[Federal Register Volume 60, Number 63 (Monday, April 3, 1995)]
[Notices]
[Pages 16970-16977]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-8055]
[[Page 16969]]
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Part IV
Office of Management and Budget
_______________________________________________________________________
Security of Federal Automated Information; Notice
Federal Register / Vol. 60, No. 63 / Monday, April 3, 1995 / Notices
[[Page 16970]]
OFFICE OF MANAGEMENT AND BUDGET
Security of Federal Automated Information
AGENCY: Office of Management and Budget, Executive Office of the
President.
ACTION: Proposed revision of OMB Circular No. A-130 Appendix III.
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SUMMARY: The Office of Management and Budget (OMB) is proposing to
revise Appendix III of Circular No. A-130, ``Security of Federal
Automated Information Systems.'' This is the third stage of revisions
to Circular No. A-130, ``Management of Federal Information Resources.''
The first stage addressed information management policy (Section 8a)
and Appendix I, ``Federal Agency Responsibilities for Maintaining
Records About Individuals'' (June 25, 1993). That revision focussed on
information exchanges with the public. The second revision addressed
agency management practices for information systems and information
technology (Section 8b) (July 25, 1994). That revision was intended to
(1) promote agency investments in information technology that improve
service delivery to the public, reduce burden on the public, and lower
the cost of Federal programs administration, and (2) encourage agencies
to use information technology as a strategic resource to improve
Federal work processes and organization.
This proposal is intended to guide agencies in securing information
as they increasingly rely on an open and interconnected National
Information Infrastructure. It stresses management controls such as
individual responsibility, awareness and training, and accountability,
rather than technical controls. For example, it would require agencies
to assure that risk-based rules of behavior are established, that
employees are trained in them, and that the rules are enforced. The
proposal would also better integrate security into program and mission
goals, reduce the need for centralized reporting of paper security
plans, emphasize the management of risk rather than its measurement and
revise government-wide security responsibilities to be consistent with
the Computer Security Act.
DATES: Persons who wish to comment on the proposed revision to OMB
Circular No. A-130, Appendix III should submit their comments no later
than June 2, 1995.
ADDRESSES: Comments should be addressed to: Information Policy and
Technology Branch, Office of Information and Regulatory Affairs, Office
of Management and Budget, Room 10236, New Executive Office Building,
Washington, DC 20503.
Electronic Availability and Comments. This document is available on
the Internet via anonymous File Transfer Protocol (FTP) from the
National Institute of Standards and Technology (NIST) Computer Security
Resource Clearinghouse at csrc.ncsl.nist.gov as /pub/secplcy/
a130app3.txt (do not use any capital letters in the file name) or via
the World Wide Web from http://csrc.ncsl.nist.gov/secplcy as
a130app3.txt. The clearinghouse can also be reached using dial-in
access at 301-948-5717. For those who do not have file transfer
capability, the document can be retrieved via mail query by sending an
electronic mail message to docserver@csrc.ncsl.nist.gov with no subject
and with send a130app3.txt as the first line of the body of the
message. Comments may be sent via electronic mail to a130@a1.eop.gov
(note that the address contains the number 1 not the letter L) and will
be included as part of the official record. For assistance using FTP,
mail query, or electronic mail, please contact your system
administrator.
FOR FURTHER INFORMATION CONTACT: Ed Springer, Information Policy and
Technology Branch, Office of Information and Regulatory Affairs, Office
of Management and Budget, Room 10236, New Executive Office Building,
Washington, D.C. 20503. Telephone: (202) 395-3785.
SUPPLEMENTARY INFORMATION: Since December 30, 1985, Appendix III of
Office of Management and Budget (OMB) Circular No. A-130, ``Security of
Federal Automated Information Systems,'' has defined a minimum set of
controls for the security of Federal automated information systems.
That Appendix, and its predecessor, Transmittal Memorandum No. 1 to OMB
Circular No. A-71, (July 27, 1978), defined controls that were
effective in a centralized processing environment which ran primarily
custom-developed application software.
Today's computing environment is significantly different. It is
characterized by open, widely distributed processing systems which
frequently operate with commercial off-the-shelf software. This shift
has increased both risks and vulnerabilities. Greater risks result from
increasing quantities of valuable information being committed to
Federal systems, and from agencies being critically dependent on those
systems to perform their missions. Greater vulnerabilities exist
because virtually every Federal employee has access to Federal systems,
and because these systems now interconnect with outside systems.
In part because of these trends, Congress enacted the Computer
Security Act of 1987. That Act requires agencies to improve the
security of Federal computer systems, plan for the security of
sensitive systems, and provide mandatory awareness and training in
security for all individuals with access to computer systems.
To assist agencies in implementing the Computer Security Act, OMB
issued Bulletin No. 88-16, ``Guidance for Preparation and Submission of
Security Plans for Federal Computer Systems Containing Sensitive
Information'' (July 6, 1988), and OMB Bulletin No. 90-08, ``Guidance
for Preparation of Security Plans for Federal Computer Systems That
Contain Sensitive Information'' (July 9, 1990). This proposed revision
of Appendix III to OMB Circular A-130 incorporates and updates the
policies set out in those Bulletins.
The report of the National Performance Review, ``Creating a
Government That Works Better and Costs Less: Reengineering Through
Information Technology'' (September 1993), recommends that Circular A-
130 be revised to: (1) Require an information security plan to be part
of each agency's strategic IT plan; (2) require that computer security
be identified as a material weakness in the Federal Managers' Financial
Integrity Act report, if security does not meet established thresholds;
(3) require awareness and training of employees and contractors; (4)
require that agencies improve planning for contingencies; and (5)
establish and employ formal emergency response capabilities. Those
recommendations are incorporated in this proposed revision.
Since its establishment by the Computer Security Act, the Computer
System Security and Privacy Advisory Board has recommended changes in
Circular A-130 to: (1) Require that agencies establish computer
emergency response teams and (2) link oversight of Federal computer
security activities more closely to the oversight established pursuant
to the Federal Managers' Financial Integrity Act (FMFIA). The proposed
Appendix incorporates both of those recommendations.
Subsequent to issuance of Bulletin 90-08, OMB, the National
Institute of Standards and Technology (NIST), and the National Security
Agency (NSA) met with 28 Federal departments and agencies to review
their computer [[Page 16971]] security programs. In February 1993, the
three agencies issued a report (``Observations of Agency Computer
Security Practices and Implementation of OMB Bulletin No. 90-08'')
which summarized those meetings and proposed several changes in OMB
Circular A-130 as next steps to improving the Federal computer security
program. Those proposed changes are incorporated in the proposed
Appendix.
Where an agency processes information which is controlled for
national security reasons pursuant to an Executive Order or statute,
security measures required by appropriate directives should be included
in agency systems. Those policies, procedures and practices will be
coordinated with the U.S. Security Policy Board as directed by the
President.
The Proposed Appendix
The Appendix proposes to reorient the Federal computer security
program to better respond to a rapidly changing technological
environment. It establishes government-wide responsibilities for
Federal computer security and requires Federal agencies to adopt a
minimum set of management controls.
These management controls are directed at individual information
technology users in order to reflect the distributed nature of today's
technology. For security to be most effective, the controls must be
part of day-to-day operations. This is best accomplished by planning
for security not as a separate activity, but as part of overall
planning.
``Adequate security'' is defined as ``security commensurate with
the risk and magnitude of harm resulting from the loss, misuse, or
unauthorized access to or modification of information.'' This
definition explicitly emphasizes the risk-based policy for cost-
effective security established by the Computer Security Act.
The Appendix would no longer require the preparation of formal risk
analyses. In the past, substantial resources have been expended doing
complex analyses of risks to systems, with limited tangible benefit in
terms of improved security for the systems. Rather than continue to try
to precisely measure risk, security efforts are better served by
generally assessing risks and taking actions to manage them. While
complex risk analyses need not be performed, the need to determine
adequate security will require that a risk-based approach be used. This
approach should include a consideration of the major factors in risk
management: the value of the system or application, threats,
vulnerabilities, and the effectiveness of current or proposed
safeguards.
Automated Information Security Programs
Agencies are required to establish controls to assure adequate
security for all information processed, transmitted, or stored in
Federal automated information systems. This proposal emphasizes
management controls affecting individual users of information
technology. Technical and operational controls are linked to management
controls regarding user behavior. Four interrelated management controls
are proposed: assigning responsibility for security, security planning,
periodic review of security controls, and management authorization.
The Appendix requires that these management controls be applied in
two areas of management responsibility: one for general support systems
and one for major applications. The terms ``general support system''
and ``major application'' were used in OMB Bulletin Nos. 88-16 and 90-
08. A general support system is ``an interconnected set of information
resources under the same direct management control which shares common
functionality.'' Such a system can be, for example, a local area
network (LAN) including smart terminals that support a branch office,
an agency-wide backbone, a communications network, a departmental data
processing center including its operating system and utilities, a
tactical radio network, or a shared information processing service
organization. Normally, the purpose of a general support system is to
provide processing or communications support.
A major application is a use of information and information
technology to satisfy a specific set of user requirements that requires
special management attention to security due to the risk and magnitude
of harm resulting from the loss, misuse or unauthorized access to or
modification of the information in the application. All Federal
information requires some level of protection. However, certain
applications, because of the information in them, require special
management oversight and should be treated as major. Adequate security
for other applications should be provided by security of the general
support systems in which they operate.
The focus of OMB Bulletins No. 88-16 and 90-08 was on identifying
and securing both general support systems and applications which
contained sensitive information. The Appendix proposes to establish
security controls in all general support systems, under the presumption
that all contain some sensitive information, and focus extra security
controls on a limited number of particularly high risk or major
applications.
Discussion of the Appendix's Major Provisions.
The following discussion is provided to aid reviewers in
understanding the changes in emphasis proposed in the Appendix.
a. General Support Systems. The following controls are required in
all general support systems:
(1) Assign Responsibility for Security. For each system, an
individual should be a focal point for assuring there is adequate
security within the system, including ways to prevent, detect, and
recover from security problems. That responsibility should be assigned
to an official trained in the technology used in the system and in
providing security for such technology.
(2) Security Plan. The Computer Security Act requires that security
plans be developed for all Federal computer systems that contain
sensitive information. Given the expansion of distributed processing
since passage of the Act, the presumption in the Appendix is that all
general support systems contain some sensitive information and
therefore require security plans.
Current guidance on security planning is contained in OMB Bulletin
90-08. The Appendix will supersede Section 6 of Bulletin 90-08. The
Appendix also expands the coverage of security plans to address rules
of individual behavior as well as technical security. Consistent with
OMB Bulletin 90-08, the Appendix directs NIST to update and expand
security planning guidance and issue it as a Federal Information
Processing Standard (FIPS). In the interim, agencies should continue to
use OMB Bulletin No. 90-08 as guidance for the technical portion of
their security plans.
The Appendix continues the requirement that independent advice and
comment on the security plan for each system be sought. The intent of
this requirement is to improve the plans, foster communication between
managers of different systems, and promote the sharing of security
expertise.
The following specific security controls should be included in the
security plan for a general support system:
(a) Rules. An important new requirement for security plans is the
establishment of a set of rules of [[Page 16972]] behavior for
individual users of each general support system. These rules should
clearly delineate responsibilities of and expectations for all
individuals with access to the system. In addition, they should state
the consequences of non-compliance. The rules should be in writing and
will form the basis for security awareness and training.
The development of rules for a system must take into consideration
the needs of all parties who use the system. Rules should be as
stringent as necessary to provide adequate security. Therefore, the
acceptable level of risk for the system must be established and should
form the basis for determining the rules.
Rules should cover such matters as work at home, dial-in access,
connection to the Internet, use of copyrighted software, unofficial use
of government equipment, the assignment and limitation of system
privileges, and individual accountability. Often rules will address
technical security controls in the system. For example, rules regarding
password use should be consistent with technical password features in
the system. In addition, the rules should specifically address
restoration of service as a concern of all users of the system.
(b) Awareness and Training. The Computer Security Act requires
mandatory periodic training for everyone with access to Federal
computer systems. This includes contractors, employees of other
agencies, and members of the public. The Appendix proposes to enforce
such mandatory awareness and training by requiring its completion prior
to granting access to the system. Each new user, in some sense,
introduces a risk to all other users of a general support system.
Therefore, each user should be versed in acceptable behavior--the rules
of the system--before being allowed to use the system. Awareness and
training should also inform the individual how to get help in the event
of difficulty with using or security of the system.
Awareness and training should be tailored to what a user needs to
know to use the system securely, given the nature of that use.
Awareness and training may be presented in stages, for example as more
access is granted. In some cases, the awareness and training should be
in the form of classroom instruction. In other cases, interactive
computer sessions or well-written and understandable brochures may be
sufficient, depending on the risk and magnitude of harm.
Over time, attention to security tends to atrophy. In addition,
changes to a system may necessitate a change in the rules or user
procedures. Therefore, individuals should periodically have refresher
training to assure that they continue to understand and abide by the
applicable rules.
To assist agencies, the Appendix proposes that NIST, with
assistance from the Office of Personnel Management (OPM), update its
existing awareness and training guidance. It also proposes that OPM
assure that its rules for computer security training for Federal
civilian employees are effective.
(c) Personnel Controls. It has long been recognized that the
greatest harm comes from authorized users engaged in improper
activities, whether intentional or accidental. In every general support
system, a number of technical, operational, and management controls are
used to prevent and detect harm. Such controls include individual
accountability, ``least privilege,'' and separation of duties.
Individual accountability consists of holding someone responsible
for his or her actions. In a general support system, accountability is
normally accomplished by identifying and authenticating users of the
system and subsequently tracing actions on the system to the user who
initiated them.
Least privilege is the practice of restricting a user's access (to
data files, to processing capability, or to peripherals) or type of
access (read, write, execute, delete) to the minimum necessary to
perform his or her job.
Separation of duties is the practice of dividing the steps in a
critical function among different individuals. For example, one system
programmer can create critical operating system code, while another
authorizes its implementation. Such a control keeps a single individual
from subverting a critical process.
Nevertheless, in some instances, individuals may be given the
ability to bypass technical and operational controls in order to
perform system administration and maintenance functions. Screening such
individuals in positions of trust will supplement technical,
operational, and management controls, particularly where the risk and
magnitude of loss or harm is high.
(d) Incident Response Capability. Security incidents, whether
caused by viruses, hackers, or software bugs, are becoming more common.
When faced with a security incident, an agency should be able to
respond in a manner that both protects its own information and helps to
protect the information of others who might be affected by the
incident. To address this concern, agencies should establish formal
incident response mechanisms. Awareness and training for individuals
with access to the system should include how to use the system's
incident response capability.
To be fully effective, incident handling must also include sharing
information concerning common vulnerabilities and threats with those in
other systems. Agencies should coordinate assistance and sharing
through the Forum of Incident Response & Security Teams (FIRST).
The Appendix also directs the Department of Justice to develop
guidance on pursuing legal remedies in the case of serious incidents.
(e) Continuity of Support. Inevitably, there will be service
interruptions. Agency plans should assure that there is an ability to
recover and provide service sufficient to meet the minimal needs of
users of the system. Moreover, manual procedures are generally NOT a
viable back-up option. When automated support is not available, many
functions of the organization will effectively cease. Therefore, it is
important to take cost-effective steps to manage any disruption of
service.
Decisions on the level of service needed at any particular time and
on priorities in service restoration should be made in consultation
with the users of the system and incorporated in the system rules.
Experience has shown that recovery plans that are periodically tested
are substantially more viable than those that are not. Moreover,
untested plans may actually create a false sense of security.
(f) Technical Security. Agencies should assure that each system
appropriately uses effective security products and techniques,
consistent with standards and guidance from NIST. Often such techniques
will correspond with system rules of behavior such as in the proper use
of password protection.
The Appendix directs NIST to continue to issue computer security
guidance to assist agencies in planning for and using technical
security products and techniques. Until such guidance is issued,
however, the planning guidance included in OMB Bulletin 90-08 can
assist in determining techniques for effective security in a system and
in addressing technical controls in the security plan.
(g) System Interconnection. In order for a community to effectively
manage risk, it must control access to and from other systems. The
degree of such control should be established in the rules of the system
and all participants should be made aware of any limitations on outside
access. Technical controls to accomplish this should be put in place in
accordance with guidance issued by NIST. [[Page 16973]]
There are varying degrees of how connected a system is. For
example, some systems will choose to isolate themselves, others will
restrict access such as allowing only e-mail connections or remote
access only with advanced authentication, and others will be fully
open. The management decision to interconnect should be based on the
availability and use of technical and non-technical safeguards and
consistent with the acceptable level of risk defined in the system
rules.
(3) Review of Security Controls. The security of a system will
degrade over time, as the technology evolves and as people and
procedures change. Reviews should assure that management, operational,
personnel, and technical controls are functioning effectively. Security
controls may be reviewed by an independent audit or a self review. The
type and rigor of review or audit should be commensurate with the
acceptable level of risk that is established in the rules for the
system and the likelihood of learning useful information to improve
security. Technical tools such as virus scanners, vulnerability
assessment products (which look for known security problems,
configuration errors, and the installation of the latest patches), and
penetration testing can assist in the on-going review of different
facets of systems. However, these tools are no substitute for a formal
management review at least every three years. Indeed, for some high-
risk systems with rapidly changing technology, three years will be too
long.
Depending upon the risk and magnitude of loss or harm that could
result, weaknesses identified during the review of security controls
should be reported as deficiencies in accordance with OMB Circular No.
A-123, ``Management Accountability and Control'' and the Federal
Managers' Financial Integrity Act. In particular, if a basic management
control such as assignment of responsibility, a workable security plan,
or management authorization are missing, then consideration should be
given to identifying a deficiency.
(4) Authorize Processing. The authorization of a system to process
information, granted by a management official, provides an important
quality control. By authorizing processing in a system, a manager
accepts the risk associated with it. Authorization is not a decision
that should be made by the security staff. Some agencies refer to this
authorization as an accreditation.
Both the security official and the authorizing management official
have security responsibilities. In general, the security official is
closer to the day-to-day operation of the system and will direct or
perform security tasks. The authorizing official will normally have
general responsibility for the organization supported by the system.
Management authorization should be based on an assessment of
management, operational, and technical controls. Since the security
plan establishes the security controls, it should form the basis for
the authorization, supplemented by more specific studies as needed. In
addition, the periodic review of controls should also contribute to
future authorizations. Some agencies perform ``certification reviews''
of their systems periodically. These formal technical evaluations lead
to a management accreditation, or ``authorization to process.'' Such
certifications (such as those using the methodology in FIPS Pub 102
``Guideline for Computer Security Certification and Accreditation'')
can provide useful information to assist management in authorizing a
system, particularly when combined with a review of the broad
behavioral controls envisioned in the security plan required by the
Appendix.
b. Controls in Major Applications. Certain applications require
special management attention due to the risk and magnitude of loss or
harm that could occur. For such applications, the controls of the
support system(s) in which they operate are likely to be insufficient.
Therefore, additional controls specific to the application are
required. Since the function of applications is the direct manipulation
and use of information, controls for securing applications should
emphasize protection of information and the way it is manipulated.
(1) Assign Responsibility for Security. By definition, major
applications are high risk and require special management attention.
Major applications usually support a single agency function and often
are supported by more than one general support system. It is important,
therefore, that an individual be assigned responsibility to assure that
the particular application has adequate security. To be effective, this
individual should be knowledgeable in the information processed by the
application and in the management, operational, and technical controls
used to protect the application.
(2) Application Security Plans. Security for each major application
should be addressed by a security plan specific to the application. The
plan should include controls specific to protecting information and
should be developed from the application manager's perspective. To
assist in assuring its viability, the plan should be shown to the
manager of the primary support system which the application uses for
advice and comment. This recognizes the critical dependence of the
security of major applications on the underlying support systems they
use.
(a) Application Rules. Rules of behavior should be established
which delineate the responsibilities and expected behavior of all
individuals with access to the application. The rules should state the
consequences of inconsistent behavior. Such rules should include, for
example, limitations on changing data, searching data bases, or
divulging information.
(b) Specialized Awareness and Training. Awareness and training
should vary depending on the type of access allowed and the risk that
access represents to the security of information in the application.
This training will be in addition to that required for access to a
support system.
(c) Personnel Security. For most major applications, management
controls such as individual accountability requirements, separation of
duties enforced by access controls, or limitations on the processing
privileges of individuals, are generally more cost-effective personnel
security controls than background screening. If adequate audit or
access controls (through both technical and non-technical methods)
cannot be established, then it may be cost-effective to screen
personnel.
(d) Contingency Planning. Normally the Federal mission supported by
a major application is critically dependent on the application. Manual
processing is generally NOT a viable back-up option. Managers should
plan for how they will perform their mission and/or recover from the
loss of existing application support in the event of an emergency.
Experience has demonstrated that testing a contingency plan
significantly improves its viability. Indeed, untested plans may create
a false sense of ability to recover in a timely manner.
(e) Technical Controls. Technical security controls, for example
software edits that limit data that can be entered into certain files,
should be built into each application. Often these controls will
correspond with the rules of behavior for the application. Under the
current Appendix, application security is focused on the process by
which sensitive, custom applications are developed. Given the
increasing reliance on commercial off-the-shelf software, that process
is not addressed in detail in this Appendix. However, some custom-
developed applications will remain. For them the technical
[[Page 16974]] security controls defined in OMB Bulletin No. 90-08 will
continue, until that guidance is replaced by NIST's security planning
guidance.
(f) Information Sharing. Assure that information which is shared
with Federal organizations, State and local governments, and the
private sector is appropriately protected relative to the protection
provided when the information is within the application. Controls on
the information may stay the same or vary when the information is
shared with another entity. For example, the primary user of the
information may require a high level of availability while the
secondary user does not, and can therefore relax some of the controls
designed to maintain the availability of the information. At the same
time, however, the information shared may require a level of
confidentiality that should be extended to the secondary user. This may
require agreements to protect such information prior to its being
shared.
(g) Public Access Controls. Permitting public access to a Federal
application is an important method of improving information exchange
with the public. At the same time, it introduces risks to the Federal
application. To mitigate these risks, additional controls should be in
place as appropriate. These controls are in addition to controls such
as ``firewalls'' that are put in place for security of the general
support system.
In general, it is more difficult to apply conventional controls to
public access systems, because many of the users of the system may not
be subject to individual accountability policies. In addition, public
access systems may be a target for mischief because of their higher
visibility and published access methods.
Official records need to be protected against loss or alteration.
Official records in electronic form are particularly susceptible since
they can be relatively easy to change or destroy. Therefore, official
records should be segregated from information made directly accessible
to the public. There are different ways to segregate records. Some
agencies and organizations are creating dedicated information
dissemination systems (such as bulletin boards or World Wide Web
servers) to support this function. These systems can be on the outside
of secure gateways which protect internal agency records from outside
access.
In order to secure applications that allow direct public access,
conventional techniques such as least privilege (limiting the
processing capability as well as access to data) and integrity
assurances (such as checking for viruses, clearly labeling the age of
data, or periodically spot checking data) should also be used.
Additional guidance on securing public access systems is available from
NIST Computer Systems Laboratory Bulletin ``Security Issues in Public
Access Systems'' (May, 1993).
(3) Review of Application Controls. At least every three years, a
review or audit of the security controls for each major application
should be performed. Such reviews should verify that responsibility for
the security of the application has been assigned, that a viable
security plan for the application is in place, and that a manager has
authorized the processing of the application. A deficiency in any of
these controls should be considered a deficiency pursuant to the
Federal Manager's Financial Integrity Act and OMB Circular No. A-123,
``Management Accountability and Control.''
The review envisioned here is different than the system test and
certification process required in the current Appendix. That process,
however, remains useful for assuring that technical security features
are built into custom-developed software applications. While the
controls in that process are not specifically called for in the new
Appendix, they remain in Bulletin No. 90-08, and are recommended in
appropriate circumstances as technical controls.
(4) Authorize Processing. A major application should be
periodically authorized by the management official responsible for the
function supported by the application. The intent of this requirement
is to assure that the senior official whose mission will be adversely
affected by security weaknesses in the application periodically
assesses and accepts the risk of operating the application. The
authorization should be based on the application security plan and any
review(s) performed on the application. It should also take into
account the risks from the general support systems used by the
application.
4. Assignment of Responsibilities. The Appendix assigns government-
wide responsibilities to agencies that are consistent with their
missions and the Computer Security Act.
a. Department of Commerce. The Department of Commerce, through
NIST, is assigned the following responsibilities consistent with the
Computer Security Act.
(1) Develop and issue security standards and guidance.
(2) Review and update, with assistance from OPM, the guidelines for
security awareness and training issued in 1988 pursuant to the Computer
Security Act to assure they are effective.
(3) Replace and update the technical planning guidance in the
appendix to OMB Bulletin 90-08.
(4) Provide agencies with guidance and assistance concerning
effective controls for systems when interconnecting with other systems,
including the Internet. Such guidance on, for example, so-called
``firewalls'' is becoming widely available and is critical to agencies
as they consider how to interconnect their communications capabilities.
(5) Coordinate agency incident response activities. This is already
underway through the Forum for Incident Response Teams (FIRST).
(6) Assess security vulnerabilities in new information technologies
and apprise Federal agencies of such vulnerabilities. The intent of
this new requirement is to help agencies understand the security
implications of technology before they purchase and field it. In the
past, there have been too many instances where agencies have acquired
and implemented technology, then found out about vulnerabilities in the
technology and had to retrofit security measures. This activity is
intended to help avoid such difficulties in the future.
b. Security Policy Board. The Security Policy Board is assigned
responsibility for national security policy coordination in accordance
with appropriate Presidential directive.
c. Department of Defense. The Department, through the National
Security Agency, should provide technical advice and assistance to
NIST, including work products such as technical security guidelines,
which NIST can draw upon for developing standards and guidelines for
protecting sensitive information in Federal computers.
Also, the Department, through the National Security Agency, should
assist NIST in evaluating vulnerabilities in emerging technologies.
Such vulnerabilities may present a risk to national security
information as well as to unclassified information.
d. Office of Personnel Management. In accordance with the Computer
Security Act, the Office of Personnel Management should review its
regulations concerning computer security training and assure that they
are effective.
In addition, OPM should assist the Department of Commerce in the
review and update of its computer security awareness and training
guidelines. OPM worked closely with NIST in developing
[[Page 16975]] the current guidelines and should work with NIST in
revising those guidelines.
e. General Services Administration. The General Services
Administration should provide agencies guidance for addressing security
considerations when acquiring information technology products or
services. This continues the current requirement.
In addition, where cost-effective GSA should establish government-
wide contract vehicles for agencies to use to acquire certain security
services. Such vehicles already exist for providing system back-up
support and conducting security analyses.
GSA should also provide appropriate security services to assist
Federal agencies to the extent that provision of such services is cost-
effective. This includes providing, in conjunction with the Department
of Defense and the Department of Commerce, appropriate services which
support Federal use of the National Information Infrastructure (e.g.,
use of digital signature technology).
f. Department of Justice. The Department of Justice should provide
guidance to Federal agencies on legal remedies available to them when
serious security incidents occur. Such guidance should include ways to
report incidents and cooperate with law enforcement.
In addition, the Department should pursue appropriate legal actions
on behalf of the Federal government when serious security incidents
occur.
5. Reports. The Appendix requires agencies to provide two reports
to OMB:
The first is a requirement that agencies report security
deficiencies and material weaknesses within their FMFIA reporting
mechanisms as defined by OMB Circular No. A-123, ``Management
Accountability and Control,'' and take corrective actions in accordance
with that directive.
The second, defined by the Computer Security Act, requires that a
summary of agency security plans be included in the five-year
information resources management plan required by the Paperwork
Reduction Act.
Accordingly, Appendix III of Circular A-130 is proposed to be
revised to read as set forth below.
Sally Katzen.
Appendix III--To OMB Circular No. A-130, Security of Federal Automated
Information
1. Purpose
This Appendix establishes a minimum set of controls to be
included in Federal automated information security programs; assigns
Federal agency responsibilities for the security of automated
information; and links agency automated information security
programs and agency management control systems established in
accordance with OMB Circular No. A-123. The Appendix revises
procedures formerly contained in Appendix III to OMB Circular No. A-
130 (50 FR 52730; December 24, 1985), and incorporates requirements
of the Computer Security Act of 1987 (P.L. 100-235) and
responsibilities assigned in applicable national security
directives.
2. Definitions
The term:
a. ``adequate security'' means security commensurate with the
risk and magnitude of the harm resulting from the loss, misuse, or
unauthorized access to or modification of information. This includes
assuring that systems and applications used by the agency operate
effectively and provide appropriate confidentiality, integrity, and
availability, through the use of cost-effective management,
personnel, operational, and technical controls.
b. ``application'' means the use of information resources
(information and information technology) to satisfy a specific set
of user requirements.
c. ``general support system'' or ``system'' means an
interconnected set of information resources under the same direct
management control which share common functionality. A system
normally includes hardware, software, information, data,
applications, and people. A system can be, for example, a local area
network (LAN) including smart terminals that supports a branch
office, an agency-wide backbone, a communications network, a
departmental data processing center including its operating system
and utilities, a tactical radio network, or a shared information
processing service organization (IPSO).
d. ``major application'' means an application that requires
special attention to security due to the risk and magnitude of the
harm resulting from the loss, misuse, or unauthorized access to or
modification of the information in the application. Note: All
Federal information requires some level of protection. Certain
applications, because of the information in them, however, require
special management oversight and should be treated as major.
Adequate security for other applications should be provided by
security of the systems in which they operate.
3. Automated Information Security Programs. Agencies should
implement and maintain a program to assure that adequate security is
provided for all agency information collected, processed,
transmitted, stored, or disseminated in general support systems and
major applications.
Each agency's program should implement policies, standards and
procedures which are consistent with government-wide policies,
standards, and procedures issued by the Office of Management and
Budget, the Department of Commerce, the General Services
Administration and the Office of Personnel Management (OPM).
Different or more stringent requirements for securing national
security information should be incorporated into agency programs as
required by appropriate national security directives. At a minimum,
agency programs should include the following controls in their
general support systems and major applications:
a. Controls for general support systems.
(1) Assign Responsibility for Security. Assign responsibility
for security in each system to an official knowledgeable in the
information technology used in the system and in providing security
for such technology.
(2) System Security Plan. Plan for the security of each general
support system as part of the organization's information resources
management (IRM) planning process. The security plan should be
consistent with guidance issued by the National Institute of
Standards and Technology (NIST). Independent advice and comment on
the security plan should be solicited prior to the plan's
implementation. A summary of the security plans should be
incorporated into the 5-year IRM plan required by the Paperwork
Reduction Act (44 U.S.C. Chapter 35) and Section 8(b) of this
circular. Security plans should include:
(a) Rules of the System. Establish a set of rules of behavior
concerning use of, security in, and the acceptable level of risk for
the system. The rules should be based on the needs of the various
users of the system. The security required by the rules should be
only as stringent as necessary to provide adequate security for
information in the system. Such rules should clearly delineate
responsibilities and expected behavior of all individuals with
access to the system. They should also include appropriate limits on
interconnections to other systems and should define service
provision and restoration priorities. Finally, they should be clear
about the consequences of behavior not consistent with the rules.
(b) Awareness and Training. Ensure that all individuals are
aware of their security responsibilities and trained in how to
fulfill them before allowing them access to the system. Such
awareness and training should assure that individuals are versed in
the rules of the system, be consistent with guidance issued by NIST
and OPM, and apprise individuals about available assistance and
technical security products and techniques. Behavior consistent with
the rules of the system and periodic refresher training should be
required for continued access to the system.
(c) Personnel Controls. Screen all individuals who are
authorized to bypass technical and operational security controls of
the system (e.g., LAN administrators or system programmers)
commensurate with the risk and magnitude of loss or harm they could
cause. Such screening should occur prior to the individuals' being
authorized to bypass controls and periodically thereafter.
(d) Incident Response Capability. Ensure that there is a
capability to provide help to users when a security incident occurs
in the system and to share information concerning common
vulnerabilities and threats. This capability should coordinate with
those in other organizations and should assist the agency in
pursuing appropriate legal action, consistent with Department of
Justice guidance. [[Page 16976]]
(e) Continuity of Support. Establish and periodically test the
capability to continue providing service within a system based upon
the needs and priorities of the participants of the system.
(f) Technical Security. Ensure that cost-effective security
products and techniques are appropriately used within the system.
(g) System Interconnection. Obtain written management
authorization based upon the acceptance of risk to the system prior
to connecting with other systems. Where connection is authorized,
controls should be established which are consistent with the rules
of the system and in accordance with guidance from NIST.
(3) Review of Security Controls. Periodically review the
security controls in each system commensurate with the acceptable
level of risk for the system established in its rules, especially
when significant modifications are made and at least every 3 years.
Depending on the potential risk and magnitude of harm that could
occur, consider identifying a deficiency pursuant to OMB Circular
No. A-123, ``Management Accountability and Control'' and the Federal
Managers' Financial Integrity Act (FMFIA), if there is no assignment
of security responsibility, no security plan or no authorization to
process in a system.
(4) Authorize Processing. Ensure that a management official
authorizes in writing the use of each general support system based
on implementation of its security plan before beginning or
significantly changing processing in the system. Use of the system
should be reauthorized at least every three years.
b. Controls for Major Applications.
(1) Assign Responsibility for Security. Assign responsibility
for security of each major application to a management official
knowledgeable in the nature of the information processed by the
application and in the management, operational, and technical
controls used to protect it. This official should assure that
effective security products and techniques are appropriately used in
the application and should be contacted when a security incident
occurs concerning the application.
(2) Application Security Plan. Plan for the adequate security of
each major application, taking into account the security of all
systems in which the application will operate. The plan should be
consistent with guidance issued by NIST. Advice and comment on the
plan should be solicited from the official responsible for security
in the primary system in which the application will operate prior to
the plan's implementation. A summary of the security plans should be
incorporated into the 5-year IRM plan required by the Paperwork
Reduction Act. Application security plans should include:
(a) Application Rules. Establish a set of rules concerning use
of and behavior within the application. The rules should be as
stringent as necessary to provide adequate security for the
application and the information in it. Such rules should clearly
delineate responsibilities and expected behavior of all individuals
with access to the application. In addition, the rules should be
clear about the consequences of behavior not consistent with the
rules.
(b) Specialized Awareness and Training. Before allowing
individuals access to the application, ensure that all individuals
receive specialized awareness and training focused on their
responsibilities and the application rules. This may be in addition
to the awareness and training required for access to a system. Such
awareness and training may vary from a notification at the time of
access (e.g., for members of the public using an information
retrieval application) to formal training (e.g., for an employee
that works with a high risk application).
(c) Personnel Security. Incorporate controls such as separation
of duties, least privilege and individual accountability into the
application as appropriate. In cases where such controls cannot
adequately protect the application and information in it, screen
individuals commensurate with the risk and magnitude of the harm
they could cause. Such screening should be done prior to the
individuals being authorized to access the application and
periodically thereafter.
(d) Contingency Planning. Establish and periodically test the
capability to perform the agency function supported by the
application in the event of failure of its automated support.
(e) Technical Controls. Ensure that appropriate security
controls are specified, designed into, tested, and accepted in
accordance with guidance issued by NIST.
(f) Information Sharing. Ensure that information shared from the
application is protected appropriately, relative to the protection
provided when information is within the application.
(g) Public Access Controls. Where an agency's application
promotes or permits public access, additional security controls
should be added to protect the integrity of the application and the
confidence the public has in the application. Such controls should
include segregating information made directly accessible to the
public from official agency records (e.g., by putting information
onto a bulletin board).
(3) Review of Application Controls. Perform an independent
review or audit of the security controls in each application at
least every three years. Consider identifying a deficiency pursuant
to the Federal Managers' Financial Integrity Act if there is no
assignment of responsibility for security, no security plan, or no
authorization to process for the application.
(4) Authorize Processing. Ensure that a management official
authorizes in writing use of the application by confirming that its
security plan as implemented adequately secures the application.
Results of the most recent review or audit of controls should be a
factor in management authorizations. The application should be
authorized prior to operating and re-authorized at least every three
years thereafter. Management authorization implies accepting the
risk of each system used by the application.
4. Assignment of Responsibilities
a. Department of Commerce. The Secretary of Commerce should:
(1) Develop and issue appropriate standards and guidance for the
security of sensitive information in Federal computer systems.
(2) Review and update guidelines for training in computer
security awareness and accepted computer security practice, with
assistance from OPM.
(3) Provide agencies guidance for security planning to assist in
their development of application and system security plans.
(4) Provide guidance and assistance, as appropriate, to agencies
concerning effective controls when interconnecting with other
systems.
(5) Coordinate agency incident response activities to promote
sharing of incident response information and related
vulnerabilities.
(6) Evaluate new information technologies to assess their
security vulnerabilities, with technical assistance from the
Department of Defense, and apprise Federal agencies of such
vulnerabilities as soon as they are known.
b. Security Policy Board. The Security Policy Board should:
(1) Act, in accordance with applicable national security
directives, to coordinate the security activities of the Federal
Government regarding the security of automated information systems
that process national security information;
c. Department of Defense. The Secretary of Defense should:
(1) Provide appropriate technical advice and assistance
(including work products) to the Department of Commerce.
(2) Assist the Department of Commerce in evaluating the
vulnerabilities of emerging information technologies.
d. Office of Personnel Management. The Director of the Office of
Personnel Management should:
(1) Assure that its regulations concerning computer security
training for Federal civilian employees are effective.
(2) Assist the Department of Commerce in updating and
maintaining guidelines for training in computer security awareness
and accepted computer security practice.
e. General Services Administration. The Administrator of General
Services should:
(1) Assure that the Federal Information Resources Management
Regulation provides guidance to agencies on addressing security
considerations when acquiring automated data processing equipment
(as defined in section 111(a)(2) of the Federal Property and
Administrative Services Act of 1949, as amended)
(2) Facilitate the development of contract vehicles for agencies
to use in the acquisition of cost-effective security products and
services (e.g., back-up services contract).
(3) Provide appropriate security services to meet the needs of
Federal agencies to the extent that such services are cost-
effective.
f. Department of Justice. The Attorney General should:
(1) Provide guidance to agencies on legal remedies regarding
security incidents and ways to report and work with law enforcement
concerning such incidents.
(2) Pursue appropriate legal actions when security incidents
occur. [[Page 16977]]
5. Correction of Deficiencies and Reports
a. Correction of Deficiencies. Agencies shall correct
deficiencies which are identified through the reviews of security
for systems and major applications described above.
b. Reports on Deficiencies. In accordance with OMB Circular No.
A-123, if a deficiency in controls is judged by the agency head to
be material when weighed against other agency deficiencies, it
should be included in the annual FMFIA report. Less significant
deficiencies should be reported and progress on corrective actions
tracked at the appropriate agency level.
c. Summaries of Security Plans. Agencies shall include a summary
of their system security plans and major application plans in the
five-year plan required by the Paperwork Reduction Act (44 U.S.C.
3505).
[FR Doc. 95-8055 Filed 3-31-95; 8:45 am]
BILLING CODE 3110-01-P
