[ISN] ITL Bulletin for November 2004

InfoSec News isn at c4i.org
Tue Nov 30 01:49:12 EST 2004

Forwarded from: Elizabeth Lennon <elizabeth.lennon at nist.gov>

How Three Mandated Documents are Changing the Dynamic of 
Information Security for the Federal Government

By Ron Ross and Patricia Toth
Computer Security Division
Information Technology Laboratory
National Institute of Standards and Technology
Technology Administration
U.S. Department of Commerce

The Federal Information Security Management Act (FISMA) of 2002 places
significant requirements on federal agencies, including the National
Institute of Standards and Technology (NIST), for the protection of
information and information systems. In response to this important
legislation, NIST is leading the development of key information system
security standards and guidelines as part of its FISMA Implementation
Project. This high-priority project includes the development of
security categorization standards, standards and guidelines for the
specification, selection, and testing of security controls for
information systems. The flagship standard among those being developed
by NIST is Federal Information Processing Standards (FIPS) 199,
Standards for Security Categorization of Federal Information and
Information Systems, published in February 2004. This mandatory
standard, applicable to non-national security systems as defined by
FISMA, introduces some significant changes in how the U.S.  
Government protects its information and information systems, including
those systems that comprise the nation's critical infrastructure.

To gauge the impact of FIPS 199 on the massive inventory of federal
information systems, one must first understand how the world of
information technology has changed over the past two decades. Not long
ago, the information systems that populated federal enterprises
consisted of large, expensive, standalone mainframes, taking up a
significant amount of physical space in the facilities and consuming
substantial portions of organizational budgets. Information systems
were viewed as "big ticket items" requiring specialized policies and
procedures to effectively manage.

Today, information systems are more powerful, less costly (for the
equivalent computational capability), networked, and ubiquitous. The
systems, in most cases, are viewed by agencies as commodity items,
although items coupled more tightly than ever to the accomplishment of
agency missions.  However, as the technology raced ahead and brought a
new generation of information systems into the federal government with
new access methods and a growing community of users, some of the
policies, procedures, and approaches employed to ensure the protection
of those systems did not keep pace.

The Problem with the Old Way of Doing Business - Establishing

The administrative and technological costs of offering a high degree
of protection for all federal information systems at all times would
be prohibitive, especially in times of tight governmental budgets.
Achieving adequate, cost-effective information system security (as
defined in Office of Management and Budget Circular A-130, Appendix
III) in an era where information technology is a commodity requires
some fundamental changes in how the protection problem is addressed.
Information systems must be assessed to establish priorities based on
the importance of those systems to agency missions.

There is clearly a criticality and sensitivity continuum with regard
to agency information systems that affects the ultimate prioritization
of those systems. At one end of the continuum, there are high-priority
information systems performing very sensitive, mission-critical
operations, perhaps as part of the critical information
infrastructure.  At the other end of the continuum, there are
low-priority information systems performing routine agency operations.  
The application of safeguards and countermeasures (i.e., security
controls) to all these information systems should be tailored to the
individual systems based on established agency priorities (i.e., where
the systems fall on the continuum of criticality/sensitivity with
regard to supporting the agency's missions). The level of effort
dedicated to testing and evaluating the security controls in federal
information systems and the determination and acceptance of risk to
the mission in operating those systems (i.e., security certification
and accreditation)  should also be based on the same agency

Until recently, there were a limited number of standards and
guidelines available to help agencies implement a more granular
approach to establishing security priorities for their information
systems. The result-many agencies would end up expending too many
resources (both administratively and technologically) to protect
information systems of lesser criticality/sensitivity and not enough
resources to protect systems of greater criticality/sensitivity. Some
"load balancing" was needed.

Ushering in a New Era with FIPS 199

FIPS 199, the mandatory federal security categorization standard
approved by the Secretary of Commerce, provides the first step toward
bringing some order and discipline to the challenge of protecting the
large number of information systems supporting the operations and
assets of the federal government. The standard is predicated on a
simple and well-established concept-determining appropriate priorities
for agency information systems and subsequently applying appropriate
measures to adequately protect those systems.  The security controls
applied to a particular information system should be commensurate with
the system's criticality and sensitivity. FIPS 199 assigns this level
of criticality and sensitivity based on the potential impact on agency
operations (mission, functions, image, or reputation), agency assets,
or individuals should there be a breach in security due to the loss of
confidentiality (i.e., unauthorized disclosure of information),
integrity (i.e., unauthorized modification of information), or
availability (i.e., denial of service). FIPS 199 requires federal
agencies to do a "triage" on all of their information types and
systems, categorizing each as low, moderate, or high impact for the
three security objectives of confidentiality, integrity (including
authenticity and non-repudiation), and availability.

Employed within the System Development Life Cycle (SDLC), FIPS 199 can
be used as part of an agency's risk management program to help ensure
that appropriate security controls are applied to each information
system, and that the controls are adequately assessed to determine the
extent to which the controls are implemented correctly, operating as
intended, and producing the desired outcome with respect to meeting
the system security requirements. The following activities, consistent
with NIST Special Publication (SP)  800-30, Risk Management Guide for
Information Technology Systems, can be applied to both new and legacy
information systems within the SDLC-

(Note: A chart of the Risk Management Framework appears here in the
paper copy.)

* Categorize the information system, and the information resident
  within that system, based on a FIPS 199 impact analysis. (See NIST 
  SP 800-60, Guide for Mapping Types of Information and Information 
  Systems to Security Categories, for guidance in assigning security

* Select an initial set of security controls for the information
  system (as a starting point) based on the FIPS 199 security
  categorization. (See NIST SP 800-53, Recommended Security Controls 
  for Federal Information Systems. Note: FIPS 200, Minimum Security 
  Controls for Federal Information Systems, will replace NIST SP 
  800-53 in December 2005 in fulfillment of the FISMA legislative 
  requirement for mandatory minimum security requirements for federal 
  information systems.)

* Refine the initial set of security controls selected for the
  information system based on local conditions including
  organization-specific security requirements, specific threat
  information, cost-benefit analyses, the availability of compensating
  controls, or other special circumstances.

* Document the agreed-upon set of security controls in the system
  security plan including the organization's justification for any
  refinements or adjustments to the initial set of controls. (See NIST
  SP 800-18, Guide for Developing Security Plans for Information
  Technology Systems.)

* Implement the security controls in the information system. For
  legacy systems, some or all of the security controls selected may
  already be in place.

* Assess the security controls using appropriate methods and
  procedures to determine the extent to which the controls are
  implemented correctly, operating as intended, and producing the
  desired outcome with respect to meeting the security requirements 
  for the system. (See NIST SP 800-53A, Guide for Assessing the 
  Security Controls in Federal Information Systems, initial public 
  draft, fall 2004.)

* Determine the risk to organizational operations and assets resulting
  from the planned or continued operation of the information system.
  (See NIST SP 800-37, Guide for the Security Certification and
  Accreditation of Federal Information Systems.)

* Authorize information system processing (or for legacy systems,
  authorize continued system processing) if the level of risk to the
  agency's operations or assets is acceptable to the authorizing
  official. (See NIST SP 800-37, Guide for the Security Certification
  and Accreditation of Federal Information Systems.)

* Monitor selected security controls in the information system on a
  continuous basis including documenting changes to the system,
  conducting security impact analyses of the associated changes, and
  reporting the security status of the system to appropriate agency
  officials on a regular basis. (See NIST SP 800-37, Guide for the
  Security Certification and Accreditation of Federal Information

Significant changes to the information system or the security
requirements for that system may prompt the agency to revisit the
above activities. Examples of significant changes to an information
system include, but are not limited to, installation of a new or
upgraded operating system, middleware component, or application;
modifications to systems ports, protocols, or services; installation
of a new or upgraded hardware platform or firmware component; or
modifications to cryptographic modules or services. Changes in laws,
directives, policies, or regulations, while not always directly
related to the information system, can also potentially affect the
security of the system.

The Benefits to Agency Security Programs

The long-term effect of employing a FIPS 199 standards-based approach
is more targeted, more cost-effective, and improved security for
federal information and information systems. While the interconnection
of information systems often increases the risk to an agency's
operations and assets, FIPS 199 and the associated suite of standards
and guidelines provide a common framework and understanding for
expressing information security, and thus promote greater consistency
across diverse organizations in managing that risk.  Agencies will
determine which information systems are the most important to
accomplishing assigned missions based on the security categorization
of those systems and will protect the systems appropriately. Agencies
will also determine which systems are the least important to their
missions and will not allocate excessive resources for the protection
of those systems.

In the current high technology era where information systems are
viewed as commodities and are routinely used to protect some of the
nation's most important assets within the federal government and the
critical infrastructure, FIPS 199 is a standard that is right for the
time. In the end, the new security standard, when properly applied,
will facilitate a more effective allocation of available resources for
protecting information systems, determine the need and provide a
justification for the allocation of additional resources, and result
in a substantial improvement in the security posture of the
government's information systems.

The FISMA-related security standards and guidelines discussed in this
ITL bulletin are available at the FISMA Implementation Project website
at http://csrc.nist.gov/sec-cert.

Disclaimer: Any mention of commercial products or reference to
commercial organizations is for information only; it does not imply
recommendation or endorsement by the National Institute of Standards
and Technology nor does it imply that the products mentioned are
necessarily the best available for the purpose.

Elizabeth B. Lennon
Information Technology Laboratory
National Institute of Standards and Technology
100 Bureau Drive, Stop 8900
Gaithersburg, MD 20899-8900
Telephone (301) 975-2832
Fax (301) 840-1357

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