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Information Security: Comments on Proposed Government Information Act of
1999 (Testimony, 03/02/2000, GAO/T-AIMD-00-107).
Pursuant to a congressional request, GAO discussed S. 1993, the
Government Information Security Act of 1999 and it's impact on
strengthening the information security practices throughout the federal
government, focusing on: (1) potential improvements in federal agency
performance in addressing computer security issues; (2) the need for
better-defined control standards; and (3) centralized leadership.
GAO noted that: (1) the nation's computer-based infrastructures are at
increasing risk of severe disruption; (2) the dramatic increase of
computer interconnectivity has provided pathways among systems that can
be used to gain unauthorized access to data and operations from remote
locations; (3) government officials are increasingly worried about
attacks from individuals and groups with malicious intentions, such as
terrorists and nations engaging in information warfare; (4) s. 1993
provides opportunities to address this problem; (5) it updates the legal
framework that supports federal information security requirements and
addresses widespread federal information security weaknesses; (6) the
bill provides for a risk-based approach to information security and
independent annual audits of security controls; and (7) it approaches
security from a governmentwide perspective, taking steps to accommodate
the significantly varying information security needs of both national
security and civilian agency operations.
--------------------------- Indexing Terms -----------------------------
     TITLE:  Information Security: Comments on Proposed Government
	     Information Act of 1999
      DATE:  03/02/2000
   SUBJECT:  Computer security
	     Information systems
	     Data integrity
	     Internal controls
	     Confidential communication
	     Information resources management
	     Computer viruses
	     Information leaking
	     Computer crimes
	     Computer software verification and validation
IDENTIFIER:  Melissa Computer Virus
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information security
Comments on the Proposed Government Information Security Act of 1999
        Statement of Jack L. Brock
Director, Governmentwide and Defense Information Systems
Accounting and Information Management Division
Before the Committee on Governmental Affairs,
U.S. Senate
United States General Accounting Office
Mr. Chairman and Members of the Committee:
I am pleased to be here to discuss S. 1993, the Government Information
Security Act of 1999, which seeks to strengthen information security
practices throughout the federal government. Such efforts are necessary and
critical. Our work has shown that almost all government agencies are plagued
by poor computer security. Recent events such as the denial of service
attacks last month indicate the damage that can occur when an organization's
computer security defenses are breached. However, Mr. Chairman, let me
emphasize that the potential for more serious disruption is significant. As
I stated in recent testimony, our nation's computer-based infrastructures
are at increasing risk of severe disruption. The dramatic increase of
computer interconnectivity, while beneficial in many ways, has provided
pathways among systems that, if not properly secured, can be used to gain
unauthorized access to data and operations from remote locations. Government
officials are increasingly worried about attacks from individuals and groups
with malicious intentions, such as terrorists and nations engaging in
information warfare.
S. 1993 provides opportunities to address this problem. It updates the legal
framework that supports federal information security requirements and
addresses widespread federal information security weaknesses. In particular,
the bill provides for a risk-based approach to information security and
independent annual audits of security controls. Moreover, it approaches
security from a governmentwide perspective, taking steps to accommodate the
significantly varying information security needs of both national security
and civilian agency operations.
Mr. Chairman, I would like to discuss how these proposals can lead to
substantial improvements in federal agency performance in addressing
computer security issues. In addition, I would like to raise two additional
concerns-the need for better-defined control standards and centralized
leadership-that, if addressed, could further strengthen security practices
and oversight. These two concerns merit further attention as the Committee
moves ahead with its work in this area.
Information Security Improvements Are Urgently Needed
Our most recent individual agency review of the Environmental Protection
Agency (EPA), corroborated our governmentwide analysis. Overall, we found
that EPA's computer systems and the operations that rely on these systems
were highly vulnerable to tampering, disruption, and misuse. EPA's own
records identified several serious computer incidents in the last 2 years
that resulted in damage and disruption to agency operations. Moreover, our
tests of computer-based controls concluded that computer operating systems
and the agencywide computer network that support most of EPA's
mission-related and financial operations were riddled with security
weaknesses. EPA is currently taking significant steps to address these
weaknesses. However, resolving EPA's information security problems will
require substantial ongoing management attention since security program
planning and management to date have largely been a paper exercise doing
little to substantively identify, evaluate, and mitigate risks to the
agency's data and systems. Any fixes made by EPA to address specific control
weaknesses will be temporary until these underlying management issues are
EPA is not unique. Within the past 12 months we have identified significant
management weaknesses and control deficiencies at a number of agencies that
effectively undermine the integrity of their computer security operations.
   * In August 1999, we reported that pervasive weaknesses in Department of
     Defense information security continue to provide both hackers and
     hundreds of thousands of authorized users the opportunity to modify,
     steal, inappropriately disclose, and destroy sensitive DOD data. Among
     other things, these weaknesses impaired DOD's ability to control
     physical and electronic access to its systems and data; ensure that
     software running on its systems is properly authorized, tested, and
     functioning as intended; and resume operations in the event of a
   * In May 1999, we reported that, as part of our tests of the National
     Aeronautics and Space Administration's (NASA) computer-based controls,
     we successfully penetrated several mission-critical systems, including
     one responsible for calculating detailed positioning data for each
     orbiting spacecraft and another that processes and distributes the
     scientific data received from these spacecraft. Having obtained access,
     we could have disrupted ongoing command and control operations and
     modified or destroyed system software and data.
   * In August 1999, an independent accounting firm reported that the
     Department of State's mainframe computers for domestic operations were
     vulnerable to unauthorized access. Consequently, other systems, which
     process data using these computers, could also be vulnerable. A year
     earlier, in May 1998, we reported that our tests at State demonstrated
     that its computer systems and the information they maintained were very
     susceptible to hackers, terrorists, or other unauthorized individuals
     seeking to damage State operations or reap financial gain by exploiting
     the department's information security weaknesses.
   * In October 1999, we reported that serious weaknesses placed sensitive
     information belonging to the Department of Veterans Affairs (VA) at
     risk of inadvertent or deliberate misuse, fraudulent use, improper
     disclosure, or destruction, possibly occurring without detection. Such
     findings were particularly troublesome since VA collects and maintains
     sensitive medical record and benefit payment information for veterans
     and family members and is responsible for tens of billions of dollars
     of benefit payments annually.
Although the nature of operations and related risks at these and other
agencies vary, there are striking similarities in the specific types of
weaknesses reported. The following six areas of management and general
control weaknesses are repeatedly highlighted in our reviews.
   * Entitywide Security Program Planning and Management. Each organization
     needs a set of management procedures and an organizational framework
     for identifying and assessing risks, deciding what policies and
     controls are needed, periodically evaluating the effectiveness of these
     policies and controls, and acting to address any identified weaknesses.
     These are the fundamental activities that allow an organization to
     manage its information security risks cost effectively, rather than
     reacting to individual problems ad hoc only after a violation has been
     detected or an audit finding has been reported. Despite the importance
     of this aspect of an information security program, we continue to find
     that poor security planning and management is the rule rather than the
     exception. Most agencies do not develop security plans for major
     systems based on risk, have not formally documented security policies,
     and have not implemented programs for testing and evaluating the
     effectiveness of the controls they rely on.
   * Access Controls. Access controls limit or detect inappropriate access
     to computer resources (data, equipment, and facilities) thereby
     protecting these resources against unauthorized modification, loss, and
     disclosure. They include physical protections, such as gates and
     guards, as well as logical controls, which are controls built into
     software that (1) require users to authenticate themselves through
     passwords or other identifiers and (2) limit the files and other
     resources that an authenticated user can access and the actions that he
     or she can execute. In many of our reviews we have found that managers
     do not identify or document access needs for individual users or
     groups, and, as a result, they provide overly broad access privileges
     to very large groups of users. Additionally, we often find that users
     share accounts and passwords or post passwords in plain view, making it
     impossible to trace specific transactions or modifications to an
     individual. Unfortunately, as a result of these and other access
     control weaknesses, auditors conducting penetration tests of agency
     systems are almost always successful in gaining unauthorized access
     that would allow intruders to read, modify, or delete data for whatever
     purposes they had in mind.
   * Application Software Development and Change Controls. Application
     software development and change controls prevent unauthorized software
     programs or modifications to programs from being implemented. Without
     them, individuals can surreptitiously modify software programs to
     include processing steps or features that could later be exploited for
     personal gain or sabotage. In many of our audits, we find that (1)
     testing procedures are undisciplined and do not ensure that implemented
     software operates as intended, (2) implementation procedures do not
     ensure that only authorized software is used, and
     (3) access to software program libraries is inadequately controlled.
   * Segregation of Duties. Segregation of duties refers to the policies,
     procedures, and organizational structure that help ensure that one
     individual cannot independently control all key aspects of a process or
     computer-related operation and thereby conduct unauthorized actions or
     gain unauthorized access to assets or records without detection. For
     example, one computer programmer should not be allowed to independently
     write, test, and approve program changes. We commonly find that
     computer programmers and operators are authorized to perform a wide
     variety of duties, thus providing them the ability to independently
     modify, circumvent, and disable system security features. Similarly, we
     have also identified problems related to transaction processing, where
     all users of a financial management system can independently perform
     all of the steps needed to initiate and complete a payment.
   * System Software Controls. System software controls limit and monitor
     access to the powerful programs and sensitive files associated with the
     computer systems operation, e.g., operating systems, system utilities,
     security software, and database management systems. If controls in this
     area are inadequate, unauthorized individuals might use system software
     to circumvent security controls to read, modify, or delete critical or
     sensitive information and programs. Such weaknesses seriously diminish
     the reliability of information produced by all of the applications
     supported by the computer system and increase the risk of fraud,
     sabotage, and inappropriate disclosures. Our reviews frequently
     identify systems with insufficiently restricted access which makes it
     possible for knowledgeable individuals to disable or circumvent
     controls in a wide variety of ways.
   * Service Continuity Controls. Service continuity controls ensure that
     critical operations can continue when unexpected events occur, such as
     a temporary power failure, accidental loss of files, even a major
     disaster such as a fire. For this reason, an agency should have (1)
     procedures in place to protect information resources and minimize the
     risk of unplanned interruptions and (2) a plan to recover critical
     operations should interruptions occur. At many of the agencies we have
     reviewed, we have found that plans and procedures are incomplete
     because operations and supporting resources had not been fully analyzed
     to determine which were most critical and would need to be restored
     first. In addition, disaster recovery plans are often not fully tested
     to identify their weaknesses. As a result, many agencies have
     inadequate assurance that they can recover operational capability in a
     timely, orderly manner after a disruptive attack.
Unfortunately, in addressing these problems, agencies often react to
individual audit findings as they are reported, rather than addressing the
systemic causes of control weaknesses-namely, poor agency security planning
and management. S. 1993 recognizes that this approach is unworkable in
today's environment.
S. 1993 Proposals Can Lead to Improved Information Security Management
   * following a risk-based approach to information security,
   * performing independent annual audits of security controls, and
   * approaching security from a governmentwide perspective taking into
     account the varying information security needs of both national
     security and civilian agency operations.
If effectively implemented, these proposals should help federal agencies
improve their information security practices and considerably strengthen
executive branch and congressional oversight.
The first improvement area would require a risk management approach to be
implemented jointly by agency program managers and technical specialists.
Instituting such an approach is important since agencies have generally done
a very poor job of evaluating their information security risks and
implementing appropriate controls. Moreover, our studies of public and
private best practices have shown that effective security program management
requires implementing a process that provides for
   * assessing information security risks to program operations and assets
     and identifying related needs for protection,
   * selecting and implementing controls that meet these needs,
   * promoting awareness of risks and responsibilities, and
   * implementing a program for routinely testing and evaluating policy and
     control effectiveness.
The key to this process is recognizing that information security is not a
technical matter of locking down systems, but rather a management problem
that requires understanding information security risks to program operations
and assets and ensuring that appropriate steps are taken to mitigate these
risks. Thus, it is highly appropriate that S. 1993 requires a risk
management approach that incorporates these elements.
The second proposed improvement area is the requirement for an annual
independent audit of each agency information security program. Individually,
as well as collectively, these audits can provide much needed information
for improved oversight by the Office of Management and Budget (OMB) and the
Congress. Our years of auditing agency security programs have shown that
independent tests and evaluations are essential to verifying the
effectiveness of computer-based controls. Audits can also evaluate agency
implementation of management initiatives, thus promoting management
accountability. Moreover, an annual independent evaluation of agency
information security programs will help drive reform because it will
spotlight both the obstacles and progress toward improving information
security, much like the financial statement audits required by the Chief
Financial Officers Act of 1990.
Agency financial systems are already subjected to such evaluations as part
of their annual financial statement audits. However, I would like to note
that for agencies with significant nonfinancial operations, such as the
departments of Defense and Justice, the requirement for annual independent
information security audits would place a significant new burden on existing
audit capabilities. Accordingly, making these audits effective will require
ensuring that agency inspectors general have sufficient resources to either
perform or contract for the needed work.
Third, S. 1993 takes a governmentwide approach to information security by
accommodating a wide range of information security needs and applying
requirements to all agencies, including those engaged in national security.
Under current law, distinctions between national security systems and all
other government systems have tended to frustrate efforts to establish
governmentwide standards and to share information security best practices.
S.1993 should help eliminate these distinctions and ensure the development
of common approaches across government for the protection of similar risks,
regardless of the agencies involved.
This is important because the information security needs of civilian agency
operations and those of national security operations have converged in
recent years. In the past, when sensitive information was more likely to be
maintained on paper or in stand-alone computers, the main concern was data
confidentiality, especially as it pertained to classified national security
data. Now, virtually all agencies rely on interconnected computers to
maintain information and carry out operations that are essential to their
missions. While the confidentiality needs of these data vary, all agencies
must be concerned about the integrity and the availability of their systems
and data. It is important for all agencies to understand these various types
of risks and take appropriate steps to manage them.
Strengthening Security Control Standards and Leadership Also Merits
First, there is a need for better-defined security control standards.
Currently, agencies have wide discretion in deciding what computer security
controls to implement and the level of rigor with which they enforce these
controls. However, as mentioned earlier, our audit work has shown that
agencies have generally done a poor job of evaluating risks and implementing
effective controls. Moreover, these audits have shown that agencies need
more specific guidance on the controls that are appropriate for the
different types of information that must be protected. Current OMB and
National Institute of Standards and Technology (NIST) guidance is not
detailed enough to ensure that agencies are making appropriate judgments in
this area and that they are protecting the same types of data consistently
throughout the federal community.
More specific guidance could be developed in two parts:
   * A set of data classifications that could be used by all federal
     agencies to categorize the criticality and sensitivity of the data they
     generate and maintain. These classifications could range from
     noncritical, publicly available information requiring a relatively low
     level of protection to highly sensitive and critical information that
     requires an extremely high level of protection. Intermediate
     classifications could cover a range of financial and other important
     and sensitive data that require significant protection but not at the
     very highest levels. It would be important for these data
     classifications to be clearly defined and accompanied by guidelines
     regarding the types of data that would fall into each classification.
   * A set of minimum mandatory control requirements for each
     classification. Such control requirements could cover issues such as
     (1) the strength of system user authentication techniques (e.g.,
     passwords, smart cards, and biometrics) for each classification, (2)
     appropriate types of cryptographic tools for each classification, and
     (3) the frequency and rigor of testing appropriate for each
We believe that requiring the development of these standards, particularly
with minimum mandatory control requirements, is the most important addition
that could be made to your legislation. More precisely defined standards
will provide common measures that can guide agencies in developing needed
controls and improve the consistency and value of audits and evaluations.
Second, there is a need for strong, centralized leadership for information
security across government. Under current law, responsibility for guidance
and oversight of agency information security is divided among a number of
agencies, including OMB, NIST, the General Services Administration (GSA),
and the National Security Agency. Other organizations are also becoming
involved through the administration's critical infrastructure protection
initiative, including the Department of Justice and the Critical
Infrastructure Assurance Office. While some coordination is occurring,
overall, this has resulted in a proliferation of organizations with
overlapping oversight and assistance responsibilities. Lacking is a strong
voice of leadership and a clear understanding of roles and responsibilities.
Having strong, centralized leadership has been critical to addressing other
governmentwide management challenges. For example, vigorous support from
officials at the highest levels of government was necessary to prompt
attention and action to resolving the Year 2000 problem. Similarly,
forceful, centralized leadership was essential to pressing agencies to
invest in and accomplish basic management reforms mandated by the Chief
Financial Officers Act. To achieve similar results in information security,
the federal government must have the support of top leaders and more clearly
defined roles for those organizations that support governmentwide
initiatives. We believe serious consideration should be given in your
legislation to clarify the roles of organizations responsible for
governmentwide information security efforts, for example, the roles of OMB,
NIST, and GSA and to create a national Chief Information Officer to provide
higher visibility and more effective central leadership of information
Mr. Chairman and Members of the Committee, this concludes my testimony. We
look forward to working with the Committee to advance the issues discussed
today as well as to address our technical comments, which we have provided
separately. I would be happy to answer any questions you may have.
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