Appendix III to OMB Circular No. A-130 - Security of Federal Automated
Information Resources
A. Requirements.
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
shares common functionality. A system normally includes hardware,
software, information, data, applications, communications, 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
applications require 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 shall 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 shall 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 shall
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 individual knowledgeable in the
information technology used in the system and in providing
security for such technology.
2) System Security Plan. Plan for adequate security of each
general support system as part of the organization's information
resources management (IRM) planning process. The security plan
shall be consistent with guidance issued by the National Institute
of Standards and Technology (NIST). Independent advice and
comment on the security plan shall be solicited prior to the
plan's implementation. A summary of the security plans shall be
incorporated into the strategic IRM plan required by the Paperwork
Reduction Act (44 U.S.C. Chapter 35) and Section 8(b) of this
circular. Security plans shall 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 shall be based on
the needs of the various users of the system. The security
required by the rules shall be only as stringent as
necessary to provide adequate security for information in
the system. Such rules shall clearly delineate
responsibilities and expected behavior of all individuals
with access to the system. They shall also include
appropriate limits on interconnections to other systems and
shall define service provision and restoration priorities.
Finally, they shall be clear about the consequences of
behavior not consistent with the rules.
b) Training. Ensure that all individuals are appropriately
trained in how to fulfill their security responsibilities
before allowing them access to the system. Such training
shall assure that employees are versed in the rules of the
system, be consistent with guidance issued by NIST and OPM,
and apprise them about available assistance and technical
security products and techniques. Behavior consistent with
the rules of the system and periodic refresher training
shall be required for continued access to the system.
c) Personnel Controls. Screen individuals who are
authorized to bypass significant technical and operational
security controls of the system commensurate with the risk
and magnitude of harm they could cause. Such screening
shall occur prior to an individual 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 shall
share information with other organizations, consistent with
NIST coordination, and should assist the agency in pursuing
appropriate legal action, consistent with Department of
Justice guidance.
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 shall be established
which are consistent with the rules of the system and in
accordance with guidance from NIST.
3) Review of Security Controls. Review the security controls in
each system when significant modifications are made to the system,
but at least every three years. The scope and frequency of the
review should be commensurate with the acceptable level of risk
for the system. 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 for 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 shall be re-authorized 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 and process
supported by the application and in the management, personnel,
operational, and technical controls used to protect it. This
official shall assure that effective security products and
techniques are appropriately used in the application and shall 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 shall be
consistent with guidance issued by NIST. Advice and comment on
the plan shall 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 shall be incorporated into the strategic IRM plan
required by the Paperwork Reduction Act. Application security
plans shall include:
a) Application Rules. Establish a set of rules concerning
use of and behavior within the application. The rules shall
be as stringent as necessary to provide adequate security
for the application and the information in it. Such rules
shall clearly delineate responsibilities and expected
behavior of all individuals with access to the application.
In addition, the rules shall be clear about the consequences
of behavior not consistent with the rules.
b) Specialized Training. Before allowing individuals
access to the application, ensure that all individuals
receive specialized training focused on their
responsibilities and the application rules. This may be in
addition to the training required for access to a system.
Such 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 and application rules as
appropriate. In cases where such controls cannot adequately
protect the application or information in it, screen
individuals commensurate with the risk and magnitude of the
harm they could cause. Such screening shall 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 the application in accordance with appropriate guidance
issued by NIST.
f) Information Sharing. Ensure that information shared from
the application is protected appropriately, comparable 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 shall be added to protect the integrity of the
application and the confidence the public has in the
application. Such controls shall include segregating
information made directly accessible to the public from
official agency records.
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
OMB Circular No. A-123, "Management Accountability and Control"
and 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 shall be a factor in management authorizations. The
application must 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 shall:
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 cost-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. Department of Defense. The Secretary of Defense shall:
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.
c. Department of Justice. The Attorney General shall:
1) Provide appropriate 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.
d. General Services Administration. The Administrator of General
Services shall:
1) Provide 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).
3) Provide appropriate security services to meet the needs of
Federal agencies to the extent that such services are cost-
effective.
e. Office of Personnel Management. The Director of the Office of
Personnel Management shall:
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.
f. Security Policy Board. The Security Policy Board shall coordinate
the activities of the Federal government regarding the security of
information technology that processes classified information in
accordance with applicable national security directives;
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,
"Management Accountability and Control", if a deficiency in controls is
judged by the agency head to be material when weighed against other
agency deficiencies, it shall be included in the annual FMFIA report.
Less significant deficiencies shall 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 strategic
plan required by the Paperwork Reduction Act (44 U.S.C. 3506).
B. Descriptive Information.
The following descriptive language is explanatory. It is included to assist
in understanding the requirements of the Appendix.
The Appendix re-orients 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 an integral 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 no longer requires the preparation of formal risk analyses. In
the past, substantial resources have been expended doing complex analyses of
specific 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 formal risk analyses need not be
performed, the need to determine adequate security will require that a risk-
based approach be used. This risk assessment 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. Additional guidance on effective risk
assessment is available in "An Introduction to Computer Security: The NIST
Handbook" (March 16, 1995).
Discussion of the Appendix's Major Provisions. The following discussion is
provided to aid reviewers in understanding the changes in emphasis in the
Appendix.
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
Appendix emphasizes management controls affecting individual users of
information technology. Technical and operational controls support management
controls. To be effective, all must interrelate. For example, authentication
of individual users is an important management control, for which password
protection is a technical control. However, password protection will only be
effective if both a strong technology is employed, and it is managed to assure
that it is used correctly.
Four controls are set forth: 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
Bulletins 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 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. 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 applications require some level of security, and
adequate security for most of them should be provided by security of the
general support systems in which they operate. However, certain
applications, because of the nature of the information in them, require
special management oversight and should be treated as major. Agencies are
expected to exercise management judgement in determining which of their
applications are major.
The focus of OMB Bulletins Nos. 88-16 and 90-08 was on identifying and
securing both general support systems and applications which contained
sensitive information. The Appendix requires the establishment of security
controls in all general support systems, under the presumption that all
contain some sensitive information, and focuses extra security controls on a
limited number of particularly high-risk or major applications.
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 in writing to an
individual trained in the technology used in the system and in providing
security for such technology, including the management of security
controls such as user identification and authentication.
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 which
requires protection to assure its integrity, availability, or
confidentiality, and therefore all systems require security plans.
Previous guidance on security planning was contained in OMB Bulletin No.
90-08. This Appendix supersedes OMB Bulletin 90-08 and expands the
coverage of security plans from Bulletin 90-08 to include 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 the
Appendix of 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.
This Appendix also continues the requirement from the Computer Security
Act that summaries of security plans be included in agency strategic
information resources management plans. OMB will provide additional
guidance about the contents of those strategic plans, pursuant to the
Paperwork Reduction Act of 1995.
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 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. They should be consistent with system-
specific policy as described in "An Introduction to Computer
Security: The NIST Handbook" (March 16, 1995). 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 works, unofficial
use of government equipment, the assignment and limitation of
system privileges, and individual accountability. Often rules
should reflect technical security controls in the system. For
example, rules regarding password use should be consistent with
technical password features in the system. Rules may be enforced
through administrative sanctions specifically related to the
system (e.g. loss of system privileges) or through more general
sanctions as are imposed for violating other rules of conduct. In
addition, the rules should specifically address restoration of
service as a concern of all users of the system.
b) Training. The Computer Security Act requires Federal agencies
to provide for the mandatory periodic training in computer
security awareness and accepted computer security practice of all
employees who are involved with the management, use or operation
of a Federal computer system within or under the supervision of
the Federal agency. This includes contractors as well as
employees of the agency. Access provided to members of the public
should be constrained by controls in the applications through
which access is allowed, and training should be within the context
of those controls. The Appendix enforces such mandatory training
by requiring its completion prior to granting access to the
system. Each new user of a general support system in some sense
introduces a risk to all other users. Therefore, each user should
be versed in acceptable behavior -- the rules of the system --
before being allowed to use the system. Training should also
inform the individual how to get help in the event of difficulty
with using or security of the system.
Training should be tailored to what a user needs to know to use
the system securely, given the nature of that use. Training may
be presented in stages, for example as more access is granted. In
some cases, the 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 dissipate. 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 requires NIST, with assistance
from the Office of Personnel Management (OPM), to update its
existing 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 has come from authorized individuals 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. This may be
done, for example, by looking for patterns of behavior by users.
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 a critical piece of 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 some significant technical and operational
controls in order to perform system administration and maintenance
functions (e.g., LAN administrators or systems programmers).
Screening such individuals in positions of trust will supplement
technical, operational, and management controls, particularly
where the risk and magnitude of 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 and other agencies. The Appendix directs
agencies to effectuate such sharing, and tasks NIST to coordinate
those agency activities government-wide.
The Appendix also directs the Department of Justice to provide
appropriate 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. 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.
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 sophisticated 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 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 (some agencies refer to this authorization as
accreditation). 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.
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.
Re-authorization should occur prior to a significant change in
processing, but at least every three years. It should be done more
often where there is a high risk and potential magnitude of harm.
b. Controls in Major Applications. Certain applications require special
management attention due to the risk and magnitude of 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 in writing to
assure that the particular application has adequate security. To be
effective, this individual should be knowledgeable in the information
and process supported by the application and in the management,
personnel, 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 provided 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. Summaries of application security plans should be included in
strategic information resource management plans in accordance with this
Circular.
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. Often the rules
will be associated with technical controls implemented in the
application. Such rules should include, for example, limitations
on changing data, searching databases, or divulging information.
b) Specialized Training. Training is required for all individuals
given access to the application, including members of the public.
It should vary depending on the type of access allowed and the
risk that access represents to the security of the application and
information in it. 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. Such controls should be implemented as both technical
controls and as application rules. For example, technical
controls to ensure individual accountability, such as looking for
patterns of user behavior, are most effective if users are aware
that there is such a technical control. 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, commensurate with the risk and magnitude of harm they
could cause. The change in emphasis on screening in the Appendix
should not affect background screening deemed necessary because of
other duties that an individual may perform.
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,
whether the loss is due to the inability of the application to
function or a general support system failure. Experience has
demonstrated that testing a contingency plan significantly
improves its viability. Indeed, untested plans or plans not
tested for a long period of time may create a false sense of
ability to recover in a timely manner.
e) Technical Controls. Technical security controls, for example
tests to filter invalid entries, should be built into each
application. Often these controls will correspond with the rules
of behavior for the application. Under the previous Appendix,
application security was focused on the process by which
sensitive, custom applications were developed. While that process
is not addressed in detail in this Appendix, it remains an
effective method for assuring that security controls are built
into applications. Additionally, the technical 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 comparable 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 normally requires
notification and agreement to protect the 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, an
independent review or audit of the security controls for each major
application should be performed. Because of the higher risk involved in
major applications, the review or audit should be independent of the
manager responsible for the application. 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 from 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 this
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 authorized by
the management official responsible for the function supported by the
application at least every three years, but more often where the risk
and magnitude of harm is high. 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 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 This should include guidance on
effective risk-based security absent a formal risk analysis.
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. Coordination of
agency incident response activities should address both threats
and vulnerabilities as well as improve the ability of the Federal
government for rapid and effective cooperation in response to
serious security breaches.
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. 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.
c. Department of Justice. The Department of Justice should provide
appropriate 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.
d. 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 to do so, 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).
e. Office of Personnel Management. In accordance with the Computer
Security Act, OPM 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 the current guidelines and
should work with NIST in revising those guidelines.
f. Security Policy Board. The Security Policy Board is assigned
responsibility for national security policy coordination in accordance
with the appropriate Presidential directive. This includes policy for
the security of information technology used to process classified
information.
Circular A-130 and this Appendix do not apply to information technology
that supports certain critical national security missions, as defined in
44 U.S.C. 3502(9) and 10 U.S.C. 2315. Policy and procedural
requirements for the security of national security systems
(telecommunications and information systems that contain classified
information or that support those critical national security missions
(44 U.S.C. 3502(9) and 10 U.S.C. 2315)) is assigned to the Department of
Defense pursuant to Presidential directive. The Circular clarifies that
information classified for national security purposes should also be
handled in accordance with appropriate national security directives.
Where classified information is required to be protected by more
stringent security requirements, those requirements should be followed
rather than the requirements of this Appendix.
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 information resources management plan
required by the Paperwork Reduction Act.