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Commonwealth of Virginia Single Audit Report for the Year Ended ...

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Not including <strong>the</strong> specific access on <strong>the</strong> Security Access Request <strong>for</strong>m and not specifying a<br />

time frame <strong>for</strong> deleting or disabling system access in <strong>the</strong> agency’s policies increases <strong>the</strong> risk <strong>of</strong><br />

employee’s having unnecessary access to sensitive and high risk applications. There<strong>for</strong>e, <strong>the</strong><br />

Commission should establish a policy that documents <strong>the</strong> specific access needed by agency<br />

employees and a policy that defines a reasonable time frame <strong>for</strong> disabling and deleting systems<br />

access.<br />

Management Plan <strong>for</strong> Corrective Action <strong>for</strong> State Corporation Commission<br />

Access Levels: Commission current policies outline <strong>the</strong> concepts <strong>of</strong> least privilege<br />

and <strong>the</strong> established access requirements to SCC Systems. The System Access Request<br />

<strong>for</strong>m will be revised to include <strong>the</strong> specific access level requested <strong>for</strong> each user’s<br />

application.<br />

Defined Timeframe: During <strong>the</strong> existing annual review <strong>of</strong> <strong>the</strong> security policies, <strong>the</strong><br />

Commission will evaluate and revise <strong>the</strong> Access and Account Management Policy as<br />

necessary to define a reasonable time frame <strong>for</strong> disabling or deleting systems access.<br />

Responsible Party: In<strong>for</strong>mation Technology Officer and In<strong>for</strong>mation Security Officer<br />

Estimated Completion Date: December 31, 2012<br />

11-05: Improve User Account Controls<br />

Applicable to: Alcoholic Beverage Control<br />

The Department <strong>of</strong> Alcoholic Beverage Control (ABC) nei<strong>the</strong>r deletes disabled user accounts<br />

nor reviews disabled user account activity. While certain access restrictions would prevent nonsystem<br />

users from improperly using <strong>the</strong>se accounts, a knowledgeable insider could use <strong>the</strong> lack <strong>of</strong><br />

account monitoring and not deleting <strong>the</strong> accounts to take advantage <strong>of</strong> this lack <strong>of</strong> control to<br />

improperly circumvent <strong>the</strong> system without detection. Most breaches <strong>of</strong> in<strong>for</strong>mation security and loss<br />

<strong>of</strong> data and assets comes from insiders taking advantage <strong>of</strong> <strong>the</strong> system.<br />

ABC’s data retention policy requires <strong>the</strong> removal <strong>of</strong> disabled user accounts from In<strong>for</strong>mation<br />

Technology (IT) systems after three years. However, ABC is not en<strong>for</strong>cing its data retention policy<br />

nor is ABC monitoring disabled user account access to ensure that no one has improperly used <strong>the</strong><br />

accounts. Both <strong>the</strong> monitoring and <strong>the</strong> eventual removal are essential internal controls to protect<br />

in<strong>for</strong>mation and assets. There<strong>for</strong>e, we recommend that ABC dedicate <strong>the</strong> necessary resources to<br />

delete disabled user accounts and monitor disabled user accounts <strong>for</strong> unusual activity. ABC also<br />

needs to re-evaluate its current three year user account retention policy and develop a policy where<br />

<strong>the</strong> timeframe is commensurate with <strong>the</strong> risk identified in its IT risk assessment and business impact<br />

analysis.<br />

12

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