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- MINUTES OF THE
- MARCH 22-23, 1995 MEETING OF THE
- COMPUTER SYSTEM SECURITY AND PRIVACY ADVISORY BOARD
-
- Wednesday, March 22, 1995
-
- Introduction
-
- A quorum being present, the Chairman, Dr. Willis Ware, called the meeting to order at 9:00 a.m.
- at the Holiday Inn, Gaithersburg, Maryland. Besides Dr. Ware, the following Board members
- were present: Charlie Baggett Jr., Genevieve Burns, Cris Castro, Don Gangemi, Sandra Lambert,
- Henry Philcox, Randy Sanovic, Stephen Trodden, Steve Walker, and Bill Whitehurst.
-
- Mr. McNulty informed the Board that he is retiring from government service, effective April 28,
- 1995. He appointed Mr. Ed Roback Designated Federal Official for the Thursday meeting.
-
- The Board devoted the entire first day of the meeting to a thorough discussion and review of the
- assurance component of the process for evaluating security products against a criteria. It did so
- because the assurance issue has been an extremely troubling dimension of the evaluation process
- for many years. The entire meeting was held in open, public session.
-
- Assurance Framework
-
- Dr. Stuart Katzke, Chief, NIST Computer Security Division, discussed a framework for
- assurance. Some of the questions about assurance that need to be addressed, for example, are:
- What is assurance? Who requires assurance? When are assurance measurements needed/useful?
- Dr. Katzke presented a framework that includes dimensions (Factors), assurance levels (ALs),
- metrics/values (Dimensions & ALs), and assurance equivalence classes. Factors that contribute to
- assurance are: Verification Process (Testing), Development Process, Qualifications, Operational
- Track Record of System or Product, and Operational Track Record of Developer on Prior
- Systems/Products
-
- He also discussed values/metrics for measuring various dimensions of assurance. He presented an
- example diagram and pointed out that one dimension could be the verification process. He also
- offered a diagram of assurance levels in a hierarchical design with low, medium, and high. Dr.
- Katzke said that the plan is to develop a framework that involves all stakeholders. Currently,
- NIST/NSA plans to engage the IT community in the development of a framework and short term metrics
- for assurance. An annual workshop on assurance is also planned, which will be co-sponsored by
- NIST. (See Reference #1).
-
-
-
-
- Assurance Components
-
- Mr. Bill Marshall, NSA, addressed the components of an assurance framework from the
- perspectives of an information security analyst, the supplier community, and an information
- systems security customer. He discussed the reasons someone would look for an information
- security solution. He said that a customer may have information that needs protection by value or
- by direction, which could be legislative or regulatory. The customer may also have information
- that they perceive to be subject to unacceptable risk. Mr. Marshall said that customers would
- make informed decisions, as they would when buying any product, by gathering information,
- relying on experts, and using accepted metrics.
-
- The customer is generally not aware of the qualification options. Therefore, the customer would
- need to use some standards set by either regulatory agencies or the professional community. With
- regard to specification, the first thing customers need to do is examine their security policy. He
- needs to verify that assurance is provided by the vendor and that the product has been time-tested.
- Mr. Marshall summarized by saying that the same level of risk reduction can be achieved in
- several ways. (See Reference #2).
-
- Canadian Perspective on Achieving Assurance
-
- Mr. Vince Muolo, Manager, Industrial Programs and Initiatives, Communications Security
- Establishment (CSE), Canada, briefed the Board on the CSE's perspective on information
- technology security product assurance in the context of information security product evaluations.
- CSE provides advice and guidance to the federal government of Canada on Information
- Technology Security with emphasis on security evaluations of the security aspects of information
- technology products and systems. CSE is using third party product evaluations and product
- reviews, neither of which have proven successful in achieving the levels of timeliness and
- assurance desired simultaneously. As a result, CSE is planning to explore new approaches to
- information security product assurance. Mr. Muolo described assurance as a measure of
- confidence that the security functionality will perform as claimed. Products gain assurance
- through evaluations under the CSE's Trusted Product Evaluation Program (TPEP). A trusted
- product allows the end user of the product to make assumptions about the security behavior of
- the product and how it can be used to counter threats in the target environment. Currently, CSE
- has two processes for adding assurance to products: (1) product review, and (2) evaluation. (See
- Reference #3).
-
- UK Perspective on Achieving Assurance
-
- Mr. Allen Borrett, CESG, UK, briefed the Board on approaches to assurance by the UK. The UK ITSEC
- scheme should meet the needs of government and industry with respect of cost-effective secure IT
- products and systems. The scheme would provide a basis for mutual international recognition and
- produce identical evaluation results. Mr. Borrett discussed the following differences between the
- US/UK evaluation process:
-
-
- - The UK evaluations are not government sponsored, and the sponsor sets the time and money
- constraints to the evaluator.
-
- - The UK is more methodology focused, while the US is more principle based.
-
- - The UK evaluators work, in conjunction with the developer, begins with the
- development process through the product implementation phase. They obtain the necessary
- documentation and understand product development as it is being done. The US begins the evaluation
- process at the end of the product implementation phase.
-
- Mr. Borrett said that the UK uses Certified Licensed Evaluation Facilities (CLEFs) that are
- non-government resourced evaluation facilities. The demand for CLEFs is growing. The UK will have
- five operational CLEFs soon and a sixth one is expected. He said that overall, the ITSEC
- evaluation time and cost required is significantly less than the US process. The primary reason is
- because their process is sponsor controlled and flexible. (See Reference #4).
-
- Assurance Economics
-
- Mr. Joel Sachs, the Sachs Groups, presented his company's view on the economics of assurance.
- He discussed internal economics, which include: threats to the target enterprise, weaknesses as
- they relate to vulnerabilities, and risks such as operational impacts and acceptable/unacceptable
- risks. He discussed the need for a viable information security economy that includes some of the
- following: (A) Freeing the market to resolve risk, trust, and assurance for enterprise, systems,
- and products. (B) Understanding and accommodating multiple business models across and
- among the players. (C) Developing assurance framework and metrics, both qualitative and
- quantitative, to define and delineate value. (See Reference #5).
-
- Capability Maturity Modeling Project
-
- Mr. David Kitson, Software Engineering Institute (SEI), Carnegie Mellon University, briefed the
- Board on the role and significance of the SEI Software Capability Maturity Modeling (CMM) for
- software. With regard to the transition of technology, the mission is to provide leadership in
- advancing the state-of-the-practice of software engineering to improve the quality of systems that
- depend on softwre. The vision is to bring engineering discipline to the development and
- maintenance of software. CMM is a common-sense application, a community-owned guide and a
- model for organizational improvement. Some of the benefits of model-based improvement are to:
-
- - Establish a common language;
-
- - Build on a set of processes and practices developed with input from a broad selection of
- the software community;
-
- - Provide a framework for prioritizing actions and performing reliable and consistent
- appraisals; and
-
- - Support industry-wide comparisons.
- The risks of model-based improvements are simplifications of the real world and a lack of
- comprehensive scope. Interpretation and tailoring must be aligned to business objectives. Mr.
- Kitson discussed the five maturity levels, the CMM s key process areas, and the evolution of the
- process capability. He said that broad-scale acceptance of the CMM is based on plausibility of a
- common-sense model and experience in other industries. The CMM is a living document, which
- will be revised. Contributions are solicited from the community. (See Reference #6).
-
- Security Engineering Capability Maturity Model and Trusted Capability Maturity Model
-
- Mr. John Adams, National Security Agency, briefed the Board on a Trusted Capability Maturity
- Model (TCMM). The TCMM will allow organizations to use one reference model and derive
- from it the benefits of two models, software process improvement and increased software
- assurance. There are two components of the TCMM: (1) A Software Capability Maturity Model
- and (2) a Trusted Software Development Methodology.
-
- Mr. Adams also described the Security Engingineering Capability Maturity Model (SECMM).
- The purpose of the model is to:
-
- - Increase asssurance in system trustworthiness;
-
- - Reach a point to transfer assurance from evaluation to development process;
-
- - Provide consistent maturity framework for security engineering development processes;
-
- - Provide security engineering process improvement mechanisms; and
-
- - Provide process-based assurance measurement mechanisms.
-
- The model structure is based on a maturity framework (similar to the SEI model). It tailors
- management and organizational processes and adds evolutionary security engineering processes.
- Mr. Adams said that to date the SECMM has accomplished a draft model, which includes a
- framework for process improvement, independent of specific organizational structure. The draft
- model was presented at the NIST/NSA National Computer Security Conference in October,
- 1994. There was a public workshop in January, 1995 and received overwhelming community
- endorsement. Future directions include expanding the scope of the SECMM market. It has
- focused only on the NSA/DoD community. As a follow-on to the workshop, there will be three
- working groups driven by industry: (1) a steering work group to define the key process, (2) an
- authoring work group for overall strategy, and (3) an application work group to define
- measurement techniques. (See Reference #7).
-
-
-
-
- Update on X/Open Branding Project
-
- Mr. Bill Whitehurst, IBM, gave a brief update of the activities of the X/Open Branding Project.
- Two major components exist within their branding concept: (1) the ability to implement
- functionality based on a minimum set of assurance functionality requirements (MSFR), and (2) the
- confidence in the development process for achieving the functionality.
-
- He said that the workgroup meeting, hosted by Hewlett Packard, was held early in March. The
- group plans to re-write their document to include some type of evaluation process prior to the
- vendor product getting branded. X/Open plans to have a public review of the changes this
- summer.
-
- Vendor Perspective
-
- Ms. Linda Vetter, Oracle Corporation, presented oracle's views of security assurance. She
- discussed three types of assurance issues: (1) governent evaluation and certification; (2) third
- party evaluation and certification (government and business sponsored); and (3) vendor claims.
- Ms. Vetter explained Oracle s evaluation experience for two DBMS server products, Oracle7 and
- Trusted Oracle7, in both the US and the UK. Oracle used the US TCSEC TPEP evaluation for
- B1 and C2 systems. They also used the UK ITSEC evaluation for E3 systems (which is the
- equivalent for US B1 and C2 systems). The UK process took significantly less time and cost less
- money for an identical product. Ms. Vetter suggested that NIST/NSA look into developing
- equivalent/comparable trust levels between the two different evaluation criteria methods as well as
- those for other countries. This would minimize the need to have different evaluations performed
- (one for each country) for the same product.
-
- Oracle has on-going work in other areas (e.g., RAMP, CMM, ISO, and Audits) as well as
- multiple CLEFS with the UK, Sweden, France and Germany. Ms. Vetter explained the
- differences in criteria between the TCSEC and the ITSEC. She said that the ITSEC requirements
- for the content of evaluation deliverables formed a superset of the corresponding TCSEC
- requirements for the evaluations. However, the TCSEC creates a framework for the presentation
- of these requirements and there can be little deviation from this.
-
- Oracle would like to see more concentration on low-end assurance requirements and processes.
- This would enable various sectors like health care, banking, and financial industries to have
- protection for unclasified to sensitive data. Ms. Vetter encouraged NSA to continue its efforts in
- modeling (Common Assurance Framework, TCMM, and SE CMM) and would discourage any
- more efforts in product profiling. The modeling efforts encourage vendor quality improvement,
- promotes flexibility in meeting assurance objectives, and are transferable to other private sector
- domains besides DoD. (See Reference #8).
-
-
-
-
- Wrap-up and Restatement of Issues
-
- Dr. Katzke summarized the discussion of assurance by saying that opportunities exist to look at
- alternatives. He is not sure what the government's role is or which areas to concentrate on with
- respect to cost. He said that he could continue with the same level of effort that is going on now
- with community involvement. He is open to suggestions with regard to the assurance process.
-
- Discussion
-
- After a lengthy discussion on the state of the Common Criteria (CC) and assurance approaches
- and issues, some of the major points from individual Board members included:
-
- - Concern as to when the CC will be widely accepted and used;
-
- - Whether to adopt the ITSEC now and migrate to CC;
-
- - The need to simplify the CC;
-
- - Building assurance and quality into the new assurance framework;
-
- - Clearly define assurance needs to be universally understood;
-
- - Conduct more C2 and below evaluations in the US;
-
- - Concentrate on low-end assurance; and
-
- - Bring key industry players into the process.
-
- The meeting recessed at 5:45 pm.
-
- Thursday, March 23, 1995
-
- Chairman's Time
-
- Dr. Ware introduced Mr. Joseph Leo, Deputy Administrator for Management, Food and
- Consumer Service, U.S. Department of Agriculture. Mr. Leo is a member designate to fill a
- government position on the Board.
-
- After minor changes from Mr. Whitehurst, Board members voted on and unanamously approved
- the minutes of the December 1994 meeting.
-
- During this time, Board members continued their discussion of criteria and assurance from the
- previous day. Some of the major points of the discussion from Board members included the need:
-
- - for OMB to state the need for C2 level evaluation compliance for various
- government product purchases;
-
- - for NSA to make a statement about equivalency among all existing non-US trust
- levels;
-
- - to begin using components of the Common Criteria and gradually migrate to it;
-
- - to continue a wide range of assurance framework options and procedures; and
-
- - to focus on low-end assurance methods and encourage C2 level evaluation along the
- following Canadian AL-1 evaluation.
-
-
-
- Security In Governmentwide E-Mail
-
- Mr. Jack Finley, Director, Electronic Messaging Program Management Office (E-Mail PMO) at
- the General Services Administration (GSA), briefed the Board on the status of security in E-Mail.
- He said the E-Mail PMO has three focus areas: (1) functional requirements, (2) management
- requirements, and (3) technical requirements. Mr. Finley said that security is an element in each
- one of the three focus areas.
-
- There are five PMO program functions: (1) program management to develop a two-year plan,
- (2) directory service support for registration services, and directory synchronization etc., (3)
- value added services for a centralized e-mail help desk, electronic support services, and a model
- service center, (4) cross cutting initiatives to implement guidance and training, gateway
- specifications etc., and (5) common system components for standards convergence, requirements
- definition and X.400 address simplification.
-
- The PMO strategic plan will promote and support electronic messaging business process, increase
- operational quality, productivity and effectiveness of governmentwide messaging, and provide
- professional help desk services. The governmentwide e-mail vision is to produce business quality
- e-mail, intermediate e-mail, and basic e-mail. Mr. Finley defined business quality e-mail as having
- a level of security to conduct financial and regulatory business for the unclassified arena.
-
- The Board continues to be concerned about security not being adequately addressed in the PMO
- effort. The Board suggested that Mr. Finley add security and privacy requirements as a separate
- focus area and that it be number one on the list. The Board also noted that there was no mention
- of security policy documentation or an implementation strategy. Mr. Finley said that security
- policy efforts are being undertaken by the NIST Public Key Infrastructure (PKI) Steering
- Committee and other security infrastructure issues are addressed through the Security
- Infrastructure Program Management Office (SI-PMO).
- (See Reference #9).
-
- Mr. Al Williams, Director, Federal Information Security Infrastructure Program Management
- Office (SI-PMO) at GSA, gave the Board an update on the progress of the SI-PMO. The PMO is
- Co-chaired by GSA and DoD. The charter is due to be signed by DoD and the Government
- Information Technology Services (GITS) Working Group by May 1, 1995. A Program Action
- Plan is expected to be completed by April. The primary role of the PMO is to provide
- governmentwide support and coordination of federal activities necessary to implement an
- information security infrastructure for the use of the federal government. A more specific goal is
- that the SI-PMO, working with individual agencies, will design pilots, coordinate implementations
- across agencies, promote the use of an information security infrastructure within government, and
- make recommendations to resolve conflicts in implementation and funding of this information
- security infrastructure. The PMO is not chartered, staffed, or funded to manage specific product
- developments, or to manage the development programs of individual government agencies. The
- total SI-PMO is composed of DoD, civilian agencies, financial institutions, medical/health care,
- and technical elements. The PMO security objectives show support for multiple technologies that
- include: RSA, DSS with DES encryption, FORTEZZA, and other X.509 variants. (See
- Reference #10).
-
- Security Policy Board
-
- Mr. Peter Saderholm, Director, Security Policy Board (SPB) Staff, briefed the Board on the
- proposed activities of the SPB. He said the creation of the SPB was based on a recommendation
- by the Joint Security Commission report of February 28, 1994. Presidential Decision Directive
- (PDD) 29, signed by the President on September 10, 1994, articulates the roles and
- responsibilities for the SPB, the Security Policy Advisory Board, and the Security Policy Forum.
-
- Board members were provided a "fact sheet" on PDD29. Some Board members expressed
- concern with the SPB's activities with regard to [setting policy for unclassified sensitive
- information in addition to classified information] in light of the national security scope of PDD29.
- Mr. Saderholm mentioned the need for the Board and the SPB to work together regarding
- privacy and security policy issues for unclassified sensitive information. He expressed his desire
- to continue dialogue with the Board and to build cooperative arrangements with industry
- representation when dealing with the protection of unclassified information. He said that the SPB
- is abiding by the Computer Security Act of 1987 and therefore, will not be responsible for policy
- surrounding unclassified information. However, he noted that the SPB will need to facilitate
- cross-sharing of information with those responsible for setting unclassified information protection
- policy. (See Reference #11).
-
-
-
-
- Federal Computer Security Program Managers Forum Opinion
-
- Ms. Sadie Pitcher, Department of Commerce and Forum Co-Chair, presented the views of the
- Forum regarding the SPB report's proposal to form a Information Systems Security Committee
- (ISSC). The Forum represents 75 federal government agencies. The Steering Committee of the
- Forum drafted a position paper to Ms. Sally Katzen of the Office of Management and Budget on
- January 11, 1995. The position paper articulated the following concerns:
-
- - Establishment of a national security dominated ISSC is contrary to the Computer
- Security Act and inconsistent with the authority of PDD-29;
-
- - Would undercut the effort for open government;
-
- - National security related information will be viewed as imposing new government
- restrictions on access to information;
-
- - The proposal may serve to increase public concerns over the government s
- intentions in the field of ISS;
-
- - It is inappropriate for the national security/intelligence communities to
- participate in selecting security measures for unclassified systems at civil
- agencies;
-
- - The unclassified security focus is on cost-effectiveness, integrity and
- availability, not primarily confidentiality, which is the traditional primary concern
- of the classified sector; and
-
- - Concern that the SPB report is being misrepresented as Administration policy.
-
- Ms. Pitcher said that OMB was asked to restrict the SPB report implementation to only classified
- systems. (See Reference #12).
-
- Status of Key Escrow Initiative
-
- Mr. Steve Walker, Trusted Information Systems (TIS), briefed the Board on the status of
- Commercial Key Escrow (CKE). He said, with regard to application vendors, TIS is actively
- seeking the participation of commercial software vendors in widespread implementation of CKE
- enabled software products. TIS has installed a Data Recovery Center (DRC) on the Internet and
- is prepared to distribute sample DRC application software packages to any interested software
- application developer. TIS is seeking approval of the US government for export of application
- programs using encryption algorithms such as the Data Encryption Standard (DES) when
- properly bound with CKE.
-
- Mr. Walker said the advantages of CKE for government interests is that if the TIS CKE system
- were to become widely used throughout the private sector and government communities, law
- enforcement, national security and private sector interests would be preserved.
-
- Mr. Walker said that TIS has filed for patent protection for its Software Key Escrow (Clipper
- equivalent) and CKE systems including the DRC and application software approaches. TIS is
- prepared to license its CKE system and software applications technology to any software or
- hardware vendor under very favorable licensing terms. TIS is also prepared to license its DRC
- system and technology to qualified DRC operators and vendors under similarly favorable licensing
- terms. (See Reference #13).
-
- OMB Circular A-130, appendix III Revision and Reauthorization of the Paperwork Reduction
- Act
-
- Mr. Ed Springer, Office of Management and Budget (OMB), briefed the Board on the proposed
- revision of Appendix III of Circular A-130. Mr. Springer said that the proposal is intended to
- guide agencies in securing information as they increasingly rely on an open and interconnected
- National Information Infrastructure. It stresses management controls such as individual
- responsibility, awareness and training, and accountability, rather than technical controls. The
- Appendix proposes to re-orient the federal computer security program to better respond to a
- rapidly changing technological environment. It establishes governmentwide responsibilities for
- federal computer security and requires federal agencies to adopt a minimum set of management
- controls.
-
- As in the previous Appendix III, agencies are still required to establish controls to assure adequate
- security for all information processed, transmitted, or stored in federal automated information
- systems. This proposal emphasizes management controls affecting individual uses of information
- technology. The Appendix requires that these management controls be applied in two areas of
- management responsibility, general support systems and major applications. The Federal Register
- announcement of the Appendix provides supplementary discussion to aid reviewers in
- understanding the changes in emphasis proposed. Mr. Springer said that agencies will phase into
- implementing security requirements articulated in Appendix III. (See Reference #14).
-
- Public Comment
-
- During the public comment period, Ms. Sadie Pitcher advised the Board of an effort in progress
- by the Federal Information Systems Security Educators Association, a subgroup of the Federal
- Computer Security Program Managers' Forum, to revise NIST Special Pub 500-172, Training
- Guidelines. This effort is in line with OMB s recommendation to the Department of Commerce,
- in Appendix III, to review and update guidelines for training in computer security awareness and
- accepted computer security practice.
-
-
-
- Board Discussion
-
- After discussion, deliberation, and debate, the Board passed three resolutions. (See Attachments
- 1-3.)
-
- The meeting adjourned at 6:00 pm.
-
- Attachments
- #1 - Resolution 95-1
- #2 - Resolution 95-2
- #3 - Resolution 95-3
- /s/
-
- References Edward Roback
- #1 - Katzke slides Secretary
- #2 - Marshall slides
- #3 - Muolo slides
- #4 - Borrett slides
- #5 - Sachs slides
- #6 - Kitson slides
- #7 - Adams slides
- #8 - Vetter slides CERTIFIED as a true
- #9 - Finley slides and accurate summary
- #10 - Williams slides of the meeting
- #11 - Saderholm slides
- #12 - Pitcher slides
- #13 - Walker slides /s/
- #14 - Springer paper
- Willis Ware
- Chairman
-