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- This file is a DRAFT chapter intended to be part of the NIST
- Computer Security Handbook. The chapters were prepared by
- different parties and, in some cases, have not been reviewed by
- NIST. The next iteration of a chapter could be SUBSTANTIALLY
- different than the current version. If you wish to provide
- comments on the chapters, please email them to roback@ecf.ncsl.gov
- or mail them to Ed Roback/Room B154, Bldg 225/NIST/Gaithersburg, MD
- 20899.
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- DRAFT DRAFT DRAFT DRAFT
-
-
- Chapter 6: Computer and Information Security Policy
-
-
- 6.1 Introduction to Computer Security Policy
-
- Organizations rely on IT resources today to handle vast amounts of
- information. Because the data can vary widely in type and in
- degree of sensitivity, employees need to be able to exercise
- flexibility in handling and protecting it. It would not be
- practical or cost-effective to require that all data be handled in
- the same manner or be subject to the same protection requirements.
- Without some degree of standardization, however, inconsistencies
- can develop that introduce risks.
-
- Formal IT security policy helps establish standards for IT resource
- protection by assigning program management responsibilities and
- providing basic rules, guidelines, and definitions for everyone in
- the organization. Policy thus helps prevent inconsistencies that
- can introduce risks, and policy serves as a basis for the
- enforcement of more detailed rules and procedures. Ideally, policy
- will be sufficiently clear and comprehensive to be accepted and
- followed throughout the organization yet flexible enough to
- accommodate a wide range of data, activities, and resources.
-
- Policy formulation is an important step toward standardization of
- security activities for IT resources. IT security policy is
- generally formulated from the input of many members of an
- organization, including security officials, line managers, and IT
- resource specialists. However, policy is ultimately approved and
- issued by the organization's senior management. In environments
- where employees feel inundated with policies, directives,
- guidelines and procedures, an IT security policy should be
- introduced in a manner that ensures that management's unqualified
- support is clear. The organization's policy is management's
- vehicle for emphasizing the commitment to IT security and making
- clear the expectations for employee involvement and accountability.
-
- This chapter will discuss IT security policy in terms of the
- different types (program-level and issue-specific), components, and
- aspects of implementation. Potential cost and interdependencies
- will also be noted.
-
-
- 6.2 Policy Types: Program-Level and Issue-Specific
-
- Two types of policy will typically need to be developed to meet an
- organization's needs: program-level and issue-specific. Program-
- level policy's main function is to establish the security program,
- assign program management responsibilities, state the
- organizationwide IT security goals and objectives, and provide a
- basis for enforcement. Issue-specific policies also need to be
- developed, in order to identify and define specific areas of
- concern and to state the organization's position and expectations
- in relation to them. Following are discussions on these two basic
- types of policy.
-
-
- 6.2.1 Program-level Policy
-
- As discussed above, program-level policy is broad in scope and far-
- reaching in applicability. To make the subject more manageable, an
- effective approach to a discussion of program-level IT security
- policy is to break general policy into its basic components:
- purpose, scope, goals, responsibilities, and enforcement.
-
-
- 6.2.1.1 Components of Program-level Policy
-
- Purpose: A primary purpose of program-level policy is to establish
- the IT security program. This includes defining the program
- management structure, the reporting responsibilities, the roles of
- individuals and groups throughout the organization, and the
- organizationwide goals of the security program. (Chapter 5
- provides a detailed discussion of security program management and
- administration.)
-
- Additionally, program-level policy should serve the purpose of
- emphasizing to all employees the importance of IT security and
- clarifying the individual employee's role and responsibilities. IT
- security policy may be met with a degree of skepticism unless given
- appropriate visibility and support by top management, and that
- visibility and support should be clearly and energetically
- reflected in the program-level policy and in its emphasis on
- employee participation.
-
- The program-level policy should thus firmly establish individual
- employee accountability. Employees should be made aware via the
- policy that even if they are not designated IT security program
- personnel, they nonetheless have significant IT security
- responsibilities.
-
- Scope: Program-level policy should be of sufficient breadth of
- scope to include all of the organization's IT resources, including
- facilities, hardware, software, information, and personnel. In
- some instances, it may be appropriate for a policy to name specific
- assets, such as major sites, installations, and large systems. In
- addition to such specified assets, it is important to include an
- overview of all of the types of IT resources for which the
- organization is responsible, such as workstations, Local Area
- Networks (LANs), standalone microcomputers, etc.
-
- Goals: According to the National Research Council's Computers at
- Risk, published in 1991, the three security-related needs
- universally most emphasized among IT resource experts and the
- general computer user community are integrity, availability, and
- confidentiality. These concepts are the focus of many discussions
- in this handbook as well. These concepts should be the basis of
- the goals established for an organization in its IT security
- policy. Integrity means assuring that information is kept intact,
- and not lost, damaged, or modified in an authorized manner.
- Availability means assuring that information is accessible to
- authorized users when needed and that, to the extent possible, IT
- systems are safe from accidental or intentional disablement.
- Confidentiality means assuring that information is accessible only
- as authorized and that it cannot be acquired by unauthorized
- personnel and/or via unauthorized means.
-
- Goals related to these concepts should be stated in meaningful ways
- to employees based on the given environment. It is important that
- the organization's program-level policy reflect goals that are
- applicable to the specific environment by targeting the kinds of
- activities, information, and terminology that employees are
- familiar with.
-
- For instance, in an organization responsible for maintaining large
- but not highly confidential databases, goals related to reduction
- in errors, data loss, or data corruption might be specifically
- stressed. In an organization responsible for maintaining much more
- confidential data, however, goals might emphasize increased
- assurance against unauthorized disclosure.
-
- Responsibilities: As noted in the earlier discussion of Purpose,
- program-level policy performs the important function of
- establishing the IT security program and assigning program
- management responsibilities. In addition to the security program
- management responsibilities, many other responsibilities throughout
- the organization should also be discussed in the policy, including
- the role of line managers, applications owners, data users, and the
- computer systems security group.
-
- In some instances, the relationships among various individuals and
- groups may also need to be defined in the program-level policy.
- Such clarification can diminish ambiguity and confusion related to
- areas of responsibility or authority. It might be desirable to
- clarify, for example, who is to be responsible for approving the
- security measures to be used for new systems or components being
- installed: Should it be the department line manager where the item
- will be installed? Or should it be a designated inter-departmental
- IT security specialist? It might even be desirable to indicate
- under what circumstances, if any, approval of security measures
- implemented would be warranted by the head of the security program.
-
- Overall, the program-level assignment of responsibilities should
- cover those activities and personnel who will be integral to the
- implementation and continuity of the IT security policy.
-
- Enforcement: Without a formal, documented IT security policy, it
- is not possible for management to proceed with the development of
- enforcement standards and mechanisms. Program-level policy serves
- as the basis for enforcement by describing penalties and
- disciplinary actions that can result from failure to comply with
- the organization's IT security requirements. Discipline
- commensurate with levels and types of security infractions should
- be discussed. For example, serious offenses, such as theft,
- conspiracy, or intentional acts of sabotage, might be designated by
- policy as punishable by firing and prosecution. Lesser
- infractions, such as pirating software, might be stated as
- punishable by formal written reprimand.
-
- Consideration should also be given to the fact that nonconformance
- to policy can be unintentional on the part of employees. For
- example, nonconformance can often be due to a lack of knowledge or
- training. It can also be the result of inadequate communication
- and explanation of the policy. For these reasons, it is desirable
- that, along with enforcement, program-level policy make provisions
- for orientation, training, and compliance within a realistic
- timeframe.
-
-
- 6.2.2 Issue-specific Policy
-
- Whereas program-level policy is intended to address the broadest
- aspects of IT security and the IT security program framework,
- issue-specific policies need to be developed to address particular
- kinds of activities and, in some environments, particular systems.
- The types of subjects covered by issue-specific policies are areas
- of current relevance, concern, and, sometimes, controversy upon
- which the organization needs to assert a position. In this manner,
- issue-specific IT security policies help to standardize activities
- and reduce the potential risks posed by inadequate and/or
- inappropriate treatment of the IT resources. Issue-specific
- policies serve to provide guidelines for the further development of
- procedures and practices within the functional elements of an
- organization.
-
- Program-level policy is usually broad enough that it does not
- require much modification over time. Issue-specific policies,
- however, are likely to require revision and updating from time to
- time, as changes in technology and related activities take place.
- This is largely because as new technologies develop, some issues
- diminish in importance while new ones continually appear. A major
- challenge to IT security specialists has long been the fact that
- for every new technology there are also new associated problems and
- issues to be addressed.
-
- For example, the enormous increase in the use of electronic mail
- (E-mail) systems in recent years has introduced many new issues in
- communications security, which is one of the topics that will be
- briefly discussed later in this section. Many organizations today
- are developing and refining communications security policies in
- order to better address such questions as who should have E-mail
- access, how will privileges be assigned and monitored, for what
- types of activities and information is E-mail sufficiently secure,
- and what criteria should be used for the re-sending (forwarding) of
- messages among users.
-
- Another topic of recent notoriety impacting IT security policies is
- the threat posed by computer viruses. New viruses and new methods
- of transmitting them are making it necessary that organizations
- develop policies regulating activities that were once performed
- freely, such as exchanging floppy disks among users, accessing
- electronic bulletinboards, and using shareware products.
-
- As for the discussion of program-level policy, a useful approach is
- to first break issue-specific policy into its basic components:
- statement of an issue, statement of the organization's position,
- applicability, roles and responsibilities, and points of contact.
- Thereafter, some of the areas that often require issue-specific
- policies will be covered.
-
-
- 6.2.2.1 Components of Issue-specific Policy
-
- Statement of an Issue: In order to formulate a policy on an issue,
- the issue must first be defined, with any relevant terms,
- distinctions, and conditions delineated. For example, an
- organization might want to develop an issue-specific policy on the
- use of "foreign software." "Foreign software" might be defined to
- mean any software, whether applications or data, not approved,
- purchased, screened, managed, and owned by the organization.
- Additionally, the applicable distinctions and conditions might then
- need to be included, for instance, for software privately owned by
- employees but approved for use at work and for software owned and
- used by other businesses under contract to the organization.
-
- Statement of the Organization's Position: Once the issue is stated
- and related terms and conditions delineated, the organization's
- position or stance on the issue will need to be clearly stated. To
- continue the example of developing an issue-specific policy on the
- use of foreign software, this would mean stating whether use of
- foreign software as defined is strictly prohibited, whether or not
- there are further guidelines for approval and use, or whether case-
- by-case decisions will be rendered based on some defined criteria.
-
- Applicability: Issue-specific policies will also need to include
- statements of applicability. This means clarifying where, how,
- when, to whom, and to what a particular policy applies. For
- example, it could be that the hypothetical policy on foreign
- software is intended to apply only to the organization's own onsite
- resources and employees and is not to be applicable to contractor
- organizations with offices at other locations. Additionally, the
- policy's applicability to employees travelling among different
- sites and/or working at home who need to transport and use disks at
- multiple sites might need to be clarified.
-
- Roles and Responsibilities: Also included in issue-specific
- policies should be the assignment of roles and responsibilities.
- This would mean, to continue with the above example, that if the
- policy permits foreign software privately owned by employees to be
- used at work with the appropriate approvals, then the approval
- authority granting such permission would need to be stated.
- Likewise, it would need to be clarified who would be responsible
- for ensuring that only approved foreign software is used on
- organizational IT resources and, perhaps, for monitoring users in
- regard to foreign software.
-
- Related to the assignment of roles and responsibilities is the
- inclusion of guidelines for procedures and enforcement. The issue-
- specific policy on foreign-software, for example, might include
- procedural guidelines for checking disks used by employees at home
- or at other locations. It might also state what the penalties
- would be for using unapproved foreign software on the
- organization's IT systems.
-
- Points of Contact: For any issue-specific policy, the appropriate
- individuals in the organization to contact for further information,
- guidance, and enforcement should be indicated. For example, for
- some issues the point of contact might be a line manager; for other
- issues it might be a facility manager, technical support person, or
- system administrator. For yet other issues, the point-of-contact
- might be a security program representative. Using the above
- example once more, employees would need to know whether the point
- of contact for questions and procedural information would be
- his/her immediate superior, a system administrator, or a computer
- security official.
-
-
- 6.2.2.2 Areas Appropriate for Issue-specific Policies
-
- Some of the areas in which management today needs to consider
- issue-specific IT security policies are covered in this section.
- These topics are intended to provide examples and serve as sources
- for ideas and analysis. Although many of these topics are standard
- to any discussion of IT security, an organization would necessarily
- need to tailor its policies relating to them to meet its own unique
- needs.
-
- Physical security: The physical protection of and access to IT
- resources and facilities will generally need to be addressed in one
- or more specific policies. In organizations with extensive IT
- systems and equipment, this may mean developing policies that
- address such issues as who has access to what sites/locations; how
- often risks to installations are be analyzed and by whom; what
- types of physical access controls and monitoring equipment are put
- in place; what responsibilities will be assigned to trained
- security officials and what activities and responsibilities will be
- required of all employees.
-
- Personnel Security: Depending on the types of activities being
- performed, degree of data sensitivity to be encountered, and sheer
- numbers of personnel, specific security policies related to
- personnel screening, requirements, hiring, training, evaluating,
- and firing may need to be developed and administered. It may be
- appropriate that a trained personnel security specialist initiate,
- review, approve, and perform all security-related personnel
- actions.
-
- Communications Security: Communications security is a complex
- technical specialty unto itself. In organizations where day-to-day
- business relies on communicating routinely with remote locations,
- the security of the communications transmissions and lines is
- usually an issue that needs to be addressed by policy. If the data
- being transmitted is highly sensitive, then this concern is
- magnified, and issue-specific security policies may need to be
- developed on a number of activities. Issues associated with the
- use of cryptography and its related options and procedures
- (discussed in Chapter 19), the use of modems and dial-in lines, and
- precautions against wiretapping are just some of the potential
- issues to be addressed. Additionally, as noted earlier, the
- proliferation of E-mail has introduced many security- and privacy-
- related issues for which organizations need to document positions
- and policies.
-
- Administrative Security: Administrative security as it applies to
- IT system management and oversight activities comprises many
- potential security policy issues. Included are such topics as
- input/output controls, training and awareness, security
- certification/accreditation, incident reporting, system
- configurations and change controls, and system documentation.
-
- Risk Management: Risk management involves assessing IT resources
- in terms of potential threats and vulnerabilities and planning the
- means for counteracting those identified risks. Issues that will
- need to be addressed by policies include how, by whom, and when the
- assessments should be performed; and what type of documentation
- should result.
-
- Contingency Planning: Related to Risk Management, Contingency
- Planning means planning for the emergency actions to be taken in
- the event of damage, failure, and/or other disabling events that
- could occur to systems. Issues that need to be addressed by
- policies include determining which systems are most critical and
- therefore of highest priority in contingency planning; how the
- plans will be tested, how often, and by whom; and who will be
- responsible for approving the plans.
-
-
- 6.3 Policy Implementation
-
- Policy implementation is a process. Policy cannot merely be
- pronounced by upper management in a one-time statement or directive
- with high expectations of its being readily accepted and acted
- upon. Rather, just as formulating and drafting policy involves a
- process, implementation similarly involves a process, which begins
- with the formal issuance of policy.
-
-
- 6.3.1 Policy Visibility
-
- Especially high visibility should be afforded the formal issuance
- of IT security policy. This is due to a combination of factors,
- including the following:
-
- * Nearly all employees at all levels will in some way be affected;
- * Major organizational resources are being addressed;
- * Many new terms, procedures, and activities will be introduced.
-
- Providing visibility through such avenues as management
- presentations, panel discussions, guest speakers, question/answer
- forums, and newsletters can be beneficial, as resources permit.
- Including IT security as a regular topic at staff meetings at all
- levels of the organization can also be a helpful tactic.
-
- As an aspect of providing visibility for IT security policies,
- information should also be included regarding the applicable higher
- level directives and requirements to which the organization is
- responding. Educating employees as to the requirements specified
- by the Computer Security Act and related OMB circulars will help
- emphasize the significance and timeliness of computer security, and
-
- it will help provide a rational basis for the introduction of IT
- security policies.
-
-
- 6.3.2 Policy Documentation
-
- Once IT security policy has been approved and issued, it may be
- initially publicized through memorandums, presentations, staff
- meetings, or a variety of means. As soon as possible, though, it
- will also need to be incorporated into formal policy documentation
- as well. The process of documenting policies will usually require
- updating existing documentation as well as creating new
- documentation.
-
- Existing Documentation: IT security will need to be integrated
- into many existing activities and practices throughout many levels
- of the organization. This integration will be facilitated by
- revising any existing applicable documentation to reflect new
- procedures, rules, and requirements. Included may be the
- modification of various existing documents, forms, and plans at all
- levels of the organization to reflect the IT policy.
-
- For example, if IT equipment purchases and/or upgrades have been
- reviewed and approved based on documented criteria such as cost,
- productivity, maintainability, etc., then security considerations
- may need to be introduced into that criteria. Also, if it has
- previously been the documented policy to review the progress and
- status of internal IT systems under development, then security-
- related concerns should be introduced into that review process.
-
- New Documentation: Additionally, the development of many new
- documents, such as guidelines, standards, and procedures, may be
- required. This is often true in large organizations performing
- many different activities and having many levels of management. In
- such environments, different functional elements may have widely
- differing IT systems and needs to accommodate. It is therefore
- generally more practical, to the extent possible, to allow elements
- to tailor their implementations of policy to meet their unique
- needs. This can be accomplished through the development of
- documents containing more detailed procedures and practices to be
- used for specific kinds of systems and activities within
- functional elements.
-
- For example, organizations will want to issue policies to decrease
- the likelihood of data loss due to technology failures and/or
- operator errors. A program-level policy might state something to
- the effect that: "It is the policy of the organization to ensure
- against data loss due to accidents or mishaps." In an area where
- extensive writing and editing of lengthy documents is performed,
- such as a word processing or technical publications unit, security
- documentation might be developed on saving work in-progress much
- more often than would usually be done, and/or utilizing automatic
- "save" features on IT systems and software. In a different type
- of functional area, however, where, for example, databases are
- maintained that do not undergo significant changes very often, the
- security documentation might focus on procedures for the database
- administrator to use in performing periodic (daily, weekly, etc.)
- backups of the system.
-
- Appropriate visibility should be afforded the IT security policy
- through all applicable documentation. The more integral security
- policy is to all other aspects of daily routines, the more quickly
- the associated actions and practices will become natural to doing
- business. Ultimately, among the goals of policy are the
- assimilation of a common body of knowledge and values and the
- demonstration of appropriate corresponding behaviors. Those goals
- will be expedited by making the IT security policy integral to the
- organization through all avenues.
-
-
- 6.4 Cost Considerations
-
- There are a number of potential costs associated with developing
- and implementing IT security policies. In some environments, the
- major costs may be those incurred through the numerous
- administrative and management activities required for drafting,
- reviewing, disseminating, and publicizing the policies. In some
- organizations, though, successful policy implementation may require
- additional staffing, training, and equipment. In general, how
- costly IT security policy development and implementation are to an
- organization will depend upon how much change needs to be
- accomplished in order to ensure adequate security and a basic
- standardization throughout the organization.
-
-
- 6.5 Interrelationships
-
- IT security policy can be related to nearly every topic covered in
- this handbook on some level. This is because all of the topics
- discussed in the handbook have associated issues that organizations
- may need to address via policies. The topics most directly
- related, however, are: IT security program management and
- administration; risk management; personnel; security training and
- awareness; contingency planning; and physical and environmental
- security.
-
-
- 6.6 Conclusion
-
- Formulating viable IT security policies is a challenge for an
- organization and requires communication and understanding of the
- organizational goals and potential benefits to be derived from
- policies. Through a carefully structured approach to policy
- development, which includes the delegation of program management
- responsibility and an understanding of both program-level and
- issue-specific policy components, a coherent set of policies -
- integrated into sensible practices and procedures - can be
- developed
- 6.1, para 2: IT security policy helps to provide basic standards,
- guidelines, and rules for everyone in an organization.
-
- 6.2, para 1: Program-level IT security policy establishes the
- security program and assigns program management responsibilities.
-
- 6.2.1.1, para 4: Program-level policy should be sufficiently broad
- in scope to include all of the organization's IT resources.
-
- 6.2.1.1, para 5: Program-level IT security policy goals should
- stress the universal concepts of integrity, availability, and
- confidentiality.
-
- 6.2.2, para 1: Issue-specific policies address particular
- activities, concerns, and, sometimes, systems.
-
- 6.2.2, para 4: New products, developments, and trends often
- require the creation of corresponding issue-specific policies.
-
- 6.2.2.2, para 1: Many activities within an organization should be
- considered when developing issue-specific policies, including
- physical security, personnel, communications, administrative
- security, risk management, and contingency planning.
-
- 6.3.1, para 1: IT security policy should be given especially high
- visibility in order to help ensure employee awareness and
- understanding.
-
- 6.3.2, para 4: Many existing documents of an organization will
- need to be revised to reflect IT security policies, and new
- documents may also need to be developed.
-
-
-
-
-