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- Executive Guide to the Protection of Information
- Resources
-
- National Institute of Standards and Technology
-
- The National Institute of Standards and Technology (NIST), is
- responsible for developing standards, providing technical
- assistance, and conducting research for computers and related
- telecommunications systems. These activities provide technical
- support to government and industry in the effective, safe, and
- economical use of computers. With the passage of the Computer
- Security Act of 1987 (P.L. 100-235), NIST's activities also
- include the development of standards and guidelines needed to
- assure the cost-effective security and privacy of sensitive
- information in Federal computer systems. This guide is just one
- of three brochures designed for a specific audience. The
- "Managers Guide to the Protection of Information Resources" and
- the "Computer User's Guide to the Protection of Information
- Resources" complete the series.
-
- Acknowledgments
- This guide was written by Cheryl Helsing of Deloitte, Haskins &
- Sells in conjunction with Marianne Swanson and Mary Anne Todd,
- National Institute of Standards and Technology.
-
- Table of Contents
- Introduction 1
- Executive Responsibilities 3
- Executive Goals 5
- Information Protection Program Elements 7
- Information Protection Program Implementation 11
- For Additional Information 15
- Introduction
-
- 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
-
- ystems," 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.
-
- For Additional Information
-
- National Institute Of Standards and Technology
- Computer Security Program Office
- A-216 Technology
- Gaithersburg, MD 20899
- (301) 975-5200
-
- For further information on the management of information
- resources, NIST publishes Federal Information Processing
- Standards Publications (FIBS PUBS). These publications deal with
- many aspects of computer security, including password usage, data
- encryption, ADP risk management and contingency planning, and
- computer system security certification and accreditation. A list
- of current publications is available from:
-
- Standards Processing Coordinator (ADP)
- National Computer Systems Laboratory
- National Institute of Standards and technology
- Technology Building, B-64
- Gaithersburg, MD 20899
- Phone: (301) 975-2817
-