Security of Federal Automated Information

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 [email protected] 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 [email protected]

(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