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@DDDDD6 Management Guide/Protection Of Information GDDDDY
Today computers are integral to all aspects of operations within
an organization. As Federal agencies are becoming critically
dependent upon computer information systems to carry out their
missions, the agency executives (policy makers) are recognizing
that computers and computer-related problems must be understood
and managed, the same as any other resource. They are beginning
to understand the importance of setting policies, goals, and
standards for protection of data, information, and computer
resources, and are committing resources for information security
programs. They are also learning that primary responsibility for
data security must rest with the managers of the functional areas
supported by the data.
All managers who use any type of automated information resource
system must become familiar with their agency's policies and
procedures for protecting the information which is processed and
stored within them. Adequately secure systems deter, prevent, or
detect unauthorized disclosure, modification, or use of
information. Agency information requires protection from
intruders, as well as from employees with authorized computer
access privileges who attempt to perform unauthorized actions.
Protection is achieved not only by technical, physical and
personnel safeguards, but also by clearly articulating and
implementing agency policy regarding authorized system use to
information users and processing personnel at all levels. This
guide is one of three brochures that have been designed for a
specific audience. The "Executive Guide to the Protection of
Information Resources" and the "Computer User's Guide to the
Protection of Information Resources" complete the series.
Well, here is the Management Guide, use it to your advantage.
$_Purpose of this Guide
This guide introduces information systems security concerns and
outlines the issues that must be addressed by all agency managers
in meeting their responsibilities to protect information systems
within their organizations. It describes essential components of
an effective information resource protection process that applies
to a stand alone personal computer or to a large data processing
Effort is required by every Federal agency to safeguard
information resources and to reduce risks to a prudent level.
The spread of computing power to individual employees via
personal computers, local-area networks, and distributed
processing has drastically changed the way we manage and control
information resources. Internal controls and control points that
were present in the past when we were dealing with manual or
batch processes have not been established in many of today's
automated systems. Reliance upon inadequately controlled computer
systems can have serious consequences, including:
Inability or impairment of the agency's ability to perform its
Inability to provide needed services to the public
Waste, loss, misuse, or misappropriation of funds
Loss of credibility or embarrassment to an agency
To avoid these consequences, a broad set of information security
issues must be effectively and comprehensively addressed.
All functional managers have a responsibility to implement the
policies and goals established by executive management for
protection of automated information resources (data, processes,
facilities, equipment, personnel, and information). Managers in
all areas of an organization are clearly accountable for the
protection of any of these resources assigned to them to enable
them to perform their duties. They are responsible for
developing, administering, monitoring, and enforcing internal
controls, including security controls, within their assigned
areas of authority. Each manager's specific responsibilities will
vary, depending on the role that manager has with regard to
Portions of this document provide more detailed information on
the respective security responsibilities of managers of computer
resources, managers responsible for information systems
applications and the personnel security issues involved.
However, all agency management must strive to:
$_Achieve Cost-Effective Security
The dollars spent for security measures to control or contain
losses should never be more than the projected dollar loss if
something adverse happened to the information resource.
Cost-effective security results when reduction in risk through
implementation of safeguards is balanced with costs. The greater
the value of information processed, or the more severe the
consequences if something happens to it, the greater the need
for control measures to protect it.
The person who can best determine the value or importance of
data is the functional manager who is responsible for the data.
For example, the manager responsible for the agency's budget
program is the one who should establish requirements for the
protection of the automated data which supports the program. This
manager knows better than anyone else in the organization what
the impact will be if the data is inaccurate or unavailable.
Additionally, this manager usually is the supervisor of most of
the users of the data.
It is important that these trade-offs of cost versus risk
reduction be explicitly considered, and that management
understand the degree of risk remaining after selected controls
$_Assure Operational Continuity
With ever-increasing demands for timely information and greater
volumes of information being processed, the threat of information
system disruption is a very serious one. In some cases,
interruptions of only a few hours are unacceptable. The impact
due to inability to process data should be assessed, and actions
should be taken to assure availability of those systems
considered essential to agency operation. Functional management
must identify critical computer applications and develop
contingency plans so that the probability of loss of data
processing and telecommunications support is minimized.
Integrity of information means you can trust the data and the
processes that manipulate it. Not only does this mean that errors
and omissions are minimized, but also that the information system
is protected from deliberate actions to wrongfully change the
data. Information can be said to have integrity when it
corresponds to the expectations and assumptions of the users.
Confidentiality of sensitive data is often, but not always, a
requirement of agency systems. Privacy requirements for personal
information is dictated by statute, while confidentiality of
other agency information is determined by the nature of that
information, e.g., information submitted by bidders in
procurement actions. The impact of wrongful disclosure must be
considered in understanding confidentiality requirements.
$_Comply with Applicable Laws and Regulations
As risks and vulnerabilities associated with information systems
become better understood, the body of law and regulations
compelling positive action to protect information resources
grows. OMB Circular No. A-130, "Management of Federal
Information Resources" and Public Law 100-235, "Computer Security
Act of 1987" are two documents where the knowledge of these
regulations and laws provide a baseline for an information
resource security program.
$_Information Systems Development
This section describes the protective measures that should be
included as part of the design and development of information
processing application systems. The functional manager that is
responsible for and will use the information contained in the
system, must ensure that security measures have been included and
are adequate. This includes applications designed for personal
computers as well as large mainframes.
The official responsible for the agency function served by the
automated information system has a critical role in making
decisions regarding security and control. In the past, risk was
often unconsciously accepted when such individuals assumed the
computer facility operators were taking care of security. In
fact, there are decisions to be made and security elements to be
provided that cannot be delegated to the operator of the system.
In many cases, the user or manager develops the application and
The cost of control must be balanced with system efficiency and
usability issues. Risk must be evaluated and cost-effective
controls selected to provide a prudent level of control while
maximizing productivity. Controls are often closely connected
with the system function, and cannot be effectively designed
without significant understanding of the process being automated.
There are some common security attributes that should be present
in any system that processes valuable personal or sensitive
information. System designs should include mechanisms to enforce
the following security attributes.
$_Identification and Authentication of Users
Each user of a computer system should have a unique
identification on the system, such as an account number or other
user identification code. There must also be a means of verifying
that the individual claiming that identity (e.g., by typing in
that identifying code at a terminal) is really the authorized
individual and not an imposter. The most common means of
authentication is by a secret password, known only to the
$_Authorization Capability Enforcing the Principle of Least
Beyond ensuring that only authorized individuals can access the
system, it is also necessary to limit the users access to
information and transaction capabilities. Each person should be
limited to only the information and transaction authority that is
required by their job responsibilities. This concept, known as
the principle of least possible privilege, is a long-standing
control practice. There should be a way to easily assign each
user just the specific access authorities needed.
>From both a control and legal point of view, it is necessary to
maintain records of the activities performed by each computer
user. The requirements for automated audit trails should be
developed when a system is designed. The information to be
recorded depends on what is significant about each particular
system. To be able to hold individuals accountable for their
actions, there must be a positive means of uniquely identifying
each computer user and a routinely maintained record of each
Audit mechanisms detect unusual events and bring them to the
attention of management. This commonly occurs by violation
reporting or by an immediate warning to the computer system
operator. The type of alarm generated depends on the seriousness
of the event.
A common technique to detect access attempts by unauthorized
individuals is to count attempts. The security monitoring
functions of the system can automatically keep track of
unsuccessful attempts to gain access and generate an alarm if the
attempts reach an unacceptable number.
A basic design consideration for any information system should
be the ability to verify that the system is functioning as
intended. Systems that are developed without such design
considerations are often very difficult to independently audit or
review, leading to the possibility of unintended results or
Because Federal agencies can potentially be heavily dependent on
a computer system, an important design consideration is the
ability to easily recover from troublesome events, whether minor
problems or major disruptions of the system. From a design point
of view, systems should be designed to easily recover from minor
problems, and to be either transportable to another backup
computer system or replaced by manual processes in case of major
disruption or loss of computer facility.
Once the automated system is ready to use, decisions must be
made regarding access to the system and the information it
contains. For example, many individuals require the ability to
access and view data, but not the ability to change or delete
data. Even when computer systems have been designed to provide
the ability to narrowly designate access authorities, a
knowledgeable and responsible official must actually make those
access decisions. The care that is taken in this process is a
major determining factor of the level of security and control
present in the system. If sensitive data is being transmitted
over unprotected lines, it can be intercepted or passive
eavesdropping can occur. Encrypting the files will make the data
unintelligible and port protection devices will protect the files
from unauthorized access, if warranted.
$_Systems Development Process
All information systems software should be developed in a
controlled and systematic manner according to agency standards.
The quality and efficiency of the data processed, and the
possible reconfiguration of the system can all be affected by an
inadequate development process. The risk of security exposures
and vulnerabilities is greatly reduced when the systems
development process is itself controlled.
$_Computer Facility Management
Functional managers play a critical role in assuring that agency
information resources are appropriately safeguarded. This section
describes the protective measures that should be incorporated
into the ongoing management of information resource processing
facilities. As defined in OMB Circular No. A-130, "Management of
Federal Information Resources," the term "information technology
facility" means an organizationally defined set of personnel,
hardware, software, and physical facilities, a primary function
of which is the operation of information technology. This
section, therefore applies to any manager who houses a personal
computer, mainframe or any other form of office system or
Information cannot be appropriately protected unless the
facilities that house the equipment are properly protected from
physical threats and hazards. The major areas of concern are
For many types of computer equipment, strict environmental
conditions must be maintained. Manufacturer's specifications
should be observed for temperature, humidity, and electrical
$_Control of Media
The media upon which information is stored should be carefully
controlled. Transportable media such as tapes and cartridges
should be kept in secure locations, and accurate records kept of
the location and disposition of each. In addition, media from an
external source should be subject to a check-in process to ensure
it is from an authorized source.
$_Control of Physical Hazards
Each area should be surveyed for potential physical hazards.
Fire and water are two of the most damaging forces with regard to
computer systems. Opportunities for loss should be minimized by
an effective fire detection and suppression mechanism, and
planning reduces the danger of leaks or flooding. Other physical
controls include reducing the visibility of the equipment and
strictly limiting access to the area or equipment.
Although risks can be minimized, they cannot be eliminated. When
reliance upon a computer facility or application is substantial,
some type of contingency plan should be devised to allow critical
systems to be recovered following a major disaster, such as a
fire. There are a number of alternative approaches that should be
evaluated to most cost-effectively meet the agency's need for
continuity of service.
Risk can be introduced through unofficial and unauthorized
hardware or software. Another key component of information
resource management is ensuring only authorized hardware and
software are being utilized. There are several control issues to
$_Maintaining Accurate Records
Records of hardware/software inventories, configurations, and
locations should be maintained and kept up-to-date.
$_Complying with Terms of Software Licenses
Especially with microcomputer software, illegal copying and
other uses in conflict with licensing agreements are concerns.
The use of software subject to licensing agreements must be
monitored to ensure it is used according to the terms of the
$_Protecting Against Malicious Software and Hardware
The recent occurrences of destructive computer "viruses" point
to the need to ensure that agencies do not allow unauthorized
software to be introduced to their computer environments.
Unauthorized hardware can also contain hidden vulnerabilities.
Management should adopt a strong policy against unauthorized
hardware/software, inform personnel about the risks and
consequences of unauthorized additions to computer systems, and
develop a monitoring process to detect violations of the policy.
Management must ensure that appropriate security mechanisms are
in place that allow responsible officials to designate access to
data according to individual computer users' specific needs.
Security mechanisms should be sufficient to implement individual
authentication of system users, allow authorization to specific
information and transaction authorities, maintain audit trails as
specified by the responsible official, and encrypt sensitive
files if required by user management.
$_Monitoring and Review
A final aspect of information resource protection to be
considered is the need for ongoing management monitoring and
review. To be effective, a security program must be a continuous
effort. Ideally, ongoing processes should be adapted to include
information protection checkpoints and reviews. Information
resource protection should be a key consideration in all major
computer system initiatives.
Earlier, the need for system audit trails was discussed. Those
audit trails are useful only if management regularly reviews
exception items or unusual activities. Irregularities should be
researched and action taken when merited. Similarly, all
information-related losses and incidents should be investigated.
A positive benefit of an effective monitoring process is an
increased understanding of the degree of information-related risk
in agency operations. Without an ongoing feedback process,
management may unknowingly accept too much risk. Prudent
decisions about trade-offs between efficiency and control can
only be made with a clear understanding of the degree of inherent
risk. Every manager should ask questions and periodically review
operations to judge whether changes in the environment have
introduced new risk, and to ensure that controls are working
Managers must be aware that information security is more a
people issue than a technical issue. Personnel are a vital link
in the protection of information resources, as information is
gathered by people, entered into information resource systems by
people, and ultimately used by people. Security issues should be
addressed with regard to:
People who use computer systems and store information in the
course of their normal job responsibilities
People who design, program, test, and implement critical or
People who operate computer facilities that process critical or
>From the point of hire, individuals who will have routine access
to sensitive information resources should be subject to special
security procedures. More extensive background or reference
checks may be appropriate for such positions, and security
responsibilities should be explicitly covered in employee
orientations. Position descriptions and performance evaluations
should also explicitly reference unusual responsibilities
affecting the security of information resources.
Individuals in sensitive positions should be subject to job
rotation, and work flow should be designed in such a way as to
provide as much separation of sensitive functions as possible.
Upon decision to terminate or notice of resignation, expedited
termination or rotation to less sensitive duties for the
remainder of employment is a reasonable precaution.
Any Federal computer user who deliberately performs or attempts
to perform unauthorized activity should be subject to
disciplinary action, and such disciplinary action must be
uniformly applied throughout the agency. Any criminal activity
under Federal or state computer crime laws must be reported to
law enforcement authorities.
Most information resource security problems involve people.
Problems can usually be identified in their earliest stages by
people who are attuned to the importance of information
protection issues. A strong training program will yield large
benefits in prevention and early detection of problems and
losses. To be most effective, training should be tailored to the
particular audience being addressed, e.g., executives and policy
makers; program and functional managers; IRM security and audit:
ADP management and operations; end users.
Most employees want to do the right thing, if agency
expectations are clearly communicated. Internal policies can be
enforced only if staff have been made aware of their individual
responsibilities. All personnel who access agency computer
systems should be aware of their responsibilities under agency
policy, as well as obligations under the law. Disciplinary
actions and legal penalties should be communicated.
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