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Evaluation of Department of State Information Security Program ...

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UNCLASSIFIED<br />

among the IT investments. Ultimately, inadequate oversight increases the risk <strong>of</strong><br />

unapproved investments being funded.<br />

Although this report contains 19 recommendations to the <strong>Department</strong>, we believe the<br />

most significant security deficiencies are the findings related to risk management strategy and<br />

security authorizations (Finding A), security configuration management (Finding B), POA&Ms<br />

(Finding D), and the continuous monitoring program (Finding G).<br />

We reviewed the <strong>Department</strong>’s remedial actions taken to address the 2010 reported<br />

information security program control weaknesses identified in the FY 2010 FISMA report<br />

Review <strong>of</strong> the <strong>Information</strong> <strong>Security</strong> <strong>Program</strong> at the <strong>Department</strong> <strong>of</strong> <strong>State</strong> (AUD/IT-11-07,<br />

November 2010). (The statuses <strong>of</strong> the recommendations from the FY 2010 review <strong>of</strong> the<br />

information security program are in Appendix B.) Since FY 2010, the <strong>Department</strong> has taken<br />

actions to improve management controls to include the following:<br />

� Updated and verified the FISMA systems inventory list to the <strong>Information</strong><br />

Technology Asset Baseline (ITAB) to ensure that all information technology (IT)<br />

systems are accurately accounted for.<br />

� Defined and identified personnel who have significant security responsibilities in its<br />

<strong>Information</strong> Assurance (IA) Training Plan.<br />

� Ensured that personally identifiable information (PII) data incidents are reported to<br />

the U.S. Computer Emergency Response Team within the required 1-hour timeframe.<br />

� Updated its contracts to include <strong>Department</strong> <strong>of</strong> <strong>State</strong> Acquisition Regulations<br />

information security language.<br />

Management Comments. In its November 2, 2011, response to the draft report (see<br />

Appendix J), the <strong>Department</strong> stated that it “disagrees” on whether continuous monitoring, as<br />

currently conducted, produces a lower risk than a traditional C&A program, and on the relative<br />

importance <strong>of</strong> completeness and compliance vs. timeliness and risk-based prioritization.” The<br />

<strong>Department</strong> further stated, “Having carefully considered these factors, the <strong>Department</strong> is<br />

convinced its continuous monitoring program, which is 300 times more timely than traditional<br />

three-year reauthorizations, produces significantly lower security risk [<strong>Department</strong> footnote<br />

states: “Neither produce zero risk, and achieving zero risk in not foreseeable.”] on its networks.”<br />

Although OIG agrees that the continuous monitoring concept, if properly implemented<br />

and documented, allows for more rapid identification <strong>of</strong> security weaknesses, OIG is unable to<br />

provide an opinion on the effectiveness <strong>of</strong> the continuous monitoring strategy because the<br />

Bureau <strong>of</strong> <strong>Information</strong> Resource Management (IRM) did not provide a strategy, but the concept<br />

<strong>of</strong> continuous monitoring is designed to provide results in a more timely fashion. The collective<br />

weaknesses in the information security program, including IRM’s lack <strong>of</strong> strategies for risk<br />

management and continuous monitoring, leave a weakness in the approach to assessing risk and<br />

taking actions to correct identified vulnerabilities. Furthermore, IRM’s approach cannot<br />

establish responsibility and accountability for information systems security controls and leaves a<br />

vacuum between the current state <strong>of</strong> information security controls and any planned<br />

5<br />

UNCLASSIFIED

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