Information Security: Further Efforts Needed to Fully Implement  
Statutory Requirements in DOD (24-JUL-03, GAO-03-1037T).	 
                                                                 
The Department of Defense (DOD) faces many risks in its use of	 
globally networked computer systems to perform operational	 
missions--such as identifying and tracking enemy targets--and	 
daily management functions--such as paying soldiers and managing 
supplies. Weaknesses in these systems, if present, could give	 
hackers and other unauthorized users the opportunity to modify,  
steal, inappropriately disclose, and destroy sensitive military  
data. GAO was asked, among other things, to discuss DOD's efforts
to protect its information systems and networks from cyber	 
attack, focusing on its reported progress in implementing	 
statutory information security requirements.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-1037T					        
    ACCNO:   A07706						        
  TITLE:     Information Security: Further Efforts Needed to Fully    
Implement Statutory Requirements in DOD 			 
     DATE:   07/24/2003 
  SUBJECT:   Computer crimes					 
	     Computer networks					 
	     Computer security					 
	     Hackers						 
	     Information systems				 
	     Internal controls					 

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GAO-03-1037T

Testimony Before the Subcommittee on Terrorism, Unconventional Threats and
Capabilities, Committee on Armed Services, House of Representatives

United States General Accounting Office

GAO For Release on Delivery Expected at 10: 00 a. m. EDT Thursday, July
24, 2003 INFORMATION SECURITY

Further Efforts Needed to Fully Implement Statutory Requirements in DOD

Statement of Robert F. Dacey Director, Information Security Issues

GAO- 03- 1037T

In its fiscal year 2002 report on efforts to implement information
security requirements under Government Information Security Reform law,
DOD reported that it has an aggressive information assurance program and
highlighted several initiatives to improve it. These initiatives included
developing an overall strategy and issuing numerous departmentwide
information security policy documents. DOD*s reporting highlighted other
accomplishments, but acknowledged that a number of challenges remain for
the department in implementing both its policies and procedures and
statutory information security requirements.

DOD reported several material control weaknesses, which included needing
to decrease the time necessary for correcting reported weaknesses and
ensuring that computer security policies are enforced and security
capabilities are tested regularly. Further, performance data DOD reported

for a sample of its systems showed that further efforts are needed to
fully implement key information security requirements, such as testing
systems* security controls, throughout the department (see figure).

Although DOD has undertaken its Defense- wide Information Assurance
Program to promote integrated, comprehensive, and consistent practices
across the department and has recently issued both policy guidance and
implementation instructions, it does not have mechanisms in place for
comprehensively measuring compliance with federal and Defense information
security policies and ensuring that those policies are consistently
practiced throughout DOD.

Reported Results for Selected DOD Information Security Performance
Measures

The Department of Defense (DOD) faces many risks in its use of globally
networked computer systems to perform operational mi s s i ons ------ s
uch a s i dent i f yi ng a nd t r acki ng e nemy t ar get s------ and dai
l y management f unct i ons ------ such as paying soldiers and managing

supplies. Weaknesses in these systems, if present, could give hackers and
other unauthorized users the opportunity to modify, steal, inappropriately
disclose, and destroy sensitive military data. GAO was asked, among other
things, to discuss DOD*s efforts to

protect its information systems and networks from cyber attack, focusing
on its reported progress in implementing statutory information security
requirements.

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 1037T. To view the full product,
click on the link above. For more information, contact Robert F. Dacey at
(202) 512- 3317 or daceyr@ gao. gov. Highlights of GAO- 03- 1037T, a
testimony

before the Subcommittee on Terrorism, Unconventional Threats and
Capabilities, Committee on Armed Services, House of

Representatives

July 24, 2003

INFORMATION SECURITY

Further Efforts Needed to Fully Implement Statutory Requirements in DOD

Page 1 GAO- 03- 1037T Mr. Chairman and Members of the Subcommittee: I am
pleased to be here today to discuss the status of efforts by the

Department of Defense (DOD) to protect its information systems and
networks from cyber attack. DOD*s military services and agencies face many
risks in their use of globally networked computer systems to perform
operational missions, such as identifying and tracking enemy targets, and
daily management functions, such as paying soldiers and managing supplies.
Weaknesses in these systems, if present, could give hackers and other
unauthorized users the opportunity to modify, steal, inappropriately
disclose, and destroy sensitive military data.

Since 1996, 1 we have reported that poor information security in federal
agencies is a widespread problem with potentially devastating
consequences. Further, we have identified information security as a

governmentwide high- risk issue in reports to the Congress since 1997*
most recently in January 2003. 2 Concerned that significant weaknesses in
federal computer systems make them vulnerable to attack, in October 2000
the Congress passed and the President signed into law Government
Information Security Reform provisions (commonly known as GISRA) 3 to
establish information security program, evaluation, and reporting
requirements for federal agencies* requirements that are now permanently
authorized and strengthened through the recently enacted Federal
Information Security Management Act of 2002 (FISMA). 4 In my testimony
today, I will first provide an overview of the increasing

nature of cyber security threats and vulnerabilities and of the continuing
pervasive weaknesses across the federal government that led GAO to
initially begin reporting information security as a high- risk issue. I
will

1 U. S. General Accounting Office, Information Security: Opportunities for
Improved OMB Oversight of Agency Practices, GAO/ AIMD- 96- 110
(Washington, D. C.: Sept. 24, 1996). 2 U. S. General Accounting Office,
High Risk Series: Protecting Information Systems Supporting the Federal
Government and the Nation*s Critical Infrastructures, GAO- 03- 121
(Washington, D. C.: January 2003).

3 Title X, Subtitle G* Government Information Security Reform, Floyd D.
Spence National Defense Authorization Act for Fiscal Year 2001, P. L. 106-
398, October 30, 2000. 4 Title III* Federal Information Security
Management Act of 2002, E- Government Act of

2002, P. L. 107- 347, December 17, 2002. This act superseded an earlier
version of FISMA that was enacted as Title X of the Homeland Security Act
of 2002.

Page 2 GAO- 03- 1037T then discuss the status of DOD*s efforts to ensure
the security of its information systems and to implement the statutory
information security

requirements, focusing on the performance data that DOD reported to the
Office of Management and Budget (OMB). Finally, I will discuss some of the
challenges for the department in establishing an effective information
security management program. In preparing this testimony, we relied on
prior reports and testimony on

information security both governmentwide and for DOD. We also analyzed
reports prepared by the DOD chief information officer and the DOD
inspector general (IG) for fiscal year 2002 GISRA reporting, as well as
recent DOD policy and guidance documents related to information security.
Further, we analyzed OMB*s May 2003 report to the Congress on fiscal year
2002 GISRA implementation. 5 We did not validate the accuracy of the data
reported by DOD or OMB. We performed our work in July

2003, in accordance with generally accepted government auditing standards.

Protecting the computer systems that support our nation*s critical
operations and infrastructures has never been more important.
Telecommunications, power distribution, water supply, public health
services, national defense (including the military*s warfighting
capability),

law enforcement, government services, and emergency services all depend on
the security of their computer operations. Yet with this dependency comes
an increasing concern about attacks from individuals and groups with
malicious intent, such as crime, terrorism, foreign intelligence
gathering, and acts of war. Such concerns are well founded for a number of
reasons, including the dramatic increases in reported computer security
incidents, the ease of obtaining and using hacking tools, the steady
advance in the sophistication and effectiveness of attack technology, and
the dire warnings of new and more destructive attacks.

Although there have been some individual agency improvements, our most
recent analyses of audit and evaluation reports for the 24 major
departments and agencies continued to highlight significant information
security weaknesses that place a broad array of federal operations and

5 Office of Management and Budget, FY 2002 Report to Congress on Federal
Government Information Security Reform, May 16, 2003. Results in Brief

Page 3 GAO- 03- 1037T assets at risk of fraud, misuse, and disruption. For
example, resources, such as federal payments and collections, could be
lost or stolen; sensitive

information, such as taxpayer data, social security records, medical
records, and proprietary business information, could be inappropriately
disclosed, browsed, or copied for purposes of espionage or other types of
crime; and critical operations, such as those supporting national defense

and emergency services, could be disrupted. In its fiscal year 2002 GISRA
report, DOD reported that the department has an aggressive information
assurance (IA) posture and highlighted several initiatives to improve its
IA program. 6 These initiatives included developing an overall strategy
that identifies goals and objectives for the program and issuing numerous
information security policy directives, instructions, manuals, and policy
memorandums. Further, DOD*s GISRA reporting highlighted other
accomplishments, such as evaluating security controls for a sample of its
networks. However, this reporting also showed

that a number of challenges remain for the department in implementing both
its policies and procedures and statutory information security
requirements, as indicated by the material weaknesses it reported related
to its IA capabilities, and its performance data that showed further
efforts are needed to implement key requirements. For example, specific
deficiencies related to DOD*s material weaknesses included the need to
decrease the time necessary for correcting reported weaknesses and to
ensure that computer security policies are enforced and security
capabilities are tested regularly. Also, performance data reported by DOD
for a sample of its systems showed that further effort is needed by the
department to report on all its systems and to fully implement key
information security requirements, such as testing systems* information
security controls and their contingency plans.

Our past work has shown that an important challenge agencies face in
implementing an effective information security management program is
ensuring that they have the appropriate management structures and
processes in place to strategically manage information security, as well
as to ensure the reliability of performance information. For example,
disciplined processes can routinely provide the agency with timely, useful
information for day- to- day management of information security. DOD has

6 IA refers to the range of information security activities and functions
needed to protect DOD*s information and systems.

Page 4 GAO- 03- 1037T undertaken its Defense- wide Information Assurance
Program (DIAP) to promote integrated, comprehensive, and consistent IA
practices across the

department and has recently issued both policy guidance and implementation
instructions. However, as indicated by the Defense audit community*s
assessment of the DOD*s fiscal year 2001 GISRA data, DOD does not have
mechanisms in place for comprehensively measuring compliance with federal
and Defense information security policies and ensuring that those policies
are consistently practiced throughout the department.

Dramatic increases in computer interconnectivity, especially in the use of
the Internet, continue to revolutionize the way our government, our
nation, and much of the world communicate and conduct business. The
benefits have been enormous. Vast amounts of information are now literally
at our fingertips, facilitating research on virtually every topic
imaginable; financial and other business transactions can be executed
almost instantaneously, often 24 hours a day; and electronic mail,
Internet Web sites, and computer bulletin boards allow us to communicate
quickly and easily with a virtually unlimited number of individuals and
groups.

However, in addition to such benefits, this widespread interconnectivity
poses significant risks to the government*s and our nation*s computer
systems and, more important, to the critical operations and
infrastructures they support. For example, telecommunications, power
distribution, water supply, public health services, national defense
(including the military*s warfighting capability), law enforcement,
government services, and emergency services all depend on the security of
their computer operations. The speed and accessibility that create the
enormous benefits of the computer age on the other hand, if not properly
controlled, allow individuals and organizations to inexpensively eavesdrop
on or interfere with these operations from remote locations for
mischievous or malicious purposes, including fraud or sabotage. Table 1
summarizes the key threats to our nation*s infrastructures, as observed by
the Federal Bureau of Investigation (FBI). Background

Page 5 GAO- 03- 1037T Table 1: Threats to Critical Infrastructure Observed
by the FBI Threat Description

Criminal groups There is an increased use of cyber intrusions by criminal
groups who attack systems for purposes of monetary gain.

Foreign intelligence services Foreign intelligence services use cyber
tools as part of their information gathering and espionage activities.

Hackers Hackers sometimes crack into networks for the thrill of the
challenge or for bragging rights in the hacker community. While remote
cracking once required a fair amount of skill or computer knowledge,
hackers can now download attack scripts and protocols from the Internet
and launch them against victim sites. Thus, while attack tools have become
more sophisticated, they have also become easier to use.

Hacktivists Hacktivism refers to politically motivated attacks on publicly
accessible Web pages or E- mail servers. These groups and individuals
overload E- mail servers and hack into Web sites to send a political
message.

Information warfare Several nations are aggressively working to develop
information warfare doctrine, programs, and capabilities. Such
capabilities enable a single entity to have a significant and serious
impact by disrupting the supply, communications, and economic
infrastructures that support military power* impacts that, according to
the Director of Central Intelligence, a can affect the daily lives of
Americans across the country.

Insider threat The disgruntled organization insider is a principal source
of computer crimes. Insiders may not need a great deal of knowledge about
computer intrusions because their knowledge of a victim system often
allows them to gain unrestricted access to cause damage to the system or
to steal system data. The insider threat also includes outsourcing
vendors.

Virus writers Virus writers are posing an increasingly serious threat.
Several destructive computer viruses and *worms* have harmed files and
hard drives, including the Melissa Macro Virus, the Explore. Zip worm, the
CIH (Chernobyl) Virus, Nimda, and Code Red.

Source: Federal Bureau of Investigation unless otherwise indicated a
Prepared Statement of George J. Tenet, Director of Central Intelligence,
before the Senate Select Committee on Intelligence, February 2, 2000.

Government officials remain concerned about attacks from individuals and
groups with malicious intent, such as crime, terrorism, foreign
intelligence gathering, and acts of war. According to the FBI, terrorists,
transnational criminals, and intelligence services are quickly becoming

Page 6 GAO- 03- 1037T aware of and using information exploitation tools
such as computer viruses, Trojan horses, worms, logic bombs, and
eavesdropping sniffers

that can destroy, intercept, degrade the integrity of, or deny access to
data. 7 In addition, the disgruntled organization insider is a significant
threat, since these individuals often have knowledge that allows them to
gain unrestricted access and inflict damage or steal assets without
possessing a great deal of knowledge about computer intrusions. As greater
amounts of money are transferred through computer systems, as more
sensitive economic and commercial information is exchanged electronically,
and as the nation*s defense and intelligence communities increasingly rely
on commercially available information technology (IT), the likelihood
increases that information attacks will threaten vital national interests.

As the number of individuals with computer skills has increased, more
intrusion or *hacking* tools have become readily available and relatively
easy to use. A hacker can literally download tools from the Internet and
*point and click* to start an attack. Experts also agree that there has
been a steady advance in the sophistication and effectiveness of attack
technology. Intruders quickly develop attacks to exploit vulnerabilities
discovered in products, use these attacks to compromise computers, and
share them with other attackers. In addition, they can combine these
attacks with other forms of technology to develop programs that
automatically scan the network for vulnerable systems, attack them,
compromise them, and use them to spread the attack even further.

7 Virus: a program that *infects* computer files, usually executable
programs, by inserting a copy of itself into the file. These copies are
usually executed when the *infected* file is loaded into memory, allowing
the virus to infect other files. Unlike the computer worm, a virus
requires human involvement (usually unwitting) to propagate. Trojan horse:
a computer program that conceals harmful code. A Trojan horse usually
masquerades as a useful program that a user would wish to execute. Worm:
an independent computer program that reproduces by copying itself from one
system to another across a network. Unlike computer viruses, worms do not
require human involvement to propagate. Logic

bomb: in programming, a form of sabotage in which a programmer inserts
code that causes the program to perform a destructive action when some
triggering event occurs, such as terminating the programmer*s employment.
Sniffer: synonymous with packet sniffer. A program that intercepts routed
data and examines each packet in search of specified information, such as
passwords transmitted in clear text.

Page 7 GAO- 03- 1037T Along with these increasing threats, the number of
computer security incidents reported to the CERT(R) Coordination Center 8
has also risen

dramatically from 9,859 in 1999 to 82, 094 in 2002 and 76,404 for just the
first half of 2003. And these are only the reported attacks. The Director
of CERT Centers stated that he estimates that as much as 80 percent of
actual security incidents goes unreported, in most cases because (1) the
organization was unable to recognize that its systems had been penetrated
or there were no indications of penetration or attack or (2) the

organization was reluctant to report. Figure 1 shows the number of
incidents reported to the CERT Coordination Center from 1995 through the
first half of 2003.

Figure 1: Information Security Incidents Reported to Carnegie- Mellon*s
CERT Coordination Center from 1995 through the First Half of 2003

According to the National Security Agency, foreign governments already
have or are developing computer attack capabilities, and potential
adversaries are developing a body of knowledge about U. S. systems and

8 The CERT(R) Coordination Center (CERT(R) CC) is a center of Internet
security expertise at the Software Engineering Institute, a federally
funded research and development center operated by Carnegie Mellon
University.

Page 8 GAO- 03- 1037T methods to attack these systems. Since the terrorist
attacks of September 11, 2001, warnings of the potential for terrorist
cyber attacks against our

critical infrastructures have also increased. For example, in February
2002, the threat to these infrastructures was highlighted by the Special
Advisor to the President for Cyberspace Security in a Senate briefing when
he stated that although to date none of the traditional terrorists groups,
such as al Qaeda, have used the Internet to launch a known assault on the
United States* infrastructure, information on water systems was discovered
on computers found in al Qaeda camps in Afghanistan. 9 Also, in his
February 2002 statement for the Senate Select Committee on Intelligence,
the director of central intelligence discussed the possibility of cyber
warfare attack by terrorists. 10 He stated that the September 11 attacks
demonstrated the nation*s dependence on critical infrastructure systems
that rely on electronic and computer networks. Further, he noted that
attacks of this nature would become an increasingly viable option for
terrorists as they and other foreign adversaries become more familiar with
these targets and the technologies required to attack them.

Since September 11, 2001, the critical link between cyberspace and
physical space has been increasingly recognized. In his November 2002
congressional testimony, the Director of the CERT Centers at
CarnegieMellon University noted that supervisory control and data
acquisition (SCADA) systems and other forms of networked computer systems
have been used for years to control power grids, gas and oil distribution
pipelines, water treatment and distribution systems, hydroelectric and
flood control dams, oil and chemical refineries, and other physical

systems, and that these control systems are increasingly being connected
to communications links and networks to reduce operational costs by
supporting remote maintenance, remote control, and remote update
functions. 11 These computer- controlled and network- connected systems

9 *Administrative Oversight: Are We Ready for A CyberTerror Attack?*
Testimony before the Senate Committee on the Judiciary, Subcommittee on
Administrative Oversight and the Courts, by Richard A. Clarke, Special
Advisor to the President for Cyberspace Security and Chairman of the
President*s Critical Infrastructure Protection Board (Feb. 13, 2002). 10
Testimony of George J. Tenet, Director of Central Intelligence, before the
Senate Select

Committee on Intelligence, Feb. 6, 2002. 11 Testimony of Richard D.
Pethia, Director, CERT Centers, Software Engineering Institute, Carnegie
Mellon University, before the House Committee on Government Reform,
Subcommittee on Government Efficiency, Financial Management and
Intergovernmental Relations, November 19, 2002.

Page 9 GAO- 03- 1037T are potential targets for individuals bent on
causing massive disruption and physical damage, and the use of commercial,
off- the- shelf technologies for these systems without adequate security
enhancements

can significantly limit available approaches to protection and may
increase the number of potential attackers.

The risks posed by this increasing and evolving threat are demonstrated in
reports of actual and potential attacks and disruptions. For example:

 On February 11, 2003, the National Infrastructure Protection Center
(NIPC) issued an advisory to heighten the awareness of an increase in
global hacking activities as a result of the increasing tensions between
the United States and Iraq. 12 This advisory noted that during a time of
increased international tension, illegal cyber activity often escalates,
such as spamming, Web page defacements, and denial- of- service attacks.
Further, this activity can originate within another country that is party
to the tension, can be state sponsored or encouraged, or can come from
domestic organizations or individuals independently. The advisory also
stated that attacks may have one of several objectives, including
political activism targeting Iraq or those sympathetic to Iraq by self-
described

*patriot* hackers, political activism or disruptive attacks targeting U.
S. systems by those opposed to any potential conflict with Iraq, or even
criminal activity masquerading or using the current crisis to further
personal goals.

 According to a preliminary study coordinated by the Cooperative
Association for Internet Data Analysis (CAIDA), on January 25, 2003, the
SQL Slammer worm (also known as *Sapphire*) infected more than 90 percent
of vulnerable computers worldwide within 10 minutes of its release on the
Internet, making it the fastest computer worm in history. As the study
reports, exploiting a known vulnerability for which a patch has been
available since July 2002, Slammer doubled in size every 8.5 seconds and
achieved its full scanning rate (55 million scans per second) after about
3 minutes. It caused considerable harm through network outages and such
unforeseen consequences as canceled airline flights and automated teller
machine (ATM) failures. Further, the study emphasizes that the effects
would likely have been more severe had Slammer carried a

12 National Infrastructure Protection Center, National Infrastructure
Protection Center Encourages Heightened Cyber Security as Iraq* U. S.
Tensions Increase, Advisory 03002 (Washington, D. C.: Feb. 11, 2003).

Page 10 GAO- 03- 1037T malicious payload, attacked a more widespread
vulnerability, or targeted a more popular service.

 In November 2002, news reports indicated that a British computer
administrator was indicted on charges that he broke into 92 U. S. computer
networks in 14 states; these networks belonged to the Pentagon, private
companies, and the National Aeronautics and Space Administration during
the past year, causing some $900,000 in damage to computers. According to
a Justice Department official, these attacks were one of the biggest hacks
ever against the U. S. military. This official also said that the attacker
used his home computer and automated software available on the Internet to
scan tens of thousands of computers on U. S. military networks looking for
ones that might suffer from flaws in Microsoft Corporation*s Windows NT
operating system software.

 On October 21, 2002, NIPC reported that all the 13 root- name servers
that provide the primary roadmap for almost all Internet communications
were targeted in a massive *distributed denial of service* attack. Seven
of the servers failed to respond to legitimate network traffic, and two
others failed intermittently during the attack. Because of safeguards,
most Internet users experienced no slowdowns or outages.

 In July 2002, NIPC reported that the potential for compound cyber and
physical attacks, referred to as *swarming attacks,* is an emerging threat
to the U. S. critical infrastructure. 13 As NIPC reports, the effects of a
swarming attack include slowing or complicating the response to a physical
attack. For example, cyber attacks can be used to delay the notification
of emergency services and to deny the resources needed to manage the
consequences of a physical attack. In addition, a swarming attack could be
used to worsen the effects of a physical attack. For instance, a cyber
attack on a natural gas distribution pipeline that opens safety valves and
releases fuels or gas in the area of a planned physical attack could
enhance the force of the physical attack. Consistent with this threat,
NIPC also released an information bulletin in April 2002 warning against
possible physical attacks on U. S. financial institutions by unspecified
terrorists. 14 13 National Infrastructure Protection Center, Swarming
Attacks: Infrastructure Attacks for

Destruction and Disruption (Washington, D. C.: July 2002). 14 National
Infrastructure Protection Center, Possible Terrorism Targeting of US
Financial System* Information Bulletin 02- 003 (Washington, D. C.: Apr.
19, 2002).

Page 11 GAO- 03- 1037T  In August 2001, we reported to a subcommittee of
the House Government Reform Committee that the attacks referred to as Code
Red, Code Red II, and SirCam had affected millions of computer users, shut
down Web sites,

slowed Internet service, and disrupted business and government operations.
15 Then in September 2001, the Nimda worm appeared using some of the most
significant attack profile aspects of Code Red II and 1999*s infamous
Melissa virus that allowed it to spread widely in a short amount of time.
Security experts estimate that Code Red, Sircam, and Nimda have caused
billions of dollars in damage.

To better understand the risks facing DOD systems, it is useful to
consider the overall status of information security for the federal
government. Our analyses of information security at major federal agencies
have shown that federal systems were not being adequately protected from
computer- based threats, even though these systems process, store, and
transmit enormous amounts of sensitive data and are indispensable to many
federal agency operations. For the past several years, we have analyzed
audit results for 24 of the largest federal agencies and found that all 24
had significant information security weaknesses. 16 As reported in
November 2002, our latest analyses of reports issued from

October 2001 through October 2002, continued to show significant
weaknesses in federal computer systems that put critical operations and
assets at risk. 17 Weaknesses continued to be reported in each of the 24
agencies included in our review, 18 and they covered all six major areas
of

15 U. S. General Accounting Office, Information Security: Code Red, Code
Red II, and SirCam Attacks Highlight Need for Proactive Measures, GAO- 01-
1073T (Washington, D. C.: Aug. 29, 2001).

16 U. S. General Accounting Office, Information Security: Serious
Weaknesses Place Critical Federal Operations and Assets at Risk, GAO/
AIMD- 98- 92 (Washington, D. C.: Sept. 23, 1998); Information Security:
Serious and Widespread Weaknesses Persist at Federal Agencies, GAO/ AIMD-
00- 295 (Washington, D. C.: Sept. 6, 2000); Computer Security:
Improvements Needed to Reduce Risk to Critical Federal Operations and
Assets,

GAO- 02- 231T (Washington, D. C.: Nov. 9, 2001); and Computer Security:
Progress Made, but Critical Federal Operations and Assets Remain at Risk,
GAO- 03- 303T (Washington, D. C.: Nov. 19, 2002).

17 GAO- 03- 303T. 18 Does not include the Department of Homeland Security
that was created by the Homeland Security Act in November 2002.
Significant Weaknesses Persist in

Federal Information Security

Page 12 GAO- 03- 1037T general controls* the policies, procedures, and
technical controls that apply to all or a large segment of an entity*s
information systems and help

ensure their proper operation. These six areas are (1) security program
management, which provides the framework for ensuring that risks are
understood and that effective controls are selected and properly
implemented; (2) access controls, which ensure that only authorized
individuals can read, alter, or delete data; (3) software development and
change controls, which ensure that only authorized software programs are
implemented; (4) segregation of duties, which reduces the risk that one
individual can independently perform inappropriate actions without
detection; (5) operating systems controls, which protect sensitive
programs that support multiple applications from tampering and misuse; and
(6) service continuity, which ensures that computer- dependent operations
experience no significant disruptions. Figure 2 illustrates the
distribution of weaknesses for the six general control areas across the 24
agencies.

Page 13 GAO- 03- 1037T Figure 2: Computer Security Weaknesses at 24 Major
Federal Agencies Although our analyses showed that most agencies had
significant weaknesses in these six control areas, as in past years*
analyses,

weaknesses were most often identified for security program management and
access controls.

For security program management, we identified weaknesses for all 24
agencies in 2002* the same as reported for 2001, and compared to 21 of the
24 agencies (88 percent) in 2000. Security program management, which is
fundamental to the appropriate selection and effectiveness of the other
categories of controls, covers a range of activities related to
understanding information security risks; selecting and implementing
controls commensurate with risk; and ensuring that controls, once
implemented, continue to operate effectively.

Page 14 GAO- 03- 1037T For access controls, we found weaknesses for 22 of
24 agencies (92 percent) in 2002 (no significant weaknesses were found for
one agency, and access controls were not reviewed for another). This
compares to

access control weaknesses found in all 24 agencies for both 2000 and 2001.
Weak access controls for sensitive data and systems make it possible for
an individual or group to inappropriately modify, destroy, or disclose
sensitive data or computer programs for purposes such as personal gain or
sabotage. In today*s increasingly interconnected computing environment,

poor access controls can expose an agency*s information and operations to
attacks from remote locations all over the world by individuals with only
minimal computer and telecommunications resources and expertise.

Our analyses also showed service- continuity- related weaknesses at 20 of
the 24 agencies (83 percent) with no significant weaknesses found for 3
agencies (service continuity controls were not reviewed for another). This
compares to 19 agencies with service continuity weaknesses found in 2001
and 20 agencies found in 2000. Service continuity controls are important
in that they help ensure that when unexpected events occur, critical
operations will continue without undue interruption and that crucial,
sensitive data are protected. If service continuity controls are
inadequate, an agency can lose the capability to process, retrieve, and
protect electronically maintained information, which can significantly
affect an agency*s ability to accomplish its mission. Further, such
controls are particularly important in the wake of the terrorist attacks
of September 11, 2001.

These analyses of information security at federal agencies also showed
that the scope of audit work performed has continued to expand to more
fully cover all six major areas of general controls at each agency. Not
surprisingly, this has led to the identification of additional areas of
weakness at some agencies. These increases in reported weaknesses do not
necessarily mean that information security at federal agencies is getting
worse. They more likely indicate that information security weaknesses are
becoming more fully understood* an important step toward addressing the
overall problem. Nevertheless, the results leave no doubt that serious,
pervasive weaknesses persist. As auditors increase

their proficiency and the body of audit evidence expands, it is probable
that additional significant deficiencies will be identified.

Most of the audits represented in figure 2 were performed as part of
financial statement audits. At some agencies with primarily financial
missions, such as the Department of the Treasury and the Social Security
Administration, these audits covered the bulk of mission- related

Page 15 GAO- 03- 1037T operations. However, at agencies whose missions are
primarily nonfinancial, such as DOD and the Department of Justice, the
audits may

provide a less complete picture of the agency*s overall security posture
because the audit objectives focused on the financial statements and did
not include evaluations of individual systems supporting nonfinancial
operations. However, in response to congressional interest, beginning in
fiscal year 1999, we expanded our audit focus to cover a wider range of
nonfinancial operations* a trend we expect to continue. Audit coverage for
nonfinancial systems has also increased as agencies and their IGs reviewed
and evaluated their information security programs as required by GISRA.

To fully understand the significance of the weaknesses we identified, it
is necessary to link them to the risks they present to federal operations
and assets. Virtually all federal operations are supported by automated
systems and electronic data, and agencies would find it difficult, if not
impossible, to carry out their missions and account for their resources
without these information assets. Hence, the degree of risk caused by
security weaknesses is extremely high.

The weaknesses identified place a broad array of federal operations and
assets at risk. For example,

 resources, such as federal payments and collections, could be lost or
stolen;

 computer resources could be used for unauthorized purposes or to launch
attacks on others;

 sensitive information, such as taxpayer data, social security records,
medical records, and proprietary business information, could be
inappropriately disclosed, browsed, or copied for purposes of espionage or
other types of crime;

 critical operations, such as those supporting national defense and
emergency services, could be disrupted;

 data could be modified or destroyed for purposes of fraud or disruption;
and

 agency missions could be undermined by embarrassing incidents that
result in diminished confidence in their ability to conduct operations and
fulfill their fiduciary responsibilities.

Page 16 GAO- 03- 1037T Concerned with accounts of attacks on commercial
systems via the Internet and reports of significant weaknesses in federal
computer

systems that make them vulnerable to attack, on October 30, 2000, Congress
enacted GISRA, which was signed into law and became effective November 29,
2000, for a period of 2 years. GISRA supplemented information security
requirements established in the Computer Security Act of 1987, the
Paperwork Reduction Act of 1995, and the Clinger- Cohen Act of 1996 and
was consistent with existing information security guidance

issued by OMB 19 and the National Institute of Standards and Technology
(NIST), 20 as well as audit and best practice guidance issued by GAO. 21
Most importantly, however, GISRA consolidated these separate

requirements and guidance into an overall framework for managing
information security and established new annual review, independent
evaluation, and reporting requirements to help ensure agency
implementation and both OMB and congressional oversight. GISRA assigned
specific responsibilities to OMB, agency heads and CIOs, and IGs. OMB was
responsible for establishing and overseeing policies, standards, and
guidelines for information security. This included the authority to
approve agency information security programs, but delegated OMB*s
responsibilities regarding national security systems to national security
agencies. OMB was also required to submit an annual report to the Congress
summarizing results of agencies* independent evaluations of their
information security programs. OMB released its fiscal year 2001 report in
February 2002 and its fiscal year 2002 report in May 2003.

GISRA required each agency, including national security agencies, to
establish an agencywide risk- based information security program to be
overseen by the agency CIO and ensure that information security is

19 Primarily OMB Circular A- 130, Appendix III, *Security of Federal
Automated Information Resources,* February 1996. 20 Numerous publications
made available at http:// www. itl. nist. gov/ including National
Institute of Standards and Technology, Generally Accepted Principles and
Practices for Securing Information Technology Systems, NIST Special
Publication 800- 14, September

1996. 21 U. S. General Accounting Office, Federal Information System
Controls Manual, Volume 1* Financial Statement Audits, GAO/ AIMD- 12.19.6
(Washington, D. C.: January 1999);

Information Security Management: Learning from Leading Organizations, GAO/
AIMD- 98- 68 (Washington, D. C.: May 1998). Congress

Consolidates and Strengthens Federal Information Security Requirements

Page 17 GAO- 03- 1037T practiced throughout the life cycle of each agency
system. Specifically, this program was to include

 periodic risk assessments that consider internal and external threats to
the integrity, confidentiality, and availability of systems, and to data
supporting critical operations and assets;  the development and
implementation of risk- based, cost- effective policies

and procedures to provide security protections for information collected
or maintained by or for the agency;

 training on security responsibilities for information security personnel
and on security awareness for agency personnel;

 periodic management testing and evaluation of the effectiveness of
policies, procedures, controls, and techniques;

 a process for identifying and remediating any significant deficiencies;
 procedures for detecting, reporting, and responding to security
incidents;

and  an annual program review by agency program officials.

In addition to the responsibilities listed above, GISRA required each
agency to have an annual independent evaluation of its information
security program and practices, including control testing and compliance
assessment. The evaluations of non- national- security systems were to be
performed by the agency IG or an independent evaluator, and the results of
these evaluations were to be reported to OMB. For the evaluation of
national security systems, special provisions included having national
security agencies designate evaluators, restricting the reporting of
evaluation results, and having the IG or an independent evaluator perform
an audit of the independent evaluation. For national security systems,
only

the results of each audit of an evaluation are to be reported to OMB. With
GISRA expiring on November 29, 2002, on December 17, 2002, FISMA was
enacted as title III of the E- Government Act of 2002 to permanently
authorize and strengthen the information security program, evaluation, and
reporting requirements established by GISRA. Among other things, FISMA
also requires NIST to develop, for systems other than national security
systems, (1) standards to be used by all agencies to categorize all their
information and information systems based on the objectives of

Page 18 GAO- 03- 1037T providing appropriate levels of information
security according to a range of risk levels; (2) guidelines recommending
the types of information and

information systems to be included in each category; and (3) minimum
information security requirements for information and information systems
in each category. In addition, FISMA requires each agency to develop,
maintain, and annually update an inventory of major information systems
(including major national security systems) operated by the agency or
under its control. This inventory is also to include an identification of
the interfaces between each system and all other systems or networks,
including those not operated by or under the control of the agency.

DOD has undertaken several initiatives to improve its information
security, including the development of an overall IA strategy and the
issuance of information security policy and guidance. 22 However,
information that DOD*s CIO and IG submitted for fiscal year 2002 GISRA
reporting showed that a number of challenges remain for the department in
implementing both its policies and procedures and the statutory
information security requirements. These challenges are indicated by the
material weaknesses DOD reported related to its IA capabilities and its
performance data, which showed that further efforts are needed to
implement key requirements.

Overall, the DOD CIO reported in its fiscal year 2002 GISRA report that
the department has an aggressive IA posture and highlighted several
initiatives to improve its IA program. In particular, DOD has developed an
overall IA strategic plan to define the department*s goals and objectives
and to provide a consistent departmentwide approach to information
assurance. Further, according to a DOD official, DOD is aligning its
strategic initiatives to objectives in this plan and is developing
milestones and performance measures to gauge success.

Specific plan goals include: 22 IA refers to the range of information
security activities and functions needed to protect DOD*s information and
systems. DOD Highlights Initiatives, But Also

Reports Weaknesses DOD Efforts to Improve Information Security

Page 19 GAO- 03- 1037T  protecting information to ensure that all
information has a level of trust commensurate with mission needs;

 defending systems and networks to ensure that no access is uncontrolled
and that all systems and networks are capable of self- defense; and

 creating an IA- empowered workforce that is trained, highly skilled,
knowledgeable, and aware of its role in assuring information.

The plan also identified specific objectives for each goal. For example,
to meet the goal of protecting information to ensure that all information
has a level of trust commensurate with mission needs, DOD identified
objectives including defining data protection requirements, applying
protection mechanisms across the enterprise, and developing robust
mechanisms that protect information. In addition, DOD has developed a
complementary implementation mechanism for IA known as Defense in Depth
that uses a multilayered approach with defense mechanisms on successive
layers at multiple locations.

Other initiatives highlighted in the DOD CIO*s fiscal year 2002 GISRA
report included establishing a number of senior- level bodies that
discuss, brief, and shape the future of IA efforts* such as the CIO
Executive Board and the Military Communications- Electronics Board* and
issuing information security policy directives, instructions, manuals, and
policy memorandums.

During fiscal year 2003, DOD has continued its efforts to implement IA
departmentwide by issuing additional policy and guidance. Specifically, in
October 2002, it issued DOD Directive 8500.1 to establish policy and
assign

responsibility for IA management. 23 Further, in February 2003, DOD issued
DOD Instruction 8500.2, which prescribes a framework for implementing the
department*s IA program and establishes baseline levels of assurance for
information systems. 24 23 Department of Defense Directive Number 8500.1,
Information Assurance (IA) (Oct. 24,

2002) 24 Department of Defense Instruction Number 8500.2, Information
Assurance (IA) Implementation (Feb. 6, 2003).

Page 20 GAO- 03- 1037T DOD reported eight material weaknesses in fiscal
year 2002 for which it said it is undertaking aggressive action to improve
and expand its IA

capabilities. The actions DOD identified to address the eight deficiencies
are:

 completing the implementation of the Information Assurance Vulnerability
Alert process to all services and agencies;

 ensuring that effective computer security policies and procedures are
distributed in a timely manner;

 improving DOD business processes to ensure that all systems are
protected;

 decreasing the time necessary for correction of reported weaknesses; 
ensuring that computer security policies are enforced and security

capabilities are tested regularly;  ensuring that training is conducted
for all network personnel (this

includes awareness training for all personnel to specific network defense
training for system and network administrators);

 increasing access security through the use of electronic tokens; and 
increasing security through certificates (for authentication and

nonrepudiation). OMB*s fiscal year 2002 reporting instructions included
new high- level management performance measures that the agencies and IGs
were required to use to report on agency officials* performance, such as
the number and percentage of systems that have been assessed for risk and
that have an up- to- date security plan. In addition, OMB*s reporting
instructions for fiscal year 2002 stated that agencies were expected to
review all systems annually. 25 OMB explained that GISRA requires senior

25 Office of Management and Budget, *Reporting Instructions for the
Government Information Security Reform Act and Updated Guidance on
Security Plans of Action and Milestones,* Memorandum for Heads of
Executive Departments and Agencies, Mitchell E. Daniels, Jr., M- 02- 09,
July 2, 2002. Material Weaknesses

Identified By DOD DOD Reports Show Further Efforts Needed to Implement Key
Information Security Requirements

Page 21 GAO- 03- 1037T agency program officials to review each security
program for effectiveness at least annually, and that the purpose of the
security programs discussed

in GISRA is to ensure the protection of the systems and data covered by
the program. Thus, a review of each system is essential to determine the
program*s effectiveness, and only the depth and breadth of such system
reviews are flexible.

DOD reported data for most performance measures as required. However, as
agreed with OMB, DOD reported these data for only a sample of its systems
and networks rather than for all systems. As a result, DOD cannot ensure
that these performance measures accurately reflect the information
security status of its thousands of systems or that potential weaknesses
for all systems have been identified for correction. Further, reporting on
only a sample of systems limited the usefulness of OMB*s analysis of the
governmentwide status of IT security reported in its fiscal year 2002
report to the Congress, which considered data for only DOD*s sample of
systems in measuring the overall progress by 24 large agencies.

DOD indicated in its report that because of its size and complexity, the
collection of specific metrics required sizable lead time to allow for the
collection and approval process by each military service and agency. For
this reason, DOD focused its fiscal year 2002 GISRA efforts on (1) a
sample of 366 of its networks (241 unclassified and 125 classified) and
(2) a sample of 155 systems that were selected from the sample of systems
used for DOD*s fiscal year 2001 GISRA review. Although DOD reported
performance measure data for both the sample of networks and the sample of
systems, OMB*s provided comparative results in its report to Congress
primarily for the sample of 155 systems. However, as discussed later in
this statement, DOD did report that 96 percent of its sample of networks
was certified and accredited.

OMB*s fiscal year 2002 GISRA report to the Congress summarized both agency
and overall results for certain key measures for 24 large federal
agencies. Subject to the limitation of DOD*s data, figure 3 summarizes DOD
results for six of these measures for the 155 systems and shows that most
of these measures actually decreased from fiscal year 2001 to fiscal

year 2002. DOD attributed the decreases to inaccuracies in the fiscal year
2001 data. Discussion of these and other measures follow figure 3 and
include a comparison of DOD results to results for other agencies as

Page 22 GAO- 03- 1037T presented in our recent testimonies before a
subcommittee of the House Government Reform Committee. 26 Figure 3:
Reported Results for Selected DOD Information Security Performance

Measures

Agencies are required to perform periodic threat- based risk assessments
for systems and data. Risk assessments are an essential element of risk
management and overall security program management and, as our best

26 U. S. General Accounting Office, Information Security: Progress Made,
But Challenges Remain to Protect Federal Systems and the Nation*s Critical
Infrastructures, GAO- 03- 564T (Washington, D. C.: Apr. 8, 2003), and
Information Security: Continued Efforts Needed to Fully Implement
Statutory Requirements, GAO- 03- 852T (Washington, D. C.: Jun. 24, 2003).
Systems Assessed for Risk

Page 23 GAO- 03- 1037T practice work has shown, are an integral part of
the management processes of leading organizations. 27 Risk assessments
help ensure that the

greatest risks have been identified and addressed, increase the
understanding of risk, and provide support for needed controls. Our
reviews of federal agencies, however, frequently show deficiencies related
to assessing risk, such as security plans for major systems that are not
developed on the basis of risk. As a result, the agencies had accepted an
unknown level of risk by default rather than consciously deciding what
level of risk was tolerable.

OMB*s performance measure for this requirement mandated that agencies
report the number and percentage of their systems that have been assessed
for risk during fiscal year 2001 and fiscal year 2002. DOD reported that
for its sample of 155 systems, 68 percent (106) had risk assessments for
fiscal year 2002 as compared to 81 percent (125) for fiscal year 2001* a
decrease of 13 percentage points. In comparison, our overall analyses of
reporting for this measure for all 24 agencies (including DOD) showed that
for fiscal year 2002, 11 agencies reported that they had assessed risk for
90 to 100 percent of their systems, and of the remaining 13, 8 reported
less than 50 percent.

An agency head is required to ensure that the agency*s information
security plans are practiced throughout the life cycle of each agency
system. In its reporting instructions, OMB required agencies to report

whether the agency head had taken specific and direct actions to oversee
that program officials and the CIO are ensuring that security plans are up
to date and practiced throughout the life cycle of each system. Agencies

also had to report the number and percentage of systems that had an upto-
date security plan.

Regarding the status of agencies* security plans, DOD reported that for
its sample of 155 systems, 66 percent (103) had up- to- date security
plans for fiscal year 2002* a decrease from the 84 percent (130) reported
for fiscal year 2001. In comparison, our overall analysis for all 24
agencies showed that for fiscal year 2002, 7 agencies reported that they
up- to- date security plans for 90 to 100 percent of their systems, and of
the remaining 17 agencies, 9 reported up- to- date security plans for less
than 50 percent of their systems.

27 GAO/ AIMD- 98- 68. Systems With Up- to- Date

Security Plans

Page 24 GAO- 03- 1037T As one of its performance measures for agency
program official responsibilities, OMB required agencies to report the
number and

percentage of systems that have been authorized for processing following
certification and accreditation. Certification is the comprehensive
evaluation of the technical and nontechnical security controls of an IT
system to support the accreditation process that establishes the extent to
which a particular design and implementation meets a set of specified

security requirements. Certification provides the necessary information to
a management official to formally declare that an IT system is approved to
operate at an acceptable level of risk. Accreditation is the authorization
of

an IT system to process, store, or transmit information, granted by a
management official that provides a form of quality control and challenges
managers and technical staff to find the best fit for security, given

technical constraints, operational constraints, and mission requirements.
The accreditation decision is based on the implementation of an agreed
upon set of management, operational, and technical controls, and by
accrediting the system, the management office accepts the risk associated
with it.

DOD has established a standard departmentwide process, set of activities,
general tasks, and a management structure to certify and accredit
information systems and maintain the IA and security posture throughout
the life cycle of the system. A companion manual, the DOD Information
Technology Security Certification and Accreditation Process (DITSCAP)
Application Manual, provides implementation guidance to standardize the
certification and accreditation process throughout DOD. 28 The DOD CIO
reported that the department is implementing the DITSCAP process, but
realizes the actual process is complex, lengthy, and costly; and several
internal agencies are exploring efforts to streamline DITSCAP.

DOD reported that for fiscal year 2002, 55 percent (85) of its sample of
155 systems was authorized for processing following certification and
accreditation* a decrease from the 61 percent (95) reported for fiscal
year 2001. For this particular measure, DOD also reported that in fiscal
year 2002, 96 percent (352) of its 366- network sample was certified and
accredited to operate. In comparison, our overall analysis for all 24
agencies showed that for fiscal year 2002, only 3 agencies reported that
90 28 Department of Defense, DOD Information Technology Security
Certification and

Accreditation Process (DITSCAP) Application Manual, DOD 8510. 1- M (July
31, 2000). Systems Certified and

Accredited

Page 25 GAO- 03- 1037T to 100 percent of their systems were authorized for
processing following certification and accreditation, and of the remaining
21 agencies, 13

reported that less than 50 percent of their systems were authorized,
including 3 that reported that none were authorized.

According to the DOD IG*s fiscal year 2002 GISRA report, the certification
and accreditation data reported by the department for fiscal year 2001
included systems that were certified and accredited either under the
DITSCAP or another process. In addition, in analyzing a sample of the
systems used for the department*s fiscal year 2001 GISRA reporting, the IG
found the certification and accreditation status for some systems was
incorrectly reported.

An agency head is responsible for ensuring that the appropriate agency
officials evaluate the effectiveness of the information security program,
including testing controls. Further, the agencywide information security
program is to include periodic management testing and evaluation of the
effectiveness of information security policies and procedures.
Periodically evaluating the effectiveness of security policies and
controls and acting to address any identified weaknesses are fundamental
activities that allow an organization to manage its information security
risks cost- effectively,

rather than reacting to individual problems ad hoc only after a violation
has been detected or an audit finding has been reported. Further,
management control testing and evaluation as part of the program reviews
can supplement control testing and evaluation in IG and our audits to help
provide a more complete picture of the agencies* security postures.

As a performance measure for this requirement, OMB required agencies to
report the number and percentage of systems for which security controls
have been tested and evaluated during fiscal years 2001 and 2002. DOD
reported that for fiscal year 2002, it had tested and evaluated controls
for only 28 percent (43) of the 155- system sample* a slight increase from
the 23 percent (35) reported for fiscal year 2001. In comparison, our
overall analysis for all 24 agencies showed that for fiscal year 2002,
only 4 agencies reported they had tested and evaluated controls for 90 to
100 percent of their systems, and of the remaining 20 agencies, 10
reported less than 50 percent.

Contingency plans provide specific instructions for restoring critical
systems, including such items as arrangements for alternative processing
facilities, in case the usual facilities are significantly damaged or
cannot be accessed. These plans and procedures help to ensure that
critical operations can continue when unexpected events occur, such as
Security Control Testing and

Evaluation System Contingency Plans

Page 26 GAO- 03- 1037T temporary power failure, accidental loss of files,
or major disaster. Contingency plans should also identify which operations
and supporting

resources are critical and need to be restored first and should be tested
to identify their weaknesses. Without such plans, agencies have inadequate
assurance that they can recover operational capability in a timely,
orderly manner after a disruptive attack.

As another of its performance measures, OMB required agencies to report
the number and percentage of systems for which contingency plans had been
prepared and had been tested in the past year. DOD reported that of

its 155- system sample, 66 percent (103) of its systems had contingency
plans for fiscal year 2002* a decrease from the 85 percent (131) reported
for fiscal year 2001. However, more significantly, DOD also reported that
for fiscal year 2002, only 21 percent (32) of its sample of systems had
contingency plans that had been tested within the past year. In
comparison, our overall analysis for all 24 agencies showed that for
fiscal year 2002, only 2 agencies reported they had tested contingency
plans for

90 to 100 percent of their systems, and of the remaining 22 agencies, 20
reported less than 50 percent, including 1 that reported none had been
tested.

Agencies are required to implement procedures for detecting, reporting,
and responding to security incidents. Although even strong controls may
not block all intrusions and misuse, organizations can reduce the risks
associated with such events if they promptly take steps to detect
intrusions and misuse before significant damage can be done. In addition,
accounting for and analyzing security problems and incidents are effective

ways for an organization to gain a better understanding of threats to its
information and of the cost of its security- related problems. Such
analyses can also pinpoint vulnerabilities that need to be addressed to
help ensure

that they will not be exploited again. In this regard, problem and
incident reports can provide valuable input for risk assessments, help in
prioritizing security improvement efforts, and be used to illustrate risks
and related trends in reports to senior management.

In March 2001, we reported that over the past several years, DOD had
established incident response capabilities for the military services and
enhanced computer defensive capabilities across the department. 29 29 U.
S. General Accounting Office, Information Security, Challenges to
Improving DOD*s

Incident Response Capabilities, GAO- 01- 341 (Washington, D. C.: Mar. 29,
2001). Incident- Handling Capabilities

Page 27 GAO- 03- 1037T However, we also identified six areas in which DOD
faced challenges in improving its incident response capabilities,
including (1) coordinating resource planning and priorities for incident
response across the

department; (2) integrating critical data from systems, sensors, and other
devices to better monitor cyber events and attacks; (3) establishing a
departmentwide process to periodically and systematically review systems
and networks on a priority basis for security weaknesses; (4) ensuring
that components across the department consistently and fully report
compliance with vulnerability alerts; (5) improving the coordination and
suitability of component- level incident response actions; and (6)
developing departmentwide performance measures to assess incident response
capabilities and thus better ensure mission readiness. Although DOD was
aware of these challenges and had undertaken some initiatives to address
them, the initiatives were not complete at the time of our review. We
recommended that DOD act to address these challenges to better protect its
systems and networks from cyber threats and attacks. Currently, DOD
reports that it has made progress in addressing many of these challenges.

For fiscal year 2002 GISRA reporting, OMB required agencies to report
several performance measures related to detecting, reporting, and
responding to security incidents. These included the number of agency
components with an incident- handling and response capability, whether the
agency and its major components share incident information with the
Federal Computer Incident Response Center (FedCIRC) 30 in a timely manner,
and the numbers of incidents reported. OMB also required that agencies
report on how they confirmed that patches have been tested and installed
in a timely manner.

In its fiscal year 2002 GISRA report, the DOD CIO reported that
essentially all its components have an incident handling and response
capability and that DOD has made significant progress in developing its
computer network defense capabilities, including the January 2001 issuance
of DOD Directive O- 8530. 1, *Computer Network Defense,* which established
computer network defense policy, definition, and department
responsibilities. The CIO also reported that through its computer network

30 FedCIRC, formerly within the General Services Administration and now
part of the Department of Homeland Security, was established to provide a
central focal point for incident reporting, handling, prevention and
recognition for the federal government.

Page 28 GAO- 03- 1037T defense capabilities, DOD could monitor, analyze,
detect, and respond to unauthorized activity within DOD information
systems and computer

networks. In addition, the CIO reported that each of the major military
services has a robust computer emergency response team (CERT) and
integrated network operations centers. Further, the report states that the
DOD CERT works closely with FedCIRC on all incidents within the .gov
Internet domain and, along with other service and agency CERTs, shares
incident information with FedCIRC within 10 minutes to 48 hours depending
on the seriousness of the incident. The Joint Task Force for Computer
Network Operations and the DOD CERT take responsibility for incidents
within the .mil Internet domain.

In comparison to DOD, our analyses of agencies* fiscal year 2002 GISRA
reports showed that most agencies reported that they have established
incident- response capabilities. For example, 12 agencies reported that
for fiscal year 2002, 90 percent or more of their components had incident
handling and response capabilities, and 8 others reported that they
provided these capabilities to components through a central point within
the agency.

Agencies are required to provide training on security awareness for agency
personnel and on security responsibilities for information security
personnel. Our studies of best practices at leading organizations have
shown that such organizations took steps to ensure that personnel involved
in various aspects of their information security programs had the skills
and knowledge they needed. They also recognized that staff expertise had
to be frequently updated to keep abreast of ongoing changes in threats,
vulnerabilities, software, security techniques, and security monitoring
tools.

Among the performance measures for these requirements, OMB mandated that
agencies report the number and percentage of employees* including
contractors* who received security training during fiscal years 2001 and
2002, and the number of employees with significant security

responsibilities who received specialized training. In response to these
measures, the DOD CIO reported that it provides departmentwide, component-
level security training and periodic updates for all employees, but that
actual numbers and the percentage of agency employees who received
security training in fiscal year 2002 were not available at the time of
its report. For employees with significant security responsibilities, the

CIO reported that specialized security and technical training is provided
to persons empowered to audit, alter, or affect the intended behavior or
content of an IT system, such as system/ network administrators and
Security Training for

Employees and Contractors

Page 29 GAO- 03- 1037T information systems security officers. Additional
training is also provided for others, such as CERT members, computer crime
investigators, and Web masters/ site managers. However, performance
measure data reported

for employees with significant security responsibilities showed that of
39,783 such employees, 42 percent (16,812) received specialized training
in fiscal year 2002* a decrease of 9 percentage points from the 51 percent
reported for fiscal year 2001.

In comparison with other major federal agencies, for specialized training
for employees with significant security responsibilities, our analyses
showed that 12 agencies reported 50 percent or more of their employees
with significant security responsibilities had received specialized
training for fiscal year 2002, with 5 of these reporting 90 percent or
more. Of the remaining 12 agencies, 9 including DOD reported that less
than half of such employees received specialized training, 1 reported that
none had received such training, and 2 did not provide sufficient data for
this measure.

Agencies are required to develop and implement risk- based, cost-
effective policies and procedures to provide security protection for
information collected or maintained by or for the agency. In its fiscal
year 2001 GISRA report to the Congress, OMB identified poor security for
contractorprovided services as a common weakness, and for fiscal year 2002
reporting, included performance measures to help indicate whether the

agency program officials and CIO used appropriate methods, such as audits
and inspections, to ensure that service provided by a contractor are
adequately secure and meet security requirements.

For fiscal year 2002 GISRA, the DOD CIO reported that there was
insufficient time and resources to accurately collect requested
performance measure data. The CIO also reported that execution and
verification of contractor services and facilities are managed at the
subagency levels, and that agency program officials use audits or
inspections to ensure that contractor- provided services are adequately
secure and meet statutory information security requirements, OMB policy,
and NIST guidance. The DOD IG did not review the status of
contractorprovided services for compliance with GISRA, but did identify
several reports issued from August 2001 to July 2002 by military service
audit agencies that discussed weaknesses in background investigations.

Screening of contractor or subcontractor employees as a condition for
physical or computer systems access is a recommended safeguard, and
depending on the program or system criticality or information sensitivity,
can range from minimal checks to complete background investigations.
Security of ContractorProvided

Services

Page 30 GAO- 03- 1037T As previously discussed, our past analyses of audit
results for 24 of the largest federal agencies showed that all 24 had
significant weaknesses in

security program management, which covers a range of activities related to
understanding information security risks; selecting and implementing
controls commensurate with risk; and ensuring that controls, once
implemented, continue to operate effectively. 31 Establishing a strong
security management program requires that agencies take a comprehensive
approach that involves both (1) senior agency program managers who
understand which aspects of their missions are the most

critical and sensitive and (2) technical experts who know the agencies*
systems and can suggest appropriate technical security control techniques.
We studied the practices of organizations with superior security programs
and summarized our findings in a May 1998 executive guide entitled
Information Security Management: Learning From Leading Organizations. 32
Our study found that these organizations managed their information

security risks through a cycle of risk management activities. These
activities, which are now among the federal government*s statutory
information security requirements, included

 assessing risks and determining protection needs, selecting and
implementing cost- effective policies and controls to meet those needs,

 promoting awareness of policies and controls and of the risks that
prompted their adoption among those responsible for complying with them,
and

 implementing a program of routine tests and examinations for evaluating
the effectiveness of policies and related controls and reporting the
resulting conclusions to those who can take appropriate corrective action.
Although GISRA reporting provided performance information on these areas,
it is important for agencies to ensure that they have the appropriate
management structures and processes in place to strategically manage

information security, as well as ensure the reliability of performance
information. For example, disciplined processes can routinely provide the
agency with timely, useful information for day- to- day management of
information security. Also, developing management strategies that identify
31 GAO- 02- 231T and GAO- 03- 303T.

32 GAO/ AIMD- 98- 68. Challenges to

Implementing an Effective Information Security Management Program

Page 31 GAO- 03- 1037T specific actions, time frames, and required
resources may help to significantly improve performance.

In January 1998, DOD announced its plans for DIAP* a program intended to
promote integrated, comprehensive, and consistent IA practices across the
department. In February 1999, the department issued an approved
implementation plan, which described, at a high level, the program*s
goals, objectives, and organizational structure, and confirmed its
responsibility for the planning, coordination, integration, and oversight
of Defense- wide computer security initiatives.

In March 2001, we reported that DIAP had made progress in addressing IA,
but that the department had not yet met its goals for promoting
integrated, comprehensive, and consistent practices across DOD. 33 The
program*s progress was limited by weaknesses in its management framework
and unmet staffing expectations. DOD had not established a
performancebased management framework for IA improvement at the department
level. As a result, DOD was unable to accurately determine the status of
IA across the department, the progress of its improvement efforts, or the
effectiveness of its initiatives. Also, understaffing kept the program
from fulfilling its central role in planning, monitoring, coordinating,
and integrating Defense- wide IA activities, and changes in the
composition and authority of other key organizations interacting with DIAP
left it without a consistent and fully supportive environment for its
operations. We concluded that achieving this program*s vision for
information superiority would require the commitment of DOD to proven IA
management practices. To improve progress toward the department*s goals,
we made recommendations to the Secretary of Defense in the areas of
component commitments to DIAP and executive- level monitoring of the
program. We also recommended that the DOD CIO institute performance- based
management of DIAP through a defined budget and performance objectives,
and that the program manager take steps to address the program*s unmet
goals.

DOD has made some progress in addressing our previous recommendations and,
as discussed previously, during fiscal year 2003,

33 U. S. General Accounting Office, Information Security: Progress and
Challenges to an Effective Defense- wide Information Assurance Program,
GAO- 01- 307 (Washington, D. C.: Mar. 30, 2001).

Page 32 GAO- 03- 1037T DOD issued guidance to establish policy and assign
responsibility for IA management and to prescribe a framework for
implementing the

department*s IA program and establish baseline levels of assurance for
information systems. Despite such steps, OMB reported in its fiscal year
2002 report to the Congress that the overall results of the Defense audit
community*s assessment of the DOD fiscal year 2001 GISRA reporting
reinforced the position that DOD does not have mechanisms in place for
comprehensively measuring compliance with federal and Defense information
security policies and ensuring that those policies are consistently
practiced throughout the department.

In summary, DOD has taken positive steps through its policy and guidance
to establish information security as a priority for the department.
However, as its fiscal year 2002 GISRA reporting showed, further effort is
needed to fully implement statutory information security requirements
departmentwide and to expand future FISMA reporting to all systems.
Significant improvement will likely require DOD to establish
departmentwide processes that routinely provide information for day- today
management of information security and to develop management strategies
that identify specific actions, time frames, and required resources. With
the first agency reporting under FISMA due in September 2003, updated
information on the status of DOD*s efforts will be available for continued
congressional oversight.

Mr. Chairman, this concludes my written testimony. I would be pleased to
answer any questions that you or other members of the Subcommittee may
have at this time. If you should have any questions about this testimony,
please contact me at (202) 512- 3317. I can also be reached by Email at
daceyr@ gao. gov. (310505)

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