Information Security: Further Efforts Needed to Address Serious
Weaknesses to USDA (30-JAN-04, GAO-04-154).
The U.S. Department of Agriculture (USDA) performs critical
missions that enhance the quality of life for the American
people, relying on automated systems and networks to deliver
billions of dollars in programs to its customers; process and
communicate sensitive payroll, financial, and market data; and
maintain personal customer information. Interruptions in USDA's
ability to fulfill its missions could have a significant adverse
impact on the nation's food and agricultural production. In
addition, securing sensitive information is critical to USDA's
efforts to maintain public confidence in the department. GAO was
asked to evaluate the effectiveness of USDA's information
security controls.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-04-154
ACCNO: A09141
TITLE: Information Security: Further Efforts Needed to Address
Serious Weaknesses to USDA
DATE: 01/30/2004
SUBJECT: Agency missions
Computer networks
Computer security
Information resources management
Information systems
Internal controls
Strategic planning
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GAO-04-154
United States General Accounting Office
GAO
Report to Congressional Requesters
January 2004
INFORMATION SECURITY
Further Efforts Needed to Address Serious Weaknesses at USDA
a
GAO-04-154
Highlights of GAO-04-154, a report to congressional requesters
The U.S. Department of Agriculture (USDA) performs critical missions that
enhance the quality of life for the American people, relying on automated
systems and networks to deliver billions of dollars in programs to its
customers; process and communicate sensitive payroll, financial, and
market data; and maintain personal customer information. Interruptions in
USDA's ability to fulfill its missions could have a significant adverse
impact on the nation's food and agricultural production.
In addition, securing sensitive information is critical to USDA's efforts
to maintain public confidence in the department. GAO was asked to evaluate
the effectiveness of USDA's information security controls.
GAO recommends that the Secretary of Agriculture direct the chief
information officer (CIO) to correct a number of weaknesses, including
fully implementing a comprehensive security management program. In
commenting on a draft of this report, USDA concurred with our
recommendations and stated that the department remains committed to
improving information security. USDA plans to correct the specific
information security weaknesses identified and fully implement a
comprehensive security management program.
www.gao.gov/cgi-bin/getrpt?GAO-04-154.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robert F. Dacey at (202)
512-3317 or [email protected].
January 2004
INFORMATION SECURITY
Further Efforts Needed to Address Serious Weaknesses at USDA
Significant, pervasive information security control weaknesses exist at
USDA, including serious access control weaknesses, as well as other
information security weaknesses. Specifically, USDA has not adequately
protected network boundaries, sufficiently controlled network access,
appropriately limited mainframe access, or fully implemented a
comprehensive program to monitor access activity. In addition, weaknesses
in other information security controls, including physical security,
personnel controls, system software, application software, and service
continuity, further increase the risk to USDA's information systems. As a
result, sensitive data-including information relating to the privacy of
U.S. citizens, payroll and financial transactions, proprietary
information, agricultural production and marketing estimates, and mission
critical data-are at increased risk of unauthorized disclosure,
modification, or loss, possibly without being detected.
A key reason for the weaknesses in information system controls is that the
department has not yet fully developed and implemented a comprehensive
security management program to ensure that effective controls are
established and maintained and that information security receives
significant management attention. Although USDA has various initiatives
under way, it has not yet fully implemented the key elements of a
comprehensive security management program. For example, agency security
personnel have lacked the management involvement needed to effectively
implement security programs, three agencies have not completed any of the
required risk assessments, and security controls have been tested and
evaluated for less than half of the department's systems in the past year.
USDA has recognized the need to improve information security throughout
the department, including in the components that we reviewed.
Contents
Letter 1
Results in Brief 1
Background 2
Objectives, Scope, and Methodology 5
Serious Information Security Weaknesses Exist at USDA 7
Conclusions 24
Recommendations for Executive Action 25
Agency Comments 25
Appendixes
Appendix I: Comments from the Department of Agriculture 27
Appendix II: GAO Contact and Staff Acknowledgments 28
GAO Contact 28
Staff Acknowledgments 28
Contents
Abbreviations
CIO chief information officer
FISMA Federal Information Security Management Act
ID identification
IDS intrusion-detection system
ISSPM Information System Security Program Manager
IT information technology
NASS National Agricultural Statistics Service
NIST National Institute of Standards and Technology
NITC National Information Technology Center
OCIO Office of the Chief Information Officer
OIG Office of Inspector General
OMB Office of Management and Budget
POA&M Plan of Actions and Milestones
TSO Telecommunications Services and Operations
USDA U.S. Department of Agriculture
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separately.
A
United States General Accounting Office Washington, D.C. 20548
January 30, 2004
The Honorable Thad Cochran
Chairman
Committee on Agriculture, Nutrition, and Forestry
United States Senate
The Honorable Tom Harkin
Ranking Democratic Member
Committee on Agriculture, Nutrition, and Forestry
United States Senate
The Honorable Richard G. Lugar
United States Senate
The U.S. Department of Agriculture (USDA) performs critical missions that
enhance the quality of life for the American people, relying on automated
systems and networks to deliver billions of dollars in programs to its
customers; process and communicate sensitive payroll, financial, and
market data; and maintain personal customer information. Interruptions in
USDA's ability to fulfill its missions could have a significant adverse
impact
on the nation's food and agricultural production. In addition, the
security of
sensitive information is critical to the department's efforts to maintain
public confidence in the output, supply, and marketing sectors in
agriculture.
At your request, we evaluated the effectiveness of USDA's information
security controls. Effective controls are essential for ensuring that
sensitive information and information technology resources are adequately
protected from inadvertent or deliberate misuse, fraudulent use, or
destruction, as well as for protecting information from disclosure.
This report summarizes the information security control weaknesses that
we identified during our review. We are also issuing a report designated
for
"Limited Official Use Only," which describes the weaknesses in more
detail.
Results in Brief Significant, pervasive information security control
weaknesses exist at USDA, including serious access control weaknesses, as
well as other information security weaknesses. Specifically, USDA has not
adequately protected network boundaries, sufficiently controlled network
access, appropriately limited mainframe access, or fully implemented a
comprehensive program to monitor access activity. In addition, weaknesses
in other information security controls, including physical security,
personnel controls, system software, application software, and service
continuity, further increase the risk to USDA's information systems. As a
result, sensitive data-including information relating to the privacy of
U.S. citizens, payroll and financial transactions, proprietary
information, agricultural production and marketing estimates, and other
mission critical data-are at increased risk of unauthorized disclosure,
modification, or loss, possibly without being detected.
A key reason for the weaknesses in information system controls is that the
department has not yet fully developed and implemented a comprehensive
security management program to ensure that effective controls are
established and maintained and that information security receives
significant management attention. Although USDA has various initiatives
under way, the key elements of a comprehensive security management program
are not yet fully implemented. For example, agency security personnel have
lacked the management involvement needed to effectively implement security
programs, three agencies have not completed any of the required risk
assessments, and security controls have been tested and evaluated for less
than half of the department's systems in the past year. USDA has
recognized the need to improve information security throughout the
department, including the components that we reviewed.
We are making a recommendation to fully implement a comprehensive
information security management program. In the separate report designated
"Limited Official Use Only," we are making recommendations to correct the
specific weaknesses identified during our review.
In providing written comments on a draft of this report, USDA's Chief
Information Officer (CIO) concurred with our recommendations and stated
that the department remains committed to improving information security.
USDA plans to fully implement a comprehensive security management program
as well as correct the specific information security weaknesses
identified.
Background USDA's missions are diverse, covering a wide range of
responsibilities that include ensuring a safe, affordable, nutritious, and
accessible food supply; caring for agricultural, forest, and range lands;
providing economic opportunities for farm and rural residents; and
expanding global markets for agricultural and forest products and
services. To support its missions,
USDA employs approximately 114,000 people in 29 agencies and staff offices
covering 7 mission areas with over 7,000 offices throughout the United
States. For fiscal year 2004, its proposed budget is $74 billion, of which
a little over $2 billion is for information technology (IT) spending.
The Office of the Chief Information Officer (OCIO) is responsible for
establishing, implementing, and overseeing a departmentwide information
security program, while the component agencies are responsible for the
day-to-day management of information security for their mission-support
systems. OCIO provides policy guidance, leadership, and coordination for
the department's information management, technology investment, and cyber
security activities in support of delivering USDA's program. OCIO also
operates the National Information Technology Center (NITC), which is a
centralized computing facility providing applications and technical
support to USDA agencies, and the Telecommunications Services and
Operations (TSO) organization, which is responsible for developing USDA
telecommunications policy and guidance and leading the design of and
migration to the department's future corporate telecommunications network.
TSO also manages the current network and provides local telecommunications
and computer support services throughout Washington D.C. The Office of
Cyber Security, within OCIO, works with the CIO to develop and implement
cyber security policies and standards. Its functions include analyzing
agency risk assessments, monitoring system vulnerabilities, monitoring
agency compliance with departmental policies, and establishing and
maintaining a cyber security training and awareness program.
IT resources are essential to the success of the department's mission. To
efficiently fulfill its agricultural responsibilities, USDA relies
extensively on interconnected computer systems to perform various
functions, such as issuing billions of dollars in payroll and loan
disbursements, supplying market-sensitive data on commodities to the
agricultural economy, and managing other critical departmental programs.
USDA also houses and processes all types of sensitive data, including
information relating to the privacy of U.S. citizens, payroll and
financial transactions, proprietary information, and mission-critical
data. For example:
o Rural Development's financial programs support such essential public
facilities and services as water and sewer systems, housing, health
clinics, emergency service facilities, and electric and telephone service.
It promotes economic development by supporting loans to businesses through
banks and community-managed lending pools. In addition, it
offers technical assistance and information to help start agricultural and
other cooperatives and improve the effectiveness of their member services,
as well as providing technical assistance to help communities undertake
community empowerment programs.
o The Farm Service Agency is responsible for the well-being of American
agriculture, the environment, and the American public through efficient
and equitably administering of farm commodity programs; farm ownership,
operating, and emergency loans; conservation and environmental programs;
emergency and disaster assistance; and domestic and international food
assistance and international export credit programs.
o The Agricultural Marketing Service administers programs that facilitate
the efficient, fair marketing of U.S. agricultural products, including
food, fiber, and specialty crops. Its programs promote a strategic
marketing perspective that adapts product and marketing practices and
technologies to current issues.
o The National Agricultural Statistics Service (NASS) conducts hundreds
of surveys and prepares reports covering virtually every facet of U.S.
agriculture-production and supplies of food and fiber, prices paid and
received by farmers, farm labor and wages, and farm aspects of the
industry. NASS regularly surveys thousands of operators of farms, ranches,
and agribusinesses who provide information on a confidential basis. The
statistical data provided by NASS are essential to both the public and
private sectors for making effective policy, production, and marketing
decisions on a wide range of agricultural commodities. Data for certain
commodities are particularly sensitive due to their potential impact on
the futures market prices.
Information security is a critical consideration for any organization that
depends on information systems and networks to carry out its mission or
business. The dramatic expansion in computer interconnectivity and the
rapid increase in the use of the Internet are changing the way our
government, the nation, and much of the world communicate and conduct
business. Without proper safeguards, these changes pose enormous risks
that make it easier for individuals and groups with malicious intent to
intrude into inadequately protected systems and use this access to obtain
sensitive information, commit fraud, disrupt operations, or launch attacks
against other computer systems and networks.
We have reported information security as a governmentwide high-risk area
since February 1997.1 Our previous reports, and those of agency inspectors
general, describe persistent information security weaknesses that place a
variety of federal operations, including those at USDA, at risk of
disruption, fraud, and inappropriate disclosure. In August 2000, we
recommended2 that USDA (1) develop and document a strategy for improving
information security; (2) provide sufficient resources and hold the OCIO
accountable for implementing the strategy, as well as providing quarterly
status reports; and (3) report information security as a material internal
control weakness under the Federal Managers' Financial Integrity Act.
According to OCIO, USDA has taken actions to address these
recommendations.
Congress and the executive branch have taken action to address the risks
associated with persistent information security weaknesses. In December
2002, the Federal Information Security Management Act (FISMA), which is
intended to strengthen information security, was enacted as Title III of
the E-Government Act of 2002.3 In addition, the administration undertook
other important actions to improve information security, such as
integrating information security into the President's Management Agenda
Scorecard. Moreover, the Office of Management and Budget (OMB) and the
National Institute of Standards and Technology (NIST) have issued security
guidance to agencies.
Objectives, Scope, and The objective of our review was to determine the
effectiveness of USDA's information security controls. These controls
affect the security and
Methodology reliability of sensitive data, including personnel, customer
accounts, and financial information. Our evaluation was based on (1) our
Federal Information System Controls Audit Manual, which contains guidance
for reviewing information system controls that affect the integrity,
confidentiality, and availability of computerized data; (2) previous USDA
1See, for example, 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).
2U.S. General Accounting Office, Information Security: USDA Needs to
Implement Its Departmentwide Information Security Plan, GAO/AIMD-00-217
(Washington, D.C.: Aug. 10, 2000).
3Federal Information Security Management Act of 2002, Title III,
E-Government Act of 2002, P.L. 107-347 (Dec. 17, 2002).
Office of Inspector General (OIG) reports; and (3) our May 1998 report on
security management best practices4 at leading organizations, which
identifies key elements of an effective information security program.
Specifically, we evaluated information system controls intended to
o protect data and software from unauthorized access;
o prevent the introduction of unauthorized changes to application and
system software;
o provide segregation of duties involving application programming, system
programming, computer operations, information security, and quality
assurance;
o ensure recovery of computer processing operations in case of disaster
or other unexpected interruption; and
o ensure an adequate information security management program.
To evaluate these controls, we identified and reviewed pertinent USDA
security policies and procedures documentation, conducted vulnerability
testing and assessments of systems from both inside the USDA network and
from a remote location through the Internet to assess USDA's efforts in
minimizing the risk of unauthorized access, and held discussions with
staff to determine if information system general controls were in place,
adequately designed, and operating effectively. In addition, we
coordinated our efforts with the OIG to take advantage of its prior work
in this area.
We performed our review at two component agencies, four field offices, and
other offices within the OCIO organization. We also performed
vulnerability testing and assessments of three additional agencies'
servers5 that were physically located at one of the offices within the
OCIO organization. Our review was performed from February 2003 through
October 2003 in accordance with U.S. generally accepted government
auditing standards.
4U.S. General Accounting Office, Information Security Management: Learning
from Leading Organizations, GAO/AIMD-98-68 (Washington, D.C.: May 1,
1998).
5A server is a computer on a network that manages network resources, such
as storing files, managing printers, managing network traffic, or
processing database queries.
Serious Information Security Weaknesses Exist at USDA
Significant, pervasive information security control weaknesses exist at
USDA. Serious access control weaknesses included not adequately protecting
network boundaries, sufficiently controlling network access, appropriately
limiting mainframe access, or fully implementing a comprehensive program
to monitor access activity. In addition to access controls, weaknesses
existed in other control areas such as physical security, personnel
controls, system software, application change control, and service
continuity. As a result, sensitive data-including information relating to
the privacy of U.S. citizens, payroll and financial transactions,
proprietary information, agricultural production and marketing estimates,
and other mission critical data-are at increased risk of unauthorized
disclosure, modification, or loss, possibly without being detected. A key
reason for USDA's weaknesses is that it has not yet fully implemented a
comprehensive security management program.
Access to Sensitive Data and Programs Not Adequately Controlled
A basic management control objective for any organization is to protect
data supporting its critical operations from unauthorized access, which
could lead to improper modifications, disclosure, or deletion. The network
architecture, including network boundary controls,6 should support a
secure operating environment, and network access controls should be
established to restrict access to networks and systems to only authorized
users. Organizations can protect critical information by granting
employees the 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. Effective access controls
also include a program to monitor the access activities of the network and
mainframe systems.
USDA's network boundary controls do not provide sufficient protection, and
network and mainframe access controls were inadequate. Also, the increased
risks created by the access control problems were further heightened
because USDA agencies had not yet established a comprehensive program for
monitoring user access.
6Network boundary protection defines a logical or physical boundary around
a set of information resources and implementing measures to prevent
unauthorized information exchange across the boundary in either direction.
Firewall devices represent the most common boundary protection technology.
Network Boundary Not Secure Networks are series of interconnected devices
and software that allow individuals to share data and computer programs.
Because sensitive programs and data are stored on and transmitted along
networks, effectively securing networks is essential for protecting
computing resources and data from unauthorized access, manipulation, and
use. Organizations can secure their networks, in part, by limiting the
services that are available on the network and by installing and
configuring network devices that permit authorized network service
requests and deny unauthorized requests. Network services consist of
protocols for transmitting data between computers. Network devices include
(1) firewalls designed to prevent unauthorized access into the network,
(2) routers that filter and forward data along the network, (3) switches
that filter and forward information among parts of a network, and (4)
servers that host applications and data. Insecurely configured network
services and devices can make a system vulnerable to internal or external
threats, such as hackers, cyber-terrorist groups and denial-of-service
attacks.7 Since networks provide the entry point for access to electronic
information assets, failure to secure them increases the risk of
unauthorized use of sensitive data and systems.
USDA's network does not provide a secure operating environment. USDA owns
and uses a large public Internet address range to support its customers.
While USDA established a restrictive policy to protect its agencies'
internal networks from the Internet by using firewalls, its current
network boundary controls are not configured in accordance with its
security policy and do not provide adequate protection. Without a secure
network boundary, USDA is at increased risk of system compromise that
could include unauthorized access to sensitive data, disruption of
service, and denial of service. USDA is in the process of redesigning its
network architecture to create a more secure operating environment by
strengthening network boundary controls.
Network Access Controls Not Network access controls are key to ensuring
that only authorized
Sufficient individuals gain access to sensitive and critical agency data.
Effective network access controls, such as passwords, should be
established to authenticate authorized users who access the network from
local and remote locations. In addition, network controls should provide
safeguards
7A denial-of-service attack is an attack on a network that sends a flood
of useless traffic that prevents legitimate use of the network.
to ensure that system software is adequately configured to prevent users
from bypassing network access controls or causing network failures.
USDA did not always securely control network services or configure devices
to prevent unauthorized access to and ensure the integrity of computer
systems operating on its networks. USDA's OCIO provided agencies with
guidance to mitigate potential vulnerabilities on network servers.
However, we identified weaknesses in the way USDA agencies managed remote
access, configured certain servers, managed passwords, assigned user
rights and permissions, and enabled unnecessary network services, as the
following examples demonstrate.
o Default vendor accounts and passwords were being used, including for a
dial-in modem account at one agency, for a server for router management at
another agency, and for a database server at a third agency. Information
on default vendor accounts and passwords is documented in vendor-supplied
manuals and is widely available on the Internet to anyone, including
hackers. With this access, a malicious user could seriously disable or
disrupt network operations, or simply use it as a means to attack other
internal systems.
o Certain servers were configured to allow unauthorized users to connect
to the network without entering a valid user ID and password combination
and obtain access to system information describing the network
environment, including user IDs and password information.
o Password settings were inadequate. OCIO provided policies and guidance
pertaining to password settings; however, USDA agencies did not always
comply with USDA policies and guidance. For example, in some cases,
password length was set to 0, meaning that a password is not required.
Also, some servers did not allow for an adequate account lockout period
after unsuccessful logon attempts, and servers were not configured to
enforce the use of complex passwords. Further, we identified instances in
which passwords were being shared among personnel, which resulted in
USDA's losing accountability over individual IDs. Such weaknesses increase
the risk that passwords may be compromised and unauthorized access to
USDA's networks gained.
o Although USDA guidance suggests that users be assigned to system access
groups on the basis of least privilege, or "need to know," users were
assigned to groups that allowed more access than needed to perform their
job. In some instances, this access violated the principle
Mainframe Access Not Appropriately Limited
of segregation of duties, in which duties are split among two or more
individuals or groups to diminish the likelihood that errors and wrongful
acts will go undetected.
o Potentially dangerous services, including some allowing users to
remotely execute commands, were available on several network systems.
Because of the availability of these services, a greater risk exists that
an unauthorized user could exploit them to gain high-level access to the
system and applications, obtain information about the system, or deny
system services.
o Agencies did not always update software to alleviate potential
vulnerabilities or detect viruses. Certain servers were vulnerable to
known system exploits because patches8 had not been installed in a timely
manner. Some of these exploits had been reported in mid-2002, but at the
time of our review, agencies had yet to apply available patches to correct
the weaknesses. In our September 2003 testimony,9 we noted that, according
to the CERT(R) Coordination Center,10 about 95 percent of all network
intrusions could be avoided by keeping systems up to date with appropriate
patches. Further, although USDA guidance recommends the use of antivirus
software on servers, certain servers that we reviewed were not running it.
By not running antivirus software, the department is at increased risk of
having a virus infect its systems and potentially disabling or disrupting
hardware and data.
Weak network access controls increase the risk of system compromise, such
as unauthorized access to and manipulation of sensitive system data,
disruption of services, and denial of service.
Effective mainframe access controls should be designed to prevent, limit,
and detect access to computer programs and data on the mainframe. These
8A patch is a piece of software code that is inserted in a program to
temporarily correct a defect. Patches are developed and released by
software vendors when vulnerabilities are discovered.
9U.S. General Accounting Office, Information Security: Effective Patch
Management is Critical to Mitigating Software Vulnerabilities,
GAO-03-1138T (Washington, D.C.: Sept. 10, 2003).
10The CERT/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.
controls include assigning users access rights and permissions,
appropriately configuring the security software for granting access, and
ensuring that access remains appropriate on the basis of job
responsibilities.
Although USDA restricted access to certain data and programs on its
mainframe, we identified instances in which access to sensitive data and
programs had not been sufficiently restricted. For example,
o Access to sensitive data and programs was not adequately controlled. At
one agency, 143 user IDs had been granted read access to very sensitive
data although some of them did not need this access to perform their jobs;
11 of the 143 also had the capability to modify the data. In addition,
users such as secretaries and server administrators could modify system
and application programs-a level of access that is typically not allowed
for their job functions. Moreover, 69 mainframe users had been granted the
ability to read all data (i.e., data of all organizations that use the
mainframe).
o Certain users had unnecessary access to a powerful mainframe privilege.
This privilege is intended for routine system management activities, such
as backup and disk management. However, USDA had not restricted its use to
its intended purpose. Ten users had been granted this privilege, allowing
them to read, copy, edit, or delete any data and programs on the
mainframe. Further, since its use does not create an audit trail, their
activities would not be detected.
o Many users had the capability to read powerful IDs and passwords stored
on the mainframe. USDA's mainframe security standards require that
logons/passwords not be stored on systems; however, we observed IDs and
passwords stored in files we selected. All users (approximately 17,000) on
the system could view a very powerful ID and password that is used to
support mainframe operations and has full access to all files stored on
tape. At least 1,200 user IDs could read Job Control Language files
containing network IDs and passwords, and at least 800 user IDs had the
capability to read files containing database IDs and passwords.
o Password settings and software access rules were not adequate. USDA's
mainframe security standards set minimum requirements for passwords.
However, the mainframe configuration at the time of our review did not
comply with these standards, allowing simple passwords that did not
necessarily require periodic change. As a result, passwords
might be easily guessed. Additionally, because of the way that access
rules are created in the mainframe security software, individuals may be
unintentionally granted access to datasets.
One reason for USDA's mainframe access vulnerabilities was that access
granted was not always periodically reviewed to ensure that it remained
appropriate. Although USDA policy requires that users' access be annually
reviewed to ensure that it remains appropriate, the policy was not always
being followed or, in some cases, was not effective. For example, at one
agency, there was no procedure in place to review access to ensure that it
remained appropriate on the basis of job responsibilities. At another,
although a procedure had been implemented to periodically review access
granted, it was not working as intended; we identified instances in which
access was reviewed, yet individuals had more access than needed to
perform their jobs.
Comprehensive Monitoring Not The risks created by these access control
weaknesses were heightened
Yet Fully Implemented because USDA had not fully established a
comprehensive program to monitor user access. A successfully implemented
and properly functioning monitoring program is essential to ensure that
unauthorized attempts to access critical program and data are detected and
investigated. Such a program would include routinely reviewing user access
activity and investigating failed attempts to access sensitive data and
resources, as well as unusual and suspicious patterns of successful access
to sensitive data and resources. These actions are critical for ensuring
that improper access to sensitive information is detected.
To effectively monitor user access, it is critical that logs of user
activity be maintained for all critical system processing activities. This
includes collecting and monitoring access activities on all critical
systems, including mainframes, network servers, and routers. Because the
security information collected is likely to be voluminous, the most
effective monitoring techniques selectively target specific actions. These
efforts should include provisions to identify unusual activities, such as
changes to sensitive system files, updates to security files, or access to
data not required to perform a user's job function. Further, a
comprehensive monitoring program should include an intrusion-detection
system (IDS) to automatically log unusual activity and provide timely
alerts and effective responses.
While USDA had some monitoring efforts in place, it did not consistently
audit or monitor computer system activity, as illustrated by the
following:
o Logging features were not enabled for certain sensitive mainframe data
files, as well as for numerous servers. As a consequence, adverse access
events that could result in disclosure or modification of data may not be
recorded or detected.
o Inappropriate mainframe configuration settings allowed audit logs to be
modified, potentially without detection.
o In some cases, USDA agencies did not adequately review audit
information or monitor system activity. Where audit logs existed, they
were not always reviewed for certain servers to determine if violations
had occurred. For example, according to OIG, one organization did not have
procedures in place outlining which logs or reports to review.
o USDA had implemented IDSs on its wide area network, and some agencies
implemented their own IDSs for their internal networks and servers.
However, at the time of our review, one of the agencies had not yet
implemented IDSs. Without full implementation of such systems, USDA
reduces its ability to identify and investigate unusual or suspicious
access to sensitive information in a timely manner.
As a result, increased risk exists that USDA may not detect unauthorized
system activity or determine which users are responsible.
Other Information System Controls Were Ineffective
Insufficient Physical Security Controls
In addition to information system access controls, other important
controls should be in place to ensure the integrity and reliability of an
organization's data. These controls include policies, procedures, and
control techniques to physically protect computer resources, restrict
access to sensitive information, maintain system software integrity,
prevent unauthorized changes to application programs, and ensure that
computer processing operations continue in case of disaster. However, the
department (1) had insufficient physical security controls, (2) had not
performed appropriate background investigations, (3) had inadequate system
software controls, (4) did not always have application change controls in
place, and (5) had incomplete service continuity planning.
Physical security controls are important for protecting computer
facilities 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 in which they are housed and
periodically reviewing access granted to ensure that it continues to be
appropriate based on criteria established for granting such access. At
USDA, physical access control measures (such as guards, badges, and locks,
used alone or in combination) are vital to protecting its computing
resources and the sensitive data they process from external and internal
threats.
USDA established a departmentwide policy for physically protecting its
computing resources. The policy includes provisions for authorizing access
on the basis of business need, periodically reviewing access, and securing
space for computing resources by means of locks or electronic access
systems. One organization used biometric systems to control access to
sensitive areas. Another agency established procedures for "locking down"
certain sections of its facility during sensitive deliberations.
Although USDA agencies took actions to comply with USDA's physical
security requirements, certain weaknesses reduced their effectiveness in
protecting and controlling physical access to sensitive work areas, as
illustrated by the following examples:
o Agencies did not always ensure that access to sensitive computing
resources had been granted to only those who needed it to perform their
jobs. One agency had not developed a policy that included criteria for
granting access to sensitive areas such as server rooms, or for
periodically reviewing individual access to ensure whether it remained
appropriate. We identified instances in which access cards remained active
for contractors who no longer needed access to sensitive areas, and two
lost cards had not been removed from the access system.
o Sensitive computing resources were not always secured. At one agency,
we observed server rooms that were unlocked, including one that had a door
without a lock. At another agency, server rooms in two of the four field
offices that we visited were unlocked.
As a result, increased risk exists that unauthorized individuals could
gain access to sensitive computing resources and data and inadvertently or
deliberately misuse or destroy them.
Background Investigations Not According to OMB A-130,11 it has long been
recognized that the greatest
Performed harm has come from authorized individuals engaged in improper
activities, whether intentional or accidental. Personnel controls (such as
screening individuals in positions of trust) supplement other technical,
operational, and management controls, particularly where the risk and
magnitude of harm is high. NIST suggests first determining the sensitivity
of particular positions based on such factors as the type and degree of
harm that the individual can cause through misuse of the computer system,
(e.g., disclosure of private information, interruption of critical
processing, computer fraud), as well as more traditional factors such as
access to classified information and fiduciary responsibilities.
Background screenings (i.e., investigations) help determine whether a
particular individual is suitable for a given position by attempting to
ascertain the person's trustworthiness and appropriateness for the
position. The exact type of screening that takes place depends upon the
sensitivity of the position and applicable agency implementing
regulations.
Adequate personnel controls were not always in place at USDA. USDA policy
requires that agencies be responsible for determining the sensitivity of
their positions and for ensuring that employees have the appropriate
background investigation commensurate with the position. Nevertheless, one
agency had not determined the sensitivity of positions and had conducted
only a minimal agency check for each employee. Due to the sensitive
information maintained by this agency and the level of system access
granted to certain employees, there were instances in which individuals
should have a higher-level background investigation. By granting
individuals access to sensitive information or critical systems without
background investigations, agencies may be at increased risk of having
individuals who could cause damage or realize personal gain.
System Software Controls Not System software controls, which limit and
monitor access to the powerful Adequate 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 includes (1) configuring system software to protect
against security vulnerabilities, (2) periodically reviewing programs in
sensitive software libraries to identify potential security weaknesses,
and (3) establishing a system change management
11Office of Management and Budget, Circular A-130, Appendix III, Security
of Federal Automated Information Resources (Nov. 28, 2000).
process that ensures that only authorized and fully tested system software
is placed in operation. We and the OIG identified instances in which
current system software controls were not always adequate. For example:
o A sensitive program was configured in a way that potentially affects
system integrity. As a result, an unauthorized user could introduce
incorrect or malicious code. This configuration could also affect the
stability and reliability of the operating system.
o Sensitive software libraries, which have the authority to perform
sensitive functions that can circumvent security controls, contained
duplicate 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. Also, USDA
had not established a process to periodically review programs in sensitive
libraries for security weaknesses, such as programs with duplicate names.
Until it establishes such a program, USDA will not have adequate assurance
that other security controls cannot be bypassed.
o According to OIG, the system software change management process had
been strengthened as of October 2003 and continues to improve. However,
OIG noted that approval, testing, and implementation documentation was not
always maintained. Consequently, USDA faces increased risks of unintended
operational problems caused by programming errors or the deliberate
execution of unauthorized programs that could compromise security
controls.
Application Change Controls Not Also important for an organization's
information security is ensuring that
Always in Place only authorized and fully tested software is placed in
operation. To ensure that software changes are needed, work as intended,
and do not result in the loss of data and program integrity, such changes
should be documented, authorized, tested, and independently reviewed.
Before software is moved into the production environment, actual software
changes should be compared to the approved request to ensure that only
approved changes have been made. Further, access to software libraries
should be protected, and movement among libraries (i.e., from a
development environment to a production environment) should be controlled
by an organization independent of both the user and programming staff.
Without proper controls, there is a risk that software could be
inadvertently or deliberately modified without authorization, or
that other processing irregularities or malicious code could be introduced
into the production environment.
Although USDA policy requires that agencies develop plans and procedures
to ensure that any changes made to systems are reviewed and approved by
management, one agency lacked documented policies and procedures to ensure
that application software modifications were properly authorized, tested,
and approved. Although it had an ad hoc process in place for testing the
functionality of application changes before putting them into the
production environment, there was no process for authorizing changes, no
procedures for documenting tests performed, and no review to ensure that
only authorized changes were made to the application software.
Further, several USDA agencies had not adequately protected their software
libraries. Although each agency had designated an independent group to
control movement between the development and production environments,
security software controlling access had been configured to grant similar
privileges to individuals who did not need it to perform their jobs.
Service Continuity Planning An organization must take steps to ensure that
it is adequately prepared to
Incomplete cope with the loss of operational capability due to earthquake,
fire, accident, sabotage, or any other disruption. An essential element in
preparing for such catastrophes is an up-to-date, detailed, and fully
tested service continuity plan covering all key computer operations and
including plans for business continuity. 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 if a
disaster occurs. To ensure that it is complete and fully understood by all
key staff, the service continuity plan should be tested, including
surprise tests, and the test plans and results documented to provide a
basis for improvement. If service continuity controls are inadequate, even
relatively minor interruptions can result in lost or incorrectly processed
data, which can cause financial losses, expensive recovery efforts, and
inaccurate or incomplete missioncritical information.
Weaknesses in USDA's service continuity controls limit its ability to
restore or continue data processing service after a service disruption or
an emergency occurs. For example:
o Although departmentwide guidance stresses that contingency planning is
an integral part of the USDA information security program, agencies
had not developed contingency plans for all operations. One agency had not
developed service continuity plans; another agency's plan was outdated;
and a third agency had not developed a service continuity plan for its
network environment.
o Although a service continuity plan existed and had been periodically
tested for the mainframe environment, there had been no unannounced tests.
All previous tests had been planned, with participants fully aware of the
disaster recovery scenario. In an actual disaster, of course, there is
usually little or no warning.
o Contingency planning is a departmentwide weakness. In September 2003,
the USDA OIG reported that eight of ten agencies that it reviewed had not
prepared complete, executable disaster recovery plans.12 Further, in the
department's October 2003 FISMA report, USDA stated that only about 60
percent of its systems had a contingency plan, and about 30 percent had
tested contingency plans.13
As a result, USDA has diminished assurance that in case of an unexpected
interruption, it will be able to protect or recover essential information
and critical business processes.
Initiatives Are Under Way, but a Comprehensive Security Management Program
Is Not Yet Fully Implemented
USDA has recognized the need to improve information security throughout
the department, including the components that we reviewed, and has
initiatives under way. It identified information security as a material
weakness in its fiscal year 2002 Federal Managers' Financial Integrity Act
report and noted corrective actions needed to address such issues as
physical and logical access, as well as service continuity. USDA also
acknowledged the weaknesses that we found, developed action plans to
correct them, and, in some cases, took immediate action. OIG, in its
fiscal year 2002 consolidated financial statement audit, also reported
information security as a material weakness. In its report, OIG stated
that although most USDA agencies have taken steps to improve their
security programs,
12U.S. Department of Agriculture, Office of Inspector General, Audit
Report: Fiscal Year 2003 Federal Information Security Management Act
Report, Report No. 50099-52-FM (Washington, D.C.: Sept. 24, 2003).
13U.S. Department of Agriculture, Office of the Chief Information Officer,
Federal Information Security Management Act-FY2003 Information Systems
Security Program Review (Washington, D.C.: October 2003).
it identified widespread serious weaknesses. Its audits continue to
disclose that most agencies did not have adequate physical and logical
access controls in place over their IT resources.
A key reason for USDA's weaknesses in information system controls is that
it has not yet fully developed and implemented a comprehensive security
management program to ensure that effective controls are established and
maintained and that information security receives significant management
attention. Our May 1998 study of security management best practices14
determined that a comprehensive information security management program is
essential to ensuring that information system controls work effectively on
a continuing basis. The recently enacted FISMA,15 consistent with our
study, describes certain key elements of a comprehensive information
security management program. These elements include
o a senior agency information security officer with the mission and
resources to ensure compliance;
o periodic assessments of the risk and magnitude of the harm that could
result from the unauthorized access, use, disclosure, disruption,
modification, or destruction of information and information systems;
o policies and procedures that (1) are based on risk assessments, (2)
costeffectively reduce risks, (3) ensure that information security is
addressed throughout the life cycle of each system, and (4) ensure
compliance with applicable requirements;
o security awareness training to inform personnel, including contractors
and other users of information systems, of information security risks and
their responsibilities in complying with agency policies and procedures;
and
o at least annual testing and evaluation of the effectiveness of
information security policies, procedures, and practices relating to
management,
14GAO/AIMD-98-68.
15FISMA requires each agency to develop, document, and implement an
agencywide information security program to provide information security
for the information and systems that support the operations and assets of
the agency, using a risk-based approach to information security
management.
operational, and technical controls of every major information system
identified in agencies' inventories.
Although USDA has various initiatives under way, key elements of a
comprehensive security management program are not yet fully implemented to
the extent that they are effective. In recent reports, both OCIO and OIG
have identified deficiencies in USDA's information security management
program.
Designating an Information One key element of effective information
security management is
Security Officer designating an information security officer as part of
establishing a central security group with clearly defined roles and
responsibilities. This group provides overall security policy and
guidance, along with oversight to ensure compliance with established
policies and procedures; further, it reviews the effectiveness of the
security environment. The central security group often is supplemented by
individual security staff designated to assist in implementing and
managing the organization's security program. To ensure the effectiveness
of the security program, an organization should establish clearly defined
roles and responsibilities for all security staff and develop coordination
responsibilities between individual security staff and central security.
USDA established a centralized security management structure, including a
senior information security officer. In February 2000, USDA appointed an
Associate CIO for Cyber Security to provide security expertise and
oversight in establishing a new comprehensive information security program
at the department. Also, USDA departmental regulations require that each
agency assign an Information System Security Program Manager (ISSPM) to
implement policies related to information security. The components we
reviewed had established these positions and defined their roles and
responsibilities.
Although USDA had this structure in place, in some cases it was not fully
effective. In its September 2003 FISMA report, OIG stated that agency
security personnel have not commonly been given the authority needed to
effectively implement and manage their agency's security programs.
Further, it reported a lack of agency management involvement and
commitment in complying with federal information security guidelines. In
its most recent FISMA report, OCIO agreed with the OIG's conclusion that
lack of management involvement has been a key factor in agencies' poor
security performance. This was also the case at one of the components that
we reviewed; ISSPMs questioned whether they had the authority and
management support to enforce compliance with security policies and
procedures.
Assessing Risks Identifying and assessing information security risks are
essential steps in determining what controls are required and what level
of resources should be expended on controls. Moreover, by increasing
awareness of risks, these assessments generate support for the adopted
policies and controls, which helps ensure that the policies and controls
operate as intended.
USDA Cyber Security established policy that requires agencies to use a
structured approach to assessing risks. This policy requires that a risk
assessment of an agency's security program be conducted annually, and that
a vulnerability assessment be completed for information systems whenever a
major change is made to the system, or at least once every 3 years. To
assist in accomplishing these assessments, Cyber Security also developed
detailed checklists for various computing platforms (e.g., mainframe,
Unix, Windows, etc.) that prescribe recommended secure system settings.
However, agency risk assessments had not been completed. OCIO reported
that about 78 percent of its systems departmentwide had completed risk
assessments. However, three agencies, including one that we reviewed, had
not completed any of their risk assessments for 46 systems. The lack of
risk assessments indicates that USDA had not done all that it was required
to do to understand and manage risks to its systems. Inadequately
assessing risk can lead to implementing inadequate or inappropriate
security controls that might not address the system's true risks and to
costly efforts to subsequently implement effective controls.
Establishing and Implementing Another key element of an effective
information security program, as
Policies identified during our study of information security management
practices at leading organizations, is establishing and implementing
appropriate policies and related controls. Establishing or documenting
security policies is important because they are the primary mechanism by
which management communicates its views and requirements; these policies
also serve as the basis for adopting specific procedures and technical
controls. In addition, agencies need to take the actions necessary to
effectively implement or execute these procedures and controls. Otherwise,
agency systems and information will not receive the protection provided by
the security policies and controls.
The department has made some progress in developing information security
policies and procedures. During fiscal year 2003, Cyber Security issued 16
additional information security guidance and policy statements. These
statements provide USDA agencies with guidance on topics such as risk
assessment methodology, encryption, remote access, and disaster recovery.
However, many of these statements remain in draft, or interim guidance,
because the department has not yet approved them.
OMB A-130 and department policy require USDA agencies to develop and
implement information security plans for major applications and general
support systems. These plans should address policies and procedures for
achieving management, operational, and technical controls. According to
OCIO, up-to-date security plans were in place for three-fourths of the
department's systems. However, OIG reported that none of the agencies that
it reviewed in fiscal year 2003 had prepared all required security plans
or ensured that existing plans adequately addressed OMB A-130
requirements. While some plans had been developed at the agencies we
reviewed, not all were complete. One agency had an overall plan, but had
not completed plans for its general support systems or major applications.
At the time of our review, the other agencies were in the process of
completing their plans.
As noted throughout this report, some agencies lacked other policies and
procedures, such as for periodically reviewing system access, granting
physical access, and performing application change control.
Promoting Security Awareness Another important element of an information
security program involves promoting awareness and providing required
training so that users understand the risks and their role in implementing
related policies and controls to mitigate those risks. Computer intrusions
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-to-day 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, integrity,
and availability. Federal information security laws mandate that all
federal employees and contractors involved with the management, use, or
operation of federal computer systems be provided periodic training in
information security awareness and accepted information security practice.
The USDA components that we reviewed had generally established information
security awareness programs for their employees and contractors. These
programs included distributing security awareness bulletins and brochures;
creating information security Web pages; and, at one agency, having
employees sign a confidentiality statement that included acknowledgement
of reading and understanding information security expectations. Agencies
were also in the process of obtaining access to a Web-based security
awareness training package that would also track employee participation.
Nevertheless, the OIG reported that agencies still lack the controls to
ensure that all their employees receive security awareness training. In
October 2003, USDA reported that only 59 percent of its employees had
received security training in fiscal year 2003.
Testing and Evaluating the The final key element of an information
security program is ongoing testing
Effectiveness of Controls and evaluation to ensure that systems are in
compliance with policies, and that policies and controls are both
appropriate and effective. This type of oversight is a fundamental element
because it demonstrates management's commitment to the security program,
reminds employees of their roles and responsibilities, and identifies and
mitigates areas of noncompliance and ineffectiveness. Although control
tests and evaluations may encourage compliance with security policies, the
full benefits are not achieved unless the results improve the security
program. Analyzing the results of monitoring efforts, as well as security
reviews performed by external audit organizations, provides security
specialists and business managers with a means of identifying new problem
areas, reassessing the appropriateness of existing controls, and
identifying the need for new controls.
USDA had some efforts under way to test and evaluate controls. During
fiscal year 2003, Cyber Security reviewed compliance at five sites. It
also contracted for testing of USDA's network. Agencies that we reviewed
had also undertaken limited ongoing testing, such as periodically scanning
their networks and servers. USDA's OCIO also initiated a formal IT
certification and accreditation16 program, including a methodology based
on NIST
16Certification is the comprehensive evaluation of the management,
operational, and technical security controls in an information system to
determine the effectiveness of these controls and identify existing
vulnerabilities. Accreditation is the official management decision to
authorize operation of an information system. This authorization
explicitly accepts the risk remaining after the implementation of an
agreed upon set of security controls.
guidance and contracting support for assistance with certifying and
accrediting the department's major systems.
However, further efforts are needed to fully implement an ongoing program
of tests and evaluations. The department reported that security controls
were tested and evaluated for just over one-third of its systems in the
past year. In addition, although USDA policy requires that certification
and accreditation of systems should occur at least every 3 years or before
a significant change in processing, the department reported in October
2003 that only about 16 percent of its systems had been certified and
accredited. Further, none of the components that we reviewed had completed
certification and accreditation for any of their systems. An effective
program of ongoing tests and evaluations can be used to identify and
correct information security weaknesses such as those discussed in this
report.
Based on the results of tests and evaluations that have been conducted,
agencies have developed corrective action plans (i.e., Plans of Actions
and Milestones-POA&Ms), as required by FISMA. However, these plans may not
be effective. In its latest FISMA report, OIG stated that its review of
POA&Ms at the agency level disclosed that agencies have not prepared
POA&Ms for individual systems, and the information they contain is
sometimes vague and unreliable. USDA's OCIO also reported that it is
unable to tie specific agency POA&Ms to identified weaknesses. Without
adequate corrective action plans, the results of tests and evaluations may
not be effectively used to improve the security program and correct
identified weaknesses.
Conclusions Serious information security weaknesses exist at USDA that
place sensitive information at risk of disclosure, modification, or loss,
and operations at risk of disruption. Specifically, USDA has not
sufficiently secured its network, adequately limited mainframe access, or
fully implemented a program to monitor access activity. Weaknesses in
physical security, personnel controls, system and application software,
and service continuity increase the level of risk.
A key reason for USDA's weaknesses in information system controls is that
it has not yet fully developed and implemented a comprehensive security
management program to ensure that effective controls are established and
maintained, and that information security receives adequate attention.
Effective implementation of such a program provides for periodically
assessing risks, establishing appropriate policies and procedures,
promoting security awareness, and establishing an ongoing program of tests
and evaluations of the effectiveness of policies and controls to ensure
that they remain appropriate and accomplish their intended purpose.
Although USDA has various initiatives under way to address these areas,
further efforts are needed to address its information security weaknesses.
Recommendations for Executive Action
To establish effective information security, we recommend that the
Secretary of Agriculture direct the CIO to address the following action:
o Fully implement a comprehensive security management program.
Specifically, this would include (1) ensuring that security management
positions have the authority and cooperation of agency management to
effectively implement and manage security programs, (2) completing
periodic risk assessments for systems, (3) completing information security
plans and establishing policies and procedures on the basis of identified
risks, (4) ensuring that employees complete security awareness training,
(5) implementing ongoing tests and evaluations of controls, (6) completing
system certifications and accreditations, and (7) developing corrective
action plans that clearly tie to identified weaknesses.
We are also making recommendations in a separate report designated for
"Limited Official Use Only." These recommendations address actions needed
to correct the specific information security weaknesses related to the
network boundary, network access, mainframe access, physical security,
background investigations, system software, application change controls,
and service continuity.
Agency Comments In providing written comments on a draft of this report,
USDA's CIO concurred with our recommendations and stated that the
department remains committed to improving information security. He further
stated that USDA plans to fully implement a comprehensive security
management program as well as correct the specific information security
weaknesses identified. USDA's comments are reprinted in full in appendix
I.
As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from
the
report date. At that time, we will send copies to congressional committees
with jurisdiction over agriculture and information security programs, the
Secretary of Agriculture, the USDA CIO, the USDA Inspector General, and
other interested parties. We also will make copies available to others
upon
request.
In addition, the report will be available at no charge on the GAO Web site
at
www.gao.gov. If you have any questions, please contact me at (202) 512
3317 or Carol Langelier, Assistant Director, at (202) 512-5079. We can
also
be reached at [email protected] and [email protected], respectively. Key
contributors to this report are listed in appendix II.
Robert F. Dacey
Director, Information Security Issues
Appendix I
Comments from the Department of Agriculture
Appendix II
GAO Contact and Staff Acknowledgments
GAO Contact Carol Langelier (202) 512-5079
Staff Acknowledgments
(310184)
In addition to the individual named above, Edward Alexander, Gerald
Barnes, Nicole Carpenter, Lon Chin, West Coile, Debra Conner, Denise
Fitzpatrick, Edward Glagola, David Hayes, Jeffrey Knott, Harold Lewis,
Suzanne Lightman, Leena Mathew, Duc Ngo, Kevin Secrest, Eugene Stevens,
Rosanna Villa, Charles Vrabel, and Chris Warweg made key contributions to
this report.
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