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UNCLASSIFIED<br />

� The development <strong>of</strong> the new data center ESOC West.<br />

In addition, we identified the following deficiencies:<br />

� IRM had not documented an entity-wide Business Impact Analysis (BIA) to ensure<br />

the coordination <strong>of</strong> the recovery prioritizations <strong>of</strong> critical mission/business processes<br />

and services in the event <strong>of</strong> a disruption within the ESOC. The BIA had not been<br />

documented because IRM does not think that the entity-wide BIA applies to its<br />

contingency planning process. However, NIST SP 800-34, Revision 1, 38 states that<br />

the BIA helps identify and prioritize information systems and components critical to<br />

supporting the organization’s mission/business processes.<br />

� The entity-wide process-based BIA, which supports COOP functions developed by<br />

the Office <strong>of</strong> Emergency Management (OEM) to support Federal Continuity<br />

Directive 2 (FCD-2), does not agree with the OpenNet Contingency Plan. For<br />

example, OEM <strong>of</strong>ficials stated that the infrastructure should not be interrupted in the<br />

event <strong>of</strong> a disaster, and IRM <strong>of</strong>ficials stated that the infrastructure Maximum<br />

Tolerable Downtime is 24 hours. The inconsistency between the two documents<br />

occurred because the <strong>Department</strong> does not require OEM and IRM to coordinate with<br />

the continuity <strong>of</strong> operations planning. According to NIST SP 800-34, Revision 1,<br />

information systems that support COOP functions will be identified in the processbased<br />

BIA.<br />

An out-<strong>of</strong>-date COOP CCP increases the risk that the <strong>Department</strong> may not be able to<br />

recover in a timely manner or may experience difficulty in recovering from a disaster.<br />

Additionally, the IRM CCP supports the <strong>Department</strong> COOP; therefore, the COOP relies upon the<br />

CCP to be current. Without a BIA, there is an increased risk that the <strong>Department</strong> will not<br />

recover mission-critical functions based on established recovery priorities. Additionally, the lack<br />

<strong>of</strong> communication between OEM and IRM may cause incongruent requirements and the<br />

expectations in the availability <strong>of</strong> the infrastructure in the event <strong>of</strong> a disaster.<br />

Recommendation 12. We recommend that the Chief <strong>Information</strong> Officer, as required by<br />

NIST SP 800-34, Revision 1, “Contingency Planning Guide for Federal <strong>Information</strong><br />

Systems,” take the following actions:<br />

� Update the Continuity <strong>of</strong> Operations Communication Plan annually or<br />

when changes occur to the organization, network hardware, systems, and<br />

applications and, if necessary, after Continuity Testing.<br />

� Perform an entity-wide Business Impact Analysis and develop a strategy to<br />

prioritize recovery <strong>of</strong> the critical assets within the <strong>Department</strong> <strong>of</strong> <strong>State</strong>.<br />

� Update the Foreign Affairs Manual that contains guidance and direction for<br />

development and implementation <strong>of</strong> Continuity <strong>of</strong> Operations<br />

Communication Plan.<br />

38 NIST SP 800-34, rev. 1.<br />

25<br />

UNCLASSIFIED

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