oversight

Executive Guide: Information Security Management: Learning From Leading Organizations (Exposure Draft) (Superseded by AIMD-98-68)(Superseded by AIMD-00-21.2.8)

Published by the Government Accountability Office on 1997-11-01.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                    United States General Accounting Office

GAO                 Accounting and Information
                    Management Division



November 1997-v**
                    Executive Guide
                    N



                    Information Security
                    Management
                    Learning From Leading
                    Organizations




                    Exposure Draft


GAO/ALDM-98-21

                           0X600 Y3 /\5 cl toY6
                                                 Preface



           The dramatic increase in computer interconnectivity and the popularity of the
           Internet are offering government agencies, businesses, educational institutions,
           and others unprecedented opportunities to improve operations by reducing
           paper processing, cutting costs, and sharing information. Many organizations
           are using their systems now to instantly provide information to, and
           communicate with, the communities they serve. At the same time, they are
           exploring innovative ways to expand their use of electronic data and
           telecommunications to take further advantage of the increasingly networked
           computer environment.

           However, the ultimate success of many of these efforts depends on an
           organization's ability to protect the integrity, privacy, and availability of the
           data and systems it relies on. As organizations increase their reliance on
           electronic information, they must have assurance that the information they use
           has not been inappropriately altered and that its confidentiality is appropriately
           protected. Further, the information must be readily available with few
           disruptions in the operation of supporting computer and telecommunications
           systems. Without these assurances, organizations expose themselves to risks
           from fraud, sabotage, and other malicious acts; user errors; natural disasters;
           and other events that may result in a loss of assets, disclosure of sensitive
           data, inability to carry out critical operations, or incidents leading to a loss of
           customer or taxpayer confidence.

           Deficiencies in federal information security are receiving increasing attention,
           in part due to our government's growing reliance on automated systems and
           electronic data. Audit reports are identifying serious information security
           deficiencies at a growing number of agencies, and, in February 1997, in a series
           of reports to the Congress, GAO designated information security as a new
           governmentwide high-risk area. Most recently, the President's Commission on
           Critical Infrastructure Protection described the potentially devastating
           implications of poor information security in its October 1997 report entitled
           Critical Foundations: Protecting America's Infrastructures.

           Although many factors contribute to information security deficiencies at
           federal agencies, GAO and inspector general audits have found that an
           underlying cause is that senior agency officials have not established a
           management framework for exploring and reducing the information security
           risks associated with their operations. To assist federal agencies in
           establishing such a framework, Senators Fred Thompson and John Glenn,
           Chairman and Ranking Minority Member, respectively, of the Senate

GAO/AIMD-98-21 Information Security Management                                     Page 1
         Committee on Governmental Affairs, requested that we study organizations
         with reputations for having superior security programs to identify practices
         that could be adopted successfully by federal agencies.

         The results of this study are outlined in this exposure draft, which we expect
         to issue as an executive guide in early 1998. This guide is one of a series of
         GAO efforts intended to more specifically define the actions federal officials
         can take to better manage the information resources upon which our nation is
         increasingly reliant. Other guides developed by GAO are listed in appendix I.

         This guide was prepared under the direction of Jack Brock, Director,
         Information Resources Management-General Government Issues. You may
         submit comments before December 31, 1997, by phone, email, or regular mail
         to Jean Boltz at the following:

         Phone:    (202) 512-5247

         Email:    boltzj.aimd@gao.gov

         Mail:     Jean Boltz, AIMD
                   U.S. General Accounting Office
                   Room 4T21
                   441 G Street, NW
                   Washington, D.C. 20548




            e L. Dodaro
         Assistant Comptroller General
         Accounting and Information Management Division




Page 2                                       GAO/AIMD-98-21 Information Security Management
           Contents
           Federal Information Security Is A Growing Concern                                      5

           Leading Organizations Apply Fundamental Risk                                          14
           Management Principles

           Assess Risk and Determine Needs                                                       20

               Practice 1:   Recognize Information Resources as Essential                        21
                             Organizational Assets That Must Be Protected
               Practice 2:   Develop Practical Risk Assessment Procedures That Link              23
                             Security to Business Needs
               Practice 3:   Hold Program or Business Managers Accountable                       26
                             Case Example: A Practical Method for Involving Business             27
                                             Managers in Risk Assessment
               Practice 4:   Manage Risk on a Continuing Basis                                   28

               Getting Started-Assessing Risk and Determining Needs                              30

           Establish A Central Management Focal Point                                            31

               Case Example: Transforming an Organization's Central                              32
                              Security Focal Point
               Practice 5: Designate A Central Group to Carry Out Key Activities                 33
               Practice 6: Provide the Central Group Ready and Independent Access to             35
                           Senior Executives
               Practice 7: Designate Dedicated Funding and Staff                                 36
               Practice 8: Enhance Staff Professionalism and Technical Skills                    38

               Getting Started-Establishing A Central Focal Point                                41

           Implement Appropriate Policies and Related Controls                                   42

               Practice 9: Link Policies to Business Risks                                       43
               Practice 10: Distinguish Between Policies and Guidelines                          45
               Practice 11: Support Policies Through the Central Security Group                  47

               Getting Started-Implementing Appropriate Policies and Related Controls            48




GAO/AIMD-98-21 Information Security Management                                          Page 3
         Promote Awareness                                                                    49

            Practice 12: Continually Educate Users and Others on Risks                        50
                         and Related Policies
            Practice 13: Use Attention-Getting and User-Friendly Techniques                   51
                         Case Example: Coordinating Policy Development and                    52
                                        Awareness Activities

            Getting Started-Promoting Awareness                                               52

         Monitor and Evaluate Policy and Control Effectiveness                               53

            Practice 14: Monitor Factors that Affect Risk and Indicate                        54
                         Security Effectiveness
                         Case Example: Developing an Incident Database                        56
            Practice 15: Use Results to Direct Future Efforts and Hold Managers               58
                         Accountable
                         Case Example: Measuring Control Effectiveness and                    59
                                         Management Awareness
            Practice 16: Be Alert to New Monitoring Tools and Techniques                      60

            Getting Started-Monitoring and Evaluating Policy and Control Effectiveness        61

         Conclusion                                                                          62

         Appendix I - GAO Guides on Information Technology Management                        63

         Appendix II - NIST's Generally Accepted Principles and Practices                    64
         for Securing Information Technology Systems

         Appendix III - Major Contributors to This Executive Guide                           65

         GAO Reports and Testimonies on Information Security                                 66


         Abbreviations

         CEO              Chief Executive Officer
         CERT             Computer Emergency Response Team
         CIO              Chief Information Officer
         CISSP            Certified Information Systems Security Professional
         GAO              General Accounting Office
         NIST             National Institute of Standards and Technology
         OMB              Office of Management and Budget




Page 4                                             GAO/AIMD-98-21 Information Security Management
  Federal Information Security Is
  A Growing Concern



Electronic information and automated systems are essential to virtually all major federal
operations. If agencies cannot protect the availability, integrity, and, in some cases, the
confidentiality, of this information, their ability to carry out their missions will be severely
impaired. However, despite the enormous dependence on electronic information and
systems, audits continue to disclose serious information security weaknesses. As a result,
billions of dollars in federal assets are at risk of loss, vast amounts of sensitive data are
at risk of inappropriate disclosure, and critical computer-based operations are vulnerable
to serious disruptions.

Most senior federal executives, like many of their private sector counterparts, are just
beginning to recognize the significance of these risks and to fully appreciate the
importance of protecting their information resources. In some cases, this awareness has
been prompted by disturbing break-ins and damage to agency systems that have
illustrated the vulnerability of operations supported by these resources. Some of these
events are pranks that result in little or no lasting damage, such as placing graffiti on
agency Internet web pages. However, because controls and incident reporting procedures
are weak, other losses or inappropriate disclosures of sensitive information could be
occurring without detection, and the risk of significant losses is high. It is important that
senior agency executives, chief information officers, and agency program managers
recognize these risks and take steps to mitigate them.

This guide is designed to promote senior executives' awareness of information security
issues and to provide information they can use to establish a management framework for
more effective information security programs. The opening segments describe the
problem of weak information security at federal agencies, identify existing federal
guidance, and describe the issue of information security management in the context of
other information technology management issues. The remainder of the guide describes
 16 practices, organized under 5 management principles, that GAO identified during a
study of nonfederal organizations with reputations for having good information security
programs. Each of these practices contains specific examples of the techniques used by
these organizations to increase their security program's effectiveness.




GAO/AIMD-98-21 Information Security Management                                       Page 5
Potential Risks Are Significant

         Although they have relied on computers for years, federalagencies, like
         businesses and other organizations throughout the world, are experiencing an
         explosion in the use of electronic data and networked computer systems. As a
         result, agencies have become enormously dependent on these systems and data
         to support their operations.

         The Department of Defense, alone, has a vast information infrastructure that
         includes 2.1 million computers and over 10,000 networks that are used to
         exchange electronic messages, obtain data from remote computer sites, and
         maintain critical records. Civilian agencies also are increasingly reliant on
         automated, often interconnected, systems, including the Internet, to support
         their operations. For example,

         * law enforcement officials throughout the United States and Canada rely on
           the Federal Bureau of Investigation's National Crime Information Center
           computerized database for access to sensitive criminal justice records on
           individual offenders;
         * the Internal Revenue Service relies on computers to process and store
           hundreds of millions of confidential taxpayer records;
         * the Customs Service relies on automated systems to support its processing
           and inspection of hundreds of billions of dollars worth of goods imported
           into the United States; and
         * many federal agencies, such as the Social Security Administration, the
           Department of Agriculture, and the Department of Health and Human
           Services, rely on automated systems to manage and distribute hundreds of
           billions of dollars worth of payments to individuals and businesses, such as
           medicare, social security, and food stamp benefits.

         Although these advances promise to streamline federal operations and improve
         the delivery of federal services, they also expose these activities to greater
         risks. This is because automated systems and records are fast replacing
         manual procedures and paper documents, which in many cases are no longer
         available as "backup" if automated systems should fail.

         This risk is exacerbated because, when systems are interconnected to form
         networks or are accessible through public telecommunication systems, they are
         much more vulnerable to anonymous intrusions from remote locations.
         Additionally, much of the information maintained by federal agencies, although
         unclassified, is extremely sensitive, and many automated operations are
         attractive targets for individuals or organizations with malicious intentions,
         such as committing fraud for personal gain or sabotaging federal operations.
         Several agencies have experienced intrusions into their systems, and there are

Page 6                                       GAO/AIMD-98-21 Information Security Management
           indications, such as tests at the Department of Defense, that the number of
           attacks is growing and that many attacks are not detected.



                                              Information Security Risks



                                                                    -.Threats       :
                             Attempts to
                            Access Private          .                                                 Sabotage
                              Information
                                                         Malicious                Natural
                                                          \\.Acts        |        Disaster


                                                                                                                    User
                         .Fraud                          \Pr-\                anksA'                                Error




                                                        Systems Supporting
                                                         Federal Operations



                      eJ Taxpayer%    i^ :,   ^^.       - ^ i ..;       -.-                  \        . SJ      Integntyof
                                       Confidence                                                             ~~~~~~~~~~~~~~~~~~FederlDt
                                                                                                                & Reports


                                                          Dat
                                                            s ,ve t S          Services &
                                                         Dataose                 Benef its
                           Critcal                       icoe                  Interrupe
                         Operations
                           Haltedet 9 An                                                         ,;     ~~~~~~~~~~~~~~Assets
                                                                                                                      ,
                                                                                                             Lost

                                                           Potential Damage




GAO/AIMD-98-21 Information Security Management                                                                              Page 7
Weaknesses Abound, But Management
Attention Has Been Lacking
         "Just as in the private sector, many federal agencies are reluctant to make
         the investments required in this area [of computer security] because of
         limited budgets, lack of direction and prioritization from senior officials,
         and general ignorance of the threat."
                                           - Statement of Gary R. Bachula, Acting Under Secretary for
                                           Technology, Department of Commerce, before House
                                           Science Subcommittee on Technology, June 19, 1997

         Unfortunately, federal agencies are not adequately protecting their systems and
         data. In September 1996, we reported that audit reports and agency self-
         assessments issued during the previous 2 years showed that weak information
         security was a widespread problem.' Specifically, weaknesses such as poor
         controls over access to data and inadequate disaster recovery plans increased
         the risk of losses, inappropriate disclosures, and disruptions inmservice
         associated with the enormous amounts of electronically maintained
         information essential for delivering federal services and assessing the success
         of federal programs. Due to these previously reported weaknesses and
         findings resulting from our ongoing work, in February 1997, we designated
         information security as a new governmentwide high-risk issue.2

         In our September 1996 report, we stated that an underlying cause of federal
         information security weaknesses was that agencies had not implemented
         information security programs that (1) established appropriate policies and
         controls and (2) routinely monitored their effectiveness. Despite repeated
         reports of serious problems, senior agency officials had not provided the
         management attention needed to ensure that their information security
         programs were effective.

         Also, in that report, we made a number of recommendations intended to
         improve the Office of Management and Budget's (OMB) oversight of agency
         information security practices and strengthen its leadership role in this area.
         Specifically, we recommended that OMB promote the federal Chief Information
         Officers Council's adoption of information security as one of its top priorities
         and encourage the council to develop a strategic plan for increasing awareness
         of the importance of information security, especially among senior agency
         executives, and improving information security program management


         lInformation Security: Opportunities for Improved OMB Oversight of Agency Practices
         (GAO/AIMD-96-1 10, September 24, 1996).

         2 High-Risk Series: Information Management and Technology (GAO/HR-97-9, February 1997).

Page 8                                             GAO/AIMD-98-21 Information Security Management
           governmentwide. Initiatives that we suggested for the CIO Council to consider
           incorporating in its strategic plan included
               (1) developing information on the existing security risks associated with
                   nonclassified systems currently in use,
               (2) developing information on the risks associated with evolving practices,
                   such as Internet use,
              (3) identifying best practices regarding information security programs so
                   that they can be adopted by federal agencies,
              (4) establishing a program for reviewing the adequacy of individual agency
                   information security programs using interagency teams of reviewers,
              (5) ensuring adequate review coverage of agency information security
                   practices by considering the scope of various types of audits and
                   reviews performed and acting to address any identified gaps in
                   coverage,
              (6) developing or identifying training and certification programs that could
                   be shared among agencies, and
              (7) identifying proven security tools and techniques.

           Although there is much that OMB can do in this area, we recognize that
           information security is primarily the responsibility of individual agencies. This
           is because agency managers are in the best position to assess the risks
           associated with their programs and to develop and implement appropriate
           policies and controls to mitigate these risks. Accordingly, in our reports over
           the last several years, we have made dozens of specific recommendations to
           individual agencies. Although many of these recommendations have been
           implemented, similar weaknesses continue to surface because agencies have
           not implemented a management framework for overseeing information security
           on an agencywide and ongoing basis. A list of our previous reports on
           information security is provided at the end of this guide.


Requirements Are Outlined in Laws and Guidance

           The need for federal agencies to protect sensitive and critical, but unclassified,
           federal data has been recognized for years in various laws, including the
           Privacy Act of 1974, the Paperwork Reduction Act of 1995, and the Computer
           Security Act of 1987. Further, since enactment of the original Paperwork
           Reduction Act in 1980, OMB has been responsible for developing information
           security guidance and overseeing agency practices, and the Computer Security
           Act assigns the National Institute of Standards and Technology (NIST) primary
           responsibility for developing technical standards and providing related
           guidance. OMB, NIST, and agency responsibilities regarding information
           security were recently reemphasized in the Clinger-Cohen Act of 1996, formerly
           named the Information Technology Management Reform Act of 1996.

GAO/AIMD-98-21 Information Security Management                                    Page 9
          The adequacy of controls over computerized data is also addressed indirectly
          by the Federal Managers' Financial Integrity Act of 1982 and the Chief
          Financial Officers Act of 1990. The Federal Managers' Financial Integrity Act
          requires agency managers to annually evaluate their internal control systems
          and report to the President and the Congress any material weaknesses that
          could lead to fraud, waste, and abuse in government operations. The Chief
          Financial Officers Act requires agencies to develop and maintain financial
          management systems that provide complete, reliable, consistent, and timely
          information.

          In addition, a considerable body of federal guidance on information security
          has been developed. OMB has provided guidance since 1985 in its Circular A-
          130, Appendix III, "Security of Federal Automated Information Resources,"
          which was updated in February 1996. Further, NIST has issued numerous
          Federal Information Processing Standards, as well as a comprehensive
          description of basic concepts and techniques entitled An Introduction to
          Computer Security: The NIST Handbook, Special Publication 800-12, December
          1995, and "Generally Accepted Principles and Practices for Securing
          Information Technology Systems,"3 published in September 1996.

          Additional federal requirements have been established for the protection of
          information that has been classified for national security purposes. However,
          these requirements are not discussed here because this guide pertains to the
          protection of sensitive but unclassified data, which comprise the bulk of data
          supporting most federal operations.


Exploring Practices of Leading Organizations

          To supplement our ongoing audit work at federal agencies and gain a broader
          understanding of how information security programs can be successfully
          implemented, we studied the management practices of eight nonfederal
          organizations recognized as having strong information security programs. The
          specific objective of our review was to determine how such organizations have
          designed and implemented their programs in order to identify practices that
          could be applied at federal agencies.

          We focused primarily on the management framework that these organizations
          had established rather than on the specific controls that they had chosen,
          because previous audit work had identified security management as an


          3Appendix II lists the principles identified in NIST's Generally Accepted Principles and
          Practices for Securing Information Technology Systems, September 1996.

Page 10                                                GAO/AIMD-98-21 Information Security Management
           underlying problem at federal agencies. Although powerful technical controls,
           such as those involving encryption, are becoming increasingly available to
           facilitate information security, effective implementation requires that these
           techniques be thoughtfully selected and that their use be monitored and
           managed on an ongoing basis. In addition, there are many aspects of
           information security, such as risk assessment, policy development, and disaster
           recovery planning, that require coordinated management attention.

           To identify leading organizations, we reviewed professional literature and
           research information and solicited suggestions from experts in professional
           organizations, nationally known public accounting firms, and federal agencies.
           In selecting organizations to include in our study, we relied primarily on
           recommendations from the Computer Security Institute and public accounting
           firms because they were in a position to evaluate and compare information
           security programs at numerous organizations. In addition, we attempted to
           select organizations from a variety of business sectors to gain a broad
           perspective on the information security practices being employed. After initial
           conversations with a number of organizations, we narrowed our focus to eight
           organizations that had implemented fairly comprehensive organizationwide
           information security programs. All were prominent nationally known
           organizations. They included a financial services corporation, a regional
           electric utility, a state university, a retailer, a state agency, a nonbank financial
           institution, a computer vendor, and an equipment manufacturer. The number
           of computer users at these organizations ranged from 3,500 to 100,000, and
           four had significant international operations. Because most of the
           organizations we studied considered discussions of their security programs to
           be sensitive and they wanted to avoid undue public attention on this aspect of
           their operations, we agreed not to identify the organizations by name.

           We obtained information primarily through interviews with senior security
           managers and document analysis conducted during and after visits to the
           organizations we studied. In a few cases, we toured the organizations'
           facilities and observed practices in operation. We supplemented these findings,
           to a very limited extent, with information obtained from others. For example,
           at the state agency we visited, we also met with a statewide security program
           official and with state auditors. In addition, we asked the Computer Security
           Institute to query its members about their efforts to measure the effectiveness
           of their security programs in order to gain a broader perspective of practices in
           this area-s

           To determine the applicability of the leading organization's practices to federal
           agencies, we discussed our findings with numerous federal officials, including
           officials in OMB's Information Policy and Technology Branch, the Computer
           Security Division of NIST's Information Technology Laboratory, CIO Council

GAO/AIMD-98-21 Information Security Management                                        Page 11
          members, the chairman of the Chief Financial Officers Council's systems
          subcommittee, information security officers from 15 federal agencies, and
          members of the President's Commission on Critical Infrastructure Protection.
          Further, we discussed our findings with our Executive Council on Information
          Management and Technology, a group of executives with extensive experience
          in information technology management who advise us on major information
          management issues affecting federal agencies.

          Throughout the guide, we make several observations on federal information
          security practices in order to contrast them with the practices of the non-
          federal organizations we studied. These observations are based on the body of
          work we have developed over the last several years and on our recent
          discussions with federal information security officers and other federal officials
          who are knowledgeable about federal information security practices.

          Although we attempted to be as thorough as possible within the scope of our
          study, we recognize that more work in this area remains to be done, including
          a more indepth study of individual practices. We also recognize that the
          practices require customized application at individual organizations depending
          on factors such as existing organizational strengths and weaknesses.


Security as an Element of a Broader
Information Management Strategy

          Although this guide focuses on information security program management, this
          is only one aspect of an organization's overall information management
          strategy. As such, an organization's success in managing security-related
          efforts is likely to hinge on its overall ability to manage its use of information
          technology. Unfortunately, federal performance in this broader area has been
          largely inadequate. Over the past 6 years, federal agencies have spent a
          reported $145 billion on information technology with generally disappointing
          mission-related results.

          Recognizing the need for improved information management, the Congress has
          enacted legislation that is prompting landmark reforms in this area. In
          particular, the Paperwork Reduction Act of 1995 emphasized the need for
          agencies to acquire and apply information resources to effectively support the
          accomplishment of agency missions and the delivery of services to the public.
          The Clinger-Cohen Act of 1996 repeated this theme and provided more detailed
          requirements. These laws emphasize involving senior executives in information
          management decisions, appointing senior-level chief information officers, and
          using performance measures to assess the contribution of technology in
          achieving mission results. Although their primary focus is much broader, both
Page 12                                         GAO/AIMD-98-21 Information Security Management
           of these laws specify security as one of the aspects of information management
           that must be addressed. This environment of reform is conducive to agencies
           rethinking their security programs, as part of broader information management
           changes, and considering the implementation of the practices that have been
           adopted by nonfederal organizations.


Other Issues Affecting Federal Information Security
           Security program management and the related implementation of controls over
           access to data, systems, and software programs, as well as service continuity
           planning, are central factors affecting an organization's ability to protect its
           information resources and the program operations that these resources
           support. However, there are numerous policy, technical, legal, and human
           resource issues that are not fully within the control of officials at individual
           agencies. These issues are currently being debated and, in many cases,
           addressed by private-sector and federal efforts. They include, but are not
           limited to, matters concerning (1) the use of encryption to protect the
           confidentiality of information and other cryptographic capabilities, including
           digital signatures and integrity checks, (2) personal privacy, (3) the adequacy
           of laws protecting intellectual property and permitting investigations into
           computer-related crimes, and (4) the availability of adequate technical
           expertise and security software tools.

           These topics are beyond the scope of this guide and, thus, are not discussed
           herein. However, it is important to recognize that strengthening information
           security requires a multifaceted approach and sometimes involves issues that
           are beyond the control of individual businesses and agencies. Although the
           management practices described in this guide are fundamental to improving an
           organization's information security posture, they should be considered in the
           context of this broader spectrum of issues.




GAO/AIMD-98-21 Information Security Management                                   Page 13
   Leading Organizations Apply Fundamental
   Risk Management Principles



The organizations we studied were striving to manage the same types of risks that face
federal agencies. To do so, they had responded to these risks by reorienting their
security programs from relatively low-profile operations focused primarily on mainframe
security to visible, integral components of their organizations' business operations.
Because of the similarities in the challenges they face, we believe that federal entities can
learn from these organizations to develop their own more effective security programs.


Federal and Nonfederal Entities Face
Similar Risks and Rely on Similar Technologies

          Like federal agencies, the organizations we studied must protect the integrity,
          confidentiality, and availability of the information resources they rely on.
          Although most of the organizations we studied were private business
          enterprises motivated by the desire to earn profits, their information security
          concerns focused on providing high-quality reliable service to their customers
          and business partners, avoiding fraud and disclosures of sensitive information,
          promoting efficient operations, and complying with applicable laws and
          regulations. These are the same types of concerns facing federal agencies.

          Also, like federal agencies, the organizations we studied relied, to varying
          degrees, on a mix of mainframe and client-server systems and made heavy use
          of interconnected networks. In addition, all were either using or exploring the
          possibilities of using the Internet to support their business operations.




Page 14                                          GAO/AIMD-98-21 Information Security Management
                              Information Security Objectives Common to
                                    Federal and Nonfederal Entities


                * Maintain customer, constituent,              * Ensure that organizational
                  stockholder, or taxpayer confidence in         computer, network, and data
                  the organization's products, services,         resources are not misused or
                  efficiency, and trustworthiness                wasted

                * Protect the confidentiality of sensitive     * Avoid fraud
                  personal and financial data on
                  employees, clients, customers, and           * Avoid expensive and
                  beneficiaries                                  disruptive incidents

                * Protect sensitive operational data from      * Comply with pertinent laws
                  inappropriate disclosure                       and regulations

                * Avoid third-party liability for illegal or   * Avoid a hostile workplace
                  malicious acts committed with the              atmosphere that may impair
                  organization's computer or network             employee performance
                  resources




GAO/AIMD-98-21 Information Security Management                                          Page 15
Risk Management Principles Provide A Framework for an Effective
Information Security Program

          Although the nature of their operations differed, the organizations we studied
          all had embraced five risk management principles, which are listed in the box
          below. These principles guided the organizations' efforts to manage the risk
          associated with the increasingly automated and interconnected environment in
          which they functioned.




                      Risk Management Principles Implemented
                             by Leading Organizations

            * Assess risk and determine needs

           * Establish a central management focal point

           * Implement appropriate policies and related controls

           * Promote awareness

           * Monitor and evaluate policy and control effectiveness




          An important factor in effectively implementing these principles was linking
          them in a cycle of activity that helped ensure that information security policies
          addressed current risks on an ongoing basis. The single most important factor
          in prompting the establishment of an effective security program was a general
          recognition and understanding among the organization's most senior executives
          of the enormous risks to business operations associated with relying on
          automated and highly interconnected systems. However, risk assessments of
          individual business applications provided the basis for establishing policies and
          selecting related controls. Steps were then taken to increase the awareness of
          users concerning these risks and related policies. The effectiveness of controls
          and awareness activities was then monitored through various analyses,
          evaluations, and audits, and the results provided input to subsequent risk
          assessments, which determined if existing policies and controls needed to be
          modified. All of these activities were coordinated through a central security

Page 16                                        GAO/AIMD-98-21 Information Security Management
           management office or group who served as consultants and facilitators to
           individual business units and senior management. This risk management cycle
           is illustrated in the diagram below.




                                Risk Management Cycle
                                           Assess Risk
                                           & Determine
                                              Needs




                 Implement                   Cetral                Monitor &
                    Policies &O                  Focal             Evaluate
                   Controls                      Point




                                             Promot
                                            Awareness




           This continuing cycle of monitoring business risks, maintaining policies and
           controls, and monitoring operations parallels the process associated with
           managing the controls associated with any type of program. In addition, these
           principles should be familiar to federal agency officials since they have been
           emphasized in much of the recent guidance pertaining to federal information
           security. Most notably, they incorporate many of the concepts included in
           NIST's September 1996 publication, Generally Accepted Principles and
           Practices for Securing Information Technology Systems, and in OMB's
           February 1996 revision of Circular A-130, Appendix LUI, "Security of Federal
           Automated Information Resources."

GAO/AIMD-98-21 Information Security Management                                  Page 17
Principles Were Implemented Though Similar Practices
          The organizations we studied had developed similar sets of practices to
          implement the five risk management principles, although the techniques they
          employed varied depending largely on each organization's size and culture.
          Some programs were less mature than others and had not fully implemented
          all of the practices. However, security managers at each organization we
          studied agreed that the 16 practices outlined in the following illustration, which
          relate to the five risk management principles, were key to the effectiveness of
          their programs.




Page 18                                         GAO/AIMD-98-21 Information Security Management
                         Sixteen Practices Employed by Leading Organizations
                               To Implement the Risk Management Cycle


                                                                                      Practices
                         Principles
                                                                     1. Recognize information resources as
                                                                        essential organizational assets
                       Assess Risk                                   2. Develop practical risk assessment
                       and Determine                                    procedures that link security to
                       Needs               1ll 11 11             _     business needs
                                                                     3. Hold program and business managers
                                                                        accountable
                                                                     4. Manage risk on a continuing basis



                                                                     5. Designate a central group to carry
                       Establish A                                      out key activities
                       Central             * *| *
                                           Estalis
                                             -              _        6. Provide the central group ready and
                                                                        independent access to senior executives
                       Management                           _        7. Designate dedicated funding and staff
                       Focal Point                                   8. Enhance staff professionalism and
                                                                        technical skills



                      Implement                                      9. Link policies to business risks
                      Appropriate
                       Policies and
                       Related
                                           *            l
                                                            _h
                                                                ,.
                                                                     10. Distinguish between policies and
                                                                         guidelines
                                                                     11. Support policies through central
                      Controls                                           security group


                                                                     12. Continually educate users and
                      Promote
                      Awareness
                                               Es
                                       ______________       _   rl
                                                                 _
                                                                         others on risks and related policies
                                                                     13. Use attention-getting and
                                                                         user-friendly techniques



                                                                     14. Monitor factors that affect risk and
                      Monitor and                                        indicate security effectiveness
                      Evaluate
                      Policy and
                      Potolc an
                                       I   *l                   Al
                                                                     15. Use results to direct future efforts
                                                                            1lill
                                                                              hold _>and
                                                                                   managers accountable
                                                                     16. Be alert to new monitoring tools
                      Effectiveness                                      and techniques




           The following pages provide a more detailed discussion of these practices and
           illustrative examples of the techniques used to implement them by the
           organizations we studied.

GAO/AIMD-98-21 Information Security Management                                                                    Page 19
  Assess Risk and
                                                ( -u
                                              Implement                    Central
   Determine        Needs
          Determine Needs                      Controls&
                                             ~~~~Policies   U<Ill0fl   -    Focal
                                                                            Point             ontoe
                                                                                          Evalat
                                                                                            Evalua~U




                                                                            Promote
                                                                           Awareness




"We are not in the business of protecting information. We only protect information
insofar as it supports the business needs and requirements of our company. "
                                        - Senior security manager at a major electric utility


All of the organizations we studied said that risk considerations and related cost-benefit
tradeoffs were a primary focus of their security programs. Security was not viewed as an
end in itself, but a set of policies and related controls designed to support business
operations. Controls were identified and implemented to address specific business risks.
As one organization's security manager said, "Because every control has some cost
associated with it, every control needs a business reason to be put in place." Regardless
of whether they were analyzing existing or proposed operations, security managers told
us that identifying and assessing information security risks in terms of the impact on
business operations was an essential step in determining what controls were needed and
what level of resources could be expended on controls. In this regard, understanding the
business risks associated with information security was the starting point of the risk
management cycle.




Page 20                                          GAO/AIMD-98-21 Information Security Management
Practice 1:          Recognize Information Resources as Essential
                     Organizational Assets That Must Be Protected


           "Information technology is an integral and critical ingredient for the
           successful functioning of major U.S. companies."
                                           - Deloitte & Touche LLP Survey of American Business
                                           Leaders, November 1996


           The organizations we studied recognized that information and information
           systems were critical assets essential to supporting their operations that must
           be protected. As a result, they viewed information protection as an integral
           part of their business operations and of their strategic planning.


           Senior Executive Support Is Crucial

           In particular, senior executive recognition of information security risks and
           interest in taking steps to understand and manage these risks were the most
           important factors in prompting development of the information security
           programs we studied. Such high-level interest helped ensure that information
           security was taken seriously at lower organizational levels and that security
           specialists had the resources needed to implement an effective program.

           This contrasts with the view expressed to us by numerous federal managers
           and security experts that many top federal officials have not recognized the
           indispensable nature of electronic data and automated systems to their
           program operations. As a result, security-related activities intended to protect
           these resources do not receive the resources and attention that they merit.

           In some cases, senior management's interest at the organizations we studied
           had been generated by an incident that starkly illustrated the organization's
           information security vulnerabilities, even though no damage may have actually
           occurred. In other cases, incidents at other organizations had served as a
           "wake-up call." Two organizations noted that significant interest on the part of
           the board of directors was an important factor in their organizations' attention
           to information security. However, security managers at many of the
           organization's we studied told us that their chief executive officers or other
           very senior executives had an ongoing interest in information technology and
           security, which translated into an organizationwide emphasis on these areas.

           Although the emphasis on security at the organizations we studied generally
           emanated from top officials, security specialists at lower levels nurtured this

GAO/AIMD-98-21 Information Security Management                                          Page 21
          emphasis by keeping them abreast of emerging security issues, educating
          managers at all levels, and by emphasizing the related business risks to their
          own organizations.


          Security Seen As An Enabler

          In addition, most of the organizations we studied were aggressively exploring
          ways to improve operational efficiency and service to customers through new
          or expanded applications of information technology, which usually prompted
          new security considerations. Officials at one organization told us that they
          viewed their ability to exploit information technology as giving them a
          significant competitive advantage. In this regard, several organizations told us
          that security was increasingly being viewed as an enabler-a necessary step in
          mitigating the risks associated with new applications involving Internet use and
          broadened access to the organization's computerized data. As a result, security
          was seen as an important component in improving business operations by
          creating opportunities to use information technology in ways that would not
          otherwise be feasible.




Page 22                                        GAO/AIMD-98-21 Information Security Management
Practice 2:     Develop Practical Risk Assessment Procedures That Link
                Security to Business Needs

           The organizations we studied had tried or were exploring various risk
           assessment methodologies, ranging from very informal discussions of risk to
           fairly complex methods involving the use of specialized software tools.
           However, the organizations that were the most satisfied with their risk
           assessment procedures were those that had defined a relatively simple process
           that could be adapted to various organizational units and involved a mix of
           individuals with knowledge of business operations and technical aspects of the
           organization's systems and security controls.

           The manufacturing company had developed an automated checklist that asked
           business managers and relevant staff in individual units a series of questions
           that prompted them to consider the impact of security controls, or a lack
           thereof, on their unit's operations. The results of the analysis were reported in
           a letter to senior management that stated the business unit's compliance with
           the security policy, planned actions to become compliant, or willingness to
           accept the risk. The results were also reported to the internal auditors, who
           used them as a basis for reviewing the business unit's success in implementing
           the controls that the unit's managers had determined were needed. Through
           the reporting procedure, the business managers took responsibility for either
           tolerating or mitigating security risks associated with their operations.

           Such procedures provided a relatively quick and consistent means of exploring
           risk with business managers, selecting cost-effective controls, and documenting
           conclusions and business managers' acceptance of final determinations
           regarding what controls were needed and what risks could be tolerated. With
           similar objectives in mind, the utility company we studied had developed a
           streamlined risk assessment process that brought together business managers
           and technical experts to discuss risk factors and mitigating controls. (This
           process is described in detail as a case example on page 27.)

           Other organizations had developed less formal and comprehensive techniques
           for ensuring that risks were considered prior to changes in operations.

           *      The retailer had established standard procedures for requesting and
                  granting new network connections. Under these procedures,
                  documentation about the business need for the proposed connection and
                  the risks associated with the proposed connection had to be submitted
                  in writing prior to consideration by the central security group. Then, a
                  meeting between the technical group, which implemented new
                  connections, the requester, and the central security group was held to
                  further explore the issue. The documentation and meeting helped

GAO/AIMD-98-21 Information Security Management                                   Page 23
                ensure that the requester's business needs were clearly understood and
                the best solution was adopted without compromising the network's
                security.

          *      The financial services corporation had implemented procedures for
                 documenting business managers' decisions to deviate from
                 organizationwide policies and standards. In order to deviate from a
                 "mandatory policy," the business unit prepared a letter explaining the
                 reason for the deviation and recognizing the related risk. Both the
                 business unit executive and the central security group manager signed
                 the letter to acknowledge their agreement to the necessity of the policy
                 deviation. Deviations from less rigid "standards" were handled similarly,
                 although the letter could be signed by the business unit executive, alone,
                 and did not require the central security group's approval, though it was
                 generally received. In all cases, the central security group discussed the
                 information security implications of the deviation with the appropriate
                 executive and signed-off only when it was satisfied that the executives
                 fully understood the risk associated with the deviation. However, the
                 ultimate decision on whether a deviation from policies or standards was
                 appropriate was usually left to the business unit.


          Organizations Saw Benefits Despite Lack of Precision

          "Actual losses are not necessarily good indications of risk."
                            - Security manager at a prominent financial institution

          Although all of the organizations placed emphasis on understanding risks, none
          attempted to precisely quantify them, noting that little quantified data are
          available on the likelihood of an incident occurring or on the amount of
          damage that is likely to result from a particular type of incident. Such data are
          not available because many losses are never discovered and others are never
          reported, even within the organizations where they occurred. In addition, there
          are limited data on the full costs of damage caused by security weaknesses and
          on the operational costs of specific control techniques. Further, due to fast-
          paced changes in technology and factors such as the tools available to would-
          be intruders, the value of applying data collected in past years to the current
          environment is questionable. As a result, it is difficult, if not impossible, to
          precisely compare the cost of controls with the risk of loss in order to
          determine which controls are the most cost-effective. Ultimately, business
          managers and security specialists must rely on the best information available
          and their best judgment in determining what controls are needed.




Page 24                                           GAO/AIMD-98-21 Information Security Management
           Despite their inability to precisely compare the costs of controls with
           reductions in risk, the organizations we studied said that risk assessments still
           served their primary purpose of ensuring that the risk implications of new and
           existing applications were explored. In particular, the security managers we
           met with believed that adequate information was available to identify the most
           significant risks. For example, in addition to their own organization's
           experience, they noted that information on threats, specific software
           vulnerabilities, and potential damage was widely available in technical
           literature, security bulletins from organizations such as the Carnegie-Mellon
           Computer Emergency Response Team (CERT), surveys done by professional
           associations and audit firms, and discussion groups. Although much of this
           information was anecdotal, the security managers thought that it was sufficient
           to give them a good understanding of the threats of concern to their
           organizations and of the potential for damage.

           In addition, the lack of quantified results did not diminish the value of risk
           assessments as a tool for educating business managers. By increasing the
           understanding of risks, risk assessments (1) improved business managers'
           ability to make decisions on controls needed, in the absence of quantified risk
           assessment results, and (2) engendered support for policies and controls
           adopted, thus helping to ensure that policies and controls would operate as
           intended.




GAO/AIMD-98-21 Information Security Management                                    Page 25
Practice 3: Hold Program and Business Managers Accountable

          "Holding business managers accountable and changing the security staff's
          role from enforcement to service has been a major paradigm shift for the
          entire company."
                                        - Security manager at a major equipment manufacturer

          The organizations we studied were unanimous in their conviction that business
          managers must bear the primary responsibility for determining the level of
          protection needed for information resources that support business operations.
          In this regard, most of the organizations we studied held the view that business
          managers should be held accountable for managing the information security
          risks associated with their operations, much as they would for any other type
          of business risk. However, security specialists played a strong educational and
          advisory role and had the ability to elevate discussions to higher management
          levels when they believed that risks were not being adequately addressed.

          Business managers, usually referred to as program managers in federal
          agencies, are generally in the best position to determine which of their
          information resources are the most sensitive and what the business impact of a
          loss of integrity, confidentiality, or availability would be. Business or program
          managers are also in the best position to determine how security controls may
          impair their operations. For this reason, involving them in selecting controls
          can help ensure that controls are practical and will be implemented.

          Accordingly, security specialists at the organizations we studied had assumed
          the role of educators, advisors, and facilitators who helped ensure that
          business managers were aware of risks and of control techniques that had
          been or could be implemented to mitigate the risks. For several of the
          organizations we studied, these roles represented a dramatic reversal from past
          years, when security personnel were viewed as rigid, sometimes overly
          protective enforcers who often did not adequately consider the effect of
          security controls on business operations.

          Some of the organizations we studied had instituted mechanisms for
          documenting and reporting business managers' risk determinations. These
          generally required some type of sign-off on memoranda that either (1) reported
          deviations from predetermined control requirements, as was the case at the
          financial services corporation and the manufacturing company discussed
          previously or (2) provided the results of risk assessments, as was the case of
          the utility company described in the following case example. According to the
          security managers we met with, such sign-off requirements helped ensure that
          business managers carefully considered their decisions before finalizing them.


Page 26                                         GAO/AIMD-98-21 Information Security Management
                 Case Example: A Practical Method for Involving Business
                 Managers in Risk Assessment
                A major electric utility company has developed an efficient and disciplined process
                for ensuring that information security-related risks to business operations are
                considered and documented. The process involves analyzing one system or segment
                of business operation at a time and convening a team of individuals that includes
                business managers who are familiar with business information needs and technical
                staff who have a detailed understanding of potential system vulnerabilities and
                related controls. The sessions, which follow a standard agenda, are facilitated by a
                member of the central security group who helps ensure that business managers and
                technical staff communicate effectively and adhere to the agenda

                During the session, the group brainstorms to identify potential threats,
                vulnerabilities, and resultant negative impacts on data integrity, confidentiality, and
                availability. Then, they analyze the effects of such impacts on business operations
                and broadly categorize the risks as major or minor. The group does not usually
                attempt to obtain or develop specific numbers for threat likelihood or annual loss
                estimates unless the data for determining such factors are readily available. Instead,
                they rely on their general knowledge of threats and vulnerabilities obtained from
                national incident response centers, professional associations and literature, and their
                own experience. They believe that additional efforts to develop precisely quantified
                risks are not cost-effective because (1) such estimates take an inordinate amount of
                time and effort to identify and verify or develop, (2) the risk documentation becomes
                too voluminous to be of practical use, and (3) specific loss estimates are generally
                not needed to determine if a control is needed.

                After identifying and categorizing risks, the group identifies controls that could be
                implemented to reduce the risk, focusing on the most cost-effective controls. As a
                starting point, they use a list of about 25 common controls designed to address
                various types of risk. Ultimately, the decision as to what controls are needed lies
                with the business managers, who take into account the nature of the information
                assets and their importance to business operations and the cost of controls.

                The team's conclusions as to what risks exist and what controls are needed are
                documented along with a related action plan for control implementation. This
                document is then signed by the senior business manager and technical expert
                participating and copies are made available to all participant groups and to the
                internal auditors, who may later audit the effectiveness of the agreed upon controls.

                Each risk analysis session takes approximately 4 hours and includes 7 to 15 people,
                though sessions with as many as 50 and as few as 4 people have occurred.
                Additional time is usually needed to develop the action plan. The information
                security group conducts between 8 and 12 sessions a month. According to the
                utility's central information security group, this process increases security awareness
                among business managers, develops support for needed controls, and helps integrate
                information security considerations into the organization's business operations.




GAO/AIMD-98-21 Information Security Management                                                 Page 27
Practice 4: Manage Risk on a Continuing Basis
          "Information security is definitely a journey, not a destination--there are
          always new challenges to meet."
                                        - Chief information security officer at a major financial
                                        services corporation

          The organizations we met with emphasized the importance of continuous
          attention to security to ensure that controls were appropriate and effective.
          They stressed that constant vigilance was needed to ensure that controls
          remained appropriate-addressing current risks and not unnecessarily hindering
          operations-and that individuals who used and maintained information systems
          complied with organizational policies.

          Such attention is important for all types of internal controls, but it is especially
          important for security over computerized information, because, as mentioned
          previously, the factors that affect computer security are constantly changing in
          today's dynamic environment. Such changing factors include threats, systems
          technologies and configurations, known vulnerabilities in existing software, the
          level of reliance on automated systems and electronic data, and the sensitivity
          of such operations and data-


Existing Federal Guidance Provides a Framework for Implementing
Risk Management Practices

OMB's most recent revision of Circular A-130, Appendix III, recognizes that federal
agencies have had difficulty in performing effective risk assessments and it reemphasizes
the importance of holding program managers accountable for authorizing systems for use
and, thus, accepting the risks associated with these systems. In its 1996 revisions of
Circular A-130, OMB eliminated a long-standing federal requirement for formal risk
assessments because agencies were expending resources on complex assessments of
specific risks with limited tangible benefits in terms of improved security. Instead, OMB's
revised circular promotes a risk-based approach and suggests that, rather than trying to
precisely measure risk, agencies focus on generally assessing risks and managing them.
This approach is similar to that used by the organizations we studied.

Similarly, the concept of holding program managers accountable underlies the existing
federal process for accrediting systems for use. Accreditation is detailed in NIST's
Federal Information Processing Standards Publication 102, "Guideline for Computer
Security Certification and Accreditation," which was published in 1983. According to
NIST, accreditation is "the formal authorization by the management official for system
operation and an explicit acceptance of risk." OMB's 1996 update to Circular A-130,
Appendix HI, provides similar guidance, specifying that a management official should

Page 28                                          GAO/AIMD-98-21 Information Security Management
authorize in writing the use of each system before beginning or significantly changing use
of the system. "By authorizing processing in a system, a manager accepts the risks
associated with it."




GAO/AIMD-98-21 Information Security Management                                  Page 29
          [Getting         Started-Ases ing Riskandy DetermininaNg Neied                                              J
                      Seniorrogram         ain an understanding o~~f'ther criticaiyadsniiiyo
                         Of7the icials       infobrmationand systems                     u   eency
                                          rogram.Batc~~

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                 ll:i~~~ii|402iii0t~l|i0040404i;40Lr;




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                                                                   specialists and other technical
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                                                                             :program
                                         ofiil regarding potential vulnerabilities and related


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                                         In promotingthe adoption of policies and othebrcontrols;
                                         fus on the specificbiness
                                                             u onIstroilsd
                                                                       reasons for the
                                         rather ta n eei requirements



Page 30                                                    GAO/AIMD-98-21 Inforrnation Security Management
                                                                        Assess Risk
                                                               _        ~~~&Determine          _
                                                                            Needs




  Establish A Central                             Implement

  Management Focal                                 Controls   gl1l0                                Eonite

  Point                                                       I

                                                                          Promote
                                                                         Awareness




"A central focal point is essential to spotting trends, identifying problem areas, and
seeing that policies and administrative actions are handled in a consistent manner.
                                           -   Senior information security officer for a major university

"Information security has become too important to handle on an ad hoc basis."
                                           - Security specialist at a major retailing company




Managing the increased risks associated with a highly interconnected computing
environment demands increased central coordination to ensure that weaknesses in one
organizational unit's systems do not place the entire organization's information assets at
undue risk. Each of the organizations we studied had adopted this view and, within the
last few years, primarily since 1993, had established a central security management group
or reoriented an existing central security group to facilitate and oversee the organization's
information security activities. As such, the central group served as the focal point for
coordinating activities associated with the four segments of the risk management cycle.

As discussed in the previous section on risk analysis, the central security groups served
primarily as advisers or consultants to the business units, and, thus, they generally did not
have the ability to independently dictate information security practices. However, most
possessed considerable "clout" across their organizations due largely to the support they
received from their organization's senior management. In this regard, their views were

GAO/AIMD-98-21 Information Security Management                                               Page 31
sought and respected by the organizations' business managers. The following case
example describes how one organization strengthened its central security group and
reoriented its focus.



     Case Example: Transforming an Organization's Central Security Focal
     Point

     In 1995, realizing that security was an essential element of its efforts to innovatively
     use information technology, a major manufacturer significantly reorganized and
     strengthened its central information security function. Prior to the reorganization, a
     central security group of about four individuals concentrated on mainframe security
     administration and had little interaction with the rest of the company. Since then,
     the central group has grown to include 12 individuals who manage the security of
     the company's main network, decentralized computer operations, and Internet use.
     In addition, the group participates in the company's strategic planning efforts and in
     the early stages of software development projects to ensure that security
     implications of these efforts are addressed. In this regard, it serves as a
     communications conduit between management and the information systems staff
     who design, build, and implement new applications.

     Members of the central group possess a variety of technical skills and have specific
     information security responsibilities, such as developing policy, maintaining the
     firewall that protects the organization's network from unauthorized intrusions, or
     supporting security staff assigned to individual business units. According to the
     group's manager, because of the shift in the central group's responsibilities, "the
     members of the group had to change their mind-set from a staff organization to a
     service organization. They had to be willing to work with business managers to
     enable rather than to control business operations."




Page 32                                                   GAO/AIMD-98-21 Information Security Management
Practice 5:      Designate a Central Group to Carry Out Key Activities

           Overall, the central security groups we studied served as (1) catalysts for
           ensuring that information security risks were considered in both planned and
           ongoing operations, (2) central resources for advice and expertise to units
           throughout their organizations, and (3) a conduit for keeping top management
           informed about security-related issues and activities affecting the organization.
           In addition, these central groups were able to achieve some efficiencies and
           increase consistency in the implementation of the organization's security
           program by performing tasks centrally that might otherwise be performed by
           multiple individual business units.

           Specific activities performed by central groups differed somewhat, primarily
           because they relied to a varying extent on security managers and
           administrators in subordinate units and on other organizationally separate
           groups, such as disaster recovery or emergency response teams. Examples of
           the most common activities carried out by central groups are described below.

           *      Developing and adjusting organizationwide policies and guidance, thus
                  reducing redundant policy-related activities across the organization's
                  units. For example, the manufacturer's central security group recently
                  revamped the company's entire information security manual and
                  dedicated one staff member to maintaining it.

           *      Educating employees and other users about current information security
                  risks and helping to ensure consistent understanding and administration
                  of policies through help-line telephone numbers, presentations to
                  business units, and written information communicated electronically or
                  through paper memos.

           *      Initiating discussions on information security risks with business
                  managers and conducting defined risk assessment procedures.

           *      Meeting periodically with senior managers to discuss the security
                  implications of new information technology uses being considered.

           *      Researching potential threats, vulnerabilities, and control techniques and
                  communicating this information to others in the organization. Many of
                  the organizations supplemented knowledge gained from their own
                  experiences by frequently perusing professional publications, alerts, and
                  other information available in print and through the Internet. Several
                  mentioned the importance of networking with outside organizations,
                  such as the International Information Integrity Institute, the European
                  Security Forum, and the Forum of Incident Response and Security

GAO/AIMD-98-21 Information Security Management                                    Page 33
              Teams, to broaden their knowledge. One senior security officer noted,
              "Sharing information and solutions is important. Many organizations are
              becoming more willing to talk with outsiders about security because
              they realize that, despite differing missions and cultures, they all use
              similar technology and face many of the same threats."

          *   Monitoring various aspects of the organization's security-related
              activities by testing controls, accounting for the number and types of
              security incidents, and evaluating compliance with policies. The central
              groups often characterized these evaluative activities as services to the
              business units.

          *   Establishing a computer incident response capability, and, in some
              cases, serving as members of the emergency response team.

          *   Assessing risks and identifying needed policies and controls for general
              support systems, such as organizationwide networks or central data
              processing centers, that supported multiple business units. For
              example, some central groups controlled all new connections to the
              organization's main network, ensuring that the connecting network met
              minimum security requirements. Similarly, one organization's central
              group was instrumental in acquiring a strong user authentication system
              to help ensure that network use could be reliably traced to the
              individual users. Further, most central groups oversaw Internet use.

          *   Creating standard data classifications and related definitions to facilitate
              protection of data shared among two or more business units.

          *   Reviewing and testing the security features in both commercially
              developed software that was being considered for use and internally
              developed software prior to its being moved into production. For
              example, the manufacturing company's central group reviewed all new
              Internet related applications and had the authority to stop such
              applications from going into production if minimum security standards
              were not met. Similarly, the central information protection group at the
              utility we studied was required to approve all new applications to
              indicate that risks had been adequately considered.

          *   Providing self-assessment tools to business units so that they could
              monitor their own security posture. For example, the financial services
              corporation provided business units with software tools and checklists
              so that they would assume responsibility for identifying and correcting
              weaknesses, rather than depending on auditors to identify problems.


Page 34                                      GAO/AIMD-98-21 Information Security Management
Practice 6:      Provide the Central Group Ready and Independent Access to
                 Senior Executives

           Senior information security managers emphasized the importance of being able
           to discuss security issues with senior executives. Several noted that, to be
           effective, these senior executives had to be in a position to take action and
           effect change across organizational divisions. The ability to independently
           voice security concerns to senior executives was viewed as important because
           such concerns could often be at odds with business managers' and system
           developers' desires to implement new computer applications quickly and avoid
           controls that would impede efficiency, user friendliness, and convenience. This
           ability to elevate significant security concerns to higher management levels
           helped ensure that risks were thoroughly understood and that decisions as to
           whether such risks should be tolerated were carefully considered before final
           decisions were made.

           The organizational positions of the central groups varied. Most were located
           two levels below the Chief Information Officer (CIO). However, the groups
           reporting directly to the CIO or to an even more senior official viewed this as
           an advantage because it provided them greater independence. Several others
           said that, despite their lower organizational position, they felt free to contact
           their CIOs and other senior executives when important security issues arose,
           and they were relatively unrestrained by the need to "go through the chain of
           command." Some noted that senior managers frequently called them to discuss
           security issues. For example, at the nonbank financial institution, the senior
           security manager was organizationally placed two levels below the CIO, but
           she met independently with the CIO once every quarter. Also, during the first
           three months of 1997, she had met twice with the organization's chief
           executive officer, at his request, to discuss the security implications of new
           applications.

           In contrast, several federal information security officials told us that they felt
           that their organizations were placed too low in the organizational structure to
           be effective and that they had little or no opportunity to discuss information
           security issues with their CIOs and other senior agency officials.

           Rather than depend on the personal interest of individual senior managers, two
           of the organizations we studied had established senior-level committees to
           ensure that information technology issues, including information security,
           received appropriate attention. For example, the university's central group had
           created a committee of respected university technical and policy experts to
           discuss and build consensus about the importance of certain information
           security issues reported to senior management, thus lending weight and
           credibility to concerns raised by the central security office.

GAO/AIMD-98-21 Information Security Management                                      Page 35
Practice 7:    Designate Dedicated Funding and Staff
          Unlike many federal agencies, the central groups we studied had defined
          budgets, which gave them the ability to plan and set goals for their
          organization's information security program. At a minimum, these budgets
          covered central staff salaries and training and security hardware and software.
          At one organization, business units could supplement the central group's
          resources in order to increase the central group's participation in high priority
          projects. While all of the central groups we studied had staffs ranging from 3
          to 17 people permanently assigned to the group, comparing the size of these
          groups is of limited value because of wide variations in the (1) sizes of the
          organizations we studied, (2) inherent riskiness of their operations, and (3) the
          additional support the groups received from other organizational components
          and from numerous subordinate security managers and administrators.

          In particular, no two groups we studied were alike regarding the extent of
          support they received from other organizational units. For example, the
          computer vendor relied on a security manager in each of the organization's
          four regional business units, while the utility's nine-member central group
          relied on 48 part-time information security coordinators at various levels within
          the company. Some central groups relied heavily on technical assistance
          located in another organizational unit, while others had significant technical
          expertise among their own staff, and, thus, were much more involved in
          directly implementing and testing controls.

          Despite these differences, two key characteristics were common to each of the
          organization we studied: (1) information security responsibilities had been
          clearly defined for the groups involved and (2) dedicated staff resources had
          been provided to carry out these responsibilities. The following table
          summarizes the details on the size and structure of the organizations'
          information security staffs.




Page 36                                         GAO/AIMD-98-21 Information Security Management
           Placement and Staffing of Eight Central
           Information Security Management Groups

             Organization       Approximate    Placement of     Number of       Other Staff Resources
                                Number of      Central Group    Dedicated       Relied On (some numbers are
                                System Users                    Central Staff   approximate)

             Financial              70,000     Two levels              17         35 security officers in
             Services                          below CEO                          business units
             Corporation

             Electric Utility       5,000      One level               9          48 security coordinators at
                                               below CIO                          three levels throughout the
                                                                                  organization
                                                                                  Virus response team
                                                                                  Administrators

             State University      100,000     One level               3          170 LAN administrators
                                               below CIO                          Technical committee
                                                                                  Policy committee
                                                                                  Incident handling team

             Retailer              65,000      Two levels              12         2,000 distributed security
                                               below CIO                          administrators
                                                                                  Internal audit staff
                                                                                  Technical services group
                                                                                  Loss prevention staff

             State Agency           8,000      Two levels              8          25 district managers
                                               below CIO                          Security administrators in 31
                                                                                  units
                                                                                  Individuals with specialized
                                                                                  expertise in the information
                                                                                  systems group

             (Nonbank)              3,500      Two levels              7          Central security
             Financial                         below CIO                          administration group
             Institution

             Computer               15,000     Three levels            4          27 regional security
             Vendor                            below CIO                          specialists

             Equipment             35,000      Several levels          12         70 site security administrators
             Manufacturer                      below CIO




GAO/AIMD-98-21 Information Security Management                                                      Page 37
Practice 8:     Enhance Staff Professionalism and Technical Skills
          The organizations we studied had taken steps to ensure that personnel
          involved in various aspects of their information security programs had the
          skills and knowledge they needed. In addition, they recognized that staff
          expertise had to be frequently updated to keep abreast of ongoing changes in
          threats, vulnerabilities, software, security techniques, and security monitoring
          tools. Further, most of the organizations were striving to increase the
          professional stature of their staff in order to gain respect from others in their
          organizations and attract competent individuals to security-related positions.


          Update Skills and Knowledge of Security Managers and Specialists

          The training emphasis for staff in the central security management groups,
          many of whom came to their groups with significant technical expertise, was
          on keeping staff skills and knowledge current. This was accomplished
          primarily through attendance at technical conferences and specialized courses
          on topics such as the security features of new software, as well as networking
          with other security professionals and reviewing the latest technical literature
          and bulletins. To maximize the value of expenditures on external training and
          events, one central group required staff members who attended these events to
          brief others in the central group on what they had learned.

          In an effort to significantly upgrade the expertise of information security
          officers in its various business units, the central group at the financial services
          corporation had recently arranged for an outside firm to provide 5 weeks of
          training for these individuals. The training, which is planned to take place in
          1 week increments throughout the year, is expected to entail a broad range of
          security-related topics, including general information security, encryption,
          access control, and how to build a better working relationship with the
          corporation's technical information systems group.

          Citing an emerging trend, the senior information security managers had also
          started to create information security career paths and stress professional
          certification for security specialists. In particular, many organizations were
          encouraging their staff to become Certified Information Systems Security
          Professionals (CISSP).4 One security manager noted that security specialists


          4The CISSP certification was established by the International Information Systems Security
          Certification Consortium. The consortium was established as a joint effort of several
          information security-related organizations, including the Information Systems Security
          Association and the Computer Security Institute, to develop a certification program for
          information security professionals.

Page 38                                               GAO/AIMD-98-21 Information Security Management
           also needed excellent communication skills if they were to effectively fulfill
           their roles as consultants and facilitators for business managers who were less
           technically expert regarding computers and telecommunications.


           Educate System Administrators

           Increasing the expertise of system administrators presented different
           challenges. System administrators are important because they generally
           perform day to day security functions, such as creating new system user
           accounts, issuing new passwords, and implementing new software. These
           tasks must be completed properly and promptly or controls, such as passwords
           and related access restrictions, will not provide the level of protection
           intended. In addition, system administrators are the first line of defense
           against security intrusions and are generally in the best position to notice
           unusual activity that may indicate an intrusion or other security incident.
           However, at the organizations we studied, as at federal agencies, security is
           often a collateral duty, rather than a full-time job, and the individuals assigned
           frequently have limited technical expertise. As a result, the effectiveness of
           individual system administrators in maintaining security controls and spotting
           incidents is likely to vary.

           To enhance the technical skills of their security administrators and help ensure
           that all of them had the minimal skills needed, most of the groups we studied
           had established special training sessions for them. For example,

           * the manufacturer required new security administrators to spend 2 to 5 days
             in training with the central security group, depending on their technical
             skills, before they were granted authority to perform specific functions on
             the network, such as controlling the users' access rights;

           * the central security group at the university we studied held annual technical
             conferences for the university's systems administrators and engaged
             professional training organizations to offer on-campus training at very
             reduced rates; and

           * the state agency held a biannual conference for systems administrators
             that included sessions related to their information security responsibilities.


           Attract and Keep Individuals with Technical Skills

           Most of the groups cited maintaining or increasing the technical expertise
           among their security staff as a major challenge, largely due to the high demand

GAO/AIMD-98-21 Information Security Management                                    Page 39
          for information technology experts in the job market. In response, several said
          they offered higher salaries and special benefits to attract and keep expert
          staff. For example, the financial services corporation provided competitive pay
          based on surveys of industry pay levels, attempted to maintain a challenging
          work environment, and provided flexible work schedules and telecommuting
          opportunities that allowed most of the staff to work at home 1 day a week. In
          addition, provisions were made for staff to do the type of work they preferred,
          such as software testing versus giving presentations.

          Organizations relied on both internally and externally developed and presented
          training courses, sometimes engaging contractors or others to assist. For
          example, the state information security office above the state agency we
          studied worked with an information security professional organization to
          provide a relatively low-cost statewide training conference. The state
          organization provided meeting rooms and administrative support while the
          professional organization used its professional contacts to obtain
          knowledgeable speakers.




Page 40                                       GAO/AIMD-98-21 Information Security Management
            Getting Started--Establishing ,.a Central Focal. Point:
              :-:Senior Proga      Involve agencysecurity specialists in the early pI         ng
                              b
                       Officials    stages !.of proJects .involving computer and/or network


                                   Be accssible to ency securit experts       opnto
                                                                                  nand
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                                   operations.~......

                          ClOs      Establish a central gr
                                                         t                 r of
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                 ;:~~~~~~         P *Supor
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                  S erty Devel tripansfr                increasi the exper tse of
                      Officers seuit specialis tsand secunity adistao.

                      DistrExpore    echnism
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                                             x forlevraging     oudeof
                                    theagency.           -
                                   Dee lopp
                                         method foattrg             an retainingindividuals
                                   waith
                                   Manegedednte4ica kills.




GAO/AIMD-98-21 Information Security Management                                          Page 41
                                                                Assess Risk
                                                                & Determine


                                                           It             ^~~~
   Implement Appropriate                                        Central
   Policies and Related                                  0190     Focal               Evaluate

   Controls                                                       Point



                                                                 Promote
                                                                Awareness




The organizations we studied viewed information security policies as the foundation of
their information security programs and the basis for adopting specific procedures and
technical controls. As with any area of operations, written policies are the primary
mechanism by which management communicates its views and requirements to its
employees, clients, and business partners. For information security, as with other types
of internal controls, these views and requirements generally flow directly from risk
considerations, as illustrated in the management cycle depicted above.

As discussed earlier, our discussions with the eight organizations we studied focused on
their methods for developing and supporting policies and guidelines. We did not discuss
the specific controls they had implemented due to the proprietary and often highly
technical nature of this information.




Page 42                                        GAO/AIMD-98-21 Information Security Management
Practice 9:      Link Policies To Business Risks

           The organizations we studied stressed the importance of up-to-date policies
           that made sense to users and others who were expected to understand them.
           Many senior security managers told us that prior to the recent strengthening of
           their security programs, their organization's information security policies had
           been neglected and out-of-date, thus failing to address significant risks
           associated with their current interconnected computing environment. As a
           result, developing a comprehensive set of policies was one of their first steps
           in establishing an effective corporatewide security program. In addition, they
           emphasized the importance of adjusting policies on a continuous basis to
           respond to newly identified risks or areas of misunderstanding. For example,

           * At the financial services corporation we studied, the central security group
             routinely analyzed the causes of security weaknesses identified by
             management and by auditors in order to identify policy and related control
             deficiencies.

           * The university we studied had recently developed more explicit policies on
             system administrator responsibilities in recognition of the critical role of
             system administration in a distributed environment.

           * The manufacturing company we studied had recently drafted policies on
             security incident response after an incident had exposed shortfalls in the
             company's guidance in this area.

           A relatively new risk area receiving particular attention in the policies of the
           organizations we studied was user behavior. Many policies are implemented
           and, to some extent, enforced by technical controls, such as logical access
           controls that prevent individuals from reading or altering data in an
           unauthorized manner. However, many information security risks cannot be
           adequately mitigated with technical controls because they are a function of
           user behavior. In a networked environment, these risks are magnified because
           a problem on one computer can affect an entire network of computers within
           minutes and because users are likely to have easier access to larger amounts
           of data and the ability to communicate quickly with thousands of others. For
           example, users may accidentally disclose sensitive information to a large
           audience through electronic mail or introduce damaging viruses that are
           subsequently transmitted to the organizations entire network of computers. In
           addition, some users may feel no compunction against browsing sensitive
           organizational computer files or inappropriate Internet sites if there is no clear
           guidance on what types of user behavior are acceptable.



GAO/AIMD-98-21 Information Security Management                                    Page 43
          To address these risks, many of which did not exist prior to extensive use of
          networks, electronic mail, and the Internet, the organizations we visited had
          begun placing more emphasis on user behavior in their policies and guidelines.
          For example, the university's policies went beyond the traditional warnings
          against password disclosure by including prohibitions against a variety of
          possible user actions. These included misrepresenting their identity in
          electronic communications and conducting and promoting personal commercial
          enterprises on the network. The senior security officer at this organization
          noted that, when rules such as this are aimed at users, it is especially
          important that they be stated in clearly understandable, relatively nontechnical
          language. The security officers at the computer vendor we studied said that
          because the company's information security policies emphasized user behavior,
          they were included in the organization's employee code of conduct.




Page 44                                       GAO/AIMD-98-21 Information Security Management
Practice 10: Distinguish Between Policies and Guidelines


           "Detailed guidelines are an important supplement to the official policies
           because they educate users and serve as an awareness tool."
                                                  - Security manager at a prominent financial
                                                 institution


           A common technique for making organizational information security policies
           more useful was to divide them into two broad segments: concise high-level
           policies and more detailed information referred to as guidelines or standards.
           Policies generally outlined fundamental requirements that top management
           considered to be imperative, while guidelines provided more detailed rules for
           implementing the broader policies. Guidelines, while encouraged, were not
           considered to be mandatory for all business units.

           Distinguishing between organizational policies and guidelines provided several
           benefits. It allowed senior management to emphasize the most important
           elements of information security policy, provided some flexibility to unit
           managers, made policies easier for employees to understand, and, in some
           cases, reduced the amount of formal review needed to finalize updated
           policies.


           Guidelines Can Serve As An Educational Tool

           Several security managers said that short policies that emphasized the most
           important aspects of the organizations security concerns were more likely to
           be read and understood than voluminous and detailed policies. However, they
           noted that more detailed guidelines often provided answers to employees'
           questions and served as a tool for educating subordinate security managers and
           others who wanted a more thorough understanding of good security practices.

           For example, the utility company we studied had distilled the fundamental
           components of its information protection policies into less than one page of
           text. This narrative (1) stated that "Information is a corporate asset ...
           Information must be protected according to its sensitivity, criticality and
           value, regardless of the media on which it is stored, the manual or
           automated systems that process it, or the methods by which it is
           distributed," (2) outlined the responsibilities of information owners,
           custodians, and users, (3) defined the organization's three data classification
           categories, and (4) stated that each business unit should develop an
           information protection program to implement these policies. The policy

GAO/AIMD-98-21 Information Security Management                                             Page 45
          statement then referred the reader to a 73-page reference guide that provided
          definitions, recommended guidelines and procedures, explanatory discussions,
          and self-assessment questionnaires designed to assist business units in
          understanding the need for the policies and how they could be implemented.


          Guidelines Provide for Flexibility

          Although the latitude granted to business units varied, providing both policies
          and guidelines allowed business units to tailor the guidelines to their own
          individual unit's information protection needs. It also reinforced the business
          managers' sense of ownership of their information assets.

          For example, the large financial services corporation we studied had divided its
          information security rules into "policies" and "standards." Policies were
          mandatory, high-level requirements that, with rare exception, had to be
          followed. An example of a policy was that units were required to use
          commercially developed software rather than developing unique software in-
          house. An example of a standard at the same institution was a prescribed
          minimum password length. At this organization, deviations from policies had
          to be documented in a letter signed by both the executive of the business
          group requesting the deviation and the central information security group's
          manager. However, deviations from standards required only approval from the
          group's executive. Such deviations were required to be documented in a letter
          and, though not required, were usually approved by the central security group.
          All deviations had to be renewed annually.




Page 46                                        GAO/AIMD-98-21 Information Security Management
Practice 11: Support Policies Through the Central Security Group
           At the organizations we visited, the central security management group was
           responsible for developing written corporatewide policies in partnership with
           business managers, internal auditors, and attorneys. In addition, the central
           groups provided related explanations, guidance, and support to business units.
           Several security managers noted that business managers are much more likely
           to support centrally developed policies if they clearly address organizational
           needs and are practical to implement. For this reason, these organizations had
           developed mechanisms for involving other organizational components in policy
           documentation.

           Most often this involvement was in the form of reviews of policy drafts.
           However, the university we studied had established an information security
           policy committee that included top university officials, legal counsel, and
           representatives from student affairs, faculty affairs, and internal audit to assist
           in the development and review of policies.

           The central security management groups played an important role in ensuring
           that policies were consistently implemented by serving as focal points for user
           questions. By serving as a readily available resource for organization
           employees, they helped clear up misunderstandings and provided guidance on
           topics that were not specifically addressed in written guidance.

           Most organizations had also made their policies available through their
           computer networks so that users could readily access the most up-to-date
           version whenever they needed to refer to them. In addition, many
           organizations required users to sign a statement that they had read and
           understood the organization's information security policies. Generally, such
           statements were required from new users at the time access to information
           resources was first provided and from all users periodically, usually once a
           year. One security manager said that they thought that requiring such signed
           statements served as a useful technique for impressing on the users the
           importance of understanding organizational policies. In addition, if the user
           was later involved in a security violation, the statement served as evidence that
           he or she had been informed of organizational policies. Additional techniques
           for communicating information security policies are discussed in the next
           section on promoting awareness.




GAO/AIMD-98-21 Information Security Management                                      Page 47
   |G~etting Started--Implementing Apppria                                 Polici     and Rlated
         1:t :iLl~ii- iQ:t-fi0 i;;5SE;~Contr ls : EE:i:;i Lf::j;; ::i;::
             Senior
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                                                   GAOfficiAlM9 p           fol matond g   lit   anages




Page48                                          ~lte GAO/A~~~~~~~~~~~~~~~~~~a
                                                       ii pment-2         S~euiys aagmn
                                                                         PnomtOn
                                                                        Assess Risk        _
                                                                        & Determine
                                                                           Needs




  Promote Awareness                                Implement            Central
                                                               Policies
                                                               Policies &<
                                                                           Focal      II~II1ID~1U ~~~~~~Evaluate
                                                                                                    Monitor &
                                                    Controls               Point




"Users are much more likely to support and comply with policies if they clearly
understand the purpose for the policies and their responsibilities in regard to the
policies."
                                           -   Information security manager for a state agency



User awareness is essential to successfully implementing information security policies
and ensuring that related controls are working properly. Computer users, and others with
access to information resources, cannot be expected to comply with policies that they are
not aware of or do not understand. Similarly, if they are not aware of the risks
associated with their organization's information resources, they may not understand the
need for and support compliance with policies designed to reduce risk. For this reason,
the organizations we studied considered promoting awareness as an essential element of
the risk management cycle.




GAO/AIMD-98-21 Information Security Management                                                 Page 49
Practice 12: Continually Educate Users and Others on Risks and Related
             Policies
          The central groups we studied had implemented ongoing awareness strategies
          to educate all individuals who might affect the organization's information
          security. These individuals were primarily computer users, who might be
          employees; contractors; clients; or commercial partners, such as suppliers.
          One organization took an even broader view, targeting awareness efforts also
          at custodians and security guards, after a night security guard accidentally
          destroyed some important data while playing games on a computer after hours.

          The groups focused their efforts on increasing everyone's understanding of the
          risks associated with the organization's information and the related policies
          and controls in place to mitigate those risks. Although these efforts were
          generally aimed at encouraging policy compliance, the senior security official
          at the retailing company we studied emphasized the importance of improving
          users' understanding of risks. She said that her central security group had
          recognized that policies, no matter how detailed, could never address every
          scenario that might lead to a security incident. As a result, her overarching
          philosophy regarding awareness efforts was that users who thoroughly
          understood the risks were better equipped to use good judgment when faced
          with a potential security breach. For example, such employees were less likely
          to be tricked into disclosing sensitive information or passwords.

          This last point highlights one of the most important reasons for sensitizing
          computer users and other employees to the importance of information security.
          Users disclosing sensitive information or passwords in response to seemingly
          innocent requests from strangers either over the phone or in person can
          provide intruders easy access to an organization's information and systems.
          Such techniques, often referred to as "social engineering," exploit users'
          tendencies to be cooperative and helpful, instead of guarded, careful, and
          suspicious, when information is requested. Without adequate awareness about
          the risks involved in disclosing sensitive information, users may volunteer
          information which can allow an intruder to circumvent otherwise well-designed
          access controls.




Page 50                                      GAO/AIMD-98-21 Information Security Management
Practice 13: Use Attention-Getting and User-Friendly Techniques

           To get their message across, the central security groups used a variety of
           training and promotional techniques to make organizational policies readily
           accessible, educate users on these policies, and keep security concerns in the
           forefront of users' minds. Techniques used included

           * intranet websites that communicated and explained information security
             related policies, standards, procedures, alerts, and special notes;

           * awareness videos with enthusiastic endorsements from top management for
             the security program to supplement basic guidance, such as the importance
             of backing up files and protecting passwords;

           * interactive presentations by security staff to various user groups to market
             the services provided by the central information security group and answer
             user questions; and

           * security awareness day and products with security-related slogans.

           The organizations we visited avoided having once-a-year, one-size-fits-all
           security briefings like those seen at many federal agencies. The security
           managers we talked with said that it was important to relate security concerns
           to the specific risks faced by users in individual business groups and ensure
           that security was an everyday consideration.




GAO/AIMD-98-21 Information Security Management                                   Page 51
                Case Example - Coordinating Policy Development and Awareness
                Activities

                After experiencing a significant virus infection in 1989, the retailing company we
                studied assigned one of its managers to step up efforts to promote employee
                awareness of information security risks and related organizational policies. Since
                then, this individual's responsibilities for information security policy development
                and awareness, which had previously been handled on a part-time basis, have
                evolved into a full-time "awareness manager position" in the organization's central
                security group. The company's response to a minor incident involving the
                unintentional release of company financial data illustrates the compatibility of these
                roles. To reduce the chances of a similar incident, the awareness manager
                concurrently (1) coordinated the development of a policy describing organizational
                data classification standards and (2) developed a brochure and guidelines to
                publicize the new standards and educate employees on their implementation. By
                coordinating policy development and awareness activities in this manner, she helps
                ensure that new risks and policies are communicated promptly and that employees
                are periodically reminded of existing policies through means such as monthly
                bulletins, an intranet web site, and presentations to new employees.




          [   AGetting ,Started--r:oimoing Awareness

              -Senior Prograim Demonstratei support by participating in effortsto                o
                      Oifficias prormoteinformation security awareness.

                          Cl
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                                  i::nforrationsecuiy




Page 52                                              GAO/AIMD-98-21 Information Security Management
                                                                  Assess Risk
                                                                  & Determine
                                                                    Needs




  Monitor and Evaluate                           Implement        Central
  Policy and Control                             Policies &
                                                 Controls
                                                                    Focal
                                                                    Point       ULIDIDEI
  Effectiveness

                                                              _    Promote
                                                                  Awareness




As with any- type of business activity, information security should be monitored and
periodically reassessed to ensure that policies continue to be appropriate and that
controls are accomplishing their intended purpose. Over time, policies and procedures
may become inadequate because of changes in threats, changes in operations, or
deterioration in the degree of compliance. Periodic assessments or reports on activities
can be a valuable means of identifing areas of noncompliance, reminding employees of
their responsibilities, and demonstrating management's commitment to the security
program.

The organizations we studied had recognized that monitoring control effectiveness and
compliance with policies is a key step in the cycle of managing information security.
Accordingly, they monitored numerous factors associated with their security programs,
and they used the results to identify needed improvements. They used various techniques
to do this, and several mentioned their efforts to identify, evaluate, and implement new,
more effective tools as they become available. Such tools include software that can be
used to automatically monitor control effectiveness and information systems activity. In
addition, several of the security managers we met with expressed interest in improving
their ability to more precisely measure the costs and benefits of security-related activities
so that their organizations could better determine which controls and activities were the
most cost effective.




GAO/AIMD-98-21 Information Security Management                                        Page 53
Practice 14: Monitor Factors that Affect Risk and Indicate Security
             Effectiveness
          The organizations focused their monitoring efforts primarily on (1) determining
          if controls were in place and operating as intended to reduce risk and
          (2) evaluating the effectiveness of the security program in communicating
          policies, raising awareness levels, and reducing incidents. As discussed below,
          these efforts included testing controls, monitoring compliance with policies,
          analyzing security incidents, and accounting for procedural accomplishments
          and other indicators that efforts to promote awareness were effective.


          Testing the Effectiveness of Controls

          Directly testing control effectiveness was cited most often as an effective way
          to determine if the risk reduction techniques that had been agreed to were, in
          fact, operating effectively. In keeping with their role as advisors and
          facilitators, most of the security managers we met with said that they relied
          significantly on auditors to test controls. In these cases, the central security
          management groups kept track of audit findings related to information security
          and the organization's progress in implementing corrective actions.

          However, several of the central security groups also performed their own tests.
          For example, the central security group at the university we studied
          periodically ran a computer program designed to detect network vulnerabilities
          at various individual academic departments and reported weaknesses to
          department heads. A subsequent review was performed a few months later to
          determine if weaknesses had been reduced. The central security manager told
          us that she considered the tests, which could be performed inexpensively by
          her staff, a cost-effective way to evaluate this important aspect of security and
          provide a service to the academic departments, which were ultimately
          responsible for the security of their departments' information and operations.

          Several organizations periodically tested system and network access controls
          by allowing designated individuals to try to "break into" their systems using the
          latest hacking techniques. This type of testing is often referred to as
          penetration testing. The individuals performing the tests, which at various
          organizations were internal auditors, contractors, student interns, or central
          security staff, were encouraged to research and use hacking instructions and
          tools available on the Internet or from other sources in order to simulate
          attacks from real hackers. By allowing such tests, the organizations could
          readily identify previously unknown vulnerabilities and either eliminate them or
          make adjustments in computer and network use to lessen the risks.


Page 54                                           GAO/AIMD-98-21 Information Security Management
           One organization had performed annual tests of its disaster recovery plan to
           identify and correct plan weaknesses. A recent test was particularly effective
           because it involved a comprehensive simulation of a real disaster. The test
           involved staging a surprise "bomb scare" to get employees, who were unaware
           that the threat was a pretense, to evacuate the building. After the employees
           had evacuated, they were told that they were participating in a test, that they
           were to assume that a bomb had actually destroyed their workplace, and to
           proceed with emergency recovery plans. The test, which was organized by the
           agency's contingency planning group, proved extremely successful in
           identifying plan weaknesses and in dramatically sensitizing employees to the
           value of anticipating and being prepared for such events.


           Monitoring Compliance With Policies and Guidelines

           All of the organizations we studied monitored compliance with organizational
           policies to some extent. Much of this monitoring was achieved through
           informal feedback to the central security group from system admirnistrators and
           others in other organizational units. However, a few organizations had
           developed more structured mechanisms for such monitoring. For example, the
           utility company included in our study developed quarterly reports on
           compliance with organizational policies, such as the number of organizational
           units that had tailored their own information protection policies as required by
           corporate-level policy. Also, several organizations said that they had employed
           self-assessment tools, such as the Computer Security Institute's "Computer
           Security Compliance Test," to compare their organization's programs to pre-
           established criteria.


           Accounting For and Analyzing Security Incidents

           Keeping summary records of actual security incidents is one way that an
           organization can measure the frequency of various types of violations as well
           as the damage suffered from these incidents. Such records can provide
           valuable input for risk assessments and budgetary decisions.

           Although all of the organizations we studied kept at least informal records on
           incidents, those that had formalized the process found such information to be a
           valuable resource. For example, at the nonbank financial institution we
           studied, the central security manager kept records on viruses detected and
           eradicated, including estimates of the cost of potential damage to computer
           files that was averted by the use of virus detection software. This information
           was then used to justify annual budget requests when additional virus
           detection software was needed. However, as discussed in the following case

GAO/AIMD-98-21 Information Security Management                                  Page 55
          example, the university we studied had developed the most comprehensive
          procedures for accounting for and analyzing security incidents.



               Case Example: Developing an Incident Database

               The central security group at the university we studied had developed a database
               that served as a valuable management tool in monitoring problems, reassessing
               risks, and determining how to best use limited resources to address the most
               significant information security problems. The database accounted for the number
               of information security incidents that had been reported, the types of incidents, and
               actions taken to resolve each incident, including disciplinary actions At the time of
               our visit, in February 1997, incidents were categorized into 13 types, which generally
               pertained to the negative effects of the violations. Examples included denial of
               service, unauthorized access, data compromise, system damage, copyright
               infringement, and unauthorized commercial activity.

               By keeping such records, the central group could develop monthly reports that
               showed increases and decreases in incident frequency, trends, and the status of
               resolution efforts. This, in turn, provided the central security group a means of
               (1) identifying emerging problems, (2) assessing the effectiveness of current policies
               and awareness efforts, (3) determining the need for stepped up education or new
               controls to address problem areas, and (4) monitoring the status of investigative and
               disciplinary actions to help ensure that no individual violation was inadvertently
               forgotten and that violations were handled consistently.

               The means of maintaining the database and the details that it contained had
               changed as the number of reported incidents at the university had grown-from 3 or
               4 a month in 1993 to between 50 and 60 a month in early 1997-and as the
               database's value as a management tool became more apparent. Records originally
               maintained in a paper logbook had been transferred to a personal computer, and
               information on followup actions had recently been expanded.

               The university's senior security officer noted that the database could be augmented
               to provide an even broader range of security management information. For
               example, while the university did not develop data on the actual cost of incidents,
               such as the cost of recovering from virus infections, the database could be used to
               compile such information, which would be useful in measuring the cost of security
               lapses and in determining how much to spend on controls to reduce such lapses.




Page 56                                             GAO/AIMD-98-21 Information Security Management
           Monitoring the Effectiveness of the Central Security Management Group

           Several of the central security groups had developed measures of their own
           activities, outputs, and expertise as an indication of their effectiveness.
           Examples of these items included

           * the number of calls from users, indicating knowledge of and respect for
             security specialists;

           * the number of security-related briefings and training sessions presented;

           * the number of risk assessments performed;

           * the number of security managers and systems administrators who were
             Certified Information System Security Professionals; and

           * the number of training courses and conferences held or attended.


           Emerging Interest in More Precisely Measuring Cost and Benefits

           Several of the security managers we met with expressed an interest in
           developing better measurement capabilities so that they could more precisely
           measure the ultimate benefits and drawbacks of security-related policies and
           controls-that is, the positive and negative impacts of information security on
           business operations. However, they said that such measurements would be
           difficult because it is costly to do the research and recordkeeping necessary to
           develop information on (1) the full cost of controls-both the initial cost and
           operational inefficiencies associated with the controls-and (2) the full cost of
           incidents or problems resulting from inadequate controls. Further, as
           discussed previously regarding risk assessment, actual reductions in risk
           cannot be precisely quantified because sufficient data on risk factors are not
           available.

           In an effort to more thoroughly explore this topic, we expanded our
           discussions beyond the eight organizations that were the primary subjects of
           our study by requesting the Computer Security Institute to informally poll its
           most active members on this subject. We also discussed assessment
           techniques with experts at NIST. Although we identified no organizations that
           had made significant progress in applying such measures, we found that more
           precisely measuring the positive and negative effects of security on business
           operations is an area of developing interest among many information security
           experts. For this reason, improved data and measurement techniques may be
           available in the future.

GAO/AIMD-98-21 Information Security Management                                   Page 57
Practice 15: Use Results to Direct Future Efforts and Hold Managers
             Accountable
          Although monitoring, in itself, may encourage compliance with information
          security policies, the full benefits of monitoring are not achieved unless results
          are used to improve the security program. Analyzing the results of monitoring
          efforts provides security specialists and business managers a means of
          (1) reassessing previously identified risks, (2) identifying new problem areas,
          (3) reassessing the appropriateness of existing controls and security-related
          activities, (4) identifying the need for new controls, and (5) redirecting
          subsequent monitoring efforts. For example, the central security group at the
          utility we studied redirected its training programs in response to information
          security weaknesses reported by its internal auditors. Similarly, security
          specialists at the manufacturing company recently visited one of the company's
          overseas units to assist in resolving security weaknesses identified by internal
          auditors. The previously cited example of using records on virus incidents to
          determine the need for virus-detection software also illustrates this point.

          Results can also be used to hold managers accountable for their information
          security responsibilities. Several organizations had developed quarterly
          reporting mechanisms to summarize the status of security-related efforts.
          However, the financial services corporation provided the best example of how
          periodic reports of results can be used to hold managers accountable for
          understanding, as well as reducing, the information security risks to their
          business units. A description of this process is provided in the following case
          example.




Page 58                                        GAO/AIMD-98-21 Information Security Management
                Case Example: Measuring Control Effectiveness and
                Management Awareness

                At the financial services corporation we studied, managers are expected to know
                what their security problems are and to have plans in place to resolve them. To
                help ensure that managers fulfill this responsibility, they are provided self-
                assessment tools that they can use to evaluate the information security aspects of
                their operations. When weaknesses are discovered, the business managers are
                expected to either improve compliance with existing policies or consult with the
                corporation's security experts regarding the feasibility of implementing new
                policies or control techniques.

                Ratings based on audit findings serve as an independent measure of control
                effectiveness and management awareness. At the start of every audit, the
                auditors ask the pertinent business managers what weaknesses exist in their
                operations and what corrective actions they have deemed necessary and have
                planned. After audit work is complete, the auditors compare their findings with
                management's original assertions to see if management was generally aware of all
                of the weaknesses prior to the audit. The auditors then develop two ratings on a
                scale of 1 to 5: one rating to indicate the effectiveness of information security
                controls and a second rating to indicate the level of management awareness. If
                the auditors discover serious, but previously unrecognized weaknesses, the
                management awareness rating will be lowered. However, if the auditor finds no
                additional weaknesses, management will receive a good awareness rating, even if
                controls need to be strengthened.

                These ratings are forwarded to the CEO and to the board of directors, where they
                can be used as performance measures. According to the bank's central security
                manager, the bank chairman's goal is for all business units to have favorable
                ratings (4 or 5) in both categories. Such a rating system provides not only a
                measure of performance and awareness, but it also places primary responsibility
                for information security with the managers whose operations depend on it.
                Further, it recognizes the importance of identifying weaknesses and the risk they
                present, even when they cannot be completely eliminated.




GAO/AIMD-98-21 Information Security Management                                                Page 59
Practice 16: Be Alert to New Monitoring Tools and Techniques
          The security specialists we met with said that they were constantly on the
          lookout for new tools to test the security of their computerized operations.
          Two security managers noted that their organizations had implemented new,
          more sophisticated, software tools for monitoring network vulnerabilities.
          However, several security managers said that the development of automated
          monitoring tools is lagging behind the introduction of new computer and
          network technologies and that this has impaired their efforts to detect
          incidents, especially unauthorized intrusions. Similarly, as discussed
          previously, managers are looking for practical techniques for more precisely
          measuring the value of security controls and obtaining better data on risk
          factors. In such an environment, it is essential that (1) security specialists
          keep abreast of developing techniques and tools and the latest information
          about system vulnerabilities and (2) senior executives ensure they have the
          resources to do this.

          Several security managers told us that, in addition to reading current
          professional literature, their involvement with professional organizations was a
          valuable means of learning about the latest monitoring tools and research
          efforts. Examples of such organizations included the Computer Security
          Institute, Information Systems Security Association, the Forum of Incident
          Response and Security Teams, and less formal discussion groups of security
          professionals associated with individual industry segments. Several security
          managers said that by participating in our study, they hoped to gain insights
          on how to improve their information security programs.




Page 60                                        GAO/AIMD-98-21 Information Security Management
              GettingcStartedd--:Monoring and Evaluating Policy-and Control                                                                     :
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                                      ...




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                                                   key business managers and others Jiwho can act to,
                                                   address problems.

                                                   Become an active participantl inprofessional
                                                   associationsa and industry discussion groups in order to
                                                   keep abreast of the latest monitoring toolsand
                                                  techniques-




GAO/AIMD-98-21 Information Security Management                                                                                        Page 61
          Conclusion

          "We are on the verge of a revolution that is just as profound as the change
          in the economy that came with the industrial revolution. Soon electronic
          networks will allow people to transcend the barriers of time and distance
          and take advantage of global markets and business opportunities not even
          imaginable today, opening up a new world of economic possibility and
          progress.

                                                         Vice President Albert Gore, Jr., in the
                                                         Administration's July 1997 report,
                                                         A Framework For Global Electronic
                                                         Commerce


          To achieve the benefits offered by the new era of computer interconnectivity,
          the federal government, like other organizational entities and individuals, must
          find ways to address the associated security implications. Individual security
          controls and monitoring tools will change as technology advances, and new
          risks are likely to emerge. For this reason, it is essential that organizations
          such as federal agencies establish management frameworks for dealing with
          these changes on an ongoing basis.

          Developing an information security program that adheres to the basic
          principles outlined in this guide is the first and most basic step that an agency
          can take to build an effective security program. In this regard, agencies must
          continually (1) explore and assess information security risks to business
          operations, (2) determine what policies, standards, and controls are worth
          implementing to reduce these risks, (3) promote awareness and understanding
          among program managers, computer users, and systems development staff, and
          (4) assess compliance and control effectiveness. As with other types of
          internal controls, this is a cycle of activity, not an exercise with a defined
          beginning and end.

          By instituting such a management framework, agencies can strengthen their
          current security posture, facilitate future system and process improvement
          efforts, and more confidently take advantage of technology advances.




Page 62                                        GAO/AIMD-98-21 Information Security Management
           Appendix I


           GAO Guides on Information Technology
           Management

           Year 2000 Computing Crisis: An Assessment Guide (GAO/AIMD-10.1.14,
           September 1997)

           Measuring Performance and Demonstrating Results of Information Technology
           Investments Exposure Draft (GAO/AIMD-97-163, September 1997)

           Business Process Reengineering Assessment Guide (GAO/AIMD-10.1.15, April
           1997, Version 3)

           Assessing Risks and Returns: A Guide for Evaluating Federal Agencies' IT
           Investment Decision-making (GAO/AIMD-10.1.13, February 1997, Version 1)

           Executive Guide: Improving Mission Performance Through Strategic
           Information Management and Technology (GAO/AIMD-94-115, May 1994)




GAO/AIMD-98-21 Information Security Management                               Page 63
          Appendix 11

          NIST's Generally Accepted Principles and Practices
          for Securing Information Technology Systems

          To provide a common understanding of what is needed and expected in
          information technology security programs, NIST developed and published
          Generally Accepted Principles and Practices for Securing Information
          Technology Systems in September 1996. Its eight principles are listed below.


          1. Computer Security Supports the Mission of the Organization

          2. Computer Security Is an Integral Element of Sound Management

          3. Computer Security Should Be Cost-effective

          4. Systems Owners Have Security Responsibilities Outside Their Own
             Organizations

          5. Computer Security Responsibilities and Accountability Should Be Made
             Explicit

          6. Computer Security Requires a Comprehensive and Integrated Approach

          7. Computer Security Should Be Periodically Reassessed

          8. Computer Security Is Constrained by Societal Factors




Page 64                                       GAO/AIMD-98-21 Information Security Management
           Appendix III


           Major Contributors to This Executive Guide

           Accounting and               Jean Boltz, Assistant Director, (202) 512-5247
           Information                  Michael W. Gilmore, Information Systems Analyst
           Management                   Ernest A. Doring, Senior Evaluator
           Division
           Washington, D.C.




GAO/AIMD-98-21 Information Security Management                                  Page 65
          GAO Reports and Testimonies
          on Information Security
          (Issued since September 1993)


          Social Security Administration: Internet Access to Personal Earnings and
          Benefits Information (GAO/T-AIMD/HEHS-97-123, May 6, 1997)

          IRS Systems Security and Funding: Employee Browsing Not Being Addressed
          Effectively and Budget Requests for New Systems Development Not Justified
          (GAO/T-AIMD-97-82, April 15, 1997)

          IRS Systems Security: Tax Processing Operations and Data Still at Risk Due to
          Serious Weaknesses (GAO/T-AIMD-97-76, April 10, 1997)

          IRS Systems Security: Tax Processing Operations and Data Still at Risk Due to
          Serious Weaknesses (GAO/AIMD-97-49, April 8, 1997)

          High Risk Series: Information Management and Technology (GAO/HR-97-9,
          February 1997)

          Information Security: Opportunities for Improved OMB Oversight of Agencv
          Practices (GAO/AIMD-96-110, September 24, 1996)

          Financial Audit: Examination of IRS' Fiscal Year 1995 Financial Statements
          (GAO/AIMD-96-101, July 11, 1996)

          Tax Systems Modern-ization: Actions Underway But IRS Has Not Yet Corrected
          Management and Technical Weaknesses (GAO/AIMD-96-106, June 7, 1996)

          Information Security: Computer Hacker Information Available on the Internet
          (GAO/T-AIMD-96-108, June 5, 1996)

          Information Security: Computer Attacks at Department of Defense Pose
          Increasing Risks (GAO/AIMD-96-84, May 22, 1996)

          Information Security: Computer Attacks at Department of Defense Pose
          Increasing Risks (GAO/T-AIMD-96-92, May 22, 1996)

          Security Weaknesses at IRS' Cvberfile Data Center (GAO/AIMD-96-85R, May 9,
          1996)



Page 66                                        GAO/AIMD-98-21 Information Security Management
          Tax Systems Modernization: Management and Technical Weaknesses Must Be
          Overcome To Achieve Success (GAO/T-AIMD-96-75, March 26, 1996)

          Financial Management: Challenges Facing DOD in Meeting the Goals of the
          Chief Financial Officers Act (GAOIT-AID-96-1, November 14, 1995)

          Financial Audit: Examination of IRS' Fiscal Year 1994 Financial Statements
          (GAO/ AIMD-95-141, August 4, 1995)

          Federal Familv Education Loan Information System: Weak Computer Controls
          Increase Risk of Unauthorized Access to Sensitive Data (GAO/AIMD-95-117,
          June 12, 1995)

          Department of EnergW: Procedures Lacking to Protect Computerized Data
          (GAO/AIMD-95-118, June 5, 1995)

          Financial Management: Control Weaknesses Increase Risk of Improper NavM
          Civilian Payroll Payments (GAO/AIMD-95-73, May 8, 1995)

          Information Superhighway: An Overview of Technology Challenges
          (GAO/AIMD-95-23, January 23, 1995)

          Information Superhighwav: Issues Affecting Development (GAO/RCED-94-285,
          September 30, 1994)

         IRS Automation: Controlling Electronic Filing Fraud and Improper Access to
         Taxpaver Data (GAO/T-AIMD/GGD-94-183, July 19, 1994)

         Financial Audit: Federal Family Education Loan Program's Financial Statements
         for Fiscal Years 1993 and 1992 (GAO/AIMD-94-131, June 30, 1994)

          Financial Audit: Examination of Customs' Fiscal Year 1993 Financial Statements
          (GAO/AIMD-94-119, June 15, 1994)

          Financial Audit: Examination of IRS' Fiscal Year 1993 Financial Statements
          (GAO/AIMD-94-120, June 15, 1994)

          HUD Information Resources: Strategic Focus and Improved Management
          Controls Needed (GAO/AIMD-94-34, April 14, 1994)

          Financial Audit: Federal Deposit Insurance Corporation's Internal Controls as of
          December 31. 1992 (GAO/AIMD-94-35, February 4, 1994)



GAO/AIMD-98-21 Information Security Management                                  Page 67
          Financial Management: Strong Leadership Needed to Improve Army's Financial
          Accountability (GAO/AIMD-94-12, December 22, 1993)

          Communications Privacy: Federal Policy and Actions (GAO/OSI-94-2, November
          4, 1993)

          Document Security: Justice Can Improve Its Controls Over Classified and
          Sensitive Documents (GAO/GGD-93-134, September 7, 1993)

          IRS Information Systems: Weaknesses Increase Risk of Fraud and Impair
          Reliability of Management Information (GAO/AIMD-93-34, September 22, 1993)




Page 68                                       GAO/AIMD-98-21 Information Security Management
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