R 432.739
R 432.739 Sports betting operators and internet sports betting platform provider technical and security standards (controls).
Cite as Mich. Admin. Code R 432.739
Rule 739. (1) A sports betting operator or its internet sports betting platform
provider, or both must adopt, implement, and maintain technical security standards
(controls) that meet or exceed those adopted in R 432.733(2). The technical security
standards must apply, at a minimum, to all the following critical components of the
internet sports betting platform:
(a) Components that record, store, process, share, transmit or retrieve sensitive
information (e.g., validation numbers, personal identification number (PIN),
individual and authorized participant data).
(b) Components that store results or the current state of an authorized participant’s
internet sports betting wager.
(c) 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 sports betting platform components.
(d) Communication networks that transmit sensitive information involving sports
betting under the act.
(2) The following technical security standards are the minimum standards a sports betting
operator or internet sports betting platform provider must incorporate into its internal
controls:
(a) Technical security standards addressing internet sports betting platform operations
and security include, but are not limited to, all of the following:
(i) Internet Sports Betting Platform Operations and Security. The sports betting
operator or internet sports betting 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 sports betting platform.
(B) Maintenance of all aspects of security of the internet sports betting
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 sports betting platform performance.
(E) Investigating, documenting, and resolving malfunctions.
(ii) Physical Location of Servers and Security. The internet sports betting
platform must be housed in secure locations. Sports betting operators and their
internet sports betting platform providers must provide the board with
information on the location of all internet sports betting 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 Sports Betting Platform Logical Access Controls. The internet sports
betting platform must be logically secured against unauthorized access.
(iv) Internet Sports Betting Platform User Authorization. The internet sports
betting platform must be subject to user authorization requirements as
required by the board.
(v) Server Programming. The internet sports betting 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 sports betting
platform in the production environment are identical to those approved by the
board.
(vii) Electronic Document Retention System. The sports betting operator or
internet sports betting 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 sports betting 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) Technical security standards addressing data security and backup and recovery
include, but are not limited to, all of the following:
(i) Data Security. The internet sports betting 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 sports betting 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 sports betting under the act must occur at least once every day or as
otherwise specified by the board.
(iv) Storage Medium Backup. Audit logs, internet sports betting platform
databases, and any other pertinent individual and authorized participant data
and wagering data must be stored using reasonable protection methods. The
internet sports betting 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 sports betting platform with open support for backups and
restoration, so that no single failure of any portion of the internet sports
betting platform would cause the loss or corruption of the data.
(v) Internet Sports Betting Platform Failure. The internet sports betting platform
must have sufficient redundancy and modularity so that if any single
component or part of a component fails, the functions of the internet sports
betting 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 sports betting 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 sports betting operator or internet sports
betting platform provider must be able to identify and properly handle the
situation where a master reset has occurred on any component that affects
internet sports betting under the act.
(vii) Recovery Requirements. If there is a catastrophic failure when the internet
sports betting platform cannot be restarted in any other way, it must be
possible to restore the internet sports betting 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 sports betting
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 sports betting 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 sports betting
operations conducted under the act if the internet sports betting 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 sports betting wagering devices are permitted
to establish communications between any internet sports betting platform
components.
(ii) Communication Protocol. Each component of the internet sports betting
platform must function as indicated by a documented secure communication
protocol.
(iii)Communication Over Internet/Public Network. Communications between
internet sports betting platform components must be secure. Individual and
authorized participant data, sensitive information, internet sports betting
wagers, results, financial information, and individual and authorized
participant transaction information related to sports betting 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
sports betting conducted under the act are implemented with third-party
service providers, the internet sports betting 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 sports betting platform functions.
(ii) Third-Party Services. The roles and responsibilities of each third-party
service provider engaged by the sports betting operator or internet sports
betting platform provider must be defined and documented in a manner
approved by the board. The sports betting operator or internet sports betting
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. A sports betting operator or
internet sports betting platform provider must establish requirements that
apply to servers used to resolve DNS queries used in association with the
internet sports betting platform.
(ii) Cryptographic Controls. A sports betting operator or internet sports betting
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 sports betting operator or internet
sports betting platform provider and approved by the board.
(f) 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 sports betting 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 sports betting platform hosts used by the sports
betting operator or internet sports betting 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 sports betting operator or internet sports betting 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 sports betting
operator or internet sports betting 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 sports betting platform exist.
(ii) Vulnerability Assessment. The sports betting operator or the internet sports
betting 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 sports betting platform concerned.
(iii)Penetration Testing. The sports betting operator or the internet sports betting
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
sports betting 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. A sports betting operator and its internet sports betting
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 sports betting operator or its internet sports betting platform provider, or both
must include the technical security standards (controls) in the internal controls and
internet sports betting 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 sports
betting platform.
(b) Be approved by the sports betting operator’s or internet sports betting 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 sports betting operator’s staff, the internet
sports betting platform provider’s staff, and the staff of any third parties for the
operation, service, and maintenance of the internet sports betting platform or its
components, or both.