Information Security: Weak Controls Place Interior's Financial	 
and Other Data at Risk (03-JUL-01, GAO-01-615). 		 
								 
This report reviews information system general controls over the 
financial systems maintained by the Department of the Interior at
its National Business Center (NBC) in Denver, Colorado.  GAO	 
found that although NBC-Denver has made progress in correcting	 
computer security weaknesses previously identified, there are	 
additional weaknesses in NBC-Denver's information system control 
environment. These weaknesses affected the center's ability to	 
prevent and detect unauthorized changes to financial information,
control electronic access to sensitive personnel information, and
restrict physical access to sensitive computing areas. NBC-Denver
did not adequately limit access granted to authorized users,	 
control all aspects of the system software controls, or secure	 
access to its network. Also, NBC-Denver had not fully established
a comprehensive program to routinely monitor access to its	 
computer facilities and data and to identify and investigate	 
unusual or suspicious access patterns that could indicate	 
unauthorized access. The primary reason for NBC-Denver's	 
information system general control weaknesses was that it had not
yet fully developed and implemented a comprehensive entitywide	 
program to manage computer security.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-615 					        
    ACCNO:   A01312						        
  TITLE:     Information Security: Weak Controls Place Interior's     
             Financial and Other Data at Risk                                 
     DATE:   07/03/2001 
  SUBJECT:   Computer security					 
	     Financial management systems			 
	     Computer software					 

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GAO-01-615
     
A

Report to the Secretary of the Interior

July 2001 INFORMATION SECURITY

Weak Controls Place Interior?s Financial and Other Data at Risk

GAO- 01- 615

Lett er

July 3, 2001 The Honorable Gale A. Norton The Secretary of the Interior

Dear Madam Secretary: We reviewed information system general controls 1 over
the financial systems maintained by the Department of the Interior at its
National Business Center (NBC) in Denver, CO. Effective information system
general controls are critical to NBC- Denver?s ability to safeguard assets
and ensure the confidentiality and reliability of financial management
information. Such controls also affect the security and reliability of

nonfinancial information, such as personnel information maintained by NBC-
Denver. Additionally, NBC- Denver uses its information systems to provide
computer processing services to other federal agencies.

Our review of Interior?s information system general controls was performed
in connection with the department?s financial audit conducted under the
Chief Financial Officers Act of 1990, as expanded by the Government
Management Reform Act of 1994. Our evaluation included follow- up on the
computer security weaknesses previously identified by Interior?s Office of
Inspector General (OIG). The results of our evaluation

of information system general controls were shared with Interior?s OIG for
its use in auditing Interior?s consolidated financial statements for fiscal
year 2000.

This report provides a general summary of the weaknesses we identified and
our resulting conclusions and recommendations. We are also issuing today a
report designated for ?Limited Official Use,? which describes in more detail
the computer security weaknesses identified and offers specific
recommendations for correcting each. After we completed our

1 Information system general controls affect the overall effectiveness and
security of computer operations as opposed to being unique to any specific
computer application. They include security management, operating
procedures, software security features, and physical protection designed to
ensure that access to data is appropriately restricted, only authorized
changes are made to computer programs, computer security duties are
segregated, and backup and recovery plans are adequate to ensure the
continuity of essential operations.

fieldwork and orally informed the acting assistant director of NBC- Denver
of the identified weaknesses, he provided us with information regarding
corrective actions taken or planned. Although these actions are noted in
this report, we have not yet evaluated their effectiveness. Results in Brief
Although NBC- Denver has made progress in correcting the computer security
weaknesses previously identified by the OIG and has taken other steps to
improve security, we identified additional weaknesses in NBCDenver?s
information system control environment. These weaknesses

affected the center?s ability to (1) prevent and detect unauthorized changes
to financial information, including payroll and other payment data, (2)
control electronic access to sensitive personnel information, and (3)
restrict physical access to sensitive computing areas. The effect of these
weaknesses is to place sensitive NBC- Denver financial and personnel
information at risk of unauthorized disclosure, critical financial
operations at risk of disruption, and assets at risk of loss. These
weaknesses and risks also affect other agencies that use computer processing
services at NBCDenver.

NBC- Denver did not adequately limit access granted to authorized users,
control all aspects of the system software controls, or secure access to its
network. Also, NBC- Denver had not fully established a comprehensive

program to routinely monitor access to its computer facilities and data and
to identify and investigate unusual or suspicious access patterns that could
indicate unauthorized access. Further, NBC- Denver was not providing
adequate physical security for its computer facility, appropriately
segregating computer functions, effectively controlling changes to
application programs, or fully ensuring that all aspects of its service
continuity needs were addressed.

A primary reason for NBC- Denver?s information system general control
weaknesses was that it had not yet fully developed and implemented a
comprehensive entitywide program to manage computer security. An effective
program would include issuing guidance and procedures for assessing risks,
establishing appropriate policies and related controls, raising awareness of
prevailing risks and mitigating controls, and evaluating the effectiveness
of established controls. While NBC- Denver has implemented a security
awareness program and taken other actions to improve security management, it
still needs to take additional steps to address the other key elements of a
computer security management

program. Such a program, if fully and effectively implemented, would

provide NBC- Denver with a solid foundation for resolving existing computer
security problems and continuously managing information security risks.

To improve information system general controls over NBC- Denver financial
operations, we are recommending that NBC- Denver correct the computer
security weaknesses identified and implement an effective entitywide
computer security management program. The acting assistant director of NBC-
Denver stated that he has agreed to correct the weaknesses that we
identified, and at the completion of our fieldwork, he provided us with a
comprehensive corrective action plan to address each of them.

In commenting on a draft of this report, the Acting Assistant Secretary for
Policy, Management, and Budget agreed with our recommendations. He noted
that approximately 50 percent of the recommendations had already been
implemented and that all of them would be implemented by December 31, 2001.

Background NBC- Denver is a service center operated by the Department of the
Interior. NBC- Denver develops and operates administrative and financial
systems

(including payroll/ personnel, administrative payments, accounts receivable,
property management, and accounting) for the Department of the Interior as
well as more than 30 other federal organizations, under

cross- servicing agreements. During fiscal year 2000, NBC- Denver reported
processing more than $9 billion in payroll payments for more than 200,000
employees from federal organizations, including the Department of Education,
Social Security Administration, and Pension Benefit Guaranty Corporation.
The center also provided accounting and financial reporting services to the
department and other federal agencies. For fiscal year 2000, NBC- Denver
reported processing more than 3 million nonpayroll financial

transactions totaling more than $3 billion. At the time of our review, NBC
was migrating several systems from its Reston, VA, service center to its
Denver facility. NBC- Reston was responsible for operating the department?s
standardized accounting system, which supports six Interior bureaus, seven
other federal activities,

and the department?s procurement system. As a result of this migration,
completed in January 2001, NBC- Denver will be responsible for providing all
centralized administrative and financial processing to department

bureaus and offices. NBC- Reston will continue to be responsible for
providing functional support for the department?s systems.

NBC- Denver is operated by the Office of the Secretary. The center relies on
a nationwide telecommunications network that links computer hardware at
remote locations serving the Department of the Interior?s 14 bureaus and
offices to the NBC- Denver mainframe computers. In addition, many of the
other federal organizations that NBC- Denver supports have direct
communications to link them with the center?s computers. At the time of our
review, there were about 37,000 users with access to NBC- Denver

systems. Objective, Scope, and

Our objective was to evaluate the design and test the effectiveness of
Methodology information system general controls over the financial systems
maintained and operated by the Department of Interior at its NBC- Denver
data center. These information system general controls also affect the
security and

reliability of other sensitive data, including personnel information
maintained on the same computer system as the department?s financial
information.

Specifically, we evaluated information system general controls intended to 
protect data and application programs from unauthorized access;  prevent
the introduction of unauthorized changes to application and

system software;  provide segregation of duties involving application
programming,

system programming, computer operations, information security, and quality
assurance;  ensure recovery of computer processing operations in case of a
disaster

or other unexpected interruption; and  ensure an adequate information
security management program.

To evaluate these controls, we identified and reviewed NBC- Denver policies
and procedures, conducted tests and observations of controls in operation,
and held discussions with NBC- Denver staff to determine whether information
system general controls were in place, adequately designed, and operating
effectively. In addition, we reviewed the Department of the Interior?s OIG
reports on information system general controls performed in connection with
the department?s annual financial

statement audits for fiscal years 1996 through 1999. Our evaluation was
based on (1) our Federal Information System Controls Audit Manual

(FISCAM), 2 which contains guidance for reviewing information system
controls that affect the integrity, confidentiality, and availability of
computerized data, and (2) our May 1998 report on security management best
practices at leading organizations, 3 which identifies key elements of an

effective information security program. We did not perform a review of
information system general controls at NBC- Reston because at the time of
our review, the key systems maintained at this center were in the process of
being migrated to NBC- Denver.

We performed our work at NBC- Denver from October 2000 through February
2001. Our work was performed in accordance with generally accepted
government auditing standards.

We requested comments on a draft of this report from the Department of the
Interior. The department provided us with written comments, which are
discussed in the ?Agency Comments? section and reprinted in appendix I.

Improvements Made in In 1997 and again in 1998, Interior?s OIG, in
connection with the Security, but Systems

department?s required annual financial statement audit, reported on computer
security weaknesses at NBC- Denver. Among the specific Remain Vulnerable
weaknesses reported were those related to limiting access granted to
authorized users, properly managing user IDs and passwords, adequately
controlling changes to system and application software, and completely
developing its business recovery plan. These weaknesses placed critical
department operations, such as financial management, personnel, and other
operations, at greater risk of misuse and disruption. NBC- Denver has made
progress in correcting the weaknesses identified by the OIG and has

taken other steps to improve security. Although NBC- Denver had addressed
weaknesses found by the OIG, we identified additional control weaknesses in
NBC?s information systems. Specifically, NBC- Denver had not adequately
limited the access granted to 2 Federal Information System Controls Audit
Manual, Volume I- Financial Statements Audits (GAO/ AIMD- 12. 19. 6, January
1999).

3 Information Security Management: Learning From Leading Organizations (GAO/
AIMD98- 68, May 1998).

all authorized users, controlled all aspects of the system software
environment, or completely secured access to its network. The risks created
by these access control weaknesses were heightened because the center had
not established a comprehensive program for routinely monitoring access
activity to identify and investigate unusual or suspicious access patterns
that could indicate unauthorized access. Consequently, financial, payroll,
and personnel programs and data maintained at NBCDenver

are at risk of inadvertent or deliberate misuse, fraudulent use, and
unauthorized alteration or destruction, which may occur without detection.

NBC- Denver Had Acted to NBC- Denver had made progress in addressing
computer security issues

Improve Security previously identified and reported on by Interior?s OIG in
connection with

the department?s 1997 and 1998 annual financial statement audits. For
example, the center had

 limited access to certain sensitive access privileges to critical
programs, software, and data;  improved user ID and password management
controls on its mainframe

computer;  updated its service continuity plan and developed a business
recovery

plan;  performed a risk assessment of its major applications;  established
a computer security awareness program for its employees;

and  developed and performed comprehensive tests of its computer security

disaster recovery plans. In addition, during the past 3 years, NBC- Denver
initiated other steps to improve computer security. These efforts included
(1) review of system software; (2) improvements in physical security,
including the addition of a guard service, installation of camera
surveillance, and use of electronic access cards; (3) review of system user
access; and (4) installation of intrusion detection software to monitor
network access.

Access Authority Was Not A basic management control objective for any
organization is to protect

Appropriately Limited for data supporting its critical operations from
unauthorized access, which

All Users could lead to improper modifications, disclosure, or deletion.

Organizations can protect this critical information by granting employees
authority to read or modify only those programs and data that they need to

perform their duties and by periodically reviewing access granted to ensure
that it is appropriate.

A key weakness in NBC- Denver?s controls was that the center had not
sufficiently restricted user access. While NBC- Denver had restricted access
to many users who previously had broad access to critical programs,
software, and data, we found instances where the center had not sufficiently
restricted access to only legitimate users, including those described below.

 About 400 users had access privileges to four sensitive system software
libraries that are allowed to perform sensitive system functions that can be
used to circumvent all security controls. Such access increased the risk
that users could bypass security controls to alter or delete any computer
data or programs on the system and should only be granted to system
programmers. This risk was further heightened because the

center had not established mitigating controls ,such as monitoring user
access to these sensitive libraries. The acting assistant director of
NBCDenver acknowledged that many of these users did not require access. 
About 1,000 users were given broad access privileges to a system software
resource that allows users to create and modify programs and

read and copy any data set to which such users have been granted read
access. Such access is generally used for program development and testing.
About 500 of the users were using this resource to run a set of standard
programs, a task that does not require this level of access. With broad
access privileges, users with knowledge of the security system

could create and modify computer programs and read and copy sensitive data.
 Seventeen system maintenance staff had access that allowed them to alter
or update system software resources used to control the storage of system
and data files. This control function is an automated process that

does not require users to have this type of access. With this access, users
could move sensitive files to unprotected areas and modify or delete
financial or sensitive data or disrupt computer operations.  About 80
application developers, both programmers and functional specialists, had
update access to payroll and personnel data. An

essential control for ensuring the integrity of a computer application is to
prevent software developers from having access to application programs and
data in the production environment. Developers with detailed knowledge of
the system?s processing functions could improperly add, alter, or delete
payroll and personnel data and programs without leaving evidence that the
system had been compromised.

One reason for NBC- Denver?s user access vulnerabilities was that access
authority was not being reviewed on a periodic basis. Such reviews would
have allowed the center to identify and correct inappropriate access.

In February 2001, the acting assistant director of NBC- Denver told us that
the center was reviewing staff access and would limit staff access to the
level required to carry out job responsibilities. Further, he said that the
center would develop and implement procedures by October 2001 to
periodically review access lists to ensure that access remains appropriate.

All System Software To protect the overall integrity and reliability of
information systems, it is Controls Were Not Adequate

essential to control access to and modifications of system software. System
software controls, which limit and monitor access to the powerful programs
and sensitive files associated with computer operations, are

important in providing reasonable assurance that access controls are not
compromised and that the system will not be impaired. To protect system
software, a standard computer control practice is to (1) configure system
software to protect against security vulnerabilities, (2) periodically
review programs in sensitive software libraries to identify potential
security weaknesses, and (3) ensure that only authorized and fully tested
system software is placed in operation.

While NBC- Denver had performed reviews of its system software environment
and corrected those security weaknesses identified, we identified other
areas where the center was not adequately controlling system software. These
system software control weaknesses could diminish the reliability of
financial and other sensitive information maintained on this computer
system. We found the following weaknesses:

 A weakness in the system software configuration could allow knowledgeable
users with access privileges that permit them to execute programs to bypass
access controls and gain unauthorized access to sensitive financial and
personnel information. In this case, the operating

system was set up so that programs in any of 34 libraries included in the
normal search sequence 4 could perform sensitive system functions and
operate outside security software controls. This increases the risk that if
unauthorized programs are introduced users could bypass other access

4 The search sequence is used by the operating system to find and execute
programs.

controls and improperly access or modify financial, audit trail, or other
sensitive information maintained on the computer system.  About 8,200
programs in sensitive software libraries, which have the

authority to perform sensitive functions that can circumvent security
controls, did not have unique program names. While multiple versions of the
same software are maintained by NBC- Denver to satisfy customer
requirements, an undetermined number of programs do not have unique program
names. Allowing more than one program in these libraries to have the same
name could lead to inadvertent or deliberate execution of an unauthorized
program that could compromise security controls.

NBC- Denver had not established a process to periodically review programs in
sensitive libraries for security weaknesses, such as programs with duplicate
names. Until NBC- Denver begins to actively review programs in sensitive
libraries, it will not have adequate assurance that other security controls
cannot be bypassed.

 Although NBC- Denver had a process for making changes to system software,
it had not established written procedures or guidance for system software
changes and had not developed guidance for testing changes or documenting
test results. An essential control in the system

software change process is that written procedures are established that set
forth requirements for requesting, authorizing, and approving these changes.
These procedures should include requirements for testing, performing a
technical review, and obtaining approval for each system software change
before implementation. During fiscal year 2000, NBCDenver

made more than 200 system software changes. Our review of a random sample of
20 changes for this period found that changes did not include documentation
for (1) tests on 13 changes, (2) technical reviews of 16 changes, or (3)
supervisory approvals on 16 software changes.

Consequently, NBC- Denver faces increased risks of unintended operational
problems caused by programming errors or the deliberate execution of
unauthorized programs.

In February 2001, the acting assistant director of NBC- Denver told us that
the center would implement additional policies and procedures, by October
2001, to (1) review system configuration settings periodically for security
vulnerabilities, (2) evaluate programs in sensitive system libraries to
identify and correct security exposures, and (3) document that system
software changes are tested, technically reviewed, and approved before
implementation.

Network Security Was Not Network security controls are key to ensuring that
only authorized

Sufficient individuals can gain access to sensitive and critical agency
data. These

controls include a variety of tools, such as user IDs and passwords, which
are intended to authenticate authorized users who access the network from
local and remote agency locations and through dial- in facilities. In
addition, network controls provide for safeguards to ensure that the system
software is adequately configured to prevent users from bypassing network
access controls or causing network failures.

The risks introduced by the weaknesses that we identified in access and
system software controls were compounded by network security weaknesses:
NBC- Denver was not adequately protecting access to its network or
restricting access to the system that processes financial and

other sensitive information. Specifically, the center had not adequately
managed user IDs and passwords, controlled dial- in access, or adequately
configured all its network servers. Thus, sensitive financial information
processed on the network is at increased risk that unauthorized modification
or disclosure could occur without detection. Because of NBC?s interconnected
environment, these network control weaknesses

also increase the risk of unauthorized access to financial and other
sensitive information (such as payroll, personnel, and financial management
information) maintained on the NBC- Denver mainframe computer. For example,

 The network had user ID and password management weaknesses that an
intruder could exploit to gain unauthorized access to the NBCDenver network.
For example, on one network server, we identified easily guessed passwords
and passwords that had not been used since 1998. On another network, network
commands available to all users allowed access to a listing that included
password information.  An ID and password used for dial- in access to the
centralized modem pool was easily guessed. We were able to guess a user ID
and password

that provided an access path into the network. With this access we were able
to browse the internal network and collect information about the network,
which could be used to identify and exploit network vulnerabilities. The
lack of adequate dial- in access controls increases the risk that a hacker
could obtain access to the network, from which an attack could be launched
on the mainframe to gain access to critical financial and sensitive
department information. NBC- Denver staff corrected this network
vulnerability before we completed our

fieldwork.

 The network had system software configuration weaknesses that could allow
users to bypass access controls and gain unauthorized access to NBC- Denver
networks or cause network system failures. For instance, certain network
systems configuration settings allowed unauthorized users to connect to the
network without entering a valid user ID and

password combination. This could allow unauthorized individuals to obtain
access to system information describing the network environment, including
user IDs and password information. These network security weaknesses
increased the risk that someone could gain unauthorized access to
information on the network and that intruders or authorized users with
malicious intent could exploit the network

weaknesses to misuse, improperly disclose, or destroy financial and other
sensitive information.

In February 2001, the acting assistant director of NBC- Denver told us that
all accounts that had not been used within the prior 90 days had been
deleted. Also, the acting assistant director told us that all test accounts
and other easily guessed passwords had been removed. In addition, he stated
that network system software configurations were reviewed and changes made
to limit security vulnerabilities. Further, he informed us that policies and
procedures had been developed and implemented to periodically

review network password settings, accounts, and network system software
configurations. Program to Monitor Access

The risks created by the access control problems described above were
Activities Was Not Complete

heightened because NBC- Denver had not yet established a comprehensive
program to monitor user access. Such a program would include routinely
reviewing user access activity to identify and investigate failed attempts
to access sensitive data and resources, as well as unusual and suspicious
patterns of successful access to sensitive data and resources. Such a

program is critical to ensuring that improper access to sensitive
information is detected.

The most effective monitoring efforts are those that selectively target
unauthorized, unusual, and suspicious patterns of access to sensitive data
and resources, such as security software, system software, application
programs, and production data. While the center had begun to review failed
attempts to access sensitive system resources (e. g., security software and
sensitive system software), it had not established a program to monitor
successful access to production resources, including application programs

and data. Thus, there is an increased risk that application developers with
access to production programs and data could add, alter, or delete payroll
and personnel information (for example) without being detected, since these
types of user activities were not being monitored. In addition, although
NBC- Denver was reviewing access to certain system software, its process did
not include logging all critical activities, such as access violations to or
modifications made to all sensitive system libraries.

While NBC- Denver had installed an intrusion detection system to monitor
access to its network, it had not established procedures for managing this
system. For example, it had not established procedures for (1) determining

where on its network it will monitor access, (2) protecting intrusion data
from tampering, and (3) classifying, storing, analyzing, and using intrusion
data to identify agency network vulnerability patterns. Further, it had not
established procedures for following up and reporting on system anomalies or
computer misuse after initial alarms are triggered. Without procedures for
addressing these types of activities, NBC- Denver reduces its ability to
establish and maintain an effective intrusion detection program, which

reduces the risk of unauthorized access of computer resources. In February
2001, the acting assistant director of NBC- Denver told us that by January
2002, the center would expand its user access monitoring program to include
all sensitive system libraries and critical application production programs
and data. Further, he stated that the center planned to develop and
implement procedures for managing its intrusion detection

program and reporting the results of unusual or suspicious access
activities.

Other Information In addition to the information system access controls
discussed above, System Controls Were

other important controls should be in place to ensure the integrity and
reliability of an organization?s data. These information system controls Not
Sufficient

include policies, procedures, and control techniques to physically protect
computer resources and restrict access to sensitive information, provide
appropriate segregation of duties of computer personnel, prevent
unauthorized changes to application programs, and ensure the continuation of
computer processing operations. We found weaknesses in each of these areas.

Physical Security Controls Physical security controls are important for
protecting computer facilities Were Not Adequate and resources from
espionage, sabotage, damage, and theft. These controls involve restricting
physical access to computer resources, usually by limiting access to the
buildings and rooms where they are housed and

periodically reviewing access granted to ensure that it continues to be
appropriate. At NBC- Denver, physical access control measures (such as
locks, guards, badges, and alarms, used alone or in combination) are vital
to safeguarding critical financial and sensitive personnel information and
computer operations from internal and external threats.

Although NBC- Denver policy requires a photo access card to gain access, via
electronically controlled doors, to the building that contains the computer
center, we observed on different occasions that several people

entered the building by merely following one person with an authorized
access card. While guards were posted at the entrance to the building, we
observed that they were not checking each person entering the building for
an appropriate NBC- Denver photo access card. Thus, individuals who did not
have NBC- Denver photo access cards could pass unchallenged through the main
entry doors and gain unauthorized access to the facility, increasing the
risk that intruders with malicious intent might obtain access to sensitive
computer resources or disrupt operations.

Further, we identified 40 employees and contractors, including mail room,
facility support, computer support, tape librarian, local- area network
(LAN) support, and personnel/ payroll staff, who had access to the
electrical room. This room contains fiber optic boxes that could be used by
a knowledgeable person to establish an unauthorized internal connection to
the center?s computer system. While it is appropriate for facility and
computer support staff to have access to the electrical room, care should

be taken to limit access to only those staff who need access to perform
their job responsibilities. NBC- Denver had not established policies and
procedures for granting access to the electrical room. We also determined
that the center had not restricted physical access to a console in the tape
library with master console authority, which could be used to issue
sensitive operator commands. Although at the time of our

review this console had only recently been moved to its temporary location,
the area was unprotected and provided an opportunity for unauthorized
individuals entering the building to use the console to issue commands that
could disable security access checking or cause the system

to fail. Allowing unrestricted access to this console increased the risk of
unauthorized access to NBC- Denver systems and disruption of services.

In February 2001, the acting assistant director of NBC- Denver told us that
a policy would be developed and implemented to ensure that photo
identification access cards would be checked on all individuals entering the
facility that houses the main computer. In addition, the acting assistant
director told us that a policy for granting and periodically reviewing
access to the electrical room would be developed. Further, the acting
assistant

director told us that the master console command capabilities were removed
from the operator console in the tape library in December 2000.

Computer Duties Were Not Another fundamental technique for safeguarding
programs and data is to Always Properly Segregated

segregate the duties and responsibilities of computer personnel so as to
reduce the risk that errors or fraud will occur and go undetected.
Incompatible duties that should be separated include application and system
programming, production control, database administration, computer
operations, and data security. Once policies and job descriptions supporting
the principles of segregation of duties have been developed, it is important
to ensure that adequate supervision is provided and adequate

access controls are in place to ensure that employees perform only
compatible functions.

Although computer duties were generally properly segregated at NBCDenver, we
identified instances where controls did not enforce segregation of duties
principles. For example, two application support staff had access privileges
that allowed them to modify financial production programs and

data as well as security- related information. These staff were assigned
responsibility for performing certain functions related to security
administration and production program maintenance. Under normal
circumstances, staff with security responsibilities should report to the

security administrator and have no programming duties. However, because
these individuals had both program and security administration access
privileges, they had the ability to change programs and data and eliminate
any evidence of their activity in the system. Compounding this risk,
NBCDenver was not monitoring the system activities of these individuals.
Allowing staff the capability to modify financial programs and security
information without compensating controls increases the risk of unauthorized
modification of critical financial data.

In addition, NBC- Denver did not provide supervisory oversight to its
computer operators on selected weekend shifts, nor was it routinely
reviewing the console activity logs for these shifts to ensure that only
authorized operational activities were being conducted. Controls over

personnel activities require active supervision and review of these
activities. To aid in this oversight, all computer operator activities on
the computer system should be recorded on an automated history log; this log

should be reviewed routinely by supervisory staff and any abnormalities
investigated. Because these controls were not implemented, NBC- Denver
increased its risk that unauthorized activities could occur on these shifts
without detection. In February 2001, the acting assistant director of NBC-
Denver told us that the two application staff would be given access to a
second user ID so that they could perform certain needed operational
functions on an ad hoc

basis. This ID will be tightly controlled, requiring management approval for
its use and audit recording and review of all access activities. Further,
the acting assistant director told us that lead operators were being added
to those shifts where only one operator was assigned. The lead operator
would also be responsible for reviewing all changes made at the system
console.

Changes to Application It is important to ensure that only authorized and
fully tested application

Programs Were Not programs are placed in operation. To ensure that changes
to application

Adequately Controlled programs are needed, work as intended, and do not
result in the loss of data or program integrity, such changes should be
documented, authorized,

tested, and independently reviewed. In addition, as part of the application
change control process, library management software should be used to
control program versions, and test procedures should be established to

ensure that only authorized changes are made to program code. Changes to
application programs at NBC- Denver were not adequately documented or
controlled. Described below are several examples of application change
control weaknesses.

 Although a change control board at NBC- Denver was responsible for
authorizing all application changes, the authorizations for these changes
were not formally documented. For example, in a random sample of 20
application changes made during fiscal year 2000, none of the changes

had formal documentation to show that the software modifications had been
authorized by the change control board.  Documentation was not always
maintained to provide evidence of the specific program modifications made or
their approval. Specifically, the

change control documentation for 13 of the 20 changes that we

reviewed did not include a description of the specific modifications made to
the program code or evidence of supervisory approval.  NBC- Denver did not
use automated library management software to ensure that program versions
were not accidentally misidentified and to avoid simultaneous changes to the
same program.

 Procedures were not in place to periodically test program code to ensure
that only authorized changes had been made. Without a clearly defined and
implemented application change control process, changes may be implemented
that are not authorized, tested, documented, or approved. Further, NBC-
Denver is at greater risk that software supporting its operations will not
produce reliable data or effectively meet operational needs.

In February 2001, the acting assistant director of NBC- Denver told us that
a form would be developed and attached to each modification request to (1)
document authorization for program changes, (2) record a description of the
change made, (3) identify program modules modified, and (4) provide for the
signature of the reviewing official. Also, he stated that NBC- Denver would
perform program code reviews to ensure that only

authorized program changes are made. Service Continuity Planning

An organization must take steps to ensure that it is adequately prepared to
Was Not Complete

cope with a loss of operational capability due to earthquakes, fires,
accidents, sabotage, or any other disruption. An essential element in
preparing for such catastrophes is an up- to- date, detailed, and fully
tested disaster recovery plan that covers all key computer operations and
includes plans for business recovery. Such a plan is critical for helping to
ensure that information system operations and data, such as financial
processing and related records, can be promptly restored in the event of a

disaster. To ensure that it is complete and fully understood by all key
staff, the disaster recovery plan should be tested annually and the test
plans and results documented to provide a basis for improvement. In
addition, critical computer data and programs should be stored off site and
periodically inventoried.

While NBC- Denver had conducted comprehensive tests of its computer center
disaster recovery plan, improvements are still needed in some areas of its
overall plan, including the business recovery plan. Described below are
examples of service continuity weaknesses identified at NBC- Denver.

 NBC- Denver had not conducted unannounced tests or walk- throughs of its
disaster recovery plan. Instead, all tests had been planned with
participants fully aware of the disaster recovery test scenario. In an
actual disaster, there is usually little or no warning.

 Critical backup files for financial and sensitive agency personnel
programs, data, and software stored off site were not inventoried. As a
result, if a disaster befell the center?s main computer facility, there are
no assurances that all critical and sensitive system resources would be
available to fully restore all key systems.  NBC- Denver had not tested its
business recovery plan annually as required by the center?s plan. The plan
has not been tested since October

1999. Conducting tests of the plan serves to reinforce staff roles and
responsibilities in a disaster and in the process provides greater assurance
that business operations will be restored if a disaster occurs.

In February 2001, the acting assistant director of NBC- Denver told us that
the center will begin performing periodic walk- throughs of its various
disaster recovery plans by October 1, 2001. Also, policy and procedures will
be developed that will require a semiannual inventory of programs, data, and
software files stored off site. Further, he stated that center staff will
ensure that the NBC- Denver business recovery plan is tested at least
annually, as required by the existing NBC- Denver procedures.

Computer Security A key reason for NBC- Denver?s weaknesses in information
system controls Management Program Is was that it had not yet fully
developed and implemented a comprehensive

Essential entitywide security management program to ensure that effective
controls were established and maintained and that computer security received
adequate attention. Our May 1998 study of security management best practices
found that a comprehensive computer security management program is essential
to ensure that information system controls work

effectively on a continuing basis. 5 An effective computer security
management program would include

 establishing a central security management staff that provides guidance
and oversight for the computer security management program,  performing
periodic risk assessments,  establishing appropriate policies and
procedures,  raising security awareness, and

5 GAO/ AIMD 98- 68.

 evaluating the effectiveness of established controls. NBC- Denver had
taken action related to each of the key elements described above, including
the implementation of a comprehensive security awareness program both for
employees and contractors. However, aside from security awareness, the steps
taken to address the other key elements of a comprehensive security
management program were not sufficient to ensure the continuing success of
the program.

The first key element of effective computer security management is the
establishment of a central security group. This function serves to provide
overall security policy and guidance for the organization. In addition, it
provides the oversight to ensure compliance with established policies and
procedures and reviews the effectiveness of the security environment.

NBC- Denver had not established a central computer security management
staff. Instead, NBC- Denver relied on the IT security manager and certain
staff assigned to the network, facilities, and application functions to

perform security tasks. Although these staff had general department guidance
on information security, NBC- Denver had not developed specific policies and
procedures that clearly defined the security roles and responsibilities of
these staff and the reporting lines between the security functions. In
addition, there were no specific procedures requiring these

staff to coordinate on security- related issues, such as policy development
and implementation, risk assessment, monitoring compliance with established
policies and procedures, and reviewing the effectiveness of controls. A
second key aspect of computer security management is periodically assessing
risk. Regular risk assessments assist management in making decisions on
necessary controls by helping to ensure that security resources are
effectively distributed to minimize potential loss. Also, by increasing the
awareness of risks, these assessments generate support for the adopted
policies and controls, which helps ensure that the policies and controls
operate as intended.

Although Department of the Interior policy requires that risk assessments be
performed whenever significant changes are made to a facility or its
computer systems, but at least every 5 years, NBC- Denver had not developed
a framework for assessing and managing risk when significant changes
occurred. During the past year, the center upgraded its mainframe operating
system and added servers to its network. Each of these events

was a significant change that warranted a separate risk assessment. However,
while NBC- Denver had performed risk assessments for part of the key
applications, it had not performed a risk assessment when these

significant changes occurred. A third key element of effective security
management is having established policies and procedures governing a
complete computer security program. Such policies and procedures should
integrate all security aspects of an organization?s interconnected
environment, including local area network, wide area network, and mainframe
security. The integration of network

and mainframe security is particularly important as computer systems become
more and more interconnected.

NBC- Denver had not yet established comprehensive policies and procedures to
govern a complete computer security program. While the center had made
progress in developing policies and procedures for specific security areas,
including remote dial- in access, the network

firewall, incident response capability, and user ID and password management,
it had not developed an overall policy on computer security. This policy
would address security requirements for physical and logical access control,
segregation of duties, application change control, service

continuity, and security management covering both network and mainframe
environments. In addition, NBC- Denver had not developed technical standards
for implementing security software and maintaining operating system
integrity on either its mainframe or network systems. Such standards would
not only help ensure that appropriate computer controls are established
consistently, but would also facilitate periodic reviews of these controls.

A fourth key area of security program management is promoting security
awareness. Computer attacks and security breakdowns often occur because
computer users fail to take appropriate security measures. For this reason,
it is vital that employees who use computer systems in their day- today

operations be aware of the importance and sensitivity of the information
they handle, as well as the business and legal reasons for maintaining its
confidentiality and integrity. In accepting responsibility for

security, employees should, for example, devise effective passwords, change
them frequently, and protect them from disclosure. In addition, employees
should help maintain physical security over their assigned areas.

NBC- Denver had established a security awareness program for all its
employees and contractors. Specifically, NBC- Denver developed a computer-
based security awareness program that all of its employees and contractor
staff are required to complete annually. Further, NBC- Denver had
established procedures to monitor compliance with this requirement.

A final key area of an overall computer security management program is an
ongoing security oversight program. Such a program includes processes for
(1) monitoring compliance with established information system control
policies and procedures, (2) testing the effectiveness of information system
controls, and (3) improving information system controls based on the results
of these activities.

NBC- Denver had not established a program to routinely monitor and evaluate
the effectiveness of information system controls. Such a program would allow
NBC- Denver to ensure that policies remain appropriate and that controls
accomplish their intended purpose.

Weaknesses discussed in this report could have been identified and corrected
if the center had been monitoring compliance with established procedures.
For example, if NBC- Denver had periodically reviewed user access authority
to ensure that it was limited to the minimum required access level based on
job requirements, the center would have been able to discover and limit the
access of application development staff to sensitive

system resources. Likewise, routinely evaluating the technical
implementation of its system software would have permitted the center to
eliminate or mitigate the additional system software exposures discussed in
this report. A program to regularly test information system controls would
also have allowed NBC- Denver to detect additional network security
weaknesses. For example, using network analysis software designed to detect
network

vulnerabilities, we identified user accounts and services that could provide
hackers with information to exploit the network and launch an attack on NBC-
Denver systems. Although NBC- Denver fixed this problem before our fieldwork
was completed, center staff could have identified and corrected this
exposure using similar network analysis software available to them.

In February 2001, the acting assistant director of NBC- Denver told us that
a security oversight team would be established to coordinate overall
security at the center. In conjunction with this effort, he said that
policies and procedures would be developed and implemented that define the
roles and

responsibilities of all NBC- Denver functions involved in security
management. These policies and procedures will include requirements for
coordinating security activities among the designated security functions.

He added that NBC- Denver will develop a framework for risk assessments,
including a policy and procedures for performing risk assessments for the
physical facility, application, and computer center environments. In
addition, the acting assistant director told us that his staff was currently
developing a comprehensive site security policy that will include technical
standards for each operating computer platform. He also said that the center
will develop a security oversight program to monitor compliance with
established information system control policies and procedures, test the
effectiveness of information system controls, and improve information

system controls based on the results of these activities. These computer
security management elements are to be implemented no later than October
2001, according to the acting assistant director. Conclusions Information
system general controls are critical to NBC- Denver?s ability to ensure the
reliability of Interior?s financial management information and

maintain the confidentiality of sensitive personnel and other department
information. While NBC- Denver has made progress in correcting the computer
security weaknesses that Interior?s OIG identified and has taken other steps
to improve security, additional weaknesses were identified in NBC- Denver?s
information system control environment. Specifically, NBCDenver

had not adequately limited users access, controlled system software, secured
network access, or established a program to comprehensively monitor access.
Also, NBC- Denver was not providing adequate physical security, segregating
computer functions, controlling changes to application programs, or ensuring
that all aspects of its service continuity needs were addressed. These
weaknesses placed sensitive NBCDenver

financial and personnel information at risk of disclosure, critical
financial operations at risk of disruption, and assets at risk of loss.
These weaknesses could also affect other agencies that depend on NBC-
Denver?s computer processing services.

A primary reason for NBC- Denver?s information system control weaknesses was
that it had not yet fully developed and implemented a comprehensive computer
security planning and management program. A comprehensive program for
computer security management is essential for achieving an effective
information system general control environment.

Effective implementation of such a program provides for periodically
assessing risks, implementing effective controls for restricting access

based on job requirements and actively reviewing access activities,
communicating the established policies and controls to those who are
responsible for their implementation, and perhaps most important, evaluating
the effectiveness of policies and controls to ensure that they remain
appropriate and accomplish their intended purpose. The acting assistant
director of NBC- Denver stated that he has recognized the seriousness of the
weaknesses we identified and at the completion of our fieldwork provided us
with a comprehensive corrective action plan to address each of them.

Recommendations for To establish an effective information system general
control environment, Executive Action

we recommend that you instruct the Director of the National Business Center
and the acting assistant director of NBC- Denver, in coordination with the
Interior Chief Information Officer (CIO), to ensure that the following
actions are completed.

 NBC- Denver corrects the information system control weaknesses related to
access authority, system software, network security, access monitoring,
physical access, segregation of duties, program changes,

and service continuity. These specific weaknesses are described in a
separate report designated for ?Limited Official Use,? also issued today. 
NBC- Denver develops and implements an effective computer security
management program. Such a program would include (1) establishing a

central security group to manage a cycle of security management activities,
(2) assessing risk to determine computer security needs, (3) developing and
implementing policies and controls that meet these

needs, and (4) instituting an ongoing program of tests and evaluations to
ensure that policies and controls are appropriate and effective. In
addition, we recommend that you instruct the Interior CIO, as the
department?s key official responsible for computer security, to report
periodically to you, or your designee, on progress in implementing
Interior?s corrective action plans.

Agency Comments In commenting on a draft of this report, the Acting
Assistant Secretary for Policy, Management, and Budget agreed with our
recommendations. He reported that to date, approximately 50 percent of the
recommendations

made had been implemented, and that action on all of them would be completed
by December 31, 2001.

This report contains recommendations to you. The head of a federal agency is
required by 31 U. S. C. 720 to submit a written statement on actions taken
on these recommendations to the Senate Committee on Governmental Affairs and
the House Committee on Government Reform not later than 60 days after the
date of this report. A written statement also must be sent to the House and
Senate Committees on Appropriations with agency?s first

request for appropriations made more than 60 days after the date of this
report. We are sending copies of this report to Senator Conrad Burns,
Senator Robert C. Byrd, Senator Joseph Lieberman, Senator Ted Stevens,
Senator Fred Thompson, Representative Dan Burton, Representative Norman
Dicks, Representative Joe Skeen, and Representative Henry A. Waxman in their
capacities as Chairmen or Ranking Minority Members of the Senate and House
Committees. We will also send copies to Mitchell E. Daniels, Jr., Director,
Office of Management and Budget; Robert J. Lamb, Acting

Assistant Secretary for Policy, Management and Budget, Department of the
Interior; Daryl W. White, Chief Information Officer, Department of the
Interior; Timothy G. Vigotsky, Director of the National Business Center; and

Earl E. Devaney, Inspector General of the Department of the Interior. Copies
will also be made available to others upon request and will be available on
our home page at http:// www. gao. gov.

If you have any questions or wish to discuss this report, please contact me
at (202) 512- 3317 or Dave Irvin at (214) 777- 5716. We can also be reached
at daceyr@ gao. gov and irvind@ gao. gov. Key contributors to this report
are listed in appendix II. Sincerely yours,

Robert F. Dacey Director, Information Security Issues

Comments From the Department of the

Appendi x I Interior

Appendi x II

GAO Contact and Staff Acknowledgements GAO Contact Dave Irvin, (214) 777-
5716 Acknowledgements In addition to the person named above, Edward
Alexander, Lon Chin,

Debra Conner, Denise Fitzpatrick, Edward Glagola, David Hayes, Sharon
Kittrell, Jeffrey Knott, West Coile, Harold Lewis, Suzanne Lightman, Duc
Ngo, Tracy Pierson, Norman Poage, and Charles Vrabel made key

contributions to this report.

(310115) Lett er

GAO United States General Accounting Office

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Appendix I

Appendix I Comments From the Department of the Interior

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Appendix I Comments From the Department of the Interior

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Appendix II

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