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Evaluation of Department of State Information Security Program ...

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UNCLASSIFIED<br />

J. Oversight <strong>of</strong> Contractor Systems and Extensions Needs Improvement<br />

The <strong>Department</strong> had not implemented an effective program for the oversight <strong>of</strong><br />

contractor systems and contractor extensions (remote network connections to <strong>Department</strong><br />

systems). Although the <strong>Department</strong> established initial contract agreements and conducted initial<br />

risk assessments for contractor extensions, we noted several deficiencies. For example, COCO<br />

systems did not have security-related documentation. The FAM 43 and NIST SP 800-47 44 require<br />

that the <strong>Department</strong> document the interconnection agreements between the network and the<br />

contractor with language similar to that contained in a memorandum <strong>of</strong> understanding (MOU)<br />

and an interconnection security agreement (ISA). The agreement must be submitted to IRM/IA.<br />

Specifically, for COCO systems, IRM/IA did not provide documentation for the<br />

following:<br />

� For all five COCO systems, a contractor agreement and system security<br />

documentation were lacking for the <strong>State</strong> Assistance Management System<br />

(SAMS); the Consular Visa System (CVS); the Antiterrorism Assistance<br />

(ATA) Student Database; the Foreign Service Office Tester (FSOT) system,<br />

and the Gateway to <strong>State</strong> (GTS). The <strong>Department</strong> relies on a decentralized<br />

security program whereby system owners/bureaus are responsible for<br />

overseeing COCO systems that provide services to a bureau.<br />

� Of five COCO systems, ATOs were not made available for review for four<br />

systems (SAMS, CVS, ATA database, and FSOT). According to OMB, 45<br />

the <strong>Department</strong> must assess security controls in accordance with NIST<br />

guidelines for contractor systems that collect, process, maintain, and house<br />

Government information.<br />

The list <strong>of</strong> OpenNet extensions does not contain a complete inventory <strong>of</strong> workstations at<br />

other Government agencies. For example, OpenNet terminals (workstations) were observed by<br />

an OIG audit team at International Boundary and Water Commission (IBWC) and Broadcasting<br />

Board <strong>of</strong> Governors (BBG) <strong>of</strong>fices. These connections are not on the list <strong>of</strong> OpenNet extensions.<br />

The <strong>Department</strong> tracks only OpenNet extensions at contractor sites and vendors and does not<br />

include other third parties, such as Government agencies.<br />

We also found that the <strong>Department</strong> did not have an effective mechanism in place to<br />

identify the total number <strong>of</strong> contractors’ personnel who had access to and privileges within the<br />

<strong>Department</strong>’s network, applications, databases, and data. OMB Memorandum M-11-33 states:<br />

“Agencies must develop policies for information security oversight <strong>of</strong> contractors and other users<br />

with privileged access to Federal data. Agencies must also review the security <strong>of</strong> other users<br />

with privileged access to Federal data and systems.”<br />

43 5 FAM 1065.3-1, “Requests for Interagency and Non-<strong>Department</strong> Connectivity.”<br />

44 NIST SP 800-47, <strong>Security</strong> Guide for Interconnecting <strong>Information</strong> Technology Systems,, Aug 2002.<br />

45 OMB Memorandum M-10-15, FY 2010 Reporting Instructions for the Federal <strong>Information</strong> <strong>Security</strong> Management<br />

Act and Agency Privacy Management.<br />

29<br />

UNCLASSIFIED

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