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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:
-
- o Inability or impairment of the agency's ability to
- perform its mission
-
- o Inability to provide needed services to the public
-
- o Waste, loss, misuse, or misappropriation of funds
-
- o 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:
-
- o the value to the agency of data and information
- resources and the need to preserve their integrity, availability,
- and confidentiality
-
- o the intent of the organization to protect the resources
- from accidental or deliberate unauthorized disclosure,
- modification, or destruction by employing cost-effective controls
-
- o the assignment of responsibility for data security
- throughout the organization
-
- o the requirement to provide computer security and
- awareness training to all employees having access to information
- resources
-
- o the intent to hold employees personally accountable for
- information resources entrusted to them
-
- o the requirement to monitor and assess data security via
- internal and external audit procedures
-
- o 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:
-
- o Security management
- o Physical security
- o Security of system/application software and data
- o Network security
- o 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
- (FIPS 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
-
-
-