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UNCLASSIFIED<br />

Management Comments: The <strong>Department</strong> stated that it “agrees some increased level <strong>of</strong><br />

documentation,” as was recommended, “would be valuable.”<br />

OIG Analysis: OIG considers this recommendation resolved. The recommendation can<br />

be closed when OIG reviews and accepts documentation showing that the ISSC has<br />

developed, documented, and implemented an enterprise-wide continuous monitoring<br />

strategy.<br />

Recommendation 11. We recommend that the Chief <strong>Information</strong> Officer in<br />

accordance with the requirements in NIST SP 800-39, Managing <strong>Information</strong><br />

<strong>Security</strong> Risk:<br />

� Implement a continuous monitoring strategy at the enterprise-wide level.<br />

� Obtain and use scanning s<strong>of</strong>tware to enable effective scans <strong>of</strong> non-<br />

Windows operating systems, databases, firewalls, routers, and switches.<br />

� Develop operating procedures to ensure the results are included in the Risk<br />

Scoring <strong>Program</strong> dashboard.<br />

� Develop procedures to ensure that System <strong>Security</strong> Owners update the<br />

system security plans to include a continuous monitoring strategy to detail<br />

how system security controls are to be monitored.<br />

Management Response: The <strong>Department</strong> stated that it is “already engaged in” efforts<br />

pertaining to the scanning s<strong>of</strong>tware, that it will “pursue [these efforts] with an appropriate<br />

level <strong>of</strong> priority,” that it “will expand the coverage <strong>of</strong> the risk scoring program,” and that<br />

it “will continue to expand coverage <strong>of</strong> risk in iPost.” As far as documenting a strategy in<br />

its security plans, the <strong>Department</strong> stated that “the continuous monitoring strategy is an<br />

enterprise level strategy” and therefore “does not need to be addressed in detail in every<br />

system security plan.”<br />

Regarding implementation <strong>of</strong> a continuous monitoring strategy at the enterprise-wide<br />

level, the <strong>Department</strong> stated that this implementation “will require continuous<br />

improvement and thus never be completed” and that its “current continuous monitoring<br />

implementation is being copied as a model by other government agencies and the private<br />

sector.”<br />

OIG Analysis: OIG considers this recommendation unresolved. Although OIG is aware<br />

that the <strong>Department</strong> has received nation-wide recognition for its continuous monitoring<br />

program, the <strong>Department</strong> must document a continuous monitoring strategy in every<br />

security plan, as required by NIST.<br />

Furthermore, in its response to the Government Accountability Office’s July 2011 report<br />

on information security, 34 the <strong>Department</strong> responded as follows: “<strong>State</strong> <strong>of</strong>ficials<br />

34<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 11-49, July 2011).<br />

23<br />

UNCLASSIFIED

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