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UNCLASSIFIED<br />

that an organization-defined continuous monitoring strategy be implemented. NIST SP 800-53,<br />

Revision 3 32 requires that the organization establish a continuous monitoring strategy and<br />

implement a continuous monitoring program that includes a configuration management process,<br />

security impact analysis, ongoing security control assessment, and a method to report the<br />

security state <strong>of</strong> the system to appropriate organizational <strong>of</strong>ficials. During the course <strong>of</strong> our<br />

evaluation, we inquired about the implementation <strong>of</strong> iPost on ClassNet and were informed that<br />

iPost was not currently implemented. Therefore, we did not perform an assessment <strong>of</strong> any hosts<br />

or networks residing on ClassNet. Furthermore, we discovered that iPost was in production on<br />

ClassNet as <strong>of</strong> August 2011, which exceeded our testing timeframe.<br />

Additionally, the Government Accountability Office (GAO), in July 2011, issued a<br />

continuous monitoring report on the <strong>Department</strong>’s iPost system. 33 GAO stated the following<br />

concerning iPost:<br />

While <strong>State</strong> has reported success with implementing iPost to provide ongoing<br />

monitoring <strong>of</strong> certain controls over Windows hosts on OpenNet and reporting the<br />

status <strong>of</strong> these controls across the enterprise to appropriate <strong>of</strong>ficials, the<br />

department faces an ongoing challenge in continuing this success because it does<br />

not have a documented continuous monitoring strategy in place.<br />

In addition to those weaknesses identified in the FY 2010 FISMA report on the<br />

<strong>Department</strong>’s information security program and the specified weaknesses presented in the GAO<br />

report, the FY 2011 evaluation identified weaknesses with the <strong>Department</strong>’s existing continuous<br />

monitoring approach to include the following:<br />

� The <strong>Department</strong> did not identify all Windows operating systems or<br />

<strong>Department</strong> assets on OpenNet.<br />

� The <strong>Department</strong> did not take into consideration those security controls that<br />

cannot be tested with automation (that is, physical and environmental<br />

controls, effectiveness <strong>of</strong> the IT security training, and the newest family <strong>of</strong><br />

controls that deal with IT program management).<br />

Not having a robust continuous monitoring program prevents an organization from fully<br />

understanding the security state <strong>of</strong> the information system over time. It also limits an<br />

organization’s ability to effectively monitor its environment with changing threats,<br />

vulnerabilities, and technologies, thereby effecting missions/business functions. Without a fully<br />

implemented continuous monitoring program, management cannot conduct ongoing<br />

authorizations <strong>of</strong> information systems.<br />

Recommendation 10. We recommend that the <strong>Information</strong> <strong>Security</strong> Steering Committee<br />

develop, document, and implement an enterprise-wide continuous monitoring strategy<br />

that addresses framing risk, assessing risk, responding to risk, and monitoring risk, as<br />

required by NIST SP 800-39, Managing <strong>Information</strong> <strong>Security</strong> Risk.<br />

32<br />

NIST SP 800-53, CA-7, “Continuous Monitoring.”<br />

33<br />

<strong>Information</strong> <strong>Security</strong>: <strong>State</strong> Has Taken Steps To Implement a Continuous Monitoring Application, but Key<br />

Challenges Remain (GAO-11-149, July 8, 2011).<br />

22<br />

UNCLASSIFIED

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