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UNCLASSIFIED<br />

On an annual basis, OMB provides guidance with reporting categories and questions for<br />

meeting the current year’s reporting requirements. 6 OMB uses this data to assist in its oversight<br />

responsibilities and to prepare its annual report to Congress on agency compliance with FISMA.<br />

Results <strong>of</strong> Review<br />

Overall, we found that the <strong>Department</strong> had implemented an information security program,<br />

but we identified weaknesses that significantly impact the information security program<br />

controls. If these control weaknesses are exploited, the <strong>Department</strong> could be exposed to<br />

additional security breaches. Collectively, these control weaknesses represent a significant<br />

deficiency, as defined by the Office <strong>of</strong> Management and Budget M-11-33, to enterprise-wide<br />

security including the <strong>Department</strong>’s financial system. The weakened security controls could<br />

adversely affect the confidentiality, integrity, and availability <strong>of</strong> information and information<br />

systems. A further compounding factor is that the <strong>Department</strong> had not taken corrective action to<br />

remediate all <strong>of</strong> the control weaknesses identified in the FY2010 FISMA report. To improve the<br />

information security program and to bring the program into compliance with FISMA, OMB, and<br />

NIST requirements, the <strong>Department</strong> needs to address the following control weaknesses:<br />

A. Risk Management Framework Needs Improvement<br />

The <strong>Department</strong> needs to improve its risk management program for information security<br />

at both the organization and the system levels. We found that the <strong>Department</strong> had not taken<br />

adequate remedial actions to resolve control weaknesses reported in the FY 2010 OIG FISMA<br />

report and that the <strong>Department</strong> continues to experience control deficiencies at both the<br />

organizational and information systems levels <strong>of</strong> the Risk Management Framework (RMF). The<br />

RMF is important because NIST SP 800-37 7 requires an organizational perspective with the<br />

development <strong>of</strong> a comprehensive governance structure and organization-wide risk management<br />

strategy, instead <strong>of</strong> sole reliance on security authorizations at the system level.<br />

At the organizational level, the <strong>Department</strong> had not implemented an effective risk<br />

management strategy addressing how it intends to assess, respond to, and monitor information<br />

security risk as required by NIST 800-39. 8 As <strong>of</strong> June 30, 2011, the ISSC, 9 a key component <strong>of</strong><br />

the <strong>Department</strong>’s cyber security governance structure, had not met during FY 2011. The<br />

committee chose to meet only during emergency events and not regularly, as specified in its<br />

charter. Key members <strong>of</strong> the ISSC consist <strong>of</strong> the Chief <strong>Information</strong> <strong>Security</strong> Officer, the Senior<br />

Coordinator for <strong>Security</strong> Infrastructure; Co-Executive Secretaries from the Office <strong>Information</strong><br />

Resource Management/<strong>Information</strong> Assurance/Policy Liaison and Reporting (IRM/IA/PLR) and<br />

6 OMB Memorandum M-11-33, FY 2011 Reporting Instructions for the Federal <strong>Information</strong> <strong>Security</strong> Management<br />

Act and Agency Privacy Management, dated Sept.14, 2011.<br />

7 NIST SP 800-37, rev. 1, Guide for Applying the Risk Management Framework to Federal <strong>Information</strong> Systems,<br />

Feb. 2010.<br />

8 NIST SP 800-39, Managing <strong>Information</strong> <strong>Security</strong> Risk: Organization, Mission, and <strong>Information</strong> System View,<br />

March 2011.<br />

9 According to the ISSC charter, members will meet on a monthly basis; more or less frequent meetings may be<br />

scheduled at the request <strong>of</strong> any member, given a majority agreement <strong>of</strong> the ISSC. Among its responsibilities, the<br />

ISSC shall: (a) Develop priorities and determine availability <strong>of</strong> resources for security <strong>of</strong> <strong>Department</strong> information<br />

systems; (b) coordinate strategic direction <strong>of</strong> the <strong>Department</strong>’s information security efforts; and (c) support<br />

<strong>Department</strong> funding and budget mechanisms as they relate to information security.<br />

7<br />

UNCLASSIFIED

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