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-
- United States General Accounting Office
- ___________________________________________________________________
- GAO Report to the Chairman, Committee on
- Science, Space, and Technology,
- House of Representatives
-
- ___________________________________________________________________
- May 1990 COMPUTER SECURITY
-
- Governmentwide Planning Process
- Had Limited Impact
-
-
-
-
- ___________________________________________________________________
- GAO/IMTEC-90-48
-
-
-
-
- This U.S. General Accounting Office (GAO) report is 1 of 7
- available over the Internet as part of a test to determine
- whether there is sufficient interest within this community to
- warrant making all GAO reports available over the Internet.
- The file REPORTS at NIH lists the 7 reports.
-
- So that we can keep a count of report recipients, and your
- reaction, please send an E-Mail message to KH3@CU.NIH.GOV and
- include, along with your E-Mail address, the following
- information:
-
- 1) Your organization.
-
- 2) Your position/title and name (optional).
-
- 3) The title/report number of the above reports you have
- retrieved electronically or ordered by mail or phone.
-
- 4) Whether you have ever obtained a GAO report before.
-
- 5) Whether you have copied a report onto another bulletin
- board--if so, which report and bulletin board.
-
- 6) Other GAO report subjects you would be interested in.
- GAO's reports cover a broad range of subjects such as
- major weapons systems, energy, financial institutions,
- and pollution control.
-
- 7) Any additional comments or suggestions.
-
- Thank you for your time.
-
-
- Sincerely,
-
- Jack L. Brock, Jr.
- Director,
- Government Information and Financial
- Management Issues
- Information Management and Technology Division
-
- B-238954
-
-
- May 10, 1990
-
-
- The Honorable Robert A. Roe
- Chairman, Committee on Science,
- Space, and Technology
- House of Representatives
-
- Dear Mr. Chairman:
-
- This report responds to your June 5, 1989, request and
- subsequent agreements with your office that we review the
- governmentwide computer security planning and review process
- required by the Computer Security Act of 1987. The act
- required federal agencies to identify systems that contain
- sensitive information and to develop plans to safeguard
- them. As agreed, we assessed the (1) planning process in 10
- civilian agencies as well as the extent to which they
- implemented planned controls described in 22 selected plans
- and (2) National Institute of Standards and Technology
- (NIST)/National Security Agency (NSA) review of the plans.
-
- This is the fifth in a series of reports on implementation
- of the Computer Security Act that GAO has prepared for your
- committee. Appendix I details the review's objectives,
- scope, and methodology. Appendix II describes the systems
- covered by the 22 plans we reviewed.
-
- RESULTS IN BRIEF
- ----------------
- The planning and review process implemented under the
- Computer Security Act did little to strengthen computer
- security governmentwide. Although agency officials believe
- that the process heightened awareness of computer security,
- they typically described the plans as merely "reporting
- requirements" and of limited use in addressing agency-
- specific problems.
-
- Officials cited three problems relating to the design and
- implementation of the planning process: (1) the plans
- lacked adequate information to serve as management tools and
- some agencies already had planning processes in place, (2)
- managers had little time to prepare the plans, and (3) the
- Office of Management and Budget (OMB) planning guidance was
- sometimes unclear and misinterpreted by agency officials.
-
-
-
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- B-238954
-
- Although a year has passed since the initial computer
- security plans were completed, agencies have made little
- progress in implementing planned controls. Agency officials
- said that budget constraints and inadequate top management
- support--in terms of resources and commitment--were key
- reasons why controls had not been implemented.
-
- Based on the results of the planning and review process,
- OMB--in conjunction with NIST and NSA--issued draft security
- planning guidance in January 1990. The draft guidance
- focuses on agency security programs and calls for NIST, NSA,
- and OMB to visit agencies to discuss their security programs
- and problems, and provide advice and technical assistance.
- We believe that efforts directed toward assisting agencies
- in solving specific problems and drawing top management
- attention to computer security issues have greater potential
- for improving computer security governmentwide.
-
- BACKGROUND
- ----------
- The Computer Security Act of 1987 (P.L. 100-235) was passed
- in response to concerns that the security of sensitive
- information was not being adequately addressed in the
- federal government.1 The act's intent was to improve the
- security and privacy of sensitive information in federal
- computer systems by establishing minimum security practices.
- The act required agencies to (1) identify all developmental
- and operational systems with sensitive information, (2)
- develop and submit to NIST and NSA for advice and comment a
- security and privacy plan for each system identified, and
- (3) establish computer security training programs.
-
- OMB Bulletin 88-16, developed with NIST and NSA assistance,
- provides guidance on the computer security plans required by
- the act. To be in compliance, approximately 60 civilian
- agencies submitted almost 1,600 computer security plans to a
- NIST/NSA review team in early 1989. Nearly all of these
- plans followed, to some degree, the format and content
- requested by the bulletin. The bulletin requested that the
- following information be included in each plan:
-
-
- 1The act defines sensitive information as any unclassified
- information that in the event of loss, misuse, or
- unauthorized access or modification, could adversely affect
- the national interest, conduct of a federal program, or the
- privacy individuals are entitled to under the Privacy Act of
- 1974 (5 U.S.C. 552a).
-
- 2
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- B-238954
-
- -- Basic system identification: agency, system name and
- type, whether the plan combines systems, operational
- status, system purpose, system environment, and point of
- contact.
-
- -- Information sensitivity: laws and regulations affecting
- the system, protection requirements, and description of
- sensitivity.
-
- -- Security control status: reported as "in place,"
- "planned," "in place and planned" (i.e., some aspects of
- the control are operational and others are planned), or
- "not applicable," and a brief description of and expected
- operational dates for controls that are reported as
- planned.2 (Appendix V lists the controls.)
-
- Appendix III presents a composite security plan that we
- developed for this report as an example of the civilian
- plans we reviewed. It is representative of the content,
- format, and common omissions of the plans.
-
- PLANS HAD LIMITED IMPACT ON
- ---------------------------
- AGENCY COMPUTER SECURITY PROGRAMS
- ---------------------------------
- The goals of the planning process were commendable--to
- strengthen computer security by helping agencies identify
- and evaluate their security needs and controls for sensitive
- systems. According to agency officials, the process yielded
- some benefits, the one most frequently cited being increased
- management awareness of computer security. Further, some
- officials noted that the planning process provided a
- framework for reviewing their systems' security controls.
-
- However, problems relating to the design and implementation
- of the planning process limited its impact on agency
- security programs. Specifically, (1) the plans lacked
- adequate information to serve as effective management tools,
- (2) managers had little time to prepare the plans, and (3)
- the OMB guidance was sometimes unclear and misinterpreted by
- the agencies. Consequently, most agency officials viewed
- the plans as reporting requirements, rather than as
- management tools.
-
-
- 2In this report, we are using the term "planned controls" to
- include controls that agencies listed as "planned" or "in
- place and planned" in their January 1989 plans. Both
- categories indicated that the controls were not fully in
- place.
-
-
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-
- Plans Lacked Adequate Information to
- ------------------------------------
- Serve as Effective Management Tools
- -----------------------------------
- Although agency officials said that security planning is
- essential to the effective management of sensitive systems,
- the plans lacked important information that managers need in
- order to plan, and to monitor and implement plans. The
- plans did not include this information, in part, because
- they were designed not only to help agencies plan, but also
- to facilitate NIST/NSA's review of the plans and to minimize
- the risks of unauthorized disclosure of vulnerabilities.
- For example:
-
- -- Many plans provided minimal descriptions (a sentence or
- nothing at all) of system sensitivity and planned
- security controls. Detailed descriptions would have
- made the plans more useful in setting priorities for
- implementing planned controls.
-
- -- The plans did not assign responsibility for each planned
- control. It was not clear, therefore, who was
- accountable for implementing the control (e.g., who would
- be performing a risk assessment).
-
- -- The plans did not include resource estimates needed to
- budget for planned actions.
-
- -- The plans generally did not refer to computer security-
- related internal control weaknesses, although such
- information can be important in developing plans.
-
- Finally, officials from about one-third of the agencies said
- that they already had more comprehensive planning processes
- to help them identify and evaluate their security needs. As
- a result, the governmentwide process was largely superfluous
- for these agencies. Officials at such agencies said that
- their plans, which included information such as detailed
- descriptions of security controls, already met the
- objectives of the governmentwide planning process. Many
- officials said that what they needed was assistance in areas
- such as network security.
-
- Managers Had Little
- -------------------
- Time to Prepare the Plans
- -------------------------
- Officials had little time to adequately consider their
- security needs and prepare plans, further limiting the
- usefulness of the plans. OMB Bulletin 88-16 was issued July
- 6, 1988, 27 weeks before the plans were due to the NIST/NSA
-
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-
- review team, as required by the Computer Security Act.
- However, less than 14 weeks was left after most agencies
- issued guidance on responding to the OMB request. Within
- the remaining time, instructions were sent to the component
- agencies and from there to the managers responsible for
- preparing the plans, meetings were held to discuss the
- plans, managers prepared the plans, and the plans were
- reviewed by component agencies and returned to the agencies
- for review. As a result, some managers had only a few days
- to prepare plans.
-
- Guidance Was Sometimes Unclear
- ------------------------------
- and Misinterpreted by Agencies
- ------------------------------
- Many agency officials misinterpreted or found the guidance
- unclear as to how systems were to be combined in the plans,
- the definition of some key terms (e.g., "in place"), the
- level of expected detail, and the need to address
- telecommunications. For example, some plans combined many
- different types of systems--such as microcomputers and
- mainframes--having diverse functions and security needs,
- although the guidance specified that only similar systems
- could be combined. When dissimilar systems were combined,
- the plan's usefulness as a management tool was limited.
-
- Further, for plans that combined systems, some agencies
- reported that a security control was in place for the entire
- plan, although it was actually in place for only a few
- systems. Agency officials stated that they combined systems
- in accordance with their understanding of the OMB guidance
- and NIST/NSA verbal instructions.
-
- In addition, officials were confused about how much detail
- to include in the plans and whether to address
- telecommunications issues (e.g., network security). For
- example, they said that although the guidance asked for
- brief descriptions of systems and information sensitivity,
- NIST/NSA reviewers frequently commented that plans lacked
- adequate descriptions. NIST officials said they expected
- that the plans would be more detailed and discuss the
- vulnerabilities inherent in networks. They said, in
- retrospect, that it would have been helpful if the guidance
- had provided examples and clarified the level of expected
- detail.
-
- AGENCIES HAVE NOT IMPLEMENTED
- -----------------------------
- MOST PLANNED SECURITY CONTROLS
- ------------------------------
- Although a year has passed since the initial computer
- security plans were completed, agencies have made little
-
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- B-238954
-
- progress in implementing planned controls.3 The 22 plans we
- reviewed contained 145 planned security controls. According
- to agency officials, as of January 1990, only 38 percent of
- the 145 planned controls had been implemented.
-
- Table 1 shows the number and percentage of planned security
- controls that had been implemented as of January 1990.
-
- Table 1: Implementation of Security Controls in 22 Plans
-
- Percent
- Security control Planned Implemented implemented
- ---------------- ------- ----------- -----------
- Assignment of security
- responsibility 7 7 100
-
- Audit and variance
- detection 7 7 100
-
- Confidentiality
- controls 3 3 100
-
- User identification
- and authentication 2 2 100
-
- Personnel selection
- and screening 7 6 86
-
- Security measures for
- support systems 9 5 56
-
- Security awareness and
- training measures 20 12 60
-
- Authorization/access
- controls 4 2 50
-
- Contingency plans 11 5 45
-
- Data integrity and
- validation controls 8 2 25
-
- Audit trails and
- maintaining
- journals 12 2 17
-
-
-
- 3Only 4 percent of the security controls had implementation
- dates beyond January 1990.
-
- 6
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-
- Production, input/
- output controls 8 1 13
-
- Risk/sensitivity
- assessment 11 1 9
-
- Security specifications 10 0 0
-
- Design review and
- testing 11 0 0
-
- Certification/
- accreditation 14 0 0
-
- Software controls 1 0 0
-
- Total 145 55 -
-
-
- According to many agency officials, budget constraints and
- lack of adequate top management support--in terms of
- resources and commitment--were key reasons why security
- controls had not yet been implemented.
-
- Although some officials stated that the planning process has
- raised management awareness of computer security issues,
- this awareness has, for the most part, apparently not yet
- resulted in increased resources for computer security
- programs. A number of officials said that security has been
- traditionally viewed as overhead and as a target for budget
- cuts. Some officials noted that requests for funding of
- contingency planning, full-time security officers, and
- training for security personnel and managers have a low
- approval rate.
-
- NIST/NSA REVIEW FEEDBACK WAS GENERAL
- ------------------------------------
- AND OF LIMITED USE TO AGENCIES
- ------------------------------
- Agency officials said that the NIST/NSA review comments and
- recommendations on their plans were general and of limited
- use in addressing specific problems. However, because the
- plans were designed to be brief and minimize the risks of
- unauthorized disclosure, they had little detailed
- information for NIST and NSA to review. Thus, the NIST/NSA
- review team focused their comments on (1) the plans'
- conformity with the OMB planning guidance and (2)
- governmentwide guidance (e.g., NIST Federal Information
- Processing Standards publications) relating to planned
- security controls. (Appendix IV provides an example of
- typical NIST/NSA review comments and recommendations.)
-
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- B-238954
-
-
- Despite the limited agency use of the feedback, NIST
- officials said that the information in the plans will be
- useful to NIST in identifying broad security weaknesses and
- needs. During the review process, the NIST/NSA review team
- developed a data base that included the status of security
- controls for almost 1,600 civilian plans. NIST intends to
- use statistics from the data base to support an upcoming
- report on observations and lessons learned from the planning
- and review process. Noting that the data have limitations--
- for example, varying agency interpretations of "in place"--
- NIST officials said that areas showing the greatest
- percentage of planned controls indicated areas where more
- governmentwide guidance might be needed. Appendix V shows
- the status of security controls in the civilian plans,
- according to our analysis of the NIST/NSA data base.4
-
- REVISED GUIDANCE PROVIDES
- -------------------------
- FOR AGENCY ASSISTANCE
- ---------------------
- The 1990 draft OMB security planning guidance calls for
- NIST, NSA, and OMB to provide advice and technical
- assistance on computer security issues to federal agencies
- as needed. Under the guidance, NIST, NSA, and OMB would
- visit agencies and discuss (1) their computer security
- programs, (2) the extent to which the agencies have
- identified their sensitive computer systems, (3) the quality
- of their security plans, and (4) their unresolved internal
- control weaknesses. NIST officials said that the number of
- agencies visited in fiscal year 1991 will depend on that
- year's funding for NIST's Computer Security Division, which
- will lead NIST's effort, and the number of staff provided by
- NSA.
-
- In addition, under the 1990 draft guidance, agencies would
- develop plans for sensitive systems that are new or
- significantly changed, did not have a plan for 1989, or had
- 1989 plans for which NIST and NSA could not provide comments
- because of insufficient information. Agencies would be
- required to review their component agency plans and provide
- independent advice and comment.
-
- CONCLUSIONS
- -----------
- The government faces new levels of risk in information
- security because of increased use of networks and computer
-
-
- 4NIST and NSA deleted agency and system names from the data
- base provided to us.
-
- 8
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- B-238954
-
- literacy and greater dependence on information technology
- overall. As a result, effective computer security programs
- are more critical than ever in safeguarding the systems that
- provide essential government services.
-
- The planning and feedback process was an effort to
- strengthen computer security by helping agencies identify
- and assess their sensitive system security needs, plans, and
- controls. However, the plans created under the process were
- viewed primarily as reporting requirements, and although the
- process may have elevated management awareness of computer
- security, as yet it has done little to strengthen agency
- computer security programs.
-
- OMB's draft planning security guidance creates the potential
- for more meaningful improvements by going beyond planning
- and attempting to address broader agency-specific security
- problems. However, although NIST, NSA, and OMB assistance
- can provide an impetus for change, their efforts must be
- matched by agency management commitment and actions to make
- needed improvements. Ultimately, it is the agencies'
- responsibility to ensure that the information they use and
- maintain is adequately safeguarded and that appropriate
- security measures are in place and tested. Agency
- management of security is an issue we plan to address in our
- ongoing review of this important area.
-
-
- --- --- ---
-
- As requested, we did not obtain written agency comments on
- this report. We did, however, discuss its contents with
- NIST, OMB, and NSA officials and have included their
- comments where appropriate. We conducted our review between
- July 1989 and March 1990, in accordance with generally
- accepted government auditing standards.
-
- As arranged with your office, unless you publicly release
- the contents of this report earlier, we plan no further
- distribution until 30 days after the date of this letter.
- At that time we will send copies to the appropriate House
- and Senate committees, major federal agencies, OMB, NIST,
- NSA, and other interested parties. We will also make copies
- available to others on request.
-
- This report was prepared under the direction of Jack L.
- Brock, Jr., Director, Government Information and Financial
- Management, who can be reached at (202) 275-3195. Other
- major contributors are listed in appendix VI.
-
-
- 9
-
- B-238954
-
- Sincerely yours,
-
-
-
-
-
- Ralph V. Carlone
- Assistant Comptroller General
-
-
-
- 10
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- B-238954
-
- CONTENTS Page
- --------- ----
-
- LETTER 1
-
-
- APPENDIX
-
- I Objectives, Scope, and Methodology 12
-
- II Plans GAO Reviewed 14
-
- III Computer Security and Privacy Plan 16
-
- IV NIST/NSA Feedback on Computer Security Plans 21
-
- V Status of Security Controls in 1,542 Plans 22
-
- VI Major Contributors to This Report 24
-
- Related GAO Products 25
-
- TABLE
-
- 1 Implementation of Security Controls in 22 6
- Plans
-
- ABBREVIATIONS
- -------------
- GAO General Accounting Office
- IMTEC Information Management and Technology Division
- NIST National Institute of Standards and Technology
- NSA National Security Agency
- OMB Office of Management and Budget
-
-
- 11
-
- APPENDIX I APPENDIX I
-
-
- OBJECTIVES, SCOPE, AND METHODOLOGY
- ----------------------------------
- In response to a June 5, 1989, request of the Chairman,
- House Committee on Science, Space, and Technology, and
- subsequent agreements with his office, we assessed the
- impact of the computer security planning and review process
- required by the Computer Security Act of 1987.
-
- As agreed, we limited our review primarily to 10 civilian
- agencies in the Washington, D.C. area: the Departments of
- Agriculture, Commerce, Energy, Health and Human Services,
- the Interior, Labor, Transportation, the Treasury, and
- Veterans Affairs and the General Services Administration.
- As agreed, the Department of Defense was excluded from our
- review because the plans it submitted differed
- substantially in format and content from the civilian plans.
-
-
- Specifically, we
-
- --assessed the computer security planning process and
- NIST/NSA review comments on the security plans developed as
- a result of the process,
-
- --determined the extent to which the 10 agencies implemented
- planned control measures reported in 22 selected plans, and
-
- --developed summary statistics using a NIST/NSA data base
- covering over 1,500 civilian computer security plans.
-
- To assess the impact of the planning and review process on
- agencies' security programs, we interviewed information
- resource management, computer security, and other officials
- from the 10 agencies listed above. In addition, we
- interviewed officials from NIST, NSA, and OMB who were
- involved in the planning process, to gain their perspectives
- on the benefits and problems associated with the process.
-
- We analyzed 22 computer security plans developed by the 10
- agencies and the NIST/NSA review feedback relating to the
- plans. Most plans addressed groups of systems. (See app.
- II for a description of the systems.) We selected the
- systems primarily on the basis of their sensitivity,
- significance, and prior GAO, President's Council on
- Integrity and Efficiency, and OMB reviews. We also reviewed
- federal computer security planning and review guidance,
- department requests for agency component plans, and
- department and agency computer security policies.
-
-
- 12
-
- APPENDIX I APPENDIX I
-
- To determine the extent to which planned computer security
- controls have been implemented, we reviewed the 22 plans and
- discussed with agency officials the status of these
- controls. To develop security plan statistics, we used the
- NIST/NSA data base, which contains data on the status of
- controls for over 1,500 plans. We did not verify the status
- of the planned controls as reported to us by agency
- officials, the accuracy of the plans, or the data in the
- NIST/NSA data base.
-
-
-
- 13
-
- APPENDIX II APPENDIX II
-
- PLANS GAO REVIEWED
- ------------------
- Organization Plan
- ------------ ----
- Farmers Home Administration Automated Field Management
- System
-
- Accounting Systems
-
- Patent and Trademark Office Patent and Trademark
- Automation Systems
-
- Social Security Administration Benefit Payment System
-
- Social Security Number
- Assignment System
-
- Earnings Maintenance System
-
- Access Control Event
- Processor System
-
- Bureau of Labor Statistics Economic Statistics System
-
- Employment Standards Federal Employees'
- Administration Compensation System
- Level I
-
- U.S. Geological Survey National Digital
- Cartographic Data Base
-
- National Earthquake
- Information Service
-
- Federal Aviation Administration En Route and Terminal Air
- Traffic Control System
-
- Maintenance and Operations
- Support Systems
-
- Interfacility
- Communications System
-
- Ground-to-Air Systems
-
- Weather and Flight
- Services Systems
-
-
-
-
- 14
-
-
- APPENDIX II APPENDIX II
-
- Organization Plan
- ------------ ----
- Internal Revenue Service Compliance Processing
- System
-
- Tax Processing System
-
- Customs Service Automated Commercial
- System
-
- Veterans Affairs Austin Data Mainframe Equipment
- Processing Center Configuration
-
- General Services Administration FSS-19 Federal Supply
- System
-
- Department of Energy Strategic Mainframe Computer and PC
- Petroleum Reserve Project Sensitive Systems
- Management Office
-
- Note: Summary information describing each of the above
- systems has been omitted from this version of the report.
- Call GAO report distribution at 202-275-6241 to obtain a
- complete copy of this report.
-
-
-
-
- 15
-
- APPENDIX III APPENDIX III
-
- COMPUTER SECURITY AND PRIVACY PLAN
- ----------------------------------
- We developed this composite security plan to show what most
- civilian plans contained, their format, and some common omissions.
- Notes in parentheses show common deviations from the OMB guidance.
-
-
- Computer Security and Privacy Plan
-
- 1. BASIC SYSTEM IDENTIFICATION
-
- Reporting Department or Agency - Department of X
-
- Organizational Subcomponent - Subagency Y
-
- Operating Organization - Organization Z
-
- System Name/Title - Automated Report Management System (ARMS)
-
- System Category
-
- [X] Major Application
- [ ] General-Purpose ADP Support System
-
- Level of Aggregation
-
- [X] Single Identifiable System
- [ ] Group of Similar Systems
-
- Operational Status
-
- [X] Operational
- [ ] Under Development
-
-
- General Description/Purpose - The primary purpose of ARMS is
- to retrieve, create, process, store, and distribute data.
- (Note: The description and purpose is incomplete. OMB
- Bulletin 88-16 required a one or two paragraph description of
- the function and purpose of the system.)
-
- System Environment and Special Considerations - System is
- controlled by a ABC series computer which is stored in the
- computer room. (Note: The environment is not adequately
- described. OMB Bulletin 88-16 requested a description of
- system location, types of computer hardware and software
- involved, types of users served, and other special
- considerations.)
-
- Information Contact - Security Officer, J. Doe, 202/275-xxxx
-
- 16
-
- APPENDIX III APPENDIX III
-
- 2. SENSITIVITY OF INFORMATION
-
- General Description of Information Sensitivity
-
- The data ARMS maintains and uses are those required to provide
- a total management information function. (Note: This
- description is inadequate. OMB Bulletin 88-16 requested that
- the plans describe, in general terms, the nature of the system
- and the need for protective measures.)
-
-
- Applicable Laws or Regulations Affecting the System
-
- 5 U.S.C. 552a, "Privacy Act," c. 1974.
-
-
-
- System Protection Requirements
-
- The Protection Requirement is:
-
- Primary Secondary Minimal/NA
- [X] Confidentiality [X] [ ] [ ]
- [X] Integrity [X] [ ] [ ]
- [X] Availability [ ] [X] [ ]
-
-
-
- 3. SYSTEM SECURITY MEASURES
-
- Risk Assessment - There currently exists no formal large scale
- risk assessment covering ARMS. We are scheduling a formal
- risk analysis.
-
- Applicable Guidance - FIPS PUBS No. 41, Computer Security
- Guidelines for Implementing the Privacy Act of 1974;
- FIPS PUB No. 83, Guidelines on User Authentication Techniques
- for Computer Network Access Control.
-
-
-
-
- 17
-
- APPENDIX III APPENDIX III
-
-
- SECURITY MEASURES
- -----------------
-
- MANAGEMENT CONTROLS
- In Place
- In Place Planned & Planned N/A
- -------- ------- --------- ---
- Assignment of Security
- Responsibility [X] [ ] [ ] [ ]
-
- Risk/Sensitivity
- Assessment [ ] [ ] [X] [ ]
-
- A formal risk analysis program will be used to update the
- current assessment. (Note: An expected operational date is
- not included. OMB Bulletin 88-16 states that there should be
- expected operational dates for controls that are planned or
- in place and planned.)
-
- Personnel Selection
- Screening [ ] [ ] [X] [ ]
-
- National Agency Check Inquiries (NACI) are required for all
- employees but have not been completed for everyone having
- access to sensitive information. Expected operational date -
- October 1989.
-
-
- DEVELOPMENT CONTROLS
-
- In Place
- In Place Planned & Planned N/A
- -------- ------- --------- ---
- Security
- Specifications [X] [ ] [ ] [ ]
-
- Design Review
- & Testing [ ] [ ] [ ] [X]
-
- Certification/
- Accreditation [ ] [X] [ ] [ ]
-
- (Note: No information is given for certification/
- accreditation. OMB Bulletin 88-16 states that a general
- description of the planned measures and expected operational
- dates should be provided.)
-
-
-
-
- 18
-
- APPENDIX III APPENDIX III
-
- OPERATIONAL CONTROLS
-
- In Place
- In Place Planned & Planned N/A
- -------- ------- --------- ---
-
- Production, I/O Controls [X] [ ] [ ] [ ]
-
- Contingency Planning [ ] [X] [ ] [ ]
-
- A contingency plan is being developed in compliance with
- requirements established by the agency's security program.
- Completion date - November 1990.
-
- Audit and Variance
- Detection [ ] [ ] [X] [ ]
-
- Day-to-day procedures are being developed for variance
- detection. Audit reviews are also being developed and will be
- conducted on a monthly basis. Completion date - June 1989.
-
- Software Maintenance
- Controls [X] [ ] [ ] [ ]
-
- Documentation [X] [ ] [ ] [ ]
-
-
- SECURITY AWARENESS AND TRAINING
-
- In Place
- In Place Planned & Planned N/A
- -------- ------- --------- ---
- Security Awareness and
- Training Measures [ ] [ ] [X] [ ]
-
- Training for management and users in information and
- application security will be strengthened, and security
- awareness training provided for all new employees beginning in
- June 1989.
-
-
-
- 19
-
- APPENDIX III APPENDIX III
-
- TECHNICAL CONTROLS
-
- In Place
- In Place Planned & Planned N/A
- -------- ------- --------- ---
- User Identification and
- Authentication [X] [ ] [ ] [ ]
-
- Authorization/Access
- Controls [X] [ ] [ ] [ ]
-
- Data Integrity &
- Validation Controls [X] [ ] [ ] [ ]
-
- Audit Trails & Journaling [X] [ ] [ ] [ ]
-
-
-
- SUPPORT SYSTEM SECURITY MEASURES
-
- In Place
- In Place Planned & Planned N/A
- -------- ------- --------- ---
- Security Measures for
- Support Systems [X] [ ] [ ] [ ]
-
-
- 4. NEEDS AND ADDITIONAL COMMENTS
-
- (Note: This section was left blank in most plans. OMB
- Bulletin 88-16 stated that the purpose of this section was to
- give agency planners the opportunity to include comments
- concerning needs for additional guidance, standards, or other
- tools to improve system protection.)
-
-
-
-
- 20
-
- APPENDIX IV APPENDIX IV
-
- NIST/NSA FEEDBACK ON COMPUTER SECURITY PLANS
- --------------------------------------------
-
- The following example shows typical NIST/NSA comments and
- recommendations.
-
- COMPUTER SECURITY PLAN REVIEW PROJECT COMMENTS AND RECOMMENDATIONS
-
- REF. NO. 0001
-
- AGENCY NAME: Department of X
- Subagency Y
-
- SYSTEM NAME: Automated Report Management System
-
-
- The brevity of information in the information sensitivity, general
- system description, and the system environment sections made it
- difficult to understand the security needs of the system.
- Information on the physical, operational, and technical environment
- and the nature of the sensitivity is essential to understanding the
- security needs of the system.
-
- For some controls, such as security training and awareness,
- expected operational dates are not indicated as required by OMB
- Bulletin 88-16.
-
- The plan refers to the development control, design review and
- testing, as not applicable. Even in an operational system,
- development controls should be addressed as historical security
- measures and as ongoing measures for changing hardware and
- software.
-
- The plan notes that a more formal risk assessment is being planned.
- This effort should help your organization more effectively manage
- risks and security resources. National Institute of Standards and
- Technology Federal Information Processing Standards Publication 65,
- "Guideline for Automatic Data Processing Risk Analysis," and 73,
- "Guideline for the Security of Computer Applications" may be of
- help in this area.
-
-
-
-
- 21
-
- APPENDIX V APPENDIX V
-
-
- STATUS OF SECURITY CONTROLS IN 1,542 PLANS
- ------------------------------------------
- Planned &
- Plan In place in place Planned
- ---- -------- --------- -------
- Security controls responses#a (percent) (percent) (percent)
-
- Management controls
-
- Assignment of security
- responsibility 1,448 91 5 4
-
- Personnel selection and
- screening 1,268 84 11 5
-
- Risk analysis and
- sensitivity assessment 1,321 71 13 17
-
- Development controls
-
- Design review and testing 728 82 10 8
-
- Certification and
- accreditation 948 66 10 24
-
- Security and acquisition
- specifications 1,093 83 10 7
-
- Operational controls
-
- Audit and variance
- detection 1,177 81 7 12
-
- Documentation 1,375 83 10 8
-
- Emergency, backup, and
- contingency planning 1,381 69 14 17
-
- Physical and environmental
- protection 450 87 10 4
-
- Production and input/
- output controls 1,290 87 7 7
-
- Software maintenance
- controls 1,327 87 7 7
-
- Security training and
- awareness measures 1,408 58 27 15
-
-
- 22
-
- APPENDIX V APPENDIX V
-
- Technical controls
-
- Authorization/access
- controls 1,389 87 6 7
-
- Confidentiality controls 357 84 7 9
-
- Audit trail mechanisms 1,194 83 8 9
-
- Integrity controls 1,220 85 8 7
-
- User identification
- and authentication 1,370 87 7 6
-
-
- Weighted average -- 81 10 10
-
-
- Note: The status of security controls is based on information reported
- in 1,542 civilian plans in early 1989 and contained in the NIST/NSA data
- base. Missing and not applicable answers were not included in the
- percentages. Some percentages do not add up to 100 due to rounding.
-
- a"Plan responses" is the number of plans, out of 1,542, that addressed
- each control.
-
-
-
- 23
-
- APPENDIX VI APPENDIX VI
- MAJOR CONTRIBUTORS TO THIS REPORT
- ---------------------------------
-
- INFORMATION MANAGEMENT AND TECHNOLOGY DIVISION, WASHINGTON, D.C.
- ----------------------------------------------------------------
- Linda D. Koontz, Assistant Director
- Jerilynn B. Hoy, Assignment Manager
- Beverly A. Peterson, Evaluator-in-Charge
- Barbarol J. James, Evaluator
-
- (510465)
-
-
-
- 24
-
- RELATED GAO PRODUCTS
- --------------------
- Computer Security: Identification of Sensitive Systems Operated on
- Behalf of Ten Agencies (GAO/IMTEC-89-70, Sept. 27, 1989).
-
- Computer Security: Compliance With Security Plan Requirements of the
- Computer Security Act (GAO/IMTEC-89-55, June 21, 1989).
-
- Computer Security: Compliance With Training Requirements of the
- Computer Security Act of 1987 (GAO/IMTEC-89-16BR, Feb. 22, 1989).
-
- Computer Security: Status of Compliance With the Computer Security Act
- of 1987 (GAO/IMTEC-88-61BR, Sept. 22, 1988).
-
-
- 25
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- Downloaded From P-80 International Information Systems 304-744-2253
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