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NIA #20 - Executive Guide: Protection of Informati
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? Founded By: ? ? Network Information Access ? ? Founded By: ?
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???????? Executive Guide/Protection Of Information ??????
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Federal agencies are becoming increasingly
dependent upon automated information systems to carry out their
missions. While in the past, executives have taken a hands-off
approach in dealing with these resources, essentially leaving the
area to the computer technologist, they are now recognizing that
computers and computer-related problems must be understood and
managed, the same as any other resource.
$_The success of an information resources protection
program depends on the policy generated, and on the attitude of
management toward securing information on automated systems.
You, the policy maker, set the tone and the emphasis on how
important a role information security will have within your
agency. Your primary responsibility is to set the information
resource security policy for the organization with the objectives
of reduced risk, compliance with laws and regulations and
assurance of operational continuity, information integrity, and
confidentiality.
$_Purpose of this Guide
This guide is designed to help you, the policy
maker, address a host of questions regarding the protection and
safety of computer systems and data processed within your agency.
It introduces information systems security concerns, outlines the
management issues that must be addressed by agency policies and
programs, and describes essential components of an effective
implementation process.
$_The Risks
The proliferation of personal computers,
local-area networks, and distributed processing has drastically
changed the way we manage and control information resources.
Internal controls and control points that were present in the
past when we were dealing with manual or batch processes have not
always been replaced with comparable controls in many of today's
automated systems. Reliance upon inadequately controlled
information systems can have serious consequences, including:
Inability or impairment of the agency's ability to
perform its mission
Inability to provide needed services to the public
Waste, loss, misuse, or misappropriation of funds
Loss of credibility or embarrassment to an agency
To avoid these consequences, a broad set of
information security issues must be addressed effectively and
comprehensively. Towards this end, executives should take a
traditional risk management approach, recognizing that risks are
taken in the day-to-day management of an organization, and that
there are alternatives to consider in managing these risks. Risk
is accepted as part of doing business or is reduced or eliminated
by modifying operations or by employing control mechanisms.
$_Executive Responsibilities
Set the Security Policy of the Organization
Protecting information resources is an important goal for all
organizations. This goal is met by establishing an
information resource security program. It will require staff,
funding and positive incentives to motivate employees to
participate in a program to protect these valuable assets.
This information resource protection policy should
state precisely:
the value to the agency of data and information
resources and the need to preserve their integrity, availability,
and confidentiality
the intent of the organization to protect the resources
from accidental or deliberate unauthorized disclosure,
modification, or destruction by employing cost-effective controls
the assignment of responsibility for data security
throughout the organization
the requirement to provide computer security and
awareness training to all employees having access to information
resources
the intent to hold employees personally accountable for
information resources entrusted to them
the requirement to monitor and assess data security via
internal and external audit procedures
the penalties for not adhering to the policy
$_Executive Goals
The policy established for securing information
resources should meet the basic goals of reducing the risk,
complying with applicable laws and regulations, and assuring
operational continuity, integrity and confidentiality. This
section briefly describes these objectives and how they can be
met.
$_Reduce Risk To An Acceptable Level
The dollars spent for security measures to control
or contain losses should never be more than the projected dollar
loss if something adverse happened to the information resource.
Cost-effective security results when reduction in risk is
balanced with the cost of implementing safeguards. The greater
the value of information processed, or the more severe the
consequences if something happens to it, the greater the need
for control measures to protect it. It is important that these
trade-offs of cost versus risk reduction be explicitly
considered, and that executives understand the degree of risk
remaining after selected controls are implemented.
$_Assure Operational Continuity
With ever-increasing demands for timely
information and greater volumes of information being processed,
availability of essential systems, networks, and data is a major
protection issue. In some cases, service disruptions of just a
few hours are unacceptable. Agency reliance on essential
computer systems requires that advance planning be done to allow
timely restoration of processing capabilities in the event of
severe service disruption. The impact due to inability to process
data should be assessed, and action taken to assure availability
of those systems considered essential to agency operation.
$_Comply with Applicable Laws and Regulations
As the pervasiveness of computer systems increases
and the risks and vulnerabilities associated with information
systems become better understood, the body of law and regulations
compelling positive action to protect information resources
grows. OMB Circular No. A-130, "Management of Federal Information
systems," and Public Law 100-235, "Computer Security Act of 1987"
are two documents where the knowledge of these laws provide a
baseline for an information resources security program.
$_Assure Integrity and Confidentiality
An important objective of an information resource
management program is to ensure that the information is accurate.
Integrity of information means you can trust the data and the
processes that manipulate it. A system has integrity when it
provides sufficient accuracy and completeness to meet the needs
of the user(s). It should be properly designed to automate all
functional requirements, include appropriate accounting and
integrity controls, and accommodate the full range of potential
conditions that might be encountered in its operation.
Agency information should also be protected from
intruders, as well as from employees with authorized computer
access privileges who attempt to perform unauthorized actions.
Assured confidentiality of sensitive data is
often, but not always, a requirement of agency systems. Privacy
requirements for personal information are generally dictated by
statute, while protection requirements for other agency
information are a function of the nature of that information.
Determination of requirements in the latter case is made by the
official responsible for that information. The impact of
wrongful disclosure should be considered in understanding
confidentiality requirements.
$_Information Protection Program Elements
$_Need for Policies and Procedures
Successful execution of the responsibilities previously outlined
requires establishing agency policies and practices regarding
information protection. The security policy
directive facilitates consistent protection of information
resources. Supporting procedures are most effectively
implemented with top management support, through a program
focused on areas of highest risk. A compliance assessment
process ensures ongoing effectiveness of the information
protection program throughout the agency.
$_Scope
Although the protection of automated information
resources is emphasized in this publication, protection
requirements will usually extend to information on all forms of
media. Agency programs should apply safeguards to all
information requiring protection, regardless of its form or
location. Comprehensive information resource protection
procedures will address: accountability for information,
vulnerability assessment, data access, hardware/software control,
systems development, and operational controls. Protection should
be afforded throughout the life cycle of information, from
creation through ultimate disposition.
Accountability for Information
An effective information resource protection
program identifies the information used by the agency and assigns
primary responsibility for information protection to the managers
of the respective functional areas supported by the data. These
managers know the importance of the data to the organization and
are able to quantify the economic consequences of undesirable
happenings. They are also able to detect deficiencies in data
and know definitively who must have access to the data supporting
their operations. A fundamental information protection issue is
assignment of accountability. Information flows throughout the
organization and can be shared by many individuals. This tends
to blur accountability and disperse decision-making regarding
information protection. Accountability should be explicitly
assigned for determining and monitoring security for appropriate
agency information.
When security violations occur, management must be
accountable for responding and investigating. Security
violations should trigger a re-evaluation of access
authorizations, protection decisions, and control techniques.
All apparent violations should be resolved; since absolute
protection will never be achieved, some losses are inevitable.
It is important, however, that the degree of risk assumed be
commensurate with the sensitivity or importance of the
information resource to be protected.
$_Vulnerability Assessment
A risk assessment program ensures management that
periodic reviews of information resources have considered the
degree of vulnerability to threats causing destruction,
modification, disclosure, and delay of information availability,
in making protection decisions and investments in safeguards.
The official responsible for a specific
information resource determines protection requirements.
Less-sensitive, less-essential information will require minimal
safeguards, while highly sensitive or critical information might
merit strict protective measures. Assessment of vulnerability is
essential in specifying cost-effective safeguards; overprotection
can be needlessly costly and add unacceptable operational
overhead.
Once cost-effective safeguards are selected,
residual risk remains and is accepted by management. Risk status
should be periodically re-examined to identify new threats,
vulnerabilities, or other changes that affect the degree of risk
that management has previously accepted.
$_Data Access
Access to information should be delegated
according to the principles of need-to-know and least possible
privilege. For a multi-user application system, only individuals
with authorized need to view or use data are granted access
authority, and they are allowed only the minimum privileges
needed to carry out their duties. For personal computers with
one operator, data should be protected from unauthorized viewing
or use. It is the individual's responsibility to ensure that the
data is secure.
$_Systems Development
All information systems software should be
developed in a controlled and systematic manner according to
agency standards. Agency policy should require that appropriate
controls for accuracy, security, and availability are identified
during system design, approved by the responsible official, and
implemented. Users who design their own systems, whether on a
personal computer or on a mainframe, must adhere to the systems
development requirements.
Systems should be thoroughly tested according to
accepted standards and moved into a secure production environment
through a controlled process. Adequate documentation should be
considered an integral part of the information system and be
completed before the system can be considered ready for use.
$_Hardware/Software Configuration Control
Protection of hardware and resources of computer
systems and networks greatly contributes to the overall level of
control and protection of information. The information
protection policies should provide substantial direction
concerning the management and control of computer hardware and
software.
Agency information should be protected from the
potentially destructive impact of unauthorized hardware and
software. For example, software "viruses" have been inserted
into computers through games and apparently useful software
acquired via public access bulletin boards; viruses can spread
from system to system before being detected. Also, unauthorized
hardware additions to personal computers can introduce unknown
dial-in access paths. Accurate records of hardware/software
inventory, configurations, and locations should be maintained,
and control mechanisms should provide assurance that unauthorized
changes have not occurred.
To avoid legal liability, no unauthorized copying
of software should be permitted. Agencies should also address
the issue of personal use of Federal computer systems, giving
employees specific direction about allowable use and providing
consistent enforcement.
$_Operational Controls
Agency standards should clearly communicate
minimum expected controls to be present in all computer
facilities, computer operations, input/output handling, network
management, technical support, and user liaison. More stringent
controls would apply to those areas that process very sensitive
or critical information.
Protection of these areas would include:
Security management;
Physical security;
Security of system/application software and data;
Network security; and
Contingency planning.
The final section of this guide describes the
organizational process of developing, implementing, and managing
the ongoing information protection program.
$_Information Protection Program Implementation
$_Information Protection Management
In most cases, agency executive management is not
directly involved in the details of achieving a controlled
information processing environment. Instead, executive action
should focus on effective planning, implementation, and an
ongoing review structure. Usually, an explicit group or
organization is assigned specific responsibility for providing
day-to-day guidance and direction of this process. Within this
group an information security manager (ISM) should be identified
as a permanent focal point for information protection issues
within the agency.
The ISM must be thoroughly familiar with the
agency mission, organization, and operation. The manager should
have sufficient authority to influence the organization and have
access to agency executives when issues require escalation.
$_Independence
In determining the reporting relationship of the
ISM, independence of functional areas within the agency is
desirable. Plans and budget for the ISM function should be
approved by agency management, rather than being part of any
functional area budget. This approach avoids conflicts of
interest and facilitates development and maintenance of a
comprehensive and consistent protection program that serves the
needs of agency management.
Degree of Centralization
The desirability of centralized versus
decentralized security is heavily debated and largely depends on
size, organizational structure, and management approach at the
individual agency. A centralized approach to security has the
advantages of being directly responsive to executive direction
and specifically accountable for progress and status.
A decentralized approach to security has the
advantages of being close to the functional area involved. In
the long term, decentralization may provide better integration of
security with other entity functions.
An effective combined approach offers advantages.
A small dedicated resource at the agency level can direct the
information protection program, while additional resources are
utilized at the functional area level to implement the program in
each area.
$_Dedicated Staff
The common practice of assigning responsibility
for information security to existing staff with other major
responsibilities is often unsuccessful. At least one dedicated
staff member is recommended at the program management level.
The need for additional full-time resources depends on the
agency's computer environment. The number of information
systems, their technical complexity, the degree of
networking, the importance of information processed, adequacy of
existing controls, and extent of agency dependence on information
systems affect the resources needed.
$_Implementation Stages
Development of a comprehensive information
protection program that is practiced and observed widely
throughout a Federal agency occurs in stages and requires ongoing
monitoring and maintenance to remain viable.
First, organizational requirements for information
protection are identified. Different agencies have varying
levels of need for security, and the information protection
program should be structured to most effectively meet those
needs.
Next, organizational policies are developed that
provide a security architecture for agency operations, taking
into consideration the information protection program elements
discussed in the previous section of this guide. The policies
undergo normal review procedures, then are approved by agency
management for implementation.
Activities are then initiated to bring the agency
into compliance with the policies. Depending on the degree of
centralization, this might require development of further plans
and budgets within functional entities of the agency to implement
the necessary logical and physical controls.
$_Training
Training is a major activity in the implementation
process. Security violations are the result of human action, and
problems can usually be identified in their earliest stages by
people. Developing and maintaining personnel awareness of
information security issues can yield large benefits in
prevention and early detection of problems and losses.
Target audiences for this training are executives
and policy makers, program and functional managers, IRM security
and audit personnel, computer management and operations, and end
users. Training can be delivered through existing policy and
procedures manuals, written materials, presentations and classes,
and audio-visual training programs.
The training provided should create an awareness
of risks and the importance of safeguards, underscoring the
specific responsibilities of each of the individuals being
trained.
$_Monitoring and Enforcement
An ongoing monitoring and enforcement program
assures continued effectiveness of information protection
measures. Compliance may be measured in a number of ways,
including audits, management reviews or self-assessments,
surveys, and other informal indicators. A combination of
monitoring mechanisms provides greater reliability of results.
Variances from policy requirements should be
accepted only in cases where the responsible official has
evaluated, documented, and accepted the risk of noncompliance.
Enforcement of agency policies and practices is important to the
overall success of an information protection program.
Inconsistent or lax enforcement quickly results in deterioration
of internal controls over information resources.
A positive benefit of an effective monitoring and
enforcement process is an increased understanding of the degree
of information-related risk in agency operations. Without such a
feedback process, management unknowingly accepts too much risk.
An effective information protection program allows the agency to
continue to rely upon and expand the use of information
technology while maintaining an acceptable level of risk.
$_Maintenance
As agency initiatives and operations change, and
as the computer environment evolves, some elements of the
information protection program will require change as well.
Information protection cannot be viewed as a project with a
distinct end; rather, it is a process that should be maintained
to be realistic and useful to the agency. Procedures for review
and update of policies and other program elements should be
developed and followed.
-JUDGE DREDD/NIA
[OTHER WORLD BBS]
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