shut-down that retains all individual
and authorized participant data and wagering data during a power loss. It is
acceptable that the internet gaming platform may be a component of a
network that is supported by a network-wide UPS if the server is included as a
device protected by the UPS. There must be a surge protection system in use
if not incorporated into the UPS itself.
(ix) Business Continuity and Disaster Recovery Plan. A business continuity and
disaster recovery plan must be in place to recover internet gaming operations
conducted under the act if the internet gaming platform’s production
environment is rendered inoperable.
(c) Technical security standards addressing communications include, but are not
limited to, all of the following:
(i) Connectivity.
Only
authorized
devices
are
permitted
to
establish
communications between any internet gaming platform components.
(ii) Communication Protocol. Each component of the internet gaming platform
must function as indicated by a documented secure communication protocol.
(iii)Communication Over Internet/Public Network. Communications between
internet gaming platform components must be secure. Individual and
authorized participant data, sensitive information, internet wagers, results,
financial information, and individual and authorized participant transaction
information related to internet gaming conducted under the act must always be
encrypted and protected from incomplete transmissions, misrouting,
unauthorized message modification, disclosure, duplication, or replay.
(iv) Wireless Local Area Network (WLAN) Communications. The use of WLAN
communications must adhere to applicable requirements specified for wireless
devices and is subject to approval by the board.
(v) Network Security Management. Networks must be logically separated to
ensure that there is no network traffic on a network link that cannot be
serviced by hosts on that link.
(vi) Mobile Computing and Communications. Formal policies shall be in place,
and appropriate security measures shall be adopted to protect against the risk
of using mobile computing and communication facilities. Telecommuting
shall not be permitted except under circumstances where the security of the
endpoint can be guaranteed.
(d) Technical security standards addressing third party service providers include, but
are not limited to, all of the following:
(i) Third-Party Service Communications. Where communications related to
internet gaming conducted under the act are implemented with third-party
service providers, the internet gaming platform must securely communicate
with all third-party service providers utilizing encryption and strong
authentication, ensure that all login events are recorded to an audit file, and
ensure that all communications do not interfere or degrade normal internet
gaming platform functions.
(ii) Third-Party Services. The roles and responsibilities of each third-party
service provider engaged by the internet gaming operator or internet gaming
platform provider must be defined and documented in a manner approved by
the board. The internet gaming operator or internet gaming platform provider
must have policies and procedures in place for managing third-party service
providers and monitoring their adherence to relevant security requirements.
(e) Technical security standards addressing technical controls include, but are not
limited to, all of the following:
(i) Domain Name Service (DNS) Requirements. An internet gaming operator or
internet gaming platform provider must establish requirements that apply to
servers used to resolve DNS queries used in association with the internet
gaming platform.
(ii) Cryptographic Controls. An internet gaming operator or internet gaming
platform provider must establish and implement a policy for the use of
cryptographic controls that ensures the protection of information.
(iii)Encryption Key Management. The management of encryption keys must
follow defined processes established by the internet gaming operator or
internet gaming platform provider and approved by the board.
(f) The technical security standards addressing remote access and firewalls include,
but are not limited to, all of the following:
(i) Remote Access Security. Remote access, if approved by the board, must be
performed via a secured method, must have the option to be disabled, may
accept only the remote connections permissible by the firewall application and
internet gaming platform settings, and must be limited to only the application
functions necessary for users to perform their job duties.
(ii) Remote Access and Guest Accounts Procedures. Remote access and guest
accounts procedures must be established that ensure that remote access is
strictly controlled.
(iii)Remote Access Activity Log. The remote access application must maintain
an activity log that updates automatically and records and maintains all remote
access information.
(iv) Firewalls. All communications, including remote access, must pass through at
least 1 approved application-level firewall. This includes connections to and
from any non-internet gaming platform hosts used by the internet gaming
operator or internet gaming platform provider.
(v) Firewall Audit Logs. The firewall application must maintain an audit log and
must disable all communications and generate an error if the audit log
becomes full. The audit log must contain, at a minimum, all the following
information:
(A) All changes to configuration of the firewall.
(B) All successful and unsuccessful connection attempts through the firewall.
(C) The source and destination IP Addresses, Port Numbers, Protocols, and,
where possible, MAC Addresses.
(vi) Firewall Rules Review. The firewall rules must be periodically reviewed by
the internet gaming operator or internet gaming platform provider to verify the
operating condition of the firewall and the effectiveness of its security
configuration and rule sets and must be performed on all the perimeter
firewalls and the internal firewalls.
(g) Technical security standards addressing change management include, but are not
limited to, all of the following:
(i) Program Change Control Procedures. Program change control procedures
must ensure that only authorized versions of programs are implemented on the
production environment.
(ii) Software Development Life Cycle. The acquisition and development of new
software must follow defined processes established by the internet gaming
operator or internet gaming platform provider and subject to review by the
board.
(iii) Patches. All patches should be tested, as applicable, in a development and
test environment configured to match the target production environment
before being deployed into production. Permitted exceptions and related
procedures and controls must be fully addressed.
(h) Technical security standards addressing periodic security testing include, but are
not limited to, all of the following:
(i) Technical Security Testing. Periodic technical security tests on the production
environment must be performed quarterly or as required by the board to
guarantee that no vulnerabilities putting at risk the security and operation of
the internet gaming platform exist.
(ii) Vulnerability Assessment. The internet gaming operator or the internet
gaming platform provider must conduct vulnerability assessments. The
purpose of the vulnerability assessment is to identify vulnerabilities, which
could be later exploited during penetration testing by making basic queries
relating to services running on the internet gaming platform concerned.
(iii)Penetration Testing. The internet gaming operator or the internet gaming
platform provider must conduct penetration testing. The purpose of the
penetration testing is to exploit any weaknesses uncovered during the
vulnerability assessment on any publicly exposed applications or internet
gaming platform hosting applications processing, transmitting, or storing
sensitive information.
(iv) Information Security Management System (ISMS) Audit. An audit of the
ISMS will be periodically conducted, including all the locations where
sensitive information is accessed, processed, transmitted, or stored. The ISMS
will be reviewed against common information security principles in relation to
confidentiality, integrity, and availability.
(v) Cloud Service Audit. An internet gaming operator and its internet gaming
platform provider that utilizes a cloud service provider (CSP), if approved by
the board, to store, transmit, or process sensitive information must undergo a
specific audit as required by the board. The CSP must be reviewed against
common information security principles in relation to the provision and use of
cloud services, such as ISO/IEC 27017 and ISO/IEC 27018, or equivalent.
(3) The internet gaming operator or its internet gaming platform provider, or both must
include the technical security standards (controls) in the internal controls and internet
gaming platform submitted to the board for approval.
(4) The technical security standards (controls) must:
(a) Have a provision requiring review when changes occur to the internet gaming
platform.
(b) Be approved by the internet gaming operator’s or internet gaming platform
provider’s senior management.
(c) Be communicated to all affected employees and relevant external parties.
(d) Undergo review at planned intervals.
(e) Delineate the responsibilities of the internet gaming operator’s staff, the internet
gaming platform provider’s staff, and the staff of any third parties for the
operation, service, and maintenance of the internet gaming platform or its
components, or both.